Coated 42 inch high pressure pipe is seem at lower right, quite risky for the steep terrain of WV & VA or under rivers & streams
To: Kimberly D. Bose, Secretary, Federal Energy Regulatory Commission
Subject: Docket Number – CP21-57-000; Deny MVP’s request to amend Certificate
Appalachian Voices and our supporters, whose signatures will be submitted, respectfully request that the Federal Energy Regulatory Commission deny the Mountain Valley Pipeline’s request to amend their Certificate of Public Convenience and Necessity. There has been no supplemental environmental impact statement for the requested changes, and MVP’s request appears to be an attempt to circumvent restrictions resulting from the loss of water crossing permits, and to interfere with their own application for state-level permits.
Expanding upon their 2020 amendment request, which the Commission did not approve, MVP applies the same approach: altering plans at will, mid-construction, requesting hundreds of variances from approved permit conditions and pursuing conflicting, simultaneous paths to circumvent missing water protection permits. The company’s construction plan—and subsequent environmental impacts—continue to move further from the original, approved certificate. This newest Certificate Amendment is akin to a variance request for the entire route.
Without proper analysis, the public cannot know the severity of impacts to soil, steep slopes, streams and wetlands that would be caused by close to two hundred conventional borings. The company should not receive a blank check to arbitrarily alter construction practices along almost the entire route.
Waterways in steep terrain and with karst geology are not suitable locations for boring, and longer crossings bring additional risk. Multiple requests by Intervenors for a Supplemental Environmental Impact Statement in response to granted variances have gone unanswered by the Commission in the original Docket CP16-10. As construction potentially proceeds, the plans and execution of these plans bear less and less resemblance to what was reviewed and approved by the Commission in 2017 and used to inform other Federal and State agency decisions.
We respectfully ask that the request to amend the certificate be denied. If the FERC is seriously considering this amendment, we request that the Commission undertake a full Supplemental Environmental Impact Statement that thoroughly addresses impacts from boring and is accompanied by a 90-day public comment period.
Thank you for consideration of our comments and any additional personal comments our supporters have submitted.
Sincerely, Appalachian Voices & associates
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See also: Appalachian Voices’s petition for the MVP Certificate Amendment, Docket CP21-57
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