Contact the US Army Corps of Engineers on MVP Permit

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Contact the US Army Corps of Engineers on Mountain Valley Pipeline Permit

For years, the Mountain Valley Pipeline has struggled to obtain their stream crossing permit from the US Army Corps of Engineers (USACE). First, they tried to use a basic, general permit that was not sufficient for their large-scale project. When that didn’t work, they tried to change the conditions of the general permit. That also got them into trouble, so last year they finally relented and applied for an individual permit from USACE. However, the information they supplied for that permit application was insufficient to meet the permit requirements.

Now, MVP has finally supplied the necessary information. The U.S. Army Corps of Engineers (USACE) released for public comment MVP’s proposed monitoring and restoration plans for streams and wetlands impacted by construction. However, it should come as no surprise, given their track record, that MVP’s Comprehensive Stream and Wetland Monitoring, Restoration, and Mitigation Framework is woefully insufficient.

The public has until February 25 to submit their comment. 

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US Army Corps of Engineers

Subject: Mountain Valley Pipeline’s (MVP) Mitigation Framework

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I am writing to comment on Mountain Valley Pipeline’s (MVP) Comprehensive Stream and Wetland Monitoring, Restoration, and Mitigation Framework (Framework). The Baseline Monitoring is insufficient in adequately documenting baseline conditions of impacted waterbodies. MVP conducted benthic monitoring under ideal conditions on select streams. They have data on select streams that met their conditions however they are lacking data on the majority of impacted streams. Additionally, their methodology, while accepted by WVDEP, has been criticized by EPA. The Performance Standards do not provide reasonable assurance that impacts to water resources will be properly identified. MVP provided arbitrary benchmarks to determine if the water quality shows degradation. However, those benchmarks are based on outdated methodologies that do not properly identify impairments. The Restoration Plan uses an annual monitoring event to identify whether a stream or wetland is meeting the performance standards. If they are not meeting standards, MVP will develop a remediation plan. If that plan proves ineffective, they will simply buy mitigation credits. Simply throwing money at the problem, however does not solve it. As a result, our water resources will be left damaged. For these reasons, I encourage the USACE to deny MVP’s permit.

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Contact the US Army Corps of Engineers on Mountain Valley Pipeline Permit

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Contact the US Army Corps of Engineers on Mountain Valley Pipeline Permit

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