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The Mountain Valley
Pipeline: An Analysis of
Environmental Impacts
Prepared by: Gabrielle Gonzalez, Jacqueline Tkac, Katie...
Acknowledgements:
Dr. John Browder
All Interviewees
Thank you for helping us throughout the
duration of this project
Cover...
Table of Contents
Executive Summary..........................................................................................
P a g e | 1
I. Executive Summary
The Mountain Valley Pipeline (MVP) is a proposed 301 mile long, 42 inch wide
natural gas ...
P a g e | 2
II. Introduction
The Mountain Valley Pipeline (MVP) is a proposed, 42-inch wide shale gas
pipeline that will r...
P a g e | 3
subjects such as eminent domain, potential alternatives or modifications to reduce effects
on buildings, fence...
P a g e | 4
Districts (AFD) located in areas of MC that would be bisected by the proposed route of
the pipeline, the const...
P a g e | 5
II. The Town of Blacksburg has expressed concerns about the karst topography and
the effect the pipeline and i...
P a g e | 6
III. Problem Statement
The proposed Mountain Valley Pipeline will have potential adverse
environmental impacts...
P a g e | 7
Statement, and ends with the research and comparison of the Mountain Valley Pipeline’s
future plans, including...
P a g e | 8
V. Overview of Environmental Issues Surrounding Pipelines
Air Quality and Compressor Stations
According to MVP...
P a g e | 9
from natural gas is still greater (Ingraffea, 2013). The Intergovernmental Panel on
Climate Change (IPCC) has ...
P a g e | 10
placed along the pipeline to boost the system pressure to maintain required flow rates
(FERC, 2011). In addit...
P a g e | 11
substantial amount of emissions were observed at both operating and standby compressor
stations.
Methane cont...
P a g e | 12
activities would eventually result in violations of the health and welfare-based federal
standards (Corbett e...
P a g e | 13
emergency depressurization, high noise levels can be generated due to release of high-
pressure gases to flar...
P a g e | 14
noise monitors that frequently and continuously log data over this time period to ensure
accuracy of data. Ho...
P a g e | 15
right-of-way for the pipeline will be 125 feet wide, and the permanent right-of-way will
be 50 feet wide (MVP...
P a g e | 16
Figure 1. Forest Fragmentation, Natural Gas Production
(Source: www.marcellus-shale.us, 2012)
Habitat fragmen...
P a g e | 17
raccoons, crows, and blue jays that adapt easily to different conditions (Mulhollem,
2014). The pipeline corr...
P a g e | 18
Figure 2. Loggerhead Shrike
(Source: www.bird-friends.com, Scott Streit, 2000)
In addition to the forest and ...
P a g e | 19
Erosion and Sedimentation
Figure 3. Pipeline Construction
(Source: Marcellus-shale.us, 2011)
Although erosion...
P a g e | 20
activities that are necessary for building the pipeline like vegetation removal can increase
the soil erosion...
P a g e | 21
sedimentation, especially if the open-cut process and bore crossing techniques are used
(Johnson, 2011). The ...
P a g e | 22
releases, exposure to an accidental natural gas leak may result in asphyxiation as a result
of oxygen displac...
P a g e | 23
the pipeline protects the pipeline and its infrastructure from above ground damages,
including accidents (eit...
P a g e | 24
with one of the more extreme corroded sections located less than 200 feet away from the
Mississippi River. Th...
P a g e | 25
very likely one due to the fact that it is a gas, so light in weight, and would more than
likely escape into ...
P a g e | 26
Non-Environmental Concerns
Economic Issues
The Mountain Valley Pipeline considers the economic gains, costs a...
P a g e | 27
natural gas, coal, nuclear power, or combination thereof - will provide an adequate
solution to any parts of ...
P a g e | 28
(1929).VA. CONST. art I, § 11. Virginia’s eminent domain amendment defines public
use as the following:
That ...
P a g e | 29
Appalachian Culture and Resources
Appalachia is rich in culture and can be identified by certain types of mus...
P a g e | 30
Community and Public Engagement
Figure 4. Anti-Pipeline Advertising
(Source: Team E, 2015)
Active engagement ...
P a g e | 31
successful because of the condescending demeanor of the company towards the
community. According to an interv...
P a g e | 32
Figure 5. VA Localities Containing Karst
(Source: VA Cave Board, n.d.)
There are various degrees of karst lan...
P a g e | 33
or air can more easily migrate from void to void (USGS, 2014). This is why bedrock in
karst is referred to as...
P a g e | 34
Figure 6. Karst System Diagram
(Source: Geospace, web.viu.ca, n.d.)
Any construction that has the potential t...
P a g e | 35
Cave Board, n.d.). The rapid carry of pollutants creates risk of contamination traveling
undetected to areas ...
P a g e | 36
emphasized that pipelines carrying oil and liquefied natural gas are what would present
risks for groundwater...
P a g e | 37
than other construction activities that occur in karst such as the building of roadways. He
has even seen wel...
P a g e | 38
Trenching and Groundwater Protection
Trenching for pipeline construction is a more common practice and will m...
P a g e | 39
Risk, Threat, and Profit Losses
To conclude this section on groundwater, it is important to emphasize the
dif...
P a g e | 40
2014). However, the location and rate in which they form can be affected by human
activities such as construc...
P a g e | 41
Inadequate erosion control during construction can lead to the plugging of natural
sinkhole drains. The restr...
P a g e | 42
should serve as a warning that despite cover collapses being rare, the sensitivity of karst
terrain to altera...
P a g e | 43
Florida, is not necessarily a valid assumption (VA Cave Board, n.d.). At the very least,
the Florida study ma...
P a g e | 44
such as sinkholes, is lacking due to a previous and enduring lack of trust existing within
the community. We ...
P a g e | 45
Issues with Caves
The main issues associated with pipeline construction and caves are public safety
and habit...
P a g e | 46
groundwater in karst. Although the water would not directly be polluted by the gas,
groundwater in contact wi...
P a g e | 47
Figure 8. Significant (federally regulated) Caves in the New River Watershed
(Source: VA DCR, 2008)
Caves as ...
P a g e | 48
Resources Protection Act and the National Historic Preservation Act (National Park
Service, 2013). Depending ...
P a g e | 49
and Atlantic Coast Pipeline).” Acknowledging this comment, it is fair to assume that
MVP, LLC’s plans to prot...
P a g e | 50
VII. Pipelines and Karst: Case Studies Comparative Analysis
Sabal Trail Pipeline, Proposed
The proposed Sabal...
P a g e | 51
sensitive area in Florida that the pipeline will traverse, as of now. A main takeaway from
this case study is...
P a g e | 52
desire of avoiding potential legal actions could be absolutely detrimental to the
environment and the area su...
P a g e | 53
years (VA DMME, 2014). Both of these proposed Virginia pipelines are facing major
backlash from the public. L...
P a g e | 54
VIII. Recommendations and Conclusion
Based on the research provided in this report, informed by secondary sou...
P a g e | 55
6. Require MVP, LLC to draft a plan and set aside funding for mitigation of the
Mountain Valley Pipeline when...
P a g e | 56
IX. References
Appalachian Landscape Conservation Cooperative. Biodiversity Hotspot- Appalachian
LCC. Web. 20...
P a g e | 57
EPA. "Clean Power Plan for Existing Power Plants." Environmental Protection Agency,
n.d. Web. Nov. 2015. <htt...
P a g e | 58
MVP LLC. FERC Formal Filing Resource Reports 2, 3, 4, and 7. October 2015.
Ramsey, J. F., and S. A. Burgess. ...
P a g e | 59
Theo Colborn , Carol Kwiatkowski , Kim Schultz & Mary Bachran (2011) Natural Gas
Operations from a Public Hea...
P a g e | 60
X. Appendix
Expert and Stakeholder Interviews
Geophysics professor, Virginia Tech. September 2015.
Environmen...
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Mountain Valley Pipeline, Analysis of Environmental Issues

The following report addresses the impacts of highest concern from residential community members as well as the scientific community. The primary focus of the report is on environmental impacts, especially relating to karst topography, but also addresses four non-environmental concerns of significant importance. These include economic issues, eminent domain, Appalachian culture, and community engagement. Our conclusions are based on a set of ten recommendations to the Federal Energy Regulatory Commission (FERC) and Mountain Valley Pipeline (MVP), LLC that outline the need for oversight, mitigation, community engagement, and cumulative impact analysis. The approval of the Mountain Valley Pipeline should be contingent on these recommendations.

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Mountain Valley Pipeline, Analysis of Environmental Issues

  1. 1. The Mountain Valley Pipeline: An Analysis of Environmental Impacts Prepared by: Gabrielle Gonzalez, Jacqueline Tkac, Katie White Prepared for Client: Dr. John Browder , UAP December 11, 2o15 UAP 4354
  2. 2. Acknowledgements: Dr. John Browder All Interviewees Thank you for helping us throughout the duration of this project Cover Photo: Allegheny Mountain Radio, Rick Webb, 2014
  3. 3. Table of Contents Executive Summary.................................................................................................................1 Introduction............................................................................................................................2 Problem Statement and Project Methods..........................................................................6 Overview of Environmental Issues Surrounding Pipelines............................................8 Air Quality and Compressor Stations Noise Pollution and Compressor Stations Forest Fragmentation and Degradation Erosion and Sedimentation Public Safety and Human Health in the Natural Gas Production Process Water Quality and Pipelines Agriculture Non-Environmental Concerns Key Issue: Pipelines and Karst Topography .....................................................................31 Introduction to Karst Pipelines and Karst: Groundwater Pipelines and Karst: Sinkholes and Caves MVP, LLC and Karst Mitigation Pipelines and Karst: Case Studies Comparative Analysis .............................................50 Recommendations and Conclusion..................................................................................54 References .............................................................................................................................56 Appendix................................................................................................................................60
  4. 4. P a g e | 1 I. Executive Summary The Mountain Valley Pipeline (MVP) is a proposed 301 mile long, 42 inch wide natural gas pipeline that will carry fracked natural gas from Marcellus Shale wells in Wetzel County, West Virginia to a distribution center in Pittsylvania County, Virginia, travelling through 15 other counties along the way. The pipeline has potential adverse environmental, social, and economic impacts. In order to better evaluate the MVP, we completed primary research in the form of stakeholder interviews and secondary research by reviewing scholarly journals and publications from various government agencies and expert organizations. The following report addresses the impacts of highest concern from residential community members as well as the scientific community. The primary focus of the report is on environmental impacts, especially relating to karst topography, but also addresses four non-environmental concerns of significant importance. These include economic issues, eminent domain, Appalachian culture, and community engagement. Our conclusions are based on a set of ten recommendations to the Federal Energy Regulatory Commission (FERC) and Mountain Valley Pipeline (MVP), LLC1 that outline the need for oversight, mitigation, community engagement, and cumulative impact analysis. The approval of the Mountain Valley Pipeline should be contingent on these recommendations. 1 Limited Liability Company
  5. 5. P a g e | 2 II. Introduction The Mountain Valley Pipeline (MVP) is a proposed, 42-inch wide shale gas pipeline that will run through Montgomery County, VA carrying ‘fracked’ gas from Wetzel County, West Virginia to a distribution center in Pittsylvania, VA. The pipeline is a contentious issue for the local communities it will travel through. Numerous environmental concerns surround the issue, including its effect on karst topography, safety, noise pollution, water quality, air quality, watershed hydrology, and seismic activity. Additionally, under the Natural Gas Act, interstate pipeline companies are often permitted to exercise eminent domain in the land requirement process for pipeline construction. If the final route of the MVP is approved by FERC, the acquisition of land via eminent domain will become a possibility for local landowners, which will be discussed further in the Eminent Domain section of this report. Due to the convenience and abundance of natural gas in the United States, it seems that a dramatic shift is taking place towards the use of natural gas. The shift has largely been encouraged by new policies pushing toward a cleaner energy future, including the new Clean Power Plan (EPA, 2015). Natural gas produces about half as much carbon dioxide as the burning of coal, which has influenced natural gas becoming a preferable source of energy (EIA, 2015). In order to gain approval from FERC, the MVP must prove to provide multiple public benefits that outweigh any potential adverse impacts the pipeline and its construction may have. FERC is alleged to be working with other agencies to ensure compliance with the United States Department of Transportation standards on safety (FERC, 2011). The FERC focus, when considering approval, includes considerations on
  6. 6. P a g e | 3 subjects such as eminent domain, potential alternatives or modifications to reduce effects on buildings, fences, crops, water supplies, soil, vegetation, wildlife, air quality, noise, safety, the economic interests of landowners and communities affected by the pipeline route, environmental impacts (long and short term), evaluating extensively all potential alternatives to the proposed projects, and then balancing the potential benefits against potential adverse effects (FERC, 2011) . In the creation of this report, research on these impacts was necessary to form appropriate recommendations for the Federal Energy Regulatory Commission’s future decision-making on the pipeline. As students of Virginia Tech, there is constant discussion around the town between concerned citizens as well as by the media concerning the Mountain Valley Pipeline and its potential social, economic, and environmental impacts. Because of the preconceived notions that many citizens have surrounding fracking and pipelines, this comprehensive report was deemed necessary as an accessible overview for citizens, not only to clarify what the specific positive and negative impacts are surrounding the Mountain Valley Pipeline, but also surrounding pipelines in general. Montgomery County (MC), Virginia has released a Resolution of the Board of Supervisors that expresses their opposition to the proposed pipeline and their reasoning behind it. Some examples of the County’s reasoning for opposition include, but are not limited to, the following: the current proposed route of the pipeline has an adverse impact on a large number of developed residences in highly developed subdivisions, on what they describe as “scenic, recreational, and sensitive environmental areas in MC.” The proposed route bisects two major fault lines located in this specific county, raising concern for potential increase in seismic activity; there are two Agricultural Forestal
  7. 7. P a g e | 4 Districts (AFD) located in areas of MC that would be bisected by the proposed route of the pipeline, the construction along with any required ongoing maintenance of the pipeline (including the use of herbicides and pesticides to keep the rights-of-ways clear2 ) could be detrimental to the AFDs with regard to their forestall and agricultural uses, and is in direct conflict with the purpose of putting land in an AFD; which is to conserve and protect these lands as valued natural and ecological resources, providing watershed protection, wildlife habitats, aesthetic qualities, clean air sheds, among other environmental purposes. In addition, the Town of Blacksburg, Virginia released Resolution 12-D-14 expressing their concerns about the Mountain Valley Pipeline due to the fact that the MVP is proposed to cut through Montgomery County, Virginia, which is extremely close to Blacksburg town limits. The town of Blacksburg has expressed their opposition with the following reasoning: I. Blacksburg’s economic strengths are closely tied with the tourism of the surrounding area. This tourism includes the aesthetically pleasing natural environment in which the proposed pipeline would make clearing of the land necessary for the right-of-way easement, both temporary and permanent;3 2 A right-of-way (ROW) is a defined strip of land on which an operator has the rights to construct, operate, and/or maintain a pipeline. A right-of-way may be owned outright by the operator or an easement may be acquired for specific uses of the right-of-way (FERC 2011) 3 Part of this right-of-way easement is temporary and will be restored immediately after construction. The permanent right-of-way will remain until FERC determines that it is able to be abandoned by the pipeline company, which can be 20-50 years, or more. This right-of-way will have specified restricted uses that apply to on or across the right-of-way. The continuation of past agricultural uses and practices on or across the right-of-way would not be permitted. Buildings and large trees are also not usually allowed. The possibility of companies converting the pipeline for another use after abandonment exists as well (FERC 2011).
  8. 8. P a g e | 5 II. The Town of Blacksburg has expressed concerns about the karst topography and the effect the pipeline and its construction would have on the town’s water quality; III. Numerous accidents involving pipelines similar to the one proposed have occurred in the past, which include explosions; IV. Blacksburg Volunteer Rescue Squad and the Blacksburg Volunteer Fire Department would be first responders in any accident that may occur and potentially exceed the town’s emergency response capabilities; V. The town does not believe that the pipeline would add any positive aspects to their own economy, nor the Montgomery County economy; VI. Blacksburg Town Council does not see any potential benefit to the surrounding community with the approval of the pipeline, and takes note of the many potential adverse impacts of the proposed pipeline. Included in this report, is a critical analysis of the significance of pipelines on actors/stakeholders involved as discussed in this introduction as well as the planning approaches that can be taken to deal with potential adverse effects and potential risk to the general public.
  9. 9. P a g e | 6 III. Problem Statement The proposed Mountain Valley Pipeline will have potential adverse environmental impacts on the New River Valley, and its surrounding areas, and further research on these impacts is required to form appropriate recommendations for the Federal Energy Regulatory Commission (FERC)’s future decision-making on the pipeline, especially as it relates to karst topography and its underlying issues. IV. Project Methods Secondary Research, Identification of Relevant Studies and Literature Reviews This report primarily draws information from sources that possess jurisdiction by law and/or special expertise with respect to the environmental issues that are applicable to the Mountain Valley Pipeline project. Our literature review references some studies that do not directly evaluate the environmental impacts of pipelines, but that are nonetheless relevant to various aspects of the overall process of pipeline development (e.g. economic concerns). Other information in this report is predominantly sourced from different peer-reviewed scientific literature but include, where appropriate, government reports and other literature/research by organizations outside of commercial or academic publishing and distribution channels. Case studies of different pipelines (proposed or finished) in areas of similar topography as the proposed Mountain Valley Pipeline were reviewed for the purpose of identifying key problems MVP, LLC may face and potential solutions. Our research is focused on the processes of pipeline development that begins with surveying land, community outreach, and developing an Environmental Impact
  10. 10. P a g e | 7 Statement, and ends with the research and comparison of the Mountain Valley Pipeline’s future plans, including, but not limited to, expansion or abandonment of different facilities. These processes signify the very beginning and end in pipeline development and contribute to the comprehensive nature of this report. Interviews with Key Informants and Stakeholders Within our research, we included interviews with key informants that have expertise with direct pertinence to the environmental impacts of pipelines and their significance throughout the community. These interviews were meant to enhance, support, and understand secondary research. Interviews with stakeholders and community members were conducted to highlight the values and ethics involved with the Mountain Valley Pipeline decision making process, as well as to identify what some key issues that direct stakeholders have with the proposed pipeline. Interviewees will remain anonymous throughout this report, however professional titles can be found in the appendix. Pipeline Proposed Route Site Visits Visiting the proposed alternate routes was valuable in our research process due to the fact that it presented the opportunity of potentially meeting different stakeholders, and also offered a visualization of the proposed affected land by the Mountain Valley Pipeline, as well as photographs of the different areas.
  11. 11. P a g e | 8 V. Overview of Environmental Issues Surrounding Pipelines Air Quality and Compressor Stations According to MVP’s Resource Report on Air Quality and Noise, construction of most of the reasonably foreseeable future projects and activities would involve the use of heavy equipment that would generate emissions of air contaminants, fugitive dust, and noise. Construction and operation of the MVP Project will contribute cumulatively to negative air quality impacts. The combined impact of multiple construction projects occurring in the same airshed and timeframe as the MVP Project could temporarily add to air impacts in the Project area. Emissions from gas wells at the site of extraction combined with emissions from construction activities along the route, including construction vehicles, could result in cumulative impacts. However, MVP LLC claims it is unlikely that these emissions, together with emissions from gas wells, will have a significant impact on air quality. Natural gas has the reputation of being a “bridging” or “transition” fuel towards a society run on more renewable energy. The difference between natural gas and other fossil fuels is that its amount of carbon dioxide emissions is not nearly as high. Instead it is a huge emitter of methane gas, which is the main component in natural gas. Methane is an intense greenhouse gas that lasts about 20 years in the atmosphere rather than 100 years like carbon dioxide, but its heat trapping capabilities are over 20 times greater than carbon dioxide in a 100-year period (Natural Gas and Its Uses, 2011). About 3.6% to 7.9% of methane gas from the shale production escapes into the atmosphere during the production process alone. In the atmosphere there are 20% greater emissions derived from natural gas than from coal and oil; and in the long term the amount of emissions
  12. 12. P a g e | 9 from natural gas is still greater (Ingraffea, 2013). The Intergovernmental Panel on Climate Change (IPCC) has concluded that this type of “human-produced” methane ends up having as much of an impact as carbon dioxide does over a 10-year period and 80% as much impact over a 20-year period; this is due to the fact that methane is 86 times more damaging to the atmosphere in the 20-year time frame, but is being released in smaller quantities (IPCC, 2014). Methane is a gas that is lighter than air, and therefore has the ability to escape into the atmosphere easily during the natural gas production and transport process. Methane could potentially escape from multiple sources during the entire production process; such as the actual well itself, pipeline leaks, and deliberate venting or “blow-off” of gas at compressor stations along the pipeline (Tollefson, 2012). In 2014 researchers at Cornell University published a peer-reviewed analysis comparing the total greenhouse impact of natural gas from fracked and conventional sources to other fossil fuels, taking into account all sources of methane release. Using a 20 year time period, the researchers concluded that “both shale gas and conventional natural gas have a larger GHG impact than do coal or oil, for any possible use of natural gas and particularly for the primary uses of residential and commercial heating. The 20- year time period is appropriate because of the urgent need to reduce methane emissions over the coming 15–35 years” (Howarth, 2014). MVP compressor stations will be a permanent source of noise and airborne emissions. These compressor stations together could have a cumulative negative impact on air quality. Compressor Stations are facilities that are located along a natural gas pipeline that houses and keeps compressors protected. Compressors are used to compress (pump) the gas to move it through the system. Compressor stations are strategically
  13. 13. P a g e | 10 placed along the pipeline to boost the system pressure to maintain required flow rates (FERC, 2011). In addition to compressors, compressors stations often include equipment to remove and store water vapor, and condensate other remaining impurities. Compressors have been identified as an emission source that has the potential to produce emissions escaping into the atmosphere during natural gas production, processing, transmission and storage. Vented emissions from compressors occur from seals (wet seal compressors4 ) or packing surrounding the mechanical compression components (reciprocating compressors5 ) of the compressor. These emissions typically increase over time as the compressor components begin degrading (OAQPS, 2014). When referring to natural gas compressors, the most popular types of compressors that are used are reciprocating and centrifugal compressors6 . In a study done by Subramanian et al., equipment and site-level methane emissions from 45 compressor stations in the transmission and storage (T&S) sector of the United States Natural Gas System were measured. These sites included 25 that were required to report under the EPA greenhouse gas reporting program (GHGRP). Compressor vents, leaky isolation valves, reciprocating engine exhaust, and equipment leaks were major sources of methane emissions, and a 4 Wet seals use oil around the rotating shaft to prevent natural gas from escaping where the compressor shaft exits the compressor casing. The oil is circulated at high pressure to form a barrier against compressed natural gas leakage. The circulated oil entrains and absorbs some compressed natural gas that may be released to the atmosphere during the seal oil recirculation process (degassing or off- gassing) (EPA, 2014). 5 Reciprocating compressors: a piece of equipment that increases the pressure of a process gas by positive displacement, employing linear movement of the drive shaft (EPA, 2014). 6 Centrifugal compressors: any machine for raising the pressure of a natural gas by drawing in low pressure natural gas and discharging significantly higher pressure natural gas by means of mechanical rotating vanes or impellers (EPA, 2014)
  14. 14. P a g e | 11 substantial amount of emissions were observed at both operating and standby compressor stations. Methane contributes to the creation of ozone (Subramanian, 2015). At each stage of natural gas production and delivery, a massive amount of methane gas, and toxic volatile compounds have the potential to escape and mix with the nitrogen oxides being released from the exhaust of diesel-fueled equipment, both mobile and stationary. When combined, this mixture produces ground-level ozone. One highly reactive molecule of ground level ozone can cause premature aging in the lungs. Chronic exposure can lead to asthma and chronic obstructive pulmonary disease (COPD), and is particularly damaging to children, active young adults who spend time outdoors, and the elderly (Colborn et. al, 2011). Ozone, when combined with particulate matter less than 2.5 micrometers, will produce smog that has been demonstrated to be extremely harmful to human health, as measured by emergency room admissions during periods of elevation (Peng et al. 2009). Key findings from a Marcellus Shale Short-Term Ambient Air Sampling report from Northcentral Pennsylvania, done by the Pennsylvania Department of Environmental Protection, state that concentrations of certain natural gas constituents including methane, ethane, propane and butane, and associated compounds in the air near Marcellus Shale drilling operations were detected during sampling. After sampling for carbon monoxide, nitrogen dioxide, sulfur dioxide and ozone, there were no concentrations found above National Ambient Air Quality Standards at any of the sampling sites. Afterwards, the PA DEP did make a statement that they were unable to predict or determine whether or not the potential cumulative emissions of criteria pollutants from natural gas exploration
  15. 15. P a g e | 12 activities would eventually result in violations of the health and welfare-based federal standards (Corbett et. al., 2011). Most natural gas is referred to as "dry." “It generally consists of 95% methane, 3% ethane, propane, and butane, and 2% non-hydrocarbon gases such as carbon dioxide, nitrogen, or helium” (EPA, 2010). According to the Institute For Energy and Environmental Research for Northeastern Pennsylvania (Wilkes, 2011), “some forms of natural gas, called “wet”, contain up to 20% of ethane, propane, and butane. These components have to be removed or converted to methane to produce dry natural gas.” The Scientific and Technical Issues (STI) Group explains that “compressor stations typically include scrubbers, strainers or filter separators which remove liquids, dirt, particles, and other impurities from the natural gas. Though natural gas is considered ‘dry’ as it passes through the pipeline, water and other hydrocarbons may condense out of the gas as it travels” (STI, 2014). The compressor stations have the responsibility of removing these impurities so that the natural gas can be sold in the desired form to the customers (STI, 2014). If these impurities are not removed, these liquids could potentially collect in low spots, eventually blocking gas flow. This is a major cause of pipeline internal corrosion and can completely freeze in colder weather, bringing the gas flow to a complete halt (Miesner et al., 2006). Noise Pollution and Compressor Stations The main sources of noise in natural gas processing facilities include large rotating machines (e.g., compressors, turbines, pumps, electric motors, air coolers, and fired heaters, air coolers at liquefaction facilities, vaporizers used during regasification, and general loading/unloading operations of natural gas carriers/vessels). During
  16. 16. P a g e | 13 emergency depressurization, high noise levels can be generated due to release of high- pressure gases to flare and/or steam release into the atmosphere (IFC, 2007). Atmospheric conditions that may affect noise levels include humidity, wind direction, and wind speed. Vegetation, such as trees, and walls can reduce noise levels. Installation of acoustic insulating barriers can be implemented where necessary (IFC, 2007). How loud a compressor station can potentially be is an on-going issue that does not stop once construction of a pipeline is complete. The United States Department of Agriculture explains that in many rural areas, the sound of compressor stations is exceptionally loud. The noise level near a compressor station can be up to 100 decibels, roughly the sound of a power saw, whereas the usual nighttime noise level in many rural areas is around 35 decibels (Four Corners, 2009). FERC regulates interstate pipeline compressor stations and requires that noise levels from the station do not exceed 55 decibels (dBA), which is the level of an average day-night sound level (Ldn), at the nearest noise sensitive area (NSA), when operating at full load (FERC, 2015). The Pennsylvania State Department of Conservation and Natural Resources has a regulation that is even stricter than FERC’s at the maximum noise level being 55 decibels, 300 feet away from the site. A department worker explains that the decibel level of a noise only measures loudness, which is only one aspect of a noise perception. Other factors that need to be considered range from its frequency, to the topography of the area, and even the weather on a particular day. Noise regulations vary by locality, but as of now, there are no state standards for compressor station noise. The federal government will only get involved with compressor station noise if it is connected to an interstate pipeline (Cusik, 2014). Typical monitoring periods should be sufficient for statistical analysis. Monitoring periods may last 48 hours and use
  17. 17. P a g e | 14 noise monitors that frequently and continuously log data over this time period to ensure accuracy of data. Hourly, or even more frequent monitoring may be appropriate depending on the area (Mokhatab et al., 2012). The noise level limit generally is represented by the ambient noise levels that would be present even in the absence of the compressor station. The preferred method for controlling noise from stationary sources is to implement noise control measures at the source. Four examples of noise reduction options include selecting equipment with lower sound power levels, installing silencers for fans, installing suitable mufflers on engine exhausts and compressor components, and installing acoustic enclosures for equipment casing radiating noise (Mokhatab et al., 2012). According to MVP, LLC, Resource Reports, these methods for noise pollution are being implemented on each of the compressor stations accordingly. Forest Fragmentation and Degradation The Appalachian Mountains are one of the most biologically diverse regions in the world in terms of both species variety and abundance (Highlands Biological Station Foundation, n.d.). The Appalachian region contains the highest diversity of aquatic species in the United States and is only comparable to China for diversity of forests (Appalachian Landscape Conservation Cooperative, n.d.). The MVP will cross 3.4 miles of the Jefferson National Forest, crossing Peter’s Mountain, Brush Mountain, Sinking Creek Mountain, Slussers Chapel Conservation Site, and the Appalachian Trail (MVP LLC, 2015). About 2,500 acres of forest core habitat in West Virginia will be temporarily affected by the pipeline, and 866 acres will be permanently affected (MVP, LLC 2015). In Virginia, about 1, 100 acres of core forests will be temporarily impacted, while 195 acres will be permanently impacted (MVP LLC, 2015). The temporary construction
  18. 18. P a g e | 15 right-of-way for the pipeline will be 125 feet wide, and the permanent right-of-way will be 50 feet wide (MVP LLC, 2015). Forested upland habitats will be most heavily impacted because of permanent conversion to shrub and grassland. Construction activities can cause indirect damage to vegetation, especially trees, outside the pipeline right-of-way by damaging root systems that spread into the trench. Such impacts include tree decline, premature falling, and death (MVP LLC, 2015). MVP, LLC includes in Resource Report 3 that impacts on root systems will be offset by the 125 ft. construction right-of-way, and they expect damage to be minimal. Forest fragmentation is a significant impact of concern caused by pipeline development. Even when large sections of forest remain and impacts are minimized, pipeline corridors can fragment large patches of forest into smaller ones (Johnson, 2011). MVP, LLC acknowledges in Resource Report 3 that, “Continuous tracts of forest will be fragmented and sharp edges created at the interface of intact forest.” The conversion of forest interior to edge also completely changes the habitat dynamic from shade, humidity, and canopy cover to increased exposure to sunlight, air flow, and reduction of cover. Figure 1 below shows a fragmented forest in West Virginia resulting from natural gas pipeline development.
  19. 19. P a g e | 16 Figure 1. Forest Fragmentation, Natural Gas Production (Source: www.marcellus-shale.us, 2012) Habitat fragmentation is an inevitable result of forest fragmentation because of the creation of sharp forest edges, loss of forest interior, and change in forest dynamics. Habitat fragmentation is one of the biggest threats to species diversity (Honnay, 2005). Interior species like migratory birds, salamanders, and woodland flowers will be deprived of the conditions necessary for survival when shade, humidity, and canopy cover are diminished (Johnson, 2011). This will also result in the transition of the plant community to plants that are intolerant of shade (MVP LLC, 2015). The creation of new corridors will also likely impact the movement of interior species that are unlikely to cross the corridors because of the increase in predator species. Studies suggest that mutualisms like pollination and seed dispersal are more sensitive to fragmentation than herbivory and predation (Magrach, 2014). Therefore, there will be a decrease in pollinators like bees and butterflies, while there will likely be an increase in common species like deer,
  20. 20. P a g e | 17 raccoons, crows, and blue jays that adapt easily to different conditions (Mulhollem, 2014). The pipeline corridors are also likely to be travelled by black bears (MVP LLC, 2015). Migratory birds and songbirds are just some of the species to be impacted heavily by habitat fragmentation. Margaret Billingham, a wildlife specialist at Pennsylvania State University, is an expert in avian ecology and has studied the impacts of shale gas development on forests and birds. She says, “The cumulative effect of many small-scale disturbances within the forest is resulting in the homogenization of bird communities…Biotic homogenization is a subtle process by which generalists replace specialists with common species becoming more abundant, and habitat specialist species declining,” (Mulhollem, 2014). Other impacts to wildlife include impaired reproductive ability, displacement of the project area, direct mortality to less mobile and subterranean species, and injury or death caused by falling into the pipeline trench and getting trapped (MVP LLC, 2015). Tree removal will permanently reduce the amount of habitat available for nesting, roosting, and denning of woodland species (MVP LLC, 2015). Multiple species within the project area are federally listed and state protected. Some of the species include the Timber Rattlesnake, Loggerhead Shrike (pictured below in Figure 2), James Spinymussel, Roanoke Logperch, and Smooth Coneflower (MVP LLC, 2015).
  21. 21. P a g e | 18 Figure 2. Loggerhead Shrike (Source: www.bird-friends.com, Scott Streit, 2000) In addition to the forest and wildlife habitat impacts, pipeline construction increases the likelihood for infestations of invasive species. A report written on pipeline development in Fernow, West Virginia, described the increased potential of dispersal of invasive species, especially due to roadways and roadsides (Buszynski, n.d.). MVP, LLC has outlined plans in their Resource Report to mitigate some of these effects by placing the pipeline corridor parallel to existing utility right-of-ways as much as possible, shrinking the size of right-of-way from original plans, utilizing existing infrastructure like roads, and collaboration with organizations like the U.S. Forest Service. MVP, LLC has also vowed not to use pesticides or herbicides during maintenance of the right-of-ways.
  22. 22. P a g e | 19 Erosion and Sedimentation Figure 3. Pipeline Construction (Source: Marcellus-shale.us, 2011) Although erosion is a natural process, it can be dramatically accelerated by human activity, especially construction. The Mountain Valley Pipeline will most likely create erosion and sedimentation problems, as does any other large construction project. A report produced by The Nature Conservancy on pipeline development in Pennsylvania states, “the large amount of soil disturbance involved in laying pipelines poses erosion and sedimentation risks, particularly in steeper areas, near water bodies, and during extreme rain events,” (Johnson, 2011). Slope is of concern because it is a factor in velocity of rainfall runoff (Brindle, 2003). About 70% of the pipeline route crosses slopes that are higher than 20%, and 78% of the pipeline crosses slopes higher than 15%, indicating high potential for erosion (MVP LLC, 2015). Additionally, slopes in the Jefferson National Forest range from 11 to 70% (MVP LLC, 2015). Construction
  23. 23. P a g e | 20 activities that are necessary for building the pipeline like vegetation removal can increase the soil erosion rate 2 to 40,000 times the rate before construction (Brindle, 2003). Soil compaction is caused mostly by construction equipment travelling over wet soils and decreases the infiltration of the soil, increasing the potential for erosion. About 80% of the pipeline route could experience compaction (MVP LLC, 2015). Most construction activities associated with the pipeline will disturb topsoil and subsoil. Mixing topsoil and subsoil can lead to soil fertility loss because of loss of nutrients and loss of suitable structure necessary for plant growth (MVP LLC, 2015). It is also difficult to re-vegetate steep slopes with typical techniques like seeding and mulch application, which makes erosion control especially difficult (Brindle, 2003). The Army Corps of Engineers acknowledges the insufficiency of vegetative stabilization on steep slopes and emphasizes the need for non-vegetative erosion control like matting with durable material, and also specifies earthen berm dikes as the most effective form of erosion control in steep, rocky terrain instead of hay bales and silt fences (Dickson, n.d.). Specific erosion control measures that MVP, LLC outlines in its Soil Resource Report include slope breakers, using both silt fences and earthen berm dikes, temporary sediment barriers, permanent sediment barriers like bags of sand and clay, re-vegetation, and efficient timing practices. The effectiveness of these measures are largely dependent upon their proper execution. The company repeatedly states that they will continue to monitor these activities until the desired outcome is reached. There is a potential for large amounts of sediment to be introduced into bodies of water during the construction of pipelines, especially in steep and mountainous areas (Dickson, n.d.). Stream and wetland crossings pose significant risks for erosion and
  24. 24. P a g e | 21 sedimentation, especially if the open-cut process and bore crossing techniques are used (Johnson, 2011). The impacts of erosion and sedimentation on water bodies will be further discussed in the water quality section of this report. Soil contamination is another risk posed by the Mountain Valley Pipeline. Contamination could occur during construction and trench excavation; leaks and spills of lubricants, coolants, and fuel from construction equipment could harm the soil quality in the pipeline route (MVP LLC, 2015). MVP, LLC has indicated that they are currently developing a Spill Prevention, Control, and Countermeasure Plan in the event that soil contamination occurs. Public Safety and Human Health in the Natural Gas Production Process Rupture/Blast Radius Potential and Seismic Activity The blast radius of a pipeline is the distance measured in feet that the fire touches and consumes; from the point of pipeline rupture to the outer edge of the affected burned area. According to Stephens, for a given pipeline, the type of hazard that develops, and the potential damages or injuries associated with the hazard, will depend on the mode of line failure (i.e., leak vs. rupture), the nature of gas discharge (i.e., vertical vs. inclined jet, obstructed vs. unobstructed jet) and the time of ignition (i.e., immediate vs. delayed) (Stephens, 2000). In 2013, the Alberta Energy Regulator flagged external corrosion as the second leading cause of pipeline failures at 12.7%, mainly due to old age or excessive production temperatures (Council of Canadians, 2015). Natural gas is transported in steel pipe to minimize costs, and steel is prone to corrosion over time. To prevent external corrosion steel pipes containing natural gas are coated with a layer of electrically insulating material known as dielectric (Eng, 2014). For terrestrial
  25. 25. P a g e | 22 releases, exposure to an accidental natural gas leak may result in asphyxiation as a result of oxygen displacement, and the greatest threats from a natural gas leak are explosion and fire (Mokhatab et. al, 2012). Another main hazard presented with natural gas pipelines is thermal radiation from a sustained jet or a trench fire7 . An estimate of the ground area affected by a credible worst case event can be obtained from a model that characterizes the heat intensity associated with rupture failure of the pipe where the escaping gas is assumed to feed a fire that ignites very soon after line failure. The possibility of a significant flash fire occurring from delayed remote ignition is low due to the buoyant nature of the vapor.8 The MVP’s proposed route currently bisects two major fault lines in certain areas of Montgomery County. If failure or damage were to occur during seismic activity, extreme environmental damage and potential for human harm is plausible, especially when the topography of the area is considered, which will be discussed in more detail in later sections of this report. The Federal Emergency Management Agency (FEMA) has defined specific indications and tools to be used when estimating the possible damage scenarios due to natural catastrophic events (Physical Monitoring, 2010). The 42 inch diameter of the proposed MVP would require it to be buried deeper into the ground and MVP, LLC has claimed the pipeline will be buried to a depth of at least 3 feet. Burying at increased depth can potentially lessen the amount of damage in the event of seismic activity. This is due to the fact that the surrounding landfill around 7 A trench fire is essentially a jet fire in which the discharging gas jet impinges upon an opposing jet and/or the side of the crater formed in the ground (Stephens,2000) 8 Formula: Rupture probability = (number of ruptures / total length of pipelines) /number of years X pipe- line length X 100% (Council of Canadians, 2015)..
  26. 26. P a g e | 23 the pipeline protects the pipeline and its infrastructure from above ground damages, including accidents (either natural or man-made). Also, the lateral9 confinement provided by the surrounding soil reduces the seismic effects. Therefore, the performance of the structure during seismic activity directly correlates to the geotechnical effects (Physical Monitoring, 2010). TransCanada Pipeline Corrosion Problems A case study revealed that in July 1995, a pre-existing stress corrosion crack gave away, rupturing TransCanada Limited’s 42-inch natural gas pipeline. There was an explosion that caught fire and spread all throughout the compressor station. The damage made shutting the flow of gas off extremely difficult. “From the mainline, the fire spread to a secondary gas line, weakening it. The second line ruptured and also went up in flames. The fires lasted for two hours. An on-duty TransCanada staff member discovered the rupture and made two attempts to contact the regional operations controller. A third attempt from an emergency phone located outside the compressor station failed as well. Ultimately, the employee had to use a bystander’s cell phone to make the call. A subsequent Transportation Safety Board investigation found that the supervisory control and data acquisition system malfunctioned, delaying the shutdown and the isolation of the two burning pipelines. The line that suffered the corrosion and ruptured is part of the same line that TransCanada wants to convert and use to carry crude oil for the proposed Energy East project. (Mandal, 2015).” In a 2013 report on corrosion, it was discovered that another one of TransCanada’s pipelines built in 2009 was also extremely corroded, 9 A lateral is a segment of a pipeline that branches off the main or transmission line to transport the product to a termination point, such as a tank farm or metering station (FERC 2011)
  27. 27. P a g e | 24 with one of the more extreme corroded sections located less than 200 feet away from the Mississippi River. This pipeline is the same diameter as the proposed MVP pipeline. Water Quality and Pipelines According to the Mountain Valley Pipeline Resource Report #2, “Water Use and Quality”, construction of the pipeline could result in “minor, short-term impacts to water bodies.” The proposed route would intersect 3 major aquifers, 22 public water supplies are located less than a mile from the route, 24 public wells, 23 springs, 35 potential contaminated ground water sources are within a half mile of the route, 14 wellhead/source water protection areas are located within 150 feet of the route, 33 watershed crossings are crossed, 65 FEMA-100 year floodplain zones, 5 potentially eligible wild and scenic rivers, 5 significant rivers, 44 Impaired water bodies and 8.5 wetlands (MVP, LLC, 2015). Potential contamination of water bodies from natural gas pipelines may result from the discharge of potentially harmful substances such as hydrocarbons and process chemicals by spills or accidental leaks. Gas enters the environment due to both natural and anthropogenic processes. It should be noted that these hydrocarbon gases are piped over great distances, and as mentioned before, cross hundreds of water bodies. Possible pipeline damages can lead to hazardous impacts on water ecosystems. Water toxicology of saturated aliphatic hydrocarbons of the methane series has not been developed fully (Mokhatab et. al, 2012). Natural gas exhibits negligible solubility in water and thus has little effect on water quality in the event of an underwater leak. (Mokhatab et. al, 2012). In an expert interview conducted with a member of the Department of Environmental Quality, it was stated methane leakage into a water system was a possibility, but not a
  28. 28. P a g e | 25 very likely one due to the fact that it is a gas, so light in weight, and would more than likely escape into the atmosphere, but it all depends on where the leak occurred along the pipeline route. Agriculture The Mountain Valley Pipeline will also impact agriculture in the region. About 38% of the soils in West Virginia and 52% of soils in Virginia crossed by the pipeline are classified as farmland of statewide importance and prime farmland (MVP LLC, 2015). The most common impact of pipelines on agriculture is impaction of soil and alteration of topsoil. Soil compaction causes a reduction in soil permeability which can lead to a decrease in root absorption (Ramsey, 1985). Construction of the pipeline right-of-way can result in loss of topsoil. Loss of topsoil can reduce the stability of soils and reduce crop yields (Ramsey, 1985). Construction of the pipeline could place stone and rock fragments into the surface soil, which can cause a decrease in soil productivity and damage agricultural equipment that comes into contact with large fragments. There also is potential for disruption to livestock lands that can interfere with grazing (Ramsey, 1985). Agriculture and livestock businesses are important to the region affected by the pipeline. MVP, LLC submitted mitigation plans to FERC regarding conservation and segregation of topsoil to reduce risks of erosion and loss of crop productivity, as well as plans to monitor crop production post-construction to evaluate the success of the soil restoration.
  29. 29. P a g e | 26 Non-Environmental Concerns Economic Issues The Mountain Valley Pipeline considers the economic gains, costs and expected benefits of tax, job creation and natural gas sales. However, what is not noticed to its fullest extent is the unforeseen costs, or externalities. Environmental degradation has a real economic price and one that companies are able to bypass without paying true expenses. From an anthropocentric point of view we must consider economic rationality. An economically rational decision is one that includes the welfare of its citizens; land beauty, individual right to own private property, and health. Ethically if we consider economic rationality, monetary value is not the reasoning behind an economically sound decision. According to a study done by Robert Pollin on the economic advantages and disadvantages of pipelines, spending on green investments creates approximately three times as many jobs as spending on maintaining our existing fossil fuel sector. The reasons behind this are obvious, according to Pollin. This is because clean energy investments are more labor intensive, and a higher proportion of overall spending on the green economy10 remains within the domestic economy as opposed to purchasing imports. Investments in fossil fuels create only about 6.5 jobs per $1 million spent. This is about half the level of jobs per dollar generated by the green stimulus programs and less than one-third what focusing on green investments in a generally labor-intensive area would result in, such as public transportation. Pollin concludes his study by stating “there is no way that increasing our dependence on conventional energy sources - that is, oil, 10 Market economists use the term 'Green economy' to describe strategies that use market mechanisms to counter environmental damage (The Green Economy, 2015).
  30. 30. P a g e | 27 natural gas, coal, nuclear power, or combination thereof - will provide an adequate solution to any parts of our environment and employment crisis. But aggressive investments in energy efficiency and renewable energy do offer a viable program today and into the future…” (Pollin, 2012). A major economic concern for local landowners is property value fluctuations due to pipeline construction. After comparing literature reviews from all over the country, including studies done before and after the incident in San Bruno, California, there is no systematic relationship between proximity to a natural gas pipeline and real estate sale prices or values (Wilde et al., 2013). There is also no systematic evidence, based on actual sales data, that pipeline ruptures, including catastrophic ones, correlate to any reduction in property values. Due to the fact that literature on this subject is limited, future analysis on actual sales data is necessary in order to reach a more legitimate conclusion (Wilde et al., 2013). Eminent Domain While conducting interviews with direct stakeholders and property owners along the proposed pipeline route, many expressed concern over the ethics and logistics behind the potential use of the state’s police power of eminent domain. Eminent domain is the power to take or damage private property for a public use, provided that the owner is paid just compensation. Just compensation is the monetary value of the property taken or damaged. Virginia has adopted the rule established by the Supreme Court of the United States that a landowner is entitled to the “full and perfect equivalent for the property taken or damaged.” Chairman of Highway Commission of Va. v. Fletcher, 153 Va. 43, 47
  31. 31. P a g e | 28 (1929).VA. CONST. art I, § 11. Virginia’s eminent domain amendment defines public use as the following: That the General Assembly shall pass no law whereby private property, the right to which is fundamental, shall be damaged or taken except for public use. No private property shall be damaged or taken for public use without just compensation to the owner thereof. No more private property may be taken than necessary to achieve the stated public use. Just compensation shall be no less than the value of the property taken, lost profits and lost access, and damages to the residue caused by the taking. The terms “lost profits” and “lost access” are to be defined by the General Assembly. A public service company, public service corporation, or railroad exercises the power of eminent domain for public use when such exercise is for the authorized provision of utility, common carrier, or railroad services. In all other cases, a taking or damaging of private property is not for public use if the primary use is for private gain, private benefit, private enterprise, increasing jobs, increasing tax revenue, or economic development, except for the elimination of a public nuisance existing on the property. The condemner bears the burden of proving that the use is public, without a presumption that it is. (VA. CONST. art. I, § 11.) According to (SE Negro, 2012), it is state law that determines what authority specific municipalities may exercise. Each individual state provides their municipalities with varying degrees of authority to enact different regulations that may affect the oil and natural gas industry. Virginia is a Dillon Rule state, which means that local governments can only regulate the areas where the General Assembly has granted specific legislative authority. Local governments have been granted specific authority over: erosion and sediment control, stormwater, and noise (Montgomery County, 2015).
  32. 32. P a g e | 29 Appalachian Culture and Resources Appalachia is rich in culture and can be identified by certain types of music, dance, storytelling, speech, and food. Appalachian people are typically characterized as independent, self-reliant, loyal to family, and are known for their love and attachment to land. Land serves as a basis of identity for many people in Appalachia; land is viewed not as property but as a part of the person, and the person a part of the land (Utz, 2001). Land represents historical roots for Appalachian families and instills a sense of place and independence in landowners. The Mountain Valley Pipeline threatens this sense of identity for many Appalachian people. If approved, the pipeline will be constructed not only directly through some landowners’ properties, but also in the path of historical sites and natural areas of significant importance to Appalachia. In West Virginia, 123 archeological resources and 138 archeological sites in Virginia have been identified within a mile of the project (MVP LLC, 2015). Some of these sites include cemeteries, Civil War battlegrounds, villages, plantations, cabins, farmsteads, and campgrounds. Blasting during construction has the potential to impact these sites. Views of the sites could also be impaired by the permanent right-of-way of the pipeline. Appalachia has a long history of being exploited by natural resource extraction industries, which has created a lot of distrust of outsiders by Appalachian people (Burris, 2014). Therefore, the Mountain Valley Pipeline has the potential to negatively impact Appalachian culture.
  33. 33. P a g e | 30 Community and Public Engagement Figure 4. Anti-Pipeline Advertising (Source: Team E, 2015) Active engagement and involvement of the public by any company impacting the community is crucial for the well-being of the community and the company. The overwhelming consensus of stakeholder interviews revealed that both supporters and opponents of the pipeline feel that MVP, LLC has done a very poor job at public engagement efforts thus far. MVP, LLC acknowledged the importance of this process on their website in a written statement that reads, “Community engagement is integral to the Mountain Valley Pipeline’s development process.” (MVP LLC, 2015). They also provided a toll-free phone number for stakeholders and spoke of the importance of open houses and feedback. However, many stakeholders felt the open houses were not
  34. 34. P a g e | 31 successful because of the condescending demeanor of the company towards the community. According to an interview with a mining engineer, and supporter of the pipeline, MVP, LLC has so far used an outdated D.A.D style of public engagement- decide, announce, and defend. Also, according to interviews with community members who live along the route, there have also been instances of company surveyors trespassing onto private property and failing to follow procedures by not sending certified letters of request and intent to several landowners. News articles describing lawsuits taken against landowners by MVP, LLC have also circulated in the region. This has created a vast amount of apprehension and distrust of MVP, LLC from landowners and community members that will be impacted by the pipeline. VI. Key Issue: Pipelines and Karst Topography Introduction to Karst Topography Karst topography is formed from the dissolution of underlying soluble rocks by surface or groundwater. Karst landscapes are commonly dominated by carbonate rocks, such as limestone and dolomite, as well as other soluble rocks like gypsum and rock salt (USGS, 2014). About 10% of the Earth’s surface is occupied by karst landscape and a quarter of the world’s population depends on water supplied from karst aquifers (USGS, 2014). Southwest Virginia is dominated by karst topography in several different areas, as seen in figure 5 below. The MVP route crosses karst terrain in Summers and Monroe County in West Virginia and in Giles, Craig, and Montgomery Counties in Virginia (MVP, LLC, 2015).
  35. 35. P a g e | 32 Figure 5. VA Localities Containing Karst (Source: VA Cave Board, n.d.) There are various degrees of karst landscapes and large drainage systems in karst usually have both fluvial (surface) and underground drainage components. The dissolution process is important to understand before delving into the sensitivity of karst features and their associated risks (USGS, 2014). The process relies on rainfall and snowfall to soak into the soil. The soil becomes slightly acidic because it reacts chemically with the carbon dioxide that is already present in the atmosphere and existing soil. As the rainwater seeps further into the soil, it fractures and dissolves the bedrock (USGS, 2014). The result is the formation of cave passages and caverns, which are prominent karst features. Karst terrain also results in the formation of water-rich zones, also called saturated zones, and the upper surface of these zones are known as the water tables (USGS, 2014). Water-rich zones are also defined by the volume of void spaces in the bedrock, which determines the porosity of the bedrock. Greater porosity means water
  36. 36. P a g e | 33 or air can more easily migrate from void to void (USGS, 2014). This is why bedrock in karst is referred to as permeable because of how easily fluids can move through it, which causes concerns over contamination. It is the permeable bedrock that often makes for a good aquifer and many karst areas have aquifers supplying drinking water to surrounding populations (USGS, 2014). Doline karst is the most common type of karst landscape and is prominent in Virginia. Dolines are also known as sinkholes, which are surface depressions formed by the dissolution of bedrock (USGS, 2014). They can fill with water forming lakes or ponds depending on their size. Sinkholes are also often characterized by springs where groundwater emerges at the surface (USGS, 2014). They are associated with disappearing streams, which terminate quickly by flowing or seeping into the ground, indicating an underground drainage system (USGS, 2014). This feature presents a risk for carrying pollutants underground. Another significant karst feature in Virginia is caves. Caves are natural openings large enough to permit a person to enter (VA DMME, 2014). Caves form when weakly acidic groundwater reacts with carbonate rocks as it moves through fractures and bedding partings. Most of Virginia’s 4,000 caves are in soluble carbonate rocks in 27 counties in the western portion of the state (VA DMME, 2014). The karst system diagram below (figure 6) presents a visual of the processes described here as well as the layout of karst features.
  37. 37. P a g e | 34 Figure 6. Karst System Diagram (Source: Geospace, web.viu.ca, n.d.) Any construction that has the potential to disturb the ground in karst creates potential risk to features noted above, but there is a community-wide concern over a 42 inch wide pipeline being placed into a sensitive karst system. These concerns are relevant, as there are several studied risks associated with pipeline construction and karst topography. Groundwater is one such concern. Groundwater can flow rapidly through the channel solutions found in karst, much quicker than in other landscapes. Therefore, pollutants in groundwater can be carried rapidly as well with little to no filtration (VA
  38. 38. P a g e | 35 Cave Board, n.d.). The rapid carry of pollutants creates risk of contamination traveling undetected to areas distant from the source of the pollution (VA Cave Board, n.d.). Another concern is species impact, as many species/organisms are specifically adapted to living in caves and cannot live in other habitats. Cave species are therefore at high risk for degradation from alteration of karst features. Additionally, natural gas can travel through karst conduits at similar speeds of water (VA Cave Board, n.d.). Gasoline vapors traveling quickly through karst presents a risk to public safety. Lastly, sinkhole and cover collapse are also a major concern with pipeline construction. Disturbing sensitive areas can cause the collapse of sediment overlying bedrock and is often exasperated by poor stormwater management practices and erosion controls (VA Cave Board, n.d.). Each of these issues will be discussed in detail in the following sections. Pipelines and Karst: Groundwater As mentioned in the introduction, groundwater contamination in karst is a major public concern. Groundwater flow in karst is non-uniform. The flow is not as predictable as flow in unconsolidated sediment, which makes many computer models of groundwater flows in karst unreliable (VA Cave Board, n.d.). Groundwater flow can move rapidly through karst conduits, carrying possible pollutants unfiltered. Groundwater pollution risk from a pipeline leak has been an issue brought up in various community discussions for this report. However, through interviews with several experts on karst and groundwater, it has become apparent that there is no risk of direct pollution to groundwater in karst due to a natural gas leak. A groundwater expert with the Virginia Department of Environmental Quality (DEQ) noted in an interview that a pipeline carrying natural gas is not a threat to groundwater because it is not carrying a liquid. He
  39. 39. P a g e | 36 emphasized that pipelines carrying oil and liquefied natural gas are what would present risks for groundwater contamination. To reinforce this statement, a mining professor and energy researcher at Virginia Tech described that methane, the major component of natural gas, evaporates into the air and not into water. The Virginia DEQ expert also stated that groundwater in karst regions in Virginia is often well below the surface, between 20 to 75 feet underground. The depth lessens contamination risks. Although expert interviews revealed little risk to groundwater from natural gas, this is only if the gas is not liquefied in any form. If there are other components added to natural gas there may be an increased risk of evaporation into water rather than air. An interview with an environmental science professor at Virginia Tech revealed this issue. According to his knowledge, compressor stations placed along pipeline routes often contain filtration systems which would be unneeded if the only compound within a pipeline was methane. He noted that longer chained hydrocarbons are commonly present in natural gas and these carbons are more likely to be liquid under certain ambient temperatures. Therefore, the threat to direct pollution of groundwater is largely dependent on the makeup of the natural gas content within the pipeline. MVP, LLC will need to clarify the specific contents of the gas to ensure that proper risks can be evaluated. Groundwater Hydrology Alteration of hydrology is another issue associated with impacts to groundwater from constructing a pipeline in karst. The Virginia DEQ expert interviewed expressed that during pipeline construction, blasting is a common practice and can cause turbidity in groundwater. Turbidity can lead to other problems such as sinkhole collapse when sediment resettles into fractures. He made it clear, however, that this risk is no different
  40. 40. P a g e | 37 than other construction activities that occur in karst such as the building of roadways. He has even seen well drawings cause strong turbidity in groundwater when installed in karst, using this example to emphasize that the risks are present regardless if it is a pipeline or something else. The VA Cave Board also highlights the impacts on groundwater hydrology from pipeline construction. Water in karst aquifers moves primarily through solution channels, making flow dependent on the direction and characteristics of these channels. Impacts from blasting to install a pipeline can alter solution channels causing the water to flow in different directions, which can result in the alteration of water quantity and quality (VA Cave Board, n.d.). The VA Cave Board states that if these hydrologic changes occur, it is very unlikely that previous groundwater conditions can be restored. Blasting can also affect groundwater recharge characteristics, but this is a concern both in karst and non- karst regions (VA Cave Board, n.d.). However, blasting does pose a greater risk of altering flow in surficial karst aquifers. Additionally, blasting can release soluble chemicals, such a nitrates and semi-volatile compounds, which can enter local surface or groundwater. This is a problem in both karst and non-karst regions as well, but as this report has previously discussed, pollutants in karst waters can travel quicker and relatively unfiltered (VA Cave Board, n.d.).
  41. 41. P a g e | 38 Trenching and Groundwater Protection Trenching for pipeline construction is a more common practice and will most likely be primarily utilized for the MVP where it is feasible to do so. Trenching presents less risk to groundwater than blasting. However, trenching can lead to diverted or ponded water that modifies natural pathways, potentially accelerating sinkhole development (VA Cave Board, n.d.). The VA Cave Board recommends the installation of water breaks on slopes to direct water away from flowing down the pipeline. Clay dams and collars can prevent the outer edge of the pipeline from acting like a conduit for water flow (VA Cave Board, n.d.). The ponding of water behind these dams remains a concern. Karst assessments and these best management practices can reduce some of the negative effects on water from trenching, but not eliminate them completely (VA Cave Board, n.d.). There are additional practices suggested by experts to reduce the chance of impacts to groundwater. Dr. Ewers, a prominent karst hydrogeologist, recommends groundwater tracing be done when considering the placement of a pipeline within karst terrain. This is because groundwater flow is often impossible to predict from simple geological data. The VA Cave Board also provides recommendations, including regular inspections for leaks and reporting of leaks, reducing the occurrence of the pipeline being in contact with groundwater, and the creation of mapped water flow studies (VA Cave Board, n.d.).
  42. 42. P a g e | 39 Risk, Threat, and Profit Losses To conclude this section on groundwater, it is important to emphasize the difference between risk and threat when it comes to groundwater in karst and pipeline construction. Research has revealed that while the risk to groundwater from pipeline construction is the same in both karst and non-karst regions, the threat is greater in karst due to the ability of its groundwater to rapidly carry pollutants far distances from the initial source of pollution. Additionally, several of our interviews emphasized that due to the profits and costs surrounding natural gas, companies maintaining these pipelines will try to construct in a way that minimizes the chance of leaks, therefore minimizing loss of profits. Natural gas lost from a pipeline results in the loss of company product available for consumer sales. The mining professor interviewed, with experience working in the energy industry, noted that the cost of natural gas production is currently high while the prices are generally low. He concludes that a company would more than likely implement the best technology such as automatic leak detection systems to prevent any loss of profits. It is in MVP, LLC’s best interest to follow expert recommendations presented here regarding groundwater to not only avoid profit loss, but to also protect a valuable community resource. Pipelines and Karst: Sinkholes and Caves Sinkholes Sinkholes, also referred to as dolines, are a prominent feature of karst topography in Virginia. The areas that would be affected by the MVP have naturally occurring sinkholes associated with karst terrain, as opposed to man-made. Sinkhole formation is a natural process in areas underlain by limestone and other soluble rock (VA DMME,
  43. 43. P a g e | 40 2014). However, the location and rate in which they form can be affected by human activities such as construction. Sinkholes are funnel-shaped or vertical sided depressions in the surface and form by the subsidence of unconsolidated materials or soils into voids created by the dissolution of the underlying soluble bedrock. In karst, sinkholes are input points where surface water enters the groundwater system, creating a concern for pollution (VA DMME, 2014). Issues with Sinkholes There are three main potential problems associated with sinkholes that the VA Division of Geology and Resources describes specifically. The first problem to consider is subsidence. Subsidence is a term used to describe a gradual sinking, but can also refer to an instantaneous collapse. Man-made activities that impact hydrology of an area can affect the rate of subsidence (VA DMME, 2014). The subsidence process is a concern because construction practices, including pipeline construction, can lead to drawdowns of the water table. Rapid or large drawdowns of the water table in these unconsolidated soils can lead to instant or catastrophic sinkhole collapse. Disposal of stormwater in sinkholes can also induce subsidence, while diverting water and allowing it to pond elsewhere may also accelerate sinkhole formation (VA DMME, 2014). As noted in the previous section, diverting water is a common practice with trenching, which makes avoiding impacts to subsidence difficult. Another problem associated with sinkholes is flooding. The flooding of sinkholes also happens naturally, but can be exasperated by human activity. The plugging of sinkhole drains by sediment and the overwhelming of these drains by increases in runoff due to artificial surfaces are the two main human-caused impacts (VA DMME, 2014).
  44. 44. P a g e | 41 Inadequate erosion control during construction can lead to the plugging of natural sinkhole drains. The restriction of subsurface drainage also causes an increase in flooding. Precipitation that would normally percolate through a vegetated soil cover ends up being introduced rapidly into the surface and subsurface drainage networks via sinkholes. In severe cases, excessive runoff can overwhelm natural subsurface drainage systems. An example of this occurred in VA in 1985 when a stream of water estimated with a peak flow of 50,000 gallons per minute was observed flowing from a normally dry sinkhole during a storm event (VA DMME, 2014). This example highlights the risk to the public and surrounding natural areas posed by overwhelmed drainage systems. Lack of proper erosion and sediment control, especially in karst, can lead to these issues. Pollution via sinkholes is another major problem to consider (VA DMME, 2014). Liquid wastes dumped into sinkholes can enter the groundwater system unfiltered through underground drainage conduits. If blasting for pipeline installation releases chemicals as noted in the previous section, these chemicals could enter sinkholes and rapidly percolate into the groundwater. The VA Department of Mines, Minerals, and Energy emphasizes that a poor understanding of karst and its associated features has led to land-use practices that create negative economic and environmental impacts to surrounding communities (VA DMME, n.d.). They note that although dramatic collapses of sinkholes in VA are rare, they have happened in the past. In Staunton in 1910, several homes and a firehouse were lost in a series of sinkholes and in 2001, a 45 foot deep chasm opened up around the same area. Additionally, in April 2000, 32 sinkholes were reported in the upper Shenandoah Valley following 7 inches of rain that fell after a dry spell (VA DMME, n.d.). This information
  45. 45. P a g e | 42 should serve as a warning that despite cover collapses being rare, the sensitivity of karst terrain to alteration should be taken seriously when considering pipeline construction. Induced Sinkhole from Pipeline Installation: West Central Florida A well-documented incident found in the research often cited by pipeline critics, occurred in Florida during the installation of a natural gas pipeline system. The pipeline was installed using horizontal directional drilling (HDD) methods (Smith & Sinn, 2013). The pipeline is a 36 inch wide pipeline, and therefore close in width to the proposed MVP. Researchers monitoring the pipeline’s effect on geological features noted that during the HDD process, significant ground vibrations occurred along with the formation of several ground settlement and collapse features (Smith & Sinn, 2013). The data collected during this study suggested that the erosion of weak zones in overburdened soils by the high pressure drilling and the erosion of weak, soil-filled conduits caused the rapid sinkhole formation that was observed (Smith & Sinn, 2013). The VA Cave Board, acknowledging this incident, describes HDD as a method that requires enormous “tip pressure” to advance the borehole and can cause a blowout of the soft soil and limestone typically found in the Florida region. The VA Cave Board does not recommend HDD in karst regions for this reason. It is also important to note that although the bedrock underlying karst terrain in VA varies, most of it is hundreds of millions of years old and therefore generally more structurally sound (VA Cave Board, n.d.). Although the incident in Florida provides a warning for pipeline construction and its potential effect on sinkhole development, it is essential to consider that the geographic setting, geological history, climate, and local environmental conditions vary from one karst region to another. Therefore transferring the risk found in one karst setting, such as
  46. 46. P a g e | 43 Florida, is not necessarily a valid assumption (VA Cave Board, n.d.). At the very least, the Florida study makes a cast against the use of HDD, which MVP, LLC initially stated intent to use, but has since retracted that decision (MVP, LCC, 2015). Unfortunately the HDD process, while causing problems in karst, does often reduce impact to stream crossings and wildlife. Damage, in this case, seems unavoidable. To conclude this section, an important issue regarding sinkholes was brought to our attention by Dr. Ewers, a karst hydrogeologist. He stated that during pipeline construction, it is not the known sinkholes that often present a problem, but the incipient (unknown) sinkholes that present a more prominent risk. It is therefore essential that MVP, LLC consider that the rapid subsidence of unknown sinkholes can serve as an unavoidable risk during construction. Sinkholes: A Community Concern In addition to the expert community, local community members with properties that will be impacted by the MVP have expressed concern over the potential effects on sinkhole formation. A community member, who we interviewed and whose property we surveyed, highlighted this concern for his own property. The community member lives in the Mt. Tabor region of Blacksburg and his property is currently affected by the presence of sinkholes. All proposed pipeline routes pass through this property. He expressed skepticism of MVP, LLC’s ability to construct a pipeline safely in sensitive karst terrain as they have promised because, according to him, they have failed to follow other promised procedures. This includes failing to send certified letters of intent to property owners for surveying, a problem that several community members have brought up. The concern here clearly shows that the trust placed in MVP, LLC to deal with karst features,
  47. 47. P a g e | 44 such as sinkholes, is lacking due to a previous and enduring lack of trust existing within the community. We will recommend at the end of this report that MVP, LLC take new, major steps in properly re-engaging the community. Caves Caves are a common feature in karst topography. As noted in the initial introduction, caves form when weakly acidic groundwater reacts with carbonate rock. Over time, larger spaces open in the rock filling with more acidic water as the rocks are dissolved (VA DMME, 2014). The caves are filled with water until the water table drops, at which point a cave stops growing in size. Cave formations begin to form in the remaining void spaces, and are also referred to as “speleothems” (VA DMME, 2014). Caves, both commercial (recreational) and noncommercial, are common throughout VA. The map below shows the commercial caves in the state. Figure 7. Commercial (Recreational) Caves in VA (Source: VA DMME, 2014)
  48. 48. P a g e | 45 Issues with Caves The main issues associated with pipeline construction and caves are public safety and habitat degradation. As previously stated in the report, gas can move along a karst conduit quickly just like water, in most cases as fast as a person can walk (VA Cave Board, n.d.). Although a natural gas leak may not pollute groundwater, the risk of leaks in the form of gas do threaten public safety. According to Dr. Ewers, karst hydrogeologist, vapors from gas leaks traveling through karst conduits have invaded homes and schools with explosive vapors. Caves present a major explosion hazard in this case depending where the source of the leak is located relative to the cave opening. When gas vapors travel through karst conduits and enter cave systems, they can come in contact with an ignition source leading to explosion or cause asphyxiation to cave explorers (VA Cave Board, n.d.). Dr. Ewers has also stated that traveling gas vapors entering caves in karst have “become explosion hazards that have killed exploring children and their rescuers.” These instances are rare, but do emphasize the importance of keeping natural gases out of caves and karst conduits. However, if there is a leak, the probability of being able to do so seems unfeasible given the characteristics of karst systems that have been described in this report thus far. Pipeline corrosion can also be a concern when assessing this risk for leaks. Some rock layers contain pyrites, and pyrite can cause the production of sulfuric acid. The acid accelerates the dissolution of limestone as well as pipeline corrosion (VA Cave Board, n.d.). Special sealants and the use of weak electrical currents can be utilized to reduce corrosion and it is recommended that MVP, LLC does so in order to protect public safety (VA Cave Board, n.d.). Another related concern is the contact of vapors with
  49. 49. P a g e | 46 groundwater in karst. Although the water would not directly be polluted by the gas, groundwater in contact with these vapors can result in fire or explosion hazards associated with well water use in homes. Habitat degradation is a possible issue associated with alteration of cave habitats. Diverting or modifying water flow in a karst system during pipeline construction can seriously harm sensitive cave organisms that are often only adapted to living in caves and nowhere else (VA Cave Board, n.d.). There are several threatened and endangered species that live in VA caves, including the Lee County isopod, Madison Cave amphipod, Madison cave isopod, and Holsinger’s cave beetle (VA Cave Board, n.d.). Additionally, at least 31 rare species have been catalogued within the caves of the New River watershed, which are pictured below in figure 8. Some of these rare species include bats and the Allegheny woodrat as well as other specialized invertebrates that only dwell within caves and can never leave their habitat (VA DCR, 2008). Aquatic cave species are also incredibly sensitive to groundwater contamination and scientists often examine these species to detect contamination levels. Bats are among the most prominent cave dwellers in VA caves, three species of which are on the Federal Endangered Species list (VA DCR, 2008). The bat population has suffered in VA and the concern over their populations has only heightened due to the presence of white-nose syndrome. This disease commonly affects bat populations and as of 2013, has been observed in every county in VA that contain limestone caves (VA DCR, 2013). Given this information, any major human activities in karst, such as pipeline installation, should give careful consideration of the sensitive habitats within caves. Slight changes in cave ecosystems can decimate a species.
  50. 50. P a g e | 47 Figure 8. Significant (federally regulated) Caves in the New River Watershed (Source: VA DCR, 2008) Caves as a Resource Caves should not only be looked at from a perspective of public safety and valuable habitat, but also as a source for economic benefits and cultural resources. Commercial activities in VA caves help support the state economy (VA Cave Board, n.d.). Karst and its caves are considered a valuable cultural resource and therefore protected by several laws and the VA Natural Heritage Karst Program. Laws that can apply to caves vary. The VA Cave Protection Act prohibits anyone from vandalizing cave formations and artifacts, polluting caves or disturbing cave organisms (VA DCR, 2008). The Federal Cave Resources Act is also an applicable law, recognizing the importance of caves to natural heritage and protecting them for proper uses. Because caves are considered a natural resource, they can also be protected under the Archeological
  51. 51. P a g e | 48 Resources Protection Act and the National Historic Preservation Act (National Park Service, 2013). Depending on the organisms that dwell within caves, they can also be protected by the Endangered Species Act and Clean Water Act (VA Cave Board, n.d.). MVP, LLC should consider these various laws and protections when deciding on the final pipeline route. MVP, LLC and Karst Mitigation MVP, LLC has issued an advertisement about karst topography and a preliminary karst mitigation plan via one of their resource reports. MVP, LLC describes the contracting of Draper Allen Associates, an engineering firm, which will survey the project’s route and associated karst features. The firm will also develop the formal mitigation plan for pipeline construction. The project manager from Draper, William Newcomb, has stated that they will analyze geologic documentation and conduct extensive field observations to identify sensitive karst features (MVP, LLC, 2015). MVP, LLC emphasized, while working with Draper, that they will implement additional measures to control water and sediment runoff in karst sensitive areas. The firm thus far has identified 30 miles of karst areas that will be impacted by the pipeline. Figure 9 below illustrates where the pipeline will be placed relative to karst locations in the New River watershed. A majority of MVP, LLC’s preliminary plan describes avoiding karst features where feasible and mitigating areas where the pipeline cannot avoid (MVP, LLC, 2015). Wil Orndorff, Karst Protection Coordinator for the VA DCR, has stated that “the pipeline companies’ strategies to protect karst features and groundwater sound good on paper and if the plans are followed the potential for contamination is pretty low. But the rubber will hit the road when the pipelines are being built (in reference to both the MVP
  52. 52. P a g e | 49 and Atlantic Coast Pipeline).” Acknowledging this comment, it is fair to assume that MVP, LLC’s plans to protect karst features described thus far will only work if they are followed exactly, meaning a significant amount of oversight may be necessary. Figure 9. MVP Route Affecting Karst in the New River Watershed (Source: VA DCR, 2008)
  53. 53. P a g e | 50 VII. Pipelines and Karst: Case Studies Comparative Analysis Sabal Trail Pipeline, Proposed The proposed Sabal Trail Pipeline Project has approximately 500 miles of 36- inch and 24-inch diameter pipeline, proposed in an area with primarily karst topography. Sabal Trail Transmission (ST) and Spectra Energy, have been evaluating proposed routes, design and construction methods and impacts to community members and the environment since June 2013. In their Draft Environmental Impact Statement, (DEIS) with regard to karst geology, the DEIS states that Sabal Trail will not significantly impact karst terrain, springs or the Floridian Aquifer with its construction or operations. This is up for debate, due to the fact that the US EPA has recently made the recommendation to FERC to reroute the pipeline away from the Floridian Aquifer, due to the karst topography that is extremely prone to sinkholes as well as the presence of wetlands. FERC originally found no evidence that sinkhole development poses a safety risk for the pipeline. Sabal Trail’s construction techniques and operation plans in karst areas were acceptable to FERC. In relation to the Mountain Valley Pipeline, the karst topography that is mainly throughout Florida’s coastline in this specific case-study is closer to sea-level and does not deal with the same amount of slope issues that the Mountain Valley Pipeline is facing. The Sabal Trail Project has more of a rolling-hills, flat plains, and lower-elevation region to deal with. In Florida, a notable karst area is the Cody Scarp, which is a karst escarpment that the proposed route crosses after entering Florida that coincides with the northern extent of the area where the Upper Floridian aquifer becomes unconfined. Due to the numerous sinkholes, sinking streams, siphons, springs, and other karst features extended along the length of the scarp, it is the most
  54. 54. P a g e | 51 sensitive area in Florida that the pipeline will traverse, as of now. A main takeaway from this case study is how site-specific karst geology has the potential to be, and how this type of geology requires extra attention and is the root of many pipeline debates. Comparing and contrasting the draft Karst Mitigation plans for these two proposed pipelines may be a possible precautionary step to take. Bluegrass Pipeline, stopped If Kinder Morgan’s proposal would have been approved, the 71 year old Tennessee Gas Pipeline would have carried Natural Gas Liquids (NGLs) through 13,000 miles of pipe from the fracking districts in Ohio and Pennsylvania to the gulf coast. The KURE petition asserted that natural gas liquids are not "oil or gas," nor are they "oil or gas products" as those terms are defined in the law. This detail was one of the key takeaways from this case study. KURE also made a point to emphasize the fact that interstate transportation of natural gas liquids by a pipeline through the state is not transportation of oil or gas products by legal definition of "in public service," therefore the pipeline is not a public utility regulated by the Kentucky Public Service Commission and could not be regarded as a public service. Courts ruled that Bluegrass Pipeline was a private, for-profit company that "is not acting in public service (Central KY News, 2015)." Natural gas liquids in an area of karst topography is extremely risky due to possibilities of leaks and ruptures. When relating this case study back to the MVP proposed project, it raises concern due to the lack of clarity in MVPs explanation of what is actually being proposed to travel through the pipeline. Risking deadly vapors settling in underground caves, the potential for corrosion that the weather throughout the route presents, and ignoring the risk of potential polluted water sources because of the
  55. 55. P a g e | 52 desire of avoiding potential legal actions could be absolutely detrimental to the environment and the area surrounding the MVP proposed route. As mentioned earlier, the filtration equipment stated to be inside of MVPs compressor stations have filtration and separation equipment only needed when longer chained hydrocarbons are present, which are carbons more likely to be liquid under ambient temperatures. The potential of accidental natural gas liquids traveling throughout the MVP should be carefully analyzed and dealt with, using this pipeline as an example of recognizing the potential danger to the karst, and the correct legal action being put forward using stated facts on what would actually be transported. Atlantic Coast Pipeline, proposed According to the 2014 Virginia State Energy plan, Virginia must create a regulatory and business environment that allows renewable energy development to prosper. A signal must be sent that Virginia is supportive of and enthusiastic about the role of renewable energy in the economy. Clean energy jobs are the next generation of employment opportunity. The U.S. Bureau of Labor Statistics’ Virginia green workforce estimates are skewed heavily to U.S. military and federal government employment. With these jobs removed, the Commonwealth’s green jobs concentration drops to an unremarkable 2.6 percent share of workforce, or roughly 100,000 people. Not having a properly trained and ready workforce has prevented some clean energy companies from moving their businesses to Virginia. With new technology and an emerging renewable energy field, Virginia should be a global leader and be ready to compete in this new Virginia economy. Virginia’s natural gas reserves were estimated in 2009 to be 3,091 BCF. Given current removal rates, this reserve would support production for about 22
  56. 56. P a g e | 53 years (VA DMME, 2014). Both of these proposed Virginia pipelines are facing major backlash from the public. Legal controversies are prevalent in both cases, due to the Virginia law that allows a pipeline firm to enter private property for survey work without permission, as long as request for permission to inspect and notice of intent to enter are sent to the intended property no less than 15 days before proposed entry, delivered by certified mail only (Adams, 2015). This study provided good insight on the desire of Virginia citizens with regards to pipeline concerns, and gave reasoning for emphasis on good public relations recommendations.
  57. 57. P a g e | 54 VIII. Recommendations and Conclusion Based on the research provided in this report, informed by secondary sources and expert interviews, we provide the following ten recommendations to FERC and MVP, LLC concerning the Mountain Valley Pipeline. We encourage that the approval and subsequent installation of the pipeline be contingent on these recommendations: 1. Conduct a programmatic EIS to assess the cumulative impacts of both the Mountain Valley Pipeline and Dominion (Atlantic Coast Pipeline) and evaluate the need/purpose of these pipelines and their impacts to the Central Appalachian Region. 2. Allow for third party oversight that is disaffiliated from MVP, LLC and its contractors to ensure that proper management practices, both during and following construction, and mitigation plans are being executed as promised by MVP, LLC. 3. Due to the communicated disdain from community members concerning MVP, LLC’s public outreach practices, we recommend the formation of a Community Engagement Plan by MVP, LLC to better address community members during the remainder of their pre-construction processes. 4. Development of a highly detailed Karst Mitigation Plan, which focuses on avoiding karst sensitive features (caves, sinkholes, groundwater recharge areas) and suggests rerouting techniques for the pipeline if needed. 5. Ensure that MVP, LLC also uses the Mountain Valley Pipeline to help supply local communities along the route with natural gas.
  58. 58. P a g e | 55 6. Require MVP, LLC to draft a plan and set aside funding for mitigation of the Mountain Valley Pipeline when it is no longer in service or if disaster occurs while in service. 7. Require MVP, LLC to issue a report, describing in specific detail, the contents that will be present within the pipeline to better assess potential threats to groundwater. 8. Implement severance taxes for EQT Midstream Partners, LP (part of MVP, LLC) on all natural gas extracted in West Virginia for the Mountain Valley Pipeline. 9. Advise local governments to implement impact fees in order to mitigate costs of development and reduce the economic strain on local jurisdictions. The amount of the impact fee imposed in each individual jurisdiction would vary due to the rational nexus test. 10. Create federal and state regulations on noise pollution emitted from compressor stations. We strongly believe that these recommendations are reasonably feasible for MVP, LLC and its associates to comply with. Negative environmental and economic impacts are more likely to be avoided with the implementation of these recommendations when considering the research presented in this report. The Mountain Valley Pipeline should not be approved unless these recommendations are fulfilled and strictly enforced.
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  63. 63. P a g e | 60 X. Appendix Expert and Stakeholder Interviews Geophysics professor, Virginia Tech. September 2015. Environmental Science professor, Virginia Tech. September 2015. Community members on Mt. Taber Rd. September 2015. Community members, Preserve Montgomery Country. September-October 2015. Mining Engineer and professor and energy researcher, Virginia Tech. October 2015. Virginia Department of Environmental Quality Groundwater specialist, October 2015. Energy Director at The Nature Conservancy, October 2015. Lead Scientist at The Nature Conservancy, October 2015. Virginia Cave Board Karst Protection Specialist, November 2015.

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