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.
Mountain Valley Pipeline, Analysis of Environmental Issues
The Mountain Valley
Pipeline: An Analysis of
Prepared by: Gabrielle Gonzalez, Jacqueline Tkac, Katie White
Prepared for Client: Dr. John Browder , UAP
December 11, 2o15 UAP 4354
Dr. John Browder
Thank you for helping us throughout the
duration of this project
Cover Photo: Allegheny Mountain Radio, Rick
Table of Contents
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
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
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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
Limited Liability Company
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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
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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
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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
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
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)
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
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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
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.
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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
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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.
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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
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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
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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
) or packing surrounding the mechanical compression components
) 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
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).
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).
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)
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substantial amount of emissions were observed at both operating and standby compressor
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
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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
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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
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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
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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
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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,
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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).
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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.
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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
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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
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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
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
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,
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
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)
Formula: Rupture probability = (number of ruptures / total length of pipelines) /number of years X pipe-
line length X 100% (Council of Canadians, 2015)..
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the pipeline protects the pipeline and its infrastructure from above ground damages,
including accidents (either natural or man-made). Also, the lateral9
by the surrounding soil reduces the seismic effects. Therefore, the performance of the
structure during seismic activity directly correlates to the geotechnical effects (Physical
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,
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)
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
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
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
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.
P a g e | 26
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
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
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,
Market economists use the term 'Green economy' to describe strategies that use market mechanisms to
counter environmental damage (The Green Economy, 2015).
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).
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
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).
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.
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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
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).
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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
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.
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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
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
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.
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
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.).
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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
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
Pipelines and Karst: Sinkholes and Caves
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,
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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
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).
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
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
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,
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 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)
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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
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.
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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
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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
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
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)
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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
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
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
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.
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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
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
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.
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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
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
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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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.