Reports and Comments to the FERC from ICWA and Others – We are currently updating this page with more information

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Dr. Ernst Kastning, university professor and renowned karst expert, prepared two reports about the implications of constructing the MVP through karst terrain. You can access them below:

  1. “An Expert Report on Geologic Hazards in the Karst Regions of Virginia and West Virginia, Investigation and Analysis Concerning the Proposed Mountain Valley Pipeline” (5mb pdf file), Ernst H.Kastning, Ph.D., P.G., July 2016.
  2. “Kastning Response to DEIS: Karst Features Visible on the Surface Are Not a Sufficient Measure of a Well-Integrated Flow System in the Subsurface. A Critical Analysis of Interpretation in the Draft Environmental Impact Statement Regarding the Proposed Mountain Valley Gas Pipeline,  Ernst H. Kastning, Ph.D., P.G, December 2016

Key points made by Dr. Kastning are that:

  • Karst by itself is a significant risk factor in siting a gas pipeline, especially one of this size.
  • Other significant hazards in the region include: land instability and steep slopes, weak soils, and seismicity (the pipeline passes through the center of the Giles County Seismic Zone).
  • When two or more of these factors are involved, the hazards are “compounded and exacerbated.”

His executive summary concludes that in this region: “… the karst and associated hazards constitute a serious incompatibility with the proposed pipeline. The effect of these threats on the emplacement and maintenance of the line, as well as the potential hazards of the line on the natural environment, renders this region as a ‘no-build’ zone for the project.”

Pam Dodds cover August 2016Pamela C. Dodds, Ph.D., Licensed Professional Geologist, prepared six reports assessing the impact of the MVP on watersheds in Monroe and Summers Counties. You can access them all below:

  1. The first Dodds report provided a preliminary assessment of impacts caused by construction of the MVP in Monroe and Summers Counties:“Hydrogeological Assessment of Watershed Impacts Caused by Constructing the Mountain Valley Gas Pipeline Through Summers and Monroe Counties, West Virginia,” Pamela C. Dodds, Ph.D., August 2016.In her report, Dr. Dodds, finds that “The MVP gas pipeline construction will require deforestation and blasting, both of which will reduce groundwater recharge and cause significant changes to the amount of groundwater available as a drinking water source, as well as to groundwater flow routes” As she explains how soil type, slope, depth to bedrock, karst, landslides, seismic activity and location can adversely headwater aquatic habitats, springs, wetlands, and stormwater discharge, she concludes that “cumulative adverse impacts will result from construction of a gas pipeline in the numerous watersheds of first order high gradient streams in Summers and Monroe Counties.”
  2. In December 2016, Dr. Dobbs made additional site visits to Monroe and Summers Counties to so that she could assess the impact of the proposed MVP pipeline through some of the subwatersheds in these two counties.

These site reports provide exactly the sort of empirical evaluations missing from the materials in the Draft Environmental Impact Statement for the Mountain Valley Pipeline. Dr. Dodds provides sufficient details on geological principles for the reader to fully understand their implications when they are subsequently applied to the particulars of each site. Her reports also make clear the cumulative impacts of stream crossings, excavation, and other construction activities on the accumulating sediments so damaging to the county’s water resources.


“The Proposed Mountain Valley Pipeline Jefferson National Forest Segment Cultural Attachment Report”[full report] (Jan. 2016), prepared for Tetra Tech, Inc. by Applied Cultural Ecology, LLC
[Introduction and Conclusions]

Key findings & issues:

  • The ACE report, conducted in response to a FERC request, identifies Cultural Attachment as a resource that exists beyond the boundaries of the JNF itself. However, this was just a preliminary study. More work is needed.
  • The Forest Service should request—and the FERC should agree—that the ACE study be expanded from ACE’s resource identification, to also include the MVP project impacts on that resource.
  • This Effects Analysis should be done by a Cultural Anthropologist—either ACE or another qualified firm or individual—for the same reasons that the Forest Service and FERC insisted that a Cultural Anthropologist be used for the resource identification.
  • The Effects Analysis should be completed before the issuance of the Draft Environmental Impact Statement, so that its results can be included in the comprehensive environmental analysis of the potential negative impacts of the MVP project on Cultural Resources in the project area.

Related comments to FERC: Richard Ettelson (Accession #20160524-0028); Border Conservancy, Save Monroe, et al. (Accession #20160505-5090)

keylog-image“Economic Costs of the Mountain Valley Pipeline: Effects on Property Value, Ecosystem Services, and Economic Development” [full report] (May 2016) Key-Log Economics, LLC.
[Executive Summary]
An 8-county study from Greenbrier County, WV to Franklin County, VA. Includes a county-specific report on Monroe’s Economy: What’s at Risk?”

Key findings: The MVP’s construction, operation, and presence would impose three types of costs that will impact residents, not MVP. Projected costs below are for Monroe County.

  • Property values – loss of property use and enjoyment; increased safety risks (for those on the ROW, in the “high consequence area” blast radius, and 1.4-mile wide evacuation zone); loss of beautiful views.
    • Property value lost (one-time cost): $3.7 to $4.5 million
    • Loss in property tax revenue (annual): $13,300 to $16,200
  • Ecosystem services – loss of the benefits we get from clean water for drinking, agricultural uses, food; good habitat for wildlife, etc., as well as the protection a healthy ecosystem provides from extreme events like floods and wildfire, invasive species.
    • Over the 2-year construction period (one-time cost): $3.6 to $13.0 million
    • Recurring every year for life of MVP (annual): $752,800 to $2.7 million
  • Economic development opportunity – loss of scenic, unspoiled quality of county, increased sense of danger, and environmental and property damage could discourage people from expanding businesses, visiting, relocating to, or staying in Monroe.
    • Annual loss of recreation tourism spending of $1 million
    • Annual loss of personal income of $567,800 from fewer retirees moving here

Read printable copies of comments that ICWA and other submitted to the FERC