Indian Creek Watershed Association

PO Box 711
Union, WV 24983
(304) 832-6331
Email: info@IndianCreekWatershedAssociation.org

December 21, 2018

ATTN: Commissioners Neil Chatterjee (Chairman), Cheryl A. LaFleur, Richard Glick,

Kevin J. McIntyre, Bernard L. McNamee

C/O: Ms. Kimberly D. Bose, Secretary

Federal Energy Regulatory Commission (FERC)
888 First Street, N.E.
Washington, DC 20426
(via e-filing)

RE: ICWA calls for a Project-wide Stop Work Order and Supplemental EIS based on MVP’s
Request for VARIANCE MVP-006 and MVP/FERC/USACE “Privileged Communication”,
FERC Docket 16-10-000

Dear Commissioners:

Indian Creek Watershed Association hereby submits the attached Comment and Supplemental
Information pertaining to MVP’s September 2018 Request for Project-wide Variance MVP-006 and
related “Privileged Communication” that took place among MVP, the FERC, and the US Army Corps
of Engineers (Accession No. 20180921-5229). Posted with this ICWA comment, we have attached
copies of MVP’s Request, the inter-agency “Privileged Communication”, and MVP’s “Vertical Scour
and Lateral Channel Erosion Analyses, Revised June 2018”.
These documents reveal substantive and procedural issues that call into question the veracity and
reliability of MVP’s certificated application. ICWA therefore calls on the FERC to issue a Project-wide
Stop Work Order and require a Supplemental Environmental Impact Statement that includes a full
and rigorous public review and comment period.

We ask that Ms. Bose please forward to the attention of the Commissioners and file accordingly.

Respectfully submitted,

Indian Creek Watershed Association Board of Directors

Howdy Henritz, President; Scott Womack, Vice President;
Judy Azulay, Treasurer; Nancy Bouldin, Secretary
 ICWA calls for a Project-wide Stop Work Order and Supplemental EIS.
MVP Request for VARIANCE MVP-006 and related “Privileged Communication”
provide admission and evidence of increased environmental risk and damage
caused by the lack of site-specific field-based analyses in MVP’s application.
ICWA questions FERC’s role in withholding vital information from the public.

On September 25, 2018, the FERC quietly approved a Project-wide Variance that allows MVP to
bury its 42-inch pipeline under stream crossings at shallower depths than those proposed and
reviewed in Its application and approved by the FERC. This action of profound consequence for
environmental and public safety was taken with only one day’s notice to the public, limited
prior communication with the US Army Corps of Engineers, and no known communication with
or input from the West Virginia and Virginia environmental regulatory agencies.
Indian Creek Watershed Association (ICWA) calls foul, both on the substance of Variance MVP-
006 and on the unconscionable delay and deception that has been carried out by FERC staff and
MVP in hiding MVP’s misinformation and unilateral plan changes from the public. A Project-
wide Stop Work Order and Supplemental EIS on the entire project is required, because Variance
MVP-006 is just the tip of the iceberg.
The problem of “constructability” surfaced for MVP when it finally had to look more closely at
the sites and streams under question, rather than its desktop analyses. This was precisely the
warning and complaint in more than three years of comments from experts, landowners,
environmental groups, and even staff at participating and consulting agencies—all calling for
more realistic, site-specific evaluations and plans.
Our streams, wetlands, forests, and farmlands in West Virginia and Virginia are now ground-
truth evidence of FERC’s folly in trusting MVP’s desktop analyses and one-size-fits-all permits.
They are suffering the “negative impacts” as FERC rubber-stamps MVP requests for
modifications and variances that overturn whatever Certificate protections stand in the way of
increasing construction speed and reducing costs. Meanwhile, literally hundreds of erosion and
control violations have been reported along the construction route, as mudslides slip down
steep slopes and muddy MVP water spews into streams and wetlands. 1
In its Request for Variance MVP-006, MVP acknowledges that its original error stemmed from
not having conducted site-specific analyses and plans. Yet, even in this Request transaction,
MVP refused a direct request from FERC’s lead environmental contractor to provide site-

1
As reported by the Roanoke Times, a lawsuit filed on Dec. 7, 2018 by Virginia’s Attorney General on behalf of the
VADEQ and State Water Control Board alleges that MVP has violated environmental regulations more than 300
times in Virginia. In addition, ICWA submitted 93 reports of violations committed by Mountain Valley Pipeline and
their contractors between Apr. 15 and Sept. 30, 2018 in a 25-mile segment of Monroe and Summers Counties, WV
(Accession No. 20181018-5009). The WVDEP has issued 20 Notices of Violation.
1
specific analyses and plans for each of the stream crossings where MVP anticipated needing to
bury the pipe at shallower depths and “mitigate” by monitoring. FERC chose not to push back.
To quote the phrase of the times: “Enough is enough!”
INTRODUCTION
On June 23, 2017 the FERC issued a Final Environmental Impact Statement (FEIS) for the
Mountain Valley Pipeline and on October 13, 2017 an order granting Mountain Valley Pipeline,
L.L.C. a Certificate of Convenience and Necessity (Certificate). The FERC order that granted MVP
permission to build its pipeline was based on assurances that the information submitted
concerning its crossing of 1108 waterbodies (FEIS Table 4.3.2-2) by MVP was correct and that
the FERC staff and third-party environmental contractor Cardno 2 had determined that the
pipeline would be built safely and without “environmental harm.”
Incorporated into the permit were certain plans including the “Vertical Scour and Lateral
Erosion Analysis, October 2016,” which was later revised February 2017. Multiple intervenors
submitted comments to the FERC Docket arguing that this plan and others were insufficient,
that the route and environmental analyses of the route were based on desktop analyses, and
that individual site evaluations and plans were required; ICWA in particular called for on-site
visits by FERC staff.
The submittal and approval of the Variance raise several issues that include but are not limited
to the Variance itself. Truth-be-told, Variance MVP-006 is not a “variance”. It is an audacious,
under-the-radar re-write of permit conditions that significantly reduces environmental
protections and public safety for water crossings along the entire 303-mile MVP route through
West Virginia and Virginia.
The presumption of the accuracy of MVP’s description of conditions was paramount to the
issuance of the FEIS and the Certificate. In order to comply with FERC’s requirement for
veracity, i.e., “to file all responses under oath,” on February 9, 2017 MVP submitted the first
part of its “Response to Post-Draft Environmental Impact Statement Environmental Information
Request Issued January 27, 2017” (Accession No. 20170209-5249).
In spite of these precautions, the June 2018 Revision shows that the Commission relied on
essentially worthless (and in many cases grossly inaccurate) information in issuing the FEIS and
Certificate, as admitted by MVP in its request for Variance MVP-006. Even now, in mid-
December 2018, there is no indication that the members of the Commission know that they
certified a project based on what amount to “bait and switch” tactics employed by MVP and
approved by a compliant FERC staff.

2 “Third-party contractors are selected by Commission staff and funded by Applicants. Third-party contractors
work solely under the direction of the FERC staff, who directs the scope, content, quality, and schedule of the
contractor’s work. The FERC staff independently evaluates the results of the third-party contractor’s work, and the
Commission, through its staff, bears ultimate responsibility for full compliance with the requirements of NEPA”
(FEIS I-5n) (emphasis added).
2
In late September 2018, almost a full four years after the public learned about the MVP
pipeline, MVP submitted the three documents discussed in this comment—MVP’s Request for
Variance MVP-006; communications between MVP, FERC, and the US Army Corps of Engineers
regarding the Variance; and MVP’s “Vertical Scour and Lateral Channel Erosion Plan, June 2018
Revision”. Taken together, they lead inexorably to the conclusion that the FERC should revisit
the Certificate through a Supplemental EIS and that it should issue a Stop Work Order until MVP
complies with the assurances that MVP made to the FERC and to the public in the application
that was ultimately certificated by the FERC.
In this comment, ICWA presents a summary of each of the three documents, provides a
discussion of what they reveal, and issues the following requests:

• ICWA calls for an immediate Stop Work Order along the entire route, not limited to
streams and wetlands.
• ICWA calls for the FERC to require a Supplementary Environmental Impact Statement
that includes a full and rigorous public comment period.
MVP’s Request for Variance MVP-006 exposes the fundamental failing of the FERC’s
environmental review and approval of the entire MVP application. Desktop analyses and
“trust us” assurances were accepted in lieu of rigorous field-based studies.
PART I: THREE SIGNIFICANT DOCUMENTS & COMMUNICATIONS BETWEEN MVP AND FERC
1. The Variance MVP-006 Request (EXHIBIT A): On Monday September 24, 2018 FERC
posted to the docket Mountain Valley Pipeline Variance Request No. MVP-006
(Accession No. 20180921-5228). Misleadingly calling it an “update”, MVP requested
permission to reduce the requirements for stream crossing procedures, excavation, and
depth of cover. Because the request covers the entire length of the MVP route, the
Variance allows MVP to change the pipeline burial depth of any stream crossing at any
time without submitting site-specific plans to the FERC or any other agency for review or
approval.3
Although MVP submitted the Variance on Friday September 21, 2018 at 4:52 p.m., the
public first became aware of it on Monday, September 24 when the FERC posted it to
the docket at 8:09 a.m. Approximately 25 hours later, at 9:46 a.m. on September 25, the
FERC approved Variance Request No. MVP-006, thereby granting MVP permission to
unilaterally revise its Vertical Scour and Lateral Channel Erosion and Analysis (Accession
No. 20180925-3015) without any opportunity for public review or comment.
Excerpt from MVP Variance Request Form with bold/underline added:
"Mountain Valley requests a variance to update two project plans. Attachment 1

3
Appendix B of MVP’s “Vertical Scour and Lateral Channel Erosion Analyses, Revised June 2018” (see EXHIBIT D)
presents data on “Potential Lateral Channel Erosion and Mitigation” for intermediate and major streams crossed
by MVP. Eleven of the first 20 streams in West Virginia and 3 of the first 4 streams in Virginia are asterisked as “a
sampling of streams” identified as potentially requiring the revised mitigation measure.
3
 includes the Vertical Scour and Lateral Channel Erosion and Analysis and the
Traffic and Transportation Management Plan. Changes are highlighted in yellow.
“The original Vertical Scour and Later (sic) Channel Erosion and Analysis was a
theoretical desktop analysis and did not take site specific constructability
issues (elevations, terrain, and workspace) into account. During its subsequent
field reviews, Mountain Valley determined that execution of the mitigation
measures, as written, would pose increased environmental or landslide risks,
or be unsafe or impractical due to terrain or geology. MVP also would not have
adequate workspace to store the soils required to meet the proposed burial
elevations. In the updated plan, Mountain Valley added another mitigation
measure of monitoring lateral channel erosion. The plan updates provide an
equal or greater level of environmental protection than the original measure.
Attachment 2 includes comments provided by the U.S. Army Corps of
Engineers regarding these updates.”
2. Privileged “Agency Correspondence” between MVP and the FERC: The List of
Attachments on page 1 of the MVP Variance Request Form included reference to
“Attachment 2 - Agency Correspondence (CUI//PRIV -- DO NOT RELEASE).” MVP
separately submitted this attachment on the Docket (Accession No. 20180921-5229,
Privileged).
In an attempt to obtain the information in Attachment 2, on September 27, 2018, ICWA
filed Freedom of Information Act (F.O.I.A.) requests at both the US Army Corps of
Engineers (USACE) and the FERC.
On October 24, 2018, ICWA received a copy of file FA18-184 Response MVP Scour.PDF
containing comments and correspondence between the USACE and MVP pertaining to
the Vertical Scour and Lateral Channel Erosion Analysis from the USACE (see EXHIBIT B).
On October 25, 2018, ICWA received an email from the FERC advising us that they
needed to extend the time period for responding because they needed to “consult with
other components of the agency having substantial subject-matter interest therein.“ On
November 9, 2018, ICWA finally received a copy of Attachment 2 (FERC Enclosure-FOIA-
2018-131) from the FERC, with Paul Freidman’s name redacted (see EXHIBIT C). 4
3. The Mountain Valley Pipeline “Vertical Scour and Lateral Channel Erosion Analyses,
Revised June 2018” (EXHIBIT D): This is a revision of the February 2017 Vertical Scour
and Lateral Channel Erosion Analyses (20170209-5249) which itself was a revision of the
2016 Version. The submittal of the February 2017 Vertical Scour and Lateral Channel
Erosion Analyses was in response to the FERC’s data request of January 27, 2017.

4
Note: The content of EXHIBITS B and C are identical, with the exception that Paul Friedman’s name is redacted in
EXHIBIT C and EXHIBIT B does not include a final email from DiSanto to MVP dated September 19, 2018. Unless
otherwise indicated, EXHIBIT C is the source for all page numbers in references to MVP-006 Attachment 2.
4
PART II: WHAT THESE DOCUMENTS & COMMUNICATIONS REVEAL
The three documents described above contain newly released information that contradicts
information submitted by MVP in its application and upon which the FERC relied in their
approval of the Certificate of Convenience and Necessity for MVP.
Information contained in The Variance Request Form (EXHIBIT A) shows that the June 29,
2017 FEIS and October 13, 2017 Certificate were approved on the basis of information that is
now known by the FERC and the public to be false. As stated by MVP:
“The original Vertical Scour and Later (sic) Channel Erosion Analysis was a theoretical
desktop analysis and did not take site specific constructability issues (elevations, terrain,
and workspace) into account. During its subsequent field reviews, Mountain Valley
determined that execution of the mitigation measures, as written, would pose increased
environmental or landslide risks, or be unsafe or impractical due to terrain or geology.
MVP also would not have adequate workspace to store the soils required to meet the
proposed burial elevations.”
In that one paragraph, hidden in one variance request, approved in one day by the FERC, MVP
finally admitted the truth of what citizens, hydrologists, geologists, soil scientists, and others
with scientific training posted in hundreds of comments on the FERC docket during the Pre-
filing, Draft EIS, and post-FEIS comments. The “theoretical desktop analyses” upon which MVP
based most of its application—not just for Vertical Scour and Lateral Channel Erosion, but for
virtually every environmentally significant hazard and challenge—were inadequate and
therefore both misleading and unreliable.
1. The FERC erred in accepting MVP’s application and post-application submittals
without requiring ground truth in spite of hundreds of comments by landowners and
other stakeholders who pointed out errors in MVP’s filings. ICWA not only requested
ground truth, but invited the FERC staff/DEP staff to perform site visits and assured
them that many landowners who refused entry to MVP contractors would welcome
FERC/DEP staff. For three years, ICWA, Thomas Bouldin, Dr. Pamela Dodds, Preserve
Craig, and others challenged claims made by MVP and the FERC as to the ability of MVP
to build the pipeline through the streams and rivers of this region without causing
increased erosion, sedimentation, and landslide risks. All of these comments were
ignored. Even as late as February 2017 in post-Certificate filings for which there was no
opportunity for public comment to be considered, MVP filed a revision to the Vertical
Scour and Lateral Channel Erosion Analysis of October 2016. With that filing, several
MVP staff members swore to the correctness of the document.
On the late date of September 24, 2018, the public finally learned the truth: There was
no ground truth. 5

5
Significant objections to Variance MVP-006 and the impropriety of its swift approval by FERC staff were filed by
Thomas Bouldin on September 25, 2018 (Accession No.20180926-5062).
5
 2. The FERC erred in allowing MVP to dismiss and over-rule the advice of FERC’s own
lead Environmental Contractor in approving Variance MVP-006 without individual
site-specific analyses. Information contained in the Privileged Communication shows
that MVP refused directives to provide a site-specific analysis or scenario for each
location that would receive mitigation under the revised Scour and Erosion Analyses and
the accompanying Request for Variance MVP-006.

On May 11, 2018, Senior FERC Cardno Consultant Lavinia M. DiSanto included the
following directive in her comments to MVP regarding the June 2018 revision to the
Scour and Erosion Analyses:
“Revise Appendix C to provide a site-specific scenario (such as was provided for
Second Big Run and Stony Creek) for each location that would receive mitigation
as described in section 5.2.2 versus mitigation as described in section 5.2.1”
(MVP-006 Attachment 2, p.7).
Given that the Scour and Erosion Analyses could potentially change the depth of burial
of the pipeline in every single one of the streams crossed by the pipeline, one would
have expected that MVP would have incorporated such site-specific information into
the June 2018 Revised Plan before it submitted it to the FERC for approval.
Instead, MVP blatantly dismissed Consultant DiSanto’s directive:
“MVP: Including a site-specific scenario for each location is excessive. We have
included in Section 5.2.2 that we will consult with the monitor before employing
this mitigation measure at additional streams” (MVP-006 Attachment 2, p. 4).
As for the FERC, as early as May 11, 2018 Consultant DiSanto was “…seeking additional
FERC comments” on the revision of the Analyses (MVP-006 Attachment 2, p. 6). Given
that the FERC’s Environmental Project Manager Paul Freidman was consulted about
MVP’s Plan before MVP submitted its June 2018 plan, one would have expected that he
would require MVP to follow the directions of the FERC’s own contractor. Instead
Environmental Project Manager Friedman, without providing justification for deviating
from Senior Consultant DiSanto’s recommendation, issued the Approval of the Variance
on September 25, 2018.
PART III: FERC’s APPROVAL OF MVP-006 DISREGARDS ACCEPTED ENGINEERING PRACTICES
AND ALLOWS MVP TO WEAKEN MITIGATION REQUIREMENTS
1. The FERC erred in allowing post-construction monitoring to substitute for mitigation.
There exists no regulation that would permit FERC to ignore industry standards and
accepted best management practices with regard to burial of pipes through streams.

a. Monitoring practices are no substitute for Best Management Practices (BMPs).

Individuals who are not professional engineers must not be allowed to substitute

6
 on-the-fly expedient pipeline burial techniques for those that have been
approved by engineers: “Mountain Valley may employ this measure for
additional streams based on further field measurements and studies and
consultations with relevant parties, including the geotechnical team, 6
environmental inspectors, and the FERC monitor.” (MVP reply to Consultant
DiSanto recommendation, p. 4)
i. The FERC did not require, nor did MVP submit, engineering drawings of
the two samples and the “additional streams” certifying that the amount
of scour and sedimentation caused by the shallower depths of burial of
the pipes will be within the limits of environmental or safety
requirements.
ii. The FERC did not require, nor did MVP submit, a detailed protocol for
identifying where the 'shallow burial' will be necessary.

b. Monitoring is not a substitute for mitigation. In substituting monitoring as a

management practice to control erosion and sedimentation, MVP admits that
reducing the depth of burial of the pipeline in streams increases scour,
sedimentation, and the risk of the pipe becoming exposed.
i. The FERC erred in allowing MVP to utilize “NMPs” (No Management
Practices) instead of BMPs, the accepted industry standards.
ii. Moreover, the FERC did not require any safeguards or impose any
oversight conditions to ensure that MVP will in fact monitor the project
as proposed.
iii. Looking to the future, high-intensity precipitation events are likely to
increase both vertical scour and lateral channel erosion, exposing MVP’s
reduced depth of burial to greater stress. There are no assurances that
the requisite monitoring will continue “in perpetuity” by MVP or by
whatever entity buys the pipeline from them.

2. The FERC erred in not requiring MVP to submit alternatives that would be within
industry standards (e.g., moving the soil to upland areas, boring under streams, etc.)
to prevent erosion and sedimentation: MVP controls hundreds of acres of land in WV
and VA through its lease of construction rights-of-way and temporary and permanent
workspaces where pipeline construction crews operate multiple pieces of heavy
equipment that tear up the earth in each spread. That equipment could easily move the
spoil away from the stream crossing to an upland location along the already existing
LOD. Such an action would not even necessitate a variance. Instead, the FERC approved
the Variance within one day of public notice.

6No indication is given by MVP about the composition and/or qualifications of the referenced “geotechnical team”
or how many such teams would be making these independent, “extra-Certificate” plan modifications.
7
3. The FERC erred in failing to realize that the Request for Variance MVP-006 was a thinly
veiled attempt to evade appropriate public review of a significant change to the
Certificate-approved permit conditions for MVP construction and to decrease costs,
likely in order to allay shareholder fears. The Variance MVP-006 Request Form claims
that the rationale for needing the variance was that the theoretical desktop analysis was
inadequate. However, MVP’s refusal to provide the on-the-ground site-based
information recommended by Ms. DiSanto shows the insincerity of MVP’s justification.

Coincidentally perhaps, on the same date as MVP submitted this variance to the FERC,
the following information about EQT’s financial picture was posted:
“In a revised estimate announced this week, the developers of the natural gas
pipeline said they now expect to spend $4.6 billion on the project, a jump of
about 25 percent over their previous calculation of $3.7 billion.” (“Estimated
Cost of Mountain Valley Pipeline Increased to $4.6 Billion,” Laurence Hammack,
Roanoke Times, September 25, 2018)
How much money will MVP save by decreasing the depth of burial of the pipes? The
Clean Water Act prohibits an entity to use the potential of increased financial costs to
justify its being allowed to cut back on water pollution controls. It is disingenuous for
MVP to pretend that they wouldn’t be able to move the soil with their own equipment
to their own ROW and workspaces and for them to claim that a decrease in depth of
pipe burial is necessary to protect the environment.
Even if environmental conditions at some crossings suggest that it might be preferable
to “maintain a minimum depth of cover” instead of “maintain the burial elevation” of
the pipe, these crossings should have been revealed during the application process and
all such proposed modifications accompanied by detailed engineering plans approved
by the ACE or DEP. MVP’s cavalier and dismissive replies to Ms. DiSanto that site-specific
analyses are “excessive” and that “we will consult with the monitor before employing
this mitigation measure at additional streams” are an affront to both the FERC and the
public.
What if MVP had been required in its application process, through the site-specific
analyses called for by the public, to acknowledge that it would be unable to comply with
standard recommended burial depths for many of the streams along its path? Perhaps
FERC and other agencies would not have been so acquiescent in approving MVP’s
proposed route and project plans.

8
PART IV: US ARMY CORPS OF ENGINEERS’ COMMENTS RAISE ISSUES OF JURISDICTION AND
THE INADEQUACY OF MVP INFORMATION
Correspondence of the USACE raises serious unaddressed issues about jurisdiction and, even
more important, about the inadequacy of information provided by MVP for the agency to make
a determination.
1. The FERC erred in ignoring a USACE comment that “[t]hese actions would fall outside
the jurisdiction of the Corps” and the implications for the WVDEP and VADEQ in
enforcement of erosion and sedimentation controls.

On July 17, 2018 Consultant DiSanto asked the Norfolk and Huntington Districts of the
Army Corps of Engineers whether they had any comments or suggested revisions to the
June 2018 revised Scour and Erosion Plan. Emails from the USACE were included in the
Privileged Attachment 2 (EXHIBIT C) and are reprinted below.
September 5, 2018 email from Todd Miller, Western Virginia Regulatory Division, Norfolk
District US Army Corps of Engineers to Lavinia DiSanto, cc. Paul Friedman (FERC),
Douglas Mooneyhan (Cardno):
Lavinia,
I have reviewed the updates to the Scour and transportation plan. These actions
would fall outside the jurisdiction of the Corps, however a failure in erosion
and sediment control could potentially impact waters of the U.S. including
wetlands. MVP’S “Patrol After Installation” Plan appears to be adequate enough
to stop and remediate any issues prior to impacting waters or wetlands. Thank
you for the opportunity to comment (emphasis added).
Todd Miller, Western Virginia Regulatory Section
While stating his belief that the actions in Variance MVP-006 would “fall outside the
jurisdiction of the Corps,” Miller nevertheless warns of potential negative impacts that
could be caused by failure in erosion and sedimentation controls.
If the responsibility falls outside the jurisdiction of USACE, one would expect the FERC
would have provided VADEQ and WVDEP the opportunity to comment since the state
agencies could bear a heavier burden in enforcing their Erosion and Sedimentation
regulations given the changes anticipated by Variance MVP-006. There is no evidence
afforded to the public either in the privileged communication, in the Revised Scour and
Erosion Plan, or in the Request for Variance MVP-006 that indicates involvement of
either State’s environmental regulatory agencies in the decision to approve the plan.

9
2. The FERC erred by ignoring the Huntington District ACE comment citing insufficient
information to allow a reasoned decision on Variance MVP-006.
Most significant perhaps is the response of the Huntington District on September 19,
2018. Email from Christopher Carson, USACE Huntington District, contradicts Todd
Miller’s opinion that the “Patrol After Installation” Plan appears to be adequate. As seen
in the email below, Carson cited the failure of MVP to provide any information upon
which the Corps could determine whether or not Variance MVP-006 would comply with
the USACE regulations.
September 19, 2018 email from Christopher Carson, USACE Huntington District, CELRH.
to Lavinia DiSanto, Todd Miller, cc. Paul Friedman (FERC), Douglas Mooneyhan (Cardno):
Lavinia,
The Huntington District has reviewed the submitted report. Mountain Valley
proposes to use a variety of mitigation strategies to prevent scour from affecting
the proposed MVP at certain waterbody crossings. The report includes changes
to the February 2017 version. No information is provided indicating whether
any of the changes would result in additional discharges of dredged and/or fill
material into waters of the United States (emphasis added).
Very respectfully, Christopher Carson, Project Manager, Programs & Project
Management Branch, USACE, Huntington District, CELRH
Consultant DiSanto instructed MVP senior personnel to inform the FERC of the
Huntington District’s comment.
September 19, 2018 email from Lavinia DiSanto to Matthew Eggerding (MVP), Philip
Veneziano (MVP), Megan Neylon (MVP) cc. Paul Friedman (FERC), Douglas Mooneyhan
(Cardno):
Hi All,
Below is the email the FERC received from Mr. Carson. Please include this email
and Mr. Miller’s email in your variance request.
Lavinia DiSanto
While submitting no additional information to the USACE, two days later, on September
21, MVP filed on the docket its Request for Variance MVP-006 and its 2018 Revised
Scour and Erosion Plan; and two working days after that, on September 25, the FERC
approved the Variance and the Plan.

10
PART V: WHY DID FERC AND MVP WITHHOLD CRUCIAL INFORMATION FOR SO LONG?
1. When did the FERC know that MVP had submitted erroneous information about the
stream crossings in West Virginia and Virginia?
The email stream shows that the FERC had knowledge of this fact before May 11, 2018.
The May 11 email from FERC Consultant DiSanto to MVP Supervisor Environmental
Permitting Megan Neylon stated, “Our apologies on the delay with these comments.
We were seeking additional FERC comments” (emphasis added). (EXHIBIT C, p. 13.)

Agency correspondence also reveals communication with the USACE as early as July 12,
2018. A July 12 email from Consultant DiSanto to Christopher Carson and Todd Miller at
the USACE, cc Paul Friedman, stated, “Mountain Valley has provided to the FERC a
preliminary copy of revisions they wish to make to their Vertical Scour and Lateral
Channel Erosion Plan (attached). Mountain Valley has already revised the document to
incorporate the FERC’s comments. Please let us know if U.S. Army Corps of Engineers
has any comments or suggested revisions” (emphasis added). (EXHIBIT B, p. 5.)
2. Why did the FERC allow three months to pass before the public was informed of new
material information that revealed MVP’s previously submitted information
concerning stream crossings was false?
Significantly, even once the June 2018 Revised Vertical Scour and Lateral Erosion
Analysis was completed, MVP did not place it on the docket until Sept 21, 2018.7

Not only did the FERC cooperate with MVP to keep the documents from being seen by
the public, but more nefarious was the FERC’s attempt (literally) to “cover up” the fact
that the FERC knew that the information was inaccurate at least three months before
that information was released to the public. In response to its FOIA requests, ICWA
obtained one response from the USACE on October 24, 2018 and a separate response
from the FERC on November 9, 2018. The documents were identical except that the one
received from the FERC redacted 8 Paul Friedman’s name from the “cc” line in two
locations. In other words, the FERC attempted a cover-up with black ink. Clearly the
FERC did not want the public to know about the depth of the collusion.

7
September 25, 2018 email from FERC Environmental Project Manager Paul Friedman to Judy Azulay: “You are
correct the Scour Analysis was filed by MVP on 9-21-18 in Accession No. 20180921-5228 – apparently not
previously.”
8
According to FERC Office of External Affairs, “The document is being released in full with the signature of
landowners and identity of lower level staff redacted pursuant to FOIA Exemption 6, which protects ‘personnel and
medical files and similar files the disclosure of which would constitute a clearly unwarranted invasion of personal
privacy.’” (EXHIBIT C, Determination Letter-FOIA-2018-131)
11
 3. Had this information been made public when it was first known by the FERC, what
impact might it have had on legal challenges to the Certificate and crucial stream-
related permits in West Virginia and Virginia?
According to the inter-agency communication documents described above, both the
FERC and its Environmental Contractor Cardno were aware of the new information and
proposed “revisions” by at least May 11, 2018. The revised MVP “Vertical Scour and
Lateral Channel Erosion Analyses” was dated “June 2018”. The Army Corps of Engineers
was aware of the new information and proposed revisions by July 11, 2018. Several legal
cases brought by organizations in opposition to the issuance of Certificate were
adjudicated between May 11 and the September 24 release of the revised scour and
erosion analysis to the public (including the plaintiffs in those cases). Among these:

a. The FERC Commissioners announced their decision to deny or dismiss all

Requests for a Rehearing on the MVP project on June 15, 2018.
b. On June 21, 2018 the U.S. Court of Appeals for the Fourth Circuit issued a stay of
the US Army Corps of Engineers Huntington District Nationwide Permit 12 for
MVP. On August 30, 2018 the Court granted a Motion by MVP to lift the stay and
effectively allowed in-stream construction activity pending oral arguments on
September 28.
c. The Virginia State Water Control Board met on August 21, 2018 to consider
revoking MVP’s 401 Certificate because of environmental damage due to erosion
and sediment control failures, stopping short of revoking the permit but calling
for aggressive environmental oversight instead.9
d. The Fourth Circuit Court of Appeals heard oral arguments on the Nationwide
Permit 12 case on September 28, 2018, and VACATED in its entirety, the Corps’
verification of the Pipeline’s compliance with NWP 12 on Oct 2.
The Timing of MVP’s Request for Variance 006 is suspiciously coincidental. Why, after
keeping the Revised Analyses from public view for three months, did MVP finally choose
to submit the Revised Analysis on September 21, 2018, just one week before the
conclusion of legal arguments at the Fourth Circuit Court of Appeals? Did MVP wait until
this last minute before requesting approval so that it would be “shovel ready” for
shallow pipeline burial if the Fourth Circuit issued an opinion allowing construction to
proceed?

9
At its December 13, 2018 meeting, the Virginia State Water Control Board voted 4-3 to initiate the formal hearing
process to consider revoking the 401 Certification of MVP. The motion was made in response to extensive public
comment regarding the ongoing damage being done by the Mountain Valley Pipeline’s construction through
Southwest Virginia.
12
CONCLUSION
The presumption of the accuracy of MVP’s description of conditions was paramount to the
issuance of the FEIS and the Certificate. In order to comply with FERC’s requirement for
veracity, i.e., “to file all responses under oath,” On February 9, 2017 MVP submitted the first
part of its “Response to Post-Draft Environmental Impact Statement Environmental Information
Request Issued January 27, 2017” (Accession No. 20170209-5249). Included in MVP’s Response
were verifications executed by the respondents, including Ricky Myers, Engineering Manager,
Megan Neylon, Supervisor Environmental Permitting, Shawn Posey, Senior Vice President-
Construction and Engineering.
Each of them submitted a sworn statement attesting that they had read and were familiar with
MVP’s responses to the Commission’s January 27 data requests, and “that the contents of the
responses are true and correct to the best of [his or her] knowledge, information and belief.”
In spite of these precautions, the June 2018 Revision shows that the Commission relied on
essentially worthless (and in many cases grossly inaccurate) information in issuing the FEIS and
Certificate, as admitted by MVP in its request for Variance MVP-006. Even now, in mid-
December 2018, there is no indication that the members of the Commission know that they
certified a project based on what amount to “bait and switch” tactics employed by MVP and
approved by a compliant FERC staff.
In late September 2018, almost a full four years after the public learned about the MVP
pipeline, MVP submitted the three documents discussed in this comment—MVP’s Request for
Variance MVP-006; communications among MVP, FERC, and the US Army Corps of Engineers
regarding the Variance; and MVP’s “Vertical Scour and Lateral Channel Erosion Plan, June 2018
Revision”. Taken together, they lead inexorably to the conclusion that the FERC should revisit
the certificate through a Supplemental EIS and that it should issue a Stop Work Order until MVP
complies with assurances that MVP made to the FERC and the public in the application that was
ultimately certificated by the FERC.
ICWA calls on the FERC, even at this late date, to fulfill its responsibility on the Mountain
Valley Pipeline project:
1. FERC must issue an immediate Stop Work Order along the entire route, not limited to
streams and wetlands. The fact that MVP admits the deficiencies in its use of a
theoretical desktop analyses in its stream crossing analyses should alone automatically
trigger a call for a Stop Work Order until it can provide ground truth on the crossing of
all streams on the pipeline route: “The original Vertical Scour and Later (sic) Channel
Erosion and Analysis was a theoretical desktop analysis and did not take site specific
constructability issues (elevations, terrain, and workspace) into account. During its
subsequent field reviews, Mountain Valley determined that execution of the mitigation
measures, as written, would pose increased environmental or landslide risks, or be
unsafe or impractical due to terrain or geology.”

13
 Importantly, streams are not the only locations where FERC has allowed MVP to submit
only desktop analyses. Since April 2018, the ground truth of failed Erosion and
Sedimentation controls where BMP’s were posited to protect the environment
demonstrates that the FERC should issue a Stop Work Order in order to arrest all
pipeline construction until they can determine what other non-stream “mitigation
measures, as written, would pose increased environmental or landslide risks, or be
unsafe or impractical due to terrain or geology.”
2. FERC must require a Supplementary Environmental Impact Statement that includes a
full and rigorous public comment period. The information contained in the three
documents reveals that what MVP submitted as Variance MVP-006 is not actually a
“variance”. It is a behind-the-scenes post-Certificate re-write of the permit conditions
that also reveals MVP’s blatant sense of empowerment to refuse a direct request for
site-specific calculations and plans by FERC’s lead environmental contractor.
3. MVP’s Request for Variance MVP-006 exposes the fundamental failing of the FERC’s
environmental review and approval of the entire MVP application. Desktop analyses
and “trust us” assurances were accepted in lieu of rigorous field-based studies.
Three hundred miles of beloved mountains, valleys, streams, farms, and communities have paid
a steep and painful price for the FERC’s misplaced trust. It is time to hold MVP accountable.

With respect for the mission of the Federal Energy Regulatory Commission,
Indian Creek Watershed Association Board of Directors
Howdy Henritz, President; Scott Womack, Vice President;
Judy Azulay, Treasurer; Nancy Bouldin, Secretary

14
 Exhibit  A  
MVP  Variance  Request  Form  
 For  MVP-­‐006  
20180921-5228 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

MVP Variance Request Form Variance Request

No.: MVP-006
Date Approval Requested by Contractor:
Date Submitted by Chief Inspector to LEI:
Date Received by FERC:
FERC Approval Reference No.:
Project Variance
Requested By: Jeff Klinefelter Spread: Wide Type: PM
Variance Sequence
Request Prepared By *: Megan Neylon Number: MVP-006
* The FERC compliance monitor should be alerted and given a copy of the draft variance for review prior to submittal
Location (Use either Station or Milepost)

Station: Project Wide To: Milepost: To:

Alignment Sheet Number: N/A Tract No.: All

Other Agency
None
Current Land Use/ Vegetative Cover: All Jurisdiction:
Nearby Features (Water body, T&E Habitat, Wetland, Noxious Weed Area, Residence
Yes No
(distance), Cultural Resource Site (distance) etc.): In or w/in 50 feet of a wetland:
Noxious Weed Area Raptor Nest Residence (Distance) In or w/in 50 feet of a waterbody: Yes No
T/E Species Habitat Cultural Resource Site Water Well Site Specific
Wetland or Waterbody ID:
Other (Specify):
Site Specific
Additional Stream footage
impacted: None Additional Wetland impacts: N/A
Net acreage affected: N/A
Tree Clearing Acreage of tree
Required: N/A clearing: N/A

Level 1 Level 2 Level 3

Variance Level:
Variance From: Permit Plan Procedures EPPM Specification Drawing Mitigation Measure
Line List Other: Describe:

Detailed Description of Variance: Attachments? Yes No Photos? Yes No

Mountain Valley requests a variance to update two project plans. Attachment 1 includes the Vertical Scour and Lateral
Channel Erosion and Analysis and the Traffic and Transportation Management Plan. Changes are highlighted in yellow.

The original Vertical Scour and Later Channel Erosion and Analysis was a theoretical desktop analysis and did not take site-
specific constructibility issues (elevations, terrain, and workspace) into account. During its subsequent field reviews, Mountain
Valley determined that execution of the mitigation measures, as written, would pose increased environmental or landslide
risks, or be unsafe or impractical due to terrain or geology. MVP also would not have adequate workspace to store the soils
required to meet the proposed burial elevations. In the updated plan, Mountain Valley added another mitigation measure of
monitoring lateral channel erosion. The plan updates provide an equal or greater level of environmental protection than the
original measure. Attachment 2 includes comments provided by the U.S. Army Corps of Engineers regarding these updates.

In the Traffic and Transportation Management Plan, Mountain Valley revised the central point of command for construction
traffic route plan. Traffic coordinators will now be reporting to the construction directors with oversight from our safety program
manager. The plan update provides an equal or greater level of safety than the original measure.

List Attachments: Attachment 1 - Updated Plans; Attachment 2 -Agency

Correspondence (CUI//PRIV -- DO NOT RELEASE)
20180921-5228 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Variance Justification:
See description above.

For MVP Use Only

Additional Surveys
Additional Surveys Required Surveyed Corridor Description
Completed
Yes No N/A Yes No
Cultural Survey
Yes No Yes No
T & E Survey
Yes No Yes No

Waterbodies/Wetlands
Proof of Previous Biological and Cultural Survey Clearance
N/A

Landowner:
Land Agent Contact
Landowner Approval Yes No
Obtained

Sign Off: Name Signature Date

Construction Manager Jeff Klinefelter Jeff Klinefelter 9/19/2018
Lead Environmental Inspector n/a
Third Party Compliance Manager or
n/a
monitor
ROW Land Agent * n/a
Environmental Supervisor Megan Neylon Megan Neylon 9/19/2018
*signature denotes confirmed landowner approval
20180921-5228 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

For FERC Compliance Monitor and Compliance Manager Use Only

Variance Approved: Variance Denied: Beyond Authority:
Signature:
Date:

Stipulations:

Spread No.: Project Wide Variance Request No.: MVP-006

VARIANCE CONDITIONS
Name: Title: Organization:
Conditions:

Name: Title: Organization:

Conditions:

Name: Title: Organization:

Conditions:
 Exhibit  B  
US  Army  Corps  of  Engineers  Response  to  
FOIA  request  by  ICWA  

FA18-­‐184  RESPONSE  MVP  SCOUR.PDF  

Response  to  FOIA  request  by  ICWA  to  US  Army  Corps  of  Engineers  for  
“Copies  of  those  comments  and  all  other  correspondence  between  the  
USACE  and  MVP  that  pertain  to  MVP's  Vertical  Scour  and  Lateral  
Channel  Erosion  Analysis”  
Gmail - FA-18-0184_Response (UNCLASSIFIED) https://mail.google.com/mail/u/3?ik=6dc71b9f25&view=pt&search=...

Indian Creek Watershed Association <indiancreekwater@gmail.com>

FA-18-0184_Response (UNCLASSIFIED)
1 message

Wed, Oct 24, 2018 at 10:19

Belcher, Billi A CIV USARMY CELRH (US) <Billi.A.Belcher@usace.army.mil>
AM
To: Indian Creek Watershed Association <indiancreekwater@gmail.com>

CLASSIFICATION: UNCLASSIFIED

Ms. Azulay,

This is in response to your FOIA request received in our office on 27 September 2018, in which you requested.
"Copies of those comments and all other correspondence between the USACE and MVP that pertain to MVP's
Vertical Scour and Lateral Channel Erosion and Analysis."

Please find attached the documents responsive to your request.

Pursuant to the FOIA, we are required to charge for the direct cost of processing the request unless the total is
$15.00 or less. Since the cost of processing this FOIA request is less than $15.00, there are no assessable fees.

Please do not hesitate to contact me if you have any questions.

Thank you,

Billi Anne Belcher

Paralegal Specialist / FOIA Officer
U.S. Army Corps of Engineers
Huntington District
Office of Counsel
502 Eighth Street
Huntington, West Virginia 25701-2070
Telephone: (304) 399-5889
Cell: (304) 654-3410
Facsimile: (304) 399-5154
E-mail: billi.a.belcher@usace.army.mil

CLASSIFICATION: UNCLASSIFIED

FA18-184 RESPONSE MVP SCOUR.PDF

3108K

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers
 FA18-184 RESPONSE MVP SCOUR.pdf

From: Carson, Christopher L CIV USARMY CELRH (US)

To: Hoover, Matthew S.; ROBINETTE, Lee A CIV USARMY CELRH (US)
Cc: Neylon, Megan; Spagna, Teresa D CIV USARMY CELRH (US)
Subject: RE: Revised MVP Plans - Scour and Transportation
Date: Wednesday, September 19, 2018 9:05:00 AM

Hi Matt,

A response was provided to the FERC today.

Very respectfully,

Chris

-----Original Message-----
From: Hoover, Matthew S. [mailto:MHoover@eqt.com]
Sent: Wednesday, September 19, 2018 6:27 AM
To: Carson, Christopher L CIV USARMY CELRH (US) <Christopher.L.Carson@usace.army.mil>; ROBINETTE, Lee
A CIV USARMY CELRH (US) <Lee.A.Robinette@usace.army.mil>
Cc: Neylon, Megan <MNeylon@eqt.com>
Subject: [Non-DoD Source] Re: Revised MVP Plans - Scour and Transportation

Good morning Lee & Chris,

I just wanted to follow up on the email below.  Would it be possible for the Huntingdon District to provide a response
on the Scour report to the FERC this week?

Thanks,
Matt

> On Sep 11, 2018, at 1:02 PM, Hoover, Matthew S. <MHoover@eqt.com> wrote:
>
> Chris/Lee,
> The FERC is looking for a response from the Huntington District concerning the Scour and Transportation report.  I
was hoping you could provide a response, similar to what Todd from Norfolk sent to Lavinia.
>
> Chris, during our last conversation, it was my understanding that you had the same opinion about how the actions fall
outside of the USACE's jurisdiction.  Is there any chance you could provide an update to Lavinia?  This has become a
pressing issue within the FERC and I'm hoping we can wrap this up within the next couple of days.
>
> Let me know if you have any questions.  I can be reached any time at 412.258.5627.
>
> Thanks,
> Matt
>
>
> -----Original Message-----
> From: Miller, Todd M CIV USARMY CENAO (US) [mailto:Todd.M.Miller@usace.army.mil]
> Sent: Wednesday, September 05, 2018 4:15 PM
> To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com>
> Cc: Paul Friedman <Paul.Friedman@ferc.gov>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
> Subject: RE: Revised MVP Plans - Scour and Transportation
>
> Lavinia,
>
> I have reviewed the updates to the Scour and transportation plan.  These actions would fall outside the jurisdiction of
the Corps, however a failure in erosion and sediment control could potentially impact waters of the U.S. including
wetlands.  MVP's "Patrol After Installation" Plan appears to be adequate enough to stop and remediate any issues prior

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 1
 From: Carson, Christopher L CIV USARMY CELRH (US)
To: Lavinia DiSanto; Miller, Todd M CIV USARMY CENAO (US)
Cc: Paul Friedman; Douglas Mooneyhan
Subject: RE: Revised MVP Plans - Scour and Transportation
Date: Wednesday, September 19, 2018 8:59:00 AM

Lavinia,

The Huntington District has reviewed the submitted report.  Mountain Valley proposes to use a variety of mitigation
strategies to prevent scour from affecting the proposed MVP at certain waterbody crossings.  The report includes
changes to the February 2017 version.  No information is provided indicating whether any of the changes would  result
in additional discharges of dredged and/or fill material into waters of the United States.

Very respectfully,

 Christopher L. Carson
Project Manager
Programs & Project Management Branch
USACE, Huntington District, CELRH
502 Eighth Street
Huntington, WV  25701
304-399-5819
Christopher.l.carson@usace.army.mil 

-----Original Message-----
From: Lavinia DiSanto [mailto:Lavinia.DiSanto@cardno.com]
Sent: Tuesday, July 17, 2018 2:27 PM
To: Carson, Christopher L CIV USARMY CELRH (US) <Christopher.L.Carson@usace.army.mil>; Miller, Todd M
CIV USARMY CENAO (US) <Todd.M.Miller@usace.army.mil>
Cc: Paul Friedman <Paul.Friedman@ferc.gov>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject: [Non-DoD Source] RE: Revised MVP Plans - Scour and Transportation

Hi Chris and Todd,

Mountain Valley has provided to the FERC a preliminary copy of revisions they wish to make to their Vertical Scour
and Lateral Channel Erosion Plan (attached).  Mountain Valley has already revised the document to incorporate the
FERC’s comments.  Please let us know if U.S. Army Corps of Engineers has any comments or suggested revisions. 
Thank you.  

Lavinia M. DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1 302 395 3340  Fax +1 302 395 1920 Address 121 Continental Drive Suite 308, Newark , DE 19713
Email lavinia.disanto@cardno.com <mailto:lavinia.disanto@cardno.com>   Web Blockedwww.cardno.com
<Blockedhttp://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s). All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying of
the information contained in this email and its attachments is strictly prohibited. If you have received this email in error,
please email the sender by replying to this message and immediately delete and destroy any copies of this email and any

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 2
 From: Hoover, Matthew S.
To: Carson, Christopher L CIV USARMY CELRH (US); ROBINETTE, Lee A CIV USARMY CELRH (US)
Cc: Neylon, Megan
Subject: [Non-DoD Source] Re: Revised MVP Plans - Scour and Transportation
Date: Wednesday, September 19, 2018 6:27:40 AM

Good morning Lee & Chris,

I just wanted to follow up on the email below.  Would it be possible for the Huntingdon District to provide a response
on the Scour report to the FERC this week?

Thanks,
Matt

> On Sep 11, 2018, at 1:02 PM, Hoover, Matthew S. <MHoover@eqt.com> wrote:
>
> Chris/Lee,
> The FERC is looking for a response from the Huntington District concerning the Scour and Transportation report.  I
was hoping you could provide a response, similar to what Todd from Norfolk sent to Lavinia.
>
> Chris, during our last conversation, it was my understanding that you had the same opinion about how the actions fall
outside of the USACE's jurisdiction.  Is there any chance you could provide an update to Lavinia?  This has become a
pressing issue within the FERC and I'm hoping we can wrap this up within the next couple of days.
>
> Let me know if you have any questions.  I can be reached any time at 412.258.5627.
>
> Thanks,
> Matt
>
>
> -----Original Message-----
> From: Miller, Todd M CIV USARMY CENAO (US) [mailto:Todd.M.Miller@usace.army.mil]
> Sent: Wednesday, September 05, 2018 4:15 PM
> To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com>
> Cc: Paul Friedman <Paul.Friedman@ferc.gov>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
> Subject: RE: Revised MVP Plans - Scour and Transportation
>
> Lavinia,
>
> I have reviewed the updates to the Scour and transportation plan.  These actions would fall outside the jurisdiction of
the Corps, however a failure in erosion and sediment control could potentially impact waters of the U.S. including
wetlands.  MVP's "Patrol After Installation" Plan appears to be adequate enough to stop and remediate any issues prior
to impacting waters or wetlands.  Thank you for the opportunity to comment.
>
> Todd Miller
> Western Virginia Regulatory Section
> U.S. Army Corps of Engineers
> 9100 Arboretum Pkwy, Ste 235
> Richmond, Virginia 23236
>
> (804) 323-3782 Richmond Office
> todd.m.miller@usace.army.mil
>
>
> -----Original Message-----
> From: Lavinia DiSanto [mailto:Lavinia.DiSanto@cardno.com]
> Sent: Thursday, July 12, 2018 8:11 AM
> To: Carson, Christopher L CIV USARMY CELRH (US) <Christopher.L.Carson@usace.army.mil>; Miller, Todd M

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 3
 From: Hoover, Matthew S.
To: Carson, Christopher L CIV USARMY CELRH (US); ROBINETTE, Lee A CIV USARMY CELRH (US)
Cc: Neylon, Megan
Subject: [Non-DoD Source] FW: Revised MVP Plans - Scour and Transportation
Date: Tuesday, September 11, 2018 1:04:02 PM

Chris/Lee,
The FERC is looking for a response from the Huntington District concerning the Scour and Transportation report.  I was
hoping you could provide a response, similar to what Todd from Norfolk sent to Lavinia.

Chris, during our last conversation, it was my understanding that you had the same opinion about how the actions fall
outside of the USACE's jurisdiction.  Is there any chance you could provide an update to Lavinia?  This has become a
pressing issue within the FERC and I'm hoping we can wrap this up within the next couple of days.

Let me know if you have any questions.  I can be reached any time at 412.258.5627.

Thanks,
Matt

-----Original Message-----
From: Miller, Todd M CIV USARMY CENAO (US) [mailto:Todd.M.Miller@usace.army.mil]
Sent: Wednesday, September 05, 2018 4:15 PM
To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com>
Cc: Paul Friedman <Paul.Friedman@ferc.gov>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject: RE: Revised MVP Plans - Scour and Transportation

Lavinia,

I have reviewed the updates to the Scour and transportation plan.  These actions would fall outside the jurisdiction of the
Corps, however a failure in erosion and sediment control could potentially impact waters of the U.S. including
wetlands.  MVP's "Patrol After Installation" Plan appears to be adequate enough to stop and remediate any issues prior
to impacting waters or wetlands.  Thank you for the opportunity to comment.

Todd Miller
Western Virginia Regulatory Section
U.S. Army Corps of Engineers
9100 Arboretum Pkwy, Ste 235
Richmond, Virginia 23236

(804) 323-3782 Richmond Office

todd.m.miller@usace.army.mil

-----Original Message-----
From: Lavinia DiSanto [mailto:Lavinia.DiSanto@cardno.com]
Sent: Thursday, July 12, 2018 8:11 AM
To: Carson, Christopher L CIV USARMY CELRH (US) <Christopher.L.Carson@usace.army.mil>; Miller, Todd M
CIV USARMY CENAO (US) <Todd.M.Miller@usace.army.mil>
Cc: Paul Friedman <Paul.Friedman@ferc.gov>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject: [Non-DoD Source] FW: Revised MVP Plans - Scour and Transportation

Hi Chris and Todd,

Mountain Valley has provided to the FERC a preliminary copy of revisions they wish to make to their Vertical Scour

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 4
 From: Lavinia DiSanto
To: Carson, Christopher L CIV USARMY CELRH (US); Miller, Todd M CIV USARMY CENAO (US)
Cc: Paul Friedman; Douglas Mooneyhan
Subject: [Non-DoD Source] FW: Revised MVP Plans - Scour and Transportation
Date: Thursday, July 12, 2018 8:13:20 AM
Attachments: Vertical Scour and Lateral Channel Erosion Analyses_June 2018.pdf

Hi Chris and Todd,

Mountain Valley has provided to the FERC a preliminary copy of revisions they wish to make to their Vertical Scour
and Lateral Channel Erosion Plan (attached).  Mountain Valley has already revised the document to incorporate the
FERC’s comments.  Please let us know if U.S. Army Corps of Engineers has any comments or suggested revisions. 
Thank you.  

Lavinia M. DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1 302 395 3340  Fax +1 302 395 1920

Address 121 Continental Drive Suite 308, Newark , DE 19713
Email lavinia.disanto@cardno.com <mailto:lavinia.disanto@cardno.com>   Web Blockedwww.cardno.com
<Blockedhttp://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s). All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying of
the information contained in this email and its attachments is strictly prohibited. If you have received this email in error,
please email the sender by replying to this message and immediately delete and destroy any copies of this email and any
attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of Cardno.

From: Veneziano, Philip [mailto:PVeneziano@eqt.com]

Sent: Friday, June 15, 2018 10:48 AM
To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Cc: Neylon, Megan <MNeylon@eqt.com>; Eggerding, Matthew <MEggerding@eqt.com>
Subject: FW: Revised MVP Plans - Scour and Transportation

Lavinia / Doug,

Please see the updated version of the plan and responses to the comments below.  Please let us know if you have any
additional questions / comments.

Thanks,

Phil

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 5
 From: Myers, Ricky L.
Sent: Thursday, June 14, 2018 11:39 AM
To: Veneziano, Philip <PVeneziano@eqt.com <mailto:PVeneziano@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto:MEggerding@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Phil,

Here is an updated version of the Analyses along with a response to each comment from Lavinia.  Let me know of
additional questions or comments.

*       Revise Section 5.2.2 to include the details of 49 CRF 192.705. 

        *       MVP: 192.705 included.

*       Section 5.2.2 should be revised to include a detailed discussion regarding the criteria that would need to be met in
order for a distance to be considered an “increased environmental or landslide risk, or be unsafe or impractical due to
terrain or geology.”

        *       MVP: Updated Section 5.2.2.

*       Revise Appendix B to denote which locations would receive patrols as a mitigation measure. 

        *       MVP: Asterisk added to signify which ones we know from field and desktop reviews and paragraph added to
Section 5.2.2.

*       Clarify if any other values within Appendix A and Appendix B would require changes based on Mountain Valley
proposed revisions. 

        *       MVP: Any changes would be required based upon consultations in the field.  See Section 5.2.2. 

*       Revise Appendix C to provide a site-specific scenario (such as was provided for Second Big Run and Stony Creek)
for each location that would receive mitigation as described in section 5.2.2 versus mitigation as described in section
5.2.1. 

        *       MVP: Including a site-specific scenario for each location is excessive.  We have included in Section 5.2.2 that
we will consult with the monitor before employing this mitigation measure at additional streams. 

*       Several places refer to Section 5.3, however, there isn’t a section 5.3 in the report.

        *       MVP: Updated to remove reference to Section 5.3.

Thanks,

Ricky L. Myers

MVP Design Engineering Manager

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 6
 EQT Midstream

rmyers@eqt.com <mailto:rmyers@eqt.com>

724.873.3640 (o)

412.297.2709 (c)

From: Veneziano, Philip

Sent: Monday, May 14, 2018 7:46 AM
To: Myers, Ricky L. <RMyers@eqt.com <mailto:RMyers@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto:MEggerding@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Ricky,

See below, can you work to update the scour plan to address Lavinia’s commetns?

Thanks,

Phil

From: Eggerding, Matthew

Sent: Friday, May 11, 2018 3:31 PM
To: Veneziano, Philip <PVeneziano@eqt.com <mailto:PVeneziano@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Phil, see below.

Regards,

Matt

Matthew Eggerding

Senior Counsel, Midstream

EQT Corporation

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 7
 625 Liberty Avenue, Suite 1700

Pittsburgh, PA 15222

Direct: (412) 553-5786

Cell: (412) 258-5399

meggerding@eqt.com <mailto:meggerding@eqt.com>

From: Lavinia DiSanto [mailto:Lavinia.DiSanto@cardno.com]

Sent: Friday, May 11, 2018 3:12 PM
To: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com <mailto:Douglas.Mooneyhan@cardno.com> >;
Eggerding, Matthew <MEggerding@eqt.com <mailto:MEggerding@eqt.com> >
Subject: [EXTERNAL] RE: Revised MVP Plans - Scour and Transportation

Hi All,

Our apologies on the delay with these comments.  We were seeking additional FERC comments.  There are no
comments on the revisions to the Traffic and Transportation Management Plan.

Our comments on the Scour Plan are below.  Thanks. 

*       Revise Section 5.2.2 to include the details of 49 CRF 192.705. 

*       Section 5.2.2 should be revised to include a detailed discussion regarding the criteria that would need to be met in
order for a distance to be considered an “increased environmental or landslide risk, or be unsafe or impractical due to
terrain or geology.”
*       Revise Appendix B to denote which locations would receive patrols as a mitigation measure. 
*       Clarify if any other values within Appendix A and Appendix B would require changes based on Mountain Valley
proposed revisions. 
*       Revise Appendix C to provide a site-specific scenario (such as was provided for Second Big Run and Stony Creek)
for each location that would receive mitigation as described in section 5.2.2 versus mitigation as described in section
5.2.1. 
*       Several places refer to Section 5.3, however, there isn’t a section 5.3 in the report.

Lavinia M. DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1 302 395 3340  Fax +1 302 395 1920

Address 121 Continental Drive Suite 308, Newark , DE 19713
Email lavinia.disanto@cardno.com <mailto:lavinia.disanto@cardno.com>   Web Blockedwww.cardno.com
<Blockedhttp://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s). All electronically supplied data must be checked against an applicable hardcopy version which shall be the

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 8
 only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying of
the information contained in this email and its attachments is strictly prohibited. If you have received this email in error,
please email the sender by replying to this message and immediately delete and destroy any copies of this email and any
attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of Cardno.

From: Neylon, Megan [mailto:MNeylon@eqt.com]

Sent: Friday, April 27, 2018 3:42 PM
To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com <mailto:Lavinia.DiSanto@cardno.com> >
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com <mailto:Douglas.Mooneyhan@cardno.com> >;
Eggerding, Matthew <MEggerding@eqt.com <mailto:MEggerding@eqt.com> >
Subject: Revised MVP Plans - Scour and Transportation

Hi Lavinia,

As discussed several weeks ago, MVP would like to make changes to two project plans. Attached for your review are the
Vertical Scour and Lateral Channel Erosion and Analysis and the Traffic and Transportation Management Plan. Changes
are highlighted in yellow.

In the original Vertical Scour and Later Channel Erosion and Analysis the plan was a theoretical desktop analysis and
did not take site specific constructability (elevations, terrain, and workspace) into account. MVP recently field reviewed
some of the sites contained in the analyses, it was quickly determined that execution of the mitigation measures, as
written, would pose increased environmental or landslide risks, or be unsafe or impractical due to terrain or geology.
MVP also would not have adequate workspace to store the soils required to meet the proposed burial elevations. This
version adds another mitigation measure of monitoring lateral channel erosion.

In the Traffic and Transportation Management Plan, MVP has changed the central point of command for construction
traffic route plan. Traffic coordinators will now be reporting to the construction directors with oversight from our safety
program manager.

If you approve these changes, we plan to file both plans as one variance request. Please let me know if you have any
questions.

Thank you,

Megan

To learn about EQT’s sustainability efforts visit: Blockedhttps://csr.eqt.com

<Blockedhttps://urldefense.proofpoint.com/v2/url?u=https-3A__csr.eqt.com&d=DwMFAg&c=QSj8pw-Dfe-
PLjj4Ds2WCg&r=nqxJGjFnduIyVtwWKuKgs7eN2N4LQ9eA8DYB8WisLus&m=xMWyk0-
j4HMJrUkGHgczGcbDnhFnzCZDrXXOT9W28JE&s=CexrRvrkTSGQTKZUsGRVKG0b5Rs2Qwy4UPEstneb5hk&e=> 

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 9
 To learn about EQT’s sustainability efforts visit: Blockedhttps://csr.eqt.com

US Army Corps of Engineers Response to FOIA request by ICWA to US Army Corps of Engineers Page 10
 Exhibit  C  
Attachment  2,  VarianceMVP-­‐006  Request  Form  
Agency  Correspondence    
(CUI//PRIV  -­‐-­‐  DO  NOT  RELEASE).  

FERC  FOIA-­‐2018-­‐131  

FERC  Response  to  FOIA  request  by  ICWA  for  copy  of  file  on  
MVP  Docket  16-­‐10-­‐000,  Accession  No.  20180921-­‐5229,  Privileged  
 FEDERAL ENERGY REGULATORY COMMISSION
WASHINGTON, D.C. 20426

Re: FOIA No. FY18-131

NOV 0 9 2018 Release Letter

VIA ELECTRONIC & REGULAR MAIL

Ms. Judith Azulay
Indian Creek Watershed Association
P.O. Box 711
Union, W.V. 24983
indiancreekwater(a)gmai I .com

Dear Ms. Azulay:

This letter responds to your correspondence of September 27, 2018, in which you
requested documents pursuant to the Freedom of Information Act (FOIA) and the Federal
Energy Regulatory Commission's (Commission) regulations at 18 C.F.R. § 388.112(d)
(2018). 1 Specifically, you requested a copy of the document filed under FERC Accession
No.: 20180921-5229 submitted in FERC Docket No.: CP-16-10 by EQT Corporation
(EQT).

On October 9, 2017, in response to a notice sent by the Commission pursuant to

18 C.F.R. § 388.112(d), EQT informed Commission staff via voice mail that it had no
intention of filing comments and did not oppose release of the requested document.

A search of the Commission's non-public records identified the requested

document. It contains a cultural resources report where no resources were identified. In
addition, the document includes a Landowner Exhibit, emails between the Commission,
U.S. Army Corp of Engineers, and the licensee. The document is being released in full
with the signature of landowners and identity of lower level staff redacted pursuant to
FOIA Exemption 6, which protects "personnel and medical files and similar files the
disclosure of which would constitute a clearly unwarranted invasion of personal privacy."
It is well established that the names and personal home addresses of private landowners
are protected from release under FOIA Exemption 6. See, e.g., Bibles v. Oregon Natural
Desert Ass'n, 519 U.S. 355 (1997); US. Dep't of Defense v. Federal Labor Relations
Authority, 510 U.S. 487 (1994); Carter, Fullerton & Hayes LLC v. FTC, 520 F. Supp. 2d
134, 144-45 (D.D.C 2007); National Ass'n of Retired Fed. Employees v. Horner, 879 F.2d
873 (D.C. Cir. 1989). To overcome the presumption in favor of protecting individual
privacy, it must be demonstrated that the public interest in disclosure of the information
outweighs the substantial privacy interest of the landowners. See NARA v. Favish, 541
U.S. 157, 172; see also Martin v. Dep 't of Justice, 488 F.3d 446, 458 (D.C. Cir. 2007).

1
5 U.S.C. § 552, as amended by the FOIA Improvement Act of 2016, Pub. L.
No. 114-185, 130 Stat. 538 (2016).
FOIA No. FYI 8-131 -2-

That burden has not been met here. See also Odland v. Fed. Energy_ Regulatory Comm 'n,
No. CV 13-141(RMC),2014 WL 1244773 (D.D.C. Mar. 27, 2014)(holding that disclosing
the names and addresses of landowners would not "reveal anything about the workings of
FERC" and therefore would not further the public interest.)

The documents can be found on the enclosed disk. As provided by FOIA, any
appeal from this determination must be filed within 90 days of the date of this letter. The
appeal must be in writing, addressed to James Danly, General Counsel, Federal Energy
Regulatory Commission, 888 First Street, NE, Washington, DC 20426, and clearly marked
"Freedom of Information Act Appeal." Please include a copy to Charles A. Beamon,
Associate General Counsel, General and Administrative Law, at the same address.

You also have the right to seek dispute resolution services from the FOIA Public
Liaison of the agency or the Office of Government Information Services (OGIS). Using
OGIS services does not affect your right to pursue your appeal. You may contact OGIS
by mail at Office of Government Information Services, National Archives and Records
Administration, Room 2510, 8601 Adelphi Road, College Park, MD 20740-6001; email at
ogis<q>nara.gov; telephone at (301) 837-1996; facsimile at (301) 837-0348; or toll-free at
1-(877) 684-6448.

~'0Y(
Leonard M. Tao
Director
Office of External Affairs

Enclosures
20180921-5229 FERC PDF (Unofficial) 9/21/2018 4 :5 2:13 PM

Redactions Made Pursuant to FOIA Exemption 6

Mountain Valley Pipeline, LLC
Mountain Valley Pipeline Project
Docket No. CP16-10-000

Agency Correspondence
(CUI//PRIV -- DO NOT RELEASE)
. Attachment 2

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2

2 01809 2 1-5 22 9 FERC PDF (Unoffi c i a l ) 9/2 1 /20 1 8 4 :5 2 :1 3 PM

Redactions Made Pursuant to FOIA Exemption 6

Veneziano, Philip

From: Lavinia Di Santo < Lavinia.DiSanto@cardno.com >

Sent: Wednesday, September 19, 2018 1:52 PM
To: ~tthew; Veneziano, Philip; Neylon, Megan
Cc: - - - Douglas Mooneyhan
Subject: [EXTERNAL] FW: Revised MVP Plans - Scour and Transportation

Hi All,

Below is the email the FERC rece ived from Mr. Carson . Please include this email and Mr. Miller's email in your variance
request . Thank you.

Lavinia M. DiSanto
SENIOR CONSULTANT
NATURAL RESOURCES & HEALTH SCIENCES DIVISION CARDNO

Direct +1302 395 3340 Fax +1302 395 1920 Address 121 Continental Drive Suite 308, Newark, DE 19713 Email
lavinia.disanto@cardno.comWebwww.cardno.com

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s) . All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying
of the information contained in this email and its attachments is strictly prohibited. If you have received this email in
error, please email the sender by replying to this message and immediately delete and destroy any copies of this email
and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of
Cardno.

-----Original Message-----
From : Carson, Christopher L CIV USARMY CELRH(US)[mailto:Christopher.L.Carson@usace.army.mil]
Sent : Wednesday, September 19, 2018 8:59 AM
To : Lavinia DiSanto <Lavinia.DiSanto@cardno.com>; Miller, Todd M CIV USARMY CENAO (US)
<Todd.M .Miller@usace.army.mi l>
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject: RE: Revised MVP Plans - Scour and Transportation

Lavinia,

The Huntington District has reviewed the submitted report . Mounta in Valley proposes to use a variety of mitigation
strategies to prevent scour from affecting t he proposed MVP at certain wate·rbody crossings . The report includes
changes to the February 2017 version . No information is provided indicating whether any of the changes would result
in additional discharges of dredged and/or fill material into waters of the United States.

Very respectfully,

Christopher L. Carson
Project Manager
Programs & Project Management Branch
USACE, Huntington District, CELRH

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 1
20 1 8092 1 - 5 229 FERC PDF (Uno f f i c i al) 9/2 1 /20 1 8 4:52: 1 3 PM

Redactions Made Pursuant to FOIA Exemption 6

502 Eighth Street
Huntington, WV 25701
304-399-5819
Christopher.l.carson@usace.army.mil

-----Original Message ~- - --
From : Lavinia DiSanto [mailto:Lavinia.DiSanto@cardno.com)
Sent: Tuesday, July 17, 2018 2:27 PM
To: Carson, Christopher L CIV USARMY CELRH (US)<Christopher.L.Carson@usace.army.mil>; Miller, Todd M CIV USARMY
CENAO(US)<Todd .M .Miller@usace.army.mil>
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject : [Non -DoD Source) RE: Revised MVP Plans - Scour and Transportation

Hi Chris and Todd,

Mountain Valley has provided to the FERC a preliminary copy of revisions they wish to make to their Vertical Scour and
Lateral Channel Erosion Plan (attached). Mountain Valley has already revised the document to incorporate the FERC's
comments. Please let us know if U.S. Army Corps of Engineers has any comments or suggested revisions . Thank you .

Lavinia M . DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1302 395 3340 Fax +1302 395 1920 Address 121 Continental Drive Suite 308, Newark, DE 19713
Email lavinia .disanto@cardno.com <mailto :lavinia .disanto@cardno .com> Web Blockedwww.cardno.com
<Blockedhttp ://www.cardno .com>

This email an d its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s) . All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying
of the information contained in this email and its attachments is strictly prohibited . If you have received this email in
error, please email the sender by replying to this message and immed iately delete and destroy any copies of this email
and any attachments. The views o.r opinions expressed are the author's own and may not reflect the views or opinions of
Cardno.

From: Lavinia Disanto

Sent: Thursday, July 12, 2018 8:10 AM
To: 'Christopher.L.Carson@usace.army.mil'<Christopher.L.Carson@usace.army.mil>; 'Miller, Todd M CIV USARMY
CENAO(US)'<Todd.M .Miller@usace.army.mil>
Cc Douglas Mooneyhan
<Douglas. Mooneyha n@ca rd no.com>
Subject : FW: Revised MVP Plans - Scour and Transportation

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 2
2 01 80921 - 5 229 FERC PDF (Uno f ficial ) 9 / 21 / 2018 4: 5 2:13 PM

Redactions Made Pursuant to FOIA Exemption 6

Hi Chris and Todd,

Mountain Valley has provided to the FERC a preliminary copy of revisions they wish to make to their Vertical Scour and
Lateral Channel Erosion Plan (attached). Mountain Valley has already revised the document to incorporate the FERC's
comments. Please let us know if U.S. Army Corps of Engineers has any comments or suggested revisions . Thank you.

Lavinia M . DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1302 395 3340 Fax +1302 395 1920 Address 121 Continental Drive Suite 308, Newark, DE 19713
Email lavinia .disanto@cardno.com <mailto :lavinia.disanto@cardno .com> Web Blockedwww.cardno.com
<Blockedhttp ://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s). All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying
of the information contained in this email and its attachments is strictly prohibited. If you have received this email in
error, please email the sender by replying to this message and immediately delete and destroy any copies of this email
and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of
Cardno.

From: Veneziano, Philip [mailto:PVeneziano@eqt.com]

Sent : Friday, June 15, 2018 10:48 AM
To: Lavinia DiSanto <Lavinia .DiSanto@cardno.com <mailto:Lavinia .DiSanto@cardno.com> >; Douglas Mooneyhan
<Douglas .Mooneyhan@cardno .com <mailto:Douglas .Mooneyhan@cardno.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto :MNeylon@eqt .com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto :MEggerding@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Lavinia I Doug,

Please see the updated version of the plan and responses to the comments below. Please let us know if you have any
additional questions/ comments.

Thanks,

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 3
20180921-5229 FERC PDF (Unof ficial ) 9 /2 1 /2 018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

Phil

From: Myers, Ricky L.

Sent: Thursday, June 14, 2018 11:39 AM
To: Veneziano, Philip <PVeneziano@eqt.com <mailto:PVeneziano@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto:MEggerding@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Phil,

Here is an updated version of the Analyses along with a response to each comment from Lavinia. Let me know of
additional questions or comments.

* Revise Section 5.2.2 to include the details of 49 CRF 192. 705.

* MVP : 192.705 included.

* Section 5.2.2 should be revised to include a detailed discussion regarding the criteria that would need to be met
in order for a distance to be considered an "increased environmental or landslide risk, or be unsafe or impractical due to
terrain or geology."

* MVP: Updated Section 5.2.2.

* Revise Appendix B to denote which locations would receive patrols as a mitigation measure.

* MVP: Asterisk added to signify which ones we know from field and desktop reviews and paragraph
added to Section 5.2.2.

* Clarify if any other values within Appendix A and Appendix B would require changes based on Mountain Valley
proposed revisions.

* MVP : Any changes would be required based upon consultations in the field . See Section 5.2.2.

* Revise Appendix C to provide a site-specific scenario (such as was provided for Second Big Run and Stony Creek)
for each location that would receive mitigation as described in section 5.2.2 versus mitigation as described in section
5.2.1.

* MVP: Including a site-specific scenario for each location is excessive. We have included in Section 5.2.2
that we will consult with the monitor before employing this mitigation measure at additional streams.

* Several places refer to Section 5.3, however, there isn't a section 5.3 in the report.

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 4
20180921-5229 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

* MVP: Updated to remove reference to Section 5.3 .

Thanks,

Ricky L. Myers

MVP Design Engineering Manager

EQT Midstream

rmyers@eqt.com <mailto:rmyers@eqt.com>

724.873.3640 (o)

412.297.2709 (c)

From: Veneziano, Philip

Sent: Monday, May 14, 2018 7:46 AM
To: Myers, Ricky L. <RMyers@eqt.com <mailto:RMyers@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto:MEggerding@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Ricky,

See below, can you work to update the scour plan to address Lavinia's commetns?

Thanks,

Phil

From: Eggerding, Matthew

Sent: Friday, May 11, 2018 3:31 PM
To: Veneziano, Philip <PVeneziano@eqt.com <mailto:PVeneziano@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto :MNeylon@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Phil, see below.

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 5
2 01 80921- 5 22 9 FERC PDF (Unofficial) 9/21/20 18 4 :5 2: 1 3 PM

Redactions Made Pursuant to FOIA Exemption 6

Regards,

Matt

Matthew Eggerding

Senior Counsel, Midstream

EQT Corporation

625 Liberty Avenue, Suite 1700

Pittsburgh, PA 15222

Direct : (412) 553-5786

Cell: (412) 258-5399

meggerding@eqt.com <mailto:meggerding@eqt.com>

From: Lavinia DiSanto [mailto:Lavinia .DiSanto@cardno.com]

Sent: Friday, May 11, 2018 3:12 PM
.To: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com <mailto:Douglas .Mooneyhan@cardno.com> >; Eggerding,
Matthew <MEggerding@eqt.com <mailto:MEggerding@eqt.com> >
Subject: [EXTERNAL] RE: Revised MVP Plans - Scour and Transportation

Hi All,

Our apologies on the delay with these comments. We were seeking additional FERC comments. There are no
comments on the revisions to the Traffic and Transportation Management Plan .

Our comments on the Scour Plan are below. Thanks.

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 6
20180921-5229 FERC PDF (Unofficial) 9 / 21 / 2018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

* Revise Section 5.2.2 to include the details of 49 CRF 192.705.
* Section 5.2.2 should be revised to include a detailed discussion regarding the criteria that would need to be met
in order for a distance to be considered an "increased environmental or landslide risk, or be unsafe or impractical due to
terrain or geology."
* Revise Appendix B to denote which locations would receive patrols as a mitigation measure.
* Clarify if any other values within Appendix A and Appendix B would require changes based on Mountain Valley
proposed revisions.
* Revise Appendix C to provide a site-specific scenario (such as was provided for Second Big Run and Stony Creek)
for each location that would receive mitigation as described in section 5.2.2 versus mitigation as described in section
5.2.1.
* Several places refer to Section 5.3, however, there isn't a section 5.3 in the report.

Lavinia M . DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1302 395 3340 Fax +1302 395 1920 Address 121 Continental Drive Suite 308, Newark, DE 19713
Email lavinia.disanto@cardno.com <mailto:lavinia.disanto@cardno.com> Web Blockedwww.cardno.com
<Blockedhttp://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s) . All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying
of the information contained in this email and its attachments is strictly prohibited. If you have received this email in
error, please email the sender by replying to this message and immediately delete and destroy any copies of this email
and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of
Cardno.

From: Neylon, Megan [mailto:MNeylon@eqt.com]

Sent: Friday, April 27, 2018 3:42 PM
To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com <mailto:Lavinia .DiSanto@cardno.com> >
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com <mailto:Douglas.Mooneyhan@cardno.com> >; Eggerding,
Matthew <MEggerding@eqt.com <mailto:MEggerding@eqt.com> >
Subject: Revised MVP Plans - Scour and Transportation

Hi Lavinia,

As discyssed several weeks ago, MVP would like to make changes to two project plans. Attached for your review are the
Vertical Scour and Lateral Channel Erosion and Analysis and the Traffic and Transportation Management Plan. Changes
are highlighted in yellow.

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 7
20180921-5229 FERC PDF (Unofficial) 9 /2 1 /20 18 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

In the original Vertical Scour and Later Channel Erosion and Analysis the plan was a theoretical desktop analysis and did
not take site specific constructability (elevations, terrain, and workspace) into account. MVP recently field reviewed
some of the sites contained in the analyses, it was quickly determined that execution of the mitigation measures, as
written, would pose increased environmental or landslide risks, or be unsafe or impractical due to terrain or geology.
MVP also would not have adequate workspace to store the soils required to meet the proposed burial elevations. This
version adds another mitigation measure of monitoring lateral channel erosion .

In the Traffic and Transportation Management Plan, MVP has changed the central point of _command for construction
traffic route plan. Traffic coordinators will now be reporting to the construction directors with oversight from our safety
program manager.

If you approve these changes, we plan to file both plans as one variance request. Please let me know if you have any
questions.

Thank you,

Megan

To learn about EQT's sustainability efforts visit : Blockedhttps://csr.eqt.com

<Blocked htt ps ://u rldefe nse. proof point.co m/v2/u rl?u =htt ps-3A_ cs r .eqt. com &d= DwM FAg&c=QSj8 pw-Dfe-
PLjj4 Ds2 WCg&r=n qxJG j Fnd u lyVtwW Ku Kgs 7eN2N 4LQ9eA8DYB8Wislus&m=xMWykO-
j4HMJrUkGHgczGcbDnhFnzCZDrXXOT9W28JE&s=CexrRvrkTSGQTKZUsGRVKGOb5Rs2Qwy4UPEstneb5hk&e=>

To learn about EQT's sustainability efforts visit : Blockedhttps ://csr.eqt.com

8
Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 8
20180921-5229 FERC PDF (Unofficial) 9 / 21 / 2018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

Veneziano, Philip

From: Eggerding, Matthew

Sent: Thursday, September 6, 2018 1:57 PM
To: Veneziano, Philip; Neylon, Megan
Subject: FW: Revised MVP Plans - Scour and Transportation

Regards,

Matt

Matthew Eggerding
Senior Counsel, Midstream
EQT Corporation
625 Liberty Avenue, Suite 1700
Pittsburgh, PA 15222
Direct: (412) 553-5786
Cell: (412) 258-5399
meggerding@eqt.com

-----Original Message-----
From:
Sent: Thursday, September 06, 2018 1:38 PM
To: Eggerding, Matthew <MEggerding@eqt.com>; Eggerding, Matthew <MEggerding@eqt.com>; Cooper, Bob
<RCooper@eqt.com>
Cc: Lavinia DiSanto <Lavinia.DiSanto@cardno.com>; Doug Mooneyhan (douglas.mooneyhan@cardno.com)
<douglas.mooneyhan@cardno.com>
Subject: [EXTERNAL] FW: Revised MVP Plans - Scour and Transportation

fyi

-----Original Message-----
From: M_iller, Todd M CIV USARMY CENAO (US) [mailto:Todd.M .Miller@usace.army.mil]
Sent: Wednesday, September 05, 2018 4:15 PM
To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com>
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject: RE : Revised MVP Plans - Scour and Transportation

Lavinia,

I have reviewed the updates to the Scour and transportation plan. These actions would fall outside the jurisdiction of
the Corps, however a failure in erosion and sediment control could potentially impact waters of the U.S. including
wetlands. MVP's "Patrol After Installation" Plan appears to be adequate. enough to stop and remediate any issues prior
to impacting waters or wetlands. Thank you for the opportunity to comment.

Todd Miller
Western Virginia Regulatory Section

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 9
20180921-5229 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

U.S. Army Corps of Engineers
9100 Arboretum Pkwy, Ste 235
Richmond, Virginia 23236

(804) 323-3782 Richmond Office

todd.m .miller@usace.army.mil

-----Origi na I Message-----
From: Lavinia DiSanto [mailto:Lavinia.DiSanto@cardno.com]
Sent : Thursday, July 12, 2018 8:11 AM
To: Carson, Christopher L CIV USARMY CELRH (US)<Christopher.L.Carson@usace.army.mil>; Miller, Todd M CIV USARMY
CENAO(US)<Todd.M.Miller@usace.army.mil>
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Subject: [Non-DoD Source] FW: Revised MVP Plans - Scour and Transportation

Hi Chris and Todd,

Mountain Valley has provided to the FERC a preliminary copy of revisions they wish to make to their Vertical Scour and
Lateral Channel Erosion Plan (attached) . Mountain Valley has already revised the document to incorporate the FERC's
comments. Please let us know if U.S. Army Corps of Engineers has any comments or suggested revisions. Thank you .

Lavinia M. DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1302 395 3340 Fax +1302 395 1920 Address 121 Continental Drive Suite 308, Newark, DE 19713
Email lavinia.disanto@cardno.com <mailto:lavinia.disanto@cardno.com> Web Blockedwww.cardno.com
<Blockedhttp://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s) . All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying
of the information contained in this email and its attachments is strictly prohibited . If you have received this email in
error, please email the sender by replying to this message and immediately delete and destroy any copies of this email
and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of
Cardno.

From: Veneziano, Philip [mailto:PVeneziano@eqt.com]

Sent: Friday, June 15, 2018 10:48 AM
To: Lavinia DiSanto <Lavinia .DiSanto@cardno.com>; Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com>
Cc: Neylon, Megan <MNeylon@eqt.com>; Eggerding, Matthew <MEggerding@eqt.com>
Subject: FW: Revised MVP Plans - Scour and Transportation

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 10
20 1 80921- 5 229 FERC PDF (Unofficial) 9/21/20 1 8 4:52 :1 3 PM

Redactions Made Pursuant to FOIA Exemption 6

Lavinia I Doug,

Please see the updated version of the plan and responses to the comments below. Please let us know if you have any
additional questions I comments.

Thanks,

Phil

From: Myers, Ricky L.

Sent: Thursday, June 14, 2018 11:39 AM
To: Veneziano, Philip <PVeneziano@eqt.com <mailto :PVeneziano@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto:MEggerding@eqt.com> >
Subj ect: FW: Revised MVP Plans - Scour and Transportation

Phi l,

Here is an updated version of the Analyses along with a response to each comment from Lavinia . Let me know of
additional questions or comments .

* Revise Section 5.2.2 to include the details of 49 CRF 192.705.

*MVP : 192.705 included .

*Section 5.2.2 should be revised to include a detailed discussion regarding the criteria that would need to be met in
order for a distance to be considered an "increased environmental or landslide risk, or be unsafe or impractical due to
terrain or geology."

* MVP : Updated Section 5.2.2.

* Revise Append ix B to denote which locations would receive patrols as a mitigation measure.

*MVP : Asterisk added to signify which ones we know from field and desktop reviews and paragraph added to Section
5.2.2.

* Clarify if any other values within Appendix A and Appendix B would require changes based on Mountain Valley
proposed revisions .

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 11
20180921-5229 FERC PDF (Uno fficial ) 9/21/2018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

*MVP: Any changes would be required based upon consultations in the field. See Section 5.2 .2.

*Revise Appendix C to provide a site-specific scenario (such as was provided for Second Big Run and Stony Creek) for
each location that would receive mitigation as described in section 5.2;2 versus mitigation as described in section 5.2.1.

*MVP: Including a site-specific scenario for each locat,ion is excessive. We have included in Section 5.2.2 that we will
consult with the monitor before employing this mitigation measure at additional streams.

*Several places refer to Section 5.3, however, there isn't a section 5.3 in the report.

*MVP: Updated to remove reference to Section 5.3.

Thanks,

Ricky L. Myers

MVP Design Engineering Manager

EQT Midstream

rmyers@eqt.com <mailto:rmyers@eqt.com>

724.873.3640 (o)

412.297.2709 (c)

From : Veneziano, Philip

Sent: Monday, May 14, 2018 7:46 AM
To: Myers, Ricky L. <RMyers@eqt.com <mailto:RMyers@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >; Eggerding, Matthew <MEggerding@eqt.com
<mailto:MEggerding@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Ricky,

See below, can you work to update the scour plan to address Lavinia's commetns?

Thanks,

Phil

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 12
20 1 8092 1 - 5 229 FERC PD F (Uno f fi cia l) 9/2 1 /20 1 8 4 :5 2 :1 3 PM

Redactions Made Pursuant to FOIA Exemption 6

From : Eggerding, Matthew

Sent: Friday, May 11, 2018 3:31 PM
To: Veneziano, Philip <PVeneziano@eqt.com <mailto:PVeneziano@eqt.com> >
Cc: Neylon, Megan <MNeylon@eqt.com <mailto :MNeylon@eqt.com> >
Subject: FW: Revised MVP Plans - Scour and Transportation

Phil, see below.

Regards,

Matt

Matthew Eggerding

Senior Counsel, Midstream

EQT Corporation

625 Liberty Avenue, Suite 1700

Pittsburgh, PA 15222

Direct: (412) 553-5786

Cell : (412) 258-5399

meggerding@eqt.com <mailto:meggerding@eqt.com>

From: Lavinia DiSanto [mailto:Lavinia .DiSanto@cardno.com]

Sent: Friday, May 11, 2018 3:12 PM
To : Neylon, Megan <MNeylon@eqt.com <mailto:MNeylon@eqt.com> >
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com <mailto :Douglas .Mooneyhan@cardno.com> >; Eggerding,
Matthew <MEggerding@eqt.com <mailto:MEggerding@eqt.com> >
Subject: [EXTERNAL] RE : Revised MVP Plans - Scour and Transportation

Hi All,

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 13
20180921-5229 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Redactions Made Pursuant to FOIA Exemption 6

Our apologies on the delay with these comments . We were seeking additional FERC comments. There are no
comments on the revisions to the Traffic and Transportation Management Plan .

Our comments on the Scour Plan are below. Thanks.

*Revise Section 5.2.2 to include the details of 49 CRF 192.705.

*Section 5.2.2 should be revised to include a detailed discussion regarding the criteria that would need to be met in
order for a distance to be considered an "increased environmental or landslide risk, or be unsafe or impractical due to
terrain or geology."
*Revise Appendix B to denote which locations would receive patrols as a mitigation measure.
*Clarify if any other values within Appendix A and Appendix B would require changes based on Mountain Valley
proposed revisions .
*Revise Appendix C to provide a site-specific scenario (such as was provided for Second Big Run and Stony Creek) for
each location that would receive mitigation as described in section 5.2.2 versus mitigation as described in section 5.2.1.
*Several places refer to Section 5.3, however, there isn't a section 5.3 in the report.

Lavinia M. DiSanto
SENIOR CONSULTANT
CARDNO

Direct +1302 395 3340 Fax +1302 395 1920 Address 121 Continental Drive Suite 308, Newark, DE 19713
Email lavinia.disanto@cardno.com <mailto:lavinia.disanto@cardno.com> Web Blockedwww.cardno.com
<Blockedhttp://www.cardno.com>

This email and its attachments may contain confidential and/or privileged information for the sole use of the intended
recipient(s) . All electronically supplied data must be checked against an applicable hardcopy version which shall be the
only document which Cardno warrants accuracy. If you are not the intended recipient, any use, distribution or copying . j
of the information contained in this email and its attachments is strictly prohibited . If you have received this email in
error, please email the sender by replying to this message and immediately delete and destroy any copies of this email
and any attachments. The views or opinions expressed are the author's own and may not reflect the views or opinions of
Cardno.

From: Neylon, Megan [mailto:MNeylon@eqt.com]

Sent: Friday, April 27, 2018 3:42 PM
To: Lavinia DiSanto <Lavinia.DiSanto@cardno.com <mailto:Lavinia .DiSanto@cardno.com> >
Cc: Douglas Mooneyhan <Douglas.Mooneyhan@cardno.com <mailto :Douglas.Mooneyhan@cardno.com> >; Eggerding,
Matthew <MEggerding@eqt.com <mailto:MEggerding@eqt.com> >
Subject: Revised MVP Plans - Scour and Transportation

Hi Lavinia,

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 14
20180921 - 52 2 9 FERC PDF (Uno fficia l) 9/2 1 /20 18 4:5 2 :13 PM

Redactions Made Pursuant to FOIA Exemption 6

As discussed several weeks ago, MVP would like to make changes to two project plans. Attached for your review are the
Vertical Scour and Lateral Channel Erosion and Analysis and the Traffic and Transportation Management Plan. Changes
are highlighted in yellow.

In the original Vertical Scour and Later Channel Erosion and Analysis the plan was a theoretical desktop analysis and did
not take site specific constructability (elevations, terrain, and workspace) into account. MVP recently field reviewed
some of the sites contained in the analyses, it was quickly determined that execution of the mitigation measures, as
written, would pose increased environmental or landslide risks, or be unsafe or impractical due to terrain or geology.
MVP also would not have adequate workspace to store the soils required to meet the proposed burial elevations . This
version adds another mitigation measure of monitoring lateral channel erosion.

In the Traffic and Transportation Management Plan, MVP has changed the central point of command for construction
traffic route plan . Traffic coordinators will now be reporting to the construction directors with oversight from our safety
program manager.

If you approve these changes, we plan to file both plans as one variance request. Please let me know if you have any
questions.

Thank you,

Megan

To learn about EQT's sustainability efforts visit: Blockedhttps ://csr.eqt.com

<Blockedhttps://urldefense .proofpoint.com/v2/url?u=https-3A_csr.eqt.com&d=DwMFAg&c=QSj8pw-Dfe-
PLjj4Ds2WCg&r=nqxJGjFndulyVtwWKuKgs7eN2N4LQ9eA8DYB8WisLus&m=xMWykO-
j4HMJrUkGHgczGcbDnhFnzCZDrXXOT9W28JE&s=CexrRvrkTSGQTKZUsGRVKGOb5Rs2Qwy4UPEstneb5hk&e=>

To learn about EQT's sustainability efforts visit : Blockedhttps ://csr.eqt.com

Zero is Possible - Today!

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 15
20180921-5229 FERC PDF (Unofficial) 9 / 21/2018 4:52 : 13 PM
Document Content ( s) Redactions Made Pursuant to FOIA Exemption 6

PRIV MVP Variance Request H-9.PDF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-10

PRIV Variance Request MVP-006.PDF . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 11-26

Exhibit C - FERC FOIA Agency Correspondence (CUI//PRIV—Do Not Release), Attachment 2 Page 16
 Exhibit  D  
“Mountain  Valley  Pipeline:    
Vertical  Scour  and    
Lateral  Channel  Erosion  Analyses  
Revised  June  2018”  

Submitted  September  21,  2018  by  MVP  

Accession  No.  20180921-­‐5228    
20180921-5228 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Mountain Valley Pipeline, LLC

Mountain Valley Pipeline Project
Docket No. CP16-10-000

Updated Plans
Attachment 1
20180921-5228 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Mountain Valley Pipeline:

Vertical Scour and
Lateral Channel Erosion Analyses

Mountain Valley Pipeline, LLC

Revised: June 2018

Changes from February 2017 Version are highlighted yellow

20180921-5228 FERC PDF (Unofficial) 9/21/2018 4:52:13 PM

Vertical Scour and Lateral Channel Erosion Analyses

TABLE OF CONTENTS

1.0 OVERVIEW ................................................................................................................................1

2.0 DATA ........................................................................................................................................2
2.1 VERTICAL SCOUR ANALYSIS .......................................................................................... 2
2.1.1 Design Discharge ............................................................................................... 2
2.1.2 Particle Size Distribution ................................................................................... 2
2.1.2.1 Major Waterbody Crossings ................................................................ 3
2.1.2.2 Intermediate Waterbody Crossings .................................................... 3
2.1.3 Channel Hydraulics ........................................................................................... 3
2.1.4 Bedrock ............................................................................................................. 4
2.2 LATERAL CHANNEL EROSION ANALYSIS........................................................................ 4
3.0 METHODS .................................................................................................................................5
3.1 VERTICAL SCOUR ANALYSIS .......................................................................................... 5
3.1.1 General Scour.................................................................................................... 5
3.1.2 Component Scour ............................................................................................. 5
3.1.2.1 Bend Scour........................................................................................... 6
3.1.2.2 Bedform Scour ..................................................................................... 6
3.1.2.3 Contraction Scour ................................................................................ 6
3.1.2.4 Local Scour........................................................................................... 6
3.2 LATERAL CHANNEL EROSION ANALYSIS........................................................................ 6
3.2.1 HMZ – Greater than 40 feet Top of Bank Width .............................................. 7
3.2.2 HMZ – Less than 40 feet Top of Bank Width .................................................... 7
4.0 RESULTS ...................................................................................................................................8
4.1 POTENTIAL VERTICAL SCOUR ........................................................................................ 8
4.1.1 General Scour.................................................................................................... 8
4.1.2 Component Scour ............................................................................................. 8
4.1.3 Maximum Vertical Sour Estimate ..................................................................... 9
4.2 POTENTIAL LATERAL CHANNEL EROSION ..................................................................... 9
5.0 MITIGATION MEASURES..........................................................................................................10
5.1 VERTICAL SCOUR ......................................................................................................... 10
5.1.1 Bedrock ........................................................................................................... 10
5.1.2 Armoring Layer................................................................................................ 10
5.1.3 Revetment Mats ............................................................................................. 11
5.2 POTENTIAL LATERAL CHANNEL EROSION ................................................................... 11
5.2.1 Historic Migration Zone and Factor of Safety ................................................. 11
5.2.2 Patrol After Installation................................................................................... 13
6.0 REFERENCES ...........................................................................................................................14

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Vertical Scour and Lateral Channel Erosion Analyses

TABLES
Table 5-1: Primary Mitigation Measures ............................................................................................................. 10
Table A-1: Vertical Scour Estimates and Mitigation ............................................................................................A-1
Table B-1: Potential Lateral Channel Erosion and Mitigation .............................................................................. B-1

FIGURES
Figure 5-1: Construction Typical Horizontal Setback ............................................................................................ 12

APPENDICES

Appendix A: Vertical Scour Estimates and Mitigation

Appendix B: Potential Lateral Channel Erosion and Mitigation
Appendix C: Maintaining Burial Elevation Risks

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Vertical Scour and Lateral Channel Erosion Analyses

LIST OF ACRONYMS

CFS Cubic Feet per Second

D50 Median Particle Size
DRNAREA Drainage Area
EQT EQT Midstream Partners, LP
EROS Earth Resources Observation and Science
FERC Federal Energy Regulatory Commission
FS Factor of Safety
Ft Feet
GPS Global Positioning System
HEC-RAS Hydrologic Engineering Center River Analysis System
HMZ Historical Migration Zone
ID Identification
LDB Left Descending Bank
LiDAR Light Detection and Ranging
mm Millimeter
Mountain Valley Mountain Valley Pipeline, LLC
MP Mile Post
MVP Mountain Valley Pipeline
NA Not Applicable
NRPW Non-Relatively Permanent Waterway
RDB Right Descending Bank
RI Recurrence Interval
ROW Right-of-Way
RPW Relatively Permanent Waterway
Sq. mi. Square Mile(s)
UNT Unnamed Tributary
Q Discharge
RTK Real-Time Kinematic
TNW Traditional Navigable Waterway

Page iii
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Vertical Scour and Lateral Channel Erosion Analyses

1.0 OVERVIEW
The proposed Mountain Valley Pipeline (MVP) is a 42-inch diameter natural gas pipeline
traversing approximately 301 miles and 17 counties in West Virginia and Virginia. The project
will extend the existing EQT Midstream Partners, LP (EQT) system from Wetzel County, West
Virginia to the Transcontinental Gas Pipe Line Company, LLC Zone 5 Compressor Station 165 in
Pittsylvania County, Virginia. The proposed pipeline crosses 128 perennial waterbodies with
Federal Energy Regulatory Commission (FERC) classifications of intermediate or major. This
includes 124 intermediate and four (4) major. FERC permitting requires vertical scour and lateral
channel erosion analyses. This report describes the methods, assumptions, data limitations, and
results for the analyses, which were conducted at all proposed perennial major and perennial
intermediate FERC classification waterbody crossings.

Page 1
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Vertical Scour and Lateral Channel Erosion Analyses

2.0 DATA

2.1 VERTICAL SCOUR ANALYSIS

Vertical scour analyses require a number of data inputs to estimate potential scour depth. The
approach used in this study utilized the following primary data inputs:
• Design discharge
• Stream bed particle size
• Channel hydraulics (i.e., width, depth, velocity)
• Depth to bedrock
The following sections describe the methods to obtain data outlined above and the associated
assumptions.

2.1.1 Design Discharge

Gaging stations are not present directly at the proposed waterbody crossings. Therefore, design
discharge estimates were required. This study utilized the estimated 2-year and 100-year peak
discharge values. The 2-year peak discharge is assumed to be equivalent to bankfull discharge
(Messinger, 2009; Lotspeich, 2009). The bankfull discharge is required to estimate the median
particle size; details are provided in Section 2.1.2.2. The bankfull discharge was also utilized to
calculate bend scour; details are provided in Section 3.1.2.1. The 100-year peak discharge is a
standard design discharge for estimating general channel scour.

These design discharges were estimated via the peak-flow regional regression equations
developed by the United States Geological Survey (USGS) (Wiley & Atkins, 2010; Austin, Krstolic,
& Wiegand, 2011). The equations require two input parameters: drainage area and location of
the drainage area. Drainage areas located in West Virginia were estimated via the online tool
offered by the West Virginia Department of Environmental Protection Technical Applications and
GIS Unit (7Q10 Flow Estimates, n.d.). Drainage areas located in Virginia were estimated via the
online tool offered by the USGS (StreamStats, n.d.). The waterbody crossings are located within
two West Virginia regions (Central Mountains and Western Plateaus) (Wiley & Atkins, 2010) and
three Virginia regions (Piedmont, Blue Ridge, and Valley and Ridge) (Austin, Krstolic, & Wiegand,
2011).

2.1.2 Particle Size Distribution

Particle size distribution data, specifically the median particle size (D50), is a required data input
for scour calculations. Therefore, a D50 estimate is required for each waterbody crossing. The
following describes the methods utilized for major and intermediate waterbody crossings.

Page 2
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Vertical Scour and Lateral Channel Erosion Analyses

2.1.2.1 Major Waterbody Crossings

Detailed field data was collected to generate surface and subsurface particle size distributions at
the four major waterbody crossings, which include the Gauley River, Greenbrier River, Elk River,
and Little Kanawha River. A pebble count study was performed to estimate surface particle size
distributions, because an established armor layer is present (Bunte & Abt, 2001). A sieve analysis
was performed to estimate subsurface particle size distribution (Bunte & Abt, 2001).

The particle size distribution, specifically subsurface, represents a single point in the river.
However, river systems are complex, non-homogeneous systems, and point data does not
necessarily represent conditions across the river reach of interest. Therefore, scour calculations
using pebble count and sieve analysis data were run at 90, 100, and 110 percent of the estimated
D50 value to account for uncertainties. The particle size that produced the deepest potential
scour depth was used in the calculation estimate.

2.1.2.2 Intermediate Waterbody Crossings

Quantitative and qualitative methods were used to estimate a D50 value at each proposed
intermediate waterbody crossing. The D50 value was estimated quantitatively via a regime
relationship that utilizes the bankfull discharge and the channel slope (USACE, Channel Stability
Assessment for Flood Control Projects, 1994). Bankfull discharge was assumed to be the
estimated 2-year peak-flow discharge (Messinger, 2009; Lotspeich, 2009) and was estimated via
the methods described in Section 2.1.1. The channel slope was estimated from 2-foot contour
light detection and ranging (LiDAR) data obtained from Mountain Valley Pipeline, LLC (Mountain
Valley). The estimated D50 value was verified qualitatively by reviewing project stream
assessment field notes and photographs.
Regime estimated D50 values have a relatively high degree of uncertainty. Therefore, scour
calculations using regime estimated values were run at 50, 100, and 150 percent of the estimated
D50 value to account for uncertainties. The particle size that produced the deepest potential
scour depth was used in the calculation estimate.

2.1.3 Channel Hydraulics

Channel hydraulics were estimated via a simplified Hydrologic Engineering Center River Analysis
System (HEC-RAS) model at each proposed waterbody crossing. The primary inputs in the HEC-
RAS model included the following: channel geometry, channel slope, Manning’s roughness
coefficient, and design discharge. Channel geometry and channel slope were generated from
project LiDAR with 2-foot contours. The Manning’s roughness coefficient was estimated
according to USGS guidelines (Arcement & Schneider, 1989). The hydraulic model was run for
two design discharges: 2-year peak-flow discharge and 100-year peak-flow discharge. The peak-
flow discharge values were estimated via the methods described in Section 2.1.1.

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Vertical Scour and Lateral Channel Erosion Analyses

2.1.4 Bedrock

Vertical scour estimates performed in this study assume near surface bedrock material is not
present. Vertical scour would be limited to depth of bedrock. Therefore, Tetra Tech conducted
detailed field work via seismic refraction and electrical resistivity analyses at the four (4) major
waterbody crossings, and Mountain Valley conducted a desktop review via geographic
information system (GIS) data and soil resistivity data at the 124 intermediate waterbody
crossings.

2.2 LATERAL CHANNEL EROSION ANALYSIS

This study utilizes a framework for delineating channel migration zones to predict areas at risk of
future lateral channel erosion due to fluvial processes (Rapp & Abbe, 2003). This analysis requires
topographic data and present and historic aerial imagery. Topographic data was obtained from
project LiDAR with 2-foot contours. Aerial imagery was obtained from the Earth Resources
Observation and Science (EROS) Center (Areial Photography, n.d.). Present and historic aerial
imagery dates included 2010-2015 and 1949-1976, respectively. Analysis method details are
described in Section 3.2.

Page 4
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Vertical Scour and Lateral Channel Erosion Analyses

3.0 METHODS
The following sections describe the methods used in this study to estimate potential vertical
scour and lateral channel erosion.

3.1 VERTICAL SCOUR ANALYSIS

Total potential vertical scour at a given river location may be estimated via general scour
equations and/or the summation of component scour. Component scour calculation estimates
must consider the summation of long-term bed elevation change, bedform scour, contraction
scour, and scour associated with structures (i.e., local scour). Therefore, a comprehensive
approach is required to estimate scour for a given design discharge and river reach. This study
took the following components into consideration:
• General channel scour
• Component scour
o Bend scour
o Bedform scour
o Contraction scour
o Local scour (scour associated with structures)

The following briefly describes the components outlined above and the associated assumptions.

3.1.1 General Scour

General scour equations assume uniform degradation of the channel for a given river reach and
discharge. The 100-year peak-flow discharge estimate from methods described in Section 2.1.1
was utilized in this study to estimate general scour. Empirical and regime equations have been
developed to estimate total general scour. However, the various equations are only applicable
for specified condition ranges. This study assessed the applicability of three general scour
equations: Lacey regime equation, Blench regime equation, and Borah armor layer equation.
The Lacey and Blench regime equations are only appropriate when the predominant bed material
is 0.06 – 2 mm (sand particle size range) (NRCS, 2007). The Borah armor layer equation is typically
only applicable when the predominant bed material is greater than 6 mm (gravel and larger)
(NRCS, 2007).

3.1.2 Component Scour

The component method estimates potential vertical scour by summing the estimates from each
contributing scour mechanism. This study assessed the following contributing scour
components: bend, bedform, contraction, and local. The following briefly describes each
component.

Page 5
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Vertical Scour and Lateral Channel Erosion Analyses

3.1.2.1 Bend Scour

Bend scour occurs when flow through channel meander bends results in eddy flow patterns that
move sediment from the outside to the inside of the meander bend. This scour effect is most
significant at bankfull events because the flow energy dissipates when waterbody levels overtop
the channel bank. Therefore, bend scour estimates in the study use values associated with the
2-year flood event peak discharge estimate, which was assumed to be approximately equivalent
to a bankfull event (Lotspeich, 2009; Austin, Krstolic, & Wiegand, 2011). Bend scour was
estimated via regime relationships described in the Corps of Engineers Manual 1110-2-1601
(USACE, Hydraulic Design of Flood Control Channel, 1994).

3.1.2.2 Bedform Scour

Bedform scour occurs when ripples, dunes, and antidunes form on the bed surface. This is
applicable when the predominant bed material is in the sand particle size range. Bedform scour
was estimated, when appropriate, to be half of the calculated bedform height (NRCS, 2007).

3.1.2.3 Contraction Scour

Contraction scour occurs when higher velocities are present due to constricted flow conditions.
Natural (i.e. ice jams, bedrock, etc) and/or anthropogenic (i.e. bridges, culverts, etc) features in
the channel can restrict the flow cross-section. Contraction scour is most typically associated
with bridge structures (NRCS, 2007). Aerial imagery (Google, 2013, 2015, 2016) and project
stream assessment field photographs were reviewed for possible contraction scour.

3.1.2.4 Local Scour

Local scour occurs when anthropogenic structures (i.e., bridge piers, weirs/sills, culverts, dams,
etc.) in the channel alter the natural flow regime (NRCS, 2007). Aerial imagery (Google, 2013,
2015, 2016) and project stream assessment field photographs were reviewed for possible
contraction scour.

3.2 LATERAL CHANNEL EROSION ANALYSIS

This study utilized a framework for delineating the historical migration zone (HMZ) to predict
areas at risk of future lateral channel erosion due to fluvial processes (Rapp & Abbe, 2003). The
HMZ is defined by the extent of area the channel occupied over the available historic record. It
encompasses the current waterbody course and has the highest likelihood of lateral erosion.
Planimetric analysis of historical aerial photography is typically used to determine the HMZ (Rapp
& Abbe, 2003). However, planimetric analysis using aerial photography is not feasible for small
streams due to difficulty distinguishing channel banks through closed, as well as open, canopy
and resolution limitations common to older photographic sources. Furthermore, the margin of
error during the digitization process is often too large, as a percentage of bank width, to be useful.
Therefore, two approaches were required: one for waterbody crossings with top of bank widths

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greater than 40 feet and another for waterbody crossings with top of bank widths less than 40
feet.

3.2.1 HMZ – Greater than 40 feet Top of Bank Width

The oldest, digitally available, historic aerial photography for each waterbody crossing was
obtained and georeferenced (Areial Photography, n.d.). The most recently available, high-
resolution orthophotography was also obtained (Areial Photography, n.d.). The bank lines for
both the historic and recent aerial imagery were digitized and merged to delineate the extent of
the HMZ (Rapp & Abbe, 2003). Project LiDAR was also analyzed for evidence of historic channel
locations that may not have been captured by available aerial photography.

3.2.2 HMZ – Less than 40 feet Top of Bank Width

High-resolution project LiDAR was analyzed to estimate the HMZ. Project LiDAR and its first
derivative (slope) were used to map the existing banks and identify relic channels, meander scars,
and other fluvial features that indicate previous channel locations. The HMZ was drawn to
encompass the existing channel corridor and any identified features that indicate past channel
locations (Rapp & Abbe, 2003).

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4.0 RESULTS

4.1 POTENTIAL VERTICAL SCOUR

Potential vertical scour was analyzed via the methods described in Section 3.1. This included a
general scour and component scour analysis. The following summarizes the vertical scour results
generated by this study.

4.1.1 General Scour

The appropriate general scour equation(s) described in Section 3.1.1 were selected based on the
predominant bed material present at a given waterbody crossing. The predominant bed material
at some waterbody crossings was a mix of sand and gravel. Therefore, the general scour
equations for both bed types were assessed at these waterbody crossings.
The predominant bed material was gravel or larger at the 4 major and 109 intermediate
waterbody crossings. Therefore, the Borah armor layer equation was utilized to estimate the
potential vertical scour at these waterbody crossings. The general scour estimates via the Borah
armor layer equation for the 4 major and 109 intermediate ranged from 0.1 – 4.8 feet and 0.1 –
18.6 feet, respectively.
The predominant bed material was sand at 18 intermediate waterbody crossings. Therefore, the
Lacey and Blench regime equations were utilized to estimate the potential vertical scour at these
waterbody crossings. The general scour estimates via the Lacey and Blench regime equations for
the 18 intermediate waterbody crossings ranged from 0.8 – 12.6 feet.
The most conservative (deepest) potential vertical scour estimate for waterbody crossing was
retained as the maximum general scour. The maximum general scour estimates for the 4 major
and 124 intermediate waterbody crossings ranged from 0.1 – 4.8 feet and 0.3 – 18.6 feet,
respectively. The general scour estimate details for each waterbody crossing are presented in
Appendix A, Table A-1.

4.1.2 Component Scour

Potential vertical scour was estimated via the summation of each applicable scour component
outlined in Section 3.1.2 at a given waterbody crossing. The components included the following:
bend scour, bedform scour, contraction scour, and local scour. Bend scour estimates for the 4
major and 124 intermediate waterbody crossing ranged from 0.0 – 10.4 and 0.0 – 8.7 feet,
respectively. There was no potential for bedform scour at the 4 major waterbody crossings
(NRCS, 2007). Furthermore, potential for bedform scour was only present at 15 intermediate
waterbody crossings and the estimates ranged from 0.0 – 0.6 feet. Aerial photography (Google,
2013, 2015, 2016) and project stream assessment field photographs were reviewed for potential
contraction and/or local scour effects. Potential for significant contraction scour resulting from
structures (i.e., bridges) was not observed. Similarly, no structures were identified that would
cause local scour at any proposed waterbody crossings. Therefore, these values are reported as
not applicable (NA). Total component scour estimates for the 4 major and 124 intermediate

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waterbody crossings ranged from 0.0 – 10.4 and 0.0 – 8.7 feet, respectively. The component
scour estimate details for each waterbody crossing are presented in Appendix A.

4.1.3 Maximum Vertical Sour Estimate

The most conservative (deepest) result via the general and component scour analyses was
retained for the maximum potential vertical scour estimate at each waterbody crossing.
Furthermore, a 20% factor of safety (FS) was also added to the maximum potential vertical scour
estimate. This is an engineering standard best practice, which is intended to account for data
uncertainties and potential long-term bed elevation change. The maximum vertical scour
estimates with a 20% FS for the 4 major and 124 intermediate waterbody crossings ranged from
0.1 – 12.5 and 0.4 – 22.3 feet, respectively. The maximum vertical scour estimates with a 20% FS
details for each waterbody crossing are presented in Appendix A. These vertical scour estimates
assume near surface bedrock material is not present. Vertical scour would be limited to the
depth of bedrock. Bedrock details are provided in Section 2.1.4 and Appendix A.

4.2 POTENTIAL LATERAL CHANNEL EROSION

The HMZ was delineated for each waterbody crossing via the methods described in Section 3.2.
The length of pipeline within the HMZ was measured from the current channel centerline to the
lateral extent associated with left descending bank (LDB) and right descending bank (RDB). The
HMZ may not be symmetrical about the current channel centerline. The length of pipeline within
the HMZ for the 4 major waterbody crossings ranged from 58 – 220 feet and 53 – 215 feet for
the LDB and RDB, respectively. The length of pipeline within the HMZ for the 124 intermediate
waterbody crossings ranged from 5 – 505 feet and 3 – 463 feet for the LDB and RDB, respectively.
Pipeline length measurements within the HMZ for each waterbody crossing are presented in
Appendix B, Table B-1.

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5.0 MITIGATION MEASURES

5.1 VERTICAL SCOUR

Mountain Valley proposes to employ a variety of mitigation strategies to prevent scour from
affecting the proposed MVP at waterbody crossings. The primary mitigation strategies are
provided in Table 5-1 below. The proposed burial depths for each waterbody crossing are
provided in Appendix A, Table A-1.
Table 5-1: Primary Mitigation Measures

Estimated Scour
Mitigation
Depth Proposed Mitigation Measure(s)
ID
(ft)

None Required; installed per 49 CFR 192.327 (PHMSA & DOT, 2011)
<2.25 If navigability is not officially determined, pipeline buried with a minimum 4-foot depth of A
cover
≥2.25 and <3.00 Pipeline buried with a minimum of 4-foot depth of cover B

≥3.00 and <3.75 Pipeline buried with a minimum of 5-foot depth of cover C

≥3.75 and <4.50 Pipeline buried with a minimum of 6-foot depth of cover D

≥4.50 and <5.25 Pipeline buried with a minimum of 7-foot depth of cover E

≥5.25 Mitigation option(s) detailed in Sections 5.1.1 and/or 5.1.2 F

Notes:
ID: Identification

5.1.1 Bedrock

Potential scour is limited to the bedrock surface. Therefore, no additional mitigation is required
if the pipeline is installed below the bedrock surface. Pipeline burial depths provided in Table 5-
1 will be decreased to the bedrock surface if two requirements are met: bedrock depth is
shallower than 7 feet and bedrock depth is shallower than the burial depth provided in Table 5-
1. Burial depths must still comply with 49 CFR 192.327. Estimated bedrock depth data was
gathered via the methods outlined in Section 2.1.4 and is presented in Appendix A, Table A-1.
Bedrock depths will be field verified during construction.

5.1.2 Armoring Layer

Mountain Valley would consider using an armoring layer at the pipeline crossing as a mitigation
option if the estimated scour depth exceeds 5.25 feet and bedrock depth is greater than 7 feet.
An armoring layer with a given minimum particle size would restrict potential scour for a given
discharge event. The proposed armoring layer would consist of particle sizes that are equal to or
greater than the minimum armor particle size corresponding to the 100-year peak discharge
design estimate. The armoring layer would also be placed upstream and downstream of the

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pipeline crossing to prevent local scour. Pipeline burial depth would be determined after the size
of the armoring layer is finalized.

5.1.3 Revetment Mats

Mountain Valley would consider using revetment mats at the pipeline crossing as a mitigation
option if the estimated scour depth exceeds 5.25 feet and bedrock depth is greater than 7 feet.
Revetment mats are engineered materials that form an erosion-resistant protective barrier.
Revetment mats would also be placed upstream and downstream of the pipeline crossing to
prevent local scour. Pipeline burial depth would be determined after the size of the revetment
mat is finalized.

5.2 POTENTIAL LATERAL CHANNEL EROSION

5.2.1 Historic Migration Zone and Factor of Safety

Mountain Valley proposes to utilize the delineated HMZ with a FS to determine the horizontal
setback for each waterbody crossing. The added FS will be the greater of 5 feet or 20% of the
HMZ width at the waterbody crossing. Figure 5-1 is a construction typical of the proposed
horizontal setback for a hypothetical waterbody crossing. The X setback value corresponds to
the 20% FS. The proposed pipeline will be installed at an elevation equal to or greater than the
elevation corresponding to the in-channel maximum potential vertical scour depth reported in
Section 4.1.3 while within the HMZ and 20% FS. Pipeline length measurements within the HMZ
with 20% FS for each waterbody crossing are presented in Appendix B, Table B-1.

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Figure 5-1: Construction Typical Horizontal Setback

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5.2.2 Patrol After Installation

When compared to maintaining a minimum depth of cover, requiring installation as described in

section 5.2.1 will always result in a greater amount of earthwork. In some instances, the
excavated volume required to maintain burial elevation is up to four times greater than that
required to achieve depth of cover. More earthwork results in more environmental impacts and
an increase in landslide potential. It also presents greater safety, construction, and maintenance
challenges. These matters are discussed in more detail in Appendix C.
Should the lateral distances described in section 5.2.1 and presented in Appendix B, Table B-1
pose increased environmental or landslide risks, or be unsafe or impractical due to terrain or
geology, Mountain Valley will patrol the waterbodies as a mitigation measure in lieu of
maintaining the burial elevation throughout the entire HMZ . Patrols will be performed to assess
any channel movement conditions and in accordance with 49 CFR 192.705, as described in the
excerpt below.

Increased environmental risk includes any situation that presents additional risk for damaging
environmental resources, such as inadequate space to store spoils, which may then contaminate
the adjacent waterway. Increased landslide risk includes situations where the additional
excavation would require storing excessive quantities of spoil and overloading the native slopes
subjacent to the spoil. Areas where additional excavation is impractical due to terrain or geology
includes areas where blasting or special equipment would be required to maintain the burial
depth, or areas where the pipeline passes under other infrastructure.
Appendix B denotes a sampling of streams as of June 14, 2018 that Mountain Valley has identified
via field measurements or desktop study where one or both Proposed Horizontal Setbacks would
increase environmental or landslide risk, or be unsafe or impractical due to terrain or geology,
and thus will employ patrol as a mitigation measure. Mountain Valley may employ this measure
for additional streams based on further field measurements and studies and consultations with
relevant parties, including the geotechnical team, environmental inspectors, and the FERC
monitor.

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6.0 REFERENCES
7Q10 Flow Estimates. (n.d.). Retrieved from TAGIS: WVDEP Technical Applications and GIS Unit:
http://tagis.dep.wv.gov/streamflow/
Arcement, G. J., & Schneider, V. R. (1989). Guide for Selecting Manning's Roughness Coefficients
for Natural Channels and Flood Plains. Denver, CO: U.S. Geological Survey Water-Supply
Paper 2339.
Areial Photography. (n.d.). Retrieved from USGS: Earth Resource Observation and Science Center:
http://eros.usgs.gov/aerial-photography
Austin, S., Krstolic, J., & Wiegand, U. (2011). Peak-flow characteristics of Virginia streams. Reston,
Virginia: U.S. Geological Survey Scientific Investigations Report 2011–5144, 106 p.
Bunte, K., & Abt, S. R. (2001). Sampling Surface and Subsurface Particle-Size Distributions in
Wadable Gravel- and Cobble-Bed Streams for Analyses in Sediment Transport, Hydraulics,
and Streambed Monitoring. Fort Collins, CO: U.S. Department of Agriculture, U.S. Forest
Service, Rocky Mountain Research Station General Technical Report RMRS-GTR-74.
Google. (2013, 2015, 2016). Google Earth. Retrieved from https://www.google.com/earth/
Lotspeich, R. (2009). Regional curves of bankfull channel geometry for non-urban streams in the
Piedmont Physiographic Province, Virginia. Reston, Virginia: U.S. Geological Survey
Scientific Investigations Report 2009– 5206, 51 p.
Messinger, T. (2009). Regional curves for bankfull channel characteristics in the Appalachian
Plateaus, West Virginia. Reston, Virginia: U.S. Geological Survey Scientific Investigations
Report 2009–5242, 43 p.
NRCS. (2007). Technical Supplement 14B: Scour Calculations. U.S. Department of Agriculture
Natural Resources Conservation Service National Engineering Handbook.
PHMSA, & DOT. (2011). 49 CFR 192.327 - COVER. Washington, D.C.: U.S. Government Publishing
Office.
Rapp, C. F., & Abbe, T. B. (2003). A Framework for Delineating Channel Migration Zones.
Washington State Department of Transportation: Ecology Final Draft Publication #03-06-
027.
StreamStats. (n.d.). Retrieved from United States Geological Survey:
http://streamstatsags.cr.usgs.gov/streamstats/
USACE. (1994). Channel Stability Assessment for Flood Control Projects. Washington D.C.: U.S.
Army Corps of Engineers: Engineer Mannual 1110-2-1418.
USACE. (1994). Hydraulic Design of Flood Control Channel. Washington, D.C.: U.S. Army Corps of
Engineers: Engineer Mannual 1110-2-1601.
Wiley, J. B., & Atkins, J. T. (2010). Estimation of Flood-Frequency Discharges for Rural,
Unregulated Streams in West Virginia. Reston, Virginia: U.S. Geological Survey Scientific
Investigations Report 2010–5033, 78 p.

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APPENDIX A: VERTICAL SCOUR ESTIMATES AND MITIGATION

Table A-1: Vertical Scour Estimates and Mitigation

Estimated Peak- Proposed

Particle General Scour Estimates Component Scour Estimates Maximum
Location Drainage Basin Flow Discharge Estimated Vertical
Size (ft) (ft) Vertical Proposed Pipeline Burial
(RI) Bedrock Scour
Scour Depth
FERC Drainage 100- Estimated Depth Mitigation
2-year Maximum Total Estimate (ft)3
Waterbody Name Classification State County MP Area Regression Region year D50 Borah Lacey Blench Bend Bedform Contraction Local (ft)1 Method
(cfs) General Component with 20% FS
(sq. mi.) (cfs) (mm) (ID)2
North Fork Fishing Creek Intermediate West Virginia Wetzel 0.7 5.7 Western-Plateaus Region 462 1809 10 1.1 NA NA 1.1 0.3 NA NA NA 0.3 1.3 6.7 A 3 or 4
Fallen Timber Run Intermediate West Virginia Wetzel 2.3 0.7 Western-Plateaus Region 101 446 1 NA 0.8 3.6 3.6 0.0 0.3 NA NA 0.3 4.3 6.7 D 6
Price Run Intermediate West Virginia Wetzel 5.0 11.0 Western-Plateaus Region 741 2797 43 1.7 NA NA 1.7 1.7 NA NA NA 1.7 2.0 6.7 A 3 or 4
Sams Run Intermediate West Virginia Wetzel 7.9 1.1 Western-Plateaus Region 141 605 86 3.5 NA NA 3.5 0.0 NA NA NA 0.0 4.2 6.7 D 6
Little Tenmile Creek Intermediate West Virginia Harrison 15.4 15.2 Western-Plateaus Region 938 3479 2 0.1 1.5 2.7 2.7 0.0 0.0 NA NA 0.0 3.3 6.7 C 5
Little Rockcamp Run Intermediate West Virginia Harrison 17.8 1.5 Western-Plateaus Region 176 744 47 0.4 NA NA 0.4 0.0 NA NA NA 0.0 0.5 6.7 A 3 or 4
Rockcamp Run Intermediate West Virginia Harrison 18.7 5.3 Western-Plateaus Region 437 1720 21 0.4 NA NA 0.4 0.0 NA NA NA 0.0 0.4 6.7 A 3 or 4
Grass Run Intermediate West Virginia Harrison 20.8 2.3 Western-Plateaus Region 236 972 1 NA 1.1 2.0 2.0 0.0 0.0 NA NA 0.0 2.5 6.7 B 4
UNT to Grass Run Intermediate West Virginia Harrison 21.6 1.4 Western-Plateaus Region 169 715 1 NA 1.0 2.0 2.0 0.0 0.2 NA NA 0.2 2.4 6.7 B 4
Indian Run Intermediate West Virginia Harrison 23.0 2.5 Western-Plateaus Region 254 1040 30 0.3 NA NA 0.3 0.0 NA NA NA 0.0 0.4 6.7 A 3 or 4
Salem Fork Intermediate West Virginia Harrison 25.9 14.6 Western-Plateaus Region 915 3401 1 NA 1.6 2.4 2.4 0.0 0.0 NA NA 0.0 2.9 6.7 B 4
Laural Run Intermediate West Virginia Doddridge 34.8 2.0 Western-Plateaus Region 212 881 43 2.0 NA NA 2.0 0.0 NA NA NA 0.0 2.4 6.7 B 4
Right Fork Freemans Creek Intermediate West Virginia Lewis 42.5 3.2 Western-Plateaus Region 303 1224 38 1.1 NA NA 1.1 0.0 NA NA NA 0.0 1.3 6.7 A 3 or 4
Fink Creek Intermediate West Virginia Lewis 44.7 1.7 Western-Plateaus Region 187 786 1 NA 1.0 1.4 1.4 0.0 0.0 NA NA 0.0 1.6 6.7 A 3 or 4
Left Fork Freemans Creek Intermediate West Virginia Lewis 45.8 1.5 Western-Plateaus Region 173 732 34 0.5 NA NA 0.5 2.3 NA NA NA 2.3 2.8 6.7 B 4
Sand Fork Intermediate West Virginia Lewis 55.1 12.5 Western-Plateaus Region 816 3059 26 0.5 NA NA 0.5 2.4 NA NA NA 2.4 2.9 8.7 B 4
Indian Fork Intermediate West Virginia Lewis 58.5 5.1 Western-Plateaus Region 426 1677 42 0.5 NA NA 0.5 0.0 NA NA NA 0.0 0.6 6.7 A 3 or 4
UNT to Bens Run Intermediate West Virginia Lewis 59.4 0.7 Western-Plateaus Region 99 435 2 3.1 1.5 2.6 3.1 0.4 0.0 NA NA 0.4 3.7 2.5 C 3 or 4
UNT to Indian Fork Intermediate West Virginia Lewis 59.9 0.2 Western-Plateaus Region 36 173 152 10.5 NA NA 10.5 0.2 NA NA NA 0.2 12.6 5.0 F 5
Second Big Run Intermediate West Virginia Lewis 61.2 0.4 Western-Plateaus Region 70 315 164 7.5 NA NA 7.5 0.3 NA NA NA 0.3 9.0 8.7 F Alternative Mitigation
UNT to Second Big Run Intermediate West Virginia Lewis 61.3 0.4 Western-Plateaus Region 70 319 164 7.5 NA NA 7.5 0.3 NA NA NA 0.3 9.0 8.7 F Alternative Mitigation
Clover Fork Intermediate West Virginia Lewis 65.4 2.2 Western-Plateaus Region 228 943 11 1.3 NA NA 1.3 0.0 NA NA NA 0.0 1.5 6.7 A 3 or 4
Barbecue Run Intermediate West Virginia Braxton 67.4 0.7 Western-Plateaus Region 99 437 79 1.9 NA NA 1.9 0.0 NA NA NA 0.0 2.2 6.7 A 3 or 4
Left Fork Knawl Creek Intermediate West Virginia Braxton 68.7 2.6 Western-Plateaus Region 262 1072 47 1.2 NA NA 1.2 0.0 NA NA NA 0.0 1.4 6.7 A 3 or 4
Knawl Creek Intermediate West Virginia Braxton 68.7 3.8 Western-Plateaus Region 340 1364 39 1.2 NA NA 1.2 2.0 NA NA NA 2.0 2.4 6.7 B 4
UNT to Falls Run Intermediate West Virginia Braxton 71.6 0.4 Western-Plateaus Region 72 324 69 2.7 NA NA 2.7 0.0 NA NA NA 0.0 3.2 11.0 C 5
Falls Run Intermediate West Virginia Braxton 72.4 8.0 Western-Plateaus Region 590 2267 51 1.2 NA NA 1.2 2.2 NA NA NA 2.2 2.6 11.0 B 4
Little Kanawha River Major West Virginia Braxton 74.8 110.5 Western-Plateaus Region 4002 13277 78 0.1 NA NA 0.1 2.7 NA NA NA 2.7 3.2 6.6 C 5
Stonecoal Run Intermediate West Virginia Braxton 76.7 0.4 Western-Plateaus Region 66 299 170 9.7 NA NA 9.7 1.3 NA NA NA 1.3 11.6 2.9 F 3 or 4
UNT to Little Kanawha River Intermediate West Virginia Braxton 77.6 0.7 Western-Plateaus Region 97 428 135 4.6 NA NA 4.6 0.0 NA NA NA 0.0 5.5 2.9 F 3 or 4
UNT to Left Fork Holly River Intermediate West Virginia Braxton 79.7 1.2 Central-Mountains Region 82 345 98 3.9 NA NA 3.9 2.0 NA NA NA 2.0 4.7 2.9 E 3 or 4
Left Fork Holly River Intermediate West Virginia Webster 81.6 55.4 Central-Mountains Region 2308 7368 96 2.1 NA NA 2.1 0.0 NA NA NA 0.0 2.6 6.7 B 4
Oldlick Creek Intermediate West Virginia Webster 82.3 10.9 Central-Mountains Region 559 2011 103 3.2 NA NA 3.2 2.2 NA NA NA 2.2 3.8 3.3 D 3.3
Right Fork Holly Creek Intermediate West Virginia Webster 84.1 56.6 Central-Mountains Region 2352 7498 86 3.0 NA NA 3.0 0.0 NA NA NA 0.0 3.6 5.1 C 5

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Estimated Peak- Proposed
Particle General Scour Estimates Component Scour Estimates Maximum
Location Drainage Basin Flow Discharge Estimated Vertical
Size (ft) (ft) Vertical Proposed Pipeline Burial
(RI) Bedrock Scour
Scour Depth
FERC Drainage 100- Estimated Depth Mitigation
2-year Maximum Total Estimate (ft)3
Waterbody Name Classification State County MP Area Regression Region year D50 Borah Lacey Blench Bend Bedform Contraction Local (ft)1 Method
(cfs) General Component with 20% FS
(sq. mi.) (cfs) (mm) (ID)2
Elk River Major West Virginia Webster 87.3 269.2 Central-Mountains Region 9180 26112 95 0.1 NA NA 0.1 0.0 NA NA NA 0.0 0.1 4.9 A 3 or 4
UNT to Elk River Intermediate West Virginia Webster 87.6 0.3 Central-Mountains Region 27 126 173 10.6 NA NA 10.6 0.0 NA NA NA 0.0 12.8 6.7 F 6.7
UNT to Camp Creek Intermediate West Virginia Webster 92.4 0.6 Central-Mountains Region 45 198 136 7.9 NA NA 7.9 0.0 NA NA NA 0.0 9.5 6.7 F 6.7
UNT to Camp Creek Intermediate West Virginia Webster 93.0 0.8 Central-Mountains Region 59 257 131 4.3 NA NA 4.3 0.0 NA NA NA 0.0 5.2 6.7 E 7
Camp Creek Intermediate West Virginia Webster 93.1 2.8 Central-Mountains Region 169 673 65 0.5 NA NA 0.5 0.0 NA NA NA 0.0 0.6 8.7 A 3 or 4
Amos Run Intermediate West Virginia Webster 97.7 7.2 Central-Mountains Region 389 1441 76 0.7 NA NA 0.7 0.8 NA NA NA 0.8 1.0 4.1 A 3 or 4
Lost Run Intermediate West Virginia Webster 98.6 2.8 Central-Mountains Region 169 673 61 1.9 NA NA 1.9 0.0 NA NA NA 0.0 2.3 6.7 B 4
Laurel Creek Intermediate West Virginia Webster 98.8 15.8 Central-Mountains Region 770 2695 88 3.5 NA NA 3.5 0.0 NA NA NA 0.0 4.2 6.7 D 6
UNT to Birch River Intermediate West Virginia Webster 104.9 0.7 Central-Mountains Region 50 218 98 4.7 NA NA 4.7 0.0 NA NA NA 0.0 5.7 8.0 F Alternative Mitigation
UNT to Strouds Creek Intermediate West Virginia Webster 110.1 8.5 Central-Mountains Region 447 1638 85 0.9 NA NA 0.9 4.1 NA NA NA 4.1 4.9 6.7 E 7
UNT to Barn Run Intermediate West Virginia Nicholas 111.8 0.2 Central-Mountains Region 17 83 171 8.1 NA NA 8.1 0.0 NA NA NA 0.0 9.7 6.7 F 6.7
Big Beaver Creek Intermediate West Virginia Nicholas 114.3 29.0 Central-Mountains Region 1314 4397 113 3.6 NA NA 3.6 0.0 NA NA NA 0.0 4.3 6.7 D 6
Big Beaver Creek Intermediate West Virginia Nicholas 116.2 33.7 Central-Mountains Region 1496 4952 110 2.3 NA NA 2.3 0.0 NA NA NA 0.0 2.8 2.0 B 3 or 4
Gauley River Major West Virginia Nicholas 118.9 557.4 Central-Mountains Region 17329 46742 100 4.8 NA NA 4.8 0.0 NA NA NA 0.0 5.7 12.1 F Alternative Mitigation
UNT to Little Laurel Creek Intermediate West Virginia Nicholas 120.3 1.0 Central-Mountains Region 67 289 136 7.1 NA NA 7.1 0.0 NA NA NA 0.0 8.5 7.8 F Alternative Mitigation
UNT to Little Laurel Creek Intermediate West Virginia Nicholas 120.3 1.0 Central-Mountains Region 67 289 136 3.4 NA NA 3.4 0.0 NA NA NA 0.0 4.0 4.6 D 6
Jims Creek Intermediate West Virginia Nicholas 123.4 3.6 Central-Mountains Region 210 820 134 3.8 NA NA 3.8 0.0 NA NA NA 0.0 4.6 7.1 E 7
Hominy Creek Intermediate West Virginia Nicholas 126.9 48.2 Central-Mountains Region 2045 6594 131 5.1 NA NA 5.1 0.0 NA NA NA 0.0 6.2 6.7 F Alternative Mitigation
Sugar Branch Intermediate West Virginia Nicholas 130.5 1.3 Central-Mountains Region 85 359 72 2.1 NA NA 2.1 0.0 NA NA NA 0.0 2.5 6.7 B 4
UNT to Hominy Creek Intermediate West Virginia Nicholas 131.5 1.2 Central-Mountains Region 81 343 1 NA 0.8 2.5 2.5 0.0 0.3 NA NA 0.3 2.9 6.7 B 4
UNT to Hominy Creek Intermediate West Virginia Nicholas 132.4 0.4 Central-Mountains Region 34 155 61 1.5 NA NA 1.5 0.0 NA NA NA 0.0 1.8 6.7 A 3 or 4
UNT to Meadow Creek Intermediate West Virginia Greenbrier 140.4 7.0 Central-Mountains Region 378 1403 1 NA 2.5 4.2 4.2 0.8 0.3 NA NA 1.1 5.1 6.7 E 7
Meadow River Intermediate West Virginia Greenbrier 144.0 164.3 Central-Mountains Region 5965 17591 1 NA 5.7 4.8 5.7 4.2 0.6 NA NA 4.8 6.8 6.7 F 6.7
Little Sewell Creek Intermediate West Virginia Greenbrier 147.0 5.1 Central-Mountains Region 289 1097 2 1.1 3.0 1.8 3.0 2.7 0.0 NA NA 2.7 3.6 6.7 C 5
Buffalo Creek Intermediate West Virginia Greenbrier 154.9 3.7 Central-Mountains Region 217 844 0.06 NA 1.5 1.2 1.5 0.0 NA NA NA 0.0 1.8 6.7 A 3 or 4
Lick Creek Intermediate West Virginia Summers 162.9 1.0 Central-Mountains Region 70 300 273 18.6 NA NA 18.6 0.0 NA NA NA 0.0 22.3 6.7 F 6.7
Hungard Creek Intermediate West Virginia Summers 169.8 5.1 Central-Mountains Region 288 1094 109 1.0 NA NA 1.0 1.5 NA NA NA 1.5 1.8 6.7 A 3 or 4
Hungard Creek Intermediate West Virginia Summers 170.0 11.4 Central-Mountains Region 582 2086 66 1.9 NA NA 1.9 0.0 NA NA NA 0.0 2.2 6.7 A 3 or 4
Greenbrier River Major West Virginia Summers 171.4 1557.7 Central-Mountains Region 42501 106351 35 0.3 NA NA 0.3 10.4 NA NA NA 10.4 12.5 6.6 F 6.6
Kelly Creek Intermediate West Virginia Summers 172.7 7.5 Central-Mountains Region 405 1496 48 1.2 NA NA 1.2 1.8 NA NA NA 1.8 2.2 6.7 A 3 or 4
Wind Creek Intermediate West Virginia Monroe 176.7 1.1 Central-Mountains Region 74 315 177 7.8 NA NA 7.8 0.0 NA NA NA 0.0 9.4 3.3 F 3.3
UNT to Wind Creek Intermediate West Virginia Monroe 176.7 0.2 Central-Mountains Region 16 79 188 10.2 NA NA 10.2 0.0 NA NA NA 0.0 12.2 3.3 F 3.3
UNT to Stoney Creek Intermediate West Virginia Monroe 177.4 1.6 Central-Mountains Region 105 433 72 2.8 NA NA 2.8 0.1 NA NA NA 0.1 3.4 3.3 C 3.3
Stony Creek Intermediate West Virginia Monroe 179.1 0.6 Central-Mountains Region 47 208 0.06 NA 0.9 1.5 1.5 0.0 NA NA NA 0.0 1.8 6.7 A 3 or 4
Slate Run Intermediate West Virginia Monroe 182.4 0.6 Central-Mountains Region 44 197 78 2.5 NA NA 2.5 0.0 NA NA NA 0.0 3.0 6.7 C 5
Indian Creek Intermediate West Virginia Monroe 182.8 108.5 Central-Mountains Region 4151 12618 20 0.3 NA NA 0.3 0.0 NA NA NA 0.0 0.4 6.7 A 3 or 4
UNT to Hans Creek Intermediate West Virginia Monroe 184.2 0.8 Central-Mountains Region 55 238 101 3.0 NA NA 3.0 0.0 NA NA NA 0.0 3.6 6.7 C 5

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Vertical Scour and Lateral Channel Erosion Analyses

Estimated Peak- Proposed
Particle General Scour Estimates Component Scour Estimates Maximum
Location Drainage Basin Flow Discharge Estimated Vertical
Size (ft) (ft) Vertical Proposed Pipeline Burial
(RI) Bedrock Scour
Scour Depth
FERC Drainage 100- Estimated Depth Mitigation
2-year Maximum Total Estimate (ft)3
Waterbody Name Classification State County MP Area Regression Region year D50 Borah Lacey Blench Bend Bedform Contraction Local (ft)1 Method
(cfs) General Component with 20% FS
(sq. mi.) (cfs) (mm) (ID)2
Hans Creek Intermediate West Virginia Monroe 187.6 14.7 Central-Mountains Region 725 2551 106 3.8 NA NA 3.8 0.2 NA NA NA 0.2 4.6 6.7 E 7
Dry Creek Intermediate West Virginia Monroe 192.0 4.3 Central-Mountains Region 249 958 87 0.9 NA NA 0.9 0.0 NA NA NA 0.0 1.0 6.7 A 3 or 4
Kimballton Branch Intermediate Virginia Giles 198.9 1.5 Valley and Ridge 151 1169 225 14.1 NA NA 14.1 0.9 NA NA NA 0.9 16.9 6.7 F 6.7
Stony Creek Intermediate Virginia Giles 200.3 47.5 Valley and Ridge 1914 9867 164 6.2 NA NA 6.2 4.0 NA NA NA 4.0 7.5 15.0 F Alternative Mitigation
Stony Creek Intermediate Virginia Giles 200.3 47.5 Valley and Ridge 1914 9867 164 6.2 NA NA 6.2 4.0 NA NA NA 4.0 7.5 15.0 F Alternative Mitigation
Stony Creek Intermediate Virginia Giles 200.3 47.5 Valley and Ridge 1914 9867 164 6.2 NA NA 6.2 4.0 NA NA NA 4.0 7.5 15.0 F Alternative Mitigation
UNT to Little Stony Creek Intermediate Virginia Giles 203.5 1.1 Valley and Ridge 124 990 227 11.3 NA NA 11.3 0.3 NA NA NA 0.3 13.5 7.8 F Alternative Mitigation
UNT to Little Stony Creek Intermediate Virginia Giles 204.2 0.3 Valley and Ridge 46 429 47 1.7 NA NA 1.7 0.0 NA NA NA 0.0 2.1 6.7 A 3 or 4
Little Stony Creek Intermediate Virginia Giles 204.3 19.8 Valley and Ridge 1008 5760 197 10.8 NA NA 10.8 1.6 NA NA NA 1.6 13.0 6.7 F 6.7
UNT to Doe Creek Intermediate Virginia Giles 205.8 0.9 Valley and Ridge 102 843 169 12.3 NA NA 12.3 0.0 NA NA NA 0.0 14.7 6.7 F 6.7
Doe Creek Intermediate Virginia Giles 206.7 3.8 Valley and Ridge 303 2101 128 5.7 NA NA 5.7 0.0 NA NA NA 0.0 6.9 6.7 F 6.7
UNT to Sinking Creek Intermediate Virginia Giles 207.8 0.2 Valley and Ridge 32 320 20 2.5 NA NA 2.5 0.0 NA NA NA 0.0 3.0 6.7 C 5
Sinking Creek Intermediate Virginia Giles 211.1 65.5 Valley and Ridge 2423 12022 58 2.3 NA NA 2.3 0.0 NA NA NA 0.0 2.8 6.7 B 4
Greenbriar Branch Intermediate Virginia Giles 212.9 2.7 Valley and Ridge 231 1672 101 6.8 NA NA 6.8 0.0 NA NA NA 0.0 8.2 6.7 F 6.7
UNT to Sinking Creek Intermediate Virginia Giles 216.6 0.1 Valley and Ridge 21 223 154 12.8 NA NA 12.8 0.9 NA NA NA 0.9 15.4 6.7 F 6.7
Craig Creek Intermediate Virginia Montgomery 219.5 5.1 Valley and Ridge 372 2495 64 2.2 NA NA 2.2 2.3 NA NA NA 2.3 2.8 6.7 B 4
North Fork Roanoke River Intermediate Virginia Montgomery 227.4 23.7 Valley and Ridge 1150 6434 59 0.5 NA NA 0.5 0.0 NA NA NA 0.0 0.7 5.0 A 3 or 4
Bradshaw Creek Intermediate Virginia Montgomery 230.9 17.6 Valley and Ridge 925 5358 46 1.9 NA NA 1.9 0.0 NA NA NA 0.0 2.2 6.7 A 3 or 4
Roanoke River Intermediate Virginia Montgomery 235.6 256.0 Valley and Ridge 6580 27801 71 1.8 NA NA 1.8 6.3 NA NA NA 6.3 7.6 5.0 F 5
UNT to Bottom Creek Intermediate Virginia Roanoke 240.8 0.4 Blue Ridge 72 913 11 7.3 NA NA 7.3 0.0 NA NA NA 0.0 8.8 1.7 F 3 or 4
Bottom Creek Intermediate Virginia Roanoke 242.4 2.9 Blue Ridge 284 2860 63 0.7 NA NA 0.7 0.5 NA NA NA 0.5 0.9 1.7 A 3 or 4
North Fork Blackwater River Intermediate Virginia Franklin 249.8 5.9 Blue Ridge 472 4376 81 2.4 NA NA 2.4 0.0 NA NA NA 0.0 2.9 6.7 B 4
UNT to North Fork Blackwater River Intermediate Virginia Franklin 251.0 2.2 Blue Ridge 231 2405 120 4.6 NA NA 4.6 0.0 NA NA NA 0.0 5.5 6.7 F Alternative Mitigation
UNT to North Fork Blackwater River Intermediate Virginia Franklin 251.9 1.8 Blue Ridge 206 2186 122 4.2 NA NA 4.2 0.5 NA NA NA 0.5 5.1 6.7 E 7
UNT to Little Creek Intermediate Virginia Franklin 256.0 1.0 Blue Ridge 132 1509 97 3.7 NA NA 3.7 0.0 NA NA NA 0.0 4.4 6.7 D 6
Teels Creek Intermediate Virginia Franklin 258.3 2.2 Blue Ridge 234 2432 50 1.3 NA NA 1.3 0.0 NA NA NA 0.0 1.5 6.7 A 3 or 4
Teels Creek Intermediate Virginia Franklin 259.2 3.4 Blue Ridge 319 3156 50 0.5 NA NA 0.5 2.6 NA NA NA 2.6 3.1 6.7 C 5
Teels Creek Intermediate Virginia Franklin 259.4 3.5 Blue Ridge 325 3205 50 2.4 NA NA 2.4 0.0 NA NA NA 0.0 2.9 6.7 B 4
Teels Creek Intermediate Virginia Franklin 260.4 4.5 Blue Ridge 388 3717 53 1.5 NA NA 1.5 2.7 NA NA NA 2.7 3.2 6.7 C 5
UNT to Teels Creek Intermediate Virginia Franklin 260.9 5.0 Blue Ridge 419 3963 44 1.6 NA NA 1.6 4.1 NA NA NA 4.1 4.9 6.7 E 7
Teels Creek Intermediate Virginia Franklin 261.1 5.1 Blue Ridge 423 4000 42 1.1 NA NA 1.1 2.3 NA NA NA 2.3 2.8 6.7 B 4
Teels Creek Intermediate Virginia Franklin 261.9 5.5 Blue Ridge 450 4207 43 1.8 NA NA 1.8 0.0 NA NA NA 0.0 2.1 6.7 A 3 or 4
UNT to Teels Creek Intermediate Virginia Franklin 262.1 6.4 Blue Ridge 498 4584 44 2.0 NA NA 2.0 0.0 NA NA NA 0.0 2.5 6.7 B 4
Teels Creek Intermediate Virginia Franklin 262.4 6.6 Blue Ridge 512 4686 45 1.8 NA NA 1.8 1.9 NA NA NA 1.9 2.3 6.7 B 4
Little Creek Intermediate Virginia Franklin 262.7 22.6 Blue Ridge 1222 9705 40 1.2 NA NA 1.2 2.9 NA NA NA 2.9 3.5 6.7 C 5
Little Creek Intermediate Virginia Franklin 263.4 25.1 Blue Ridge 1316 10328 30 0.4 NA NA 0.4 0.0 NA NA NA 0.0 0.5 6.7 A 3 or 4
UNT to Maggodee Creek Intermediate Virginia Franklin 268.6 0.5 Blue Ridge 87 1060 55 3.1 NA NA 3.1 0.0 NA NA NA 0.0 3.7 6.7 C 5

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Vertical Scour and Lateral Channel Erosion Analyses

Estimated Peak- Proposed
Particle General Scour Estimates Component Scour Estimates Maximum
Location Drainage Basin Flow Discharge Estimated Vertical
Size (ft) (ft) Vertical Proposed Pipeline Burial
(RI) Bedrock Scour
Scour Depth
FERC Drainage 100- Estimated Depth Mitigation
2-year Maximum Total Estimate (ft)3
Waterbody Name Classification State County MP Area Regression Region year D50 Borah Lacey Blench Bend Bedform Contraction Local (ft)1 Method
(cfs) General Component with 20% FS
(sq. mi.) (cfs) (mm) (ID)2
UNT to Maggodee Creek Intermediate Virginia Franklin 269.0 0.8 Blue Ridge 118 1378 58 3.3 NA NA 3.3 0.6 NA NA NA 0.6 3.9 6.7 D 6
Maggodee Creek Intermediate Virginia Franklin 269.5 45.4 Blue Ridge 2004 14677 35 1.5 NA NA 1.5 2.6 NA NA NA 2.6 3.1 6.7 C 5
Blackwater River Intermediate Virginia Franklin 269.8 165.0 Blue Ridge 5003 31548 64 2.8 NA NA 2.8 8.7 NA NA NA 8.7 10.4 6.7 F 6.7
UNT to Blackwater River Intermediate Virginia Franklin 270.3 0.1 Blue Ridge 25 376 64 4.7 NA NA 4.7 0.0 NA NA NA 0.0 5.7 6.7 F Alternative Mitigation
Foul Ground Creek Intermediate Virginia Franklin 272.4 1.9 Blue Ridge 210 2221 33 0.5 NA NA 0.5 0.0 NA NA NA 0.0 0.5 6.7 A 3 or 4
UNT to Poplar Camp Creek Intermediate Virginia Franklin 274.2 0.3 Blue Ridge 50 671 74 3.8 NA NA 3.8 1.1 NA NA NA 1.1 4.6 6.7 E 7
UNT to Blackwater River Intermediate Virginia Franklin 276.6 0.5 Blue Ridge 81 1001 54 1.7 NA NA 1.7 0.0 NA NA NA 0.0 2.0 6.7 A 3 or 4
UNT to Jacks Creek Intermediate Virginia Franklin 277.5 0.1 Blue Ridge 32 456 48 3.8 NA NA 3.8 0.0 NA NA NA 0.0 4.6 6.7 E 7
Strawfield Creek Intermediate Virginia Franklin 282.4 0.8 Blue Ridge 118 1378 58 2.6 NA NA 2.6 0.0 NA NA NA 0.0 3.2 3.3 C 5
Jonnikin Creek Intermediate Virginia Pittsylvania 284.8 1.0 Piedmont 154 1407 59 1.3 NA NA 1.3 0.0 NA NA NA 0.0 1.6 9.6 A 3 or 4
UNT to Rocky Creek Intermediate Virginia Pittsylvania 287.2 1.0 Piedmont 160 1456 1 NA 2.5 4.0 4.0 0.9 0.3 NA NA 1.2 4.8 6.7 E 7
Pigg River Intermediate Virginia Pittsylvania 289.2 340.0 Piedmont 4991 24970 0.06 NA 4.5 12.6 12.6 0.0 NA NA NA 0.0 15.1 6.7 F 6.7
Harpen Creek Intermediate Virginia Pittsylvania 290.0 7.8 Piedmont 532 3925 1 NA 3.5 3.4 3.5 0.8 0.4 NA NA 1.2 4.1 6.7 D 6
Harpen Creek Intermediate Virginia Pittsylvania 290.6 3.1 Piedmont 309 2507 1 NA 1.5 3.5 3.5 0.0 0.3 NA NA 0.3 4.2 6.7 D 6
Harpen Creek Intermediate Virginia Pittsylvania 292.1 1.6 Piedmont 205 1785 48 2.0 NA NA 2.0 0.0 NA NA NA 0.0 2.4 6.7 B 4
UNT to Harpen Creek Intermediate Virginia Pittsylvania 292.5 0.2 Piedmont 61 652 1 NA 0.9 2.1 2.1 0.0 0.2 NA NA 0.2 2.6 6.7 B 4
UNT to Cherrystone Creek Intermediate Virginia Pittsylvania 294.3 1.5 Piedmont 203 1768 48 1.8 NA NA 1.8 1.9 NA NA NA 1.9 2.3 6.7 B 4
Cherrystone Creek Intermediate Virginia Pittsylvania 295.3 3.6 Piedmont 338 2696 51 0.6 NA NA 0.6 0.5 NA NA NA 0.5 0.8 7.8 A 3 or 4
UNT to Pole Bridge Branch Intermediate Virginia Pittsylvania 296.7 4.5 Piedmont 382 2987 41 0.4 NA NA 0.4 0.1 NA NA NA 0.1 0.5 6.7 A 3 or 4
UNT to Little Cherrystone Creek Intermediate Virginia Pittsylvania 301.5 1.1 Piedmont 169 1524 53 1.5 NA NA 1.5 0.0 NA NA NA 0.0 1.8 6.7 A 3 or 4
Notes: Acronyms: cfs: cubic feet per second
1 Bedrock depth estimates at major rivers conducted by Tetra Tech via seismic refraction and electrical resistivity. FERC: Federal Energy Regulatory Commission
Bedrock depth estimates at intermediate rivers conducted by Mountain Valley via desktop review of GIS data and soil resistivity data. FS: factor of safety
2 Proposed Mitigation Measures: ft: feet
A: None Required; installed per 49 CFR 192.327 (PHMSA & DOT, 2011) ID: Identification
If navigability is not officially determined, pipeline buried with a minimum 4-foot depth of cover LDB: left descending bank
B: Pipeline buried with a minimum of 4-foot depth of cover mm: millimeter
C: Pipeline buried with a minimum of 5-foot depth of cover MP: mile post
D: Pipeline buried with a minimum of 6-foot depth of cover NA: not applicable
E: Pipeline buried with a minimum of 7-foot depth of cover sq. mi.: square mile
F: See mitigation options detailed in Sections 5.2 RDB: right descending bank
RI: recurrence interval
3 Alternative mitigation option details in Sections 5.1.1., 5.1.2, and 5.1.3. UNT: Unnamed Tributary

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APPENDIX B: POTENTIAL LATERAL CHANNEL EROSION AND MITIGATION

Table B-1: Potential Lateral Channel Erosion and Mitigation

Historical Migration Proposed Horizontal

Location Zone Setback
(ft)1 Factor of (ft)3
Safety
FERC Left Right Left Right
Waterbody Name (ft)2
Classification State County MP Descending Descending Descending Descending
Bank Bank Bank Bank
North Fork Fishing Creek Intermediate West Virginia Wetzel 0.7 19 16 7 26 23
Fallen Timber Run* Intermediate West Virginia Wetzel 2.3 21 116 27 48 143
Price Run* Intermediate West Virginia Wetzel 5.0 96 23 24 120 47
Sams Run* Intermediate West Virginia Wetzel 7.9 8 16 5 13 21
Little Tenmile Creek* Intermediate West Virginia Harrison 15.4 16 51 13 29 64
Little Rockcamp Run* Intermediate West Virginia Harrison 17.8 58 53 22 80 75
Rockcamp Run* Intermediate West Virginia Harrison 18.7 30 33 13 43 46
Grass Run* Intermediate West Virginia Harrison 20.8 34 49 17 51 66
UNT to Grass Run* Intermediate West Virginia Harrison 21.6 15 27 8 23 35
Indian Run Intermediate West Virginia Harrison 23.0 15 32 9 24 41
Salem Fork* Intermediate West Virginia Harrison 25.9 35 31 13 48 44
Laural Run* Intermediate West Virginia Doddridge 34.8 15 15 6 21 21
Right Fork Freemans Creek Intermediate West Virginia Lewis 42.5 14 25 8 22 33
Fink Creek Intermediate West Virginia Lewis 44.7 16 27 9 25 36
Left Fork Freemans Creek Intermediate West Virginia Lewis 45.8 24 15 8 32 23
Sand Fork Intermediate West Virginia Lewis 55.1 38 19 11 49 30
Indian Fork Intermediate West Virginia Lewis 58.5 20 16 7 27 23
UNT to Bens Run Intermediate West Virginia Lewis 59.4 23 29 10 33 39
UNT to Indian Fork Intermediate West Virginia Lewis 59.9 25 25 10 35 35
Second Big Run* Intermediate West Virginia Lewis 61.2 178 344 104 282 448
UNT to Second Big Run Intermediate West Virginia Lewis 61.3 59 463 104 163 567
Clover Fork Intermediate West Virginia Lewis 65.4 27 28 11 38 39
Barbecue Run Intermediate West Virginia Braxton 67.4 8 38 9 17 47
Left Fork Knawl Creek Intermediate West Virginia Braxton 68.7 20 26 9 29 35
Knawl Creek Intermediate West Virginia Braxton 68.7 35 19 11 46 30
UNT to Falls Run Intermediate West Virginia Braxton 71.6 8 34 8 16 42
Falls Run Intermediate West Virginia Braxton 72.4 41 3 9 50 12
Little Kanawha River Major West Virginia Braxton 74.8 58 53 22 80 75
Stonecoal Run Intermediate West Virginia Braxton 76.7 22 13 7 29 20
UNT to Little Kanawha River Intermediate West Virginia Braxton 77.6 31 6 7 38 13
UNT to Left Fork Holly River Intermediate West Virginia Braxton 79.7 19 17 7 26 24
Left Fork Holly River Intermediate West Virginia Webster 81.6 36 56 18 54 74
Oldlick Creek Intermediate West Virginia Webster 82.3 22 64 17 39 81
Right Fork Holly Creek Intermediate West Virginia Webster 84.1 85 34 24 109 58

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Historical Migration Proposed Horizontal
Location Zone Setback
(ft)1 Factor of (ft)3
Safety
FERC Left Right Left Right
Waterbody Name (ft)2
Classification State County MP Descending Descending Descending Descending
Bank Bank Bank Bank
Elk River Major West Virginia Webster 87.3 94 117 42 136 159
UNT to Elk River Intermediate West Virginia Webster 87.6 108 16 25 133 41
UNT to Camp Creek Intermediate West Virginia Webster 92.4 137 12 30 167 42
UNT to Camp Creek Intermediate West Virginia Webster 93.0 273 63 67 340 130
Camp Creek Intermediate West Virginia Webster 93.1 151 14 33 184 47
Amos Run Intermediate West Virginia Webster 97.7 45 168 43 88 211
Lost Run Intermediate West Virginia Webster 98.6 25 21 9 34 30
Laurel Creek Intermediate West Virginia Webster 98.8 33 20 11 44 31
UNT to Birch River Intermediate West Virginia Webster 104.9 18 159 35 53 194
UNT to Strouds Creek Intermediate West Virginia Webster 110.1 16 28 9 25 37
UNT to Barn Run Intermediate West Virginia Nicholas 111.8 23 16 8 31 24
Big Beaver Creek Intermediate West Virginia Nicholas 114.3 33 44 15 48 59
Big Beaver Creek Intermediate West Virginia Nicholas 116.2 36 55 18 54 73
Gauley River Major West Virginia Nicholas 118.9 179 106 57 236 163
UNT to Little Laurel Creek Intermediate West Virginia Nicholas 120.3 158 107 53 211 160
UNT to Little Laurel Creek Intermediate West Virginia Nicholas 120.3 178 87 53 231 140
Jims Creek Intermediate West Virginia Nicholas 123.4 51 237 58 109 295
Hominy Creek Intermediate West Virginia Nicholas 126.9 40 43 17 57 60
Sugar Branch Intermediate West Virginia Nicholas 130.5 34 19 11 45 30
UNT to Hominy Creek Intermediate West Virginia Nicholas 131.5 13 15 6 19 21
UNT to Hominy Creek Intermediate West Virginia Nicholas 132.4 72 6 16 88 22
UNT to Meadow Creek Intermediate West Virginia Greenbrier 140.4 13 31 9 22 40
Meadow River Intermediate West Virginia Greenbrier 144.0 47 49 19 66 68
Little Sewell Creek Intermediate West Virginia Greenbrier 147.0 35 16 10 45 26
Buffalo Creek Intermediate West Virginia Greenbrier 154.9 20 14 7 27 21
Lick Creek Intermediate West Virginia Summers 162.9 23 38 12 35 50
Hungard Creek Intermediate West Virginia Summers 169.8 160 423 117 277 540
Hungard Creek Intermediate West Virginia Summers 170.0 30 163 39 69 202
Greenbrier River Major West Virginia Summers 171.4 220 215 87 307 302
Kelly Creek Intermediate West Virginia Summers 172.7 16 54 14 30 68
Wind Creek Intermediate West Virginia Monroe 176.7 73 68 28 101 96
UNT to Wind Creek Intermediate West Virginia Monroe 176.7 109 32 28 137 60
UNT to Stoney Creek Intermediate West Virginia Monroe 177.4 29 33 12 41 45
Stony Creek Intermediate West Virginia Monroe 179.1 11 8 5 16 13
Slate Run Intermediate West Virginia Monroe 182.4 27 17 9 36 26
Indian Creek Intermediate West Virginia Monroe 182.8 38 41 16 54 57
UNT to Hans Creek Intermediate West Virginia Monroe 184.2 94 35 26 120 61
Hans Creek Intermediate West Virginia Monroe 187.6 70 76 29 99 105

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Historical Migration Proposed Horizontal
Location Zone Setback
(ft)1 Factor of (ft)3
Safety
FERC Left Right Left Right
Waterbody Name (ft)2
Classification State County MP Descending Descending Descending Descending
Bank Bank Bank Bank
Dry Creek Intermediate West Virginia Monroe 192.0 11 16 5 16 21
Kimballton Branch Intermediate Virginia Giles 198.9 63 19 16 79 35
Stony Creek* Intermediate Virginia Giles 200.3 505 323 166 671 489
Stony Creek* Intermediate Virginia Giles 200.3 505 323 166 671 489
Stony Creek* Intermediate Virginia Giles 200.3 505 323 166 671 489
UNT to Little Stony Creek Intermediate Virginia Giles 203.5 39 27 13 52 40
UNT to Little Stony Creek Intermediate Virginia Giles 204.2 257 18 55 312 73
Little Stony Creek Intermediate Virginia Giles 204.3 35 240 55 90 295
UNT to Doe Creek Intermediate Virginia Giles 205.8 23 26 10 33 36
Doe Creek Intermediate Virginia Giles 206.7 12 194 41 53 235
UNT to Sinking Creek Intermediate Virginia Giles 207.8 359 25 77 436 102
Sinking Creek Intermediate Virginia Giles 211.1 26 33 12 38 45
Greenbriar Branch Intermediate Virginia Giles 212.9 21 17 8 29 25
UNT to Sinking Creek Intermediate Virginia Giles 216.6 22 88 22 44 110
Craig Creek Intermediate Virginia Montgomery 219.5 30 10 8 38 18
North Fork Roanoke River Intermediate Virginia Montgomery 227.4 28 36 13 41 49
Bradshaw Creek Intermediate Virginia Montgomery 230.9 27 24 10 37 34
Roanoke River Intermediate Virginia Montgomery 235.6 116 51 33 149 84
UNT to Bottom Creek Intermediate Virginia Roanoke 240.8 70 63 27 97 90
Bottom Creek Intermediate Virginia Roanoke 242.4 38 275 63 101 338
North Fork Blackwater River Intermediate Virginia Franklin 249.8 19 22 8 27 30
UNT to North Fork Blackwater River Intermediate Virginia Franklin 251.0 41 56 19 60 75
UNT to North Fork Blackwater River Intermediate Virginia Franklin 251.9 44 36 16 60 52
UNT to Little Creek Intermediate Virginia Franklin 256.0 22 25 9 31 34
Teels Creek Intermediate Virginia Franklin 258.3 19 23 8 27 31
Teels Creek Intermediate Virginia Franklin 259.2 25 31 11 36 42
Teels Creek Intermediate Virginia Franklin 259.4 8 52 12 20 64
Teels Creek Intermediate Virginia Franklin 260.4 58 19 15 73 34
UNT to Teels Creek Intermediate Virginia Franklin 260.9 35 18 11 46 29
Teels Creek Intermediate Virginia Franklin 261.1 44 31 15 59 46
Teels Creek Intermediate Virginia Franklin 261.9 39 27 13 52 40
UNT to Teels Creek Intermediate Virginia Franklin 262.1 30 12 8 38 20
Teels Creek Intermediate Virginia Franklin 262.4 74 35 22 96 57
Little Creek Intermediate Virginia Franklin 262.7 29 30 12 41 42
Little Creek Intermediate Virginia Franklin 263.4 21 195 43 64 238
UNT to Maggodee Creek Intermediate Virginia Franklin 268.6 8 53 12 20 65
UNT to Maggodee Creek Intermediate Virginia Franklin 269.0 12 23 7 19 30
Maggodee Creek Intermediate Virginia Franklin 269.5 33 44 15 48 59

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Historical Migration Proposed Horizontal
Location Zone Setback
(ft)1 Factor of (ft)3
Safety
FERC Left Right Left Right
Waterbody Name (ft)2
Classification State County MP Descending Descending Descending Descending
Bank Bank Bank Bank
Blackwater River Intermediate Virginia Franklin 269.8 38 49 17 55 66
UNT to Blackwater River Intermediate Virginia Franklin 270.3 23 9 6 29 15
Foul Ground Creek Intermediate Virginia Franklin 272.4 21 14 7 28 21
UNT to Poplar Camp Creek Intermediate Virginia Franklin 274.2 58 12 14 72 26
UNT to Blackwater River Intermediate Virginia Franklin 276.6 27 36 13 40 49
UNT to Jacks Creek Intermediate Virginia Franklin 277.5 5 17 5 10 22
Strawfield Creek Intermediate Virginia Franklin 282.4 16 25 8 24 33
Jonnikin Creek Intermediate Virginia Pittsylvania 284.8 35 18 11 46 29
UNT to Rocky Creek Intermediate Virginia Pittsylvania 287.2 31 51 16 47 67
Pigg River Intermediate Virginia Pittsylvania 289.2 48 86 27 75 113
Harpen Creek Intermediate Virginia Pittsylvania 290.0 67 24 18 85 42
Harpen Creek Intermediate Virginia Pittsylvania 290.6 23 31 11 34 42
Harpen Creek Intermediate Virginia Pittsylvania 292.1 23 89 22 45 111
UNT to Harpen Creek Intermediate Virginia Pittsylvania 292.5 46 110 31 77 141
UNT to Cherrystone Creek Intermediate Virginia Pittsylvania 294.3 30 22 10 40 32
Cherrystone Creek Intermediate Virginia Pittsylvania 295.3 18 16 7 25 23
UNT to Pole Bridge Branch Intermediate Virginia Pittsylvania 296.7 133 18 30 163 48
UNT to Little Cherrystone Creek Intermediate Virginia Pittsylvania 301.5 16 23 8 24 31

Notes:
1 Measured from current channel centerline.
2 Factor of safety added to historical migration zone extent associated with both the left and right descending banks.
3 Measured from current channel centerline.
* Denotes a sampling of streams as of June 14, 2018 that MVP has identified via field measurements or desktop study
where one or both Proposed Horizontal Setbacks would increase environmental or landslide risk, or be unsafe or
impractical due to terrain or geology, and thus will employ the patrol mitigation measure.

FERC: Federal Energy Regulatory Commission

ft: feet
MP: mile post

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APPENDIX C: MAINTAINING BURIAL ELEVATION RISKS

When compared to achieving a depth of cover (ADOC), maintaining a burial elevation (MBE)
poses increased risks because of a greater excavation volume. The MBE construction method will
always require a greater volume of soil removed. At times, the MBE excavated volume is 4 times
greater than the ADOC volume. Increased risks include environmental impacts, landslide
potential, public and worker safety, constructability, and pipeline maintenance. Below are two
examples of when the mitigation described in section 5.2.2 would be utilized instead of the
mitigation described in section 5.2.1.
Second Big Run in Lewis County, West Virginia (near milepost 61.2) has an approximate elevation
of 888 feet, with an assumed burial depth of 6 feet. This waterbody has a right descending bank
(RDB) burial distance of 448 feet, which corresponds to a ground elevation of approximately 922
feet. Its left descending bank (LDB) burial distance is 282 feet and has a ground elevation of 925
feet. The MBE installation profile is shown below (no scale). The red line represents the ground
elevation, the blue square is the stream crossing, and the green line is the MBE pipeline.

Assuming a constant trench width of ten feet, this MBE install corresponds to about 100,000
cubic feet of earth being removed. The approximate volume for an ADOC install is 44,640 cubic
feet, which is about 2.25 times less than the MBE.
Stony Creek in Giles County, Virginia (near milepost 200.3) has an approximate elevation of 1648
feet, with an assumed burial depth of 6 feet. This waterbody has a RDB burial distance of 489
feet, which corresponds to a ground elevation of approximately 1695 feet. Its LDB burial distance
is 671 feet and has a ground elevation of approximately 1653 feet. The MBE installation profile
is shown below (no scale). The red line represents the ground elevation, the blue square is the
stream crossing, and the green line is the MBE pipeline. Also, a railroad is located just over 200
feet from the stream crossing and is represented by the black dot.

Assuming a constant trench width of ten feet, this MBE install corresponds to about 148,000
cubic feet of earth being removed. The approximate volume for an ADOC install is 37,560 cubic

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feet, which is about 4 times less than the MBE. In this instance, there is also a railroad nearby.
Lateral erosion will stop at railroads or other similar features.
As stated before, the MBE construction method will always require a greater volume of soil
removed. To reiterate, removing a greater volume of soil increases multiple risks. In general,
removing more soil takes a greater amount of time. With an increased construction time near
waterbodies, the likelihood the streams will be impacted becomes greater.
Risks of landslides will increase because a greater volume of soil will have to be compacted. With
a greater depth of soil removed and put back, the more difficult it becomes to compact in a
correct manner. Without proper compaction, the potential of slips and slides increases.
From roughly milepost 165 to milepost 240, the pipe must not be buried deeper than 10 feet.
There may be some potential for ground settlement from liquefaction in this area. The potential
for liquefaction requires consideration of specific characteristics of soil deposits along the
pipeline route. Liquefaction settlement can be screened out as not posing a credible threat to
cross-country portions of the MVP provided the depth of cover is less than 10 feet.
Should the pipe be buried at greater than normal depths, the soil weight on the pipe becomes a
concern. Additional soil weight can cause hoop stress, pipe ovality, though wall bending stress,
and buckling to be at unsafe levels. Subpar soil compaction also negatively affects the
aforementioned pipe properties.
Geometry and smart in-line-inspection tools will be used on this pipeline. If these tools discover
anomalies, the pipe will likely have to be excavated. Even if the pipe is buried 40 feet deep, it will
still have to be excavated. Once again excavating at this depth poses the environmental,
landslide, safety, and other risks previously described in this appendix.

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