20181638 Ver 1_More Info Recieved_20190117

Strickland, Bev
From:
Miller, Alex <[e-mail]>
Sent:
Thursday, January 17, 2019 9:28 PM
To:
[e-mail]
Cc:
Gibby, Jean B CIV USARMY CESAW (US); McLendon, C S CIV USARMY CESAW (US);
Wicker, Henry M Jr CIV USARMY CESAW (US); Miller, Todd M CIV USARMY CENAO
(US); Higgins, Karen; Homewood, Sue; Faul, Travis; Amanda Mardiney; Ellis, John;
Gledhill-earley, Renee; Patti, Heather (H [e-mail]); Raffenberg, Matthew
Subject:
[External] RE: Request for Additional Information; Mountain Valley Pipeline -Southgate,
Alamance and Rockingham Counties; SAW -2018-00887
Attachments:
MVP Southgate Project_SAW-2018-00887.pdf
External email. Do
not click links or open attachments unless you verified. Send all suspicious email as an attachment to
[e-mail]
Hi Mr. Bailey,
Thank you for your review of MVP Southgate's Joint Permit Application (SAW -2018-00887). Please find the attached
responses to your Request for Additional Information. Mountain Valley is requesting additional time to fully respond to
all of the information requested while we work with the agencies.
Cordially,
Alex V. Miller
Environmental Permitting Lead
on behalf of Mountain Valley Pipeline, LLC
713-374-1599
SOUTH -GATE

riq MVP
SOUTHGATE
Mr. David Bailey
United States Army Corps of Engineers -Wilmington District
Raleigh Regulatory Field Office
3331 Heritage Trade Drive, Suite 105
Wake Forest, North Carolina 27587
SAW -2018-00887
Via Safe Upload
Ms. Karen Higgins
North Carolina Department of Environmental Quality
Division of Water Resources
401 & Buffer Permitting Unit, Wetlands Branch
1617 Mail Service Center
Raleigh, North Carolina 27699 -1617
RE: MVP Southgate Project
SAW -2018-00887
Response to Request for Additional Information
Dear Mr. Bailey and Ms. Higgins,
625 Liberty Avenue, Suite 1700 1 Pittsburgh, PA 15222
833 -MV -SOUTH I [e-mail]
www.mvpsouthgate.com
January 17, 2019
Mountain Valley Pipeline, LLC ("Mountain Valley") is providing this response to your initial comment letter, dated
December 28, 2018, requesting additional information regarding the MVP Southgate Project ("Project"). The
comments from the letter are restated below and are followed by Mountain Valley's response.
While the U.S. Army Corps of Engineers, Wilmington District, Raleigh Regulatory Field Office (Corps)
has verified the delineation of potential waters of the US within a majority of the proposed pipeline
route in North Carolina, there are still sections of the route that have not been delineated or the
delineation has not been verified. In addition, it is our understanding that there may still be some re-
routing of sections of the pipeline. Pending submittal of additional delineations, the Corps may choose
to field -verify the delineation for these areas in order to determine not only the extent of the
jurisdictional impacts, but also the functional quality of the resources, upon which to determine
appropriate compensatory mitigation requirements. (see PCN Section B.4b.).
Response: Mountain Valley understands a completed jurisdictional determination is necessary prior to permit
verification. Mountain Valley is in the process of completing the wetland and waterbody delineation on the
remaining un -surveyed tracts, and will submit the updated delineation data (e.g., GIS data, maps, data sheets,
photographs) when complete. The currently proposed route is still under evaluation by the Federal Energy
Regulatory Commission (FERC) and any route adjustments would require additional survey and verification
for resources managed by the U.S. Army Corps of Engineers, Wilmington District, Raleigh Regulatory Field
Office (Corps). Mountain Valley will continue to work with the Corps for verification of delineated resource
boundaries and functional quality so the appropriate compensatory mitigation requirements can be determined.
Field survey is currently anticipated to be completed in the 3rd quarter, 2019.

NAO-2018-1574
MVP Southgate Project
Page 2 of 2
Changes to the wetland/stream delineation based on the Corps field -review are not all displayed on
Appendix K 2-Ih. For example, W13 -C18-19 is shown as a pond, but was determined to primarily be a
wetland, with a small component of surface water in its western extent. Also, S -C18-18 was determined
to not be potentially jurisdictional. Review all delineation maps and plan sheets to ensure that the field -
approved delineation is shown, and update all acreages/linear feet and impact proposals accordingly.
Further, it is possible that our office will not agree with some of your forested vs. non -forested wetland
designation (e.g. W -A18 -22 -PEM, etc.). However, these distinctions will be made following the
completion of field delineations, field verifications (if necessary), and re -submittal of your PCN and
attachments.
Response: The changes made to the delineated resource area boundaries during the Corps field verification
process conducted on September 5t" and 8t", 2018 were incorporated into the drawing set that was submitted
as part of the Joint Permit Application submitted on November 30"', 2018. Wetland and waterbody boundary
modifications made during the field verification that occurred on September 25th, 2018 were not reflected within
the original Joint Permit Application. These modifications will be submitted to the Corps with the information
obtained during the additional field surveys in 111 quarter, 2019.
3. The permit application appendices are missing the alignment sheets for the Alamance County section
of the proposed project (i.e. Appendix B; Sheets PA-ALNC-H-650-01 through ALNC-H-650-21).
Response: The alignment sheets for the portion of the Project in Alamance County have been uploaded to the
Project website.
Appendices K 2 -Ig, 2 -Ii, and 2-Ik appear to be the same file on the project website. Further, the permit
application package appears to be missing Figure 4 (Wetland & Waterway Delineation Maps) Sheets 1-
103. Please ensure that the project webpage includes the complete and correct documentation.
Response: Mountain Valley reviewed the Project website and updated these files to ensure that the project
webpage includes the complete and correct documentation. Additionally, Mountain Valley can furnish hard
copies upon request.
Please provide detailed plan and profile views for all proposed permanent fills of wetlands, streams,
and other waters, including culvert sizes and lengths, overlaid on the approved delineation.
Response: Mountain Valley will provide final plan and profile views for all proposed permanent fills of aquatic
resources in North Carolina, including culvert sizes and lengths, once all surveys have been completed and
the Project design is finalized (currently forecasted for V quarter, 2019). Any plan and profile drawings
developed in accordance with this request will be submitted to the Corps in a supplemental filing.
Although no rip rap is currently proposed in wetland or stream areas, reference was made to decisions
on rip rap needs being made during construction. Please note that the Corps Wilmington District
considers rip rap to be a permanent impact (though not necessarily a permanent loss). As such, any
rip rap proposed would need to be included in the PCN/application as a permanent impact and
authorized prior to construction.
Response: Should rip rap be proposed within any jurisdictional resource, Mountain Valley will submit for PCN
approval prior to construction.
Based on the Rockingham County alignment sheets (Appendix B), additional avoidance and
minimization of stream and wetland impacts could be achieved. Please review and update all project
plan sheets based on the following comments. If additional avoidance and minimization is not
practicable in these circumstances, please provide documentation to that effect:
M MVP
T SOUTHGATE

NAO-2018-1574
MVP Southgate Project
Page 2 of 2
a. The pipeline would presumably be constructed under roadways via conventional bore methods. As
such, wetland and stream resources located next to roadways (e.g. W -1318-99/S-1318-99, W -1318-
78/S-1318-74, etc.) could be avoided by extending conventional bores slightly beyond roadways.
Costs for extending bores already planned should be considerably less than mobilizing for entirely
new bores.
b. Several streams are proposed to be trenched through along their channel length rather than near
perpendicular (e.g. S -A18-140, S -A18-143, S -A18-147, etc.). Several hundred linear feet of stream
disturbance could be avoided by slight redesigns in pipe centerline.
c. The pipe centerline is proposed to trench through several stream confluences (e.g. S -C18 -38/S -C18-
53, etc.). Prolonged stream disturbance would be expected in these locations due to inherent
stream bank instability at stream confluences, difficulty in reconstructing intersecting stream
banks in their original location, and lack of woody vegetation along stream banks due to long term
maintenance. Slight redesigns in pipe centerline could avoid these issues.
Response: Final design of the Project's route and construction methods are still under development with
an emphasis on avoidance and minimization of wetland and stream resources to the extent practicable.
Documentation of the revised construction procedures and routes will be provided to the Corps to avoid
linear feet of stream disturbance and avoid stream confluences throughout the route development process.
On Appendix M (Section 404/401 Permit Application Proposed Pipeline Route and Impacts) Sheets
1-108, please add the 2018 aerial photo as a background, faded to still allow project details to show
clearly. Within the wetland and stream areas, also add shading or hatching to show temporary
construction impacts, permanent wetland conversion impacts, and permanent wetland/stream fill
impacts. Also clearly note acreages/linear feet of each impact type at each crossing. Provide zoom -
ins of crossing locations if necessary to show details. Note that these impacts/details could also
be shown on Appendix B plans if the two sets of plans should prove redundant.
Response: Mountain Valley will continue to work with the Corps to provide the necessary mapping that
will aid in the evaluation of project impacts.
Given the numerous proposed crossings of wetlands, streams, and open waters, please provide
the itemized proposed impact information in digital format to facilitate efficient processing. Once
additional delineations and any required field verification are complete and you plan to submit the
updated PCN and attachments, please contact David Bailey for the latest ORM upload sheets, as
the upload sheets are frequently revised.
Further, our office is under the impression that all of the delineated wetlands would be classified
as either Headwater Forest, Bottomland Hardwood Forest, Floodplain Pool, or Non -Tidal
Freshwater Marsh types based on the North Carolina Wetland Assessment Method (NCWAM). As
such, for mitigation purposes, the appropriate Wetland Group/Credit Classification would be
Riparian non-Riverine or Riparian Riverine. If applicable, please identify any delineated wetlands
that you would classify instead as Basin Wetland, Seep, or any other NCWAM type that would better
fit the Non -Riparian Wetland Group/Credit Classification.
Response: Mountain Valley will submit a completed ORM upload sheet, with the appropriate wetland
group/credit classification, once field delineations and field verifications are complete.
10. Your current proposal is to acquire compensatory mitigation through private mitigation banks. We
recommend that you also consider contingencies such as acquiring compensatory mitigation
through the North Carolina Division of Mitigation Services (NCDMS) in the event that there are not
enough appropriate private mitigation bank credits available. Further, provide letters from private
Mitigation Banks and/or NCDMS stating that they are willing to provide the appropriate type and
amount of compensatory mitigation credits required for this project. Note that a complete
compensatory mitigation plan, including the letters referenced above, is required by our office for
review and approval prior to verifying the use of NWP 12. (see PCN Sections D.2 and D.3.).
M MVP
T SOUTHGATE

NAO-2018-1574
MVP Southgate Project
Paqe 2 of 2
Further, although our office typically requires compensatory mitigation for permanent conversion
of forested wetlands to another wetland type at a 1:1 ratio, compensatory mitigation for permanent
fill of wetlands (see Access Road PA-RO-113A at MP 41.8) is typically required at a 2:1 ratio. Please
update section 4.1.2 of your project narrative, as well as your related compliance statement on
pages N-2-7 and N-2-8 of your application documents.
Response: The amount of compensatory mitigation will be developed in accordance with the above -
referenced ratios and will be updated once the Project -design is finalized. Mountain Valley will provide an
updated compensatory mitigation plan (including letters of available credit) for permanent fill of wetlands
and permanent conversion of forested wetlands to scrub -shrub or emergent wetlands, In the event that not
enough credits are available through private mitigation banks, Mountain Valley will also acquire
compensatory mitigation through the North Carolina Division of Mitigation Services.
11. We are aware thatthe FERC (Lead Federal Agency) is preparing an Environmental Impact Statement
which addresses the requirements of Section 106 of the National Historic Preservation Act (NHPA)
and Section 7 of the Endangered Species Act (ESA).
a. Their final opinion on whether the proposed activity may affect properties listed, or eligible for
listing, in the National Register of Historic Places is needed before the use of a Nationwide Permit
can be verified for this project. Please provide documentation showing compliance with Section
106 of the NHPA. (see PCN Sections F.7).
b. Their final opinion on whether or not the project "may affect" a listed species or critical habitat is
needed before the use of a Nationwide Permit can be verified for this project. Please provide
documentation showing compliance with Section 7 of the ESA. (see PCN Sections F.8).
Response: Mountain Valley is actively coordinating with the North Carolina State Historic Preservation
Office and the U.S. Fish and Wildlife Service. Final documentation of compliance with Section 106 of the
NHPA and Section 7 of the ESA for Corps jurisdictional areas is currently anticipated in 41h quarter, 2019.
Mountain Valley appreciates the opportunity to provide this information in support of its request for USACE Section
404 authorization of the Project pursuant to Nationwide Permit 12. A complete application is expected in the 2nd
quarter of 20191. Should you have any additional questions or further information to complete your review of the
Project, please do not hesitate to contact Alex Miller at 713-3741599 or via email at [e-mail] or me at
561-691-2808 or via email Matthew. RaffenbergOfpl.com. Thank you for your continued consideration.
Sincerely,
lgnr,,
�- Y��
Matthew Raffenberg
Senior Director, Environmental Services
CC: Jean Gibby, USACF
Scott McLendon, USACE
Henry Wicker, USACE
Todd Miller, USACF
Sue Homewood, NC DEQ
Amanda Mardiney, OEP
John Ellis, USFWS
Renee Gledhill -Early, NCDCR
MVP
TSOUTHGATE