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HomeMy WebLinkAbout20181638 Ver 2_Appdx E Alternatives Analysis_20190208Appendix E Alternatives Analysis Alternatives February 2019 17 Mountain Valley PIPELINE ttc Alternatives The Division will consider whether the variance is the minimum possible deviation from the terms of the applicable Buffer Rule that shall make reasonable use of the property possible. In the context of a linear project, Mountain Valley assumes this calls for a demonstration that it is not reasonably practical to change the alignment of the right-of-way such that the impact would be deemed a perpendicular crossing—for which no variance would be required because 15A NCAC 2B.0267(9) footnotes 1 and 4 would not be applicable. Appendix D demonstrates why compliance with those footnotes is not feasible for the Project. This analysis also demonstrates that buffer impacts have been reduced the maximum extent practical. The Project attempted to make all crossings perpendicular or as close to perpendicular as reasonably possible. Perpendicular alternatives are presented below for each non -perpendicular crossing within the Jordan Watershed where Mountain Valley is requesting a variance. While routing the pipeline, the project used field reconnaissance, aerial photography, project specific LiDAR data, and biological and cultural field surveys during the route identification and evaluation processes to maximize constructability, minimize impacts to sensitive resources and landowners, and to avoid encroachments. In developing the current route, a number of factors were considered, with a heavy emphasis placed on co - locating with and utilizing existing infrastructure corridors such as existing pipeline or powerline rights-of- way to the maximum extent practicable. When collocated with existing infrastructure or utility corridors, the incremental impacts of an additional pipeline are typically less compared to routing through a greenfield area. Benefits of co -locating include: • minimize the amount of tree clearing and forest fragmentation • minimizing impacts to landowners by preventing segments of their property from being isolated by the route (islanding) • minimizing impacts to landowners by limiting new corridors for access to their land, • minimizing the acreage of construction impacts and maximizing temporary impacts • reducing the length of pipe needed to deliver the gas to receipt points, and • minimizing new linear corridors where future land activities would be limited. The amount of existing cleared right-of-way (ROW) within existing infrastructure or utility corridors that is available for use as temporary workspace varies through areas of co -location but will be used to the maximum extent allowed by working agreements with the existing utility companies to minimize tree clearing and new impacts to landowners. Minimizing tree clearing is prioritized, because the 50 -foot permanent maintenance corridor will be revegetated using approved native seed mixes, and with the exception of forested areas, the permanent maintenance corridor will be returned to its existing use and riparian buffer impacts will be temporary. As part of its joint permit application to the U.S. Army Corps of Engineers and DEQ for Nationwide Permit 12 verification, 401 Water Quality Certification, and Riparian Buffer Authorization, the Project evaluated two alternative crossing methods that have the potential to reduce construction -related temporary buffer impacts (MVP Southgate Project, Pre -Construction Notification – Joint Permit Application (Nov. 2018)). It must be noted, however, that even if alternative crossing methods are used, the Project would still need to maintain a 50 -foot permanent maintenance corridor within the buffer above the pipeline. The evaluation of alternative crossing methods was conducted independently for every stream and wetland crossed by the Project in North Carolina, including the buffered streams at issue in this variance request. The alternatives analysis determined that neither of these alternative crossing methods is practicable for any of the buffered streams included in this variance request. The following summarizes these two alternative crossing methods E-1 February 2019 17 Mountain Valley PIPELINE ttc Alternatives and the key technical and logistical considerations that resulted in this conclusion. Please refer to the application on file with DEQ for additional details. The first evaluated alternative crossing method evaluated is a conventional bore. The conventional bore method for cased or uncased pipeline crossings is typically employed under roads or railroad crossings, but may also be employed at shallow wetland or waterbody crossings. Soil conditions, the length of the flight auger string, and equipment torque generally limit this method to a maximum length of approximately 400 feet. This installation method involves digging a bore pit on each side of the feature to be crossed, and typically requires a minimum setback from the feature for worker safety and slope stability purposes. The bore pit and receiving pit vary in size but are usually about 20 feet wide by 60 feet long. This provides the necessary space for the boring machine to insert a pipe joint or pipe string (two or more joints welded together) into the borehole. The depth of the bore pits generally ranges from 10 to 12 feet but may be greater, depending upon topography, to accommodate the minimum of 5 feet of cover over the bored pipeline segment. The depth would be greater for wetlands or waterbodies with an adjacent slope. While the pipeline industry considers this a dependable method for crossing under elevated road beds, highways, and railroad beds, it is not generally preferred for use in areas with shallow or near -surface groundwater. These crossings require large bore pits adjacent to saturated areas with potentially low soil shear strength, particularly near wetlands. Large bore pits in these areas would require shoring of pit walls and implementation of significant dewatering measures. Crossings of these features also would result in an increased risk of the bore -pit walls slumping and/or borehole misalignment due to track settlement. The duration of construction for bored crossings of wetlands and waterbodies typically ranges from three to more than four weeks, depending on the crossing length, topography, soil conditions, and the need for blasting in areas of shallow bedrock. A conventional open -cut crossing of wetlands and waterbodies is generally much quicker, taking days rather than weeks, which minimizes the duration of disturbance of the feature. For these reasons, the conventional bore method is generally not considered as a preferred construction method for crossing wetlands, forested areas, and waterbodies where conventional trenching construction is feasible. No conventional bore crossings were found to be practicable in the Jordan Lake Watershed. The second alternative crossing method evaluated is horizontal directional drilling ("HDD"). HDD is another method that allows for trenchless construction across an area by pre -drilling a hole below the depth of a conventional pipeline lay and then pulling the pipeline through the pre -drilled borehole. Currently, the Project has determined it practicable and is proposing to use this method at the Dan River and Stony Creek Reservoir crossings. The length of pipeline that can be installed by HDD depends upon topography, soil conditions, geology, and pipe diameters and is limited by available technology and equipment sizes. Typically for HDD crossings, electric -grid guide wires will be hand -laid across the land surface along the pipeline right-of-way to help guide the drill bit along the predetermined HDD route. In thickly vegetated riparian areas, a swath approximately two to three feet wide may be cleared across the land surface for the placement of guide wires to monitor the track of the drill alignment, resulting in ground and vegetation disturbance. Following guide wire installation, a directional drilling rig will be set up and a small -diameter pilot hole will be drilled along a prescribed profile. During this process, drilling fluid consisting of bentonite clay and water will be continuously pumped into the hole to remove cuttings and maintain the integrity of the hole. E-2 February 2019 17 Mountain Valley PIPELINE ttc Alternatives However, because it is necessary to prefabricate a section of pipe aboveground that is equal to the length of the HDD, and because existing surface features such as roads and railroads could restrict the length of the prefabricated section to less than that of the HDD, the HDD method may not be appropriate for every site condition encountered. Other technical limitations on the use of HDD include the need for proper geotechnical properties to minimize the potential for inadvertent returns of drilling fluids and limitations imposed by the bend radius of the pipe. Although the HDD method is a proven technology for pipe installation, the potential exists for a HDD installation to fail for a number of reasons, including encountering soil conditions not conducive to boring, caving of the borehole, loss of the drill string in the borehole, loss of circulation, and pullback refusal. Only one HDD crossing is currently proposed in the Jordan Lake Watershed at Stony Creek Reservoir (Impact 26 - VAR: AS -B18-16 / S -B18-16) due to the unique features of the waterbody crossing. The HDD method was not determined to be practicable for any other stream within the watershed. The proposed riparian buffer crossings will comply with the majority of the performance standards associated with the Utility, non -electric classification in the Jordan Watershed Buffer Rules' Table of Uses. However, the Project will require a major variance to complete certain activities associated with all linear pipeline installations. Footnote 1 states that: • "No heavy equipment is used in Zone One"; however, based on the size of the pipeline and required depth of burial, heavy equipment is necessary to safely install the pipe through the Jordan Lake area. • While felled trees could be removed by chain, this would slow the process down unnecessarily since heavy equipment and travel lanes would already be present to install the pipeline system. • Permanent felling of trees would need to occur across the operational "maintained" corridor. Hardship conditions associated with Footnote 4 include land grubbing and grading. To protect the pipe from being compromised by growing root systems, tree roots need to be removed in the 50' operational corridor. The exceptions to this are in wetland areas where the operation width is reduced to 10 feet (centered over the pipeline) in emergent wetlands, scrub shrub wetlands, and within 25 feet of waterbodies; and 30 feet in forested wetlands. Fertilizer may need to be utilized more than once if adequate re -vegetation is not established in the first growing season. To facilitate the Department's review of this variance request, Mountain Valley has provided an individual analysis of each non -perpendicular crossing where a variance is being proposed, which includes an alternative that would cross at a perpendicular angle and rationale as to why it is not feasible for the Project. E-3 February 2019 Impact Specific Analysis Impact 1 — Variance (VAR): S-A 18-60 Alternatives The perpendicular alternative to the currently designed crossing S -A18-60 requires an additional 135' of pipe, would increase the acreage of impacts to landowner(s), and extends through two planned additional temporary workspaces (ATWS) that would need to be relocated in the vicinity, with ATWS 1450 being moved west into the riparian buffers of S -A18-60, and ATWS 1449 moving northeast into the riparian buffers to avoid a water detention area for the adjacent solar facility. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe and relocation of the two ATWS existing into less desirable areas closer to the waterbody. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 705 square feet in Zone 1 and 330 square feet in Zone 2. There is no change in the number of Waterbodies, or residences in close proximity, but one additional parcel is affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacted tracts, and the need to find suitable locations and the associated impacts of moving the two existing ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-60 Feature Proposed Perpendicular Difference Crossing Alternative Parallel or adjacent to existing ROW No No - Pipeline length (feet) 883 1018 +135 Zone 1 buffertotal impacts (sq ft) 5225 4520 -705 Zone 2 buffertotal impacts (sq ft) 3344 3014 -330 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 2 +1 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional 0/0 0/0 0/0 temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ E-4 February 2019 Impact 2 - VAR: S -A18-183 Alternatives The perpendicular alternative to the currently designed crossing S -A18-183 would no longer be co -located with the Duke transmission line. There is an additional 157' of pipe, but the entire 1,006 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route extends through two planned ATWS that would need to be relocated in the vicinity. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, and additional side slope construction. The alternative route would result in a decrease in impacts of 1,952 square feet in Zone 1 and 3,938 square feet in Zone 2. There is no change in the number of waterbodies or residences in close proximity, but one additional parcel is affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacted tracts, islanding of landowner tracts, and the need to find suitable locations for the two existing ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-183 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 849 1006 +157 Zone 1 buffertotal impacts (sq ft) 7318 5366 -1952 Zone 2 buffertotal impacts (sq ft) 7121 3183 -3938 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 2 +1 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ E-5 February 2019 Impact 3 - VAR: SS -SOIL 18-02 Alternatives The perpendicular alternative to the currently designed crossing SS-SOIL18-02 would no longer be co - located with the Duke transmission line. There is an additional 47 F of pipe, but the maj ority of the 1,006 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing Duke corridor and the new corridor. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 1,083 square feet in Zone 1 and 512 square feet in Zone 2. There is no change in the number of NWI waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, and islanding of landowner tracts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at SS-SOM8-02 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No Yes Pipeline length (feet) 1336 1807 +471 Zone 1 buffertotal impacts (sq ft) 5681 4598 -1083 Zone 2 buffertotal impacts (sq ft) 3759 3247 -512 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 3 3 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ E-6 February 2019 Impact 4 - VAR: AS-NHD-305 Alternatives The perpendicular alternative to the currently designed crossing AS-NHD-305 would no longer be co - located with the Duke transmission line. There is an additional 254' of pipe, but the entire 1,387 feet of the alternative is located through existing forested and residential tracts, would increase the acreage of impacts to the landowner(s) property while also creating a corridor for access to the landowner's yard from the Duke corridor that is currently separated by forest, and would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route would extend through a currently designed ATWS that would need to be relocated. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 1,947 square feet in Zone 1 and 5,129 square feet in Zone 2. There is no change in the number of Waterbodies, residences in close proximity, or additional parcels affected. Due to the loss of co -location, additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts and creating an access corridor from the Duke corridor that does not currently exist, islanding of landowner tracts, and the need to find a suitable location for the existing ATWS. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at AS-NHD-305 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 1133 1387 +254 Zone 1 buffertotal impacts (sq ft) 7864 5917 -1947 Zone 2 buffertotal impacts (sq ft) 8421 3292 -5129 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.uscis.ciov/ ESRI - GIS Mapping - http://www.esri.com/ E-7 February 2019 Impact 5 - VAR: S -C18-15 Alternatives The perpendicular alternative to the currently designed crossing S -C18-15 would no longer be co -located with the Duke transmission line. There is an additional 253' of pipe, but the entire 933 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route extends through a planned ATWS that would need to be relocated to the southeast and would likely result in additional riparian buffer impact. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, additional side slope construction. The alternative route would result in a decrease in impacts of 11,495 square feet in Zone 1 and 5,349 square feet in Zone 2. There is no change in the number of Waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, islanding of landowner tracts, and the need to find a suitable location for the existing ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -C18-15 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 680 933 +253 Zone 1 buffertotal impacts (sq ft) 16615 5120 -11495 Zone 2 buffertotal impacts (sq ft) 8547 3198 -5349 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 4 4 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ E-8 February 2019 Impact 6 - VAR: S -B 18-94 Alternatives The perpendicular alternative to the currently designed crossing S -B 18-94 has an additional 59' of pipe, but the entire 756 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to landowner(s), and extends through a planned ATWS that would need to be relocated in the vicinity. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, additional side slope construction, and relocation of an existing ATWS. Without considering the impacts from the ATWS move, the alternative route would result in a decrease in impacts of 1510 square feet in Zone 1 and 763 square feet in Zone 2. There is no change in the number of Waterbodies, or residences in close proximity, but two additional parcels are crossed. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacted tracts, and the need to find a suitable location and the associated impacts of moving the ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -B18-94 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 697 756 +59 Zone 1 buffertotal impacts (sq ft) 6894 5384 -1510 Zone 2 buffertotal impacts (sq ft) 4239 3476 -763 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 4 +2 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ E-9 February 2019 Impact 7 - VAR: S-A 18-87 Alternatives The perpendicular alternative to the currently designed crossing S -A18-87 would no longer be co -located with the Duke transmission line. There is an additional 35' of pipe, but the entire 519 feet of the alternative is through existing forested and agricultural tracts, would increase the acreage of impacts to landowner(s) including operational workspace in agricultural field, and would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route extends through a planned ATWS that would need to be relocated, either requiring additional acreage of agricultural land, or additional clearing of forested tracts. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 5,145 square feet in Zone 1 and 2,531 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, islanding of landowner tracts, increased impacts in forested and agricultural areas, and the need to find a suitable location for the existing ATWS. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-87 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 484 519 +35 Zone 1 buffertotal impacts (sq ft) 10169 5024 -5145 Zone 2 buffertotal impacts (sq ft) 5738 3207 -2531 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 1 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.uscis.ciov/ ESRI - GIS Mapping - http://www.esri.com/ E-10 February 2019 Impacts 8, 9,& 10 -VAR: S -C18-60, 62, and 63 Alternatives The perpendicular alternative to the currently designed crossings S-08-60, 62, and 63 would no longer be co -located with the Duke transmission line. There is an additional 823' of pipe, but the entire 4,817 feet of the alternative is through existing forested and agricultural tracts, including operational workspace in agricultural fields. The alternative would significantly increase the acreage of impacts to landowner(s), while also creating a corridor for access to several landowner's tracts from the Duke corridor that is currently separated by forest. It would also create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route would require five planned ATWS to be relocated along the new route. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 15,156 square feet in Zone 1 and 8,927 square feet in Zone 2. There is no change in the number of waterbodies or residences in close proximity, or additional parcels affected, but a decrease of 22,510 square feet would occur along the alternative. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, islanding of landowner tracts, creating a corridor for access to several landowner's tracts from the Duke corridor, and the need to find suitable locations and the associated impacts of moving the five existing ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -C18-60,62,63 Feature Proposed Crossing Perpendicular Alternative Difference Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 3994 4817 +823 Zone 1 buffertotal impacts (sq ft) 19836 4680 -15156 Zone 2 buffertotal impacts (sq ft) 12047 3120 -8927 Number of waterbodies crossed a/ 3 3 0 NWI wetland impact (sq ft) b/ 22510 0 -22510 Total number of parcels crossed 4 4 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary workspace) 0/0 0/0 0/0 E-11 February 2019 17 Mountain Valley PIPELINE ttc Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -C18-60,62,63 Feature Proposed Crossing Perpendicular Difference Alternative a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 11&12 -VAR: S -B18-59 & SS-SOIL18-04 The perpendicular alternative to the currently designed crossing S -B18-59 & SS-SOIL18-04 would no longer be co -located with the Duke transmission line, while the proposed route is for over half of the span. There is an additional 1,339' of pipe, but the majority of the 5,876 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to the landowner(s) property while also creating a corridor for access to a number of landowner's pastures from the Duke corridor that is currently separated by forest. The alternative would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route would require relocating five planned ATWS. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 27,940 square feet in Zone 1 and 16,042 square feet in Zone 2. There alternative crosses four fewer waterbodies, has the same number of residences in close proximity, and crosses four fewer parcels. Due to the loss of co -location, additional ATWS required to support additional pipe bends, additional pipe footage, increased acreage of landowner impacts and creating an access corridor from the Duke corridor that does not currently exist, islanding of landowner tracts, and the need to find suitable locations for the ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -B18-59 & SS-SOIL18-04 Feature Proposed Crossing Perpendicular Alternative Difference Parallel or adjacent to existing ROW No No Pipeline length (feet) 4537 5876 +1339 Zone 1 buffer total impacts (sq ft) 32606 4666 -27940 Zone 2 buffer total impacts (sq ft) 19153 3111 -16042 Number of waterbodies crossed a/ 5 1 -4 E-12 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -B18-59 & SS-SOIL18-04 Feature Proposed Crossing Perpendicular Difference Parallel or adjacent to existing ROW Yes Alternative NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 8 4 -4 Number of residences within 25 and 50 1925 1577 -348 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 13 - VAR: S-A 18-120 The perpendicular alternative to the currently designed crossing S -A18-120 would no longer be co -located with the Duke transmission line. There is an additional 36' of pipe, but the majority of the 392 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing Duke corridor and the new corridor. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 955 square feet in Zone 1 and 348 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, and islanding of landowner tracts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-120 Feature Proposed Crossing Perpendicular Alternative Difference Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 356 392 +36 Zone 1 buffertotal impacts (sq ft) 5680 4725 -955 Zone 2 buffer total impacts (sq ft) 1925 1577 -348 E-13 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -A18-120 Feature Proposed Crossing Perpendicular Difference Alternative Number of waterbodies crossed a/ 2 2 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 1 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 14 -VAR: S -A18-125 The perpendicular alternative to the currently designed crossing S -A18-125 would no longer be co -located with the Duke transmission line. There is an additional 616' of pipe, but the entire 1,673 feet of the alternative is through existing forested or agricultural tracts. The alternative would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route extends stream S -A18-123, S -A18-129, and WB -A18-128 that were previously avoided, and requires two planned ATWS to be relocated. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, and additional waterbody crossings. The alternative route would result in a decrease in impacts of 2,202 square feet in Zone 1 and 6,685 square feet less in Zone 2, however SA -18- 129 is ephemeral and does not have a buffer despite being crossed. There is no change in the number of residences in close proximity, but one additional parcel is affected, one additional waterbody is crossed, and 7,473 square feet more of NWI wetlands are impacted by the alternative. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional waterbody crossings, additional wetland impacts, islanding of landowner tracts, additional wetland impacts, and the need to find suitable locations for the two ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-14 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -A18-125 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 1057 1673 +616 Zone 1 buffertotal impacts (sq ft) 17902 15700 -2202 Zone 2 buffertotal impacts (sq ft) 12855 6170 -6685 Number of waterbodies crossed a/ 1 2 +1 NWI wetland impact (sq ft) b/ 0 7473 +7473 Total number of parcels crossed 1 2 +1 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 15&16 -VAR: S -A18-132; S -A18 -136 -Zone Impact The perpendicular alternative to the currently designed crossing S -A18-132; S -A18 -136 -Zone Impact would no longer be co -located with the Duke transmission line. There is an additional 320' of pipe, but the entire 1,244 feet of the alternative is through existing forested tracts, would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing Duke corridor and the new corridor. Additionally, the alternative route extends stream S -A18-134 that was previously avoided, has significant more Zone 1 impacts, stream S -A18-136 goes from a buffer impact with no waterbody crossing to a perpendicular waterbody crossing, and requires a planned ATWS to be relocated. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, and additional waterbody crossings. The alternative route would result in an increase in impacts of 6,340 square feet in Zone 1 and a decrease in impacts of 1,861 square feet Zone 2. There is no change in the number of residences in close proximity or additional parcels affected, but two additional waterbodies are crossed. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional waterbody crossings, islanding of landowner tracts, and the need to find a suitable location for the existing ATWS areas. There is no reasonable and practical alternative to E-15 February 2019 17 Mountain Valley PIPELINE ttc Alternatives the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-132,134,136 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW Yes No Pipeline length (feet) 924 1244 +320 Zone 1 buffer total impacts (sq ft) 8864 15204 +6340 Zone 2 buffer total impacts (sq ft) 11582 9721 -1861 Number of waterbodies crossed a/ 1 3 +2 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and 0/0 0/0 0/0 associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data.nconemap.gov/geoportal/catalog/search/resource/detaiIs.page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 17 -VAR: SS-SOIL18-06 The perpendicular alternative to the currently designed crossing SS-SOIL18-06 has an additional 471' of pipe, would increase the acreage of impacts to landowner(s), adding impacts to two tracts on both sides of the Duke corridor instead of keeping impacts within the tracts on just one side of the existing corridor, and would require the relocation of four planned ATWS. Constructability concerns include: crossing the Duke corridor twice in a short span, a significant angle near a bore to cross Dodd road, an additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, and relocation of the four ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 1,083 square feet in Zone 1 and 512 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, impacts to both sides of the Duke corridor on two tracts, and the need to find suitable locations for the four ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-16 February 2019 Alternatives Comparison of the Preferred Route and Perpendicular Alternative at SS-SOIL18-06 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No Yes Pipeline length (feet) 1336 1807 +471 Zone 1 buffertotal impacts (sq ft) 5681 4598 -1083 Zone 2 buffertotal impacts (sq ft) 3759 3247 -512 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 3 3 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 18 -VAR: S -C18-11 The perpendicular alternative to the currently designed crossing S-08-11 has an additional 153' of pipe, would increase the acreage of impacts to landowner(s), and would require the relocation of three planned ATWS. While the riparian buffer for the primary stream impacted is perpendicular with the alternative, other streams are impacted like AS -C 18-12 that is not buffered because itis ephemeral, but it drains directly into S -C18-11 the primary stream. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, and relocation of the four existing ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 7,137 square feet in Zone 1 and 1,081 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacts to non -buffered streams, and the need to find suitable locations for the four existing ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-17 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -C18-11 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 1182 1335 +153 Zone 1 buffer total impacts (sq ft) 15018 7881 -7137 Zone 2 buffertotal impacts (sq ft) 4447 3366 -1081 Number of waterbodies crossed a/ 2 2 0 NWI wetland impact (sq ft) b/ 1 1 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional 0/0 0/0 0/0 temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS — Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 19 - VAR: AS-NHD-1549 The perpendicular alternative to the currently designed crossing AS-NHD-1549 has an additional 31' of pipe, would increase the acreage of impacts to landowner(s), and extends through a planned additional temporary workspaces (ATWS) that would need to be relocated in the vicinity. Constructability concerns include: relocation of the ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 1,195 square feet in Zone 1 and 764 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, increased acreage of landowner impacts, and the need to find a suitable location and the associated impacts of moving the ATWS. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-18 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at AS-NHD-1549 Feature Feature Proposed Crossing Perpendicular Difference Parallel or adjacent to existing ROW Alternative No Parallel or adjacent to existing ROW Yes No 599 Pipeline length (feet) 490 521 +31 Zone 1 buffer total impacts (sq ft) 5702 4507 -1195 Zone 2 buffer total impacts (sq ft) 3768 3004 -764 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and 0/0 0/0 0/0 associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data.nconemap.gov/geoportal/catalog/search/resource/detaiIs.page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 20&21 - VAR: S -C 18-30, S -C 18-28 The perpendicular alternative to the currently designed crossings S -C 18-30, and S -C 18-28 has an additional 158' of pipe and would increase the acreage of impacts to landowner(s). Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 3,022 square feet in Zone 1 and 2,350 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, and increased acreage of landowner impacts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -C18-28,30 Feature Proposed Crossing Perpendicular Alternative Difference Parallel or adjacent to existing ROW No No Pipeline length (feet) 599 757 +158 Zone 1 buffertotal impacts (sq ft) 14435 11413 -3022 Zone 2 buffer total impacts (sq ft) 8787 6437 -2350 E-19 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -C18-28,30 Feature Proposed Crossing Perpendicular Difference Alternative Number of waterbodies crossed a/ 2 2 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 22 - VAR: S-A 18 -76 -Zone Impact The perpendicular crossing of S -A18-78 causes the construction workspace to impact the buffer of S -A18- 76. Adjusting the alignment away from the S-A 18-76 buffer would create a non -perpendicular crossing at S -A18-78. Impact 23 - VAR: S-A 18 -76 -Zone Impact -3 The perpendicular crossing of S -A18-77 causes the construction workspace to impact the buffer of S -A18- 76. Adjusting the alignment away from the S-A 18-76 buffer would create a non -perpendicular crossing at S-A 18-77. Impact 24 -VAR: S -A18-70 & S -A18-72 The perpendicular alternative to the currently designed crossing S -A18-70 & S -A18-72 would no longer be co -located with the existing access road on the edge of the landowner's property. There is an additional 40' of pipe, but the alternative route would run through the middle of the landowner's pasture and all be greenfield impacts instead of staying on the edge of the property and utilizing the existing access road as workspace. The alternative would increase the acreage of impacts to landowner(s), and would create an islanding effect between the existing property boundary and access road, and the new corridor. The constructability concerns include additional side slope construction. The alternative route would result in a decrease in impacts of 3,823 square feet in Zone 1 and 31 square feet in Zone 2. There is no change in the number of residences in close proximity or additional parcels affected, and one fewer NWI waterbody is affected. E-20 February 2019 17 Mountain Valley PIPELINE ttc Alternatives Due to additional pipe footage, increased acreage of landowner impacts, loss of co -location with the existing access road, and islanding of a tract. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-70 & S -A18-72 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 1734 1774 +40 Zone 1 buffertotal impacts (sq ft) 9206 5383 -3823 Zone 2 buffertotal impacts (sq ft) 3394 3425 +31 Number of waterbodies crossed a/ 2 1 -1 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 3 3 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 25 -VAR: S -B18-12 The perpendicular alternative to the currently designed crossing S -B18-12 has an additional 779' of pipe, would increase the acreage of impacts to landowner(s), and require a relocation of three planned ATWS. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing, and relocation of the three ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 30,110 square feet in Zone 1 and 14,959 square feet in Zone 2. There is no change in the number of waterbodies, or residences in close proximity, but one less parcel is affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, and the need to find suitable locations and the associated impacts of moving E-21 February 2019 17 Mountain Valley PIPELINE ttc Alternatives the two ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S-11318-12 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 1989 2768 +779 Zone 1 buffer total impacts (sq ft) 34803 4693 -30110 Zone 2 buffer total impacts (sq ft) 18087 3128 -14959 Number of waterbodies crossed a/ 2 1 -1 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 4 3 -1 Number of residences within 25 and 50 feet of the edge of the construction ROW (and 0/0 0/0 0/0 associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data.nconemap.gov/geoportal/catalog/search/resource/detaiIs.page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 26 - VAR: AS -B18-16 / S -B18-16 This is proposed to be an HDD crossing. Trees will be felled to allow line of sight and a guide wire, but impacts in the riparian buffer are expected to be minimal since the drill pits will be outside the riparian buffer. Impact 27 - VAR: AS-NHD-1547 The perpendicular alternative to the currently designed crossing AS-NHD-1547 has an additional 242' of pipe, would increase the acreage of impacts to landowner(s) and move the operational acreage from the edge of the existing pasture out into the area currently being utilized. Additionally, the alternative would impact forest adjacent to the larger Deep Creek south of the proposed location, and require a relocation of one planned ATWS. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing, and relocation of the ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 2,263 square feet in Zone 1 and 1,545 square feet in Zone 2. There is no change in the number of Waterbodies, residences in close proximity, or additional parcels affected. E-22 February 2019 17 Mountain Valley PIPELINE ttc Alternatives Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, impacts moved from the edge of the pasture, clearing of trees in the current Deep Creek Buffer, and the need to find a suitable location and the associated impacts of moving the ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at AS-NHD-1547 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 817 1059 +242 Zone 1 buffertotal impacts (sq ft) 8361 6098 -2263 Zone 2 buffertotal impacts (sq ft) 4593 3048 -1545 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 3 3 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 28 - VAR: AS-NHD-3040 The perpendicular alternative to the currently designed crossing AS-NHD-3040 has an additional 27' of pipe, but the entire length of the alternative is through existing forested tracts and would increase the acreage of impacts to landowner(s), and extend through a planned ATWS that would need to be relocated. Constructability concerns include: additional ATWS required to support additional pipe bends and relocation of the ATWS. Without considering the impacts from the ATWS move, the alternative route would result in a decrease in impacts of 217 square feet in Zone 1 and 120 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, and the need to find a suitable location for the ATWS areas. There is no E-23 February 2019 17 Mountain Valley PIPELINE ttc Alternatives reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at AS-NHD-3040 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 696 723 +27 Zone 1 buffer total impacts (sq ft) 4764 4547 -217 Zone 2 buffertotal impacts (sq ft) 3150 3030 -120 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW 0/0 0/0 0/0 (and associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 29 -VAR: S -A18-250 The perpendicular alternative to the currently designed crossing S -A18-250 has an additional 31' of pipe, but the entire length of the alternative is through existing forested tracts. The alternative would increase the acreage of impacts to landowner(s), while also creating a corridor for access from the proposed operational corridor that is currently separated by forest. The alternative also and extends through a planned ATWS that would need to be relocated. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing, and relocation of the ATWS. Without considering the impacts from the ATWS move, the alternative route would result in a decrease in impacts of 892 square feet in Zone 1 and 1,194 square feet in Zone 2. There is no change in the number of residences in close proximity, but one additional parcel is affected, and one less NWI waterbody is impacted. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, creating a corridor for access to a landowner tract that would otherwise have E-24 February 2019 17 Mountain Valley PIPELINE ttc Alternatives a forested buffer, and the need to find a suitable location for the ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. Comparison of the Proposed Route and Perpendicular Alternative at S -A18-250 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 987 1018 +31 Zone 1 buffer total impacts (sq ft) 5944 5052 -892 Zone 2 buffer total impacts (sq ft) 4466 3272 -1194 Number of waterbodies crossed a/ 2 1 -1 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 3 +1 Number of residences within 25 and 50 feet of the edge of the construction ROW (and 0/0 0/0 0/0 associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data.nconemap.gov/geoportal/catalog/search/resource/detaiIs.page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 30 - VAR: AS-NHD-3025 The perpendicular alternative to the currently designed crossing AS-NHD-3025 has an additional 123' of pipe, would increase the acreage of impacts to landowner(s), increase forested impacts, and extends through two planned ATWS that would need to be relocated. Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe and relocation of the two ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 898 square feet in Zone 1 and 644 square feet in Zone 2. There is no change in the number of Waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, increased forested clearing, and the need to find suitable locations for the two ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-25 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at AS-NHD-3025 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 1207 1330 +123 Zone 1 buffer total impacts (sq ft) 5401 4503 -898 Zone 2 buffer total impacts (sq ft) 3646 3002 -644 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 3 3 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and 0/0 0/0 0/0 associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data.nconemap.gov/geoportal/catalog/search/resource/detaiIs.page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 31 -VAR: S -A18-233 The perpendicular alternative to the currently designed crossing S -A18-233 has an additional 65' of pipe, would increase the acreage of impacts to landowner(s), increase forested clearing, and extends through two planned ATWS that would need to be relocated. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, additional side slope construction, and relocation of the two ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 468 square feet in Zone 1 and 340 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected, but there is 271square feet less NWI wetland impacts. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacted tracts, additional forested clearing, and the need to find suitable locations for the two ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-26 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -A18-233 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 835 900 +65 Zone 1 buffer total impacts (sq ft) 7133 6665 -468 Zone 2 buffer total impacts (sq ft) 3480 3140 -340 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 1762 1491 -271 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and 0/0 0/0 0/0 associated additional temporary workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data.nconemap.gov/geoportal/catalog/search/resource/detaiIs.page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 32 -VAR: AS -A18 -233 -Zone Workspace This ATWS was moved and there are no buffer impacts. Impact 33 - VAR: AS-NHD-1551 The perpendicular alternative to the currently designed crossing AS-NHD-1551 has an additional 98' of pipe, would increase the acreage of impacts to landowner(s), and extends through two planned ATWS that would need to be relocated. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing, and relocation of the two ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 780 square feet in Zone 1 and 540 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacted tracts, and the need to find suitable locations and the associated impacts of moving the two ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-27 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at AS-NHD-1551 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 484 582 +98 Zone 1 buffertotal impacts (sq ft) 5299 4519 -780 Zone 2 buffertotal impacts (sq ft) 3552 3012 -540 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 34 - VAR: S -B 18 -3 -Zone Impact S -B 18-3 is between the perpendicular crossing of S -B 18-7 and the perpendicular crossing of Indian Village Trail, and adjusting the route to avoid the S -B18-3 buffer impact would require additional pipe bends and ATWS and would push the construction impacts toward the buffer of WB -B 18-1. Impact 35 - VAR: S -B18-11 The perpendicular alternative to the currently designed crossing S -B 18-11 has an additional 3 F of pipe and would increase the acreage of impacts to landowner(s). Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe, additional tree clearing, and additional side slope construction. The alternative route would result in a decrease in impacts of 1,109 square feet in Zone 1 and 64 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, and increased acreage of landowner impacts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-28 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -B18-11 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 538 569 +31 Zone 1 buffertotal impacts (sq ft) 5848 4739 -1109 Zone 2 buffertotal impacts (sq ft) 4061 3997 -64 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 1 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 36 - VAR: S -A18-15; WB -A18 -16 -Zone Impact The perpendicular alternative to the currently designed crossing S-A 18-15; WB -A18 -16 -Zone Impact has an additional 43' of pipe, would move the route closer to homes, and would increase the acreage of impacts to landowner(s). Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe, and would likely be located within the buffer area of S-A 18-15 due to constraints on space in the immediate vicinity. Without accounting for additional buffer impacts from another ATWS, the alternative route would result in a decrease in impacts of 556 square feet in Zone 1 and 1,238 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, moving the pipe closer to homes, and increased acreage of landowner impacts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-29 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -A18-15; WB -A18 -16 -Zone Impact Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 533 576 +43 Zone 1 buffertotal impacts (sq ft) 5066 4510 -556 Zone 2 buffertotal impacts (sq ft) 4244 3006 -1238 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 5431 6185 +754 Total number of parcels crossed 1 1 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 37 - VAR: AS -A18-115 The perpendicular alternative to the currently designed crossing AS -A18-115 has an additional 60' of pipe, would increase the acreage of impacts to landowner(s) in areas that are currently forested, and extends through a planned ATWS that would need to be relocated. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing and relocation of the ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 1,571 square feet in Zone 1 and 765 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, and the need to find a suitable location for the ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-30 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at AS -A18-115 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 629 689 +60 Zone 1 buffertotal impacts (sq ft) 6661 5090 -1571 Zone 2 buffertotal impacts (sq ft) 3842 3077 -765 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 1 Oc Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 38 - VAR: S -B18-133, S -B18-134 The perpendicular alternative to the currently designed crossing S -B 18-133, 134 has an additional 104' of pipe and would increase the acreage of impacts to landowner(s). Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe. The alternative route would result in a decrease in impacts of 4,421 square feet in Zone 1 and 2,656 square feet in Zone 2. There is no change in the number of residences in close proximity, or additional parcels affected, but one fewer waterbody is crossed. Due to additional pipe footage, additional ATWS required to support additional pipe bends, and increased acreage of landowner impacts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-31 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -B18-133,134 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 699 803 +104 Zone 1 buffertotal impacts (sq ft) 9700 5279 -4421 Zone 2 buffertotal impacts (sq ft) 5795 3139 -2656 Number of waterbodies crossed a/ 2 1 -1 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 39&40 -VAR: S-08-81 & S -A18-109 The perpendicular alternative to the currently designed crossing S -C18-81 & S-A 18-109 has an additional 555' of pipe, would increase the acreage of impacts to landowner(s), all of which are forested, and would require the relocation of five planned ATWS. Constructability concerns include: an additional ATWS will be required to support the additional bends in the pipe and additional tree clearing, and the relocation of the five ATWS. Without considering the impacts from the ATWS moves, the alternative route would result in a decrease in impacts of 7,690 square feet in Zone 1 and 3,903 square feet in Zone 2. There is no change in the number of residences in close proximity, but one additional parcel is affected, and one fewer waterbody is crossed. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional impacted tracts, additional forested clearing, and the need to find suitable locations and the associated impacts of moving the five ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-32 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at S -C18-81 &S -A18-109 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 1835 2390 +555 Zone 1 buffertotal impacts (sq ft) 12291 4601 -7690 Zone 2 buffertotal impacts (sq ft) 6967 3064 -3903 Number of waterbodies crossed a/ 3 2 -1 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 4 5 +1 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 41 -VAR: SS-SOIL18-10 The perpendicular alternative to the currently designed crossing SS-SOIL18-10 has an additional 97' of pipe, would increase the acreage of impacts to landowner(s), all of which are forested, and extends through a planned ATWS that would need to be relocated. Constructability concerns include: a significant bend in the pipe just before a bore under the road, an additional ATWS will be required to support the additional bend in the pipe, additional tree clearing, and the relocation of tan existing ATWS. Without considering the impacts from the ATWS move, the alternative route would result in a decrease in impacts of 6114 square feet in Zone 1 and 4068 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, increased acreage of landowner impacts, additional forested impacts, and the need to find a suitable location for the ATWS areas. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-33 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative at SS-SOIL18-10 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No Yes Pipeline length (feet) 395 492 +97 Zone 1 buffertotal impacts (sq ft) 10874 4760 -6114 Zone 2 buffertotal impacts (sq ft) 7223 3155 -4068 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 1 1 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ Impact 42 -VAR: S -B 18-125 The perpendicular alternative to the currently designed crossing S -B18-125 has an additional 89' of pipe and would increase the acreage of impacts to landowner(s). Constructability concerns include: additional ATWS will be required to support the additional bends in the pipe and additional tree clearing. The alternative route would result in a decrease in impacts of 1,517 square feet in Zone 1 and 1,109 square feet in Zone 2. There is no change in the number of waterbodies, residences in close proximity, or additional parcels affected. Due to additional pipe footage, additional ATWS required to support additional pipe bends, and increased acreage of landowner impacts. There is no reasonable and practical alternative to the proposed alignment, and Mountain Valley believes that a variance is warranted at this crossing to minimize overall impacts. E-34 February 2019 Alternatives Comparison of the Proposed Route and Perpendicular Alternative a S -B18-125 Feature Proposed Crossing Perpendicular Difference Alternative Parallel or adjacent to existing ROW No No Pipeline length (feet) 840 929 +89 Zone 1 buffertotal impacts (sq ft) 6041 4524 -1517 Zone 2 buffer total impacts (sq ft) 4125 3016 -1109 Number of waterbodies crossed a/ 1 1 0 NWI wetland impact (sq ft) b/ 0 0 0 Total number of parcels crossed 2 2 0 Number of residences within 25 and 50 feet of the edge of the construction ROW (and associated additional temporary 0/0 0/0 0/0 workspace) a/ Waterbodies regulated by the Buffer Rule b/ Assumes entire width of construction impacts ROW = right-of-way. Information Sources: GIS —Analysis based on Geodatabase layers and shapefiles. NC Parcel Boundaries and Standard Fields - http://data. nconemap.gov/geoportal/catalog/search/resource/details. page NLCD — 2006 National Land Cover Data - http://www.epa.gov/mrlc/nlcd-2006.html NWI — National Wetlands Inventory - http://www.fws.gov/wetlands/ USGS — U.S. Geological Survey - http://www.usgs.gov/ NHD — National Hydrography Dataset - http://nhd.usgs.gov/ ESRI - GIS Mapping - http://www.esri.com/ E-35 February 2019