Suggested Comments for the Public:

-I strongly oppose the application for a Special Use Permit to cross the Jefferson National Forest and the requests for amendments to the Forest Plan. I believe the Bureau of Land Management (BLM) and the Forest Service must reject these proposals and I urge you to do so.

-The Draft EIS is legally and technically inadequate. It omits important information, misrepresents facts and findings, and fails to support conclusions with credible scientific and technical analyses.  A revised DEIS must be prepared and the public must have the opportunity to review and comment on a version that is complete and accurate.

-The DEIS fails to meet the regulatory standard to justify crossing the Jefferson National Forest. The applicant is required to show that there is NO reasonable alternative to crossing Forest Service lands or the request must be denied.  The applicant and FERC have merely given the opinion that the route crossing the Forest is preferable – this does not satisfy the law.

-The MVP, as currently proposed, would harm the wilderness experience in the Peters Mountain and Brush Mountain East areas. Though, the pipeline would skirt the boundaries of both Wilderness areas, the disruption during construction would damage the value of these areas and the scars left behind could also mar certain views from both areas.

-Wild Virginia and area residents have documented the existence of springs and wells around the MVP route in the Peters Mountain area that were not discovered or disclosed in the DEIS. These omissions are, by themselves, serious breaches of FERC’s duty to identify and assess the environmental impacts of the project.  In addition, they call into question the applicant and FERC’s overall effort to find and protect water sources that could be affected by the pipeline.

-The MVP is proposed to cross about 1 mile of the Brush Mountain Inventoried Roadless Area, thus damaging the value of this area. The existence of remaining roadless areas on the Forest is valuable, because they are all too rare.  Roads damage forests by degrading water quality, changing hydrologic cycles, promoting invasion of harmful non-native species, and eliminating forest habitat.  The pipeline, both during construction and throughout the many decades its impacts would be felt, will create many of the damages and risks that roads create.

-The DEIS must be revised to include analysis of impacts and the ability of the applicant to avoid or mitigate resource damages in what the Forest Service has designated High Hazard areas. The combined risks of high landslide potentials, highly erodible soils, very steep slopes, sensitive species and habitats, and other factors calls into question whether the MVP can be built at all in a way that protects public resources.

-The DEIS analysis of possible cumulative impacts on water bodies, particularly on headwater streams is superficial and incomplete.

-The DEIS makes no attempt to assess the impacts of this proposed pipeline on the Appalachian Trail in context with other pipelines and projects that would damage the AT’s character and value. This failure violates FERC’s duty to perform an adequate cumulative impacts analysis under NEPA.