After three months of monitoring the construction work on the Mountain Valley Pipeline, Mountain Valley Watch, a citizen watchdog group, has submitted detailed comments to the Virginia State Water Control Board. Through August 7, 2018, Mountain Valley Watch volunteers submitted 277 reports of suspected improper erosion controls at Southwest Virginia construction sites, reports which professional engineers and academics evaluated before submitting 58 complaints to DEQ.
The executive Summary of the report states, “The data demonstrates that:
- Precision Pipeline frequently failed to employ Best Management Practices and properly install required erosion control devices and maintain them. The direct result is the serious impairment of Virginia waters.
- The extent and repetition of these failures (often in the same location), consistent with research in referenced journals, indicates the limitations of BMPs in mountainous terrain. BMPs are not infallible, nor are they intended to be so; they are designed to minimize adverse impacts. Rain events, well within the standard of “normal,” on steep slopes of upland watersheds overwhelm BMPs. This is documented in scientific reports in refereed journals.
- The processes by which DEQ decided the Nationwide Permit 12 and conducted the 30 day public comment period were fundamentally flawed, contributing to an unsubstantiated opinion that MVP construction would not significantly impair Virginia waters. This report demonstrates significant sediment loading into streams.
- It is imperative that DEQ and the SWCB revisit their decisions to approve the Section 401 Certification and Nationwide 12 permit for the Mountain Valley Pipeline.
- There is a reasonable likelihood, based in on the facts on the ground, that continued construction will continue to significantly adversely impact Virginia water for years to come.