Wild Virginia has submitted a report to the Virginia Department of Environmental Quality and State Water Control Board summarizing thousands of public comments addressing the proposal by Mountain Valley Pipeline to dig and blast through streams and wetlands across western Virginia.
The board will consider the public’s oral and written testimony in making a decision on a water permit for MVP in December.
The permit decision will fulfill the state’s responsibilities under Virginia law and the federal Clean Water Act. A denial by the board would serve as a veto of a related permit by the U.S. Army Corps of Engineers covering the same activities.
Wild Virginia undertook this task because the DEQ has decided not to provide such a summary to the board, as the Department has traditionally done. It is vital that both the board and the public get a comprehensive picture of the views expressed about this important matter. This summary will help accomplish that.
While some documents submitted at the end of the comment period could not be acquired in time for inclusion in this review, this document provides both a useful overview and much important specific information.
Selected findings from the Summary report include:
- Of 2,290 comments reviewed, 2,069 (90 percent) oppose the project.
- Only a small number of comments reviewed specifically address the central legal question the board must answer; whether the board can ensure water quality standards will not be violated.
- Almost all comments that specifically address issues that must govern the board’s decision oppose approval. These comments overwhelmingly describe deficiencies in the data and analysis submitted by MVP and describe serious risks to our waters, some nearly certain to occur.
- Of just 33 sites where MVP has already crossed waterbodies in Virginia, MVP failed to give DEQ advance notification, as required, in nine instances (greater than 25 percent of the time). Therefore, DEQ was unable to properly monitor those risky in-stream operations and pollution problems may have gone unobserved.
- A necessary component of Virginia’s water quality standards, the antidegradation policy to prevent harm to high quality waters, was not even mentioned in DEQ documents and has not been addressed by data or analyses from either MVP or DEQ.
According to Jacqueline Goodrum, Conservation Policy Associate at Wild Virginia: “We presented all of the information and documents we could gather, whether for or against project approval, and did so in a straightforward manner. We have also provided the board members (and the public) with links in the document so they have easy access to each and every comment we could acquire, and can form their own conclusions.”
“We do not presume that board members will agree with our opinions or those of any other party” Goodrum continued, “however, one fact seems clear to us. Opponents of MVP
provided a huge body of evidence, backed by legal analysis, scientific reports, and data, indicating that MVP has not proven its case. Supporters of project approval provided very little of that type of information, nor did DEQ cite such proofs in its recommendation to the board.”
“We prepared this document because we respect the fact that the Board members donate their time and efforts for this important work and, as we wrote in the report, we see ourselves as partners with all who are working to protect our waters,” stated David Sligh, Wild Virginia’s Conservation Director.
“We want the facts known as widely and clearly as possible, because we are confident that if the evidence is thoroughly and fairly reviewed issuance of this permit can never be supported. We and thousands of other Virginians have and will continue to work hard to see that the record is complete and that the truth is known. The board has information that was not available to it in 2017 and that must help determine the outcome now. MVP has caused much destruction and pain to local residents and water users so far and these proposals would be a major blow to our precious resources and our communities. Further damage must not be allowed.”
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