The Mountain Valley Pipeline (MVP) has asked the Federal Energy Regulatory Commission (FERC) for an extension of time of “an additional two years, or until October 13, 2022, to complete construction of the Project and place the Project facilities into service.” FERC issued on August 27 an official notice of a comment period for the public to have input on the MVP request, the deadline for which is Friday, September 11 (more information below).
The MVP request, made in an August 25 letter, contends:
- The need for the MVP by potential customers still exists.
- FERC has already approved the Southgate Project to extend the MVP into North Carolina.
- The recent cancellation of the Atlantic Coast Pipeline (ACP) makes it “vitally important for this Project to be completed and placed in service as soon as possible to meet the demand for national gas in these regions.”
- “Unforeseen litigation and permitting delays outside of Mountain Valley’s control” have prevented the pipeline from being in service by October 13, 2020 (when the current certificate for the project expires).
- The “Project is approximately 92% complete.”
MVPs request, while not surprising, raises several questions, among them:
- Given natural gas market realities in 2020, how can the need for the MVP still be as justified as it was when the project’s certificate was granted in 2017? After all, as noted in the August 13 issue of ABRA Update, the CEO of EQT Corporation, potentially the largest shipper of gas on the MVP should the project be completed, there is now – without the MVP being operational – there is an excess of pipeline capacity over production coming from the Marcellus Basin and that production is going to continue to decline, thus widening the gap of excess pipeline capacity over production.
- How can the project be called 92% complete when by the company’s own admission only half of the MVP route has been fully restored, with the fully restored percentage in Virginia, which is one-third of the route, being only 15%?
- If 92% of the MVP route is actually complete, why would it take two years to complete the remaining 8% of the project?
- Given that North Carolina has denied a Section 401 water certificate for the Southgate Project, what assurance can MVP demonstrate that the project (which is one of the cited reasons for the certificate extension request to FERC) will even be built?
ABRA members and those active in the coalition are strongly urged to file comments with FERC by 5 pm, Friday, September 11 in opposition to the extension of the certificate for the MVP. Regarding filing comments, the FERC Notice states:
The Commission strongly encourages electronic filings of comments, protests and interventions in lieu of paper using the “e-File” link at http://www.ferc.gov. Persons unable to file electronically may mail similar pleadings to the Federal Energy Regulatory Commission, 888 First Street, NE, Washington, DC 20426. Hand delivered submissions in docketed proceedings should be delivered to Health and Human Services, 12225 Wilkins Avenue, Rockville, Maryland 20852.
Comment Date: 5:00 pm Eastern Time on September 11, 2020