Twenty-two conservation groups, including ABRA and several of its members, filed comments on November 19 with the U.S. Army Corps of Engineers on the permit application for the Mountain Valley Pipeline (MVP) to cross rivers and streams under Section 404 of the Clean Water Act. The comments were jointly prepared and submitted for the groups by Appalachian Mountain Advocates, Southern Environmental Law Center and Natural Resources Defense Council. Among major points made in the comments, were:
- MVP’s proposed open-cut, dry-ditch crossings are not the least environmentally damaging practicable alternatives.
- Because the MVP would cause or contribute to violations of water quality standards, its application must be denied.
- MVP’s restoration plans impermissibly focus solely on structure and ignore function.
- MVP has not remedied the inadequacies the U.S. Environmental Protection Agency identified in its compensatory mitigation plans.
- MVP’s recently submitted draft mitigation framework is insufficient to ensure that potential adverse impacts are minimized.
- The Army Corps must issue supplemental public notice of pivotal data and allow time for meaningful public comment.
For a copy of the groups’ comments, click here.