Roanoke County filed comments February 22 in objection to the revised treatment plans for Bent Mountain Rural Historic District, Bent Mountain Apple Orchard Rural Historic District, and Coles-Terry Rural Historic District. Roanoke County objected to the treatment plans on the following grounds:
- Mountain Valley did not complete the consultation process provided under Stipulation III.B.5 of the Programmatic Agreement, as the County had to initiate contact with MVP in order to continue the required consultation, and MVP failed to notify the County that they were filing a revised treatment plan on February 15, while consultation was still ongoing.
- The proposed compensatory mitigation is not proportional to the MVP Project’s adverse effects and does not adequately consider the input of consulting parties and local stakeholders, particularly in regard to the preservation and restoration of the Bent Mountain Center. MVP’s proposal limits funding for this purpose to $500,000, which the County objects to because “it is not proportional to the adverse effect and does not reflect the County’s input.” MVP indicated to the County that they should rely on the funds allocated in the Memorandum of Agreement for Historic Resource Mitigation of Virginia Resource Impacts of Mountain Valley Pipeline for additional mitigation, a fund that has not yet been established and which FERC has no say in allocating.
The Greater Newport Rural Historic District Committee (GNRHDC) filed comments February 22 regarding the revised treatment plan for the Greater Newport Rural Historic District, with an amended copy of said comments filed February 23. The filing raises the following issues:
- MVP has failed to comply with Section II of the Programmatic Agreement, and there are still studies outstanding in the District that MVP’s own contractor and GNRHDC’s contractor indicated needed to be completed. “In response and despite the language in the Programmatic Agreement, MVP indicated that it would not perform those studies because FERC had not yet specifically directed it to perform those studies,” the filing states.
- The mitigation funds indicated are not adequate to address damages to the District, and GNRHDC proposes the fund be increased from MVP’s proposed $500,000 to $2 million.
- The filing includes a list of Section 106 issues that remain unaddressed in the District, as well as a list of misidentified and mislocated properties that MVP still has failed to address, despite concerns raised in consultation.
- The determination that there will be no adverse effects on several properties in question was based on false and missing information provided by MVP, including misrepresentation of requests made by Giles County and the GNRHDC.
Giles County filed comments February 23 concurring with the comments made by the Greater Newport Rural Historic District Committee. The County highlighted concerns about future pipeline co-location, a process that would be significantly more streamlined than the current one with MVP and which MVP has refused to take into account. Additionally, Giles County expressed objections to MVP’s suggestion that the County can rely on the Historic Resources Mitigation Fund outlined in the Memorandum of Agreement for Historic Resource Mitigation of Virginia Resource Impacts of Mountain Valley Pipeline for further mitigation costs.