Comments to FERC: Week of March 19

This is a compilation of the comments filed with FERC by landowners, concerned residents, county governments, and other interested parties for the week of March 19.

John Terry

John Terry, a resident of Centreville, VA, filed comments that were added to the FERC docket March 19 asserting that “construction must stop until all the issues” with the pipeline “have been researched and attended to.” He states that he finds it “impossible for the construction crews to realistically follow the guidelines they’ve set for themselves” after walking the proposed pipeline route himself.

“Rushing the pipeline forward only creates dangerous situations and the potential for damages that are unrecoverable,” he concluded.

>> John Terry Comments Filed 3/19/18

Lois King Waldron & Lois Waldron Martin

Lois King Waldron and Lois Waldron Martin filed comments March 21 regarding the discovery of Lakota, Dakota, Nakota artifacts found on their property by Ben Rhodd of the Rosebud Sioux Tribe.

Their property was one of those visited by Rhodd and Steve Vance in early March, and their visit resulted in the discovery of Native American artifacts that could date back to 9,000 BCE. Previously, their property was documented in compliance with Section 106 of the National Historic Preservation Act for including two separate layers of historical significance, dating 1890 to1972 and 300BCE to 500CE.

“During their visit our property was identified as having significance as ‘an encampment and having rock formations’ which deserve further evaluation (Vance, Rhodd),” the statement said. “Also, many artifacts of ours were viewed and recommended as ‘being important and in need of further evaluation’ (Rhodd).”

Waldron and Martin qualified that “neither Mr. Vance nor Mr. Rhodd were visiting properties in an official capacity.” However, Rhodd’s qualifications are of note, as “Mr. Rhodd, B.A., M.S., RPA, is an archeologist (who meets the Secretary of the Interior Standards) with the Rosebud Sioux Tribe and is ‘versed in mountain, desert, prairie, and riverine ecosystems inclusive of the cultural landscapes contained therein’ (Rhodd).”

Waldron and Martin conclude their comments by asking that FERC not grant a Notice to Proceed with tree felling and construction on Bent Mountain in Roanoke County, VA until the relevant Sioux tribes are consulted in a manner required within the Programmatic Agreement.

>> Lois King Waldron & Lois Waldron Martin Comments Filed 3/21/18

Dale & Mary Angle

Dale and Mary Angle filed comments with FERC March 22, requesting that FERC “halt all tree clearing and pipeline construction activities on the MVP until consultations with the Cheyenne River Sioux Tribe and Rosebud Sioux Tribe have been completed.”

As with other landowners, Ben Rhodd and Steve Vance visited the Angles’ property on March 5, paying close attention to a field alongside the Blackwater River. The Angles indicated “we find arrowheads and remnants of pottery nearly every time we set foot in that field.”

The Angles comments indicated that Franklin County is recognized by historians as having been inhabited by a tribe that is part of the eastern Sioux language family in the 1600s.

Included in the Angle’s filing were a letter Vance filed with FERC January 16, 2018, FERC’s response to Vance dated January 30, 2018, and Rhodd’s letter to the Advisory Council on Historic Preservation dated March 9, 2018.

In his letter to FERC, Vance requested the commission provide him with any Class I, Class II, and Class III studies conducted for the MVP project for identification of cultural resources. FERC declined to do so, stating that his request “is unrealistic considering that Mountain Valley has submitted over 104 reports to date; many of which were filed as ‘privileged’.” Instead, Paul Friedman referred Vance to the Environmental Impact Statement, a 930-page document that, among other things, “addressed FERC’s government-to-government consultations with interested Indian Tribes, including tribes that may have historically used or occupied the project area,” Friedman said.

>> Dale & Mary Angle Comments Filed 3/22/18

Montgomery County

The County of Montgomery in Virginia filed comments with FERC through their County Attorney March 23. The comments were written in regards to MVP’s mitigation plan for the North Fork Valley Rural Historic District.

In the previously proposed Work Plan and Scheduled Treatment Plan for the North Fork Valley Rural Historic District, MVP proposed the creation of a $25,000 fund that the company manages that would be “dedicated to the identification, digitization, and preservation of district-related historic material for inclusion in the existing Montgomery County Memory Project.” This would serve as means to mitigate any impacts of pipeline construction on the district.

As detailed in the County’s comments, the Montgomery Museum sent a letter to MVP March 7 explaining that the museum has “very limited funding, exhibit space, and human resources” to accommodate such an exhibit, and advising MVP that “an alternative plan needs to be developed because the money dedicated for this project is unlikely to cover the needed staff, equipment and long term management required for such an exhibit.”

MVP did not share this correspondence with FERC, so Montgomery County filed the letter as an attachment to their comments “so that FERC will be fully informed of the Montgomery Museum’s concerns.”

Montgomery County additionally requested that FERC review the letter and not approve MVP’s Work Plan and Scheduled Treatment Plan for the North Fork Valley Rural Historic District until further consultation is done to resolve concerns with the plans as they stand.

>> Montgomery County Comments Filed 3/23/18

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