December 22, 2016

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426
RE:  Mountain Valley Pipeline, LLC

FERC Docket No: CP16-10-000

DEIS-DO272  September 2016

Dear Secretary Bose:

FERC’s Draft Environmental Impact Study (DEIS) is incomplete and lacks detailed data from land the Mountain Valley Pipeline (MVP) proposes to cross.  Our property has not been surveyed, as is the case with other landowners along the proposed route.  As affected property owners (not “stakeholders”) and registered interveners, we insist that FERC deny the application for building the proposed Mountain Valley Pipeline.  There are many reasons to deny the permit for MVP; below we share our personal concerns as a family farm business and multi-generational landowners.

Economic Devastation to our Family Farm.

We own and operate a multi-generational family farm raising pastured poultry, range-raised pork, grass only beef, and eggs from hens on pasture.  We sell directly to families and individuals as well as restaurants and organizations.  Our animals are treated with care, having plenty of room as they are rotated through our three main pastures and woods.  We also support local agriculture by using a non-genetically modified (Non-GMO) feed, grown and milled in Franklin County.  Additionally, we are moving toward organic certification as we do not allow any chemical inputs or toxic sprays anywhere on our property.  The proposed Mountain Valley Pipeline route bisects our lower pasture, which borders a creek and receives ample sun and protection from the north wind during winter months and is, therefore, critical to pasturing our animals.

Interrupting our farming operations by the construction of this proposed pipeline and maintaining a cleared ROW through chemical spraying would clearly put us out of business.  We simply cannot afford to have one season of interruption as we would lose most of our customers and would struggle to regain them.  We utilize a mob grazing method with our cows (also known as rotational grazing), if our lower pasture is not available to use because of herbicide sprays and treatment on the right of way (ROW), we do not have enough land to properly rotate our cows through a season.  We would lose 1/3 of our grass land, which greatly restricts our ability to farm.

Four Corners Farm rests along the foothills of the Blue Ridge Mountains in the Boone District of Franklin County, VA.  We are a community focused, family friendly farm that practices sustainable agriculture, raising animals on pasture, supplying clean and healthy food for our local area.

We are a multi-generational family farm

We have bi-annual tours of our farm – customers and the community enjoy seeing our organic practices and farm operation – We strive to restore the land through rotational grazing of a variety of animals. 

 

One of our livestock guardian dogs, protecting the layers in our lower pasture where the proposed MVP is routed.

 

Pigs are a part of our livestock rotation through our land, including our lower pasture

 

Our Laying Chickens enjoying the lower pasture as they are rotated through the land

 

Our moveable hoop houses safely contain our meat chickens as they are moved to fresh pasture daily

Our cows are rotated through all of our pastures as we practice mob grazing techniques to restore soil health and fertility. 

We have escorted surveyors off our land – we have refused access to our property.

Surveyors exiting our property through Teels Creek and our woods

Environmental Issues

As has been filed by many individuals, organizations and agencies, the proposed Mountain Valley Pipeline poses an assault against the environment and wildlife throughout Appalachia.  Our Family’s land is rich with wildlife in a natural environment, one that has been chemical free for generations.  There are two creeks that the MVP has proposed to cross on our land – Teels Creek and Little Creek. In September of 2015 and 2016, our region experienced heavy rains and flooding.  Both of the creeks flooded and swiftly washed away debris as well as parts of the bank.  Below are before and after pictures.

Teels Creek, looking north

Teels Creek, looking west

Teels Creek, looking west after heavy rains

 

Teels Creek after heavy rains, September 2016

Little Creek, looking east at our four children playing, exploring, and enjoying nature; foreground is a damselfly resting on Carolyn Reilly’s hand. 

Little Creek after heavy rains, September 2016

In May of 2016, I, Carolyn Reilly, was able to visit a landowner in Pittsylvania whose property is crossed by the Williams Transco pipeline, crossing one of his creeks.  In the heavy rains of September 2015, he saw that the pipe was completely exposed due to the bottom of the creek being washed out.  Debris and tree limbs were being stopped by the pipe.  Williams Transco was contacted and their solution was to place a concrete “mesh” on top of pipeline across the entire 50 foot ROW.  See images below.

Easement ROW – white is the concrete mesh covering the pipes.

Concrete mesh covering exposed pipe along a pipeline ROW in a Pittsylvania County, VA creek

View of concrete mesh through creek in Pittsylvania County, VA

Oily sheen of the water is concerning… is there a leak? 

 

Just above the creek area was a wooded land that was marshy and sitting with oily looking water – image below.

Wooded area near the concrete creek in Pittsylvania County, VA

The DEIS does not address mitigation measures of seasonal rains and flooding concerns through waterways and creeks.  Concrete is not a solution or a fix for pipelines through a creek.

Another concern is the movement and erosion of Little Creek.  The current route of the proposed MVP runs through our lower pasture following Little Creek.  Below are a series of images from Google Earth that show the change of the creek as it has slowly moved north and more into our pasture.

1995

2002

2006

2008

2010

2011

2015

From 1995 to 2016, just over 20 years, the Little Creek shifted north into the pasture over 100 feet.  The current centerline of the proposed MVP is only 100 feet away from Little Creek.  How can the effects of natural creek shifting be accounted for and mitigated?

Another environmental concern of ours is the wetland area that runs through our lower pasture.  There is a spring source (noted in Google Earth image below) that runs down toward our lower pasture forming a wetland.  The proposed route of the pipeline crosses this wetland area.  Where would the spring water run off to?  Would it seep into the pipe trench and speed up corrosion, eventually causing a leak in the pipe?

The proposed route of the pipeline also destroys livestock waterers that are connected to our home’s well. 

What mitigation measures are in place for situations like these?

The sheer volume of construction, earth movement and equipment would wreak havoc on our land.  How would all the equipment, pipes and other materials get trucked onto our pasture that has creeks and steep woods surrounding most of it?  There has been no mention of an access road using our driveways.  The only access road is from Grassy Hill entering our wooded land then through Teels Creek.  What immitigable damage would be caused with the amount of equipment crossing the creek?  Teels Creek merges with Little Creek on our property; Little Creek then flows into the Blackwater River just under a mile downstream from our farm.  The erosion and sedimentation that would occur is detrimental to aquatic life, including the endangered Roanoke Logperch.  See further comments on the Roanoke Logperch on the Blue Ridge Environmental Defense League’s filing to FERC. [1]

Natural Gas Explosions Create Extreme Risk for our Family. 

Our family lives and works on the farm – we are home a majority of the time.  Our children are home-schooled and enjoy time outdoors on our land almost every day.  Our house sits approximately 700 feet from the proposed center of the pipeline (as shown in above Google Earth images – red line to house from proposed pipeline).  Along with our home, our Farm Store is in the blast zone of the MVP.  Any explosion on our land would incinerate us with little hope of escape.  We cannot put our family under the constant worry and stress of living so close to a potential bomb that would decimate our lives, livestock and livelihood.

Conclusion

In conclusion, as property owners and caretakers of our land, we demand that the MVP not be granted a permit giving them the right to use eminent domain to seize our land for their private gain.  This proposed pipeline is NOT for the public good and benefits the limited liability corporation of MVP.

Sincerely,

Ian E. Reilly                                                                Carolyn E. Reilly

David J. Werner                                                          Betty B. Werner

[1] http://bredl.org/pdf5/BREDL_Mountain_Valley_FERC_DEIS_Comments_FINAL.pdf