Why the USFS should not allow Mountain Valley Pipeline to cross the Jefferson National Forest
Team Mountain Valley Pipeline
Published 2/20/2023
A public comment to the US Forest Service addressing deficiencies in the 2022 Draft Supplemental Environmental Impact Statement
Executive Summary
We strongly urge the US Forest Service to not allow MVP to cross the Jefferson National Forest (the No Action Alternative) based on our scientific analysis of the Draft Supplemental Environmental Impact Statement. In this comment, we:
Illustrate several flaws in the Forest Service’s 2022 DSEIS analysis of USGS paired gage turbidity measurements. Further, we present an independent analysis that demonstrates pipeline construction activities do in fact elevate downstream turbidity.
Outline concerns regarding the misuse of RUSLE models, high levels of uncertainty in model results, and sole reliance on these results to inform erosion control planning.
Criticize the DSEIS conclusion that it is “not likely” MVP will adversely impact the endangered candy darter in JNF.
Discuss the potential impacts of MVP’s proposed use of insecticides in JNF and stress the importance of USFS providing a more detailed description and assessment of this proposed project for cumulative effects analysis.
Criticize the DSEIS conclusion that it is ”not expected” MVP will threaten freshwater mussels when there has been no analysis of potential impacts to mussel host fish.
