attachment ip-15 - mountain valley pipeline...letter dated july 7, 2017, dhr disagreed with the...

Mountain Valley Pipeline, LLC Mountain Valley Pipeline Project

Docket No. CP16-10-000

Implementation Plan Dated October 2017

Attachment IP-15

1

Evelyn Tidlow

From: Marine, James <[email protected]>Sent: Wednesday, September 27, 2017 10:42 AMTo: Neylon, Megan; Evelyn TidlowCc: Sparks, SeanSubject: FW: Mountain Valley Pipeline Check for FERC filing

Importance: High

From: Lamarre, Lora A [mailto:[email protected]] Sent: Wednesday, April 26, 2017 2:54 PM To: Marine, James <[email protected]> Subject: RE: Mountain Valley Pipeline

JT: We have reviewed your request for clarification of our comments regarding sites 46GB504 and 46GB505. These site were determined eligible for inclusion in the National Register of Historic Places at the conclusion of the Phase II investigations. Upon further consideration, we concur with your determination that additional archaeological investigation of these resources likely would not produce significant information. We also concur that the proposed project would have no adverse effect on these resources should they be reincorporated back into the project’s limits of disturbance. We appreciate the opportunity to be of service. If you have any questions regarding our comments or the Section 106 process, please do not hesitate to contact this office. Sincerely, Lora A Lamarre-DeMott Senior Archaeologist WV SHPO The Cultural Center 1900 Kanawha Blvd., East Charleston, WV 25305-0300 304-558-0220 x711 (p) 304-558-2779 (f) **Please note: Until further notice, we are unable to receive zip files via email due to virus issues on the WV State email servers. If zip files must be emailed, please change the file extension before sending them.

From: Marine, James [mailto:[email protected]] Sent: Thursday, April 13, 2017 7:24 AM To: Lamarre, Lora A <[email protected]>

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Subject: Mountain Valley Pipeline Importance: High

Good morning Lora Thank you for your comments on the Phase II sites in Greenbrier and Nicholas Counties. I’m hoping you can provide some clarification on comments concerning sites 46GB504 and 46GB505. In the report, these sites are recommended as eligible and we appreciate your concurrence with those recommendations. The report also indicates that the significant information associated with the sites has been collected through the Phase II excavations and that further excavation of these sites would not yield additional data to address archaeological research questions. The report, therefore, indicates that there would be no adverse effect to these sites if the locations were reincorporated back into the Project for use as additional temporary work space. This conclusion was predicated on the extent and type of landform where the sites are located – each site is bounded by the limited aerial extent of the individual fan lobe where features and artifacts were recovered for each site. Could you please address the issue of no adverse effect and the reincorporation of these site areas into the Project for use as additional temporary work space? Thank you for your attention to this request. Please call or email with any additional questions or concerns. JT James T. Marine , MS/RPA | Director of Cultural Resources Pittsburgh PA:, Fairmont WV Direct:: 304-816-0583 | Mobile 484-680-9997 [email protected] Tetra Tech | Director of Cultural Resources 661 Andersen Drive, Foster Plaza 7, Pittsburgh, PA 15220-2745 320 Adams Street, Suite 101, Fairmont WV 26554| www.tetratech.com PLEASE NOTE: This message, including any attachments, may include privileged, confidential and/or inside information. Any distribution or use of this communication by anyone other than the intended recipient is strictly prohibited and may be unlawful. If you are not the intended recipient, please notify the sender by replying to this message and then delete it from your system.

Western Region Office 962 Kime Lane

Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446

Northern Region Office 5357 Main Street

PO Box 519 Stephens City, VA 22655

Tel: (540) 868-7029 Fax: (540) 868-7033

Eastern Region Office 2801 Kensington Avenue

Richmond, VA 23221 Tel: (804) 367-2323 Fax: (804) 367-2391

Molly Joseph Ward Secretary of Natural Resources

COMMONWEALTH of VIRGINIA

Department of Historic Resources

2801 Kensington Avenue, Richmond, Virginia 23221

Julie V. Langan Director Tel: (804) 367-2323 Fax: (804) 367-2391 www.dhr.virginia.gov

September 21, 2017 Ms. Megan L. Neylon Mountain Valley Pipeline 625 Liberty Avenue, Suite 1700 Pittsburgh, PA 15222 Re: Mountain Valley Pipeline Project, Phase I Survey Supplemental Information and Criteria of Effects

Report: Addendum 2, Montgomery and Roanoke Counties, Virginia (June 2017) DHR File No. 2014-1194; FERC #CP16-10 Dear Ms. Neylon: The Department of Historic Resources (DHR) has received for our review and comment the report referenced above prepared by Tetra Tech for Mountain Valley Pipeline, LLC. The document presents additional Phase I survey information on two architectural properties within the Area of Potential Effects (APE) for the pipeline corridor in order to establish their eligibility for listing in the National Register of Historic Places (NRHP), and evaluates the project’s potential effect on six NRHP-eligible architectural resources identified. Five of the six properties had previously been incorrectly identified as located on land under the jurisdiction of the United States Forest Service (USFS) and, as a result, were to be addressed in a later report specific to USFS managed resources. The two architectural properties included in the current report and evaluated for NRHP eligibility are House and Crib (DHR ID #080-5677-0009) and Single Family Residence and Outbuildings (DHR ID #035-5136). Although a “Phase I Architectural Survey Letter Report” for each of these properties was included as appendixes in the report document, there is no indication that DHR survey forms were completed for them or that the information was entered into our Virginia Cultural Resources Inventory System (VCRIS). We request that this be done as soon as possible. The consultant recommends that 080-5677-0009 does not warrant individual NRHP listing nor is it contributing to the Bent Mountain Rural Historic District (DHR ID #080-5677). Additionally, the consultant recommends that 035-5136 is similarly not eligible for individual listing nor does it contribute to any known historic district. With the information provided in the Phase I letter reports for these two properties, we agree that 080-5677-0009 and 035-5136 lack sufficient historical significance and architectural distinction to be individually eligible for listing in the NRHP. However, we do believe that 080-5677-0009 may contribute to the Bent Mountain Rural Historic District. Unfortunately, without the required VCRIS documentation for this resource DHR is unable to state for certain if this is the case. It should be noted that 035-5136 is located in Giles County which is not reflected in the report’s title.

landfriedm

Highlight

September 21, 2017 DHR File No. 2014-1194


Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033



The six additional properties for which impacts are assessed are DHR ID #s 060-0290, 060-0337, 060-0340, 060-0414, 060-5178, and 080-5690. We agree that the following properties will not be affected by the project: 060-0290, 060-0337, 060-0340, 060-0414, and 060-5178. Only the Henry-Waldron Cemetery (DHR ID #080-5690) will be indirectly affected because of its “Dominant” viewshed of the undertaking and, therefore, was carried forward for additional analysis. The Henry-Waldron Cemetery is eligible for listing in the NRHP as a contributing element to the Coles-Terry Rural Historic District (DHR ID #080-5689). In our letter dated July 7, 2017, DHR disagreed with the consultant’s recommendation that the pipeline project will not adversely affect the Coles-Terry Rural Historic District. In that previous correspondence we stated that the pipeline will have a direct adverse effect on the rural historic district as it will physically bisect the Coles-Terry Rural Historic District. The “Dominant” viewshed of the pipeline project from the Henry-Waldron Cemetery is due to the fact that an associated access road and permanent workspace will be constructed only fourteen feet from the historic cemetery (Please note that in Table 4.0 the workspace is described as “Permanent” while in Table 4.2 it is characterized as “Temporary”. The text on page 11 reiterates the workspace as being permanent so that is what we have based our analysis.). The DHR believes that the construction of the new roadway and permanent workspace so close to the cemetery is inconsistent with its rural character and will greatly alter the property’s setting and feeling. We, therefore, disagree with the consultant’s recommendation and find that the pipeline project will adversely affect the Henry-Waldron Cemetery. If you have any questions regarding these comments or our review of this project, please do not hesitate to contact me at [email protected]. Sincerely, Roger W. Kirchen, Director Review and Compliance Division c. Ms. Sydne Marshall, Tetra Tech

mailto:[email protected]

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Evelyn Tidlow

From: Neylon, Megan <[email protected]>Sent: Tuesday, October 03, 2017 5:35 PMTo: Kirchen, Roger (DHR)Cc: Evelyn Tidlow; Clauto, Brian M.Subject: RE: MVP - 44RN0400 & 0401

Roger – I am sorry for the confusion! The original report (July 5, 2017) includes more detail related to the Phase I work conducted on that tract than is included in the newly submitted report (September 22, 2017). The revised report includes much more information related to the Phase II evaluations conducted on the two potentially eligible sites. The revised Treatment Plan (September 22, 2017) does supersede the previously submitted Treatment Plan since it is based on the additional fieldwork we completed on the sites and documented in the new report. To summarize, please review the original Phase I report and the new Phase I/II report and the new Treatment Plan. I am hoping to be out on maternity leave sooner than later. If you need additional information related to these, please don’t hesitate to contact Brian Clauto 724‐873‐3465 or Evelyn Tidlow at 612‐812‐5478 or at the email addresses included above. They will be taking over in my absence. We look forward to receiving your comments on these reports. Thank you, Megan

From: Kirchen, Roger (DHR) [mailto:[email protected]] Sent: Monday, October 02, 2017 3:06 PM To: Marshall, Sydne <[email protected]> Cc: Neylon, Megan <[email protected]> Subject: MVP ‐ 44RN0400 & 0401 Does the submission of the Supplemental Phase I survey of tract VA‐RO‐054 with Phase II evaluation of sites 44RN0400 & 0401 (with cover letter dated September 22, 2017) supersede and render moot the July 5, 2017 submission of the Phase I survey of tract VA‐RO‐054 and 44RN0400 & 0401 treatment plan? Or do both submissions remain relevant to the project. _________________________________ Roger W. Kirchen, Director Review and Compliance Division Department of Historic Resources 2801 Kensington Avenue Richmond, VA 23221 phone: 804‐482‐6091 fax: 804‐367‐2391 [email protected]


Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033








October 24, 2017 Mr. Mike Madden, Forest Archaeologist George Washington & Jefferson National Forests 5162 Valleypointe Parkway Roanoke, VA 24019 Re: Mountain Valley Pipeline Project Cultural Resources Survey and Evaluation, Jefferson

National Forest, Phase II Cultural Resources Investigations, Sites 44GS0238, 44GS0240,

44GS0241, 44GS0242, 44GS0243, 44GS0244, 44GS0247, 44GS0251, 44MY0577, 035-

5129, and 035-5134, Giles and Montgomery Counties, Virginia (June 22, 2017) DHR File No. 2014-1194; FERC #CP16-10 Dear Mr. Madden: We have received for review the report referenced above prepared by SEARCH. We provide the following comments as assistance to the U.S. Forest Service (USFS) and Federal Energy Regulatory Commission (FERC) in meeting their responsibilities under Section 106 of the National Historic Preservation Act. The Phase II investigations considered the eligibility of the studied resources for listing in the Virginia Landmarks Register (VLR) and National Register of Historic Places (NRHP). Following completion of the Phase II fieldwork, it was decided to merge sites 44GS0238, 44GS0241, 44GS0247, and 44GS0251 into a single site and that the composite site will be referenced as 44GS0241. The archaeological subcommittee of our Department’s National Register Eligibility Evaluation Team concurs that site 44GS0241 is eligible for listing in the VLR/NRHP and that sites 44GS0240, 44GS0242, 44GS0243, 44GS0244, and 44MY0577 are not eligible for listing in the VLR/NRHP. Further, we concur that DHR ID #s 035-5129 and 035-5134 are not eligible for VLR/NRHP listing. We are awaiting comments from the National Park Service on the potential effects of the project on the Appalachian Trail and will provide comments regarding that resource as soon as possible. We have received the Treatment Plan for Site 44GS0241 prepared by SEARCH for the USFS and FERC and find it to be acceptable to mitigate the adverse effect of the project on the resource.


Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033








October 25, 2017 Ms. Megan L. Neylon Mountain Valley Pipeline 625 Liberty Avenue, Suite 1700 Pittsburgh, PA 15222 Re: Mountain Valley Pipeline Project Phase IB Addendum I Archaeological Survey and

Phase II Evaluations of Sites 44GS0227, 44GS0229, 44GS0230, 44GS0231, and

44GS0236, Giles County, Virginia (January 2017) DHR File No. 2014-1194; FERC #CP16-10 Dear Ms. Neylon: We have received for review the report referenced above prepared by Tetra Tech for Mountain Valley Pipeline, LLC (MVP). We provide the following comments as assistance to the MVP and the Federal Energy Regulatory Commission (FERC) in meeting their collective responsibility under Section 106 of the National Historic Preservation Act. The supplemental archaeological survey of 280 acres in Giles County resulted in the identification of six (6) sites within the study area. The consultant recommends and DHR concurs that the following five (5) sites are not eligible for listing in the Virginia Landmarks Register (VLR) or National Register of Historic Places (NRHP): 44GS0234, 44GS0245, 44GS0248, 44GS0249, and 44GS0250. The remaining site, 44GS0230, discussed below, was found to be potentially VLR/NRHP eligible and subjected to Phase II evaluation. The Phase II evaluation of five (5) sites considered the VLR/NRHP eligibility of the resources. The archaeological subcommittee of our Department’s National Register Eligibility Evaluation Team concurs that 44GS0230 is eligible for listing in the VLR/NRHP and that sites 44GS0227, 44GS0229, 44GS0231, and 44GS0236 are not eligible for listing in the VLR/NRHP. We understand that MVP intends to substantially avoid site 44GS0230, as well as the earlier evaluated site 44GS0226. We have reviewed the avoidance plans prepared by Tetra Tech (dated

October 25, 2017 DHR File No. 2014-1194


Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033



February 2017) for sites 44GS0226 and 44GS0230 and find that the project, as amended in the plans, will not adversely impact the sites. Thank you for the opportunity to review this document. If you have any questions regarding these comments or our review of this project, please do not hesitate to contact me at [email protected]. Sincerely, Roger W. Kirchen, Director Review and Compliance Division c. Ms. Sydne Marshall, Tetra Tech




Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033



Thank you for seeking our concurrence on these studies and the recommendations of the USFS. If you have any questions regarding these comments or our review of this project, please do not hesitate to contact me at [email protected]. Sincerely, Roger W. Kirchen, Director Review and Compliance Division c. Ms. Sydne Marshall, Tetra Tech

Ms. Megan L. Neylon, MVP



Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033








October 27, 2017 Ms. Megan L. Neylon Mountain Valley Pipeline 625 Liberty Avenue, Suite 1700 Pittsburgh, PA 15222 Re: Mountain Valley Pipeline Project Phase I Archaeological Survey, Phase II

Archaeological Evaluation, Site Avoidance Plan, and Contingency Treatment Plan Site

44FR0370, Franklin County, Virginia (June 2017) DHR File No. 2014-1194; FERC #CP16-10 Dear Ms. Neylon: We have received for review the document referenced above prepared by Tetra Tech for Mountain Valley Pipeline, LLC (MVP). We provide the following comments as assistance to the MVP and the Federal Energy Regulatory Commission (FERC) in meeting their collective responsibility under Section 106 of the National Historic Preservation Act. The Phase I and II investigations at site 44FR0370 documented a multicomponent site that covers approximately 140 acres adjacent to the North Fork Blackwater River. Site 44FR0370 contains archaeological deposits dating from the Paleo-Indian Period through the 20th century within a variable depositional context. The archaeological subcommittee of our Department’s National Register Eligibility Evaluation Team concurs that site 44FR0370 is eligible for listing in the National Register of Historic Places (NRHP) The Avoidance Plan depicts a pipeline route within the southern and eastern edges of site 44FR0370 where artifact densities and archaeological integrity are relatively low, a 450-foot long bore beneath Locus E, and fencing and matting to protect archaeological deposits beyond the pipeline trench. We find that the Avoidance Plan sufficiently minimizes impacts to site 44FR0370 and effects to this resource would not be adverse. We support the implementation of the Contingency Treatment Plan should the bore beneath Locus E fail and open trenching



Salem, VA 24153 Tel: (540) 387-5443 Fax: (540) 387-5446



Tel: (540) 868-7029 Fax: (540) 868-7033



necessary. Opening trenching at Locus E would result in an adverse effect to site 44FR0370 and FERC should recognize that potential within the Programmatic Agreement for this project. Thank you for the opportunity to review this document. If you have any questions regarding these comments or our review of this project, please do not hesitate to contact me at [email protected]. Sincerely, Roger W. Kirchen, Director Review and Compliance Division c. Ms. Sydne Marshall, Tetra Tech


attachment ip-15 - mountain valley pipeline...letter dated july 7, 2017, dhr disagreed with the...

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