Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 1 of 17 PageID #: 118

IN THE UNITE It STATES DISTRICT COURT
SOUTHERN DISTRICT OF WEST VI ?kGINIA
(Charleston Division)
MOUNTAIN VALLEY PIPELINE, LLC,
Plaintiff,
v.

CIVIL ACTION NO. 2:17cv04377
(Judge Copenhaver)

MATTHEW D. WENDER, in his official capacity
as President of the County Commission
of Fayette County, West Virginia;
DENISE A. SCALPH, in her official capacity
as a Commissioner of the County Commission
of Fayette County, West Virginia; and
JOHN G. BRENEMEN, in his official capacity
as a Commissioner of the County Commission
of Fayette County, West Virginia,
Defendants.
DECLARATION OF ROBERT COOPER
I, Robert J. Cooper, an adult over the age of 18, declares as follows:
1.

I am the Senior Vice President of Engineering and Construction at Mountain Valley

Pipeline, LLC ("MVP").
2.

I have worked at MVP on the Mountain Valley Pipeline Project ("MVP Project")

since 2013 and have worked for one of MVP's partners, Equitrans, L.P., for fourteen years,
3.

The MVP Project is a natural gas pipeline system that will span approximately 303

miles from northwestern West Virginia to southern Virginia, transporting supplies of natural gas
produced from the Marcellus and Utica Shale formations in West Virginia to markets in the
Northeast, Mid-Atlantic and Southeast regions of the U.S. In addition to a 42" diameter pipeline,
the MVP system will include three new compressor stations, four new meter and regulation
stations and interconnections, and other appurtenances. The approved capital budget for the MVP

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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 2 of 17 PageID #: 119

Project is $3.7 billion, and at least $800 million of that budget is expected to be spent in West
Virginia.
4.

In my role as Senior Vice President of Engineering and Construction at MVP, I

am the company-wide leader for the MVP Project and am responsible for overseeing all
construction, engineering, environmental and land functions for the MVP Project, including the
construction of all compressor stations. I am responsible for ensuring that all construction and
engineering is accomplished safely, effectively, and in accordance with applicable regulations,
permits, and contracts.
5.

One of the compressor stations that is to be a part of the MVP Project is the

Stallworth Compressor Station (the "Stallworth Station"), which will be built on property that is
comprised of three contiguous tracts of land located in southeast Fayette County, West 'Virginia.
All three tracts are owned by MVP, and described as Parcel 6.1, comprising 74.56 acres, more or
less, in New Haven District, Fayette County, West Virginia (Deed Book 728, Page 260); Parcel
14 , comprising 40.32 acres, more or less, in New Haven District, Fayette County, West Virginia
(Deed Book 741, Page 707); and Parcel 15, comprising 16.66 acres, more or less, in New Haven
District, Fayette County, West Virginia (Deed Book 730, Page 616) (the "Stallworth Property").
6.

Alternative locations for the Stallworth Station were evaluated; however, the

Stallworth Property was selected because it was far superior to other potential sites in terms of
topography, site access, surrounding land use (including population density and distance from
residences) and overall environmental considerations. It will require significantly less cut and fill
to achieve a buildable site than alternative locations, is easily accessible from nearby County Route
29, and is located on the top of a hill with dense deciduous forest all around it.

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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 3 of 17 PageID #: 120

7.

Although the Stallworth Property is approximately 131 acres in total size,

construction of the Station is expected to affect approximately 30 acres, and the pad, buildings and
operational area for the Stallworth Station will be built on an area of approximately 7 acres. The
access road to the Station and the MVP Pipeline going into and out of the Station will be located
on other parts of the Stallworth Property. Economic projections show that it can be expected to
generate more than $800,000 in annual ad valorem taxes for Fayette County once the pipeline is
in service.
8.

On August 2, 2017, MVP filed a completed "Change in Land Classification"

application form (the "Rezoning Application") with the Office of Zoning Enforcement for Fayette
County, West Virginia (along with all required enclosures), requesting that the Stallworth Property
be rezoned from an R-R district to an H-1 district. Before that submission, MVP representatives
had met with the Fayette County Zoning Officer and received direction as to specific information
that the Zoning Office wished to have submitted in support of the Rezoning Application. A true
copy of the Stallworth Station Site Plan, as submitted to the Commission as a part of the Rezoning
Application, is attached to this statement as Exhibit A.
9.

As requested by the Fayette County Zoning Department, on August 2, 2017 MVP

also submitted a summary letter ("Project Summary"), describing the nature of the MVP Project
and the FERC certificate process, and addressing the following topics: Safety Overview;
Emergency Response Plan; Regulatory Compliance Overview; Project Construction; Construction
Techniques and Information; Pre-Construction Noise Study; Noise Mitigation; Compressor
Station Lighting; Estimated Truck Traffic; and Economic Benefits. A true copy of the Project
Summary (without exhibits) is attached to this statement as Exhibit B.

(133564792.3)

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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 4 of 17 PageID #: 121

10.

MVP has been issued a permit for the Stallworth Station under the approved state

version of the federal Clean Air Act, 42 U.S.C. 7401, et seq. and has been granted coverage under
a General Permit addressing Stormwater Associated with Oil and Gas Related Construction
Activities issued by the West Virginia Department of Environmental Protection (WV General
Permit No. WV0116815) for its planned construction of the Stallworth Station.
11.

On October 13, 2017, MVP received a Certificate of Public Convenience and

Necessity from the Federal Energy Regulatory Commission ("FERC") for the MVP Project and I am
familiar with and knowledgeable about MVP's application process and approval from FERC.
12.

Under the long-term transportation service agreements ("TSAs") that have been

entered for transportation of gas at quantities that account for all of the design capacity that will
be available on the MVP pipeline system, the shippers' obligations are not binding until the entire
MVP Project is constructed and placed in service. Once the system has been placed in service,
MVP will receive approximately $40 million to $50 million per month in revenue from the
shippers under the TSAs. There is no way of knowing whether any shippers would choose to
transport gas on a short-term basis using portions of the MVP Project, before it is placed in service.
13.

MVP plans to construct the pipeline and place it into service by December 2018.

14.

In order to have the full capacity of the MVP Project available and placed in service

by December 31, 2018, it is essential that the Stallworth Station be in service by that date.
15.

To meet this schedule, the MVP project will be constructed simultaneously across

eleven segments, and there will be separate construction spreads for each compressor station.
Because the compressor stations take longer to build than the pipeline segments, construction of
the compressor stations needs to be started before the pipeline construction itself.

(83564792.3)

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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 5 of 17 PageID #: 122

16.

In order to comply with the project construction schedule for the Stallworth Station,

construction of the station must begin as soon as possible. Because of that, immediately after
issuance of all federal permits and approvals for the project, on January 16, 2018, MVP filed a
letter requesting that FERC issue a notice to proceed with construction of the Stallworth Station
(and the other two compressor stations that are a part of the MVP Project). That Notice to Proceed
was issued on January 29, 2018, and allows MVP to proceed with construction of the Stallworth
Station immediately. If MVP is permitted to do so, it may be possible to get the construction of
the Stallworth Station back on a schedule that will allow its completion by December 31, 2018.
17.

In February 2018, MVP plans to begin mobilizing its construction crews across

eleven segments of the MVP Project.
18.

If the beginning of construction of the Stallworth Station was delayed for even two

months (i.e., until April 1, 2018), it would present a serious risk to the ability of MVP to complete
the MVP Project by December 31, 2018.
19.

In addition to the delay in receiving revenue under the TSAs for the project, if the

MVP Project is not completed and placed in service by December 31, 2018, MVP will incur
expenses in the form of contractual penalties that will be required to be paid to contractors and
increased overhead costs (such as salaries and materials management and storage). If the MVP
Project is not completed and placed in service by December 31, 2018, this would also result in
damage to MVP's reputation, that would affect the willingness of contractors to work with MVP
in the future.
20.

In its Certificate Order, FERC found that the MVP Project is a public convenience

and necessity and that the public interest will be served by construction of the MVP Project.
Specifically, the Commission found that "the public at large will benefit from the increased

(e3S64792.3)

5

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 6 of 17 PageID #: 123

reliability of natural gas supplies." FERC Certificate Order, p. 62. The Commission also found
that the MVP Project will benefit producers of natural gas. Id.
21.

Delaying the Stallworth Station would postpone the public benefits that the pipeline

will provide and increase the costs of completing the work and result in the loss of substantial
revenue to MVP.

I declare under penalty of perjury under the laws of the United States that the foregoing is
true and correct.

Dated this 544day of February, 2018.

1B3564792.3)

6

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 7 of 17 PageID #: 124

Robert J. Cooper Declaration
Exhibit A

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 8 of 17 PageID #: 125

ii

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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 9 of 17 PageID #: 126

Robert J. Cooper Declaration
Exhibit B

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 10 of 17 PageID #: 127

71 Mountain
Valley

PIPELINE ac

August 2, 2017
Fayette County Zoning Department
100 Church Street
Fayetteville, WV 25840
Re:

Mountain Valley Pipeline: Stallworth Compressor Station Project

Dear Mr. Richardson:
Please see the following information provided by Mountain Valley Pipeline, LLC (Mountain Valley) per
the request made on July 20, 2017 by the Fayette County Zoning Department during the pre-application
meeting:
Project Overview
As proposed, the Mountain Valley Pipeline project is a natural gas pipeline system that spans approximately
303 miles from northwestern West Virginia to southern Virginia. Mountain Valley will have a total of 2,656
feet of pipeline in Fayette County, West Virginia (please see Attachment 1 for a map of the project). As an
interstate pipeline, Mountain Valley will be regulated by the Federal Energy Regulatory Commission
(FERC). Mountain Valley will be constructed and owned by Mountain Valley Pipeline, LLC, which is a
joint venture between EQT Midstream Partners, LP; NextEra US Gas Assets, LLC; Con Edison
Transmission, Inc.; WGL Midstream; and RGC Midstream, LLC. EQT Midstream Partners will operate
the pipeline and own a significant interest in the joint venture.
With a vast supply of natural gas from Marcellus and Utica shale production, the Mountain Valley Pipeline
is expected to provide up to two million dekatherms per day (two billion cubic feet (Bcf) per day) of firm
transmission capacity to markets in the Mid- and South Atlantic regions of the United States. Mountain
Valley will extend from the Equitrans transmission system in Wetzel County, West Virginia to
Transcontinental Gas Pipeline Company's (Transco) Zone 5 compressor station 165 in Pittsylvania County,
Virginia. Mountain Valley Pipeline has secured firm commitments for the full capacity of the MVP project
under 20-year contracts.
The pipeline will be governed by the United States Natural Gas Act, which requires a Certificate of
Convenience and Necessity from the FERC before construction can commence. As currently planned, the
pipeline will be up to 42 inches in diameter and will require approximately 50 feet of permanent easement
(with up to 125 feet of temporary easement during construction). Engineering aspects have included
surveying and evaluating various routes to help determine a proposed route with the least overall impact to
landowners, cultural and historic resources, and the environment. During the Pre-Filing Review, which
began in late October 2014, the Mountain Valley team started to conduct environmental surveys, hosted
open houses, and participated in FERC scoping meetings, all in an effort to encourage open discussion with
community members, landowners, and public agencies. These public meetings generated valuable
feedback that helped shape the current route, as proposed in the October 2015 filing.
The proposed Mountain Valley route has been carefully designed to utilize existing gas and electric
transmission corridors when possible; avoid sensitive or protected areas when feasible; and limit surface
disturbance and minimize the overall environmental footprint. As part of Mountain Valley's commitment
www.mountainvalleypipeline.info

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 11 of 17 PageID #: 128

to communities, the project team has considered thousands of miles of alternatives and variations to the
proposed route in an effort to alleviate concerns posed by interested and informed stakeholders along the
route.
The Mountain Valley project team has identified the need for three compressor stations along the proposed
route to transport natural gas to its delivery point, Transco Zone 5 Compressor Station 165 in Pittsylvania
County, Virginia. The proposed compressor stations are located in Wetzel, Braxton, and Fayette counties
of West Virginia. A compressor station is a natural gas facility located along a pipeline route that
compresses gas in the line to increase pressure, allowing it to flow through the line toward its intended
destination. Friction and elevation changes induce pressure drops on natural gas traveling in a pipeline and
must be periodically compressed to ensure consistent pressure and efficient delivery; therefore, a
compressor station is typically placed every 40 to 100 miles along the pipeline route.
The Stations will be built on lands purchased by the project and owned by Mountain Valley Pipeline, LLC.
The natural gas compressors will be driven by turbine engines that will be powered by natural gas. The
compressors will utilize a fraction of separately metered gas corning through the station from the pipeline
as fuel and will compress the remainder for transport and delivery.
Project Information: Fayette County
Mountain Valley will have a total of 2,656 feet of pipeline in Fayette County, West Virginia. Mountain
Valley owns the property where 2,522 feet of pipeline will be located. The remaining 134 feet of right of
way is leased from a private landowner. The Stallworth Compressor Station is sited, in Fayette County, at
approximate milepost 154.2. Mountain Valley owns the entire property where the Stallworth Compressor
Station is located. The Station Site Plan is included as Attachment 2. The purpose of the compressor station
is to pull gas from the Harris Compressor Station for relay delivery to the terminus at Transco Station 165.
The Stallworth Compressor Station will contain two gas-fired turbines, providing approximately 41,000
horsepower of compresSion.
Once fully operational, the Stallworth Station will be monitored 24/7 by an offsite system and will have
remote devices with the ability to monitor, control, and shut down operations in the event of an emergency.
Emissions from the construction and operation of the compressor station will comply with all applicable
air quality regulations as permitted by regulatory authorities. Equipment, controls, and safe operating
practices will be utilized to minimize emissions. Pending FERC approval of the project, the estimated
construction start date for the compressor station is fourth quarter 2017, with construction completion in
late 2018.
Safety Overview
The Mountain Valley Pipeline project team respects the concerns and opinions of community members; we
value each landowner's property; and we certainly value the safety of our employees, contractors, and the
surrounding communities. We want to work with everyone in our Virginia and West Virginia communities
to ensure we are building this pipeline and compressor station safely and responsibly. Mountain Valley
takes tremendous precautions to ensure the long-term safety of our pipelines and compressor stations — and
Legal Description: Parcel 6.1 — 74.56 acres, more or less, New Haven District, Fayette County, West Virginia, as
described in Deed Book 728 Page 260. Parcel 14 — 40.32 acres more or less, New Haven District, Fayette County,
West Virginia, as described in Deed Book 741 page 707. Parcel 15 — 16.66 acres more or less, New Haven District,
Fayette County, West Virginia, as described in Deed Book 730 Page 616. Coordinates: latitude N37° 52' 06.92"
longitude W80" 45' 29.54"
Page 2 of 8

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 12 of 17 PageID #: 129

once operational, we will utilize sophisticated technology to monitor the pipeline and Stallworth
Compressor Station, in real time, 24-hours-a-day and 7-days-a-week.
Emergency Response Plan
When the Stallworth Compressor Station construction contract is awarded, the successful bidders for both
the civil and mechanical projects will be responsible for submitting a site specific Emergency Response
Plan (ERP) for the project's construction phases. These plans will include coordination with local
Emergency Medical Services (EMS). Mountain Valley will review, approve and distribute these plans
accordingly. Since the contractor is responsible for training, Mountain Valley will ensure that all personnel
are trained per the specific ERP requirements.
Before the Stallworth Compressor Station is completed, commissioned, and in service, Mountain Valley
will develop and implement an Emergency Response Plan for the site. Mountain Valley will contact the
local EMS to coordinate and familiarize the departments with the Stallworth Compressor Station and the
ERP. To date, Mountain Valley has conducted meetings with the county level EMS of Fayette and
Greenbrier counties in Fall of 2016 and will conduct additional meetings with each EMS prior to
construction.
Since the project's construction phase ERP will not be completed until the contract is awarded, please see
Attachment 3 that includes the EQT Bradshaw Compressor Station Emergency Response Plan for the
facility located in Jolo, West Virginia. This ERP will serve as an example of what will be included and
required within the Stallworth Compressor Station's future ERP.
Regulatory Compliance Overview
As the lead federal agency, FERC is overseeing the federal permitting process for the Mountain Valley
Pipeline project and is coordinating with other federal and state agencies during the environmental review
process to identify potential environmental concerns. In regards to the Stallworth Compressor Station and
the associated pipeline in West Virginia, Mountain Valley is coordinating with state and federal regulatory
agencies to obtain the required permits to construct and operate. Specifically, Mountain Valley has
coordinated with the West Virginia Department of Environmental Protection (DEP), the West Virginia
Division of Highways (DOH), the West Virginia Division of Natural Resources (DNR) and the United
States Army Corps of Engineers (USACE).
To date, Mountain Valley has received the following project wide permits in West Virginia:
• DEP - West Virginia Natural Streams Preservation Act Permit (Attachment 4);
• DEP - General Permit No. WV0116815 (Attachment 5);
• DEP — State 401 Water Quality Certification (Attachment 6);
In regards to Fayette County, and specifically, the Stallworth Compressor Station Project, Mountain Valley
has received the following permits, licenses and rights of entry:
• DEP, Division of Air Quality - R13 Permit to Construct and Operate (Attachment 7);
• DOH - Permit No. 09-2017-0205 (Attachment 8);
• DNR — Right of Entry: LS-16:IV/10-1576 (Attachment 9);
• DNR — License and Right of Entry: P-16-IV/10-1575 (Attachment 10); and
• DNR — License and Right of Entry: P-17-IV/10-348 (Attachment 11).
General Permit No. WV0116815 (Attachment 5) is the National Pollution Discharge Elimination System
(NPDES) permit and also known as the "Stormwater Permit." As a requirement of the project, an Erosion
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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 13 of 17 PageID #: 130

and Sediment Control Plan was approved on July 14, 2017. The DEP approved Erosion and Sediment
Control Plan for Permanent Above-Ground Facilities is included as Attachment 12. Mountain Valley's
Nationwide Permit 12 — Utility Line Activities application is currently being reviewed by the United States
Army Corps of Engineers.
On April 11, 2016, the DEP's Division of Air Quality issued Permit No. R13-3277 (Attachment 7) to
operate and construct the Stallworth Compressor Station. In regards to monitoring and frequency at the
station, Permit No. R13-3277 requires the following:
For each Turbine:
• Monthly - monitor the hours operated per Condition 4.2.1.
• Monthly - determine compliance with the annual limits in 4.1.1.
• Maintain the FERC tariff limit on total sulfur content of 20 grains of sulfur per 100 standard cubic
feet of natural gas combusted in the turbines (Condition 4.1.1.a.iii).
• Within 60 days after achieving maximum output, but no later than 180 days after initial startup,
conduct an initial performance test for NOx in accordance with Condition 33.1 and 40 CFR
60.4400 (Condition 4.3.1).
• Annually, conduct performance tests for NOx in accordance with Condition 3.3.1 and 40 CFR
60.4400 (Condition 4.3.1).
For each Heater:
• Monthly - monitor fuel consumption for each heater in accordance with Condition 4.2.2.
Project Construction
Mountain Valley will comply with all U.S. Department of Transportation Pipeline & Hazardous Materials
Safety Administration (PHMSA) regulations during construction. Safety will be engineered into all facets
of Project design, construction and operation. The Project will utilize trained and experienced inspectors
who will carefully monitor pipeline and compressor station construction to ensure compliance with safety
standards and construction specifications. Quality steel pipe will be used in the construction of the pipeline,
including adding protective coatings to the pipe during manufacturing. All pipe will be carefully inspected
before it is installed to ensure it meets quality standards. After installation, all pipeline field welds will be
tested and inspected. Before being placed into operation, the line would be pressure tested to certify
integrity. Once in service, the pipeline would be patrolled, monitored, inspected and maintained by a
subsidiary of EQT Corporation.
Construction Techniques and Information
Clearing, Grading, and Trenching
Before construction begins, surveys are conducted to identify project limits, such as the property boundary,
right of way and limit of disturbance. The surveying is done on the pipeline and compressor station
locations. Once surveying is completed, a clearing contractor removes trees, large rocks, and debris from
the limits of disturbance. After clearing occurs and the site is accessible, grading takes place to prepare a
level surface for heavy construction activity at the compressor stations and along the pipeline. Before earth
disturbance begins, the appropriate erosion and sediment control best management practices (E&S BMPs)
are installed to maintain compliance with state and federal permits and protect the adjacent resources.
Although, each compressor station will have a different construction sequence, the attached erosion and
sediment control narrative (Attachment 12) provides a General Construction Sequence for the compressor
station. A more detail construction sequence is included in each compressor stations plan set. In summary,
after clearing is completed, the compressor sites will achieve final grade by contouring the land through
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grade cuts and slope fills to meet the design requirements. The area will be structurally stabilized using
compaction tests, bonding benches, soldier pile walls, and access road soil nailing. Once the site is
structural stabilized and at final grade, construction begins on the compressor station's mechanical and
structural components.
The pipeline trench will lay, at a minimum of 36 inches below the surface, which surpasses the required
minimum of 30 inches as regulated by the Department of Transportation. As soil is removed, the topsoil
and subsoil are typically used during restoration.
Stringing, Welding, and Coating Pipeline
Pipelines typically consist of pipe segments that are 40 to 80 feet long. These segments must be moved to
the trench location, assembled, and welded before being placed in the trench. A bending machine will be
utilized to bend the pipe to conform to unique topography of the construction area. Pipe segments are
welded together to ensure maximum strength and integrity, and when necessary, an external coating will
be applied to prevent moisture from causing any type of possible corrosion. The Mountain Valley team will
X-ray 100% of the individual welds to ensure the integrity and longevity of the pipeline prior to placing the
line in-service. These welds will meet all federal regulatory requirements.
Depositing, Backfilling, and Testing
Once the pipeline is properly and accurately welded, it is lowered into the trench using equipment with
side-booms and slings to prevent the pipe from falling. When the pipe is successfully laid, the construction
crew will begin to backfill the trench. Careful measures are taken to ensure the topsoil is returned to its
original position, while special precaution is given to preserving the integrity of the pipeline and coating
during this process. Before placing the pipeline in-service, the line is water-pressure tested as a final quality
assurance test.
Restoration
The final step of the construction process is to restore the right-of-way and easement property as closely as
possible to its original condition. Steps in this process may include replacing topsoil, removing rocks,
spreading fertilizer, or restoring fences. The Mountain Valley team will work with landowners and agencies
to ensure the proper restoration of both private and public property.
Mountain Valley will ensure safe operation by maintaining the right-of-way to provide safe access and
operate the pipeline in accordance with U.S. DOT and FERC regulations. Regular inspections will occur to
ensure pipeline integrity. The pipeline will be monitored 24-hours-a-day, 365-days-a-year using
sophisticated computerized systems and around-the-clock personnel. There will be signage indicating the
location of the pipeline and a phone number posted for those who plan to do excavating in the area.
Pre-Construction Noise Study
SLR International Corporation (SLR) has constructed a computer noise model and noise control treatment
design study (Attachment 13) at the request of Mountain Valley for the proposed Stallworth Compressor
Station. The proposed Station will have two new Solar Titan 130 turbine/compressor units, each rated at
20,500 horsepower. This report presents the results of a pre-construction noise survey conducted by SLR
and the requirements for equipment sound power levels and noise control treatments that are necessary in
order for the planned equipment to meet the FERC sound level limit of 55 dBA day-night average (Ldn).
The environmental sound level contributions from the proposed equipment at this compressor station are
subject to the FERC noise regulation governing interstate gas transmission compressor stations. The FERC
noise regulation is receptor based, and limits compressor station noise contributions to no more than 55
dBA Ldn or, equivalently, no more than a continuous 48.6 dBA at the surrounding noise sensitive areas
Page 5 of 8

 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 15 of 17 PageID #: 132

(NSAs). NSAs are typically residences, schools, churches, or hospitals. Six NSAs were identified by SLR
using aerial imagery and consisted of the six closest residential areas to the compressor building. The
distance and direction from the site to the monitoring locations and ambient noise sources present during
data collection are described in the attached report and included in Table 5-2 below.
As provided below, Table 5-2, shows a summary of the predicted sound level contribution of the Station
equipment at each NSA. Table 5-2 also includes a prediction of the overall NSA sound levels, including
the Station and ambient environmental sources. The compressor station noise contributions, at all of the
nearest NSAs, will be below the FERC criterion of 55 dBA Ldn (Please see column titled "Combined, All
Sources Including Ambient"). In fact, the increase above the measured background level/existing condition
is found to be no more than 3.4 dB (Please see the column titled "Increase Above Existing Condition").

Direction

Table 6-2: Compressor Station Sound Levol Predictions

<
co
z

Distance
from NSA to
Compressor
Building

1
2
3

2,835
1,985
2,085

WNW
West
SW

4
5
6

1,465
1,340
2,755

SSW
SE
ESE

(feet)

Measured
Existing
Background
Ldn

dBA

Estimated
Contribution of
Station Equipment
L,, dBA

54.9
39.9
44.9
36.8
54.1
54_1

30.4
34.0
34.0
27.2
33.0
29.7

Lin dBA
36.8
40.4
40.4
33.6

Combined,
All Sources
Including
Ambient

Increase
Above
Existing
Condition

Lan dBA

(dB)

55.0
43.0
46.2

0.1
3.4
1.3

37 8
54.2
54.2

2.0
0.1
0.1

39.4
36.1

If applicable, the Stallworth Compressor Station would also be in compliance with the Fayette County noise
ordinance, which limits noise at the receiving residential property lines to 65 dBA between 7 a.m. and 6
p.m. and 55 dBA between 6p.m. and 7 a.m.
Noise Mitigation
The noise mitigation measures for the Stallworth Compressor project are shown in Section 6, within
Attachment 13. There are a variety of noise control mitigation measures that will provide similar noise
control and ensure compliance with the FERC sound level requirements. A summary of the modeled
performance of the noise control treatments is shown in Table 6-1, below.
Table 6-1: Recommended Noise Control Treatments

Recommended Insertion Loss (IL) or Transmission Loss (TL)
Source

Treatment Description

Recommended Treatment Performance
31.5

63

125

250

5O0

1k

STC-39 Wal: and Roof System, TL

10

16

17

24

44

49

Equipment Door

STC-21 :nsulated Rol-up Door. TL

2

7

12

17

18

Building Ventilation

Three foot silencers and tined hoods. IL
66 dBA at 12 feet

1

5

10

18

Comp Suction and
Discharge Piping

Lagging (ISO Type B2). IL_

D

0

0

0

CornpressorNalve
Building

dk

8k

55

55

58

10

22

30

35

22

26

3D

35

25

0

15

24

33

42

ai

2k

ei

Please see Section 6 (Attachment 13) for additional details on mitigation treatments.
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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 16 of 17 PageID #: 133

Compressor Station Lighting
Mountain Valley will install directional lighting at the Stallworth Compressor Station. The lighting devices
will face down towards the station to reduce any light seen from offsite locations. The lights will also have
sensors installed and timing of light usage will be determined, as necessary, once construction begins and
the station is operational.
Estimated Truck Traffic
It is currently estimated that during construction, heavy truck traffic will haul an average of three loads per
day for approximately ten months. Pickup truck traffic will average twenty pickups per day for
approximately ten months. Once the compressor station is operational, pickup truck traffic will average one
to two vehicles per day and will decrease accordingly.
Economic Benefits
Reports have been provided that outline the potential economic benefits of the Mountain Valley Pipeline
Project in West Virginia (Attachment 14), and specifically, the economic benefits for Fayette County
(Attachment 15). Said reports contain the following information:
Construction Benefits
The Mountain Valley project developers are expected to spend $811 million on West Virginia-based labor,
goods, and services from 2015 to 2018 to support construction of the project. This direct spending would
add $594 million in cumulative gross regional product to West Virginia during that period and up to 4,500
jobs in 2017 and 2018 during the peak of construction. With its established manufacturing base, Fayette
County could have the opportunity to contribute labor and other resources to the construction effort.
Pipeline Operation Benefits
Ongoing operation of the pipeline would support a total of 54 jobs across the state with average annual
wages and benefits of $65,000.
Ad Valorem Tax Benefits
The Mountain Valley project could generate up to $840,000 in annual county ad valorem taxes (property
taxes) for Fayette County once the pipeline is in service.
Direct-Use Benefits: Residential, Commercial, and Municipal
Natural gas and electricity are the main space and water heating sources in the county. Mountain Valley
could provide additional gas supply options to the county.
Project Wide Economic Benefits:
• Direct Spending: With an estimated capital expense of $3.5 billion, the Mountain Valley project
anticipates spending $407 million directly in Virginia, and $811 million directly in West Virginia
• Labor & Employment: During peak employment, the Mountain Valley project is expected to
contribute more than 4,400 jobs to the Virginia economy, and an estimated 4,500 jobs to West
Virginia's economy
• Labor Income: The Mountain Valley project will have a positive impact on labor income —
contributing an estimated, average employee labor income of $56,200 in Virginia, and a $49,300
average employee labor income in West Virginia
• Tax Revenues: A significant source of state and local tax revenues will be generated during the
construction phase, with approximately $34 million generated in Virginia, and $47 million

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 Case 2:17-cv-04377 Document 15-1 Filed 02/05/18 Page 17 of 17 PageID #: 134

•

generated in West Virginia
Ad Valorem Taxes: Once the Mountain Valley Pipeline is operational, counties along the route
will continue to receive tax revenues — generating an estimated $7 million in Virginia, and close to
$17 million to the counties in West Virginia

FERC Status
On October 23, 2015, Mountain Valley filed the formal application with the FERC for approval to construct,
own, and operate the Mountain Valley Pipeline. The application requesting the FERC Certificate of Public
Convenience and Necessity was received and the Mountain Valley project was issued Docket Number
CP16-10 on November 5, 2015.
On September 16, 2016, FERC issued the Draft Environmental Impact Statement (DEIS) for the Mountain
Valley project. The DEIS was issued after more than 27 months of project planning and development. On
October 13, 2016, the Mountain Valley project team filed an updated route with the FERC, known as the
MVP October 2016 Proposed Route, which reflects numerous route adjustments to mitigate concerns raised
during public comment periods.
On June 23, 2017, the FERC issued the Final Environmental Impact Statement (FEIS) for the Mountain
Valley project. This FEIS comes after three years of project planning and development, and takes into
account recommendations from the FERC's DEIS issued in September 2016. The FEIS also considers and
includes the analyzed data from civil and environmental surveys that have been conducted, as well as the
comments, considerations, and concerns of landowners, community members, government agencies, and
located elected officials along the proposed route.
After review of the FEIS, the FERC will make a decision, in third quarter 2017, on whether to approve the
Mountain Valley project. Subject to regulatory approvals, construction on the project is anticipated in
fourth quarter 2017 with the targeted in-service date for the Mountain Valley Pipeline in fourth quarter
2018.
***

Mountain Valley Pipeline looks forward to continuing to work with Fayette County. Please feel free to
contact me if you have questions or need any additional information. Thank you for your time and
consideration.

Sincerely,

P. Robert Pichardo III, Esq.
Senior Staff Attorney
RPichardo@eqt.com

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