20181638 Ver 3_Hearing Officer Report_20200811

To:
From:
Date:
Subject:
MEMORANDUM
S. DanielSmith
Director, Division of Water Resources n.''U,
John Hennessy, Supervisor, Compliance & Expedited Permitting Branch { -4rt,Water Quality Permitting Section, Division of Water Resources ,""-
t-'""'
August LL,2O2O
Hearing Officer's Report and Recommendations
Mountain Valley Pipeline LLC
lndividual 401 Water Quality Certification and Jordan Lake Buffer Authorization
Certificate
Alamance and Rockingham Counties
.42/Jy'J....
I served as the Hearing Officer for the subject Public Hearing held at the Rockingham
Community College in Wentworth, NC on November 19, 2OL9. The public hearing was
held under the authority of Title 15A NCAC 02H .0503. The rules applicable to the
hearing and to the project review are available in Appendix A. The purpose of this
public hearing was to receive comments on the Division of Water Resources' 401 Water
Quality Certification (401 WQC) and Jordan Lake Buffer Authorization Certificate
applications (Appendix B) submitted by Mountain Valley Pipeline, LLC (MVP). A 401
WQC and Jordan Lake Buffer Authorization Certificate are needed to construct a
proposed naturalgas pipeline through Alamance and Rockingham Counties.
In addition to listening to oral comments at the public hearing I have reviewed all
written comments received prior, during and'after the public comment period. ln
preparation of this report, I have considered all of the public comments, the public
record, discussions with Division of Water Resources (DWR) staff related to the rules,
and their review of the applications for the project.
The report has been prepared using the following outline:
l. History / Background
ll. Public Hearing Summary
lll. GeneralComments
lV. Recommendations
V. Summary
Vl. Appendices
l. History/ Background
On August 13,2OL9, Mountain Valley Pipeline, LLC (MVP) submitted an application for a
40L WQC and a Jordan Lake Buffer Authorization Certificate. MVP had previously
applied to DWR on November 3O 20L8. DWR denied the previous application on June
3,20L9 because insufficient information was available to review the application at that
time.
,4,
'"yt
2

MVP is proposing to construct and operate an approximately 75.1-mile-long interstate
natural gas transmission pipeline system through Virginia and North Carolina. In North
Carolina, MVP is proposing to install approximately 48.2 miles of transmission pipeline
and appurtenances, including 3 interconnect stations and 5 mainline valve sites (2 co-
located with the interconnects) through Alamance and Rockingham Counties.
MVP’s initial application proposed impacts to over 207 streams and open waters. The
proposed impacts comprised of temporary impacts to over 17,000 linear feet of surface
waters during the construction phase. None of the proposed impacts would be
considered permanent after the project’s construction was complete. MVP’s initial
application also proposed temporarily impacting approximately 13.95 acres of wetlands
and permanently impacting 0.02 acres of wetlands. MVP’s initial application proposed
impacts to over 357,000 square feet of Zone 1 and over 270,000 square feet of Z one 2
of the protected riparian buffers within the Jordan Lake Watershed.
DWR requested and received additional information several times throughout the
application review process:
Date Action
September 23, 2019 Req. for Add Info (1)
October 30, 2019 Add Info Received (1)
December 20, 2019 Add Info Received
January 28, 2020 Req. for Add Info (2)
March 13, 2020 Partial Add Info
Received (2)
March 23, 2020 Additional Add Info
Response Received (2)
April 17, 2020 Additional Add Info
Partial Response
Received (2)
May 19, 2020 Additional Add Info
Supplemental
Response Received (2)
June 12, 2020 Req. for Add Info (3)
June 26, 2020 Add Info Response
Received (3)

3

Throughout the application review process, MVP has continued to refine the project
design and has proposed a reduction in originally proposed impacts to jurisdictional
streams and wetlands as well as riparian buffers. The most recent application
addendum proposes the following impacts:

Impact Type Proposed Impact Amount
Streams 14,144 linear feet
Wetlands 12.34 acres
Zone 1 riparian buffer 180,680 square feet
Zone 2 riparian buffer 220,410 square feet

Under the authority of Title 15A NCAC 02H .0503, DWR held a public comment period
from October 18, 2019 until December 20, 2019 to accept public input on the
application. The public comment period included a public hearing as described below.
In accordance with Title 15A NCAC 02H .0503, notice of the public hearing and
availability of the application for the 401 WQC and Jordan Lake Buffer Authorization
Certificate was sent by email to the Water Quality Certification Listserv on October 18,
2019 (Appendix C ). It was also published in Rockingham Now on October 20, 2019 and
the Burlington Times-News on October 18, 2019. The public comment period ended at 5
pm on December 20, 2019.

II. Public Hearing
A public hearing was held November 19, 2019, at 6 p.m. at the Rockingham Community
College in Wentworth, NC. The public hearing was held under the authority of Title 15A
NCAC 02H .0503. This was a public hearing to receive public comment for the DWR 401
WQC application (Appendix B) submitted by MVP.
Fifty-nine people attended the public hearing, including eleven staff members from the
Department. (Appendi x D). The hearing officer provided opening remarks and Sue
Homewood, DWR, presented background information on the 401 WQC process and the
proposed application. Twenty-two individuals registered in advance of the hearing to
provide comments. Speakers were given three minutes for presentations. The list of
speakers is included (Appendix D).
The public hearing transcript, including oral comments, is attached to this report
(Appendix E). DWR also received 1,725 written comments during the public comment
period. (Appendix F). Of the 1,725 written comments received, all but three were
opposed to the project. A summary of the oral and written comments, along with
detailed responses that have a direct impact on the certification decision making
process, are included below in Section III.
4

III. General Comments
The following is a summary of the comments received during the November 19, 2019
public hearing and during the public comment period. Because the number of
comments received were too numerous, it is not reasonable to address every comment
individually in this report. However, after reviewing the comments, it was possible to
identify generalized areas of concern which are addressed in this report. The discussion
below is organized by these general areas of concern and is intended to analyze and
address all substantive comments received. All comments received are included in
Appendi x E. It should be noted that all the c omments received outside of the public
comment period were also made part of the public record.

Climate Change & NC Executive Order 80
General Comments
A number of comments expressed concerns about the continued use of fossil fuels,
specifically fracked natural gas, and their impact on climate change. Many expressed
the belief that the State of North Carolina, and country as a whole, should be moving
toward the use of renewable energy sources. Multiple commenters stated that the
project would conflict with Governor Cooper’s Executive Order 80. Proponents of the
project believe that natural gas is a “clean” fuel option to replace coal and other fossil
fuels.
Response to Comments on Climate Change and NC Executive Order 80
After reviewing Executive Order 80 (EO80), it was determined that, although the project
may appear to be inconsistent with the strategy outlined in the Clean Energy Report
directed by EO80 to “Decarbonize the electric power sector,” issuing a 401 Water
Quality Certification would not prevent any of the goals of the order from being
achieved, or directives placed on the NCDEQ, from being im plemented. EO80 lays out
broad reduction goals and places requirements on NCDEQ to implement larger
programmatic actions. The approval of this project would not, singularly, prevent
obtaining any of the goals stated in EO80. In addition, the directives assigned to
NCDEQ are programmatic in nature and intent, and as such, are much broader in scope
than this single project.

Cumulative Impacts
General Comments
Multiple comments were received that expressed concern about the quality of the
cumulative impact analysis provided in the application. More specifically, there was
concern expressed that the direct and indirect impacts from construction and long -
term operation of the project were not adequately identified, described, and
quantified.

5

Response to Comments on Cumulative Impact Analysis
After reviewing the received comments, as well as the application, DWR requested
additional information on the anticipated cumulative impacts for the project. That
request was sent on January 28, 2020. The requested additional information was
received by the DWR on March 13, 2020. It is important to note that the requirements
of the cumulative impacts analysis for the 401 WQC and the federally required National
Environment Policy Act (NEPA) are different in scope and detail , and are designed to
meet different standards. DWR’s is required to evaluate cumulative impacts in
accordance with DWR’s Cumulative Impact Policy (April 10, 2004) which is a more
specific and limited analysis. Concerns expressed by commenters were specific to the
federal cumulative impact analysis required as part of FERC’s implementation of the
National Environmental Policy Act (NEPA). After reviewing the original cumulative
impact analysis and the additional data provided by the applicant on March 13, 2020, it
is my opinion that the cumulative impact information provided is sufficient to meet the
requirements imposed on DWR by 15A NCAC .0506. Moreover, given the protections
provided in 15A NCAC 2H .0500, 15A NCAC 2B .0200, and the Hearing Officer’s
recommendations discussed in this report, it is my opinion that the legal requirements
for cumulative impact analysis pursuant to issuance of the 401 Water Quality
Certification have been met.

Project Purpose & Need
General Comments
Multiple comments were received that questioned the purpose and need of the project.
The concerns included evidence that the growth of natural gas markets was estimated
to be negligible and questioned the need to build such a large and expensive pipeline.
Commenters articulated concern that the market demand was generated through
companies owned or affiliated with power c ompanies and that the need was self-
serving rather than generated by actual growth projections. In addition, several
comments identified the NC Department of Environmental Quality’s comments
submitted to FERC regarding the proposed project’s purpose and need submitted to
FERC .
Response to Comments on Purpose & Need
While we understand the concerns expressed by the commenters, any remedy for the
comments is outside the evaluation criteria established in N.C. Administrative Code for
the review of 401 Water Quality Certifications and Buffer Authorizations.

Environmental Justice
General Comments
Several comments were received that expressed concern about environmental justice
issues associated with pipeline’s construction and operation. The primary concern was
that the pipeline’s construction along the chosen alternative would have a
disproportionate impact on low-income and minori ty communities. In addition, several
6

comments expressed concern that the applicant has not adequately addressed potential
impacts to cultural resources along the pipeline route.
Response to Comments on Environmental Justice
The Director evaluates a 401 WQC application based on six criteria including a no
practical alternatives analysis, minimization of adverse impacts to surface waters, an
analysis of the degradation of ground waters or surface waters, a cumulative impacts
analysis, protection of downstream water quality through stormwater control measures,
and replacement of existing uses through mitigation. Environmental justice is not
included in the criteria upon which the Director must evaluate the application under 15A
NCAC 02H .0506. Although Environmental Justice is not an evaluation criterion, the
Department has engaged with the stakeholders of North Carolina throughout the
permitting process. In addition to aforementioned stakeholder engagement, the
Department has provided transparency with all the citizens who signed up to the email
newsfeed, as well as having meetings with the Commission of Indian affairs. The
Department has considered all comments and communications received on this project
and has undertaken a thoughtful review of the information in its review of the
application for the proposed Southgate MVP project. Further comments should be
directed to FERC.

Sediment and Erosion Control
General Comments
There were multiple comments received about the potential to impact water quality
from erosion and sedimentation during construction activities. The comments
expressed concerns with the adequacy of the erosion and sedimentation control pla ns,
as well as the applicant’s record of non-compliance with environmental regulations and
permits for the present pipeline construction in other states.
Response to Comments on Sediment & Erosion Control
Under North Carolina law, MVP is required to secure , and comply with, an approved
Erosion and Sedimentation Control Permit issued by the Division of Energy and Mineral
Resources (DEMLR). Compliance with the Erosion and Sediment Control Plan Approval
will be enforced by DEML R. Regardless of DEMLR’s future compliance actions, DWR will
maintain authority to addr ess compliance concerns through the standard conditions
included in the 401 Water Quality Certification and DWR’s statutory authority to
protect water quality standards.
In addition, the applicant has identified opportunities for enhanced high-quality
sediment and erosion control measures in sensitive areas. I recommend incorporation
of these measures as a condition, should the 401 WQC be issued. All conditions of the
401 WQC would be enforced by the DWR . Additional compliance inspection
recommendations are addressed below.

7

Construction Activities
General Comments on Blasting
A few commenters raised concerns about living within the “blast zone” of the pipeline
and questioned the protection of nearby structures and private wells.
Response to Comments on Blasting During Construction Activities
These comments are outside of the evaluation criteria established in N.C.
Administrative Codes for the 401 WQC and Jordan Lake Buffer Authorization Certificate
review and should be directed to FERC.

General Comments on Inspections & Compliance
Several commenters raised concerns about DEQ’s ability to adequately inspect the
pipeline construction activities given recent annual funding cuts to the agency.
Response to Comments on Inspections & Compliance During Construction Activities
DWR enforces all the authorizations it issues to the best of its ability.

General Comments on Floodplain Impacts
Multiple comments received expressed concerns over construction of the pipeline
within, and parallel to, the floodplain of the Haw River.
Response to Floodplain Impacts During Construction Activities
Floodplain impacts are subject to the FEMA Floodplain Development Permitting
program implemented at the local government level. These comments are outside of
the evaluation criteria established in N.C. Administrative Codes for the 401 WQC and
Jordan Lake Buffer Authorization Certificate review and should be directed to either the
County Planning Department or the North Carolina Floodplain Mapping Program.

General Comments on Stream Crossing & Impacts
Several comments were received that trenching through streams and wetlands will
have a negative effect on stream stability and threaten wildlife.
Response to Comments on Stream Crossings & Impacts During Construction Activities
The applicant has provided construction plans which desc ribe in detail all steps and
measures to be employed to protect downstream water quality during trenching
activities. All areas will be dewater ed during construction and immediately restored
upon completion. In addition, the application indicates that tr enching activities in
streams and wetlands will not take place during wet conditions, or predicted wet
conditions and will be delayed until adjacent upland trenching is complete. This will
limit the time necessary for trenching activities and reduce risk to downstream waters.
The applicant has submitted stream, buffer, and wetland restoration plans indicating
that all disturbed areas will be restored upon completion and monitored for success. I
8

recommend these requirements be incorporated into a 401 certification, should one be
issued.

General Comments on Impacts to Stoney Creek Reservoir
The City of Burlington expressed concerns about water quality impacts
(turbidity/sedimentation) to the Stoney Creek Reservoir from construction activities
within the watershed. Many commenters specifically cited the already degraded
condition of the Haw River and the direct adjacency of a significant portion of the
proposed pipeline corridor.
Response to Comments on Impacts to Stoney Creek Reservoir During Construction
Activities
MVP is required to secure and comply with detailed Erosion and Sediment Control Plan
Approval issued through DEMLR. In addition, MVP has committed to the additional
high quality erosion and sediment control measures throughout the length of the
entire project. MVP stated that the following additional measures would be utilized
throughout the project:

• Use of compost filter socks around all wetlands to minimize ground
disturbance; and use of super silt fence in areas where higher sediment loading
could occur;
• Compliance with additional parameters for high quality watersheds as
described in Sections C3 and C4 of the NCG010000 Construction Stormwater
General Permit; and
• Enhancing temporary stabilization requirements by standardizing timeframes to
seven days across the project footprint.
In addition to the enhanced sediment and erosion control commitments for the Stoney
Creek Reservoir, MVP has also committed to:
• A dedicated environmental inspector , during construction of the pipeline, for
the entire Stoney Creek Reservoir Watershed.
Finally, in keeping with the need to ensure maximum protection for the Stoney Creek
Reservoir, I am recommending the following condition be added to the 401 WQC that:
• No more than 20 acres are to be cleared and grubbed at one time for the entire
Stoney Creek Reservoir watershed.

9

General Comments on Epoxy Coating
A few comments received expressed concerns over potential impacts to water quality
and public health from the use of epoxy coating.
Response to Epoxy Coating During Construction Activities
According to information supplied by FERC and the application, we believe there will be
no anticipated impacts to surface or ground waters from the use of the proposed epoxy
coating.

Miscellaneous Comments
General Comments
Multiple comments received expressed concerns about the project’s impacts to
recreation and associated economic benefits within and adjacent to the Haw River
Response to Cultural & Community Impacts
These comments are outside of the evaluation criteria established in N.C.
Administrative Codes for the 401 WQC and Jordan Lake Buffer Authorization Certificate
review and should be directed to FERC.

Reliance on Construction of the Mainline Pipeline in Virginia
General Comments
Multiple commenters expressed concern about issuing an approval for a project that is
dependent on finalization of the mainline MVP project which has several of its
necessary federal permits under supension and litigation, and is currently under a stop
wor k order for the entire project.
Response to Reliance on Construction of the Mainline Pipeline through Virginia
See the discussion later in this report regarding DWR’s require ment to consider
practical alternatives.

Degradation of Ground and Surface waters
General Comments
The majority of comments received raised concerns over the degradation of ground
and surface waters as a result of the construction and operation of the pipeline . Many
commenters mentioned the large number of str eams and wetlands that would be
crossed by the pipeline and raised concerns regarding the violations issued by Virginia
DEQ on the mainline project. They connected these impacts with the degradation of
downstream uses including drinking water supply, aquatic life, primary and secondary
contact recreation, and fisheries. Some comments were made regarding potential
impacts to drinking water wells. A significant level of concern was present among the
commenters about impacts to wells from constr uction activities (mainly blasting
10

activities) and operation of the pipeline.
Response to Degradation of Ground and Surface Waters
The application has been thoroughly reviewed to ensure that all water quality
standards are protected. The application includes a drinking water well identification,
monitoring and complaint resolution plan to specifically address concerns regarding
adjacent residential wells.
To ensure effective compliance on such a large and complex project, it is recommended
that a requirement for monthly compliance inspection be included as condition of the
401 WQC. The condition should allow for flexibility of the DWR staff to determine the
nature, extent, and mode (e.g. given issues with COVID a field investigation may not
always be the best oversight methodology) of the compliance review.

IV. Recommendations
Based on the review of public comments, the application and additional information and
revisions to the application, the North Carolina General Statutes and Administrative
Code, and discussions with DWR staff, I offer the following comments and
recommendations on the criteria for issuance of a 401 WQC pursuant to 15A NCAC 02H
.0506(b) and the issuance of Jordan Lake Buffer Authorization Certificate pursuant to
15A NCAC 02B .0267.

Recommendations Related to 15A NCAC 02H .0506
(1) Has no practical alternative under the criteria outlined in Paragraph (f) of this
Rule.
Paragraph (f) states: “A lack of practical alternatives may be shown by
demonstrating that, considering the potential for a reduction in size,
configuration or density of the proposed activity and all alternative designs the
basic project purpose cannot be practically accomplished in a manner which
would avoid or result in less adverse impact to surface waters or wetlands.”
The project proposes to construct a pipeline to transport natural gas from Virginia into
Alamance County, North Carolina. The North Ca rolina portion of the proposed route
will be constructed through Rockingham and Alamance Counties. As part of the Federal
Energy Regulatory Commission (FERC) National Environmental Policy Act (NEPA)
analysis, MVP investigated several alternatives to meet the purpose and need of the
project including a no build alternative, an alternative energy alternative, an energy
conservation alternative, and system alternatives. Of these alternatives, FERC and MVP
found that the build alternative best met the purpose and need of the project.
Next, MVP conducted an extensive alternatives analysis on potential route locations,
including co-location of the MVP Southgate pipeline with existing Duke Power ROW.
Ultimately, MVP chose the current proposed route as the best option based on the
evaluation of a variety of criteria such as project length and impacts to human and
natural resources. Any large linear project will result in significant impacts to a
11

multitude of resources and concerns. Finding a balance among the variety of human
and natural resources such as public lands, roads, conservation easements, forested
lands, streams and wetlands, known historical and cultural resources, riparian buffers,
homes, and businesses is a difficult task. Analysis for this project included pre - and
post-application communication within DWR, the NC Wildlife Resources Commission
(NCWRC) as well as various local and federal agencies on avoidance and minimization
opportunities. MVP continued to refine the avoidance and minimization practices in
response to additional information requests from DWR and through environmental
commitments. A more detailed discussion of avoidance and minimization can be found
below.

Recommendation:
The recommendation presented in this section is based on the following facts:
A) Review of 15A NCAC .02H .0506 (b) states,
“The Director shall issue a certification upon determining that existing uses are not
removed or degraded by a discharge to classified surface waters for an activity which:
(1) has no practical alternative under the criteria outlined in Paragraph (f) of this Rule;”
B) 15A NCAC .02H .0506 (f) states,
‘(f) A lack of practical alternatives may be shown by demonstrating that, considering
the potential for a reduction in size, configuration or density of the proposed activity
and all alternative designs the basic project purpose cannot be practically accomplished
in a manner which would avoid or result in less adverse impact to surface waters or
wetlands.’
C) The Certificate of Necessity issued by FERC on June 18, 2020 stated that
construction of the MVP Southgate Project shall not begin until MVP “receives
the necessary federal permits for the Mainline System and the Director of the
Office of Energy Projects, or the Director’s designee, lifts the stop-work order
and authorizes Mountain Valley to continue constructing the Mainline System.”
For a 401 Water Quality Certification to be issued, the applicant must demonstrate that
no practical alternative exists per the definition given in 15A NCAC .0H .0506 (f). In the
absence of the MVP Mainline pipeline ’s completion in Virginia, the MVP Southgate
project has no independent utility. In essence , it would be a pipeline from nowhere to
nowhere incapable of carrying any natural gas, and certainly not able to fulfill its basic
project purpose , while having no pr actical alternative . As such, prior to incurring any
impacts to North Carolina natural resources, and to ensure that the maximum
avoidance and minimization of impacts to North Carolina water and buffer resources
occurs, a level of certainty regarding the completion of the MVP Mainline pipeline is
required.

12

The MVP mainline project is curre ntly under a stop work order and multiple lawsuits. The
stated overall purpose of the MVP Southgate Project is “to provide a timely, efficient,
and cost-effective means of transporting natural gas from the existing terminus of the
Mountain Valley Pipeline in Pittsylvania County, Virginia to the T -15 Dan River
Interconnect in Rockingham County and then on to the T-21 Haw River Interconnect in
Alamance County, North Carolina, so that the natural gas may be distributed to local
and regional end users via those interconnects”.
Therefore, to ensure that a prac tical alternative that fulfills the basic project purpose can
be achieved, that all appropriate avoidance and minimization can occur, and the
protection of water quality standards and their designated uses are preserved, I am
recommending two possible options. Either option solves the previously stated problem
of an incomplete or unfinished project, in Virginia (the MVP mainline project) causing
unnecessary impacts to North Carolina resources. Thus, to ensure the proper protection
of water quality standards and ensure that all necessary avoidance and minimization of
impacts has occurred the following two options are presented:
Option 1: It is recommended that a condition be included in the 401 Water Quality
Certification that construction of the MVP Southgate pipeline (and its corresponding
impacts) cannot occur until all legal ambiguities presently surrounding the mainline
pipeline have be en resolved, and all necessary permits and authorizations have been
obtained.
Option 2: It is recommended that the 401 Water Quality Certification be denied.
Both options will be included in the summary of recommendations.

(2) Will minimize adverse impacts to the surface waters based on consideration of
existing topography, vegetation, fish and wildlife resources, and hydrological
conditions under the criteria outlined in Paragraph (g) of this Rule.
Paragraph (g) states: “Minimization of impacts may be demonstrated by showing
that the surface waters or wetlands are able to continue to support the existing
uses after project completion, or that the impacts are required due to:
(1) The spatial and dimensional requirements of the project; or
(2) The location of any existing structural or natural features that may dictate
the placement or configuration of the proposed project; or
(3) The purpose of the project and how the purpose relates to placement,
configuration or density.
MVP has minimized impacts to surface waters and wetlands to the greatest extent
practical. There are no permanent impacts proposed to streams and wetlands.
Crossings of the Dan River , an adjacent unnamed tributary to the Dan River, and Stoney
Creek Reservoir wi ll be conducted using horizontal directional drilling (HDD) to avoid
open trenching . Five additional streams will be crossed using Conventional Boring
methods to avoid sensitive aquatic ecosystems, and 26 additional streams will be
crossed using Conventional Boring methods to comply with the Jordan Lake Buffer
Rules. The magnitude of the temporary impacts is significant considering the size and
scope of the project, and consistent with other large linear projects constructed
13

throughout the state. The project design demonstrated minimization by proposing a
narrower construction corridor when crossing wetlands, streams and buffered areas.
Temporary impacts to streambanks, protected riparian buffers, and wetland areas will
be restored to the original contours and revegetated with native plants in accordance
with a restoration plan submitted on May 14, 2020. MVP will monitor any temporary
impact areas in wetlands to ensure there is no permanent loss at these locations. The
monitoring plan will include monitoring for a minimum three years for wetlands with
stability, vegetation, and hydrology requirements. Upon successful completion of the
restoration and monitoring activities, the streams, buffers, and wetland impact areas
will continue to support existing uses of hydrology, vegetation, and aquatic and wildlife
habitat.
The applicant has committed to several best management practices to avoid and
minimize impacts to streams and wetlands.
• Demarcation of wetland boundaries with flagging and signs prior to start of
construction
• Use of temporary work bridges, matting and pads to reduce the risk of soil
compaction
• Trench backfilling using native material to prevent soil contamination and to
accelerate revegetation
• Limiting operation of construction equipment in wetlands to only that necessary
for clearing, excavation, pipe installation, backfilling, and restoration
• Installing trench breakers or plugs at the boundaries of wetlands to prevent
draining of wetlands
• Pump-out activities in the work area will be routed through an energy
dissipation/sediment filtration device prior to discharging to waterbodies
• Use of a project-specific invasive plant species management plan
• Coating for concrete -coated pipe will be conducted at least 100 feet from
surface waters and springs
• Prohibiting use of live concrete as a building material so that wet concrete does
not come in contact with surface waters
• Prohibiting storage of chemicals, fuels, hazardous materials, and lubricating oils
within 100 feet of surface waters
• Use of horizontal directional drilling for two major river crossings
• Use of directional boring for five stream crossings with sensitive aquatic species
• Use of directional boring for 26 stream crossings to comply with Jordan Lake
Buffer Rules
• Use of additional erosion control measures and schedules beyond the minimum
required by the NC Erosion & Sediment Control Planning and Design Manual
• Implementation of a Spill Prevention, Control, and Countermeasure plan and a
Horizontal Directional Drill Drilling Fluid Monitoring, Operations, and
Contingency plan

14

MVP has initiated consultation with US Fish and Wildlife Service (USFWS) on threatened
and endangered species along the corridor. MVP has also coordinated extensively with
the NCWRC. This coordination began with the alternatives analysis, site-specific routing
of the pipeline and crossing methods. MVP worked with resource agencies to avoid
threatened and endangered species and sensitive habitats and to develop survey
protocols for mussels, and crayfish. MVP conducted pre-construction surveys for
mussels and crayfish in streams at the proposed crossing locations. MVP continues to
develop a relocation plan for fish, mussels and crayfish in coordination with the
resource agencies.
Recommendation:
The applicant has sufficiently demonstrated that impacts to surface waters and wetlands
are required due to spatial considerations, natural features and the purpose of the
project. The 401 WQC should require:
1) all the commitments listed above (they are not detailed here again for purposes of
brevity);
2) monitoring of temporary impact areas in accordance with the proposed restoration
and monitoring plan;
3) a reopener condition in the event that temporarily disturbed wetland, stream or
buffer areas do not return to similar pre -construction conditions. The reopener
language should require a modification to the 401 WQC to account for any
additional permanent impacts and mitigation for all permanent stream and/or
wetland impacts, and any permanent buffer impacts in accordance with current
regulations;
4) a condition, consistent with the high quality waters sediment and e rosion control
practices, that allows no more than 20 acres land disturbance (clearing and
grubbing) at any given time , within the Stoney Creek Watershed;
5) a condition that require s the issuance of a final biological opinion prior to incurring
any project impacts;
6) a condition that requires a preconstruction meeting with the permittee prior to
incurring any project impacts.

(3) Does not result in the degradation of groundwaters or surface waters.
The main risk to surface and groundwater from the MVP project will be during
construction activities. These risks include sedimentation and turbidity in surface
waters, breaches of drilling fluids during HDD, and spills of petroleum products and
hydraulic fluids from fueling and equipment maintenance. In addition, some
commenters raised concerns regarding impacts to drinking water wells from trenching
and blasting activities associated with the pipeline installation and from possible
contamination due to pipeline leaks during operation.
The applicant has committed to working in the dry for all stream and wetland crossings.
Proper erosion and sedimentation control measures will be required for the entire
15

project in accordance with an Erosion and Sediment Control Plan Approval from DEMLR .
All temporary fill placed in surface waters related to construction of the pipeline will be
removed once installation of the pipeline is completed at the crossing. The stream
banks or wetlands will be restored to the original contours and revegetated with a
native seed mix to prevent erosion. Only in areas where calculations indicate that
vegetated stabilization is not likely to be successful will hardened stabilization (rip-rap,
geogrid, etc.) techniques be used. No hardening will be placed below the ordinary high-
water mark. Furthermore, the applicant has voluntarily agreed to meet the
requirements of the NPDES Construction Activities General Permit No. NCG010000 and
to utilize additional erosion control measures beyond that required by the NC Erosion &
Sediment Control Planning and Design Manual.
The applicant will store chemicals, fuels, hazardous materials, and lubricating oils and
conduct all equipment and vehicle fueling and maintenance at least 100 feet from
surface waters and 200 feet from private drinking water wells. In situations where
equipment must continue to operate during fueling activities such as dewatering pumps
near surface waters, secondary containment structures will be used to prevent any
spillage from reaching the surface waters.
The applicant will conduct a desktop review and route alignment civil surveying to
identify all known drinking water wells and private water supply springs within 150 feet
of the construction workspaces. The applicant proposes to contact property owners via
certified mail and request permission to conduct pre and post water quantity and water
quality testing of each well prior to construction. Testing will be conducted for a suite of
parameters including pH, specific conductivity, temperature, turbidity, total and fecal
coliform bacteria, total dissolved solids, total suspended solids, hardness, alkalinity,
sulfate, chloride, nitrate (total), bicarbonate, calcium and magnesium, sodium and
potassium, iron and manganese, volatile organic compounds, semi volatile organic
compounds, and total petroleum hydrocarbons as well as well yields. These tests will
provide a baseline of groundwater quality and quantity against which to measure any
construction-related impacts. Should the applicant receive a complaint regarding
damage to well water quality or quantity, the applicant has established a complaint
resolution process which includes proposed restoration remedies.
Operation of the pipeline is not expected to have adverse effects on surface waters and
groundwater. Any post-construction stormwater generated as a result of impervious
surfaces installed during construction are subject to state and local stormwater
requirements. MVP has committed to using sheet flow for new above ground
impervious surfaces constructed in areas with no state or local stormwater programs,
these stormwater management techniques will be protective of water quality and are in
accordance with the diffuse flow requirements of the Jordan Lake Buffer Rule s.
Many commenters raised concerns about leaks from the pipeline impacting
groundwater. The pipeline will be transporting dry natural gas which is not soluble in
water . Liquids contained in the transported gas are removed at a natural gas processing
plant prior to transport and at liquid separators at compressor stations. Any remaining
liquid will be de-minimus and is not likely to impact groundwater.

16

Recommendation:
The project is not expected to violate water quality standards if the certification is issued
and if the conditions in the 401 Water Quality Certification are fully complied with by the
applicant (or its successor). The 401 WQC should also be contingent on the issuance of
an Erosion and Sediment Control Plan Approval issued by DEMLR, Winston-Salem
Regional Office and upon issuance of appropriate state and local stormwater permits.
FERC NEPA and 401 WQC application documentation indicates that the applicant has
agreed to conduct pre-construction water quality testing for drinking water wells within
150 feet of the pipeline construction corridor. The 401 WQC should be conditioned to
require MVP to comply with their proposed Water Resources Identification and Testing
Plan dated August 2019. Should post-construction testing indicate that well water
quality or quantity has been impacted by the construction, MVP should be required to
initiate their complaint resolution process and provide temporary water supplies, and/or
a new water treatment system or well. An independent, qualified groundwater
specialist should determine whether an impact has occurred or not.
The 401 WQC should be conditioned to require monthly ride -through inspections with
appropriate DWR staff to measure compliance with the certification and water quality
standards. The 401 should allow for DWR staff to determine when a specific monthly
inspection is not necessary. For example, an inspection may not be necessary whe n there
has been no recent activities within streams, wetlands, or buffers, or when DWR staff
may have recently conducted an inspection that satisfies the monthly inspection
requirement. Due to the ongoing COVID -19 pandemic, DWR may use another means
othe r than onsite inspections to fulfill this condition. The 401 WQC should also require a
pre -construction meeting with the construction contractors, ACP staff, and DWR staff to
review the conditions and requirements of the 401 certification and permits for clarity
and understanding.

(4) Does not result in cumulative impacts, based upon past or reasonably
anticipated future impacts, that cause or will cause a violation of downstream
water quality standards.
Cumulative impacts are those impacts that would result from the incremental effects of
the project added to other past, present and reasonably foreseeable future activities
(15A NCAC 01C .0103). This includes secondary impacts or impacts from future activities
that occur as a result of the proposed project. The proposed project for the most part
will consist of temporary water quality impacts from the installation of the pipeline.
These impacts could include sedimentation and temporary disturbance of aquatic and
riparian habitat during construction. No permanent impacts will occur in streams or
wetlands from project activities. The impacts will be reduced through avoidance and
mitigation efforts, erosion and sedimentation control and stormwater best
management practices (BMPs), and spill prevention, control, and countermeasure
practices. Any other projects occurring in the same geographic area as the proposed
project will also be subject to local, state, and federal regulations that address stream
and wetland impacts, stormwater management, and watershed protection.
17

In accordance with DWR’s 401 Water Quality Certification Cumulative Impact Policy, the
applicant completed a review and determined that there was no potential for secondary
growth as a result of the proposed project other than from short term temporary
(construction) impacts.

Recommendation:
In accordance with DWR’s 401 Water Quality Certification Cumulative Impact Policy the
project is not expected to result in cumulative impacts that violate water quality
standards, if the conditions in the 401 WQC and the Jordan Lake Buffer Authorization
Certificate are fully impl emented by the applicant (or its successor).

(5) Provides for protection of downstream water quality standards through the use
of on-site stormwater control measures.
Post-construction stormwater is a potential water quality concern. The vast majority of
the proposed pipeline project will not result in new impervious surfaces. However,
some new impervious surfaces are proposed as part of the project. The impervious
surfaces include multiple improved access roads, valve stations, metering and regulating
(M&R) stations, and multiple contractor yards. The access roads are existing unpaved
roads that will be improved to allow construction and maintenance equipment to safely
pass. Improvements will include minor widening and/or surface water crossing
upgrades. The valve sites are needed to segment the pipeline for safety, operation, and
maintenance purposes. The applicant has indicated that stormwater will be managed by
using existing drainage ditches a nd swales for access roads. Stormwater management
for above ground facilities will be managed via sheet flow/diffuse flow across vegetated
areas.
Recommendation:
Session Law 2017-10 prohibits DWR from requiring on-site stormwater management
through a 401 WQC. As discussed above, the 401 WQC should be conditioned to require
compliance with all applicable state and local stormwater permits for construction of a
linear utility line and associated incidental built-upon area.

18

(6) Provides for replacement of existing uses through mitigation.
Both federal and state requirements allow for the purchase of in lieu fee credits to
offset unavoidable impacts to streams and wetlands. DWR requires mitigation [15A
NCAC 02H .0506(h)] at a minimum of a 1:1 ratio for permanent perennial stream
impacts above 300 linear feet and a minimum of a 1:1 ratio for permanent wetland
impacts above one acre. Perennial stream and wetland impacts for this project will not
exceed the respective mitigation thresholds, therefore, no stream or wetland mitigation
is required by DWR. Mitigation is required, however , by the U.S. Army Corps of
Engineers for the wetland conversion impacts. Riparian buffer mitigation is required for
the uses identified in the Table of Uses of the Jordan Lake Buffer Rule [15A NCAC 02B
.0267(9)] as ”ALLOWABLE WITH MITIGATION.” “ALLOWABLE WITH MITIGATION” is
defined in 15A NCAC 02B .0267(10)(c). Buffer mitigation is discussed below in the Buffer
Authorization Certificate section.
Recommendation:
No mitigation is required for stream or wetland impacts as a result of the proposed
project. The 401 WQC should be conditioned to include language requiring mitigation
should the project changes or otherwise result in permanent impacts that exceed
mitigation thresholds.

Recommendations Related to 15A NCAC 02H .0267
(8) DIFFUSE FLOW REQUIREMENT. Diffuse flow of runoff shall be maintained in the
riparian buffer by dispersing concentrated flow and reestablishing vegetation.
As discussed above in Section 5 of the 15A NCAC 02H .0506 discussions, the vast
majority of the proposed project will not result in new impervious surfaces that will
create concentrated stormwater flow. However, there will be improved temporary and
permanent access roads, and valve sites constructed and maintained in the Jordan Lake
Watershed as part of the project. The access roads are existing unpaved roads that will
be improved to allow construction and maintenance equipment to safely pass.
Upgrades will include minor widening and/or surface water crossing upgrades. The
valve sites will consist of gravel pads around above -ground valves with gravel driveways.
Stormwater from these areas will be managed by sheet flow or by using existing
roadside ditches and swales. Sheet flow from the access roads meets the diffuse flow
requirements associated with the Jordan Lake Buffer Rule [15A NCAC 02B .0267(8)].

Recommendation:
The Jordan Lake Buffer Authorization Certificate should include conditions requiring that
diffuse flow conditions be maintained for all stormwater from impervious surfaces
flowing to or within the protected buffers in accordance with the diffuse flow
requirements stated above or other applicable buffer clarification memos.

19

(9) TABLE OF USES.
Utility, non-electric, other than perpendicular crossings:
• In Zone 2 – Allowable
• In Zone 1 – Allowable with Mitigation

Utility, non-electric, perpendicular crossings of streams and other surface
waters:
• Disturb greater than 40 linear feet but equal to or less than 150 linear feet of
riparian buffer with a maintenance corridor greater than 10 feet in width -
Allowable with Mitigation
The proposed project is categorized as a non-electric utility line. The proposed project
includes perpendicular and non-perpendicular crossings of streams and other surface
waters subject to this rule. Due to the width of the maintenance (operational) corridor
of 30 feet, all buffer impacts are in the category of “ALLOWABLE WITH MITIGATION” as
defined in NCAC 02B .0267(9). “ALLOWABLE WITH MITIGATION” uses are defined in
15A NCAC 02B .0267(10)(c).

Recommendation:
None. The proposed project is” ALLOWABLE WITH MITIGATION” under the Table of Uses.

(11) DETERMINATION OF “NO PRACTICAL ALTERNATIVES.” Persons who wish to
undertake uses designated as allowable or allowable with mitigation shall
submit a request for a “no practical alternatives” determination to the local
government (in accordance with .0267(3) the Division shall implement the rules
to the exclusion of the local government). The applicant shall certify that the
criteria identified in Sub-Item (11)(a) of this Rule are met. The Division shall
grant an Authorization Certificate upon a “no practical alternatives”
determination.
The project proposes to construct a pipeline to transport natural gas from Virginia into
Alamance County, North Carolina. The North Carolina portion of the proposed route
will be constructed through Rockingham and Alama nce Counties. As part of the Federal
Energy Regulatory Commission (FERC) National Environmental Policy Act (NEPA)
analysis, MVP investigated several alternatives to meet the purpose and need of the
project including no build, alternative energy, energy c onservation, and system
alternatives. Of these alternatives, FERC and MVP found that the build alternative best
met the purpose and need of the project.
Next, MVP conducted an extensive alternatives analysis on potenti al route locations
including co-loc ation of the MVP Southgate with existing Duke Power ROW. Ultimately,
MVP chose the current proposed route as the best option based on the evaluation of a
variety of criteria such as project length and human and natural resources. MVP
continued to refine the route balancing a variety of human and natural resources such
as public lands, roads, conservation easements, forested lands, streams and wetlands,
known historical and cultural resources, riparian buffers, homes and businesses. This
20

analysis included pre- and post-application communication within DWR, NCWRC , as well
as various local and federal agencies on avoidance and minimization opportunities.
MVP has continued to refine the avoidance and minimization practices in response to
additional information requests from DWR and through environmental commitments.
Recommendation:
Referencing the previous discussion presented in this report, similar logic and application
of the rules for the protection of buffers applies here as well.
15A NCAC 2B .0267(11)(a) states:
…The applicant shall certify that the project meets all the following criteria for finding
"no practical alternatives":
(i) The basic project purpose cannot be practically accomplished in a manner
that would better minimize disturbance, preserve aquatic life and habitat,
and protect water quality;
(ii) The use cannot practically be reduced in size or density, reconfigured or
redesigned to better minimize disturbance, preserve aquatic life and habitat,
and protect water quality; and
(iii) Best management practices shall be used if necessary, to minimize
distur bance, preserve aquatic life and habitat, and protect water quality;

In the absence of the MVP Mainline completion in Virginia, the MVP Southgate project
has no independent utility. In essence , it would be a pipeline from nowhere to nowhere
incapable of c arrying any natural gas, and certainly not able to fulfill its basic project
purpose, while having no practical alternative. As such, prior to incurring any impacts
to North Carolina natural resources, and to ensure that the maximum avoidance and
minimization of impacts to North Carolina water and buffer resources occurs, a level of
certainty regarding the completion of the MVP Mainline pipeline is required.
The MVP Mainline project is currently under a stop work order and multiple lawsuits. The
stated overall purpose of the MVP Southgate Project is “to provide a timely, efficient,
and cost-effective means of transporting natural gas from the existing terminus of the
Mountain Valley Pipeline in Pittsylvania County, Virginia to the T-15 Dan River
Interconnect in Rockingham County and then on to the T -21 Haw River Interconnect in
Alamance County, North Carolina, so that the natural gas may be distributed to local
and regi onal end users via those interconnects”.
Therefore, to ensure that a practical alternative that fulfill s the basic project purpose can
be achieved, that all appropriate avoidance and minimization can occur, and the
protection of water quality standards and their designated uses ar e preserved, I am
recommending two possible options. Either option solves the previously stated problem
of an incomplete , or unfinished project, in Virginia (the MVP mainline project) causing
unnecessary impacts to North Carolina resources. Thus, to ensure the proper protection
of water quality standards and ensure that all necessary avoidance and minimization of
impacts has occurred the following two options are presented.
21

Option 1: it is recommended that a condition be included in the Jordan Lake Buffer
Authorization Certificate that construction of the MVP Southgate pipeline (and its
corresponding impacts) cannot occur until all legal ambiguities presently surrounding
the mainline pipeline have been resolved, and all necessary permits and authorizations
have been obtained.
In addition, if option 1 is chosen, the Jordan Lake Buffer Authorization Certificate should
be conditioned to incorporate the best management practices proposed by the applicant
intended to minimize disturbance, preserve aquatic life and habitat, and protect water
quality. Furthermore, the Jordan Lake Buffer Authorization Certificate should require
demarcation of protected buffer with flagging or signs prior to the initiation of
construction and lim iting operation of construction equipment in buffers to only that
necessary for clearing, excavation, pipe installation, backfilling, and restoration
Option 2: it is recommended that the Jordan Lake Buffer Authorization Certificate be
denied.
Both options will be included in the summary of recommendations.

(13) Mitigation. Persons who wish to undertake uses designated as allowable with
mitigation shall meet the following requirements in order to proceed with their
proposed use:
(a) Obtain a determination of “no practical alternatives” to the proposed use
pursuant to Item (11) of this Rule.
(b) Obtain approval for a mitigation proposal pursuant to 15A NCAC 02B .0268.
15A NCAC 02B .0268 has been repealed and replaced with 15A NCAC 02B .0295.
Due to the fact that the maintenance corridor for the proposed pipeline will have a
width of greater than 10 feet, all of the buffer impacts within the operational
(maintenance) corridor are considered “ALLOWABLE WITH MITIGATION” uses and
subject to the buffer mitigation requirements [15A NCAC 02B .0295]. However, impacts
to wetlands within the buffers are not subject to the buffer mitigation requirements and
are regulated under 15A NCAC 02H .0506(h) as discussed above in section (6) of the 401
WQC application review process. The buffer mitigation totals reflect the removal of
wetland areas within the buffer.
The applicant has proposed to achieve buffer mi tigation through the purchase of credits
from the approved Motes Creek Mitigation Bank. A letter addressed to the applicant
from the Bank provider, Restoration Systems dated April 16, 2020 states that the Motes
Creek Mitigation Bank has sufficient riparian buffer credits to satisfy the required buffer
mitigation credits for the proposed project.

22

Recommendation:
The Jordan Lake Buffer Authorization Certificate should include conditions requiring
buffer mitigation in accordance with the table below:
Compensatory Mitigation
Amount Required
River &
Sub-basin Number (HUC)
Buffers 244,623.44 (square feet) Jordan – Haw River Subwatershed
03020102

V. Summary
Public comments received during the public hearing and public notice comment period
focused on several major areas, including the degradation of water quality, cumulative
impacts, environmental justice, sedimentation and erosion control, the permitting
process, and ground and surface water supply protection. Due to the number of public
comments, many of which expressed concerns on the same issues, each comment is not
addressed individually. Rather, the comments were categorized into major subject
areas where responses and recommendations could be presented in a coherent
manner. A detailed compilation of all the comments received is presented in Appendix
E. Only comments that have direct relevance to the 401 Water Quality Certification and
Jordan Lake Buff er Authorization Certificate decisions have been addressed in the
recommendations (Section IV).
As stated above, a thorough review of all public comments received, and the project
record has been conducted and evaluated in context of all pertinent statutes and
regulations governing the review of 401 Water Quality Certifications and Jordan Lake
Buffer Authorization Certificates. Based on all of this information, it is my
recommendation that the 401 Water Quality Certification and Jordan Lake Buffer
Authorization Certificate be issued and subject to the conditions included in the
recommendations in Section IV and summarized in below in Section V. It is further
recommended that DWR include any additional conditions necessary to ensure that the
project will meet state water quality standards.

Summary of Recommendations
Monthly Compliance Drive Through – To ensure effective compliance on such a large
and complex project, it is recommended that a requirement for monthly compliance
drive through be included as condition of the 401 WQC. The condition should allow for
flexibility of the DWR staff to determine the nature, extent, and mode (i.e . given issues
with COVID -19 a field investigation may not always be the best oversight methodology)
of the compliance review. In addition, a condition requiring a preconstruction meeting
with DWR should be included.

23

High Quality Sediment & Erosion Control Measures in Stoney Creek Reservoir – A
recommendation requiring specified additional sediment & erosion control measures
for construction occurring in the Stoney Creek Reservoir watershed. The reservoir is the
drinking water supply for the City of Burlington. The City expressed concerns about
construction impacts to the reservoir.
Additional Other Sediment & Erosion Control – A recommendation that specifies all the
sediment & erosion control measures the applicant committed to in their application be
included in the 401 WQC as specific conditions.
No Mainline Project Condition or Denial – A recommendation that that the 401 Water
Quality Certification include a condition requiring the lifting of all the stop work orders
and acquisition of all necessary permits for the MVP mainline project be acquired
before the 401 WQC and the Jordan Lake Buffer Authorization Certificate is valid. Or,
an alternative recommendation that the 401 WQC and the Jordan Lake Buffer
Authorization Certificate be denied.
Acquire All Other Necessary Permits for MVP Southgate – A recommendation that the
that the 401 WQC and Jordan Lake Buffer Authorization Certificate include the standard
condition requiring the applicant to acquire all other environmental permits and
authorizations prior to incurring any impacts to any jurisdictional waters and buffers.
Other Recommendations – A recommendation that the 401 WQC include conditions
that require the applicant to comply with:
1) all the commitments listed in their application and detailed in this report (they
are not detailed here again for purposes of brevity);
2) monitoring of temporary impact areas in accordance with the proposed
restoration and monitoring plan;
3) a reopener condition in the event that temporarily disturbed wetland, stream or
buffer areas do not return to similar pre -construction conditions;
4) a condition, consistent with the high quality waters sediment and erosion control
practices, that allows no more than 20 acres land disturbance (clearing and
grubbing) at any given time, within the Stoney Creek Watershed;
5) a condition that requires the issuance of a final biological opinion prior to
incurring any project impacts;
6) a condition that requires a preconstruction meeting with the permittee prior to
incurring any project impacts.
Well testing during construction – A recommendation that the 401 WQC include a
condition that requires the applicant follow their Water Resources Identification and
Testing Plan dated August 2019.
Mitigation for Permanent Impacts to Wetlands or Streams – A recommendation for the
standard condition that requires any permanent impacts to wetlands and streams in
excess of the regulated thresholds require mitigation.

24

Mitigation and Diffuse Flow for Buffer Impacts – A recommendation that all the buffer
impacts, that meet the definition of “Allowable with Mitigation”, have the requisite
mitigation requirement, and all the diffuse stormwater flow requirements in 15A NCAC
2B .0267 be met.
Acquire Biological Opinion – A recommendation that the biological opinion be finalized
prior to any impacts being incurred.
VI. Appendices (available on Laserfiche)
A. Rules applicable to Project pursuant to application received date
Laserfiche Folder Name: Rules applicable to project
Laserfiche link:
https://edocs.deq.nc.gov/WaterResources/Browse.aspx?id=1257843&dbid=0&repo
=WaterResources
B. August 13, 2919 401 Water Quality Certification Application
Laserfiche Folder Name: Application 8-14-2019
Laserfiche link:
https://edocs.deq.nc.gov/WaterResources/Browse.aspx?id=957735&dbid=0&repo=
WaterResources
C. Notice of Public Hearing
Laserfiche Filename: 20181638 Ver 3_Public Notice_20191018
Laserfiche link:
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?id=1007542&dbid=0&rep
o=WaterResources

D. Public Hearing Speaker and Non-Speaker Sign In sheets
Laserfiche Filename: 20181638 Ver 3_Hearing Signin Sheets_20191119
Laserfiche link:
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?id=1032000&dbid=0&rep
o=WaterResources
E. Public Hearing transcript, including oral comments
Laserfiche Filename: 20181638 Ver 3_Public Hearing Audio Transcript_20191119
Laserfiche link:
https://edocs.deq.nc.gov/WaterResources/DocView.aspx?id=1042003&dbid=0&rep
o=WaterResources
F. Written comments received during the comment period, including at the public
hearings
Laserfiche Folder Name: Public Comments Received
Laserfiche link:
https://edocs.deq.nc.gov/WaterResources/Browse.aspx?id=1023871&dbid=0&repo
=WaterResources