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Home My WebLink About20140957 Ver 2_Comments on Atlantic Coast Pipeline #401 certification_20170818 Strickland, Bev From:john.williams3@comcast.net Sent:Friday, August 18, 2017 11:54 AM To:SVC_DENR.publiccomments Subject:Comments on Atlantic Coast Pipeline #401 certification Attachments:acp401NComwritten.docx Dear Sir/Ms: Preferred Alternatives offers the attached comments regarding the above cited certification. Yours, John Williams 1 PREFERREDE ALTERNATIVES 19815 NW Nestucca DR. Portland, OR 97229 503—439-9028 John.williams3@comcast.net By e-mail to PublicComments@ncdenr.gov. I am John Paul Williams, director of Preferred Alternatives, a non-profit group that comments on energy projects such as pipelines. PA has supporters near this pipeline’s route in North Carolina. I am an environmental consultant who has reviewed large industrial projects throughout the United States, including pipelines, for over 30 years. I believe that this pipeline can be constructed and operated with only temporary and relatively insignificant direct impacts on North Carolina water Quality. In fact, the indirect impacts of providing additional economical supplies of natural gas to North Carolina will cause closure of additional coal fired power plants. The closure of those plants and their dangerous coal ash lagoons will enormously benefit North Carolina’s water quality. The Federal Energy Regulatory Commission and the Army Corps of Engineers will also implement their own measures to protect North Carolina’s water quality. FERC prepared a draft environmental impact statement on this project. It provides an encyclopedic discussion of the pipeline’s potential impacts and the requirements to reduce and eliminate those impacts, category by category. The potential to affect water quality is greatest during the pipeline’s excavation, yet that is as temporary and localized impact. I’d like to summarize some of the key mitigation requirements set forth in the Draft EIS. Those requirements provide a good starting point, to which North Carolina can add additional measures as needed. I’ve referenced relevant page numbers in the DEIS that deswcribe these protective features. IMPACTS ON WATER WELLS AND SPRINGS FERC is requiring the developer to test all water wells and springs near the pipeline route before construction, to provide baseline water quality. If folks think the project damaged their wells, additional testing will show it, and the developers will provide a new water supply system. (4-82,3) SPRINGS There are seven springs near the pipeline route in North Carolina, but only one stream is downgradient of the project. Any impacts on groundwater would be temporary and limited, because the project’s excavation will be less than 10 feet deep, and the contractor will install erosion controls and revegetate the right of way with native plantings. SURFACE WATERS While the project will cross watersheds that provide water supplies, there are no surface water intakes downstream that are near the project. (4-98,9) If the project’s construction will cause temporary impacts. FERC will impose time-of-year restrictions on work in and near surface water bodies to project sensitive aquatic life. Reclamation in and nearer surface waters will include stream bank stabilization, restoration of the original contours and revegetation with native materials including trees. (4-101) Potential impacts will be reduced by usage of dry crossing methods which isolate the pipe trench from flowing water. Most of the sites utilizing horizontal directional drilling (HDD) have suitable geology, and in any event FERC requires focused monitoring of potentially affected seeps and springs while HDD is underway. (4-103) The project will require water withdrawals, however those withdrawals will be short-term and FERC will impose time-of-year restrictions on the withdrawals. (4-111) WETLANDS The project’s construction will degrade some wetlands and convert some wetland types because of tree removal. Some wetlands will recover within 1-2 years after post-construction reclamation, recontouring, and replanting. FERC has several requirements that will reduce those impacts, including a much smaller right of way within wetlands. (4-123) Most importantly, FERC will require compensation for permanently degraded wetlands in the form of a mitigation agreement. These agreements typically require developers to restore and/or preserve nearby wetlands of a much greater area than the area of wetlands that were degraded. Fortunately North Carolina has its own Department of Mitigation Services to assist and monitor this project’s efforts to restore and protect additional wetlands appropriately. HAZARDOUS MATERIALS Hazardous materials such as fuels must be stored in upland areas at least 100 feet from wetlands and water bodies as part of the project’s detailed Spill Prevention and Control Plan. ADDITIONAL PROTECTIVE MEASURES North Carolina can require smaller rights of ways within sensitive area to reduce the areas of initial disturbance. The State can also require limits on the areas undergoing new disturbance in a single day, to insure that only small areas would be subject to erosion from sudden storms before BMPs could be fully implemented. THE PROJECT WILL CAUSE INDIRECT BENEFITS TO NORTH CAROLINA WATER QUALITY. I’d like to present evidence that the proposed pipeline will actually improve Virginia’s water quality. This pipeline is a vital portion of the infrastructure needed to shut down some of the 33 coal fired power plants in Virginia and North Carolina. Every shut-down of a coal fired power plant will cause massive reductions of the air pollution that causes acid rain and degrades water quality in North Carolina. There are over 30 aging, coal-fired power plants in North Carolina and Virginia that could be closed once adequate supplies of economical natural gas are available to replace the coal. Natural gas’s availability has already sped the closure of several coal fired power plants in the region. Other industrial companies such as Celanese in Virginia are converting their coal fired boilers to run on gas since is is readily available at economic prices. Each boiler switched away from coal will reduce acid rain emissions by 1000s of tons. The Federal EPA has stated that power plant effluent is the major contributor of toxic materials into our rivers, so reductions in those effluent discharges will also reduce toxic loading. When coal plants such as Clinch River in Virginia are reengineered to run on gas, their water pollution went down by 5 million gallons a day. Virginia and North Carolina together, emit from their coal power plants, over 100,000 tons per year of air pollution that causes acid rain. If even one coal fired power plant is replaced with a gas-fired unit that will remove tens of thousands of tons of air pollution. And Dominion has indicated it could close three coal and one oil fired powered plant, as part of its Resource Plan that includes substitution of gas-fired power plants for coal. Dominion also stated it is considering generating three times as much new energy with solar power than it will with gas. Duke’s Resource Plan filed with the North Carolina Utility Commission stated it has shut down 1700 MW of coal power plants, including the HF Lee plant in Wayne County, and it will convert the Lee Steam Unit #1 in South Carolina to gas. Duke will need additional gas supplies to replace those and future coal shut-downs. This Pipeline’s operation will deliver gas supplies that will speed the closure plants, causing massive reductions in emissions of gasses that cause acid rain. It will also cause the removal of water pollution sources that discharge billion gallons a day of waste water into North Carolina’s rivers. In summary, North Carolina’s water quality could improve if allowing access to these additional gas supplies will insure that several coal power plants will close as planned.