20140957 Ver 2_No to the ACP_20170814

Strickland, Bev
From:MARTHA W GIROLAMI <[e-mail]>
Sent:Monday, August 14, 2017 7:31 PM
To:SVC_DENR.publiccomments
Subject:No to the ACP
This is comment 1 against the ACP.

Atlantic Coast Pipeline (ACP) Comments on 401 Certification in North Carolina (NC)

1. The ACP is not needed or justified. DE/Dominion fail to demonstrate need and fail to demonstrate practical alternatives.

North Carolina Department of Environmental Quality (DEQ) must not approve the ACP 401 Certification Permit because the ACP is not needed or
justified. The DE demand for a pipeline permit does not make it their right to construct the ACP or justify it as beneficial for NC’s economy, energy future,
environment, waters, water quality, health and climate.

If Duke Energy supported renewables in NC, we, the ratepayers, would have cheap solar and wind today. But DE can not extract profits up to 14% on
renewable projects. These huge profits from construction of gas infrastructure, have corrupted the judgment and values of DE and FERC and Dominion and
banks and all vested interests in a US fossil fuel energy economy.

The Federal Energy Resource Commission (FERC) Final Environmental Impact Statement (FEIS) does not consider whether the ACP is needed. FERC did
not consider the alternative to this fossil fuel infrastructure. The Public has not be given the opportunity to consider the NO ACTION alternative to the
ACP. “Alternatives” is the heart of any Environmental Impact Statement (EIS). The alternative that has not been given any hearing at all is Renewable
energies.

The fatal flaws in DE’s plan of methane dominated business plan are as follows:
1. The energy forecast is flat until 2030. Energy efficiency and renewable energy
are reducing demand for more electricity despite population growth in NC.
2. Soon there will be surplus pipelines to transport Marcellus frack gas in all
directions away from frack states. This means that the ACP will be underutilized and have steep competition. There will be fierce competition with the
Transco pipeline in western NC which already supplies NC with more gas than it needs.
3. The Marcellus shale gas production is not able to keep up with new online pipeline capacity. But, more importantly, new Marcellus gas wells lose
productivity rapidly. The best
sweet spots have been fracked already leaving less productive shale to be drilled. These newer
low producing wells are costly to drillers. There is a constant upward pressure on gas price to keep drillers in business.
4. The promise of renewables for residential and commercial electricity and transportation electricity as well as energy efficiency programs will
revolutionize the energy landscape. Renewable energies will only get cheaper and cheaper rapidly. DE will have the ACP and gas plants that are stranded
assets—as the market for their gas continues to shrink.

https://www.southernenvironment.org/uploads/words_docs/2016_09_12_Synapse_Report_-_Are_the_ACP_and_MVP_Necessary__FINAL.PDF

This study proposes a path for NC and our nation to become energy efficient and use renewable energies. The Title is NC Clean Path 2025
http://www.ncwarn.org/wp-content/uploads/NC-CLEAN-PATH-2025-FINAL-8-9-17.pdf
1