20140957 Ver 2_ACP 401 Permit Comments (2)_20170819

Strickland, Bev
From:Jeannie Ambrose <[e-mail]>
Sent:Saturday, August 19, 2017 4:37 PM
To:SVC_DENR.publiccomments
Subject:ACP 401 Permit Comments
Attachments:2017-AUG 19-JA ACP 401 Permit Public Comments.docx
Thank you for the opportunity to send in comments.
Jeannie Ambrose
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Reasons for DEQ to Deny the 401 permit for the Atlantic Coastal Pipeline:
Economic Benefits for Some but Not for the Betterment of All

Pipeline developers and supporters claim that the ACP is needed to serve growing
energy needs and will reduce energy costs in the region. However, when the demand for
gas-fired power is left out, these claims are incorrect. Energy forecasts indicate electricity
demand will remain relatively flat through 2030. NC allows companies to pass on
construction cost to its consumers. Therefore, the recovery cost for building the $5 billion
pipeline project will fall upon the utility ratepayers. In June of 2017, Duke Energy filed a
request for one of the largest electric rate hikes for residential customers (16.9%) in NC. In
addition, Dominion and Duke Energy and shareholders benefit from a guaranteed 14% rate
of return from the federal government for their investments.

According to an independent energy study, the ACP is not needed. The report states
that NC’s peak demands can be met with gas storage facilities and investments made to
modify and upgrade the existing pipeline system (i.e., Transco). Additionally, energy costs
could go up if the ACP pipeline is underutilized. Only the urban areas of Rocky Mount,
Wilson, and Fayetteville could potentially afford the high price of tapping into the ACP.
Prospective commercial and residential users in rural areas will not benefit since they lack
financial resources to gain access to the pipeline. More problematic on the national scale is
that some people think that new gas-fired power plants and its associated infrastructure are
being overbuilt near areas where fracking production may actually decline.

Fracked gas that is transported to fuel power plants contributes to release of
methane emissions driving climate change. A comprehensive scientific study published in
July of 2017 found that economic impacts from climate change differ across regions of the
U.S. The maps show that economic losses will be greatest in the South. Although climate
change damage is estimated to be worse outside the U.S., these economic losses would affect
the U.S. economy indirectly. Switching to an economy that supports the sustainable, clean
energy sector and protects the environment for future generations would seem to be the
more responsible and moral choice.

It is true that job numbers are greatest during pipeline construction but these are
temporary positions. Less than 20 jobs will be permanent. Whereas, job creation in the
renewable energy sector has been growing in NC. The State is already a leader for solar
capacity and construction in the South. Making the transition away from fossil fuel
dependence to a renewable energy mix would help us become more energy secure. We can’t
lose if we move forward, away from the many problems associated with fossil fuel
production and usage, and toward bringing even more renewables online. Conservation and
development of renewable energy together can reduce our need for fossil fuels and,
thereby, lessen the consequences of climate change due to greenhouse gas emissions. Some
sage once said that it is better to be green than greedy.

Below is a list of my concerns. (There is overlap among the sections.)

15A NCAC 02H .0506 9(b) and (f)

Sections 1.A and C. Impact to Wetlands and Streams:

• No mitigation plan for 600 acres of cleared forested wetlands. The risk for long-
term damage is greater with more intensive human disturbances. “About two-thirds

of NC’s rare, threatened and endangered species of plants and animals live in
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wetlands.”
• No monitoring or assessment plan to report restoration, if any, of valuable
ecosystem services of wetlands and forests during the regrowth period of 30 or
more years. In some cases, these changes will be permanent. Compensation for the
full range of losses and damages cannot accurately be determined unless a
preliminary ecosystem service assessment is conducted.

In April of this year scientists developed a method to quantify the economic
value of biodiversity based on carbon storage performance specific for each species
added to a degraded habitat. Understanding the value of biodiversity is a departure
from studies that estimate value by focusing on habitat loss. In any case, the true
value of biodiversity may be underestimated since carbon storage is only one of the
many services that biodiversity provides.

• 75-ft. R-O-W clearings and 150-ft. wide corridors along the 186-mile length of the
pipeline route fragment wetlands and forests. These clearings adversely alter
conditions suitable for maintaining wildlife habitats for a diverse of wetland and
forest populations, including state and federally protected, threatened and
endangered plant and animal species. Fragmentation can limit the migration of
amphibians and create edges for invasive plants to spread. Deforested areas are
converted to herbaceous cover that must be maintained to prevent root damage to
pipelines and to provide access for maintenance. Compaction can affect the normal
hydrological flow patterns, changing shallow aquifer recharge, surface water
drainage, groundwater discharge to wetlands and streams, and allow infiltration of
toxic substances.

N.B. “Swift Creek Subdivision in particular has been identified as possibly the
most significant lotic creek ecosystem remaining along the Atlantic Seaboard.”
Freshwater mussels, listed as rare, State threatened or species of concern, are all
filter-feeding organisms and, therefore, are extremely vulnerable to habitat changes
that affect water quality and hydrology due to sedimentation or toxic pollutants.
“The Carolina madtom and Neuse River waterdog are endemic to NC, known from
only the Neuse and Tar River drainage.” Many important species of note are found
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as well.
• 8-foot deep trenching for installation of pipeline change conductivity through
compacted soils, blocking natural flow or act as conduit for pollutants to enter
wetlands and streams more easily.
• Loss of nearly 28 acres of forests and riparian buffer along 7 miles of streams
crossed.

Section III. Erosion, Sedimentation, and Turbidity:

• Have the ACP developers submitted a Sedimentation and Erosion Plan to DEQ?
BMP in erodible soils may be inadequate. Swamps and marshes line the rivers that
flow downstream of the Fall Line through the soft, eroded sediments in the Coastal

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Diemer, Dr. John A. and Dr. Andy R. Bobyarchick, Coastal Plain, http://www.ncpedia.org/geography/region/coastal-
plain/ncatlasrevisited
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The Upper Tar River Basin: Swift Creek and Fishing Creek Subbasins,
http://www.ncwildlife.org/Portals/0/Learning/documents/Species/img_7b1c_forestmemo2.pdf

Plain. Land, east of U.S. 95, would still be mostly wetlands if ditching had not been
allowed to drain them decades ago.
• Detailed procedures for refueling and lubrication of equipment are not available
for evaluating protective measures that would be used. Handling of toxic or
hazardous materials must not be allowed within 500’ of wetlands, private and
public water supply wells. Testing of nearby private wells should be required if
violations occur.
• Inadvertent returns of drilling fluids from horizontal directional drilling for
pipeline installation could occur beneath six major rivers and 34 water bodies in
total. Authority is needed to enforce stop action until area is cleared. (Ohio EPA’s
Emergency Response program averages “about 1200 emergency responses per year
to incidents where sudden releases of hazardous materials, petroleum and/or other
pollutants have occurred, posing a threat to human health and the environment.”)

Section V. Cumulative, Direct and Indirect Impacts on Water Quality:

• A Princeton University study showed that clear cutting in hardwood forests
increased nitrate concentrations, from a 2- to 50-fold range, in stream water. Other studies
found that removing vegetation allows Nitrobacter bacteria to rapidly convert ammonium
into nitrates and after clear cutting Nitrobacter bacteria numbers increase 34 fold.
Increased nitrate levels adversely impact the health of aquatic life and terrestrial ecosystem
and human health through water consumption.
• Identify withdrawal locations for millions of gallons of water from the Roanoke,
Cape Fear and Neuse rivers for uses such as hydrostatic testing and dust control.
Discharge volumes and location into a receiving basin should be reported also.
• Sedimentation, turbidity and decreased DO problems due to site clearing activities
and accidents would negatively affect aquatic life and fisheries downstream.
• Near the ACP route are one Superfund site and three brownfield sites. These areas
must be well marked to avoid accidental disturbance by construction workers.

Written Public Comments VIA Email
August 19, 2017

Jeannie Ambrose
675 Lichen trail
Pittsboro, NC 2731