19910326 Ver 1_More Info Received_19940718

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North Carolina Department of Commerce
James B. fiunt Jr., Governor
July 18, 1994
Secretary
Federal Energy Regulatory Commission
825 North Capitol Street, NE
Washington, DC 20426
S. Davis Phillips, Secretary
Subject: Comments On The Gaston Pipeline Scoping Hearing
Dear Secretary:
These are the written comments completing the North Carolina
Department of Commerce review of the Final Environmental. Assessment
(FEA).
With respect to the FEA and the pipeline project in general,
this action is unprecedented in this river basin. Therefore, it is
imperative that the studies used be thorough, recent, and complete.
Most of the available studies and much of the available information
do not meet all of these requirements..
Throughout the FEA, the studies do not contain sufficient detail to
provide the level of review that is required, Conclusions appear
to have been made based on misting information, without regard to
the completeness of the information, the age of the information, or
the fact that there is considerable disparity in the data. The
studies model areas of concern which can be difficult to quantify
and can yield significantly different results depending upon the
assumptions used. Particularly with respect to industrial and
economic development, and socioeconomic issues in the Lower Roanoke
River Basin, this has biased several of the findings. One example
is the finding that industrial growth will not, be impacted. This
growth is directly proportional to the dater quality and treatment
standards in the future. The studies do not address this and the
findings ignore it.
The FEA does not adequately address the alternatives, in that it
does not explain' why Virginia Beach's planning process has allowed
it to be in. an interbasin transfer situation. The FBA also does
not account for what Virginia Beach-will do after this allocation
is no longer sufficient. The FEA should explain what Virginia
Beach has done in the way of planning for this demand, and what 'the
future plans are.
Business Industry Development Division - George Watts Carr, III, Director , C
430 North Salisbury Street, Raleigh, Forth Carolina 27611 - Tel: [phone]- Fax: [phone] +
An Equal Opportunity; AffirmativaAction Employer
Secretary
July 18, 1994
Page Two
In the Project Economics
Assessment, Virginia Beach
for lost generation. There
Virginia Beach is gQinc- to
basin for takin; this wate
effects and the associated
review of the Final Environmental
is proposing to reimburse Virginia. Power
should.be review of what re.imhursements
make to the municipalities in the lower
r and for any detrimental environmental
costs for loss of economic growth.
Sincerely,
Paul A. ordan
Environmental Consultant