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Home My WebLink About20140957 Ver 1_02_PCN Supplemental Information NC_CLEAN_20170222-wjh_20170227Atlantic CoastATLANTIC COAST PIPELINE Pipeline. DRAFT Nationwide Permit 12 Pre -Construction Notification — Joint Permit Application U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Environment and Natural Resources, Division of Water Resources Supplemental Information Prepared by February 2017 Atlantic Coast Pipeline Nationwide Permit No. 12 — Pre -Construction Notification — Joint Permit Application U.S. Army Corps of Engineers — Wilmington District TABLE OF CONTENTS APPLICATION SUPPLEMENTAL INFORMATION DESIGN.............................................1 INTRODUCTION..........................................................................................................................1 PROJECT OVERALL SUPPLEMENTAL INFORMATION ON PROPOSED FACILITIES......................................................................................................................3 A. APPLICANT INFORMATION.......................................................................................5 1. Processing: This information is included on the PCN Form.....................................5 2. Project Information.....................................................................................................5 3. Owner Information......................................................................................................5 4. Applicant Information.................................................................................................5 5. Agent/Consultant Information....................................................................................6 B. PROJECT INFORMATION AND PRIOR PROJECT HISTORY .............................6 1. Property Identification................................................................................................6 2. Surface Waters............................................................................................................6 3. Project Description......................................................................................................7 4. Jurisdictional Determinations...................................................................................27 5. Project History..........................................................................................................28 6. Future Project Plans..................................................................................................29 C. PROPOSED IMPACTS INVENTORY.........................................................................29 1. Impacts Summary.....................................................................................................32 2. Wetland Impacts.......................................................................................................32 3. Stream Impacts..........................................................................................................32 4. Open Water Impacts.................................................................................................32 5. Pond or Lake Construction.......................................................................................33 6. Buffer Impacts (for DWQ)........................................................................................33 D. IMPACT JUSTIFICATION AND MITIGATION.......................................................36 1. a.I Avoidance and Minimization..............................................................................36 2. a.2 NEPA Alternatives from FERC Documentation...............................................37 No Action Alternative to the ACP.........................................................................37 Alternative Energy Sources to the ACP.................................................................38 Energy Conservation to the ACP...........................................................................3 8 System Alternatives to the ACP............................................................................39 Conceptual Route Alternatives..............................................................................39 3. b.I Construction Minimization - Wetlands...............................................................74 4. b.2 Construction Minimization - Waterbodies..........................................................77 5. Compensatory Mitigation for Impacts on Waters of the U.S. or Waters of the State...........................................................................................................................81 6. Complete if Using a Mitigation bank........................................................................83 7. Complete if Making a Payment to In -lieu Fee Program...........................................83 8. Complete if Using a Permittee Responsible Mitigation Plan...................................83 9. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWR ....83 Atlantic Coast Pipeline i DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District E. STORMWATER MANAGEMENT AND DIFFUSE FLOW PLAN (REQUIRED BY DWR)..................................................................................................84 1. Diffuse Flow Plan.....................................................................................................84 2. Stormwater Management Plan..................................................................................84 3. Certified Local Government Stormwater Review....................................................84 4. DWQ Stormwater Program Review.........................................................................84 5. DWQ 401 Unit Stormwater Review.........................................................................85 F. SUPPLEMENTARY INFORMATION.........................................................................85 1. Environmental Documentation (DWQ Requirement)..............................................85 2. Violations (DWQ Requirement)...............................................................................85 3. Cumulative Impacts..................................................................................................85 4. Sewage Disposal (DWR Requirement)....................................................................90 5. Endangered Species and Designated Critical Habitat (USACE Requirement) ........90 6. Essential Fish Habitat (USACE Requirement).........................................................94 7. Historic or Prehistoric Cultural Resources (USACE Requirement) .........................94 8. Tribal Coordination...................................................................................................95 9. Flood Zone Designation (USACE Requirement).....................................................96 G. SECTION 408 AUTHORIZATION...............................................................................96 H. REFERENCES .................................................................................................................98 Atlantic Coast Pipeline ii DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District LIST OF JPA TABLES Table 1 Proposed Aboveground Facilities in North Carolina for the Atlantic Coast Johnston County Major Route Alternative for the Atlantic Coast Pipeline ....45 Pipeline............................................................................................................12 Table 2 Permit Table for the Atlantic Coast Pipeline in North Carolina ...................... 28 Table 3 HUC8 Wetland Impacts Table.........................................................................30 Table 4 HUC8 Waterbody Impacts in North Carolina................................................31 Mush Island Route Variation for the Atlantic Coast Pipeline .........................58 Table 5 North Carolina Buffer Impacts........................................................................34 Table 6 Select Route Adjustments Incorporated into the Proposed Atlantic Coast Red Oak Route Variation for the Atlantic Coast Pipeline...............................63 Pipeline in North Carolina...............................................................................72 Table 7 Route Avoidance Locations for Wetlands in North Carolina ..........................73 Swamp Road Route Variations for the Atlantic Coast Pipeline ......................70 Table 8 Federally Listed Species and Species Proposed for Federal Listing within the U.S. Army Corps of Engineers — WilmingtonDistrict...............................92 Table 9 State -listed Endangered and Threatened Species within the U.S. Army Corps of Engineers — Wilmington District......................................................93 LIST OF FERC ALTERNATIVE TABLES Table 10.8.1-1 Table 10.8.1-12 Table 10.8.1-13 Table 10.8.1-14 Table 10.8.1-15 Table 10.9.1-11 Table 10.9.1-12 Table 10.9.1-13 Table 10.9.1-14 Table 10.9.1-15 Table 10.9.1-16 Table 10.9.1-17 Table 10.9.1-18 Table 10.9.1-19 Eastern and Western Route Alternatives for the Atlantic Coast Pipeline ........ 41 Johnston County Major Route Alternative for the Atlantic Coast Pipeline ....45 Progress Energy Carolinas Collocation Major Route Alternative for the Atlantic Coast Pipeline....................................................................................48 Meherrin River Major Route Alternative for the Atlantic Coast Pipeline ....... 51 Northampton Major Route Alternative for the Atlantic Coast Pipeline ..........53 Geenex Route Variation for the Atlantic Coast Pipeline.................................58 Mush Island Route Variation for the Atlantic Coast Pipeline .........................58 Halifax Route Variation for the Atlantic Coast Pipeline.................................60 Breeches Swamp Route Variation for the Atlantic Coast Pipeline..................63 Red Oak Route Variation for the Atlantic Coast Pipeline...............................63 City of Nashville Route Variation for the Atlantic Coast Pipeline..................65 Little River Route Variation for the Atlantic Coast Pipeline ...........................67 Swamp Road Route Variations for the Atlantic Coast Pipeline ......................70 Cape Fear Route Variations for the Atlantic Coast Pipeline ...........................70 Atlantic Coast Pipeline iii DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District LIST OF APPENDICES Appendix A Figures Appendix B Wetland and Waterbody Survey Report Appendix C Wetland and Waterbody Crossing Impact Table Appendix D Supplemental FERC Upland Construction Information Appendix E Right -Of -Way Cross Section Drawings and Select Construction Typical Drawings Appendix F Section 10 Waters Site Specific Plans Appendix G Spill Prevention, Control, and Countermeasures Plan Appendix H Horizontal Directional Drill Fluid Monitoring, Operations, and Contingency Plan Appendix I Agency Correspondence Appendix J Restoration and Rehabilitation Plan Appendix K General, Regional, and Special Permit Conditions Tables Appendix L Cumulative Impacts Analysis - FERC Resource Report 1 Appendix M Plan for Unanticipated Discovery of Historic Properties or Human Remains during Construction Appendix N Correspondence with Federally Recognized Indian Tribes Atlantic Coast Pipeline iv DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District ACRONYMS AND ABBREVIATIONS ACP Atlantic Coast Pipeline APE Area of Potential Effects Atlantic Atlantic Coast Pipeline, LLC ATWS additional temporary workspace BA Biological Assessment bcf/d billion cubic feet per day Columbia Columbia Gas Transmission, LLC Commission Federal Energy Regulatory Commission CWA Clean Water Act DE District Engineer DOE U.S. Department of Energy Dominion Dominion Resources, Inc. DTI Dominion Transmission, Inc. EFH Essential Fish Habitat EIA U.S. Energy Information Administration EIS environmental impact statement EPA U.S. Environmental Protection Agency FERC Federal Energy Regulatory Commission FR Federal Register FWS U.S. Fish and Wildlife Service GDS-NWR Great Dismal Swamp National Wildlife Refuge GIS geographic information system HDD Plan Horizontal Directional Drill Fluid Monitoring, Operations, and Contingency Plan HDD Horizontal Directional Drill HUC Hydrologic Unit Code IPaC System Information Planning and Conservation System M&R metering and regulating MBTA Migratory Bird Treaty Act MP milepost NCDEQ North Carolina Division of Environmental Quality NCWRC North Carolina Wildlife Resources Commission NEPA National Environmental Policy Act NOAA Fisheries National Oceanic and Atmospheric Administration, National Marine Fisheries Service NOAA National Oceanic and Atmospheric Administration NRCS Natural Resources Conservation Service NWI National Wetland Inventory NWP Nationwide Permit Atlantic Coast Pipeline v DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District PASPGP-5 Pennsylvania State Programmatic General Permit 5 PCN Pre -Construction Notification PEM palustrine emergent PFO palustrine forested Piedmont Piedmont Natural Gas Co. Plan Upland Erosion Control, Revegetation, and Maintenance Plan PRM permittee responsible mitigation Procedures Wetland & Waterbody Construction & Mitigation Procedures Project Atlantic Coast Pipeline PSS palustrine scrub -shrub SHP Supply Header Project SPCC Plan Spill Prevention, Control, and Countermeasures Plan TNC The Nature Conservancy Transco Transcontinental Gas Pipe Line Company, LLC USACE United States Army Corps of Engineers USGS United States Geological Survey WQC Water Quality Certification Atlantic Coast Pipeline vi DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District APPLICATION SUPPLEMENTAL INFORMATION DESIGN Section numbering has been incorporated into this supplemental information documents to match the sections of the Pre -Construction Notification (PCN) form (Version 1.4 January 2009) for a joint permit application between the U.S. Army Corps of Engineers (USAGE) and the North Carolina Division of Environment and Natural Resources, Division Water Quality (NCDEQ) for the proposed Atlantic Coast Pipeline (ACP or Project). Atlantic Coast Pipeline, LLC (Atlantic) is seeking a Nationwide Permit (NWP) 12 verification under Section 404 of the Clean Water Act and Section 10 of the Rivers and Harbors Act. The USACE Wilmington District is responsible for permitting the North Carolina portion of the ACP. From the NCDEQ, Atlantic is seeking approval for a project -specific 401 Water Quality Certification (WQC) should any of the single and complete projects not be covered by the State's General 401 WQC issued for the USACE NWP 12 for North Carolina, and Riparian Buffer Authorization. The following sections provide the necessary information to demonstrate that the ACP will comply with the requirements for NWP 12, 401 WQC, the Riparian Buffer Authorizations, and applicable general and regional conditions. The ACP is a Federal Energy Regulatory Commission (FERC or Commission) 7(c) regulated project and the USACE has agreed to participate in FERC's National Environmental Policy Act (NEPA) process as a cooperating agency. INTRODUCTION Atlantic is a company formed by four major U.S. energy companies—Dominion Resources, Inc. (Dominion); Duke Energy Corporation; Piedmont Natural Gas Co., Inc. (Piedmont); and Southern Gas Company, Inc. The company was created to develop, own, and operate the proposed ACP, an approximately 604.6 -mile -long interstate natural gas transmission pipeline system designed to meet growing energy needs in Virginia and North Carolina (Appendix A, Figure 1). The ACP will be capable of delivering up to 1.5 million dekatherms per day of natural gas that will be used to generate electricity, heat homes, and run local businesses. By providing access to additional low-cost natural gas supplies in Virginia and North Carolina, the ACP will facilitate cleaner air, increase the reliability and security of natural gas supplies, and provide a significant economic boost in West Virginia, Virginia, and North Carolina. More information is provided at the company's website at www.dom.com/acl2il2eline. Atlantic has contracted with Dominion Transmission, Inc. (DTI), a subsidiary of Dominion, to permit, build, and operate the ACP on behalf of Atlantic. DTI also proposes to construct and operate approximately 37.5 miles of pipeline loop and modify existing compression facilities in Pennsylvania and West Virginia. This project is referred to as the Supply Header Project (SHP) and will enable DTI to provide firm transportation service of up to 1.5 million dekatherms per day to various customers, including Atlantic. In addition to pursuing the appropriate USACE permits in West Virginia, DTI has applied for authorization/verification under the Pennsylvania State Programmatic General Permit 5 (PASPGP-5) in conjunction with the Pennsylvania Department of Environmental Protection Chapter 105 General Permit for SHP proposed impacts on waters of the U.S and for proposed structures or work in navigable waters of the U.S. within Pennsylvania. The PASPGP-5 is issued pursuant to Section 404(e) of the Clean Water Act (CWA) and is based upon and consistent with the requirements of the Clean Water Act 404(b)(1) guidelines. The USACE administers the PASPGP-5 jointly with the Pennsylvania Department of Environmental Atlantic Coast Pipeline 1 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Protection to authorize the placement or discharge of dredged and/or fill material into waters of the U.S under the provisions of Section 404 of the CWA and for structures or work in or affecting navigable waters of the U.S. under the provisions of Section 10 of the Rivers and Harbors Act of 1899. Atlantic has prepared the following supplemental information document to accompany the PCN form for the ACP proposed in North Carolina used by the Wilmington District for authorization under NWP 12 and NCDEQ for permitting purposes involving water, wetlands, and riparian buffer permitting. Request for USACE NWP 12 for Single and Complete Projects of Waters of the U.S. Atlantic is providing the following information as background information regarding the ACP and the associated SHP to assist the USACE in understanding the overall undertaking being permitted and authorized through the FERC. On September 18, 2015, Atlantic, for ACP, and DTI, for SHP, filed respective applications with FERC to construct, operate, and maintain natural gas pipeline facilities in Pennsylvania, West Virginia, Virginia, and North Carolina. FERC, through the NEPA process, is assessing the potential environmental impacts that could result from constructing and operating the ACP and SHP; two separate, but related, interstate natural gas transmission pipeline projects. On September 15, 2015, Atlantic submitted PCN applications for NWP 12 for ACP to the USACE Wilmington, Norfolk, Pittsburgh, and Huntington Districts for verification of the ACP multiple single and complete projects (crossings) of waters of the U.S. including wetlands. On September 15, 2015, DTI submitted an application for authorization/verification for the SHP in Pennsylvania under the PASPGP-5 and for SHP in West Virginia within Pittsburgh District Regulatory boundaries under NWP 12 for proposed pipeline and facilities crossings of waters of the U.S. including wetlands. This NWP 12 PCN application and supplement is only for the ACP activity (pipeline and facilities) proposed crossings of waters of the U.S. including wetlands located in Wilmington District within North Carolina. In summary, for both ACP and SHP, applications for all proposed impacts on waters of the U.S. including wetlands have been submitted for authorization under General Permits (i.e., NWP 12 or PASPGP-5), with none of the proposed impacts on waters of the U.S. including wetlands requiring an Individual Permit. Atlantic understands that the USACE is a cooperating agency on the NEPA evaluation being conducted by FERC, including FERC's preparation of an environmental impact statement (EIS), but provides the following information to the USACE to provide context and understanding regarding the location of the multiple single and complete crossings proposed for verification under NWP 12. The background information provided within the application outlining the FERC process is intended to assist the USACE in determining that verification of the single and complete projects of this linear project under NWP 12 is appropriate and fully consistent with USACE regulations on scope of analysis and the NWP Program. In particular, the FERC background information is intended to provide the necessary basis for the USACE to determine that the avoidance of impacts on waters of the United States, mitigation for unavoidable conversion of forested wetlands to scrub -shrub and/or emergent wetlands results in no more than minimal impact, after considering compensatory mitigation, at each single and complete project. Furthermore, the information provided below demonstrates that the cumulative impacts on waters of the United States, after considering Atlantic Coast Pipeline 2 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District compensatory mitigation, is minimal based on evaluating impacts within 8 -digit Hydrologic Unit Code (HUC 8) watersheds. Contextual information is provided in this supplement on the ACP to provide a basis for the USACE minimal impact determinations, understanding that the USACE's scope of analysis under NWP 12 is limited to the single and complete projects and the uplands in the immediate vicinity of the single and complete projects that impact the location of such crossings of waters of the United States. Approximately 14 percent of the overall ACP pipeline length of 604.6 miles crossing West Virginia, Virginia, and North Carolina is located within waters of the United States. Under relevant USACE precedent (including without limitation, USACE regulations, NEPA implementation procedures, NWP Program, and Memorandum of Understanding with FERC), the "build/no build" decision and the overall pipeline alignment is determined through the FERC NEPA process. The USACE serves as cooperating agency on the FERC EIS through which the USACE can coordinate with FERC to determine that the overall pipeline alignment properly considers avoidance of impacts to waters of the United States. Moreover, the FERC licensing process has many policies and procedures to confirm that impacts on waters of the United States are avoided and minimized to the extent practicable. Section D provides a summary of the extensive avoidance and minimization that has occurred for the proposed project. As with any linear project, waters of the United States cannot be completely avoided because of the extensive and reticulated nature of the aquatic resource. The USACE evaluation under NWP 12 ensures that the unavoidable impacts on waters of the United States at each single and complete project are mitigated in order to ensure no more than minimal individual and cumulative impacts on waters of the United States after considering the required compensatory mitigation for unavoidable impacts. Atlantic has worked with the USACE field staff to provide minor adjustments of the pipeline route to avoid waters of the United States with special ecological value, or where feasible. Atlantic has applied for a Preliminary Jurisdictional Determination from the USAGE. See Appendix B for a copy of the Wetland and Waterbody Survey Report. PROJECT OVERALL SUPPLEMENTAL INFORMATION ON PROPOSED FACILITIES Atlantic is seeking authorization from FERC to construct, own, operate, and maintain the following proposed facilities for the ACP and from USACE for impacts on waters of the U.S. at each single and complete project: Mainline Pipeline Facilities: AP -1: approximately 333.1 miles of underground 42 -inch outside diameter natural gas transmission pipeline in Harrison, Lewis, Upshur, Randolph, and Pocahontas Counties, West Virginia; Highland, Bath, Augusta, Nelson, Atlantic Coast Pipeline 3 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Buckingham, Cumberland, Prince Edward, Nottoway, Dinwiddie, Brunswick, and Greensville Counties, Virginia; and Northampton County, North Carolina. • AP -2: approximately 186.0 miles of underground 36 -inch outside diameter natural gas transmission pipeline in Northampton, Halifax, Nash, Wilson, Johnston, Sampson, Cumberland, and Robeson Counties, North Carolina. Lateral Pipeline Facilities: • AP -3: approximately 83.2 miles of underground 20 -inch outside diameter natural gas lateral pipeline in Northampton County, North Carolina; and Greensville and Southampton Counties and the Cities of Suffolk and Chesapeake, Virginia. • AP -4: approximately 0.4 mile of underground 16 -inch outside diameter natural gas lateral pipeline in Brunswick County, Virginia. • AP -5: approximately 1.0 mile of underground 16 -inch outside diameter natural gas lateral pipeline in Greensville County, Virginia. Compressor Station Facilities: • Compressor Station 1 (Marts Compressor Station): a new, natural gas-fired compressor station approximately at milepost 1 (MP) 7.6 of the AP -1 mainline in Lewis County, West Virginia. • Compressor Station 2 (Buckingham Compressor Station): a new, natural gas-fired compressor station approximately at MP 191.5 of the AP -1 mainline in Buckingham County, Virginia. • Compressor Station 3 (Northampton Compressor Station): a new natural gas-fired compressor station approximately at MP 300.1 of the AP -1 mainline and MP 0.0 of the AP -2 mainline in Northampton County, North Carolina. Other Aboveground Facilities: • Nine new metering and regulating (M&R) stations at receipt and/or delivery points along the new pipelines (including one at Compressor Station 1 and one at Compressor Station 2). • Thirty-eight valve sites at select points along the new pipelines, at intervals specified by U.S. Department of Transportation regulations at Title 49 Code of Federal Regulations Part 192. The mileposts used in the initial FERC Application, which was filed on September 18, 2015 (FERC Accession Number 20150918-5212), were based on three-dimensional changes in topography along the proposed pipeline routes. In areas where a pipeline route has changed due to the adoption of an alternative, the mileposts in the affected area have been scaled to account for the resulting difference in the length of the route. For these reasons, the straight-line distance between consecutive mileposts as indicated or depicted in tables and figures in this updated Resource Report may be greater than or less than 5,280 feet. The mileposts should be considered as reference points only. Atlantic Coast Pipeline 4 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District • Eight sets of pig launchers and/or receiver sites at 11 points along the new pipelines (including launcher/receiver sites at Compressor Stations 2 and 3). A. APPLICANT INFORMATION 1. Processing: This information is included on the PCN Form. 2. Project Information 2a. Name of Project: Atlantic Coast Pipeline (ACP, Project) 2b.Counties: Northampton, Halifax, Nash, Wilson, Johnston, Sampson, Cumberland, Robeson, see Appendix A — Figure A-2 2c. Nearest municipality/town: Not Applicable — linear project, see Appendix A — Figures A-1, A-2, and A-3. 2d. Subdivision name: Not Applicable 2e. NCDOT only, T.I.P. or state project number: Not Applicable 3. Owner Information 3a. Name(s) on Recorded Deed: Atlantic Coast Pipeline, LLC 3b. Deed Book and Page No. N/A 3c. Responsible Party (for LLC if applicable): Leslie Hartz 3d. Street Address: 707 E Main Street, 19th Floor 3e. City, State, Zip: Richmond, VA 23219 3f. Telephone no.: (804) 771-4468 3g. Fax no.: N/A 3h. Email address: leslie.hartz@dom.com 4. Applicant Information 4a. Applicant is: Atlantic Coast Pipeline, LLC 4b. Name: Leslie Hartz 4c. Business name (if applicable): 4d. Street address: 707 E Main Street, 19th Floor Atlantic Coast Pipeline 5 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 4e. City, State, Zip: Richmond, VA 23219 4f. Telephone no.: (804) 771-4468 4g. Fax no.: N/A 4h. Email address:leslie.hartz@dom.com 5. Agent/Consultant Information 5a. Name: Richard Gangle 5b. Business name (if applicable): Dominion Resources Services, Inc. 5c. Street address: 5000 Dominion Blvd 5d. City, State, Zip: Glen Allen, Virginia 23060 5e. Telephone no.: (804) 273-2814 5f. Fax no.: N/A 5g. Email address: ridchard.b.ganglekdom.com B. PROJECT INFORMATION AND PRIOR PROJECT HISTORY 1. Property Identification Ia. Property Identification: N/A lb. Site Coordinates: Site coordinates are included on the Waterbody and Wetland Tables, see Appendix C. lc. Property Size: 3,023 acres, consists of the Project work area. 2. Surface Waters I 2a. Nearest Waterbody: Waterbody and Wetland location description and classification can be found in Appendix C for Pipeline and Aboveground Facilities. 2b. Water Quality Classification of nearest receiving water: Waterbody and Wetland location description and classification can be found in Appendix C for Pipeline and Aboveground Facilities. 2c. River basin: Eight -digit HUC (HUC 8) watersheds have been provided in Appendix A - Figure 2 and the Wetland and Waterbody Impact tables included in Appendix C for Pipeline Facilities. These codes provide the information necessary to determine the river basin within which each wetland or waterbody crossing occurs. Atlantic Coast Pipeline 6 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 3. Project Description 3a. Existing Site Conditions and General Land Use: Land use types within the proposed AP -2 and AP -3 Project areas were classified according to current land characteristics. Classifications were based on review of the U.S. Geological Survey (USGS) National Gap Analysis Program Land Cover Data and recent digital aerial photography (2013) augmented by field reconnaissance (2014) along the proposed pipeline routes. Atlantic identified nine primary land use types in the ACP Project area. These consist of the following: • Agriculture — Cultivated Crop: actively cultivated cropland (e.g., wheat, grass seed, alfalfa, hay, and vegetables); • Agriculture — Pasture: uncultivated pasture lands and hay meadows; • Agriculture — Tree Plantation/Harvested Forest: managed tree plantations and harvested forests with shrub and grass/forb regeneration; • Upland Forest/Woodland: conifer dominated forests and woodlands, deciduous dominated forests and woodlands, deciduous dominated savannas and glades, floodplain/riparian forests, and mixed deciduous/coniferous forests and woodlands; • Developed — Open to Low Intensity: herbaceous areas (e.g., golf courses, road sides, parks, and air fields) and areas with a mixture of constructed materials and vegetation where impervious surfaces account for 20 to 49 percent of total cover (e.g., single-family housing units); • Developed — Medium to High Intensity: areas with impervious surfaces accounting for 50 to 100 percent of total cover, including single-family housing units, apartment complexes, row houses, and commercial/industrial areas; • Open Land: disturbed lands, grasslands, shrub lands, beach and shore lands, and cliff, canyon, and talus lands; • Wetlands: wetland areas identified by field surveys or in National Wetland Inventory (NWI) data, including palustrine and estuarine wetlands; and • Open Water: areas of open water, generally with less than 25 percent cover of vegetation or soil, including inland waters of streams, river, ponds, and lakes, and coastal and near -shore estuarine and/or marine waters. 3b. Existing wetland acreage: 558 Acres within the Project Study Area. 3c. Existing linear feet of stream: 31,701 Linear Feet within the Project Study Area. 3d. Project Purpose and Need and Background Regarding FERC NEPA Process: Atlantic Coast Pipeline 7 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District USACE NWP 12 Purpose and Need The purpose and need for purposes of NWP 12 verification of each single and complete project is to cross wetlands, streams and other waters while avoiding impacts on those wetlands, streams and other waters to the maximum extent practicable and offsetting unavoidable impacts on the aquatic environment with compensatory mitigation. Additional details on the project purpose and need are provided below. FERC NEPA PROJECT PURPOSE STATEMENT The following description of the purpose and need for the FERC NEPA process is provided as background information. Information included has been compiled largely from documents submitted to FERC, but is provided for the convenience of the USACE review. In Section D of the application materials, below, within the Impact Justification and Mitigation, Avoidance and Minimization, and FERC Alternatives sections, the numbering of many of the referenced tables and figures has not been changed from their number in the FERC documentation, to maintain consistency across documents (e.g., Table 3.10.5-1, Figure 10.8.1-1, etc.). The ACP is a proposed interstate natural gas transmission pipeline that will serve the growing energy needs of multiple public utilities and local distribution companies in Virginia and North Carolina. The natural gas transported by the ACP will be used as a fuel to generate electricity for industrial, commercial, and residential uses. The natural gas will also be used directly for residential, commercial, and industrial uses. By providing access to additional low- cost natural gas supplies, the ACP will increase the reliability and security of natural gas supplies in Virginia and North Carolina. In recent years, demand for natural gas in Virginia and North Carolina has grown significantly. Demand for natural gas for all uses grew by 37 and 50 percent, respectively, in Virginia and North Carolina between 2008 and 2012. Demand for gas-fired electric power generation grew by 123 percent in Virginia and 459 percent in North Carolina from 2008 to 2013 (U.S. Energy Information Administration [EIA], (EIA, 2015a, 2015b, 2015c, 2015d, and 2015e).2 Demand for natural gas in Virginia and North Carolina is expected to increase in coming decades due to a combination of population growth and displacement of coal-fired electric power generation. The U.S. Census Bureau predicts 2.7 million new residents in Virginia and 4.2 million new residents in North Carolina between 2000 and 2030 (U.S. Census Bureau, U.S. Energy hiformation Administration.2015a. Annual Energy Outlook 2015.Available online at hitu://www.eia.gov/forecasts/aeo/. Accessed June 2015. U.S. Energy Information Administration.2015b. Market Trends; Electricity Demand. Available online at htip://www.eia.gov/forecasts/aeo/ MT electric.cfm. Accessed June 2015. U.S. Energy Information Administration.2015c. Market Trends; Natural Gas. Available online at http://www.eia.gov/forecasts/aeo/mt nat ural ag s.cfin. Accessed June 2015. U.S. Energy Information Administration.2015d. Natural Gas Summary for Virginia. Available online at hitp://www.eia.gov/dnav/ng/ng sum _lsum_dcu_SVA a.htm. Accessed June 2015. U.S. Energy Information Administration.2015e. Natural Gas Summary for North Carolina. Available online at htW://www.cia_gov/dnav/n ng sum Isum_dcu_SNC _a.htm. Accessed June 2015. Atlantic Coast Pipeline 8 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 2014). At the same time, use of natural gas for power generation is expected to increase significantly. By 2035, natural gas is expected to surpass coal as the most common fuel for electric power generation due to coal-fired plant retirements and low natural gas prices. The EIA (2015a) expects renewable generation to grow 1.9 percent per year, meeting a part of the demand for power, but more than 70 percent of new generating capacity will be fueled by natural gas. A study, prepared by ICF International (2015) for Atlantic, projects that electric power generation in Virginia and North Carolina will increasingly rely on natural gas over the next two decades. Between 2019 and 2038, the study predicts that approximately 9,900 megawatts of electric generating capacity from coal and nuclear fuels will be retired, while 20,200 megawatts of new generating capacity from natural gas will be built in Virginia and North Carolina. As a result, demand for natural gas for power generation in Virginia and North Carolina is expected to grow 6.3 percent annually between 2014 and 2035, increasing from 1 billion cubic feet per day (bcf/d) to 3.7 bcf/d. To meet the growing demand for natural gas, the EIA (2015a) projects total United States natural gas production to increase by 56 percent from 2012 to 2040. At the same time, natural gas transmission patterns across the United States are expected to change based on the growing production from shale basins in the mid-Atlantic region. Historically, gas produced from the Gulf of Mexico, Canada, and the Rocky Mountains was delivered to markets in the eastern United States. Large increases in production from United States supply basins have created abundant, competitively priced supplies to meet the demands of the region. A study by the U.S. Department of Energy (DOE, 2015)3, dated February 2015, examined the impact of increased demand for natural gas from the electric power sector on natural gas pipeline infrastructure in the United States over a 15 year period from 2015 to 2030.4 The DOE (2015) study found that a projected 38 to 42 bcf/d of new and expanded pipeline capacity will be necessary to meet demand over the 15 year study period. The DOE study further found that flow reversal is projected to occur "to serve markets in the Southeast." Furthermore, existing pipelines that historically transported natural gas from the Gulf Coast region to points further north are expected to change the direction of flow in order to "serve the Virginia and Carolina markets" (DOE, 2015). However, there are no existing long haul interstate pipelines with available takeaway capacity from the Appalachian region directly serving Virginia and North Carolina (see Figure 1 in the DOE [2015] study). Moreover, market participants in the region have determined that their needs cannot be adequately met by existing pipeline systems. In April 2014, Duke Energy Corporation and Piedmont issued requests for proposals for incremental pipeline transportation service due to their existing and future natural gas generation requirements, core load growth, and system U.S. Department of Energy. 2015. Natural Gas Infrastructure Implications of Increased Demand from the Electric Power Section. Available on line at: htip:Henergy.gov/sites/prod/files/2015/02/fl9/DOE%2ORgport%2ONatural%2OGas%201nfrastructure°/u20V 02-02.pdf. Accessed February 2015. 4 In comments filed with the FERC, several individuals said that demand for natural gas in Virginia and North Carolina could be met by existing pipeline systems citing this study by the DOE. The study did not conclude, as some suggested, that no additional pipeline capacity is needed to meet the increased demand for natural gas. Instead, the study found that the expected increase in pipeline capacity over the study period will be modest relative to previous expansions in pipeline capacity. Atlantic Coast Pipeline 9 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District reliability and supply diversity goals. In June 2014, Virginia Power Services Energy Corp., Inc. issued a request for proposals for firm transportation service to serve Virginia. Following the request for proposals processes, these companies contracted for transportation service on the ACP, as did other companies in the region. To meet the natural gas demand of its customers, the ACP will connect the growing demand areas in Virginia and North Carolina with growing supplies. Interstate natural gas pipelines act as common carriers to transport natural gas; they are not part of natural gas exploration or production activities. The ACP will connect growing demand areas in Virginia and North Carolina with growing supply areas in the Appalachian region and provide access to the Dominion South Point supply hub, consisting of abundant supplies on the DTI system that are sourced from a wide variety of upstream pipeline interconnects and diverse production areas. More specifically, the ACP will provide up to 1.5 bcf/d of firm natural gas transportation service into West Virginia, Virginia, and North Carolina. The ACP will receive gas on behalf of its customers at two new interconnections: one between the ACP and the SHP in Harrison County, West Virginia, to be known as the Marts Junction Interconnection; and one between the ACP and existing Transcontinental Gas Pipe Line Company, LLC (Transco) facilities in Buckingham County, Virginia, to be known as the Buckingham Interconnects. The natural gas will be delivered to various new customer interconnects in West Virginia, Virginia, and North Carolina. Additionally, the ACP will lease capacity on a pipeline owned and operated by Piedmont to enable certain deliveries in North Carolina. Of the new firm transportation capacity of up to 1.5 bcf/d proposed by the ACP, 1,360,000 dekatherms per day (approximately 1.33 bcf/d) is currently subscribed pursuant to precedent agreements with six customers. These customers are major utilities and local distribution companies in the region. The precedent agreements demonstrate the need for the Projects, the demand for new gas supplies indicated in the studies noted above, and the desire for access to a new supply region. The remaining unsubscribed capacity would be awarded and contracted for in accordance with Commission policies applicable to open -access interstate pipelines and the provisions of applicable FERC gas tariffs. The natural gas supplied to each delivery point would be provided to local distribution companies, power generators, and other interstate pipeline companies. 'I 3e. Project Details (Project Description and Project Facilities) Overall Project Description for ACP The project description of the ACP for purposes of USACE NWP 12 authorization is to construct single and complete projects on waters of the United States that result in no more than minimal individual and cumulative impacts on the aquatic environment and offsetting 5 The ACP and SHP are separate projects with separate applicants, but are being reviewed as connected actions by FERC through development of a single Environmental Impact Statement. Atlantic Coast Pipeline 10 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District unavoidable impacts on the aquatic environment with compensatory mitigation. The overall ACP project construction and operation to be authorized by FERC is a proposed 604.6 -mile - long, interstate natural gas transmission pipeline that will serve the growing energy needs of multiple public utilities and local distribution companies in the region. The natural gas transported by the ACP will be used as a fuel to generate electricity for industrial, commercial, and residential uses. The natural gas will also be used directly for residential, commercial, and industrial uses. By providing access to additional low-cost natural gas supplies, the ACP will increase the reliability and security of natural gas supplies in Virginia and North Carolina. Project Details for North Carolina A short segment of the AP -1 mainline, approximately 200 feet in length, will occur in North Carolina. This short segment of AP -1 will not cross wetlands or waterbodies, and will not be discussed further in the application. The AP -2 mainline, which will consist of 36 -inch outside diameter pipeline, will originate at the southern terminus of AP -1 at Compressor Station 3 in Northampton County, North Carolina. From this point, the pipeline will extend to the southwest crossing through Northampton, Halifax, Nash, Wilson, and Johnston Counties, passing west of Rocky Mount in Nash County, west of Wilson in Wilson County, and east of Selma in Johnston County. At the Johnston/Sampson County line, the pipeline will turn west/southwest and continue through Sampson County and southeast of Fayetteville in Cumberland County, before terminating at a new interconnect with an existing Piedmont distribution pipeline in Robeson County, North Carolina. Approximately 186.4 miles of the AP -2 mainline occurs within the USACE - Wilmington District and is a part of the proposed work under NWP 12 PCN. The AP -3 lateral, which will consist of 20 -inch outside diameter pipeline, will originate at Compressor Station 3 in Northampton County, North Carolina and extend to the east/northeast to the Virginia State line. AP -3 will then continue northeast through Greensville and Southampton Counties and the Cities of Suffolk and Chesapeake, Virginia. Approximately 12.2 miles of the AP -3 lateral occurs within the USACE— Wilmington District, all within Northampton County, North Carolina and is a part of the proposed work under NWP 12 PCN. In addition one compressor station, three M&R stations, 11 valve sites, and four sets of pig launchers and receivers are planned within the Wilmington District. The location of each aboveground facility in North Carolina, by milepost and county is listed in Table 1. Compressor Stations Compressor Station 3 will be located approximately at MP 300.1 in Northampton County, North Carolina at the intersection of the AP -1 and AP -2 mainlines and the AP -3 lateral. The station will take natural gas from the AP -1 mainline and discharge into both the AP -2 mainline and the AP -3 lateral. Atlantic Coast Pipeline 11 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District TABLE 1 Proposed Aboveground Facilities in North Carolina for the Atlantic Coast Pipeline Aboveground Facility County/City and State Approximate Milepost Compressor Stations AP -1 Mainline Compressor Station 3 Northampton County, NC 300.1 Metering and Regulating Stations AP -2 Mainline Smithfield M&R Station Johnston County, NC 92,7 Fayetteville M&R Station Cumberland County, NC 132.9 Pembroke M&R Station Robeson County, NC 182.9 Valves AP -2 Mainline Valve Site 23 Northampton County, NC 9.4 Valve Site 24 Halifax County, NC 14.9 Valve Site 25 Nash County, NC 34.7 Valve Site 26 Nash County, NC 49.5 Valve Site 27 Nash County, NC 64.3 Valve Site 28 Johnston County, NC 78.7 Valve Site 29 Johnston County, NC 108.1 Valve Site 30 Cumberland County, NC 123.0 Valve Site 31 Cumberland County, NC 136.6 Valve Site 32 Cumberland County, NC 153.7 Valve Site 33 Robeson County, NC 168.6 Pig Launcher/Receiver Sites AP -1 Mainline Site 4 (launcher/receiver) Northampton County, NC 300.1 AP -2 Mainline Site 5 (launcher/receiver) Johnston County, NC 92.7 Site 6 (receiver) Robeson County, NC 182.9 AP -3 Lateral Site 4 (launcher) Northampton County, NC 0.0 Metering and Re _ ug lating Stations Atlantic will construct three M&R stations in North Carolina at the locations identified in Table 1. The M&R stations will be built at receipt or delivery points along the pipelines. In general, each M&R station will contain two dekatherm buildings (used to house equipment such as gas chromatographs, communications equipment, etc.), a regulation building, and possibly a meter building. Equipment at each station will include gas filter/separators, gas meters, and regulators, and may include gas heaters and/or odorization equipment. Each station will be surrounded by a chain-link security fence. `%A1VA C1iAC Eleven valves will be installed along the proposed pipelines at the locations identified in Table 1. The valves will be installed below grade with aboveground valve operators, risers, blowdown valves, and crossover piping connected on each side of the valve. A chain-link Atlantic Coast Pipeline 12 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District security fence will be installed around the periphery of each valve site. The valves will allow DTI, as operator, to segment the pipelines for safety, operations, and maintenance purposes. Launchers/Receivers Four sets of pig launchers and/or receivers will be installed at the locations identified in Table 1. One set of the pig launcher/receiver assemblies and one launcher will be built on the same sites and within the same fencelines as other aboveground facilities. These include a pig launcher/receiver assembly and a launcher assembly at Compressor Station 3, a launcher/receiver assembly at the Smithfield M&R Station, and a pig receiver assembly at the Pembroke M&R Stations. The pig launchers/receivers will be used to run pipeline inspection tools, called pigs, through the pipeline system. Right-of-Wav Configuration The construction right-of-way width has been minimized following FERC's "Wetland & Waterbody Construction & Mitigation Procedures" (Procedures) as prescribed for each land type. For the AP -2 mainline, the construction corridor in non-agricultural uplands will measure 110 feet in width, with a 35 -foot -wide temporary side cast storage side and a 75 -foot -wide working side. In areas where full width topsoil segregation is required (e.g., agricultural areas), an additional 25 feet of temporary construction workspace will be needed on the working side of the corridor to provide sufficient space to store topsoil. In wetlands, the width of the construction right-of-way will be reduced to 75 feet, with 25 feet on the temporary side cast storage side and 50 feet on the working side. Following construction, a 50 -foot -wide permanent easement will be maintained for operation of the pipeline. For the AP -3 pipeline lateral section in North Carolina, the construction corridor in non- agricultural uplands and in wetlands will measure 75 feet in width, with a 25 -foot -wide temporary side cast storage side and 50 -foot -wide working side. In areas where full width topsoil segregation is required (e.g., agricultural areas), an additional 25 feet of temporary construction workspace will be needed on the working side of the corridor to provide sufficient space to store topsoil. Following construction, a 50 -foot -wide permanent easement will be maintained for operation of each pipeline. Atlantic will retain a 50 -foot -wide permanent right-of-way to allow operation and maintenance of the pipeline along the AP -2 mainline. The majority of the permanent right-of- way will be allowed to return to preconstruction uses, although permanent structures will not be allowed within the 50 -foot -wide permanent right-of-way. Section VI. D. of the FERC's Procedures specifically require: "Do not conduct routine vegetation mowing or clearing over the full width of the permanent right-of-way in wetlands. However, to facilitate periodic corrosion/leak surveys, a corridor centered on the pipeline and up to 10 feet wide may be cleared at a frequency necessary to maintain the 10 -foot corridor in an herbaceous state. In addition, trees within 15 feet of the pipeline with roots that could compromise the integrity of pipeline coating may be selectively cut and removed from the permanent right-of-way. Atlantic Coast Pipeline 13 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Do not conduct any routine vegetation mowing or clearing in wetlands that are between HDD entry and exit points." Therefore, after construction within the 50 -foot -wide permanent easement, the following maintenance will occur: (a) Ten feet centered over pipeline — maintained in an herbaceous state to facilitate periodic aerial inspections. These areas will be reseeded with native wetland seed mix. (b) Thirty feet centered over pipeline — trees with roots that could compromise the integrity of the pipeline coating would be selectively removed. These areas will be reseeded with native wetland seed mix to stabilize the area within wetlands. (c) Outside 30 -foot maintenance area in palustrine emergent (PEM) and palustrine scrub -shrub (PSS) wetlands — vegetation allowed to regrow with no restrictions - no vegetation maintained by Atlantic. Atlantic will reseed these temporarily disturbed wetland areas with native wetland see mix to stabilize following construction. (d) Outside 30 -foot -maintenance area in non -inundated deciduous hardwood palustrine forested (PFO) wetlands —Atlantic will replant deciduous hardwood wetlands as part of the minimization of impacts and compensatory mitigation plan. Where wetlands are inundated much of the growing season, Atlantic would not replant these wetlands due to the high likelihood of sapling mortality. NWP 12 Regional Condition 4.1.3 (January 9, 2017 Wilmington District Public Notice for NWP Program 2017-2022 Regional Conditions) for work in North Carolina states: "The work area authorized by this permit, including temporary and/or permanent fills, will be minimized to the greatest extent practicable. Justification for work corridors exceeding forty (40) feet in width is required and will be based on pipeline diameter and length, size of equipment required to construct the utility line, and other construction information deemed necessary to support the request. The permittee is required to provide this information to the USACE with the initial notification package." Construction of the ACP will require additional workspace beyond 40 feet in wetland areas. Justification for the additional workspace is as follows: AP -2 in North Carolina will be 36 -inch diameter pipe, which requires large construction equipment to install. The construction space in wetlands consists of a trench necessary to accommodate the pipe at an appropriate depth (3-5 feet beneath the surface), adjacent space to place excavated material from the trench excavation, and travel of equipment alongside the trench for pipe installation. Soils in wetlands areas are generally less stable than those in adjacent upland areas, therefore additional shoring is necessary to achieve the appropriate trench depth resulting in a trench that is wider than in adjacent upland areas. In addition, the extra material that is excavated requires more space for temporary side -casting and the instability of the soil requires that the travel corridor adjacent to the trench be at a safe distance so that failure of the trench walls does not occur. The FERC's Procedures specify a maximum right-of-way width of 75 feet in wetlands, unless prior written approval is obtained. Atlantic has reduced workspace from 110 feet to Atlantic Coast Pipeline 14 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 75 feet in wetlands and is not requesting a variance from this right-of-way limitation. Further consideration was made regarding a reduction in workspace in wetlands to meet the 40 feet recommended by Wilmington District NWP Regional and NCDEQ General WQC Conditions in North Carolina, but for reasons outlined above, Atlantic has determined that the full 75 feet, allowed by the FERC, will be necessary to safely install the ACP. The NCDEQ Division of Water Resources has advised that they have the ability to waive the 40 -foot construction corridor restriction limitation associated with the General WQC authorization for NWP 12. Atlantic is specifically requesting NCDEQ to waive WQC General Condition 11 and Activity Specific Condition 5 for WQC No. 3884 (WQC number referenced was issued for current 2012-2017 NWP Program so requesting same for 2017-2022 NWP Program General WQC when issued), which state: General WQC General Condition 11) Work in the Dry All work in or adjacent to stream waters shall be conducted so that the flowing stream does not come in contact with the disturbed area. Approved best management practices from the most current version of the NC Sediment and Erosion Control Manual, or the NC DOT Construction and Maintenance Activities Manual, such as sandbags, rock berms, cofferdams, and other diversion structures shall be used to minimize excavation in flowing water. Exceptions to this condition require application to and written approval from DWR. Atlantic is requesting a waiver for General Condition 11 due to the fact that several stream crossings are too large to feasibly work in the dry, but are not suitable for horizontal directional drill (HDD). The smaller stream crossings will be accomplished by working in the dry via flume, dam -and -pump, and cofferdam construction methods, as previously described. Along the Project in North Carolina, wetland-waterbody complexes occur that require special crossing techniques. These complexes consist of broad inundated wetlands with a waterbody channel located within the extents of the wetlands. The water is generally not contained within the channel of the waterbody, thus resulting in a continuum of water that extends from the channel to the upland extend of the wetlands edge. The crossing of these complexes cannot be accomplished utilizing a waterbody crossing technique, thus a combination of wetland/waterbody technique is required. The crossing cannot be accomplished "in the dry" due to the difficulty in removing water from within the wetland. The channel crossing in these complexes would be similar to the open cut method described in this section and the wetlands crossing would be accomplished using the push-pull wetlands crossings method described in Wetland and Waterbody Construction Procedures section below. The volume of water at the larger stream crossings is too great to safely and temporarily divert the flow around the work area. Rocky Swamp and Cypress Creek are proposed to be open cut (i.e., wet crossings). As part of Atlantic's effort to avoid and minimize impacts on waters of the United States and associated sensitive resources, crossings of seven large waterbodies are proposed as HDD crossings (Roanoke River, Fishing Creek, Swift Creek, Tar River, Contentnea Creek, Little River, and Cape Fear River) due to the resources present at these crossings; see response to 5) below. Atlantic Coast Pipeline 15 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District General WQC Activity Specific Condition 5) 50 foot Construction Corridor Construction corridors in wetlands and across stream channels shall be minimized to the maximum extent practicable and shall not exceed 50 feet wide for gas utility lines and 40 feet wide for all other utility lines. Exceptions to this condition require application to and written approval from DWR. Atlantic is requesting the waiver for Activity Specific Condition 5 due to the fact that a 50 foot work area through wetlands and across stream channels is not wide enough to safely install a 36 -inch pipe. Construction of the ACP will require additional workspace beyond 50 feet in wetland areas. Justification for the additional workspace is as follows: AP -2 in North Carolina will be 36 -inch diameter pipe, which requires large construction equipment to install. The construction space in wetlands consists of a trench necessary to accommodate the pipe at an appropriate depth (3-5 feet beneath the surface), adjacent space to place excavated material from the trench excavation, and travel of equipment alongside the trench for pipe installation. Soils in wetlands areas are generally less stable than adjacent upland areas, therefore additional shoring is necessary to achieve the appropriate trench depth resulting in a trench that is wider than in adjacent upland areas. In addition, the extra material that is excavated requires more space for temporary side -casting and the instability of the soil requires that the travel corridor adjacent to the trench be at a safe distance so that failure of the trench walls does not occur. In addition to the construction right-of-way, additional temporary workspace (ATWS) will be required at various locations along the construction right-of-way, such as at the beginning of each construction spread for mobilization of construction equipment; for stringing -truck turnaround areas; where the pipeline crosses under buried features (e.g., foreign pipelines, utility lines); at road crossings, railroads, wetlands, waterbodies; residential areas, and at HDD crossings. ATWS also will be required in areas with side slopes to create a level and safe work surface across the width of the right-of-way for equipment operation. For the AP -2 mainline, ATWS measuring 25 by 100 feet will typically be required on both sides of the corridor and both sides of the crossing at wetlands, waterbodies, roads, and railroads. The FERC's Procedures require that ATWS be set back at least 50 feet from the wetland boundaries and the water's edge of waterbodies, except where the adjacent lands consist of croplands or other disturbed areas. Following construction of the pipelines, ATWS will be restored to pre-existing conditions and uses. Atlantic has identified roads which will be used to provide access to the Project construction rights-of-way, permanent easement, and other facilities during construction and operation of the ACP. Atlantic will utilize existing roads to the extent practicable, but some new roads may need to be built in remote areas. Additionally, new roads will need to be built to provide access to aboveground facility sites (i.e., compressor and M&R stations, valves, and pig launcher/receiver assemblies) during operations. In some cases, existing roads will require improvement (such as grading, gravelling, replacing or installing culverts, minor widening, and/or clearing of overhead vegetation) to safely accommodate construction equipment and vehicles. A sufficient number of roads with regular spacing is needed to minimize congestion of construction vehicles and equipment on the right-of-way; having fewer access roads would Atlantic Coast Pipeline 16 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District increase the duration of construction and create unsafe work conditions for workers. If any existing roads are damaged during construction, Atlantic will restore these roads to preconstruction condition or better. See Appendix C for access road impacts. General Construction Procedures Refer to Appendix D for a discussion on general construction procedures. Waterbody and Wetland Construction Procedures Atlantic will use special construction techniques where warranted by site-specific conditions, e.g., when constructing across waterbodies, and wetlands. Each of these specialized measures is described below. Illustrations of select crossing methods are provided in Appendix E and site-specific plans are provided in Appendix F for crossings of Section 10 waterbodies. Waterbody Crossings Atlantic will use the open -cut, flume, dam -and -pump, conventional bore, cofferdam, or HDD methods to construct the pipelines across waterbodies. In each case and for each method, Atlantic will adhere to the measures specified in the Procedures; site-specific modifications to the Procedures as requested by Atlantic and approved by the FERC. As well as any additional requirements identified in federal or state waterbody crossing permits, including applicable permits and approvals from the USACE and various state agencies (see Section 135). A complete list of the waterbodies along the proposed pipeline routes within the Wilmington Distict, and the construction method proposed for each crossing, is provided in Appendix C. Construction methods for waterbodies that isolate the pipeline trench from flowing water (e.g. flume, dam - and -pump, cofferdam) will be utilized where these methods are proposed and perceptible flow is present at the time of the crossing. During the clearing and grading phase of construction, temporary bridges will be installed across waterbodies in accordance with the Procedures to allow construction equipment and personnel to cross. The bridges may include clean rock fill over culverts, timber mats supported by flumes, railcar flatbeds, flexi-float apparatuses, or other types of spans. Construction equipment will be required to use the bridges, except that the clearing and bridge installation crews will be allowed one pass through waterbodies before bridges are installed. The temporary bridges will be removed when construction and restoration activities are complete. ATWS will be required on both sides of waterbody crossings to stage construction equipment, fabricate the pipeline, and store construction materials. The ATWS will be located at least 50 feet away from the water's edge at each waterbody (with the exception of site-specific modifications as requested by Atlantic and approved by the FERC). Clearing adjacent to waterbodies will involve the removal of trees and brush from the construction right-of-way and ATWS areas. Woody vegetation within the construction right-of- way will be cleared to the edge of each waterbody. Sediment barriers may be installed at the top of the bank if no herbaceous strip exists. Initial grading of the herbaceous strip will be limited to the extent needed to create a safe approach to the waterbody and to install temporary bridges. Atlantic Coast Pipeline 17 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District During clearing, sediment barriers will be installed and maintained across the right-of- way adjacent to waterbodies and within ATWS to minimize the potential for sediment runoff. Erosion control devices located across the working side of the right-of-way will be removed during the day when vehicle traffic is present, and will be replaced each night. Alternatively, drivable berms may be installed and maintained across the right-of-way in lieu of silt fences and/or straw bales. Typically, equipment refueling and lubricating at waterbodies will take place in upland areas that are 100 feet or more from the edge of the waterbody and any adjacent wetlands. However, there will be certain instances where equipment refueling and lubricating may be necessary in or near waterbodies. For example, stationary equipment, such as water pumps for withdrawing hydrostatic test water, may need to be operated continuously on the banks of waterbodies and may require refueling in place. Atlantic's Spill Prevention, Control, and Countermeasures Plan (SPCC Plan) will address, among other items, the handling of fuel and other materials associated with the ACP. As required by the Procedures, the SPCC Plan will be available during construction on each construction spread. The SPCC Plan is provided in Appendix G. After the pipeline is installed across a waterbody using one of the methods described below, the trench will be backfilled with native material excavated from the trench. If present and moved prior to construction, larger rocks or boulders will be replaced in the stream channel within the construction area following backfill of the trench. The streambed profile will be restored to preconstruction contours and grade conditions to prevent scouring. The stream banks will then be restored as near as practicable to preconstruction conditions and stabilized. Stabilization measures will include seeding, installation of erosion control blankets, or installation of riprap materials, as appropriate. Jute thatching or bonded fiber blankets will be installed on banks of waterbodies or road crossings to stabilize seeded areas. Temporary erosion controls will be installed immediately following bank restoration. The waterbody crossing area will be inspected and maintained until restoration of vegetation is complete. Open -Cut Method The open -cut or wet trench crossing method will involve trenching through the waterbody while water continues to flow through the trenching area. Prior to initiating construction across the waterbody, the crossing section of pipeline will be fabricated (i.e., bent, welded, and coated) in adjacent ATWS areas. Backhoe -type excavators will then be used to excavate a trench in the flowing waterbody from one or both banks of the waterbody. Where the waterbody is too wide to excavate the trench from the banks, equipment may operate from within the waterbody with approval from the appropriate regulatory agencies. Equipment operating within the waterbody will be limited to that needed to construct the crossing. During these operations, flow will be maintained at the crossing as specified in the Procedures. Turbidity curtains will be installed downstream of the crossing as necessary to minimize suspended solids in the water. Temporary sidecast excavated from the trench will be placed on the bank above the high water mark (at least 10 feet from the edge of the water) or placed adjacent to the trench in the stream (major waterbodies only, in accordance with the Procedures) for use as backfill. A Atlantic Coast Pipeline 18 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District prefabricated segment of pipeline will then be placed into the trench using side -boom tractors. Concrete coating (installed in uplands in project workspace) or bag weights will be utilized, as necessary, to provide negative buoyancy for the pipeline. Once the trench is backfilled, the banks will be restored as near as practicable to pre -construction contours and stabilized as described above. Excavated material not required for backfill will be removed and disposed of at approved upland disposal sites. Throughout the construction process, Atlantic will follow the Procedures to avoid or minimize impacts on water quality. Construction activities will be scheduled so that the trench is not excavated across the waterbody until immediately prior to pipe laying activities. The duration of in -stream construction activities (excluding blasting, if required) will be limited to 24 hours across minor waterbodies (those 10 feet in width or less) and 48 hours across intermediate waterbodies (those between 10 and 100 feet in width). Flume Method The flume crossing method consists of isolating and temporarily diverting the flow of water across the trenching area through one or more large -diameter, steel flume pipes placed in the waterbody. This method allows for trenching activities to occur within a relatively dry stream or riverbed (beneath the flume pipes containing the water flow), thereby minimizing sediment and turbidity within the waterbody. The flume method is typically used to cross small to intermediate flowing waterbodies that support coldwater or other significant fisheries. For each waterbody where the flume method is implemented, a sufficient number of adequately sized flume pipes will be installed in the waterbody to accommodate the highest anticipated flows during construction. Atlantic will use stream gauge data from the USGS to determine the highest anticipated flows during the time the flume crossing is in effect. In the absence of stream gauge data, Atlantic's engineers and Environmental Inspectors will estimate the highest anticipated flows based on the width of the waterbody at the ordinary high water mark, the depth of the waterbody, existing flows at the time of the crossing, and the weather forecast at the time of the crossing. As a contingency, Atlantic will stage additional flume pipes at the crossing in the event that the volume of flow increases due to a precipitation event. Prior to installation, Atlantic will inspect the flume pipes to confirm that they are free of dirt, grease, oil, or other pollutants. After placing the pipes in the waterbody, sand- or pea gravel -filled bags, water bladders, or metal wing deflectors will be placed in the waterbody around the flume pipes upstream and downstream of the proposed trench. These devices will serve to dam the stream and divert the water flow through the flume pipes, thereby isolating the water flow from the construction work area between the dams. After installation of the flume pipes, any remaining standing water between the dams will be pumped out. Pump intakes will be appropriately screened to prevent entrainment of aquatic species. Fish trapped in the dewatered area will be removed and returned to the flowing waterbody. Leakage from the dams or subsurface flow from below the waterbody bed may cause water to accumulate in the trench once trenching has begun. If water accumulates in this area, it may be pumped out periodically and discharged into energy dissipation/sediment filtration devices as required by the Procedures. Such devices include geotextile filter bags and Atlantic Coast Pipeline 19 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District straw bale structures. Alternatively, the water will be discharged into well -vegetated areas away from the edge of the waterbody, to prevent silt -laden water from entering the waterbody. Backhoe -type excavators located on the banks of the waterbody will be used to excavate a trench under the flume pipe across the dewatered streambed. Temporary side -cast material excavated from the waterbody trench will be placed and stored on the bank above the high water mark and a minimum of 10 feet from the edge of the waterbody. Once the trench is excavated, a prefabricated segment of pipe will be installed beneath the flume pipes. The trench will then be backfilled with the native material excavated from the trench across the waterbody bed. The banks will be stabilized before removing the dams and flume pipes and returning flow to the waterbody channel. The flume method has proven to be an effective technique for constructing pipelines across sensitive waterbodies. The potential for the introduction of turbidity or suspended sediments is limited because sediment generated during trench excavation and backfilling operations is isolated to the dewatered area between dams. When flumes are installed properly, the operation of the flume is generally stable and can be left in place for periods prior to and following the installation of the waterbody pipeline crossing. The flume method also provides for continued fish passage through the construction work area via the flume pipes during the crossing. Dam -and -Pump Method The dam -and -pump method generally is preferred for smaller waterbodies, where mechanical pumps can dependably convey stream flows. In this approach, pumps and hoses are used instead of flume pipes to isolate and transport the stream flow around the construction work area. Similar to the flume method, the objective of the dam -and -pump method is to create a relatively dry work area to avoid or minimize the transportation of sediment and turbidity downstream of the crossing during in -stream work. As the first step in implementing the dam -and -pump method, one or more pumps and hoses of sufficient size to transport anticipated flows will be installed adjacent to the waterbody. Additional back-up pumps will be on site at all times as a contingency, in case of pump failure. Once the pumps are operational, the waterbody upstream and downstream of the construction area will be dammed with sandbags and/or steel plates. As the dams are installed, the pumps will be started to maintain continuous flow in the waterbody. Following the installation of the dams, the pumps will be run continuously until the pipeline is installed across the waterbody and the streambed and banks are restored. Pump intakes above the upstream dam will be appropriately screened to prevent entrainment or impingement of aquatic species. Energy -dissipation devices, such as splash blocks, filter bags, or energy dissipation sleeves, will be used to prevent scouring of the streambed at the discharge location. Water flow will be maintained through all but a short reach of the waterbody at the actual crossing location. Backhoe -type excavators located on the banks of the waterbody will be used to excavate a trench across the waterbody. Temporary sidecast removed from the trench will be placed and stored on the bank above the high water mark at a minimum of 10 feet from the edge of the Atlantic Coast Pipeline 20 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District water. Trench plugs will be maintained between the upland trench and the waterbody crossing. Once the trench is excavated, a prefabricated segment of pipe will be installed. The trench will then be backfilled with the native material excavated from the trench across the waterbody bed. After backfilling, the dams will be removed and the banks restored and stabilized as described above. Conventional Bore In some cases, waterbodies may be crossed by conventional subsurface boring beneath the waterbody. Boring involves installing pipeline through a hole bored through the substrate. Where this method is implemented, equipment operating from pits excavated on either side of the crossing will bore through the substrate beneath the waterbody. If dewatering of the pits is necessary, it will be conducted in accordance with the Upland Erosion Control, Revegetation, and Maintenance Plan (Plan) and Procedures and applicable permits in a manner that will minimize erosion and prevent silt -laden water flowing into the waterbody or adjacent wetlands. During a conventional bore crossing, the pipeline will be pushed through the bore hole under the waterbody. Like the HDD method described later in this section, the conventional bore can eliminate direct surface impacts on waterbodies, however, there are limitations to its use. This method cannot typically be used to cross waterbodies with unconsolidated soils in the substrate because it is not possible to maintain the integrity of the borehole in this condition. Because conventional bores in general are installed straight along a horizontal plane, the bore pits must be excavated to a depth sufficient to allow installation of pipe at the appropriate depth beneath the streambed (i.e., 5 feet beneath the streambed) and to account for the height of the boring machinery. Where waterbodies are entrenched or adjacent slopes are steep, excavation to sufficient depths can require excessively large pits to address Occupational Safety and Health Administration shoring requirements, which creates the potential to sink the stream or flood the bore pits. These considerations limit the use of this crossing method for entrenched waterbodies or those with steep slopes. Cofferdam Some waterbodies will be crossed using the cofferdam method. In this method, a temporary diversion structure is installed from the bank around half the width of the crossing to isolate that section of the stream from the rest of the waterbody. Once the temporary diversion structure is installed, water is pumped from the isolated section to allow excavation of the pipe trench from the bed of the waterbody in the dry. After the pipe is installed in the trench in the isolated section of stream, the temporary diversion structure is disassembled and reinstalled from the opposite bank of the crossing and the process is repeated. The cofferdam method allows waterbodies to be crossed in the dry in discrete sections while water flows unimpeded around the temporary diversion structure. The method is sometimes favored for wide, relatively shallow waterbodies or waterbodies containing sensitive fisheries because it allows water and fish to pass around the temporary diversion structure. For waterbodies crossed using the cofferdam method, sections of steel frame for the temporary diversion structure will be assembled in an upland area adjacent to the crossing. Depending on size, the frame sections will be placed in the waterbody either manually Atlantic Coast Pipeline 21 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District or by crane. The frame sections will be positioned around a predetermined perimeter in the waterbody extending from one of the banks. The spacing of frame sections will be based on the depth of the water, but a typical spacing will be 15 to 30 inches. The frame sections may be reinforced, as necessary, with steel poles or other supports to increase stability of the structure, especially in waterbodies with soft substrate. Fabric sheets will then be attached to the top of the frame and unrolled down and out onto the bed of the waterbody on the exterior side of the frame. The fabric sheets will create a liner around the frame with a seal on the bed of the waterbody. The fabric may be covered in soft sediments or sandbags to help create the seal. After the temporary diversion structure is installed, one or more pumps will be used to dewater the area within the temporary diversion structure. Pump intakes will be appropriately screened to prevent entrainment of aquatic species. Water will be discharged to the waterbody outside the structure through an energy -dissipating device to prevent scouring of the bed at locations of discharge. Once dewatering is complete, any fish trapped in the temporary diversion structure will be removed and returned to the flowing waterbody. Construction equipment will enter the isolated section of the waterbody from the adjacent bank. This construction equipment will be used to excavate the trench, install a pre -assembled section of pipe, backfill the trench, and restore the bed as near as practicable to pre -construction contours. The equipment will be removed from the temporary diversion structure via the adjacent bank. After the section of pipeline is installed, the enclosed area within the temporary diversion structure will be flooded. Then the fabric sheets and steel frame sections will be disassembled. The structure will be reinstalled from the opposite bank, with enough overlap of the initial excavation area so that the installed section is accessible for tie-in to the next section of pipe. The dewatering and construction process is then repeated from the opposite bank, to complete the crossing of the waterbody. Horizontal Directional Drill Method The HDD method allows for trenchless construction by drilling a hole beneath a surface feature, such as a waterbody or other unique resource, and installing a prefabricated segment of pipeline through the drill bore. The method avoids disturbance to the surface of the right of way between the entry and exit points of the drill. The method is sometimes used to install pipelines underneath sensitive resources or areas that present difficulties for construction or access using typical installation methods. HDDs can provide certain advantages over typical construction methods, such as avoidance of surface disturbance, riparian tree clearing, or in -stream construction. Right-of-way maintenance will not occur between the HDD entry and exit points. For each HDD crossing, electric grid guide wires will be laid by hand on the ground along the pipeline centerline to create an electromagnetic sensor grid. The grid will be used by the HDD operator to steer the drill head during drilling. The sensor grid will be fabricated by installing several stakes along the drill path and wrapping them with an insulated coil wire. The wire will be energized with a portable generator, which will create a magnetic field that can be used to track the drill bit. No ground or surface disturbing activities will be required for installation of the guide wires; however, in thickly vegetated areas a two- to three-foot wide path Atlantic Coast Pipeline 22 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District may need to be cut with hand tools for the wires. Other methods such as gyroscope guidance systems may be utilized in specific situations as an alternative to electric grid guidance to accommodate the wires. Prior to the final design and selection of the HDD method, geotechnical investigations occur at each proposed crossing to ensure that the underlying geology supports the installation. Minor disturbance may be necessary to conduct this investigation. To complete each HDD, a drill rig will be placed on the entry side of the crossing and a small -diameter pilot hole will be drilled along a predetermined path beneath the waterbody using a powered drill bit. As drilling progresses, additional segments of drill pipe will be inserted into the pilot hole to extend the length of the drill. The drill bit will be steered and monitored throughout the process to maintain the designated path of the pilot hole. Once the pilot hole is complete the hole will be enlarged to accept the pipeline. The HDD may require a drill rig on both sides due to the complexity of the drill, for reasons including but not limited to, length, substrate, noise, or duration. To enlarge the pilot hole, a larger reaming tool will be attached to the end of the drill on the exit side of the hole. The reamer will be drawn back through the pilot hole to the drill rig on the entry side of the hole. Drill pipe sections will be added to the rear of the reamer as it progresses toward the rig, allowing a string of drill pipe to remain in the drill bore at all times. Several passes with progressively larger reaming tools will be required to enlarge the hole to a sufficient diameter to accommodate the pipeline. The final hole will be approximately 12 inches larger than the pipeline to be installed. Throughout the drilling process, a fluid mixture consisting of water and bentonite clay (a naturally occurring mineral) will be pumped into the drill hole to lubricate the bit, transport cuttings to the surface, and maintain the integrity of the drill bore. Water for the mixture will be pumped from the waterbody to the drill site through a hose or temporary network of irrigation - type piping or trucked in from another source. The pump intake will be appropriately screened to prevent entrainment of aquatic species. Small pits may be dug at or near the entry and exit points for the HDD to temporarily store the drilling fluid and cuttings. The fluid and cuttings will be pumped from the pits to an on-site recycling unit where the fluid will be processed for reuse. The pipeline segment (also called a pull section) to be installed beneath the surface feature will be fabricated on the right of way or in the ATWS on the exit side of the crossing while the drill hole is reamed to size. Once assembled, the girth welds of the pull section will be coated with fusion -bonded epoxy. A sacrificial abrasion resistant overlay would be applied over the fusion -bonded epoxy coating at the pipe mill for protection from abrasive materials that may be encountered as the pull section is installed. These coating materials on girth welds will be mixed in an area prepared to contain spills; splash pads, plastic or other material will be placed on the ground in the mixing area to contain any potential spills. Activities will occur in accordance with the SPCC Plan (see Appendix G). The pull section will be inspected and hydrostatically tested prior to installation. A steel bullhead will be welded onto the front end of the pull section to aid in pulling the pipe through the drill hole. After the hole is completed, the Atlantic Coast Pipeline 23 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District pipeline segment will be attached to the drill string on the exit side of the drill bore and pulled back toward the drill rig. As the pipeline is being installed, excess drilling fluid will be collected and disposed of at an approved facility or, as allowed and approved by the agencies and landowner. The HDD drilling fluid is a mixture of bentonite clay (a naturally occurring material) and water. Excess drilling fluid will not be incorporated into soils under any circumstances within or adjacent to habitats with known federally listed plant species. If water is left over from the drilling process, it will be discharged in accordance with the Plan and Procedures and applicable permits into a well -vegetated upland area or an energy dissipation/sediment filtration device, such as a geotextile filter bag or straw bale dewatering structure, at the site. Successful crossings utilizing HDD will result in little to no impact on the surface feature being crossed. If a natural fracture or weak area in the ground is encountered during drilling, an inadvertent return of drilling fluid to the environment could occur. Substrate consisting of unconsolidated gravel, coarse sand, or fractured bedrock could increase the likelihood of an inadvertent return. Depending on the orientation of the natural fracture or substrate, the drilling fluid may move laterally or vertically from the drill hole. If the drilling fluid moves laterally, the release may not be evident on the ground. For an inadvertent return to be evident on the surface there must be a preferential pathway extending vertically from the drill hole to the surface of the ground. The volume of fluid released in an inadvertent return would depend on a number of factors, including the size of the pathway, the permeability of the geologic material, the viscosity of the fluid, and the pressure of the hydraulic drilling system. The drilling fluid is a closed system that is monitored closely for changes in pressure and volume, which may indicate development of an inadvertent return. If a change in pressure is identified, corrective action will occur. Atlantic has prepared a Horizontal Directional Drill Fluid Monitoring, Operations, and Contingency Plan (HDD Plan) which describes the measures to be implemented in the event of an inadvertent return and can be found in Appendix H. If a release occurs on land, including within a wetland, a small pit will be excavated at the release site to contain the spread of the fluid, and a pump will be used to transfer the fluid from the pit into a containment vessel. If an inadvertent return occurs in a waterbody it will be more difficult to contain because the fluid may be dispersed into the water and carried downstream. In this situation, thickening agents such as additional bentonite, cottonseed hulls, or other non -hazardous materials will be added to the drilling fluid, in order to plug the flow path. All drilling fluid additives will be non -hazardous. Once a drilling contractor has been selected and the specific additives are identified, a list of additives will be compiled in site-specific HDD Plans along with appropriate Material Safety Data Sheets and product descriptions. Atlantic will consult with and obtain permission from the appropriate state regulatory agencies regarding the use of additives during the HDD process and confirm that additives will not violate water quality standards. Atlantic will monitor source waters along and near the drill path, such as seeps and springs, for inadvertent returns. Atlantic will implement the measures identified in the HDD Plan to control and clean up the inadvertent return, test the water for water quality, and provide an alternate supply of water to affected landowners until the inadvertent return is remediated. Atlantic Coast Pipeline 24 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District The HDD method is proposed on the AP -2 mainline in North Carolina for the following seven large river crossings (five additional minor tributaries of these rivers would also be crossed via HDD of the major waterbody), pending the results of geotechnical investigations and final engineering: • Roanoke River at approximate MP 9.8 at the Northampton/Halifax County line; • Fishing Creek at approximate MP 33.9 at the Halifax/Nash County line; • Swift Creek at approximate MP 40.6 in Nash County; • Tar River at approximate MP 59.4 in Nash County; • Contentnea Creek at approximate MP 73.6 in Wilson County; • Little River at approximate MP 82.5 in Johnston County; and • Cape Fear River at approximate MP 154.2 in Cumberland County. Atlantic explored use of the HDD method at the Rocky Swamp crossing, but based on geotechnical results, due to heavily weathered bedrock and overlying unconsolidated materials, the likelihood of experiencing an inadvertent release was high. Therefore, the HDD method is not proposed for the Rocky Swamp crossing. Wetlands Construction across wetlands will be conducted in accordance with the Procedures, site- specific modifications to the Procedures requested by Atlantic and approved by the FERC, and additional requirements identified in federal or state wetland crossing permits. Typical methods for construction across wetlands are described below. A list of wetland crossings along the proposed pipeline route within the Wilmington Distict is provided in Appendix C. In accordance with the Procedures, the width of the construction right-of-way will be limited to 75 feet through wetlands, with ATWS on both sides of wetland crossings to stage construction equipment and materials, fabricate the pipeline, and store materials and excavated temporary sidecast material. ATWS will be located in upland areas a minimum of 50 feet from the wetland edge (with the exception of site-specific modifications as requested by Atlantic and approved by the FERC or where adjacent uplands consist of cultivated or rotated cropland or other disturbed land). Wetland boundaries will be clearly marked in the field prior to the start of construction with signs and flagging. Construction equipment working in wetlands will be limited to what is essential for right-of-way clearing, excavating the trench, fabricating and installing the pipeline, backfilling the trench, and restoring the right of way. In areas where there is no reasonable access to the right of way except through wetlands, non-essential equipment will be allowed to travel through wetlands once, unless the ground is firm enough or has been stabilized to avoid rutting. Stabilization may include use of rip -rap or prefabricated timber mats. Temporary stabilization materials placed in the wetlands will be removed during the restoration of the right of way. Clearing of vegetation in wetlands will be limited to trees and shrubs, which will be cut flush with the surface of the ground and removed from the wetland. To avoid excessive disruption of wetland soils and the native seed and rootstock within the topsoil, stump removal, Atlantic Coast Pipeline 25 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District grading, topsoil segregation, and excavation will be limited to the area immediately over the trenchline, except a limited amount of stump removal and grading may be conducted in other areas if required by safety-related issues. Topsoil segregation over the trenchline will only occur if the wetland soils are not saturated at the time of construction. As part of the land clearing process, sediment barriers, such as silt fences or other approved sediment barriers, will be installed and maintained adjacent to wetlands and within ATWS areas as necessary to minimize the potential for sediment runoff. Sediment barriers will be installed across the full width of the construction right-of-way at the base of slopes adjacent to wetland boundaries. Erosion control devices installed across the working side of the right-of- way will be removed during the day when vehicle traffic is present, and will be replaced each night. Alternatively, drivable berms may be installed and maintained across the right-of-way in lieu of silt fences or straw bales. Sediment barriers will also be installed within wetlands along the edge of the right-of-way, where necessary, to minimize the potential for sediment to run off the construction right-of-way and into wetlands outside the work area. If trench dewatering is necessary, it will be conducted in accordance with the Procedures and applicable permits. Silt - laden trench water will be discharged into an energy dissipation/sediment filtration device, such as a geotextile filter bag and straw bale structure, to minimize the potential for erosion and sedimentation. The method of pipeline construction used in wetlands will depend on site-specific weather conditions, soil saturation, and soil stability at the time of construction. If wetland soils are not excessively saturated at the time of construction and can support construction equipment on equipment mats, they will be crossed using conventional open -trench construction. This will occur in a manner similar to conventional upland cross-country construction techniques. In unsaturated wetlands, topsoil from the trenchline will be stripped and stored separately from subsoil. Where wetland soils are saturated or in inundated lowlands areas where soils cannot support conventional pipe -laying equipment, the pipeline may be installed using the push-pull method. This method will involve stringing and welding the pipeline outside of the wetland and excavating and backfilling the trench using a backhoe supported by equipment mats. A prefabricated section of pipeline will be installed in the wetland by equipping it with buoys and pushing or pulling it across the water -filled trench. After the pipeline is floated into place, the floats will be removed and the pipeline will sink into place. In most cases, the pipeline will be coated with concrete or equipped with set -on weights to provide negative buoyancy. Once the pipeline is in place, the trench will be backfilled. The push-pull construction method minimizes the number of equipment passes, reducing wetland impacts and soil compaction in lowland areas. The application of concrete coating will generally occur in contractor yards identified for the Projects. In areas where concrete coating of pipe is required within the construction right of way, the coating activities will occur in accordance with the SPCC Plan. Concrete coating activities will occur a minimum of 100 feet from wetlands, waterbodies and springs, and 300 feet from karst features. Concrete -coated pipe will be installed after the concrete is dried and will not be dispersed when submerged in water. Concrete coating is used to create negative buoyancy Atlantic Coast Pipeline 26 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District along the pipeline when required for waterbody or wetland crossings if necessitated by site- specific conditions. Because little or no grading will occur in wetlands, restoration of contours will be accomplished during backfilling. Prior to backfilling, trench breakers will be installed, where necessary, to prevent subsurface drainage of water from wetlands. Where topsoil is segregated, the subsoil will be backfilled first followed by the topsoil. Topsoil will be replaced to the original ground level leaving no crown over the trenchline. In areas where wetlands overlie rocky soils, the pipe will be padded with rock -free soil or sand before backfilling with native bedrock and soil. Equipment mats, gravel fill, and/or geotextile fabric will be removed from wetlands following backfilling. In addition, trench plugs will be installed at the boundaries of wetlands to prevent sub -surface hydrology from following the trenchline and indirectly removing hydrology from wetlands. Where wetlands are located at the base of slopes, permanent slope breakers will be constructed across the right of way in upland areas adjacent to the wetland boundary. Temporary sediment barriers will be installed where necessary until revegetation of adjacent upland areas is successful. Once revegetation is successful, sediment barriers will be removed from the right of way and disposed of at an approved disposal facility. 4. Jurisdictional Determinations Natural Resource Group, LLC, on behalf of Atlantic, conducted wetland and waterbody surveys for the proposed ACP. Natural Resource Group, LLC contracted with Duncan & Duncan WEST, LLC, Environmental Services Inc., and Woodard & Curran to complete the field efforts. The survey area in North Carolina consists of a 300 -foot -wide corridor approximately 198.7 miles long. Wetland and waterbody surveys have been on-going since June 2014 and will continue until the wetland and waterbody surveys are complete on all land parcels along the proposed pipeline route. As of January 2017, wetland and waterbody surveys in North Carolina for AP -2 and AP -3 are 98 percent complete. Where field surveys were not able to be completed, due to lack of access to properties, a desktop assessment was completed to delineate wetlands and waterbodies using a combination of National Wetlands Inventory data, USGS topographic maps, Soil Survey Geographic Database data, and high resolution aerial photography. Figures A-3 and A-4 of Appendix A show the relative locations of delineated features along the AP -2 and AP -3 lines within North Carolina. The assessment of all wetlands, rivers, streams, open waterbodies (e.g., ponds), and seep points were documented within the survey corridor and based on qualified wetland biologists' best professional judgment and interpretation of the U.S. Army Corps of Engineers 1987 Wetlands Delineation Manual (USACE, 1987), the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Atlantic and Gulf Coastal Plain Region (Version 2.0) (USACE, 2010b), the USACE Regulatory Guidance Letter regarding Ordinary High Water Mark Identification (USACE, 2005), and other applicable USACE guidance documents and regulations. Atlantic Coast Pipeline 27 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Atlantic has applied for a Preliminary Jurisdictional Determination from the USACE identifying wetlands, streams and other waterbodies within the ACP project area. See Appendix B for a copy of the Wetland and Waterbody Survey Report. 5. Project History In addition to the NWP 12, Atlantic is applying for several federal and state permits for ACP. A list of the permits applied for are included in Table 2 below. TABLE 2 Permit Table for the Atlantic Coast Pipeline in North Carolina Agency Permit/Approval/Consultation Filing/Anticipated Filing Date Anticipated Approval Date Federal Federal Energy Regulatory Certificate of Public Convenience and September 18, 2015 September 2017 Commission Necessity under Section 7(c) of the Natural Gas Act Federal Aviation Administration Notice of Proposed Construction or November 2016 October 2017 Authorization Federal Aviation Administration Supplemental Notice November 2016 October 2017 Federal Communications Commission Application for Wireless Telecommunications November 2016 October 2017 Bureau Radio Service Authority National Oceanic and Atmospheric Consultation under Section 7 of the Ongoing September 2017 Administration — National Marine Endangered Species Act and Section 305 of Fisheries Service the Magnuson -Stevens Act National Oceanic and Atmospheric Consultation under the Marine Mammal August 22, 2014 July 1, 2016 Administration — National Marine Protection Act Fisheries Service National Park Service — Blue Ridge Right -of -Way Grant and Special Use Permit to September 17, 2015 September 2017 Parkway cross the Blue Ridge Parkway U.S. Army Corps of Engineers — Department of the Army NWP 12 Verification September 15, 2015 September 2017 Pittsburgh, Pittsburgh, Norfolk, and under Section 404 of the Clean Water Act and Wilmington Districts Section 10 of the Rivers and Harbors Act U.S. Army Corps of Engineers — Department of the Army Permissions under August 2016 September 2017 Norfolk District Section 408 of the Rivers and Harbors Act U.S. Army Corps of Engineers — Department of the Army Permissions under August 2016 September 2017 Wilmington District Section 408 of the Rivers and Harbors Act North Carolina North Carolina Department of Air Permit — Stationary Source Construction September 16, 2015 June 2017 Environment and Natural Resources and Operation Permit for Compressor Station 3 (original) — Division of Air Quality December 15, 2016 (equipment change update) North Carolina Department of General Permit NCG 010000 to Discharge December 2016 3Q 2017 Environment and Natural Resources Stormwater under the National Pollutant — Division of Energy, Mineral, and Discharge Elimination System Land Resources (or approved local government) North Carolina Department of Water Quality Certificate under Section 401 of NA 3Q 2017 Environment and Natural Resources the Clean Water Act (including permission to — Division of Water Resources use State-owned bottom lands) North Carolina Department of Isolated and Other Non -404 Jurisdictional September 15, 2015 3Q 2017 Environment and Natural Resources Wetlands and Waters Permit (including — Division of Water Resources permission to use State-owned bottom lands) North Carolina Department of Buffer Authorization (for riparian zone September 15, 2015 3Q 2017 Environment and Natural Resources disturbance) — Division of Water Resources Atlantic Coast Pipeline 28 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District TABLE 2 Permit Table for the Atlantic Coast Pipeline in North Carolina Agency Permit/Approval/Consultation Filing/Anticipated Filing Date Anticipated Approval Date North Carolina Department of Natural Heritage/Protected Species Ongoing 3Q 2017 Environment and Natural Resources Consultation — Natural Heritage Program North Carolina State Historic Consultation under Section 106 of the National Ongoing 3Q 2017 Preservation Office Historic Preservation Act North Carolina Wildlife Commission Protected Species Consultation October 13, 2014 3Q 2017 County/City/Local Floodplain Permit (expected to be required in 2Q 2017 — 3Q 2017 2Q 2017 — 3Q 2017 all Counties and Cities along the routes) County/City/Local Special or Conditional Use Permit (where 2Q 2017 3Q 2017 required) Table includes all applications for the Wilmington District. 6. Future Project Plans See Section B.6 of the PCN Form. C. PROPOSED IMPACTS INVENTORY The ACP pipeline facilities, access roads, and aboveground facilities will require a total of 549 single and complete projects across waters of the U.S. in North Carolina, detailed within Appendix C -l. Appendix C provides details of wetlands that include location information, HUC 8 codes, wetland type classifications, and an analysis of impacts proposed, and details of waterbodies that include location information, HUC 8 codes, state special designations, tributary information, and an analysis of impacts proposed. AP -2 and AP -3 cross a total of 10 HUC 8 watersheds across North Carolina. The HUC 8 watersheds and the impacts anticipated for wetlands and waterbodies crossed by the pipeline workspace are summarized in tables 3 and 4, below. No permanent loss to wetlands or waterbodies is anticipated for mainline pipeline construction or associated facilities. However, permanent loss impacts to 1.72 acres of wetlands are proposed for construction and improvements to permanent access roads in the Wilmington District, as discussed below in the subsection on Access Roads and Aboveground Facilities. Outside of the 30 -foot maintained right-of-way, Atlantic will replant non -inundated forested deciduous hardwood wetlands. Temporary wetland impacts, conversion of type impacts, and permanent losses are noted below for HUC 8 watersheds and in Appendix C-1 for individual projects (crossings). A summary of single and complete projects can be found in Appendix C-2. Table 3 provides a summary of the proposed wetland impacts within eight -digit HUC watersheds crossed by the ACP in the Wilmington District. Atlantic Coast Pipeline 29 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District Atlantic Coast Pipeline 30 DRAFT TABLE 3 Atlantic Coast Pipeline Project - U.S. Army Corps of Engineers Wilmington District HUC 8 Wetland Impacts Table Cowardin Crossing Length Temporary Impacts Conversion Impacts Permanent Loss HUC 8 Watershed Classification' (feet) (acre)b (acre)' (acre) 03010107 PEM 374 0.84 0.00 0.00 PFO 4,118 8.43 2.87 0.00 PSS 135 0.34 0.03 0.00 Subtotal 4,626 9.60 2.91 0.00 03010204 PEM 4,003 4.33 0.00 0.00 PFO 9,983 22.05 7.99 0.01 PSS 219 0.57 0.05 0.00 Subtotal 14,204 26.96 8.04 0.01 03020101 PEM 702 1.39 0.00 0.00 PFO 23,719 40.74 16.03 0.06 PSS 116 0.21 0.03 0.00 Subtotal 24,537 42.91 16.41 0.06 03020102 PEM 1,856 3.42 0.00 0.13 PFO 19,628 34.24 13.54 0.20 PSS 3,531 6.34 0.81 0.00 Subtotal 25,015 44.00 14.36 0.32 03020201 PEM 714 1.34 0.00 0.00 PFO 44,342 81.00 30.53 0.79 PSS 2,340 4.48 0.54 0.03 Subtotal 47,396 86.82 31.06 0.82 03020203 PEM 139 0.18 0.00 0.00 PFO 24,929 44.31 17.15 0.05 PSS 360 0.65 0.08 0.00 Subtotal 25,428 45.14 17.23 0.05 03030004 PEM 91 0.57 0.00 0.00 PFO 5,196 9.83 3.57 0.06 PSS 257 0.46 0.06 0.00 Subtotal 5,545 10.86 3.63 0.06 03030005 PEM 0.00 0.43 0.00 0.00 PFO 17,571 30.37 12.03 0.00 PSS 978 1.81 0.23 0.00 Subtotal 18,549 32.61 12.25 0.00 03030006 PEM 1,518 4.67 0.00 0.03 PFO 34,727 57.77 23.40 0.00 PSS 10,342 17.84 2.37 0.37 Subtotal 46,587 80.28 25.78 0.41 03040203 PEM 1,564 2.58 0.00 0.00 PFO 30,859 55.30 21.26 0.00 PSS 10,611 18.81 2.43 0.00 Subtotal 43,035 76.12 23.35 0.00 Project Total 254,922 455.30 155.01 1.72 ' Indicates Cowardin classification. PEM - emergent, PSS - scrub -shrub, PFO - forested. b Temporary impacts include all permanent, temporary, and extra temporary workspace. ° Conversion of PFO and PSS wetlands consists of acreage that will be maintained as herbaceous/scrub-shrub wetlands following construction to facilitate inspection and maintenance of the pipeline. Note: The totals shown in this table may not equal the sum of addends due to rounding Atlantic Coast Pipeline 30 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Table 4 provides a summary of the waterbody impacts by eight -digit HUC watersheds crossed by the ACP. TABLE 4 Atlantic Coast Pipeline Project -- U.S. Army Corps of Engineers Wilmington District HUC 8 Waterbody Impacts in North Carolina HUC 8 Watershed Waterbody Type Total Count Approximate Crossing Width (feet) Affected Length (feet) 03010107 Ephemeral 1 3 124 Intermittent 11 65 1,372 Perennial 11 418 944 Open Water 2 N/A N/A Subtotal 25 486 2,440 03010204 Ephemeral 4 19 344 Intermittent 7 27 440 Perennial 8 115 846 Subtotal 19 161 1,630 03020101 Ephemeral 1 3 767 Intermittent 9 44 900 Perennial 30 619 3,194 Open Water 1 N/A N/A Subtotal 41 666 4,861 03020102 Ephemeral 1 0 107 Intermittent 18 67 1,969 Perennial 12 264 1,814 Subtotal 31 332 3,890 03020201 Ephemeral 4 7 560 Intermittent 21 87 3,110 Perennial 16 348 1,549 Open Water 4 N/A N/A Subtotal 45 442 5,219 03020203 Ephemeral 11 33 1,296 Intermittent 12 60 1,201 Perennial 15 198 1,829 Open Water 3 N/A N/A Subtotal 41 291 4,326 03030004 Ephemeral 4 11 412 Intermittent 10 44 1,262 Perennial 10 147 999 Open Water 1 N/A N/A Subtotal 25 203 2,672 03030005 Ephemeral 5 23 1,097 Intermittent 15 81 1,677 Perennial 14 506 1,474 Subtotal 34 610 4,247 03030006 Ephemeral 7 27 835 Intermittent 11 46 901 Perennial 14 467 1,752 Open Water 2 N/A N/A Subtotal 34 539 3,488 03040203 Ephemeral 5 26 510 Intermittent 17 80 2,014 Perennial 7 128 724 Open Water 2 N/A N/A Subtotal 31 233 3,248 Project Total 326 39964 36,022 Note: The totals shown in this table may not equal the sum of addends due to Atlantic Coast Pipeline 31 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Access Roads and Aboveground Facilities Impacts resulting in loss of waters of the U.S. are not anticipated as a result of mainline pipeline construction. However, loss of waters of the U.S. will occur as a result of permanent access road construction and improvements, where necessary. Existing access roads will be utilized where feasible. Where improvements are necessary for use, loss impacts to waters of the U.S. have been minimized to the maximum extent practicable, and kept below 0.5 acre for each single and complete projects. Atlantic has designed access roads to minimize impacts on waterbody and wetlands. Culverts will be installed to conform to NWP Regional Condition 3.6 Safe Passage Requirements for Culvert Placement. Since the project does not cross coastal counties the primary conditions include: proper sizing of culverts based on average historical low flow and spring flow to minimize potential for altering the stream channel, and constructed in a manner that minimizes destabilization and head cutting. Where culverts over 48 inches in diameter are utilized the culvert will be buried at least one foot below the bed of the stream, and other culvers should be placed on the stream bed or buried to maintain aquatic passage. Where these requirements cannot be met a waiver will be requested. Aboveground facilities (i.e., compressor stations, M&R stations, and valves) have been sited to avoid permanent wetland loss. 1. Impacts Summary Ia. See Section Cla of the PCN Form. 2. Wetland Impacts Impacts on wetlands are summarized in Tables 3 above, and provided in detail in Appendix C-1. 3. Stream Impacts Impacts on waterbodies are summarized in Table 4 above, and provided in detail in Appendix C -l. Site specific plans for Section 10 waters are provided in Appendix F. Section 10 waters within the Wilmington District include: • Roanoke River at Milepost 9.8 • Neuse River at Milepost 98.5 • Cape Fear River at Milepost 154.2 4. Open Water Impacts Impacts on Open Waters are summarized in Tables 4 above, and provided in detail in Appendix C-1. Atlantic Coast Pipeline 32 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 5. Pond or Lake Construction No pond, lake, or impoundments are proposed to be constructed as part of ACP in North Carolina. Temporary above -ground structures designed to hold water for hydrostatic testing will be installed adjacent to water source withdrawal areas and outside of waterbody channels. These water holding containments will be filled by mechanical pumps from nearby waters. Therefore, NWP 2017-2022 condition 8, which refers to impoundment of "waters of the U.S." and NWP 2017-2022 condition 24, which refers to dam safety are not applicable to the Project. 6. Buffer Impacts (for DWQ) AP -2 will cross riparian buffer zones within the Neuse and Tar -Pamlico river basins. Based on coordination with NCDEQ, Waterbodies subject to the buffer rules are provided in Table 5 below. Atlantic has worked closely with the NCDEQ staff to field verify waterbodies that are subject to the buffer rule in the Neuse and Tar -Pamlico basins. On November 23, 2016 Atlantic submitted a compiled package of correspondence to the NCDEQ that documents waterbodies subject to the riparian buffer rule. Subsequent to this submittal additional site visits were completed and NCDEQ replied with an additional letter. Documentation of site visits and subject waters determinations are compiled for NCDEQ convenience in Appendix I. Atlantic utilized the determinations made with the NCDEQ to further evaluated impacts within the buffers of subject waterbodies. According to 15A North Carolina Administrative Code 2B.0233 (Neuse watershed) for waterbodies that are subject to the buffer rule, the treatment of the buffer depends on whether or not the crossing is perpendicular to the waterbody.6 Table 5 provides a summary of buffer Zone 1 and Zone 2 impacts for all waterbodies subject to the rule, and provides a determination of those waterbodies that are perpendicular versus not perpendicular. 6 Perpendicular crossings are defined as those that intersect the surface water at an angle between 75° and 105° Atlantic Coast Pipeline 33 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District Atlantic Coast Pipeline 34 DRAFT TABLE5 North Carolina Buffer Impacts Zone 1 Permanent/T Requires Zone 2 (Square emporary Buffer (Square Required Watershed MP Unique M Perpendicular Feet) Impact Mitigation Feet) Mitigation Tar -Pamlico 18.5 shlb050 N/A 9,723 T N 6,800 N/A 18.5 shlg009 No 46,549 T Y 29,311 139,647 20.0 shlh008 No 4,673 T Y 3,120 14,020 20.5 shlh007 No 7,349 T Y 4,996 22,048 22.8 shlh016 No 6,006 T Y 4,678 18,018 23.1 shlh017 No 5,446 T Y 4,422 16,337 24.0 shlg012 Yes 5,958 T N 4,060 N/A 25.0 shlb100 Yes 5,220 T N 3,536 N/A 26.5 shlh009 No 5,105 T Y 3,541 15,315 27.4 shlh011 No 8,733 T Y 5,723 26,200 27.7 shlh012 Yes 4,620 T N 3,071 N/A 29.8 shla001 No 5,509 T Y 3,950 16,526 31.2 shlo001 N/A 2,032 T N 3,741 N/A 31.2 shlo002 Yes 4,543 T N 3,216 N/A 33.4 shlh022 N/A 1,954 T N 1,248 N/A 33.8 shlg011 No 3,053 T Y 2,052 9,160 34.0 snag001 No 3,296 T Y 2,207 9,887 34.8 snag002 Yes 4,514 T N 3,553 N/A 40.4 snah002 Yes 7,708 T N 5,343 N/A 40.6 snah003 No 3,275 T Y 2,145 9,824 40.9 snah006 No 6,770 T Y 4,718 20,310 41.6 snah005 Yes 5,564 T N 3,959 N/A 41.7 snah004 No 5,661 T Y 3,897 16,983 42.0 snah029 Yes 5,035 T N 3,302 N/A 42.1 snah025 No 12,283 T Y 6,166 36,849 42.2 snah026 No 7,249 T Y 4,483 21,746 42.8 snab 103 Yes 5,429 T N 4,081 N/A 44.0 snab104 N/A 2,053 T N 2,942 N/A 44.4 snabl05 N/A 1,548 T N 2,720 N/A 44.5 snac001 No 7,715 T Y 6,780 23,145 44.8 snag012 No 5,936 T Y 5,495 17,808 45.4 onac002 N/A 0 T N 654 None 47.2 snah008 No 7,637 T Y 5,024 22,912 47.6 snah010 Yes 8,433 T N 4,857 None 48.8 snah015 a New Feature New Feature New Feature New Feature New Feature New Feature 49.5 snah017 No 9,351 T Y 6,041 28,054 50.3 snag006 N/A 937 T N 2,361 None 50.8 snag005 No 9,164 T Y 7,834 27,491 51.5 snag009 No 12,855 T Y 9,275 38,564 51.6 snag009 No 12,855 T Y 9,275 38,564 52.0 onag002 N/A 505 T N 2,098 None 52.0 snab101 N/A 1,697 T N 1,597 None 53.3 snah021 No 6,260 T Y 3,595 18,780 54.8 snah020 No 4,874 T Y 3,419 14,622 56.3 snah024 Yes 7,048 T N 3,410 None 56.7 snah022 No 21,475 T Y 9,286 64,425 57.1 snah019 No 5,555 T Y 4,073 16,665 58.8 snap004 Yes 5,404 T N 4,479 None Atlantic Coast Pipeline 34 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District Atlantic Coast Pipeline 35 DRAFT TABLE5 North Carolina Buffer Impacts Zone 1 Permanent/T Requires Zone 2 (Square emporary Buffer (Square Required Watershed MP Unique M Perpendicular Feet) Impact Mitigation Feet) Mitigation 59.4 snao011 No 4,098 T Y 2,716 12,293 Neuse 63.3 snao004 Yes 4,740 T N 3,274 None 66.0 swio015 No 7,326 T Y 5,521 21,978 66.3 swio016 No 13,144 T Y 9,232 39,433 66.9 swio014 a New Feature New Feature New Feature New Feature New Feature New Feature 67.8 swio002 Yes 4,850 T N 3,129 None 69.1 swic004 N/A 522 T N 1,820 None 69.3 swio005 No 5,981 T Y 3,854 17,943 69.4 swio004 No 17,646 T Y 11,908 52,939 69.7 swio007 Yes 5,030 T N 3,923 None 70.4 swio009 Yes 5,782 T N 4,006 None 70.5 swio008 No 6,419 T Y 4,963 19,258 71.0 swio011 No 5,594 T Y 3,991 16,783 71.0 swio012 Yes 4,564 T N 3,033 None 71.0 swio013 No 17,774 T Y 11,592 53,321 72.3 swic001 No 7,852 T Y 5,780 23,556 73.1 swib100a No 10,019 T Y 8,712 30,056 73.2 swib100b No 7,405 T Y 4,792 22,216 73.3 swib100c Yes 6,970 T N 4,792 None 73.6 swic002 No 4,240 T Y 2,776 12,719 75.8 swip009 N/A 3,040 T N 5,050 None 75.8 swip017 No 5,057 T Y 4,354 15,172 79.2 sjobl03 No 22,356 T Y 18,709 67,068 79.3 sjobl03 No 22,356 T Y 18,709 67,068 79.5 sjob104 No 5,934 T Y 4,733 17,801 82.5 sjoe002 Yes 3,209 T N 2,148 None 83.5 sjoe006 Yes 10,217 T N 5,015 None 84.5 sjop001 No 8,139 T Y 5,125 24,418 85.9 sjoo003 Yes 4,552 T N 3,028 None 86.5 sjoo004 No 7,891 T Y 4,914 23,674 88.9 sjop005 No 8,634 T Y 7,744 25,901 89.8 sjop007 Yes 6,816 T N 3,897 None 91.2 sjop009 N/A 1,740 T N 9,187 None 92.1 sjop010 Yes 6,606 T N 4,796 None 95.1 sjob011 No 5,412 T Y 4,561 16,237 95.3 sjop018 N/A 13,332 T N 10,872 None 98.5 sjob105 Yes 6,761 T N 4,515 None 102.4 sjob006 No 8,011 T Y 5,269 24,032 102.8 sjob004 No 5,818 T Y 4,567 17,453 103.9 sjob003 Yes 4,897 T N 3,143 None 107.7 sjob001 N/A 0 T N 2,111 None 110.3 sjop017 N/A 839 T N 2,233 None 113.1 sjoo007 No 6,670 T Y 4,227 20,009 113.7 sjoe007 N/A 222 T N 5,745 None a Feature extended subsequent to agency field review, requires confinnation with NCDEQ. Atlantic Coast Pipeline 35 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District D. IMPACT JUSTIFICATION AND MITIGATION 1. a.1 Avoidance and Minimization For purposes of the USACE evaluation of single and complete projects, the "alternatives analysis" is to ensure that the crossing of each wetland, stream and other waterbody is made in a manner that avoids and minimizes impacts on the aquatic environment to the maximum extent practicable, after considering the approach to the crossing in the uplands immediately adjacent to the water of the United States. For example, to the extent practicable, crossings will be perpendicular to the aquatic feature to minimize the length of the pipeline in the particular aquatic system. The FERC NEPA process includes the evaluation of alternative route alignments that reduce the overall impacts on the human environment of the proposed pipeline including avoiding and minimizing impacts to wetlands, streams, and other waterbodies. In addition all crossings within the Wilmington District have been designed to meet NWP 12 criteria also resulting in further avoidance and minimization of impacts. As background, information on the FERC alternatives analysis follows, including discussion of the various alternatives FERC is considering. The USACE is a cooperating agency on the FERC NEPA EIS and is working with FERC to ensure that USACE comments regarding the overall pipeline alternatives analysis are fully considered in that process. The fact that the ACP will be subject to an EIS does not preclude the use of NWP 12 for the affected waterbody crossings. As provided for in the USACE 2012 NWP Federal Register (FR) final NWPs: "One commenter requested clarification that individual permits are not automatically required for NWP 12 activities when a Corps district participates as a cooperating agency for an environmental impact statement. [Response] "Even though an environmental impact statement may be prepared for a particular utility line, the National Environmental Policy Act process does not prohibit the Corps from using NWP 12 to authorize the construction, maintenance, repair, and removal of utility lines and associated facilities in waters of the United States, as long as the activity complies with all applicable terms and conditions and results in minimal individual and cumulative adverse effects on the aquatic environment. NEPA requires consideration of all environmental impacts, not only those to aquatic resources, so there may well be situations where aquatic impacts are minimal even though environmental impacts more generally are not. These other environmental impacts would be addressed by the lead agency preparing the environmental impact statement. " [77 FR, Vol 77, No. 34] Atlantic will restore the wetlands to preconstruction elevations and will re -vegetate emergent, scrub -shrub and forested wetlands within the 75 -foot construction corridor. In addition, Atlantic has placed the following additional protective language into the landowner easement agreements on parcels which contain waters of the US that are being negotiated for the pipeline project. This language has been reviewed and approved by Wilmington District. `7f Local, State or Federally -regulated waters or wetlands (collectively and individually "Regulated Waters or Wetlands') within the Permanent Easement or Temporary Easement are disturbed by Grantee, Grantor acknowledges that Grantee may be required by law to restore Atlantic Coast Pipeline 36 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District and/or re -vegetate any such disturbed Regulated Waters or Wetlands. Additionally, Grantor agrees to: (a) cooperate with Grantee to ensure any such restored or re -vegetated Regulated Waters or Wetlands are maintained as required by applicable laws; (b) notify Grantee in advance of any proposed plans to disturb any Regulated Waters or Wetlands within the Permanent Easement or Temporary Easement; and (c) notify Grantee of Grantor's efforts to obtain any required permits, permit modifications and/or approvals, prior to conducting any proposed disturbance of Regulated Waters or Wetlands within the Permanent Easement or Temporary Easement. Grantor agrees that any permitting and/or disturbance of Regulated Waters or Wetlands by Grantor within the Permanent Easement or Temporary Easement, including any required mitigation and/or penalties, will be at Grantor's own risk and cost. " FERC NEPA ALTERNATIVES ANALYSIS INFORMATION For purposes of the USACE evaluation of single and complete projects, the "alternatives analysis" is to ensure that the crossing of each wetland, stream and/or other waterbody is made in a manner that avoids and minimizes impacts on the aquatic environment to the maximum extent practicable, after considering the approach to the crossing in the uplands immediately adjacent to the water of the United States. For example, to the extent practicable, crossings will be perpendicular to the aquatic feature to minimize the length of the pipeline in the particular aquatic system. As background, information on the FERC alternatives analysis follows, including discussion of the various alternatives FERC is considering. Within the sections below, the numbering of many of the referenced tables and figures has not been changed from their numbering in the FERC documentation, to maintain consistency across documents (e.g., Table 10.8.1-1, Figure 10.8.1-1, etc.).Atlantic has identified and evaluated a number of alternatives to the proposed ACP. These include a no -action alternative; alternative energy sources, including traditional and renewable sources; energy conservation measures; systems alternative; and conceptual collocation route alternatives. 2. a.2 NEPA Alternatives from FERC Documentation No Action Alternative to the ACP Under the no -action alternative, the ACP would not be built and the environmental impacts associated with construction and operation of the proposed facilities would not occur. By not constructing this Project, however, Atlantic would be unable to meet its existing customers' demands for natural gas and the projected demand by other industrial, commercial, and domestic customers (including power -generating facilities) in Virginia and North Carolina. The projected demand is due to a combination of population growth and displacement of coal- fired electric power generation. In addition, other benefits from the ACP, such as future economic development opportunities, reduced energy costs in the region, and the repowering of coal-fired electric generation to gas-fired electric generation, would not be realized. Under the no -action alternative, other natural gas transmission companies could propose to construct new facilities similar to the ACP to meet the demand for new natural gas transportation service in Virginia and North Carolina. Such actions would likely result in Atlantic Coast Pipeline 37 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District impacts similar to or greater than those associated with the ACP, and might not meet Atlantic's objectives to satisfy demand from existing customers within the proposed time frames. For these reasons, the no -action alternative is not practical and provides no advantage over the Project. Alternative Energy Sources to the ACP The use of alternative energy sources is an option to meet some of the short-term and long-term demands for energy in the target market areas. Potential alternative energy sources to natural gas include traditional fuels, such as coal and oil, nuclear energy, and electricity (including electricity generated from oil, coal, and nuclear power); and renewable energy sources, such as wind, solar, hydroelectric, biomass, and tidal and wave. Like the ACP, all of these alternative energy sources, depending on the location of the source, would require new infrastructure, including transmission facilities, to connect supply and demand areas. Additional information regarding the analysis of alternative energy sources is available in Resource Report 10, Alternatives, filled with FERC as part of the licensing documentation, which is available through the FERC Project Docket (No. CP 15-554-000) to all cooperating agencies, including the USACE. Energy Conservation to the ACP Energy conservation could help alleviate some of the growing demand for energy in the United States and in the states/commonwealths to be serviced by the ACP. State/ commonwealth and federal energy conservation measures will likely play an important role in slowing the growth of energy demand in the coming decades. However, it is unlikely that these measures will offset the demand for new natural gas sources. The EIA predicts that United States energy use per capita will decrease by approximately 8 percent through 2040, as higher efficiency standards for vehicles and appliances take effect. Nevertheless, the EIA indicates that, even with the recently enacted energy efficiency policies, total primary energy consumption, including fuels used for electricity generation, will grow by 8.9 percent from 2013 to 2040. To meet this demand, the EIA predicts that total domestic production of natural gas in the United States will grow from 24.4 trillion cubic feet per year in 2013 to 35.5 trillion cubic feet per year by 2040, and that shale gas production will make up 53 percent of total United States production in 2040, up from 40 percent in 2012. The anticipated growth in natural gas demand will be driven primarily by its increased use for electric power generation and industrial applications. Reduction in the need for additional energy is the preferred option wherever possible. Conservation of energy reduces the demand for limited existing reserves. Although energy conservation measures will be important elements in addressing future energy demands, it is unlikely that they will be able to offset more than a fraction of anticipated demand in the foreseeable future. As a result, energy conservation alone (or in conjunction with other alternatives) is not a viable alternative because it does not preclude the need for natural gas infrastructure projects like the ACP to meet the growing demand for energy. U.S. Energy Information Administration. 2015. Annual Energy Outlook 2015 with Projections to 2040. U.S. Department of Energy, Washington, District of Columbia. Atlantic Coast Pipeline 38 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District System Alternatives to the ACP System alternatives would make use of other existing, modified, or proposed pipeline systems to meet the same objectives as the ACP. Use of a system alternative would make it unnecessary to construct all or part of the ACP, though modifications or additions to existing or proposed systems could be required. The modifications or additions would result in environmental impacts that could be less than, similar to, or greater than those associated with the ACP. Several existing, high-pressure, high-volume natural gas pipeline systems provide transportation services to delivery points in the Mid -Atlantic and southeast regions. These include Transco; Columbia Gas Transmission, LLC (Columbia); and East Tennessee Natural Gas, LLC. Additionally, several new pipeline projects have been proposed to provide natural gas transportation service in the same regions, including the Spectra Energy Carolina Pipeline Project; Mountain Valley, LLC Mountain Valley Pipeline Project; and Transco Appalachian Connector Pipeline Project. Significant modifications to each of these systems would be necessary to access the same supply areas and/or provide transportation service to the same customers or at the same delivery points as the ACP. The environmental impacts associated with the upgrades and new pipeline construction modifying existing or proposed systems would likely be equal to or greater than those of the ACP. Therefore, the theoretical modifications to the existing systems or proposed systems would provide no environmental advantage over the ACP. For this reason, and the fact that the existing system does not meet the ACP's purpose and need, these system alternatives are not considered viable alternatives to ACP. Conceptual Route Alternatives Where practical, and depending on site-specific conditions, new natural gas transmission pipelines can sometimes be collocated with existing linear corridor facilities (e.g., other pipelines, electric transmission lines, highways, or railroads) to minimize impacts on environmental and other resources. A pipeline is considered collocated with an existing linear corridor facility if the new right-of-way for the pipeline is adjacent to or very near (within a few hundred feet) of the existing facility. A pipeline can parallel an existing linear corridor facility without being collocated with the existing facility, but this often results in multiple clear -cuts along similar paths with no reduction in impacts on environmental and other resources. The three criteria listed below are generally used to identify and evaluate opportunities to route a new natural gas transmission pipeline adjacent to existing linear corridor facilities. • The location and orientation of existing facilities relative to the new pipeline. The existing facilities must provide a relatively direct path between the proposed receipt and delivery points for the new pipeline. Otherwise, routing adjacent to these existing facilities increases the length of the pipeline, which results in greater environmental impact and added cost to the project. • The nature of terrain along existing facilities. In some areas, the landforms crossed may not allow for the construction of a pipeline adjacent to an existing Atlantic Coast Pipeline 39 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District facility due to factors such as side slope, limitations on the amount of space available for new construction, or the orientation of landforms crossed. • The nature of land uses along the existing facilities. Developed lands (including residential, commercial, and industrial lands) are often found along linear corridor facilities such as highways and railroads. Routing a new pipeline to avoid these developed areas often results in parallel (as opposed to adjacent) alignments and increases the length (and therefore the environmental impact and cost) of a new pipeline. In addition to these conceptual alternatives, Atlantic evaluated potential collocation alternatives for the ACP in areas where existing pipelines, electric transmission lines, or roads either intersect or run parallel to and near the proposed ACP. Potential route alternatives and variations adjacent to existing facilities which would meet the purpose and need of the ACP and avoid or minimize impacts are discussed below. Desktop review of other potential collocation route alternatives identified significant impediments with the routes with regard to terrain, existing developments, or increased length of the ACP. Eastern and Western Conceptual Route Alternatives During the initial planning stages for the ACP, Atlantic identified and evaluated two conceptual route alternatives: an eastern route alternative and a western route alternative (Figure 10.8.1-1). Both routes originate south of Clarksburg in West Virginia and terminate near Lumberton in North Carolina, with laterals extending to Hampton Roads in Virginia and Clayton in North Carolina. Comparative information on each route is provided in Table 10-8.1-1. The eastern route alternative, including the laterals, measures approximately 538.0 miles in length, of which 22.6 miles is adjacent to existing linear corridor facilities. It crosses approximately 66.4 miles of Federal lands, including lands managed by the U.S. Forest Service, U.S. Fish and Wildlife Service (FWS), U.S. Army, and National Park Service. The eastern route crosses both the Blue Ridge Parkway and Appalachian Trail on Federal lands. The route crosses 2.8 miles of state/commonwealth lands, 12.2 miles of conservation easements, 328 miles of forested land, 60.6 miles of wetland, and 362 perennial waterbodies. It additionally crosses 13.5 miles of areas identified as historic properties, historic landscapes, or historic landmarks, consisting mostly of Civil War battlefields. The western route alternative, including the laterals, measures approximately 607.2 miles in length, of which 16.8 miles is adjacent to existing linear corridor facilities. The route crosses 68.4 miles of Federal lands, including lands managed by the U.S. Forest Service, FWS, U.S. Army, USACE, and National Park Service. Like the eastern route alternative, the western route crosses both the Blue Ridge Parkway and Appalachian Trail on Federal lands. It crosses 7.0 miles of State/Commonwealth lands, 18.3 miles of conservation easements, 414.7 miles of forested lands, 45.7 miles of wetland, and 425 perennial waterbodies. It also crosses 10.4 miles of areas identified as historic properties, historic landscapes, or historic landmarks, mostly Civil War battlefields. Relative to the eastern route alternative, the western route alternative is approximately 69.2 miles longer and crosses 2.0 more miles of Federal lands, including lands managed by the Atlantic Coast Pipeline 40 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District USACE, which the eastern route avoids. Both routes cross the Blue Ridge Parkway and Appalachian Trail on Federal lands. The western alternative crosses 4.2 more miles of State/Commonwealth land and 6.1 more miles of conservation easements than the eastern alternative. The western alternative crosses 15.0 miles less of wetland and 3.1 miles less of historic places, but 85.9 more miles of forested land and 63 more perennial waterbodies than the eastern route. TABLE 10.8.1-1 Eastern and Western Route Alternatives for the Atlantic Coast Pipeline Features Unit Eastern Route' Western Route Length miles 538.0 607.2 Primary U.S. or State/Commonwealth highways crossed number 115 103 Adjacent to existing linear corridor facilities miles 22.6 16.8 Federal lands crossed (total) miles 66.4 68.4 National Park Service miles 0.6 0.4 U.S. Forest Service miles 46.9 44.0 U.S. Fish and Wildlife Service miles 72 7.2 U.S. Army miles 11.7 14.0 U.S. Army Corps of Engineers miles 0.0 2.8 Blue Ridge Parkway crossings number 1 1 Appalachian Trail crossings number 1 1 State/Commonwealth lands crossed (total) miles 2.8 7.0 West Virginia miles 0.0 0.0 Virginia miles 0.2 0.0 North Carolina miles 2.6 7.0 Conservation easements crossed miles 12.2 18.3 Forested lands crossed miles 328.8 414.7 National Wetland Inventory wetlands crossed (total) miles 60.7 45.7 Forested miles 55.0 40.1 Emergent miles 4.7 4.0 Other miles 1.0 1.6 Intermittent waterbodies crossed number 342 481 Perennial waterbodies crossed number 362 425 Historic properties, historic landscapes, and historic landmarks crossed miles 13.5 10.4 The eastern route alternate is similar, but not identical, to the baseline route for the ACP. The eastern route alternative was refined into the baseline route based on customer needs and identification of delivery points for the ACP. In addition, after the receipt and delivery points were confirmed for the ACP, it was determined that the western route alternative does not provide a direct connection to the delivery point in Randolph, County, West Virginia (i.e., the Long Run M&R Station), or to the receipt and delivery point in Buckingham County, Virginia (i.e., Compressor Station 2). Additional laterals would need to be built to reach these locations if the western route was selected as the preferred alternative. Depending on the routes selected, these laterals would add an additional 75 to 85 miles of pipeline to the ACP, which would result in greater environmental impact and additional cost. For all these reasons, Atlantic identified the eastern route as the preferred alternative for the ACP. This route subsequently was refined into the baseline route for the ACP. Atlantic Coast Pipeline 41 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Southern Conceptual Route Alternative The southern conceptual alternative route originates approximately at MP 6.0 of the currently proposed AP -3 lateral route in Northampton County, North Carolina (see Figure 10.8.1-20). From this point, the conceptual route heads due east for approximately 64 miles crossing Northampton, Hertford, Gates, Pasquotank, and Camden Counties, North Carolina, passing south of the Great Dismal Swamp National Wildlife Refuge (GDS-NWR) and Dismal Swamp State Park. The conceptual route then heads north for approximately 20 miles, crossing Camden County, North Carolina and the City of Chesapeake, Virginia, passing east of the GDS-NWR. The route terminates approximately at MP 79.2, on the east side of the Southern Branch Elizabeth River. The conceptual route is approximately 13 miles longer than the corresponding segment of the GDS 1 route. Although the southern conceptual route alternative avoids the GDS-NWR, construction along this route would result in an additional 13 miles of impacts, including crossings of many miles of wetlands along the Chowen River, in the area south of the Dismal Swamp State Park, and along the Pasquatank River. Based on National Wetlands Inventory data, the southern conceptual route crosses approximately 30.6 miles of wetlands, while the corresponding segment of the currently proposed route crosses approximately 20.1 miles of wetlands. The southern conceptual route additionally crosses large blocks of land identified by The Nature Conservancy (TNC) as sensitive floodplain forest in areas south and east of the GDS-NWR. Also, the southern conceptual route alternative is almost entirely a greenfield corridor, as there are no existing pipelines, electric transmission lines, railroads, or major roads to follow in the vicinity of the route. By contrast, the corresponding segment of the proposed route is collocated with existing linear corridor facilities for approximately 13 miles. Because the southern conceptual route is longer and would result in greater impacts than the currently proposed route, particularly to wetlands, the route is not considered a viable alternative. MAJOR ROUTE ALTERNATIVES Atlantic identified initial or "baseline" routes for the proposed ACP and SHP pipelines based on locations of receipt and delivery points, engineering and constructability criteria, terrain, and existing land use. Atlantic subsequently evaluated environmental and other constraints along each of the routes in an effort to refine the baseline configurations. Route alternatives, variations, and minor adjustments were identified based on a review of desktop constraint data, consultations and discussions with agency staff or other stakeholders, and field review in an effort to optimize the routes. The objective of the process was to identify the shortest possible route between the proposed receipt and delivery points taking into account the ACP purpose and need, engineering constraints, crossings of public lands, issues identified by stakeholders, and the potential for impacts on sensitive environmental resources. 8 a The mileposts depicted on the figures in this and subsequent sections of this document are based on three-dimensional modeling of the proposed routes, which takes into account changes in elevation along the routes. As a result, the distance between two mileposts may be Atlantic Coast Pipeline 42 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Atlantic Coast Pipeline 43 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District �. ry 1 O U OA r 0 a ,Y ❑ CL 10 4C� _�` �-,r-ti8t�,rr.;!ccy�--�jl_• .:a�' "1- � �✓ I CV � C Q L , o -h• ziz a LL O e � H �i ti` °jdtrrgy Y o u ♦ `a �� F 0 ♦ J O `y9'♦ ♦ f.., en ems, v_ � N ` ♦ v) ao ,..i{� 6. x `� - Ss we o 's, = L's Y � 'n ._c.�/`- ,C�C � o a �j�a ♦ ' tl 1 O �� C07 r� � f 0 A N Q ♦ 1` Atlantic Coast Pipeline 44 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Atlantic's analysis of route alternatives and variations used a geographic information system (GIS) to characterize crossings of environmental features and other constraints along the routes. A digital centerline for each route alternative and the corresponding segment of the baseline was compared with a variety of datasets and map resources in the GIS. Features and constraints considered in the analysis included: length, public lands crossed, roads crossed, conservation easements crossed, forested lands crossed (based on the National Land Cover Database), wetlands crossed (based on the NWI), waterbodies crossed (based on the National Hydrography Dataset), and known cultural resources sites crossed, such as Civil War battlefields. Once a baseline route was determined using desktop data, a field oriented routing team consisting of a lead construction router, civil survey staff, and an ecological specialist adjusted the route based on site-specific conditions while weighing competing constraints associated with environmental, tribal, and historical resource protection, constructability, available technology, and logistical constraints. Where practicable, adjustments to the route were made to avoid and/or minimize impacts on wetlands and waterbodies. Johnston County, North Carolina Major Route Alternative Atlantic identified and evaluated an alternative route for the AP -2 mainline at the request of the Johnston County, North Carolina Economic Development Authority in an effort to move the pipeline closer to existing industrial properties along the I-95 corridor and U.S. Highway 701 south of the town of Four Oaks. The Johnston County Economic Development Authority would like to introduce natural gas into the industrial park. The baseline route for the AP -2 mainline in this area crosses Johnston County east of the towns of Smithfield and Four Oaks. Beginning at MP 92.9 near Smithfield, the alternative route follows an existing electric transmission line southwest of the baseline for approximately 7 miles to a point just south of Four Oaks. The route then heads to the south-southwest for approximately 14 miles, where it rejoins the baseline west of Jumping Run Swamp at MP 114.5. The baseline and Johnston County route alternative are depicted on Figure 10.8.1-14, and comparative information on each route is provided in Table 10.8.1-12. TABLE 10.8.1-12 Johnston County Major Route Alternative for the Atlantic Coast Pipeline Features Unit Baseline (Proposed) Route Johnston County Route Alternative Length (total) miles 21.5 20.7 Primary U.S. or State highways crossed number 7 7 Other State or local roads crossed number 23 22 Adjacent to existing linear corridor facilities miles 0.0 6.1 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Conservation easements crossed miles 0.0 0.0 Forested land crossed miles 8.0 5.4 Wetlands crossed — forested/shrub miles 2.5 0.7 Intermittent waterbodies crossed number 33 28 Perennial waterbodies crossed number 8 8 Bentonville Battlefield (total) miles 0.1 0.2 Atlantic Coast Pipeline 45 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 1 ops r I - I - e Fls>no, t9. I' gun 9 5,1— Slnilhndd �I I� `I1S Tu 1' i fl Q M t . Newlou '' 1 ® Conservation Easement NWI Wetland _ j Existing Industrial Properties OMiles 6•�:'/� �y Man& N Baseline Atlantic Coast Pipeline CAast N Johnston County Baseline Figure 10.8.1-14 PlpeUne •• N Johnston County Alternative Major Route Alternative Johnston County FILE. M 1ClientslD-F}DOM}SRPM ArcGIS}R-source R-podsiRR EP 10}Figuresl_ACP RR10 Johnston County.—d, REVISED'. O6f21 M15, SCALE= 1:200000 DRAL"JN BY. GIS Atlantic Coast Pipeline 46 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District The Johnston County route alternative is approximately 4.0 miles closer to the town of Four Oaks than the baseline. Consistent with this proximity, the proposed alternative route crosses 239 parcels of property, compared to the baseline route which affects 163 parcels. The alternative route is 0.8 mile shorter and crosses 2.6 fewer miles of forested lands and 1.8 fewer miles of forested wetland than the baseline. Of particular note, the alternative route minimizes the crossing of a forested wetland complex adjacent to the Neuse River. Both routes cross a portion of the Bentonville Battlefield area, though the alternative crosses 0.1 mile more than the baseline. Both routes cross similar numbers of roads and waterbodies; however, the alternative route would involve more difficult construction with regard to crossing existing utilities. As noted above, the alternative route is adjacent to an existing electric transmission line for approximately 6.1 miles. The towers for the power line are anchored by guy wires, which could require shifting the pipeline further away from the electric transmission line. This would reduce the benefits of collocation, such as use of previously cleared areas for workspace or temporary sidecast storage during construction. Representatives of the Johnston County Economic Development Authority met with Piedmont, the local distribution company and both a partner and customer of the ACP, to discuss the natural gas supplies that will be provided by the Project. Based on this meeting, the Johnston County Economic Development Authority stated that it is satisfied that the current proposed route will support the County's interests in getting new supplies of natural gas to its targeted industrial zones. Balancing the various considerations presented, Atlantic retained the baseline route in this area. Progress Energy Carolinas Collocation Major Route Alternative Atlantic evaluated an alternative for the AP -2 mainline route adjacent to an existing Progress Energy Carolinas 500 kV electric transmission line in Cumberland County, North Carolina. Atlantic worked closely with the Wilmington District to evaluate alternatives associated with the Progress Energy Carolinas route alternative. During a meeting on January 28, 2016, Atlantic introduced the general concept of the route alternative that would increase collocation, while potentially result in crossing of additional wetlands. On February 12, 2016 Atlantic provided the Wilmington District a map depicting the route alternative and included a table comparing routing constraints, similar to the Table 10.8.1-13, below. Based on feedback from the Wilmington District, as well as the preferred collocation and other routing constraints, Atlantic adopted the route alternative as the proposed ACP route in this area. The baseline route in this area extends to the south/southeast generally parallel to the I-95 corridor on the east side of Fayetteville. Starting approximately at MP 125.3 near an intersection with I-95, the alternative route adjacent to Progress Energy Carolinas initially heads south for approximately 8.1 miles to a point south of U.S. Highway 13. It then heads south for approximately 17.3 miles, crossing Clinton Road, Cedar Creek Road, and Tabor Church Road. The route then turns to the west for approximately 5.2 miles, crossing the Cape Fear River and North Carolina State Highway 87, reconnecting with the baseline route at MP 157.5. The Atlantic Coast Pipeline 47 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District baseline route and the Progress Energy Carolinas Major Route Alternative are depicted on Figure 10.8.1-15, and comparative information on each route is provided in Table 10.8.1-13. TABLE 10.8.1-13 Progress Energy Carolinas Collocation Major Route Alternative for the Atlantic Coast Pipeline Baseline Progress Energy Carolinas Features Unit Route Collocation Route Alternative Length miles 32.0 30.3 Primary U.S. or State highway crossed number 12 9 Other State or local roads crossed number 37 23 Adjacent to existing linear corridor facilities miles 1.5 30.3 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 32.0 30.3 Conservation easements crossed miles 0.0 0.0 Forested uplands crossed (not including forested wetlands) miles 6.1 1.1 Wetlands crossed — forested/shrub miles 3.5 7.7 Wetlands crossed — freshwater emergent miles <0.1 0.2 Wetlands crossed — other miles 0.1 0.1 Intermittent waterbodies crossed number 14 5 Perennial waterbodies crossed number 33 27 The baseline route is 1.7 miles longer than the alternative route. Both the baseline and alternative avoid Federal and State lands, as well as conservation easements. The baseline route crosses 15 more waterbodies than the route alternative, six of which are perennial waterbodies. However, the alternative route crosses 4.3 more miles of wetland (an additional 24.8 acres), most of which is forested wetland. Many of the wetland complexes along the alternative route are large forested wetlands greater than 100 acres in size. Collocation of the AP -2 mainline with the Progress Energy Carolinas line would cause significant additional impacts on these forested wetland areas, as additional tree clearing along the maintained transmission line corridor would be required to install the pipeline adjacent to the high-voltage electric transmission line. Even though the Progress Energy Carolinas route alternative would be collocated with an existing corridor, it would require substantially more disturbance and permanent clearing of forested wetlands than the baseline route. For this reason, Atlantic retained the baseline route in this area. 11, Meherrin River Maior Route Alternative In a letter dated September 8, 2014, and in a meeting on November 12, 2014, The Nature Conservancy asked Atlantic to consider an alternative route for the proposed AP -3 lateral to avoid or minimize crossings of the Meherrin River and Fountains Creek watersheds in southeastern Virginia. These watersheds are part of TNC's Albemarle Sound Whole System project area, which encompasses approximately 6 million acres of freshwater -dominated estuarine habitat in southeastern Virginia and northeastern North Carolina. TNC states that the Albemarle Sound System contains "areas of large intact wetland forest that support high levels of use by migratory and breeding birds and buffer some of the best migratory fish spawning and nursery habitats on the East Coast." TNC has worked with public agencies, corporations, landowners, and communities to protect and restore public and private lands in this area. Atlantic Coast Pipeline 48 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Atlantic Coast Pipeline 49 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Linden 2, '11ron Arm 11-ld Creek Spring state Park ;,apeArmy Lake hade rp P raq g EYIovp. 1301-alle\ Doone ,Fayetteville 0 I ,,J S t edinan .14 parklon PW 0 1 2 3 ONE Man& ~ Baseline Atlantic Coast Pipeline Coast IV Progress Energy Carolinas Baseline Figure 10.8.1-15 P rLojilrm Progress Energy Carolinas Route Major Route Alternative Alternative Progress Energy Carolinas Collocation ,FILe 10,Figuml_ACP PEVIS£O 08126F,s"S. SC.LE 12-°0 Atlantic Coast Pipeline 50 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District The baseline route for the AP -3 lateral crosses floodplain forest in the Meherrin River and Fountains Creek watersheds between MPs 0.0 and 12.0, including areas which TNC has recommended for avoidance. Atlantic identified and evaluated a route alternative which avoids Fountains Creek altogether and minimizes crossings of floodplain forest in areas recommended by TNC for avoidance. The baseline route and Meherrin River Route Alternative are depicted on Figure 10.8.1-16, and comparative information on each route is provided in Table 10.8.1-14. TABLE 10.8.1-14 Meherrin River Major Route Alternative for the Atlantic Coast Pipeline Baseline Meherrin River Route Features Unit Route Alternative Length miles 14.7 16.8 Primary U.S. or State highway crossed number 1 2 Other State or local roads crossed number 20 19 Adjacent to existing linear corridor facilities miles 0.0 6.8 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 <0.1 Private lands crossed miles 14.7 16.8 Conservation easements crossed miles 0.0 <0.1 Forested lands crossed miles 3.6 3.5 Wetlands crossed — freshwater emergent miles 0.0 0.3 Wetlands crossed — freshwater forested/shrub miles 6.5 6.2 Wetlands crossed — other miles 0.0 0.1 Intermittent waterbodies crossed number 9 7 Perennial waterbodies crossed number 13 14 TNC floodplain forest recommended for avoidance miles 4.1 1.4 The baseline route for the AP -3 lateral trends southwest to northeast across Greensville and Southampton Counties, Virginia, crossing Fountains Creek approximately 4.7 miles from the AP -1 mainline and the Meherrin River just north of Haley's Bridge approximately 8.4 miles from the AP -1 mainline. Starting at Compressor Station 3, the Meherrin River Route Alternative initially extends to the east-southeast for approximately 5.8 miles across Southampton County, North Carolina, passing south of the Fountains Creek watershed. It then heads to the northeast for approximately 7.6 miles, mostly adjacent to existing power lines, roads, or railroads. It crosses the Meherrin River along the Virginia Commonwealth/North Carolina State line adjacent to an existing railroad. The alternative route then heads north-northeast for approximately 3.4 miles, where it intersects the baseline route in Southampton County, Virginia. Atlantic Coast Pipeline 51 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District t� 1 �mPton•PkyP v SUS g�.8 �1 �a5 . ti r t — � - - - - -N(,I, l it [', ROLINA - - - - Pleasant r 4r tob to 096 1 J10 Hill f .r r �'/Zuelts}t'ie ll go a? m 4* i 40 seaboard J2 m ® Conservation Easement The Nature Conservancy Abermarle _ _ °'t Floodplain Forest (Recommended Avoidance Area) 0 1 2 0 Miles /V Baseline Atlantic Coast Pipeline Meherrin River Baseline Figure 10.8.1-16 Meherrin River Route Alternative Major Route Alternatives. Meherrin River RILE: M:\CllentslD+OQM1SRM Arc✓ ISkResource_ReportslRREP 101riguresl_ACP RR10_Meherrin.mxd, REVISED: 09!0912016, SCALE: 1:150,006 OR SY: JSSuess Atlantic Coast Pipeline 52 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District The Meherrin River Route Alternative is 2.1 miles longer than the baseline, but avoids Fountains Creek and crosses 2.7 miles less of floodplain forest areas recommended for avoidance by TNC. About 70 percent (1.0 mile) of the floodplain forest along the alternative route occurs at the Meherrin River crossing, which is adjacent to an existing railroad. This will minimize impacts in the watershed due to forest fragmentation. The alternative route additionally is adjacent to existing linear corridor facilities (power lines and roads) for approximately 6.8 miles (40 percent) compared to 0.0 miles for the baseline. The baseline avoids conservation easements, while the alternative route crosses within less than 0.1 mile of a North Carolina Department of Environmental Quality conservation easement. 9 Crossings of forested lands, wetlands, and waterbodies are similar for both routes. Based on the feasibility of collocation with other utility corridors in this area, and the relative similarity of the impact on other major resource considerations, Atlantic incorporated the Meherrin River Route Alternative into the proposed route. Northampton Major Route Alternative Atlantic identified and evaluated two major route alternatives (Northampton 1 and Northampton 2) at the beginning of the AP -3 lateral in Northampton County, North Carolina, portions of which parallel an existing DVP 115 kV electric transmission line. Northampton 1 initially follows the proposed AP -2 mainline south of Compressor Station 3 for approximately 4.3 miles, and then follows the existing electric transmission line for about 7.8 miles to the northeast. Northampton 2 would require moving Compressor Station 3 from its current proposed site to a new location in Northampton County near MP 4.3 of the AP -2 mainline, and then follow the existing electric transmission line from this new site for about 7.8 miles to the northeast. The baseline and alternative routes are depicted on Figure 10.8.1-17, and comparative information on each route is provided in Table 10.8.1-15. TABLE 10.8.1-15 Northampton Major Route Alternative for the Atlantic Coast Pipeline Baseline Northampton 1 Route Northampton 2 Route Features Unit Route Alternative Alternative Length miles 6.1 12.1 7.8 Primary U.S. or Statee highway crossed number 0 0 0 Other State or local roads crossed number 7 14 4 Adjacent to existing linear corridor facilities miles 0.0 7.8 7.8 Adjacent to proposed linear corridor facilities miles 0.0 4.2 0.0 Federal lands crossed miles 0.0 0.0 0.0 State lands crossed miles 0.0 0.0 0.0 Conservation easements crossed miles 0.0 0.0 0.0 Forested lands crossed miles 2.6 5.5 1.4 Wetlands crossed - freshwater emergent miles 0.0 0.1 0.1 Wetlands crossed - freshwater forested/shrub miles 0.9 1.2 0.8 Intermittent waterbodies crossed number 4 6 3 Perennial waterbodies crossed number 1 3 2 TNC floodplain forest recommended for avoidance miles 0.3 0.5 0.0 9 Atlantic is current evaluating route variations to avoid this easement. Atlantic Coast Pipeline 53 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Pleasant Hili . 41 seaboard Conceptual Compressor Station 3 Location for Northampton Route Alternative 2 VF- The Nature Conservancy Abormarlo Floodplain Forest (Recommended Avoidance Area) 0 1 2 w 7 /�✓ Baseline Atlantic Coast Pipeline Man&r4orthampton Baseine Figure 10.8.1-17 ')*UCqaA Northampton Route Afternative I Major Route Alternatives rm NortnrrptDn Route AMmative 2 Northampton FILE: M kC1jenWD-hDOW5RP Ft_ArcGISXRe source_ Re portskR R EP_1 OVIgu res4_ACP _R R 1 U_Northampton_M ajor_ RA.mxd, REVISED'0812812015, SCALE:1:70,000 DRAWN BY: TH.h, Atlantic Coast Pipeline 54 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District At 6.1 miles in length, the baseline is the shortest of the three routes, though none of the baseline is adjacent to existing linear corridor facilities. The baseline crosses four waterbodies, including two perennial waterbodies, 0.9 mile of wetlands, and 2.6 miles of forested land. The baseline additionally crosses 0.3 mile of floodplain forest areas identified by TNC, mostly along Jacks Swamp. It avoids crossings of State lands and conservation easements. At 12.1 miles in length, Northampton 1 is 6.0 miles longer than the baseline. About 4.2 miles of the route is adjacent to the proposed AP -2 mainline and 7.8 miles is adjacent to the existing electric transmission line. The route crosses five waterbodies, including three perennial waterbodies, 1.3 miles of wetlands, and 5.5 miles of forested land. Of these, one perennial and three intermittent waterbodies, 0.4 mile of wetlands, and 4.1 miles of forested land are adjacent to the AP -2 mainline; the remainder are along the existing electric transmission line. The route alternative crosses 0.5 mile of floodplain forest areas identified by TNC along Jacks Swamp (all adjacent to the AP -2 mainline). Like the baseline, the alternative route avoids State lands and conservation easements. In a letter filed with the Commission, the North Carolina Wildlife Resources Commission suggested avoiding crossings of Cypress Creek by shifting the route for the AP -3 lateral farther to the north. The proposed route for the AP -3 lateral crosses Cypress Creek at four locations. These crossings resulted from the Meherrin River Major Route Alternative (see Section 10.8.1.13 above), which was designed to avoid sensitive floodplain forest areas along the Meherrin River and Fountains Creek. Relative to the baseline, Northampton I would result in one additional crossing of Cypress Creek in addition to a crossing of a tributary (Ivy Creek) approximately at its confluence with Cypress Creek at Jordan's Mill Pond. The baseline route avoids both Ivy Creek and Jordan's Mill Pond. Relative to the baseline, Northampton 1 is longer and crosses more waterbodies and more miles of wetlands, forested land, and floodplain forest areas than the baseline (though some of the crossings occur along the segment of the route alternative adjacent to the AP -2 mainline). The alternative route additionally adds a crossing of Cypress Creek and a tributary relative to the baseline. For all these reasons, Northampton 1 provides no environmental advantage over the ACP as proposed. As noted above, Northampton 2 would require moving the location of Compressor Station 3 to a new site. This would require 4.3 miles of AP -2 to be upsized to 42 -inch -diameter pipeline and an additional 2.0 miles in the length of the AP -3 lateral. These modifications could require changes in the location or configuration of other aboveground facilities for the Project. Additionally, the new site would be in actively cultivated farmland, which would require a permanent conversion of farmland to developed land. In contrast, the proposed site is located on recently replanted commercial timber land. Atlantic additionally notes that the landowner of the preferred site has indicated a willingness to sell the property as evidenced by the execution of an option agreement for the property. At 7.8 miles in length, Northampton 2 is 1.7 miles longer than the baseline, though the entire route is adjacent to the existing electric transmission line. Northampton 2 crosses five waterbodies, including two perennial waterbodies, 0.8 mile of wetlands, and 1.4 miles of forested land, all of which are similar to the baseline. The route avoids floodplain forest areas identified Atlantic Coast Pipeline 55 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District by TNC, but requires an additional crossing of Cypress Creek and a tributary (Ivy Creek) approximately at its confluence with Cypress Creek at Jordan's Mill Pond. The baseline route avoids both Ivy Creek and Jordan's Mill Pond. Like the baseline and Northampton 1, Northampton 2 avoids State lands and conservation easements. Relative to the baseline, Northampton 2 is longer, crosses one additional perennial waterbody, and results in an additional crossing of Cypress Creek and a tributary. Northampton 2 would require moving Compressor Station 3 to a new site, which would require approximately 4.3 miles of AP -2 to be upsized to 42 -inch -diameter pipeline and increase the length of the AP -3 lateral by about 2.0 miles. These changes in the configuration of the ACP potentially could require changes in the location or configuration of other aboveground facilities. Additionally, the new site for the compressor station would permanently encumber actively cultivated areas, whereas the proposed site is located in a commercial timbering area. For all these reasons, Northampton 2 provides no environmental advantage over the ACP as proposed. Based on the above analysis and discussion, Atlantic retained the baseline route in this area. ROUTE VARIATIONS IN NORTH CAROLINA Atlantic identified and evaluated a number of route variations designed to avoid or minimize impacts on geographically distinct and localized resources, such as conservation easements, cultural resource sites, and wetlands. Route variations were also considered to resolve engineering or constructability issues or address stakeholder concerns, where feasible. The route variations measured between approximately one and five miles in length and passed within a couple miles of the baseline route. The primary criterion for comparing route variations to the baseline route was cumulative impact avoidance relative to the objective of the route variation. Similar to the major route alternatives described above, if a route variation was adopted, it became part of the proposed route and the corresponding segment of the baseline route was rejected. Descriptions of each route variation are provided in the subsections below. Geenex Route Variation Atlantic identified and evaluated a route variation approximately between MPs 4.3 and 7.5 of the AP -2 mainline in Northampton County, North Carolina, to avoid a property with the option site of a future solar power generation development (see Figure 10.9.1.11 and Table 10.9.1.11). Relative to the baseline route, the Geenex Route Variation heads southwest from Cornwallis Road, then heads south and crosses Highway 301 where it rejoins the baseline east of Garysburg, North Carolina. The Geenex route variation is 0.9 mile longer than the baseline, but it avoids the option site for the future solar development. The route variation additionally reduces wetland impacts by 0.3 mile and avoids five intermittent waterbody crossings, but it increases crossings of forested land by 0.4 mile. Atlantic incorporated the Geenex Route Variation into the proposed route because it avoids the option site for the future solar development and reduces wetland and waterbody impacts. Atlantic Coast Pipeline 56 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District NHD FlDvAre NVVI Wetland 0 0.1 0.2 v. Adindc N Baseline Atlantic Coast Pipeline CJOCIA Geenex Baseline Figure 10.'9.1-11 pipeline Geenex Roe Variation d Geenex Route Variation FILE: M:kCii.ntST-FSDOMlSRPPl_AMGISlResource—ReportslRREP_101Figuresl_ACP _RR10._Geenex RV...d, REVISED 00124J2015, SCALE: 1Q5,000 DRAWN BY. JSS.ess Atlantic Coast Pipeline 57 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District TABLE 10.9.1-11 Geenex Route Variation for the Atlantic Coast Pipeline Features Unit Baseline Route Geenex Route Variation (Proposed) Length miles 2.6 3.5 Roads crossed number 7 5 Adjacent to existing linear corridor facilities miles 0.0 0.0 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 2.6 3.5 Conservation easements crossed miles 0.0 0.0 Forested land crossed miles 0.5 0.9 Wetlands crossed - freshwater forested/shrub miles 0.3 0.0 Intermittent waterbodies crossed number 5 0 Perennial waterbodies crossed number 0 0 Mush Island Route Variation Atlantic identified a route variation between MPs 11.1 and 12.5 of the AP -2 mainline route in Halifax County, North Carolina to avoid a conservation easement enrolled in the U.S. Department of Agriculture's Natural Resources Conservation Service's (MRCS) Wetland Reserve Program (see Figure 10.9.1-12 and Table 10.9.1-12). Relative to the baseline route, the Mush Island Route Variation initially extends to the southwest of the baseline route for approximately 0.7 mile, and then turns due south for another 0.7 mile back to the baseline. The route variation is approximately 0.2 mile longer than the baseline route, but it avoids the conservation easement. The route variation additionally crosses approximately 0.6 mile more of forested land, 0.2 more mile of wetland, and one more intermittent waterbody. Because it avoids the conservation easement, however, Atlantic incorporated the Mush Island Route Variation into the proposed route. TABLE 10.9.1-12 Mush Island Route Variation for the Atlantic Coast Pipeline Features Unit Baseline Route Mush Island Variation (Proposed) Length miles 1.2 1.4 Roads crossed number 1 1 Adjacent to existing linear corridor facilities miles 0.0 0.0 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 1.2 1.4 Conservation easements crossed miles 0.1 0.0 Forested land crossed miles 0.4 1.0 Wetlands crossed - freshwater forested/shrub miles 0.2 0.4 Intermittent waterbodies crossed miles 0.0 <0.1 Perennial waterbodies crossed number 1 2 Cumberland Church Battlefield study area number 1 1 Atlantic Coast Pipeline 58 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District • 90 i . • 99.9 w ;��ry• AR �C" •i�!``� �•'Z! ilii••« • O lam ts•® ♦•die y�;►y�'Q, �.g4gi�q/i!`°v�"�iv�i�i�l�lla c► c� �•aa••l•i•1•!i! b'q��y �h04s�*iq!!!illiifglq!!!q!q! !i« a♦illtili! S�ii•� . �iiiiiglgii•qi i�.� +al+ `ii!••li0iq «®.� �t, ilii.• «l«« '►e�iililii�. y4�1� i4t! i•y :gi`.glq. . �i•qi®ii ~I .♦!ii �1< ►►iiil�� s� 1 3. �'Ri ,��i��1�r' 1'rili�`a► o�i� �i Baseline•Pipeline • 1 • - -_ Mush Island Route Variation• Route• 0• DRAWN Atlantic Coast Pipeline 59 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District Halifax Route Variation Atlantic evaluated a route variation (the Halifax Route Variation) approximately between MPs 19.1 and 21.1 of the AP -2 mainline in Halifax County, North Carolina, in an effort to reduce crossings of forested land (see Figure 10.9.1-13 and Table 10.9.1-13). Starting about 0.3 mile east of Grapevine Road, the Halifax Route Variation initially heads south for l.1 miles, crossing State Route 561. It then heads west for 1.2 miles, crossing Marsh Swamp, and terminating at the baseline just west of Justice Branch Road. The route variation reduces crossings of forested land by 0.2 mile and wetlands by 0.1 mile, but is 0.4 mile longer and crosses one more waterbody and one more road than the baseline. Because potential impacts for both routes are similar, the route variation provides no environmental advantage over the baseline. Therefore, Atlantic retained the baseline as the proposed route in this area. TABLE 10.9.1-13 Halifax Route Variation for the Atlantic Coast Pipeline Features Unit Baseline Route Halifax Route Variation Length miles 1.9 2.3 Roads crossed number 2 3 Adjacent to existing linear corridor facilities miles 0.0 0.0 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 1.9 2.3 Conservation easements crossed miles 0.0 0.0 Forested land crossed miles 0.7 0.5 Wetlands crossed - freshwater forested/shrub miles 0.3 0.2 Intermittent waterbodies crossed number 1 2 Perennial waterbodies crossed number 1 1 Battlefield study areas miles 0.0 0.0 Breeches Swamp Route Variation Atlantic identified a route variation between MPs 28.3 and 30.4 of the AP -2 mainline route in Halifax County, North Carolina to avoid two conservation easements enrolled in the NRCS's Conservation Reserve Program (see Figure 10.9.1-14 and Table 10.9.1-14). Starting at a point just south of Ringwood Road, the Breeches Swamp Route Variation extends west of the baseline route for approximately 0.7 mile, crossing I-95. It then heads due south for approximately 1.4 miles parallel to and west of I-95, rejoining the baseline route approximately 0.3 mile south of Sneed Road. The route variation is approximately 0.2 mile longer than the baseline route and crosses approximately 0.1 more mile of wetland, but it avoids the conservation easements, crosses 0.1 mile less of forested land, and crosses one less intermittent waterbody. For these reasons, Atlantic incorporated the Breeches Swamp Route Variation into the proposed route. Atlantic Coast Pipeline 60 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 42,r, ` I Alen IJ'v- G1 1 Glove Baseline Atlantic Coast Pipeline N Halifax Baseline Figure 10.9.9-13 Pi a ine g Route Variation p N Halifax Route Variation Halifax FILE: M: Clients%O-FVQ WSR PPI ArcGIS%Resour ReportsXRRE P_1 OWiip-re ACP RR70 Halifax RV.mxd, REVISED: 0612472015, SCALE 1:15,000 DRAWN SY.THohn Atlantic Coast Pipeline 61 DRAFT N 0 0.25 os Miles Baseline Atlantic Coast Pipeline N Halifax Baseline Figure 10.9.9-13 Pi a ine g Route Variation p N Halifax Route Variation Halifax FILE: M: Clients%O-FVQ WSR PPI ArcGIS%Resour ReportsXRRE P_1 OWiip-re ACP RR70 Halifax RV.mxd, REVISED: 0612472015, SCALE 1:15,000 DRAWN SY.THohn Atlantic Coast Pipeline 61 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 0� �i. xe.uW � 4 ��'�oJ j`�`• � rasp ._ --�� _ l/ ti ae a3s.s4 /-� i._J/ ��J `y � >" ___\_IS—S a�•p-�` = "��5 � skin! 1Q • ! ! l -� � / 1794 • f- "+ •, u, . r x9v 4. 15 -:� .,. .^'��/gyp � • , ! !"��// ---- -� m 15 X172 A' - ^' Xf 124 \ l� • \ r C lv! ,.� S rte' 1 •/' � :16—�"�—"� -- - >;--i __ � 'aa JAY t72x �'s• 111 V ` Op ight r r ( IS ie \` 4� _.I Y V`b I f • Ym_ g i ` y* Conservation Easement ,n•� �� ;. 1v *� N NWI Wetland '4 0 0. 1 �) d ' Miles + / 40 Atlantic IV Baseline Atlantic Coast Pipeline apst ~ Breeches Swamp Baseline Figure 10.9.1-14 Pine .. ♦'►i Breeches swamp Route Variation Breeches Swamp Route Variation FILE, WC1ianls1D-F%DOWSRPP1 Ar,GIS%Re urea Ra rWRREP 101Fiaure 1 ACP RR10 RA Man Sg mxd. REVISED, 080412015_ SCALE124.000 DRAWN By GIS Atlantic Coast Pipeline 62 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District TABLE 10.9.1-14 Breeches Swamp Route Variation for the Atlantic Coast Pipeline Features Unit Baseline Route Breeches Swamp Route Variation (Proposed) Length miles 1.9 2.1 Roads crossed number 4 6 Adjacent to existing linear corridor facilities miles 0.0 0.0 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 1.9 2.1 Conservation easements crossed miles 0.1 0.0 Forested land crossed miles 0.4 0.3 Wetlands crossed - freshwater forested/shrub miles 0.1 0.2 Intermittent waterbodies crossed number 3 2 Perennial waterbodies crossed number 1 1 Red Oak Route Variation Atlantic identified a route variation (Red Oak 1) between MPs 42.5 and 45.9 of the AP -2 mainline route in Nash County, North Carolina, to avoid a former landfill (see Figure 10.9.1-15 and Table 10.9.1-15). Starting north of the town of Red Oak, Red Oak 1 initially heads southeast for approximately 1.0 mile, and then turns south for approximately 1.5 miles, passing east of an existing subdivision along Flat Rock Road and Red Oak Battleboro Drive. The route then heads west for approximately 0.6 mile, rejoining the baseline at a point just north of Big Jim Road. Atlantic Coast Pipeline 63 DRAFT TABLE 10.9.1-15 Red Oak Route Variation for the Atlantic Coast Pipeline Features Unit Baseline Route Red Oak 1 Route Variation Red Oak 2 Route Variation Length miles 2.2 3.2 3.4 Roads crossed number 4 5 5 Adjacent to existing linear corridor miles 0.0 0.0 0.0 facilities Federal lands crossed miles 0.0 0.0 0.0 State lands crossed miles 0.0 0.0 0.0 Private lands crossed miles 2.2 3.2 3.4 Conservation easements crossed miles <0.1 <0.1 0.0 Forested land crossed miles 1.0 1.2 1.2 Wetlands crossed - forested/shrub miles 0.2 0.2 0.2 Intermittent waterbodies crossed number 3 4 3 Perennial waterbodies crossed number 1 3 3 Historic landfill area miles 0.1 0.0 0.0 Atlantic Coast Pipeline 63 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 67m 42 CO Red 0A, 40 41 iti or I k I I Conservation Easement Landfill NWI Weiland 0 05 1 Miles /SV Baseline Aflandic Atlantic Coast Pipeline cmist Red Oak Baseline Figure 10.9.1-15 P i rp x A..; n e Red Oak Route Variation 1 Red Oak Route Variation Red Oak Route Variation 2 11FILLM:IGlienlsO-roOWSRP�l AroGISlRescume_ReportsIRREP_lOTigumsl_ACP_RRiC_Reid Oak.mxd, REVISED, 0812412015, SCALEA:XODD DRAv'dN BY Atlantic Coast Pipeline 64 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Red Oak 1 avoids an approximately 0.1 mile long crossing of the Red Oak Landfill, which operated from 1969 to 1977. The North Carolina Department of Environmental Quality reported the one-time disposal of 135 pounds of pesticides and a three-year weekly disposal of waste rags containing the solvent methyl isobutyl ketone at the landfill. Red Oak 1 is approximately 1.1 mile longer than the baseline, but avoids the former landfill. Crossings of other features are similar or identical for the two routes. In light of the avoidance of the former landfill, and the similar impact on other major resource considerations, Atlantic initially incorporated the Red Oak 1 Route Variation into the proposed route. Subsequent to incorporation of the Red Oak 1 Route Variation, and based on the results of civil surveys, Atlantic optimized Red Oak 1 into Red Oak 2. The optimized route is similar to Red Oak 1, but it improves the crossing angle of Flat Rock Branch and also avoids paralleling this creek. In addition, Red Oak 2 avoids an existing conservation easement, which is crossed by both the baseline and Red Oak 1. Like Red Oak 1, Red Oak 2 avoids the former landfill. Other environmental impacts are similar to the baseline and Red Oak 1. Therefore, Atlantic incorporated the Red Oak 2 Route Variation into the proposed route. Citv of Nashville Route Variation Atlantic identified and evaluated a route variation for the AP -2 mainline route at the request of the City of Nashville, in an effort to avoid the proposed route running between two existing subdivisions on the south side of Oak Level Road (see Figure 10.9.1-16 and Table 10.9.1-16). Starting at MP 50.3, the route variation initially heads south for approximately 1.5 miles, passing east of these subdivisions and crossing East Old Springs Hope and Oak Level Roads. It then heads southwest for 2.2 miles, crossing North Carolina State Road 58, and intersecting the baseline at MP 53.3. The City of Nashville Route Variation is approximately 0.7 mile longer than the baseline. It crosses 0.8 mile more of forested land, but 0.2 mile less of forested wetland. While the route variation avoids the subdivisions west of East Old Spring Hope Roads, it crosses between other subdivisions along Oak Level Road and Sherrod Road. For these reasons, Atlantic retained the baseline route in this area. TABLE 10.9.1-16 City of Nashville Route Variation for the Atlantic Coast Pipeline City of Nashville Route Features Unit Baseline Route Variation Length miles 3.0 3.7 Roads crossed number 4 5 Adjacent to existing linear corridor facilities miles 0.0 0.0 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 3.0 3.7 Conservation easements crossed miles 0.0 0.0 Forested land crossed miles 0.5 1.3 Wetlands crossed — freshwater forested/shrub miles 0.3 0.1 Intermittent waterbodies crossed number 2 1 Perennial waterbodies crossed number 0 1 Atlantic Coast Pipeline 65 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District r ir i Forest hilt Cemetery Nashvi lie f!y 5�7 F)Fd t1S =fi#' F 454 rn,vFcvl Sr U err 2 .67m t3rr•:tr"', Z SJ �irclvivood courtry Auto Q, u• r NO fives. F:35tr:rn Ave i�oce ..PS 0 1 y tanbark 01 1 �l3 . �J°er,.ga Irl M Em Atlantic Coast Pipeline 66 DRAFT .y�r,ir. AJ Conservation Easement H NO Wetland �qti a fly 1 Miles 7• aunt N Baseline Atlantic Coast Pipeline Coast /�/ City of Nashville Baseline Figure 10.9.1-16 Pi.,Aj e , /v City of Nashville Route City of Nashville Route Variation { � Varlatican FILE: M,lClients'0.F10OWSRPP1_AreGISTesmume_Reports%RREP_t BSFiguresl_ACP_ RRIO_CitynNashAlle.m><d, REVISED: 0012412015. SCALE: 1:38,202 DRA' AN BY. GIS Atlantic Coast Pipeline 66 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District Little River Route Variation In response to a meeting with the FWS and North Carolina Wildlife Resources Commission, Atlantic identified the Little River Route Variation in Johnston County, North Carolina (see Figure 10.9.1-17 and Table 10.9.1-17). Starting at MP 82.3, the route variation heads to the southwest, crossing Little River, and passing south of Buffalo Creek before terminating at MP 83.8. The route variation avoids Buffalo Creek, reduces crossings of wetlands by 0.6 mile, reduces crossings of forested land by 0.4 mile, and is 0.2 mile shorter than the baseline route. Atlantic incorporated the Little River Route Variation into the proposed route. TABLE 10.9.1-17 Little River Route Variation for the Atlantic Coast Pipeline Features Unit Baseline Route Little River Route Variation Length miles 1.5 1.3 Roads crossed number 1 1 Adjacent to existing linear corridor facilities miles 0.0 0.0 Federal lands crossed miles 0.0 0.0 State lands crossed miles 0.0 0.0 Private lands crossed miles 1.5 1.3 Conservation easements crossed miles 0.0 0.0 Forested land crossed miles 1.3 .9 Wetlands crossed - freshwater forested/shrub miles 0.9 0.3 Intermittent waterbodies crossed number 0 0 Perennial waterbodies crossed number 2 1 Swamp Road Route Variation Atlantic identified a route variation between MPs 131.3 and 134.1 of the AP -2 mainline route in Cumberland County, North Carolina to minimize crossings of forested wetland (see Figure 10.9.1-18 and Table 10.9.1-18). Swamp Road Route Variation 1 generally parallels the initial baseline route beginning at a point just north of River Road and extending 2.7 miles south- southwest to Rick Walker Road. It passes east of a forested wetland near MP 131.1 and west of a forested wetland near MP 132.0. It crosses 0.8 mile less of forested wetland, 0.6 mile less of forested land, and three fewer perennial waterbodies than the baseline route. However, Swamp Road Route Variation 1 reduced collocation with existing linear corridors by 0.7 mile. Subsequent to evaluating Swamp Road Route Variation 1, Atlantic identified the Swamp Road Route Variation 2 to avoid a planned housing development and to collocate the route with an existing Piedmont natural gas pipeline. The route variation is 0.1 mile longer than the baseline and Swamp Road Route Variation 1, but it is further away from a residence, avoids an area for a planned housing development, and is collocated with an existing Piedmont pipeline for 0.6 mile. It also reduces wetland impacts by 0.4 mile compared to the baseline route (though it would have greater impact than Swamp Road Route Variation 1). For all these reasons, Atlantic incorporated Swamp Road Route Variation 2 into the proposed route. Atlantic Coast Pipeline 67 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District U � _ I r 57 m a;G Buffalo Creek Ohy T- N fOf NHD Flowline NWI Weiland 0 0.1 0.2 0 Miles Awn *OV Baseline Atlantic Coast Pipeline Coast /\VLittle River Baseline Figure 10.9.1-17 plpeUne l_ Little River Route Variation Little River GO Route Variation FILE: M:\ClientslD-MDOMISRPPI_AreGiMesource_Reports%RREP_%Figuresl_ACP_RR70_Little_River _RV.mxd, REVISED: 0012512015, SCALE:1:15,000 DRAWN BY: issues$ Atlantic Coast Pipeline 68 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District IIR Waft i I r ;04 - "� Conservation Easement t° NWI Wetland - r/kms :N;an se iS -- y P- FAHes 1 Baseline Allank Swamp Road Baseline Atlantic Coast Pipeline coaA INV Stump Road Route Variation 1 Figure 10.9.1-18 PipeUne _ Swamp Road Route Variation 41� SLvamp Road Route' Variation 2 FILE: M:1Client3W-F%DOMlSRPPt Are6151Resaume_ReponORREP_10%Fi real ACP RR10 RA Map_Set.mxd. REV14SEO: 0812512015. SCALE: 4:40,000 DRAM BY GIS Atlantic Coast Pipeline 69 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District TABLE 10.9.1-18 Swamp Road Route Variations for the Atlantic Coast Pipeline Baseline Swamp Road Route Swamp Road Features Unit Route Variation 1 Route Variation 2 Length miles 2.7 2.7 2.8 Roads crossed number 3 2 2 Adjacent to existing linear corridor facilities miles 0.7 0.0 0.6 Federal lands crossed miles 0.0 0.0 0.0 State lands crossed miles 0.0 0.0 0.0 Private lands crossed miles 2.7 2.7 2.7 Conservation easements crossed miles 0.0 0.0 0.0 Forested land crossed miles 1.4 0.8 1.2 Wetlands crossed - freshwater forested/shrub miles 0.9 0.1 0.5 Intermittent waterbodies crossed number 2 2 2 Perennial waterbodies crossed number 4 1 3 Cane Fear Route Variation Atlantic identified and evaluated a route variation (the Cape Fear 1 Route Variation) between MPs 146.6 and 152.2 of the AP -2 mainline in Cumberland County, North Carolina to avoid a conservation easement enrolled in the NRCS's Wetland Reserve Program (see Figure 10.9.1-19 and Table 10.9.1-19). From a point near Cedar Creek Road, the Cape Fear 1 Route Variation heads approximately 1.5 miles to the southwest of the baseline route to Evans Dairy Road. It then continues to the south-southwest for approximately 3.8 miles, crossing the Cape Fear River and rejoining the baseline route near Tyson Road. Cape Fear 1 is approximately 0.2 mile longer than the baseline route, crosses 0.2 mile more of forested land, and crosses two more perennial waterbodies than the baseline route. However, it avoids the conservation easement and reduces crossings of forested wetlands by 0.1 mile. TABLE 10.9.1-19 Cape Fear Route Variations for the Atlantic Coast Pipeline Cape Fear Route Cape Fear Route Features Unit Baseline Route Variation 1' Variation 2 (Proposed) Length 1% miles 5.2 5.4 5.5 Roads crossed number 3 6 4 Adjacent to existing linear corridor facilities miles 0.0 0.0 0.0 Federal lands crossed miles 0.0 0.0 0.0 State lands crossed miles 0.0 0.0 0.0 Private lands crossed miles 5.2 5.4 5.5 Conservation easements crossed miles 0.5 0.0 0.0 Forested land crossed miles 1.7 1.9 2.0 Wetlands crossed - freshwater forested/shrub miles 0.3 0.2 0.2 Intermittent waterbodies crossed number 4 3 4 Perennial waterbodies crossed number 2 4 4 Atlantic Coast Pipeline 70 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District AVf" ri, J � Y• , C I�� ``{ � ,.. \ A. - 1yh _ Y_ _ .._J JWIH°i t yam, 1 3. \\. S.ir:R . 4Gr$VY.J1 (� �V 4 - _Ph, 5 P Vf . -, Gr J -1 r Conservation Easement '1 I ; NWI Wetland *****,0Baseline Mari& Coast /*�/ cape Fear Baseline Atlantic Coast Pipeline � Cape Fear Route variation 1 Figure 1-19 PIpeV11� ,�Gape Fear Roouteuts Variation ♦ Cape Fear Route Variation 2 FILE. r,1. O?lents!D-FVOWSRPPI_AruGISiResource_ReptldslRREP_101Figuresl_ACP_RR10_Cape _F-r—d, REVISED, 08@42015, SCALE: 1:50,000 CRAWN 6Y: GIS Atlantic Coast Pipeline 71 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District Subsequent to evaluating the Cape Fear 1 Route Variation, Atlantic identified and evaluated a second route variation (Cape Fear 2) that optimizes the crossing angle of the Cape Fear River. Cape Fear 2 is approximately 0.1 mile longer, crosses 0.1 more mile of forested land, and crosses one more road than Cape Fear 2, but improves the crossing angle of the river. Other environmental impacts are comparable to Cape Fear 1. For these reasons, Atlantic adopted the Cape Fear 2 Route Variation into the proposed route. ROUTE ADJUSTMENTS IN NORTH CAROLINA Atlantic made a number of minor route adjustments to optimize the baseline routes as a result of routing, biological, cultural resources, and civil field surveys. The route adjustments generally measure less than two miles in length, pass within a quarter mile or less of the baseline routes, and do not significantly affect the total length of the routes. The route adjustments were adopted without a formal alternatives analysis, as the basis for the adjustment was intuitive and practical (e.g., a slight shift in the centerline to avoid a wetland). Individually, the refinements to the routes are small, but collectively they reduce impacts on environmental resources. Table 6 lists the route adjustments that have been incorporated into the proposed ACP pipeline route in North Carolina and the rationale for each adjustment. Atlantic Coast Pipeline 72 DRAFT TABLE 6 Select Route Adjustments Incorporated into the Proposed Atlantic Coast Pipeline in North Carolina Approximate Route Adjustment Mileposts State Rationale AP -2 Mainline Jacks Swamp 0.7 to 2.4 NC Adjustment to minimize a wetland crossing length Big John Store Road 2.5 to 3.1 NC Adjustment to avoid a cemetery Cornwallis Road 3.7 to 4.2 NC Adjustment to avoid a wetland Quankey Creek 16.0 to 17.3 NC Adjustment to avoid a proposed future development by the Halifax Airport Authority Bryant Road 25.9 to 26.0 NC Adjustment to avoid a wetland Jacket Swamp 26.9 to 27.7 NC Adjustment to avoid a conservation easement Massengale Road 40.0 to 40.3 NC Adjustment to avoid a future home site development Wollett Mill Road 42.2 to 42.4 NC Adjustment to avoid a cemetery Cambridge Drive 48.8 to 49.1 NC Adjustment to increase distance from residences Boykin Road 70.5 to 70.8 NC Adjustment to avoid a wetland Contenmea Creek 73.1 to 74.4 NC Adjustment to optimize creek crossing angle Hales Road 80.1 to 81.5 NC Adjustment to avoid a waterbody crossing and minimize a wetland crossing Old Beulah Road 84.0 to 84.5 NC Adjustment to avoid a wetland Yelverton Grove Road 92.3 to 93.3 NC Adjustment to connect to M&R Station Guin Road 98.5 to 99.0 NC Adjustment to avoid a waterbody crossing and minimize a wetland crossing Coats Road 103.5 to 103.8 NC Adjustment to address a landowner request NC -50 South 109.5 to 110.0 NC Adjustment to avoid a wetland Godwin Lake Road 110.1 to 110.7 NC Adjustment to avoid a blueberry farm Holly Grove Road 112.4 to 112.7 NC Adjustment to avoid a wetland NC DOT Easement 113.9 to 114.4 NC Adjustment to avoid a North Carolina Department of Transportation Nutrient Easement Green Path Road 117.8 to 118.2 NC Adjustment to reduce wetland impacts Godwin Falcon Road 126.2 to 126.8 NC Adjustment to reduce the pipeline length Sisk Culbreth Road 129.4 to 129.7 NC Adjustment to avoid existing structures Jackie Lee Road 133.8 to 134.2 NC Adjustment to reduce the pipeline length Tobacco Road 138.6 to 139.0 NC Adjustment to avoid a wetland Atlantic Coast Pipeline 72 DRAFT Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information DRAFT U.S. Army Corps of Engineers - Wilmington District TABLE 6 Select Route Adjustments Incorporated into the Proposed Atlantic Coast Pipeline in North Carolina Route Adjustment Approximate Mileposts State Rationale Approximate 142.0 to 142.2 NC Adjustment to avoid a wetland Pleasant View Drive Unique ID Avoided Rationale Sids Mill Road 143.2 to 143.5 NC Adjustment to reduce a wetland crossing John B Carter Road 144.5 to 145.0 NC Adjustment to avoid being parallel to a waterbody Clark West Road 146.7 to 148.6 NC Adjustment to reduce road crossings Canadian Avenue 152.9 to 153.3 NC Adjustment to reduce wetland impacts Highway 87 153.8 to 154.0 NC Adjustment to optimize road crossing angle Thrower Road 155.0 to 155.2 NC Adjustment to avoid new residential development Odom Road 156.6 to 157.5 NC Adjustment to avoid a wetland crossing and reduce tree clearing Little Marsh Swamp 162.0 to 164.8 NC Adjustment to minimize a wetland crossing and parallel an existing utility corridor Great Marsh Church 168.3 to 169.3 NC Adjustment to meet a landowner request Rennert Road 171.5 to 172.3 NC Adjustment to reduce the length of the pipeline and address a landowner request McQueen Road 175.0 to 175.4 NC Adjustment to avoid a wetland AP -3 Lateral wcmp002f Yes Highway 186 9.9 to 10.3 NC Adjustment to reduce tree clearing and optimize a railroad crossing In addition to the route variations and adjustments, Atlantic optimized the route at a localized scale to further minimize impacts on wetlands and waterbodies where feasible. Route optimization efforts that have occurred to minimize impacts on wetlands and waterbodies within the Wilmington District are listed in Table 7. Appendix A includes detailed route maps that illustrate how Atlantic has also minimized impacts on wetlands and waterbodies by reducing workspace at wetland crossings and in the Atlantic Coast Pipeline 73 DRAFT TABLE 7 Route Avoidance Locations for Wetlands in North Carolina Approximate Wetland Wetland Milepost Unique ID Avoided Rationale AP -2 Mainline 3.8 wnrg003f Yes 4.0 wnrh015f Yes 25.3 whlhOl3f Yes 35.3 wnah016f Yes 42.3 wnac001f Yes 57.0 wnagOlOf Yes 70.1 wwio011f Yes 83.6 wjop00lf Yes 108.9 wjop023f Yes 110.4 wjoo026f No The proposed shift may impact a house in an adjacent parcel 131.0 wcmp002f Yes 137.7 wcmp014f Yes Shift to minimize crossing 143.1 wcmo012f No Shift - alignment avoids power poles for high voltage lien as well as maintains a buffer from adjacent residence (-260-ft). The proposed shift may impact existing structures on parcel 22-256 145.4 wcmp021f No Current alignment avoids power poles for high voltage line as well as maintains a buffer from adjacent residence (-260-ft). 152.2 wcmp012f Yes Shift to minimize crossing 174.2 wroh012s Yes Appendix A includes detailed route maps that illustrate how Atlantic has also minimized impacts on wetlands and waterbodies by reducing workspace at wetland crossings and in the Atlantic Coast Pipeline 73 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District vicinity of wetlands and waterbodies, where feasible. In addition, to avoid impacts on wetlands along the periphery of the construction workspace, modifications to workspace have been incorporated into the project design to minimize impacts on wetlands and waterbodies. ACP is a FERC regulated pipeline project and subject to certain procedures to avoid and minimize impacts on wetland and waterbody crossings to satisfy FERC's own NEPA requirements that also include minimization of environmental impacts. These procedures are outlined in the Plan and Procedures and are applicable to all FERC regulated pipelines. Despite Atlantics efforts to avoid and minimize impacts, there will be impacts that cannot be avoided. These impacts will be offset with compensatory mitigation, as discussed in Section D2. 3. b.1 Construction Minimization - Wetlands During the routing phase of the Project, NWI data was used to provide a preliminary analysis of wetland resources and to assess where wetland impacts could be avoided or minimized. In addition, a field oriented routing team consisted of an ecological specialist that assisted in identifying water resources during field routing by civil survey crews. Where feasible, minor adjustments to the route were made to minimize impacts on wetlands. Clearing and grading of wetlands, trenching, backfilling, and trench dewatering can affect wetlands through the alteration of wetland vegetation and hydrology; loss or change to wildlife habitat; deposition or erosion of sediment; and exposure to accidental spills of fuels and lubricants. Atlantic will minimize impacts on wetlands by following the wetland construction and restoration guidelines contained in the Plan and Procedures. The proposed wetland mitigation measures are intended to avoid wetland impacts to the greatest extent practicable; minimize the area and duration of disturbance; reduce soil disturbance; and enhance wetland reestablishment after construction. Some of the measures proposed include: • limiting the construction right-of-way width to 75 -feet through wetlands (unless alternative, site-specific measures are requested by Atlantic and approved by the FERC and other applicable agencies); • clearly marking wetland boundaries with signs and flagging in the field prior to the start of construction; • locating ATWS within uplands at least 50 feet away from wetland boundaries (unless alternative, site-specific measures are requested by Atlantic and approved by the FERC and other applicable agencies); • installing and maintaining sediment barriers, such as silt fences or other approved barriers during clearing Atlantic Coast Pipeline 74 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District • limiting the operation of construction equipment within wetlands to only equipment essential for clearing, excavation, pipe installation, backfilling, and restoration; • preventing the compaction and rutting of wetland soils by operating equipment on equipment mats or timber riprap in wetlands that are not excessively saturated; • restricting grading in wetlands to the area directly over the trenchline, except where necessary to provide necessary safety; • installing trench breakers or trench plugs at the boundaries of wetlands to prevent draining of wetlands; • segregating topsoil from the trench in non -saturated wetlands and returning topsoil to its original location during backfilling to avoid changes in the subsurface hydrology and to promote re-establishment of the original plant community by replacing the seed bank found in the topsoil; • installing temporary and permanent erosion and sediment control devices, and re- establishing vegetation on adjacent upland areas, to avoid erosion and sedimentation into wetlands; • removing woody stumps only from areas directly above the trenchline, or where they will create a safety hazard, to facilitate the re-establishment of woody species by existing root structures; • returning graded areas to their preconstruction contours to the greatest extent practicable, and returning excavated soil from the trench within the wetlands back to their original soil horizon to maintain hydrologic characteristics; • prohibiting the storage of chemicals, fuels, hazardous materials, and lubricating oils within 100 feet of a wetland; • prohibiting parking and/or fueling of equipment within 100 feet of a wetland; unless the Environmental Inspector determines there is no reasonable alternative, and appropriate steps (such as secondary containment structure) are taken; • prohibiting the use of live concrete as a building material so that wet concrete does not come into contact with water; • dewatering the trench at a controlled rate into an energy dissipation/sediment filtration device, such as a geotextile filter bag and properly installed straw bale structure, to minimize the potential for erosion and sedimentation; • preventing the invasion or spread of undesirable exotic vegetation in accordance with a project -specific invasive plant species management plan; Atlantic Coast Pipeline 75 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District • limiting post -construction maintenance of vegetation to removal of trees with roots that could compromise the integrity of the pipeline within 15 feet of the pipeline centerline, and the maintenance of a 10 -foot wide corridor centered over the pipeline as herbaceous vegetation; • reseeding with a native wetland seed mix in both the temporary construction and permanent right of way to stabilize wetland areas; and • annual monitoring wetland reestablishment following construction until reestablished wetlands achieve success. See Appendix J for the Restoration and Rehabilitation Plan. Prior to construction, wetland boundaries will be clearly marked in the field with signs and flagging. Construction equipment working in wetlands will be limited to what is essential for right-of-way clearing, excavating the trench, fabricating and installing the pipeline, backfilling the trench, and restoring the right-of-way. In areas where there is no reasonable access to the right-of-way except through wetlands, non-essential equipment will be allowed to travel through wetlands only once, unless the ground is firm enough or has been stabilized to avoid rutting. Clearing of vegetation in wetlands will be limited to trees and shrubs, which will be cut flush with the surface of the ground and removed from the wetland. To avoid excessive disruption of wetland soils and the native seed and rootstock within the topsoil, stump removal, grading, topsoil segregation, and excavation will be limited to the area immediately over the trenchline, except a limited amount of stump removal and grading may be conducted in other areas if required by safety-related issues. Topsoil segregation over the trenchline will only occur if the wetland soils are not saturated at the time of construction. During clearing, sediment barriers, such as silt fences or other approved sediment barriers, will be installed and maintained adjacent to wetlands and within ATWS areas as necessary to minimize the potential for sediment runoff. Sediment barriers will be installed across the full width of the construction right-of-way at the base of slopes adjacent to wetland boundaries. Erosion control devices installed across the working side of the right-of-way will be removed during the day when vehicle traffic is present, and will be replaced each night. Alternatively, drivable berms may be installed and maintained across the right-of-way in lieu of silt fences or straw bales. Sediment barriers will also be installed within wetlands along the edge of the right-of-way, where necessary, to minimize the potential for sediment to run off the construction right-of-way and into wetlands outside the work area. If trench dewatering is necessary, it will be conducted in accordance with the Procedures and applicable permits. Silt - laden trench water will be discharged into an energy dissipation/sediment filtration device, such as a geotextile filter bag and straw bale structure, to minimize the potential for erosion and sedimentation. Temporary access roads through wetlands will be provided, when necessary, by altered for use during construction by installing timber construction mats or other removable materials to minimize rutting in wetlands. Where intended for temporary use, the access roads improvements within wetlands will be removed after pipeline construction and wetland Atlantic Coast Pipeline 76 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District reestablishment is complete. Permanent access road improvements will require minor fill of wetlands. Where feasible, Atlantic minimized impacts through necking down permanent access roads or improving areas within adjacent uplands to minimize wetland impacts. After avoidance and minimization to the extent practicable, 1.72 acres of permanent fill/loss wetland loss impacts will result from the proposed permanent access roads within the Wilmington District. The impacts associated with construction are planned to occur in an expedient and efficient manner such that impacts on the wetlands are minimized to the extent practicable, and long-term impacts are associated with minimal conversion of type but not loss of wetlands. In addition, while there are a number of wetland crossings associated with across the ACP in North Carolina are numerous, the crossings are distributed across many watersheds. Tables 3 and 4 in section C, Proposed Impacts Inventory, summarize the impacts on wetlands by watershed (HUC 8). Based on the short duration of construction thru wetlands, minimization of long-term conversion by implementing FERC procedures (i.e., minimizing clearing to of a 10 feet along the pipeline centerline to maintain a herbaceous wetland condition, and minimizing trimming to 15 feet either side of the pipeline centerline for larger trees), and providing compensatory mitigation within both the 30 foot permanently maintained right of way (15 feet either side of the pipeline centerline) and the temporarily disturbed 75 foot construction right of way by reseeding with native wetland seed mix, and replanting of the temporarily disturbed right of way in non - inundated deciduous hardwood wetlands (e.g., bottomland hardwood, hardwood riparian, and hardwood flat wetlands) with saplings (minimization and compensatory mitigation), mitigating at a 1:1 ratio for permanent conversion of non -inundated deciduous hardwood wetlands (e.g., bottomland hardwood, hardwood riparian, and hardwood flat wetlands) to scrub -shrub and emergent wetlands, Atlantic anticipates that cumulative impacts will result in no more than no more than minimal adverse impacts on the basin and sub -basins crossed. 4. b.2 Construction Minimization - Waterbodies Because little or no grading will occur in wetlands, restoration of contours will be accomplished during backfilling. Prior to backfilling, trench breakers will be installed, where necessary, to prevent subsurface drainage of water from wetlands. Where topsoil is segregated, the subsoil will be backfilled first followed by the topsoil. Topsoil will be replaced to the original ground level leaving no crown over the trenchline. In areas where wetlands overlie rocky soils, the pipe will be padded with rock -free soil or sand before backfilling with native bedrock and soil. Equipment mats, gravel fill, and/or geotextile fabric will be removed from wetlands following backfilling. Where wetlands are located at the base of slopes, permanent slope breakers will be constructed across the right-of-way in upland areas adjacent to the wetland boundary. Temporary sediment barriers will be installed where necessary until revegetation of adjacent upland areas is successful. Once revegetation is successful, sediment barriers will be removed from the right-of-way and disposed of at an approved disposal facility. Restoration/revegetation of wetlands will be considered successful when the affected wetland satisfies the federal definition of a wetland (i.e., soils, hydrology, and vegetation); the vegetation is at least 80 percent of the cover documented for the wetland prior to construction, or at least 80 percent of the cover in adjacent, undisturbed areas of the wetland; or the plant species Atlantic Coast Pipeline 77 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District composition is consistent with early successional wetland plant communities in the affected ecoregion (if seeding is used in lieu of planting); and invasive plant species are absent, unless they are abundant in adjacent areas that were not disturbed by construction. Impacts on waterbodies crossed by the proposed ACP facilities could occur as a result of construction activities in stream channels and on adjacent banks. Clearing and grading of stream banks, in -stream trenching, trench dewatering, and backfilling could each result in temporary, local modifications of aquatic habitat involving sedimentation, increased turbidity, and decreased dissolved oxygen concentrations. In almost all cases, these impacts will be limited to the period of in -stream construction, and conditions will return to normal shortly after stream restoration activities are completed. Agency recommended time of year restrictions are listed in Appendix C. Vegetative clearing, grading for construction, and soil compaction by heavy equipment near stream banks could promote erosion of the banks and the transport of sediment into waterbodies by stormwater runoff. To minimize these potential impacts, Atlantic will install equipment bridges, mats, and pads, as necessary. Additionally, Atlantic will locate ATWS at least 50 feet from stream banks (with the exception of site-specific modifications requested by Atlantic and approved by the FERC). Temporary sediment barriers will be installed around disturbed areas as outlined in the Plan and Procedures. Upon completion of construction, Atlantic will install permanent erosion control measures at stream crossing locations to provide long-term protection of water quality according to the Plan and Procedures and all permit requirements. Sedimentation and increased turbidity can occur as a result of in -stream construction activities, trench dewatering, or stormwater runoff from construction areas. In slow moving waters, increases in suspended sediments (turbidity) may increase the biochemical oxygen demand and reduce levels of dissolved oxygen in localized areas during construction. Suspended sediments also may alter the characteristics of the water column (e.g., color and clarity) on a temporary basis. Atlantic will use material excavated from the pipeline trench to backfill the trench once the pipe is installed to avoid introduction of foreign substances into waterbodies. Atlantic will install temporary equipment bridges to reduce the potential for turbidity and sedimentation resulting from construction equipment and vehicular traffic crossing waterbodies. Temporary bridges will be installed across waterbodies in accordance with the Procedures to allow construction equipment and personnel to cross. The bridges may include clean rock fill over culverts, timber mats supported by flumes, railcar flatbeds, flexi-float apparatuses, or other types of spans. Construction equipment will be required to use the bridges, except that the clearing and bridge installation crews will be allowed one pass through waterbodies before bridges are installed. The temporary bridges will be removed when construction and restoration activities are complete. After the pipeline is installed across a waterbody using one of the methods described above, the trench will be backfilled with native material excavated from the trench. The streambed profile will be restored to pre-existing contours and grade conditions to prevent scouring. The stream banks will then be restored as near as practicable to pre-existing conditions and stabilized. Stabilization measures would include seeding, installation of erosion control Atlantic Coast Pipeline 78 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District blankets, or installation of riprap materials, as appropriate. Temporary erosion controls will be installed immediately following bank restoration. The waterbody crossing area will be inspected and maintained until restoration of vegetation is complete. During construction, the open trench may accumulate water, either from a high water table and seepage of groundwater into the trench or from precipitation. In accordance with the Plan and Procedures, and when necessary, trench water will be removed and discharged into an energy dissipation/sediment filtration device, such as a geotextile filter bag and straw bale structure, to minimize the potential for erosion and sedimentation. In areas where concrete -coated pipe is required, and in accordance with the SPCC Plan, concrete coating activities will occur a minimum of 100 feet from wetlands, waterbodies, and springs. Concrete -coated pipe will be installed after the concrete is dried and will not be dispersed when submerged in water. The SPCC Plan for the ACP will describe measures that personnel and contractors will implement to prevent and, if necessary control, inadvertent spill of fuels, lubricants, solvents, and other hazardous materials that could affect water quality. As required in the Procedures and the SPCC Plan, hazardous materials, chemicals, lubricating oils, and fuels used during construction will be stored in upland areas at least 100 feet from wetlands and waterbodies. Refueling of construction equipment will be conducted at least 100 feet from wetlands and waterbodies, whenever possible. However, there will be certain instances where equipment refueling and lubricating may be necessary in or near waterbodies. For example, stationary equipment, such as water pumps for withdrawing hydrostatic test water, may need to be operated continuously on the banks of waterbodies and may require refueling in place. The SPCC Plan will address the handling of fuel and other materials associated with the ACP. As required by the Procedures, the SPCC Plan will be available during construction on each construction spread. It is possible that previously undocumented sites with contaminated soils or groundwater could be discovered during construction of the ACP. Atlantic has prepared and will implement a Contaminated Media Plan to address these circumstances. The Contaminated Media Plan describes measures to be implemented in the event that signs of contaminated soil and/or groundwater are encountered during construction. Signs of potential contamination could include discoloration of soil, chemical -like odors, or sheens on soils or water. Containment measures will be implemented to isolate and contain the suspected soil or groundwater contamination and collect and test samples of the soil or groundwater to identify the contaminants. Once the contaminants are identified, a response plan will be developed for crossing or avoiding the site. Use of the HDD method avoids impacts on waterbodies because it allows for the pipe to be installed underneath the ground surface without disturbance of the streambed or banks. However, a temporary, localized increase in turbidity could occur in the event of an inadvertent release of drilling fluid to the waterbody. Drilling fluid to be used on the ACP will be composed of water and bentonite clay (a naturally occurring mineral). The U.S. Environmental Protection Agency (EPA) does not list bentonite as a hazardous substance, and no long-term adverse environmental impacts are expected should an inadvertent release occur. Similarly, while native soils may mix with the drilling fluid as a result of the drilling process, drilling fluid is still not Atlantic Coast Pipeline 79 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District considered fill material and no adverse environmental impacts from these materials are expected should an inadvertent return occur. Due to the possibility of drilling fluid loss during HDD operations, Atlantic has prepared and will implement a HDD Plan. The plan describes measures to prevent, detect, and respond to inadvertent returns, including but not limited to, monitoring during drilling operations, the types of equipment and materials that must be readily available to contain and clean up drilling mud, containment and mitigation measures, notification requirements, and guidelines for abandoning the directional drill, if necessary. The use of HDD was considered for wetland and waterbody crossings, but was determined to not be feasible in all crossing locations based on logistical, economic, temporal, and engineering constraints, additional environmental impacts, and potential environmental risks. The HDD method requires that a prefabricated segment of pipe at least the length of the bore hole be staged in line with the drill path at the exit hole, opposite the placement of the drilling rig. This "pullback" generally requires a false right-of-way that can deviate from the right-of- way approaching the crossing, unless the drill alignment is directly in-line with the construction right-of-way for the length of the prefabricated pipe segment. In many cases the drill path is not in-line with the construction right-of-way and additional workspace that extends well outside of the standard construction right-of-way must be cleared and graded to accommodate the prefabrication of the pipe segment described above. The path of the drill is constrained by the flexibility of the pipe; the depth beneath the wetland and/or waterbody needed to achieve a successful installation; and the elevation of the entry and exit points. The entry and exit points should be similar in elevation to prevent a significant pressure differential that can contribute to failure of the HDD operation and by maintaining consistent pressure this helps maintain predictable flow of drilling mud and thus greater likelihood of a successful HDD. As a rule of thumb used in evaluating the feasibility of the HDD method, the 36 -inch diameter pipe requires a minimum drill path of 1,800 feet to achieve an acceptable radius of curvature that will prevent a catastrophic "crinkling" of the pipe as it conforms to the path of the drill hole. All proposed HDD crossings have been designed based on specific site constraints at the crossing and geologic conditions, therefore site-specific designs may vary from the planning guidelines. Atlantic explored use of the HDD method at the Rocky Swamp crossing, but based on geotechnical results, due to heavily weathered bedrock and overlying unconsolidated materials, the likelihood of experiencing an inadvertent release was high. Therefore, the HDD method is not proposed for the Rocky Swamp crossing. A large drill can be more expensive than traditional crossing methods and can take as long as several months to install. Traditional crossing methods of major waterbodies can typically be completed in less than 30 days for major waterbody crossings, whereas typical minor or intermediate waterbody crossings can be completed within a day or a few days. Due to the extended time of exposure of additional workspace associated with HDD coupled with the potential for an inadvertent return, traditional crossing methods can often reduce the Atlantic Coast Pipeline 80 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District environmental impact when compared with HDD. Based on these constraints and design considerations the HDD method is feasible and practicable where large, deep waterbodies are encountered and sufficient space to place the pullback and work area for drilling equipment is available. Atlantic explored use of the HDD method at the Rocky Swamp crossing, but based on geotechnical results, due to heavily weathered bedrock and overlying unconsolidated materials, the likelihood of experiencing an inadvertent release was high. Therefore, the HDD method is not proposed for the Rocky Swamp crossing. The proposed HDD crossing locations on ACP constitute those where it is feasible and the potential for a successful drill is acceptable. Once construction is complete, the pipeline will be buried below the ground surface and, therefore, will not impact water retention or floodplain storage within riparian corridors. Atlantic is routing the proposed pipelines to avoid sharp angle crossings or crossing streams where high stream energy could result in bank erosion. Atlantic will implement measures outlined in the Procedures to minimize impacts on the waterbodies crossed, including the installation of trench plugs to prevent water from flowing along the trenchline during and after construction. These measures will minimize potential impacts on surface and below ground hydrology. All waterbody crossings will be in accordance with the requirements identified in the federal or state waterbody crossing permits obtained for the ACP. During operations, the proposed pipelines will transport natural gas, which consist primarily of methane. Methane is buoyant at atmospheric temperatures and pressure, and disperses rapidly in air. The proposed pipelines will not carry liquids. Therefore, in the unlikely event of a leak, impacts on surface waters or groundwater from methane are not anticipated. Moreover, Atlantic will utilize a rigorous Integrity Management Plan to prevent leaks on the system. The impacts associate with construction are planned to occur in an expedient and efficient manner such that impacts on the waterbody its banks are temporary in nature. In addition, while there are numerous of waterbody crossings across the project in North Carolina, the crossings are distributed across many watersheds. Tables 3 and 4 in section C, Proposed Impacts Inventory, summarizes the impacts on waterbodies by sub -basin (HUC 8). Based on the short duration and distant nature of the waterbody crossings, Atlantic anticipates that cumulative impacts will result in no more than minimal adverse impacts on the basin and sub -basins crossed. See Appendix K — Tables K-1 to Table K-3 for a list of General, Regional and Specific NWP 12 permit conditions and how Atlantic will comply with the conditions. 5. Compensatory Mitigation for Impacts on Waters of the U.S. or Waters of the State In order to authorize any activity under the NWP Program the USACE must determine that the authorized activity in waters of the U.S. meets the terms and conditions of the relevant NWP, in this case NWP 12, which allows no more than 0.5 acre loss at each single and complete project (crossing). Furthermore, provided the activity meets the terms and conditions of NWP 12 USACE must determine that the activity will not result in no more than minimal individual or Atlantic Coast Pipeline 81 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District cumulative impacts on the aquatic environment after considering proposed compensatory mitigation. Such impacts would include the conversion impacts from one type of wetland to another. As stated in the Preamble to 33 CFR 330/NWP Rule issued on November 22, 1991 (56 FR 59118-59119) mitigation can be used to reduce impacts on the aquatic environment to the minimal level: "In response to the comments concerning whether the District Engineer (DE) should allow an activity to proceed under a relevant NWP when the mitigation reduces the adverse environmental effects to the minimal level (the "buy down " or "write down " concept), we believe it is indeed appropriate for the DE to consider mitigation in determining whether the proposed activity will result in no more than a minimal level of adverse environmental effects. " and "In summary, the net impact concept regarding the determination of minimal is consistent with NEPA, the Army/EPA Mitigation Memorandum of Agreement and the Section 404(b)(1) Guidelines as they pertain to general permits." Permanent loss of wetlands is not proposed for anticipated to occur as a result of the ACP mainline pipeline construction or associated facilities in North Carolina. However, loss of waters of the U.S. will occur as a result of access road improvements. Existing access roads will be utilized as much as possible where feasible. Where access road improvements are necessary for use, impacts will be minimized to the maximum extent practicable, and, in conjunction with other impacts will not result in more than 0.5 acre loss of waters of the U.S. at each single and complete project. Atlantic will provide compensatory mitigation for the conversion within the 30 foot permanently maintained right of way (15 feet either side of the pipeline centerline) reseeding with native wetland seed mix and mitigating at a 1:1 ratio for permanent conversion of palustrine forested wetlands to scrub -shrub or to emergent wetlands, and within the temporary disturbed construction right of way reseeding with native wetland seed mix to stabilize the area and replanting in non -inundated deciduous hardwood wetlands (e.g., bottomland hardwood, hardwood riparian, and hardwood flat wetlands) with saplings (minimization and compensatory mitigation), along the ACP right-of-way. Permanent losses of wetlands, streams, and other waters as a result of access roads are proposed to be mitigated at a 2:1 ratio for all wetland types through the purchase of commercially available mitigation credits from an agency -approved mitigation bank as a first option. In-kind mitigation bank credits will be purchased from mitigation banks servicing the areas (HUC 8 watershed, or approved service area) where the conversion or loss occurs. In the event that a conversion or loss occurs in a service area where mitigation bank credits are not available, Atlantic will seek authorization to participate in an agency approved In -Lieu Fee program and/or, Atlantic will seek authorization to purchase credits from outside the service area of the next nearest mitigation bank and/or conduct permittee responsible mitigation (PRM) under an umbrella approach. These options will be based on practicality to replace the ecological function of the temporal loss and amount of compensation required. Atlantic will coordinate with Wilmington District in such cases in order to obtain approval of either option in instances where credits are not available from an agency -approved mitigation bank. Atlantic has completed research to identify wetland mitigation banks with available credits, and will continue to contact wetland mitigation banks to identify available wetland mitigation banks as the primary source of compensatory mitigation for the ACP. As a secondary Atlantic Coast Pipeline 82 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District source of compensatory mitigation, Atlantic will pursue participation in the North Carolina In - Lieu Fee program and/or conduct PRM if adequate wetland mitigation bank credits are not available from an agency -approved bank. With respect to PRM, Atlantic's team is currently in the process of identifying HUC's where an umbrella PRM approach may be applicable. Based on this research, Atlantic's team has begun coordinating with landowners to identify suitable sites and is in the process of negotiating with landowners in order to conduct site research and assessments. Once suitable sites are selected and upon coordination with Wilmington District, Atlantic's team will be available to coordinate and schedule site visits to review the selected sites prior to final approval of the umbrella PRM approach. Atlantic intends to complete field survey on remaining inaccessible parcels, analyze and confirm impacts, and finally purchase adequate mitigation credits and/or secure sites to support the umbrella PRM approach. Atlantic will pursue this sequence of steps to provide for compensatory mitigation prior to final issuance of the JPA. 6. Complete if Using a Mitigation bank See Section D2 above for mitigation options. Additional details will be provided in the final application regarding Atlantic's plans for mitigation bank use and availability in North Carolina. At the time of this draft application, Atlantic continues to plan for mitigation and has provided a conceptual plan in Section D2 above. 7. Complete if Making a Payment to In -lieu Fee Program See Section D2 above for mitigation options. Additional details will be provided in the final application if Atlantic plans to utilize payment to the North Carolina in -lieu fee program as a compensatory mitigation option. 8. Complete if Using a Permittee Responsible Mitigation Plan See Section D2 above for mitigation options. Additional details will be provided in the final application regarding proposed sites, if Atlantic plans to utilize permittee responsible mitigation as a compensatory mitigation option. 9. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWR Buffer rules for the Tar -Pamlico River Basin and Neuse River Basin watersheds provide that mitigation will be required for certain surface water buffer impacts. The buffer rules define two zones for eligible streams. Zone 1 extends 30 feet from the top of the bank landward and Zone 2 extends another 20 feet from the end of Zone 1 landward for a total buffer of 50 feet. Impacts to Zone 1 buffer areas may be allowed with mitigation. The buffer applies to: intermittent streams, perennial streams, lakes, ponds, estuaries and modified natural streams that are depicted on the most recent printed version of the soil survey map prepared by the Natural Resources Conservation Service or the 1:24,000 scale quadrangle topographic map prepared by the USGS. Atlantic has been consulting with NCDEQ to determine which streams in the ACP pipeline corridor are subject to the buffer rule and to determine mitigation impacts. Atlantic Coast Pipeline 83 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District A package was submitted to the NCDEQ in November 2016 with Atlantic's proposed determinations for review. A response letter from NCDEQ was received by Dominion in November 2016 (provided in Appendix I). Table 5 lists the streams that are subject to the buffer rule, the perpendicularity of the stream, and the acreage of Zones 1 and 2 within the construction right-of-way. E. STORMWATER MANAGEMENT AND DIFFUSE FLOW PLAN (REQUIRED BY DWR) Stormwater permit applications and associated Erosion and Sediment Control plans will be developed by Atlantic and will be submitted during late winter -spring 2017. Atlantic is verifying the applicability a diffuse flow plan as part of the Erosion and Sediment Control plan development and permit application submittal to NCDEQ and/or the appropriate local government responsible for review and approval of construction stormwater permitting in North Carolina. 1. Diffuse Flow Plan A diffuse flow plan, is being evaluated by Atlantic, where applicable, and if necessary will be submitted as part of the erosion and sediment control plans and stormwater permitting for the project. Site design plans and review of aboveground facility sites is underway and approvals of erosion and sediment control plans and construction stormwater plans will be submitted to the appropriate agencies. 2. Stormwater Management Plan Stormwater permit applications and associated Erosion and Sediment Control plans will be developed by Atlantic and submitted in March 2017. Atlantic will develop a stormwater management plan, where required, as part of the Erosion and Sediment Control plans that will be submitted to NCDEQ and/or the appropriate local government, as applicable, responsible for review and approval of construction stormwater permitting in North Carolina. 3. Certified Local Government Stormwater Review Stormwater permit applications and associated Erosion and Sediment Control plans will be developed by Atlantic and submitted in spring 2017. Atlantic will develop an Erosion and Sediment Control plan that will be submitted to the appropriate local government and/or NCDEQ, as applicable, responsible for review and approval of construction stormwater permitting in North Carolina. 4. DWQ Stormwater Program Review Atlantic does not anticipate stormwater permitting for the mainline due to the lack of impervious surface after restoration of the pipeline right-of-way. Aboveground facilities are being evaluated for thresholds of impervious and if required stormwater management permits will be acquired for these facilities. Atlantic Coast Pipeline 84 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District 5. DWQ 401 Unit Stormwater Review Atlantic does not anticipate stormwater permitting for the mainline due to the lack of impervious surface after restoration of the pipeline right-of-way. Aboveground facilities are being evaluated for thresholds of impervious and if required stormwater management permits will be acquired for these facilities. F. SUPPLEMENTARY INFORMATION 1. Environmental Documentation (DWQ Requirement) Atlantic filed an application with FERC for a Certificate of Public Convenience and Necessity under Section 7(c) of the Natural Gas Act on September 18, 2015. As a part of the FERC filing process an Environmental Impact Statement will be produced by the FERC for the ACP. A Draft Environmental Impact Statement was published by the FERC on December 30, 2016. 2. Violations (DWQ Requirement) See Section F2 of the PCN Form 3. Cumulative Impacts As part of the USACE evaluation of the single and complete projects of waters of the United States for applicability of coverage under NWP 12, the USACE must determine if the individual and cumulative impacts on the aquatic environment are no more than minimal after considering compensatory mitigation for unavoidable impacts. The single and complete project impacts are presented by HUC 8 watershed in Appendix C and summarized in tables 3 and 4 in Section C. By avoiding impacts onto higher ecological value waters of the United States, narrowing the corridor width to 75 feet in wetlands, and otherwise minimizing impacts to the maximum extent practicable, including minimizing the duration of construction thru wetlands and the long-term conversion by implementing FERC Procedures, Atlantic has made substantial efforts so that impacts of single and complete projects are no more than minimal. Specific measures to minimize impacts include: following FERC Procedures that minimize right-of-way clearing to 10 feet along the pipeline centerline to maintain herbaceous wetland conditions; minimizing deep rooted vegetation trimming to 15 feet either side of the pipeline centerline; providing compensatory mitigation for permanent conversion of palustrine forested wetlands (PFO) to scrub -shrub or emergent wetlands within the 30 foot permanently maintained right of way (15 feet either side of the pipeline centerline) at a 1:1 ratio, and for loss of wetlands as a result of proposed access roads at a 2:1 mitigation ratio; mitigating further by reseeding both the temporarily disturbed and permanently maintained right of ways with native wetland seed mix, and by replanting with saplings the temporarily impacted right-of-way in non -inundated deciduous hardwood wetland areas (e.g., bottomland hardwood, hardwood riparian, and hardwood flat wetlands) that will not be maintained during operations (minimization and compensatory mitigation). As with all impact evaluation under the NWP program, the determination whether there would be no more than minimal cumulative adverse impacts on the aquatic environment is made after considering proposed mitigation (Preamble to 33CFR330;1991 NWPs - 56 FR 59118-59119). Furthermore, based on the level of conversion Atlantic Coast Pipeline 85 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District impacts occurring within each HUC 8 watershed, and the fact that all conversion impacts to palustrine forested wetlands will be have been offset by compensatory mitigation, the cumulative impacts on the aquatic environment have been reduced to no more than minimal as described in Section D.1., above. "In response to the comments concerning whether the DE should allow an activity to proceed under a relevant NWP when the mitigation reduces the adverse environmental effects to the minimal level (the "buy down " or "write down " concept), we believe it is indeed appropriate for the DE to consider mitigation in determining whether the proposed activity will result in no more than a minimal level of adverse environmental effects. " and "In summary, the net impact concept regarding the determination of minimal is consistent with NEPA, the Army/[U.S. Environmental Protection Agency] EPA Mitigation MOA and the Section 404(b)(1) Guidelines as they pertain to general permits. " The Preamble of the March 2012 NWP issuance package also indicates that cumulative effects will normally be evaluated on a watershed basis. Each separate and distant crossing should be evaluated to determine if it meets the terms and conditions of the NWP, and cumulative effects of the overall utility line should be evaluated to determine if the adverse cumulative effects on the aquatic environment are more than minimal and therefore do not qualify for NWP authorization. Separate utility line crossings are usually on different water bodies, and may also be in widely separated watersheds. Such factors should be considered when assessing cumulative impacts. " (77 FR 10196)" "For single and complete linear projects, each separate and distant crossing of a waterbody, as well as each crossing of other waterbodies along the corridor for the linear project maybe permitted by separate NWP authorizations. The acreage and other applicable limits for an NWP would be applied to each crossing, as long as those crossings are far enough apart to be considered separate and distant. District engineers will evaluate the cumulative effects of those linear projects when determining whether authorization by NWP is appropriate. The approach to cumulative effects analysis for linear projects is little different than the cumulative effects analysis for other types of NWP activities, including those circumstances in which more than one NWP is used to authorize a single and complete non-linear project, because cumulative effects are evaluated on a regional basis. Cumulative effects analysis may be done on a watershed basis, or by using a different type of geographic area, such as an ecoregion. " (77 FR 10264) The Preamble of the January 6, 2017 NWP Program Final Rule states in addition: "We are retaining the Y2 -acre limit for this NWP because we believe it is an appropriate limit for authorizing most utility line activities that have no more than minimal individual and cumulative adverse environmental effects. Division engineers can modify this NWP on a regional level to reduce the acreage limit if necessary to ensure that no more than minimal adverse environmental effects occur in that region. Atlantic Coast Pipeline 86 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District We do not agree that the acreage limit should apply to the entire utility line because the separate and distant crossings of waters of the United States are usually at separate waterbodies scattered along the length of the utility line, and are often in different watersheds especially for utility lines that run through multiple counties, states, or Corps districts. For utility lines that cross the same waterbody (e.g., a river or stream) at separate and distant locations, the distance between those crossings will usually dissipate the direct and indirect adverse environment effects so that the cumulative adverse environmental effects are no more than minimal. If the district engineer determines after reviewing the PCN that the cumulative adverse environmental effects are more than minimal, after considering a mitigation proposal provided by the project proponent, he or she will exercise discretionary authority and require an individual permit. " (FR Notice, January 6, 2017 Final Rule Preamble p1885) The USACE mitigation rule at 33 Code of Federal Regulations 332.8(d)(6)(ii)(A), and North Carolina General Statutes § 143-214.11, provides that normally mitigation service areas would be at the HUC 8 watershed level. HUC 8 has been used as the size of watershed in which to present the cumulative impacts of the proposed Project. The vast majority of the ACP impacts on waters of the U.S. would result from the temporary discharge of earthen fill material associated with trench excavation for pipeline installment within the rights-of-way. Furthermore, to facilitate construction equipment for pipeline installation forested and scrub/shrub wetlands would be cleared and stumps removed only where required for safe passage during pipeline installment. Where temporary discharges of fill or excavation is necessary, Atlantic will immediately restore the wetland to its pre - construction contours. The center 30 -feet of the cleared rights-of-way that previously consisted of forested wetlands will be permanently maintained free of trees. The center 10 -feet of the cleared rights-of-way that previously consisted of forested or scrub -shrub wetlands will be permanently maintained in an emergent wetland state. This maintenance for the life of the project, while not resulting in a loss of waters of the U.S., will result in a permanent impact to wetland function and value, which would otherwise exist had the vegetative cover of the wetland not been altered. These functional losses will be offset by proposed compensatory mitigation at a 2:1 ratio. This has been described as permanent conversion in associated tables. Atlantic has taken great steps to avoid permanent loss of waters of the U.S. and has successfully avoided loss of waters of the U.S. for the pipeline and at permanent aboveground facilities in the Wilmington District. However, loss of waters of the U.S. will occur as a result of access road improvements totaling 1.72 acres with no loss at each single and complete crossing exceeding the 0.5 acre NWP 12 threshold. However, the proposed pipeline will result in the permanent conversion of 148.8 acres of palustrine forested wetlands to scrub -shrub or to emergent wetland along with ACP construction. These impacts are included in Appendix C. In conjunction with the offset of the functional losses mentioned above, Atlantic will reestablish the area outside of the 30 -foot maintained corridor in deciduous hardwood forested wetlands. This reestablishment, along with natural revegetation, will encourage the temporarily impacted to areas to return to a more natural state faster than natural revegetation could accomplish while lessening the time to return to the pre -construction condition. Reestablishment will include planting saplings of deciduous hardwood species in non -inundated areas of Atlantic Coast Pipeline 87 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District deciduous hardwood wetlands impacted by clearing for the construction right-of-way and reseeding of these wetland areas with native wetland seed mix. The temporary impacts and permanent conversion impacts of the proposed ACP are provided in detail in Appendix C, and summarized by HUC 8 watershed in Section C above. A total of 455.9 acres of temporary wetland impacts, and conversion of 148.8 acres of palustrine forested wetland to scrub -shrub or emergent wetland impacts are planned along with ACP construction. There will be no loss of waters of the U.S. due to mainline pipeline crossings of waters of the U.S. Despite potential minor loss of waters of the U.S. for access road improvements and the wetland conversion impacts, the compensatory mitigation plan will provide for impact offsets and Atlantic does not anticipate a net loss in aquatic functions and services of the waters of the U.S. The reestablishment of the wetland area outside of the 30 -foot maintained corridor will assist in minimizing the temporary impacts due to clearing for construction. Assessment of cumulative effects also involves a general characterization of impacts on waters of the U.S. from similar types of projects in the past and reasonably foreseeable future. The area that the pipeline would traverse largely involves a mix of small community development, agricultural use and open undisturbed forested land. Past impacts would be those of typical rural development with road and various utility line crossings of streams and wetlands in support of agriculture and dispersed human development. Reasonably foreseeable impacts would include continued slow additional growth in the small human communities with associated road and utility line crossings of waters of the U.S. As provided in the USACE 2017 NWP issuance document at 77 FR 10197, cumulative impacts on the human environment other than impacts on waters of the U.S. will be evaluated by FERC in its NEPA EIS process. "Even though an environmental impact statement may be prepared for a particular utility line, the National Environmental Policy Act process does not prohibit the Corps from using NWP 12 to authorize the construction, maintenance, repair, and removal of utility lines and associated facilities in waters of the United States, as long as the activity complies with all applicable terms and conditions and results in minimal individual and cumulative adverse effects on the aquatic environment. NEPA requires consideration of all environmental impacts, not only those to aquatic resources, so there may well be situations where aquatic impacts are minimal even though environmental impacts more generally are not. These other environmental impacts would be addressed by the lead agency preparing the environmental impact statement. " The purpose of the proposed pipeline is to transport natural gas from West Virginia and Pennsylvania to use in areas of Virginia and North Carolina. Other pipelines, subject to future approvals with mitigation as appropriate and practicable, may be required to transport natural gas that may in the future be produced from the Marcellus Shale and Utica Shale formations. Other pipeline development in the areas traversed by the Project would involve mostly temporary impacts on waters of the U.S. that would be restored after pipeline construction is completed. Permanent loss and wetland conversion impacts of waters of the U.S. would be mitigated to achieve no more than minimal impact through USACE and state permit actions offsetting the Atlantic Coast Pipeline 88 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District impacts on streams and wetlands. Moreover, USACE Headquarters evaluated the cumulative impacts on waters of the U.S. in its decision document supporting reissuance of NWP 12 in 2017. The USACE evaluation of impacts nationwide determined that there would be no more than minimal cumulative impacts on waters of the U.S. Part of the USACE Headquarters evaluation of cumulative impacts identified that USACE districts would evaluate cumulative impacts on waters of the U.S. of the "overall pipeline project" it authorized based on evaluation of impacts on the aquatic environment on a watershed basis. The USACE Headquarters cumulative impact evaluation was partially based on full restoration of temporary impacts, districts requiring compensatory mitigation for permanent loss of waters and conversion impacts such as the compensatory mitigation proposed by Atlantic for the ACP and that high ecological value aquatic areas would be avoided as has been done on the ACP through coordination with the USACE districts. Based on the fact that the majority of the overall pipeline project impacts on waters of the U.S. are temporary with restoration of aquatic areas immediately after construction and that permanent conversion of forested and scrub -shrub wetlands to other wetland types and small unavoidable road fills will be mitigated, the impacts at each single and complete project will result in no more than minimal impact. Furthermore, the proposed impacts including loss of waters of the U.S. at each single and complete project are of such minimal impact that they will qualify for NWP 12 in North Carolina. The fact that these impacts, resulting in no more than minimal impact on wetlands, streams and other waters of the U.S., at each single and complete project, are spread widely over numerous watersheds and over approximately 198.7 miles in the North Carolina, clearly indicates that the cumulative aggregate impacts of the overall pipeline project to waters of the U.S. will be no more than minimal as well. Therefore the cumulative impacts of the overall pipeline project on each HUC 8 watershed are not of a nature or extent that would result in the requirement of an individual permit for the Project. As provided in the Preamble of the January 6, 2017 USACE 2017-2022 NWP Program Final Rule: "We are retaining the long-standing practice articulated in the NWP regulations at 33 CFR 330.2 (i), which each separate and distant crossing of waters of the United States is authorized by NWP. ....For the purposes of this NWP, the term "crossing" refers to regulated activities. ...The substations, tower foundations, roads, and temporary fills that are also authorized by NWP 12 (when those activities require DA authorization) are integral to the fulfilling the purpose of utility lines, and thus fall within the "categories of activities that are similar in nature" requirement for general permits stated in section 404(e) of the CWA." .... The Corps does not regulate oil and gas pipelines, or other types of pipelines, per se. For utility lines, including oil and gas pipelines, our legal authority is limited to regulating discharges of dredged or fill material into waters of the United States and structures or work in navigable waters of the United States, under section 404 of the Clean Water Act and section 10 of the Rivers and Harbors Act of 1899, respectively. We do not have the authority to regulate the operation of oil and gas pipelines, and we do not have the authority to address spills or leaks from oil and gas pipelines.... In addition, we do not have the legal authority to regulate the construction, maintenance, or repair of upland segments of pipelines or other types of utility lines. For example, for a recent oil pipeline (e.g., the Flanagan South pipeline), the segments of the oil pipeline that were subject to the Corps' jurisdiction (i.e., the crossings of waters of the United Atlantic Coast Pipeline 89 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District States, including navigable waters of the United States, that were authorized by the 2012 NWP 12) was only 2.3 percent of the total length of the pipeline; the remaining 97.7 percent of the oil pipeline was constructed in upland areas outside of the Corps' jurisdiction. Interstate natural gas pipelines are regulated by the Federal Energy Regulatory Commission. The Federal Energy Regulatory Commission also regulates some electric transmission projects. There are other federal laws that address the operation of pipelines and spills and leaks of substances from pipelines. Those laws are administered by other federal agencies." (FR Notice, January 6, 2017 Final Rule Preamble pp. 1883-1884) The cumulative impacts analysis submitted with the FERC Resource Report 1, in support of the project NEPA analysis, is provided in Appendix L for additional details. 4. Sewage Disposal (DWR Requirement) See Section F4 of the PCN Form 5. Endangered Species and Designated Critical Habitat (USAGE Requirement) The ACP is a FERC 7c regulated project and the USACE is participating in the pre -filing process as a cooperating agency. FERC is coordinating the review of Section 7 Endangered Species Act compliance with the FWS. Pursuant to the General Conditions 18 and 31 for NWPs, Atlantic initiated Section 7 Endangered Species Act coordination with the FWS. In a technical assistance letter dated August 15, 2014 Atlantic initiated the Section 7 review with the FWS North Carolina Raleigh Ecological Field Services Office. Agency correspondence can be found in Appendix I. Section 7 of the Endangered Species Act requires federal agencies to verify that any actions authorized, funded, or carried out by the agencies do not jeopardize the continued existence of a federally listed threatened or endangered species, or result in the destruction or adverse modification of designated critical habitat for a federally listed species. The law is jointly administered by the FWS, which is responsible for terrestrial and freshwater species, and National Oceanic and Atmospheric Administration National Marine Fisheries Service (NOAA Fisheries), which is responsible for marine and anadromous species. As the lead Federal agency for authorizing the ACP, FERC is required to coordinate with the FWS and NOAA Fisheries to determine whether federally listed endangered or threatened species or designated critical habitat are found in the vicinity of the ACP, and to evaluate the potential effects of the proposed actions on those species or critical habitat. For actions involving major construction activities with the potential to affect listed species or designated critical habitat, the FERC must report its findings to the FWS and NOAA Fisheries in a Biological Assessment (BA) for those species that could be affected. If it is determined that the proposed action is likely to adversely affect listed species or designated critical habitat, the FERC is required to initiate formal consultation with the appropriate federal agency. Atlantic reviewed the Information Planning and Conservation System (lPaC System) to determine which federally listed species could occur in the ACP Project area. Atlantic Atlantic Coast Pipeline 90 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District additionally coordinated with the FWS Ecological Field Services Office in North Carolina to introduce the Project and begin discussing and addressing potential impacts on federally listed species and designated critical habitat. Correspondence with agencies is located in Appendix I. For the ACP, Atlantic sent letters to the North Carolina FWS EFSO and the NOAA Fisheries' Office of Protected Resources in August 2014 requesting early coordination and technical assistance based on the species lists obtained through the IPaC System. These letters requested verification of the species that could be impacted by the ACP Project as well as direction on field survey protocols for species-specific surveys. Atlantic requested and received National Heritage Inventory data for a two -mile -wide corridor centered on the proposed pipeline centerlines which includes the locations of aboveground facilities. This data identifies occurrences of state and federal -listed species as well as sensitive or significant habitats including parks, forests, or nature preserves located along or adjacent to the proposed pipeline routes. Based on information obtained through IPaC System, National Heritage Inventory, and agency consultations, Atlantic has compiled a preliminary list of 20 federally listed, proposed, or under review species that potentially occur within the ACP Project area within the USACE — Wilmington District (Table 8). Atlantic has prepared a final draft BA (version 5) evaluating the potential impacts of the Projects on federally listed species. Atlantic filed the final draft BA with FERC on January 27, 2017, and a copy was also provided to the FWS and the USACE. State -listed species in North Carolina are separated into three categories: North Carolina Endangered, North Carolina Threatened, and North Carolina Special Concern. Species listed in these categories have been recognized as needing additional conservation by the North Carolina Wildlife Resources Commission (NCWRC) under the State Endangered Species Act (G.S. 113- 331 to 113-337). Atlantic requested and received data on known occurrences of State -listed species within a two -mile -wide corridor centered on the proposed ACP pipeline routes from the NCDEQ. Table 9 summarizes this data. Atlantic Coast Pipeline 91 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Abbreviations for species federal status are as follows: E = Endangered T = Threatened UR — Under review P- Proposed Atlantic Coast Pipeline 92 DRAFT TABLE 8 Atlantic Coast Pipeline Project Federally Listed Species and Species Proposed for Federal Listing within the U.S. Army Corps of Engineers — Wilmington District Species Status' Areas of Potential Occurrence Bird Red -cockaded Woodpecker E All counties crossed by the Project (Picoides borealis) Wood Stork E Sampson County (Mycteria Americana) Fish Atlantic Sturgeon E Roanoke and Neuse Rivers (Acipenser oxyrinchusoxyrinchus) Cape Fear Shiner E Cape Fear River Drainage (Notropis mekistocholas) Carolina madtom UR Tar and Neuse River Basins (Noturus furiosus) Shortnose Sturgeon E Downstream occurrences in adjacent Bladen County (Cipenser brevirostrum) Freshwater Mussels Atlantic pigtoe UR Northampton, Halifax, Nash, Wilson, Johnston, and Cumberland Counties (Fusconaia mason) Dwarf Wedgemussel E Wilson, Johnston, and Nash Counties (Alasmidonta heterodon) Tar River Spinymussel E Halifax, Johnston, and Nash Counties (Elliptio steinstansana) Green floater UR Roanoke, Tar, and Neuse River basins (Lasmigona subviridis) Yellow Lance UR Halifax, Johnston, and Nash Counties (Elliptio lanceolata) Invertebrate Saint Francis' Satyr E Cumberland County (Neonympha mitchelliifrancisca) Chowanoke crayfish UR Roanoke River basin (Orconectes virginiensis) Rusty patched bumble bee P Entire project area (Bombus affznis) Mammals Nor -them long-eared bat T All counties crossed by the Project (Myotis septentrionalis) Plants American Chaffseed E Cumberland County (Schwalba americana) Michaux's Sumac E Cumberland, Johnson, Nash, Robeson, and Wilson Counties (Rhus michauxii) Pondberry E Cumberland and Sampson Counties (Lindera melissifolia) Rough -leaved Loosestrife E Cumberland County (Lysimachia asperulifolia) Amphibians Neuse River waterdog UR Tar and Neuse River Basins (Necturus lewisi) Abbreviations for species federal status are as follows: E = Endangered T = Threatened UR — Under review P- Proposed Atlantic Coast Pipeline 92 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Abbreviations for state -listed species are as follows: E = Endangered T = Threatened SC = Special Concern SR = Significantly Rare P = Petitioned for Federal listing Atlantic Coast Pipeline 93 DRAFT TABLE 9 State -listed Endangered and Threatened Species within the U.S. Army Corps of Engineers — Wilmington District Species Status a Area of Potential Occurrence Amphibians Neuse River Waterdog SC Halifax, Nash, Johnston, Wilson Mammals Rafinesque's Big -eared Bat (Coastal Plain subspecies) SC All Counties Crossed Southeastern Myotis SC All Counties Crossed Birds Bachman's Sparrow SC Halifax, Sampson, Cumberland, Robeson Cerulean Warbler SC Halifax, Northampton Fish Carolina Madtom T Halifax, Nash, Johnston, Wilson Crayfish SC Halifax, Northampton North Carolina Spiny Crayfish SC Nash Reptiles Southern Hog -nosed Snake SC Robeson Freshwater Mussels Alewife Floater T Halifax, Nash, Johnston, Wilson Atlantic Pigtoe E Halifax, Nash, Johnston, Wilson Cape Fear Spike SC Halifax, Nash, Johnston, Wilson Creeper T Halifax, Nash, Johnston, Wilson Eastern Lampmussel T Halifax, Nash, Johnston, Wilson Eastern Pondmussel T Halifax, Nash, Johnston, Wilson Green Floater E Halifax, Nash, Johnston, Wilson Notched Rainbow SC Halifax, Nash, Johnston, Wilson Roanoke Slabshell T Halifax, Nash, Johnston, Wilson Tidewater Mucket T Halifax, Nash, Johnston, Wilson Triangle Floater T Halifax, Nash, Johnston, Wilson Yellow Lampmussel E Halifax, Nash, Johnston, Wilson Yellow Lance E Halifax, Nash, Johnston, Wilson Plants American Bluehearts E Sampson Awned Meadow -beauty SC Cumberland, Robeson, Sampson Bog Spicebush P Cumberland, Johnston, Robeson Boykin's Lobelia E Cumberland, Robeson Buffalo Clover T Halifax Canby's Bulrush SR Cumberland, Johnston Cape Fear Spatterdock P Cumberland, Nash, Robeson, Sampson Carolina Bogmint E Johnston, Robeson, Sampson Georgia Indigo -Bush , E Cumberland, Robeson Long Beach Seedbox P Cumberland, Johnston, Robeson, Sampson One -flower Hardscale SR Cumberland, Robeson, Sampson Raven's Seedbox T Sampson Running Oak SR Robeson Sandhills Lily E Cumberland Sessile -flowered Trillium T Halifax, Northampton Small -flower Blueberry SR Cumberland, Robeson Spring -flowering Goldenrod SR Cumberland, Johnston, Sampson Thin-wall Quillwort T Sampson Winter Quillwort P Johnston, Sampson Abbreviations for state -listed species are as follows: E = Endangered T = Threatened SC = Special Concern SR = Significantly Rare P = Petitioned for Federal listing Atlantic Coast Pipeline 93 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District In addition to this data, Atlantic solicited and received comments in a letter dated November 21, 2014 from the NCWRC regarding known occurrences of State -listed aquatic species along the proposed routes. The NCWRC requested a mussel survey in streams that are second order or larger within the Neuse and Tar River basins. For any streams where mussels are present at the crossing, a second mussel survey is planned to relocate mussels that could be impacted during pipeline installation. Surveys for Carolina madtoms will be completed at the same time as the mussel surveys in the Tar and Neuse basins. The NCWRC also requested mussel surveys in the Roanoke and Cape Fear Rivers immediately prior to pipeline installation to relocate mussels that will be impacted by construction. Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act Atlantic will comply with the applicable portions of both the Migratory Bird Treaty Act (MBTA) and the Bald and Golden Eagle Protection Act. Atlantic plans to clear the pipeline right-of-way outside of the migratory bird nesting season to reduce potential impacts on migratory birds and other sensitive species. Atlantic will avoid impacts on nests observed within the construction right-of-way in accordance with the MBTA. In the event that an active bald eagle nest is identified in the vicinity of the project, Atlantic will adhere to the requirements of the National Bald Eagle Management guidelines to minimize potential impacts on nesting eagles. Migratory Bird Plan to describe measures it has implemented or will implement to avoid, minimize and mitigate potential impacts on migratory birds, including bald and golden eagles, consistent with the MBTA and Bald and Golden Eagle Protection Act Plan to the FERC on January 27, 2017, with a copy sent also to the FWS and the USACE. 6. Essential Fish Habitat (USACE Requirement) Atlantic consulted with NOAA Fisheries' Southeast and Northeast Regional Offices to introduce the ACP and request technical assistance (Dominion, 2014a; Dominion, 2014b). In their reply, the Southeast Regional Office (NOAA Fisheries, 2014a) concurred with Atlantic that no Essential Fish Habitat (EFH) will be affected by the proposed ACP in North Carolina because the AP -2 mainline route does not cross or pass near EFH. In addition, the AP -3 mainline does not cross or pass near EFH in North Carolina. 7. Historic or Prehistoric Cultural Resources (USACE Requirement) The ACP is a FERC 7c regulated project and the USACE is participating in the FERC NEPA process as a cooperating agency. FERC, as the lead agency for the project, will be coordinating with the North Carolina State Historic Preservation Office for the review of compliance with Section 106 of the National Historic Preservation Act, as well as coordinating its government -to -government consultation with federally recognized Indian Tribes. For the FERC process, the area of potential effect (APE) for archaeological sites was defined horizontally as the proposed pipeline corridor and associated workspace, footprints of aboveground facility sites, and footprints of other work areas; and vertically as the maximum depth of trenching and other excavations or the depth to which evidence of human occupation could be found. The APE for aboveground historic resources was defined to include the proposed pipeline corridor and associated workspace, footprints of aboveground facility sites, and footprints of other work areas. The APE for aboveground historic resources also included Atlantic Coast Pipeline 94 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District viewsheds to and from historic sites along or near the proposed facilities. The linear extent of the viewsheds varied by site depending on changes in topography, vegetation cover, and the presence of structures or other obstructions in sight lines to and from aboveground historic resources. The reports presenting the results of the cultural resources surveys for the Project can be provided to the USACE — Wilmington upon request, along with copies of documentation of State Historic Preservation Office review and comment when they become available. See Appendix M for the Plan for Unanticipated Discovery of Historic Properties or Human Remains During Construction. 8. Tribal Coordination The ACP is a FERC 7c regulated project and the USACE is participating in the pre -filing process as a cooperating agency. FERC will be coordinating with the North Carolina State Historic Preservation Office for the review of Section 106 of the National Historic Preservation Act compliance, as well as coordinating its government -to -government consultation with federally recognized Indian Tribes as part of the Section 106 consultation process. Project introduction letters for the entire ACP/SHP were sent to 15 federally recognized Indian Tribes that might have interest in the Project area based on historic information. See Appendix N for a summary of communications with these Indian Tribes. The 15 federally recognized Indian tribes that were contacted regarding the ACP and/or SHP are listed below: • Absentee -Shawnee Tribe of Indians of Oklahoma; • Catawba Indian Nation; • Cherokee Nation; • Delaware Nation; • Delaware Tribe of Indians; • Eastern Band of Cherokee Indians; • Eastern Shawnee Tribe of Oklahoma; • Pamunkey Tribe; • Seneca -Cayuga Tribe of Oklahoma; • Seneca Nation of Indians; • Shawnee Tribe; • Stockbridge Munsee Community; • Tonawanda Band of Seneca Indians of New York; • Tuscarora Nation of New York; and • United Keetoowah Band of Cherokee Indians. Atlantic contacting state recognized tribes in the ACP project area in Virginia and North Carolina. The following seven state recognized tribes identified by the North Carolina Commission of Indian Affairs were contacted for the ACP: 1. Coharie Tribe; 2. Haliwa-Saponi Indian Tribe; 3. Lumbee Tribe of North Carolina; 4. Meherrin Indian Tribe; Atlantic Coast Pipeline 95 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District Occaneechi Band of the Saponi Nation; Sappony Tribe; and Waccamaw Siouan Tribe. The following 10 state recognized tribes identified by the Secretary of the Commonwealth of Virginia Commission of Indian Affairs were contacted for the ACP: 1. Cheroenhaka (Nottoway) Tribe; 2. Chickahominy Tribe; 3. Eastern Chickahominy Tribe 4. Monacan Indian Nation; 5. Mattoponi Tribe; 6. Nansemond Tribe; 7. Nottoway Tribe; 8. Patawomeck Tribe; 9. Rappahannock Tribe; and 10. Upper Mattaponi Tribe. There are no state recognized Indian tribes in West Virginia. Atlantic sent introductory Project letters to the Indian tribes which included a Project description and location maps, and invited each tribe to comment on the Project. In addition, the letters requested input from each of the tribes regarding the potential of the Project to affect archaeological sites, burials, and traditional cultural properties of concern to each tribe. Atlantic received confirmation of delivery of all of the letters. Communication with the tribes is ongoing as part of the Section 106 consultation process. 9. Flood Zone Designation (USACE Requirement) The ACP Project will cross several Federal Emergency Management Agency -designated 100 -year floodplains throughout North Carolina. Atlantic will apply for local permits as required by regulations and local agencies. Federal Emergency Management Agency 100 -year floodplains crossed by the ACP can be found in Appendix A — Figure A-5. Atlantic has been working with the counties in North Carolina and will apply for applicable floodplain permits. G. SECTION 408 AUTHORIZATION Section 14 of the Rivers and Harbors Act of 1899 and codified in 33 U.S. Code 408 (commonly referred to as "Section 408") authorizes the Secretary of the Army, on the recommendation of the Chief of Engineers of the USACE, to grant permission for the alteration or occupation or use of a USACE Civil Works project if the Secretary determines that the activity will not be injurious to the public interest and will not impair the usefulness of the project. Atlantic submitted a letter to USACE — Wilmington District on June 15, 2016 requesting a review of USACE projects within Wilmington District Civil Works boundaries that maybe crossed by the ACP, to determine whether or not a Section 408 permission would be required. Wilmington District reviewed the location of proposed ACP pipeline and facilities and determined that Atlantic Coast Pipeline 96 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District the crossing of the Cape Fear River would require a Section 408 permission. The District, in a letter dated November 3, 2016 signed by Colonel Kevin P. Landers, Sr., Commander Wilmington District, granted the request for the pipeline to cross the Cape Fear River for the following reasons: "(1) the proposed action will not be injurious to the public interest, and (2) the proposed action will not impair the usefulness of thefederalproject. As the requestor, Atlantic is solely responsible for any remedial action needed to correct any deficiency in the design or construction of the requested alteration. " stating that the District had reviewed the proposed alignment and determined that the pipeline path would not encroach on any Corps property and is far enough removed from any Corps infrastructure so as to not require a Section a Section 408 permission per the date of the design location received and dated April 1, 2016 (second location revision). " Correspondence is included in Appendix I. 4L r' Atlantic Coast Pipeline 97 DRAFT Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information DRAFT U.S. Army Corps of Engineers — Wilmington District H. REFERENCES Council on Environmental Quality. 1997. Considering Cumulative Effects under the National Environmental Policy Act. January 1997. Council on Environmental Quality. 2005. Guidance on the Consideration of Past Actions in Cumulative Effects Analysis. June 2005. Dominion. 2014a. Letter to David Dale (NOAA Fisheries EFH Southeast Region Coordinator) from William Scarpinato (Dominion) dated September 9, 2014. Dominion. 2014b. Letter to Karen Greene (NOAA Fisheries EFH Northeast Region Coordinator) from William Scarpinato (Dominion) dated September 9, 2014. ICF International. 2014. The Economic Impacts of the Atlantic Coast Pipeline. Prepared by ICF International for Dominion Transmission, Inc. February 9, 2015. Available online at: https://www.dom.com/library/domcom/pdfs/lzas-transmission/atlantic-coast-pipeline/ acp-icf-study_pdf. Accessed May 2015. Mid -Atlantic Fishery Management Council, 2014.Fishery Management Plans and Amendments for species managed by the Mid -Atlantic Fishery Management Council. Available online at: http://www.mafmc.or fishery-mana eg ment-plans/. Accessed September 2014. National Oceanic and Atmospheric Administration Fisheries. 2014d. The Guide to Essential Fish Habitat Designations in the Northeastern United States. Available online at: http://www.greateratlantic.fisheries.noaa.gov/hcd/webintro.html. Accessed September 2014. National Oceanic and Atmospheric Administration Fisheries. 2014a. E-mail to Sara Throndson (NRG) from David O -Brien (NOAA Fisheries Biologist Virginia Field Office) dated September 2014. National Oceanic and Atmospheric Administration Fisheries. 2014b. Letter to William Scarpinato (Dominion) from Virginia Fay (NOAA Fisheries Assistant Regional Administrator Habitat Conservation Division) dated September 2014. National Oceanic and Atmospheric Administration Fisheries. 2014c. NOAA Fisheries Essential Fish Habitat Mapper. Available online at: http://www.habitat.noaa.goy/protection /efh/habitatmapper.html. Accessed September 2014. National Oceanic and Atmospheric Administration Fisheries. 2014e. NOAA Estuarine Living Marine Resources. Available online at: hl�2:Hccma.nos.noaa.gov/ecosystems/ estuaries/elmr.aspx. Accessed September 2014. 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May 1999. 14 Atlantic Coast Pipeline 100 DRAFT ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX A FIGURES FIGURE 3 TOPOGRAPHIC MAPS FIGURE 4 AERIAL SHEET MAP FIGURE 5 FEMA FLOODPLAINS FIGURE 6 NORTH CAROLINA BUFFER ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX B WETLAND AND WATERBODY SURVEY REPORT ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX C WETLAND AND WATERBODY CROSSING IMPACT TABLE ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX D SUPPLEMENTAL FERC UPLAND CONSTRUCTION INFORMATION ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX E RIGHT-OF-WAY CROSS SECTION DRAWINGS AND SELECT CONSTRUCTION TYPICALS ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX F SECTION 10 WATERS SITE SPECIFIC PLANS ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX G SPILL PREVENTION, CONTROL, AND COUNTERMEASURES PLAN ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX H HORIZONTAL DIRECTIONAL DRILL FLUID MONITORING, OPERATIONS, AND CONTINGENCY PLAN ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX I AGENCY CORRESPONDENCE ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX J RESTORATION AND REHABILITATION PLAN ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX K GENERAL, REGIONAL, AND SPECIAL PERMIT CONDITIONS TABLES ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX L CUMULATIVE IMPACTS ANALYSIS - FERC RESOURCE REPORT 1 ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX M PLAN FOR UNANTICIPATED DISCOVERY OF HISTORIC PROPERTIES OR HUMAN REMAINS DURING CONSTRUCTION ATLANTIC COAST PIPELINE, LLC ATLANTIC COAST PIPELINE Nationwide Permit 12 Pre -Construction Notification U.S. Army Corps of Engineers — Wilmington District North Carolina Department of Water Quality APPENDIX N CORRESPONDENCE WITH FEDERALLY RECOGNIZED INDIAN TRIBES