20140957 Ver 1_Letter from 19 Organizations_20170428

Burdette, Jennifer a
From: Hope Taylor < [e-mail] >
Sent: Friday, April 28, 2017 2:27 PM
To: Regan, Michael S; Tarr, Jeremy M; Owen, Jenni
Cc: Davis, Tracy; Hardison, Lyn; Rice, Sarah M; Zimmerman, Jay; Culpepper, Linda;
Burdette, Jennifer a
Subject: Letter from 19 Organizations Re: Atlantic Coast Pipeline Concerns; Request for
meeting
Appalachian Voices — Canary Coalition — Chatham Research Group Clean Air Carolina — Clean Water
for North Carolina — Concerned Citizens of Northampton County Coastal Carolina Riverwatch
DownEast Coalition — Environmental -EE — Haw River Assembly — Nash Stop the Pipeline — No Fracking in
Stokes — Pee Dee Water, Air, Land and Lives — RiverGuardian Foundation — Save Our Sandhills
Sustainable Sandhills — 350.org Triangle — Triangle Womens' International League for Peace and
Freedom — Winyah Rivers Foundation
April 28, 2017
Governor Roy Cooper (via web form and US mail)
NC Office of the Governor
20301 Mail Service Center
Raleigh, NC 27699-0301
Via email: Jeremy Tarr, Office of the Gov. Policy Advisor Environment, Energy, Transportation
Jenni Owen, Director of Policy, Office of the Governor
NC DEQ Secretary Michael Regan (via email and US mail)
1601 Mail Service Center
Raleigh, N.C. 27699-1601
Via email: Tracy Davis, Director, DEQ Div. of Energy Mining and Land Resources
Lyn Hardison, DEQ EIS Coordinator; Sarah Rice, DEQ Environmental Justice Coordinator
Jay Zimmerman, Director, Div. of Water Resources
Linda Culpepper, Div. of Water Resources; Jennifer Burdette, Water Resources, 401 Unit
Dear Governor Cooper and Secretary Regan:
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This letter is from 19 partner organizations in FrackFreeNC, a grassroots alliance working to prevent fracking
and unneeded and dangerous gas infrastructure in North Carolina, in order to deepen the conversation about
our still growing concerns about the Atlantic Coast Pipeline.
The Atlantic Coast Pipeline is Unneeded, Costly, Dangerous and Unjust for North Carolinians
We are writing on behalf of organizations deeply concerned about the impacts of the proposed Atlantic Coast
Pipeline (ACP) on landowners, local governments, vulnerable Environmental Justice Populations, and on the
waters and economy of eastern NC. The owners of the proposed 600 mile gas pipeline—including affiliates of
Dominion Power and Duke Energy-- have distributed materials and statements to the public as well as local and
state officials in order to garner support for the proposed ACP that contain significant unsubstantiated and
misleading information. We include below a summary of the major concerns we have articulated in official
comments to the Federal Energy Regulatory Commission (FERC), as well as some concerns raised by the US EPA
and DEQ staff in comments submitted to (FERC), and we also represent members of a number of impacted
communities along the proposed pipeline route.
1. The ACP is not needed for residential and economic development needs and increases our climate vulnerability
. FERC has carried out no regional analysis to assess either the need for, nor impact of, several planned major gas
pipeline projects in the Southeastern US. Numerous studies, including a 2015 U.S. Department of Energy study
and a FERC staff report the same year, conclude that there is sufficient capacity in existing pipelines to meet
foreseeable energy requirements and that the nation, and especially our region, is headed toward a massive
overbuilding of natural gas pipelines, far in excess of demand. Many industry observers acknowledge that the
Transco pipeline, with some modifications, could accommodate their needs for any planned gas- fired electric
generation. Importantly, our organizations oppose the utilities' transition to gas fired power production, as this
approach would actually INCREASE climate impacts, with unburned methane from pipelines, compressor
stations and power plants being over 80 times as powerful a greenhouse gas as carbon dioxide in the short
term. Our organizations favor an all-out effort to maximize energy efficiency in combination with a conversion
to renewable energy sources as the most cost-effective, job creating, socially just and least polluting approach
to NC's energy future.
2. The ACP will actually increase costs for NC electric ratepayers. A detailed analysis by the Institute for Energy
Economics and Financial Analysis shows that the overbuilding of gas pipelines now under way, and particularly
the ACP, will be paid for by ratepayers, as they will be billed for cost of fuel delivery and pipelines construction
through their planned rate recovery ($5.6B+ for the Atlantic Coast Pipeline) in addition to the profit that FERC
approval would allow (up to 15%!). Further, ACP's statements that the pipeline will help "keep costs low" for
ratepayers is based on assumptions of both 1) stable high production of natural gas in WV/PA and 2) stable low
natural gas prices. In fact, the price of gas is expected by federal and private energy experts to rise in coming
years and production is already dropping. That will further increase fuel costs for natural gas, while our region
would be trapped in a long term commitment to gas. The ACP is a very costly and dangerous investment for NC!
3. Pipelines will be even LESS needed in the long term because renewables (wind and solar), are already the
predominate source of new and increasingly cost -competitive generating capacity being built in the nation. In
2015, the latest year for which figures are available, two-thirds of the new electrical generating capacity built in
the United States was from wind and solar projects. Further, implementing energy efficiency measures has

essentially flattened the demand for energy generation in recent years. Efficiency and renewable sources can
reduce climate changing emissions and create far more jobs than gas extraction, pipelines or new power plants.
4. The ACP's claim of many new jobs that would be created by the ACP is a gross exaggeration. The builders of the
ACP claim that the project "holds the promise of thousands of new jobs." Construction jobs would only be
several hundred in NC --at least half of which would be filled by people from outside the state --and would only
last for a few months to a year. In fact, the project is officially projected to create only 18 permanent jobs in
NC! The indirect jobs that ACP proponents say would be created through new industries, could only happen in
a few locations where there is enough investment to cover the cost of $500,000 to several $$ million to tap
onto the ACP. The poorest counties would see no taps at all. The ACP would impact landowners and residents
in many of the state's lowest income communities, with high minority populations, with NO new available gas
supply and NO economic benefits to local populations. A study done of costs to VA local governments of
hosting the ACP indicates that costs could exceed any local tax revenues from the pipeline by several $$million.
5. Low income and minority communities and landowners would be disproportionately impacted. The ACP
proposed corridor passes through communities in 8 counties with higher poverty levels than the state as a
whole. The counties through which the pipeline would pass also have significantly higher (51%) average
minority populations (African American, Native American, especially) than other counties in the state (30.5%),
as shown in calculations by the Research Triangle Institute. These two factors alone, in addition to the added
pressure on our most vulnerable landowners to lease for the project, present major environmental justice
impacts.
6. The pipeline would bring with it the risk of leakage, fire and explosions, and additional expenses to local
governments, as well as possible impacts to groundwater and private wells. In the Draft Environmental Impact
Statement, FERC dismisses concerns about pipeline safety by simply saying the builders will follow the safety
rules of the Pipeline and Hazardous Materials Safety Administration (PH MSA, a federal agency). However, the
agency's own data show that pipelines built since 2010 have experienced a five -fold increase over the previous
decade in significant incidents, rising even higher than for pipelines built prior to the 1940s! During this 2010-
2016 period, FERC has permitted a larger number of interstate pipelines and allowed profits of up to 14 or 15%
for their owners, causing pipeline companies and utility affiliates to undertake a "rush to build."
7. Critical natural resources, unique to North Carolina, would be substantially impacted. Of the three states that
the ACP would cross, NC has hundreds of tributary streams and critical wetlands, in addition to several major
rivers. Most of NC's economically important commercial and tourism fisheries and all healthy aquatic life
depend on the stability and cleanliness of these waters, and would be adversely impacted by sediment,
compaction and contamination during construction of the many stream and wetland crossings required. FERC
also acknowledges that construction activities can impact groundwater in the shallow aquifers in eastern NC,
but fails to require common sense actions to prevent or compensate well owners for damage.
In summary, the ACP would not serve the public good of North Carolina. If the ACP receives approval from FERC,
it would be granted the right of eminent domain to take private property for the project, designed by the ACP
owners to be very profitable to them, without providing economic or other benefits to almost any of the
communities it passes through.

When a proposed pipeline project 1) is not needed, 2) would result in negative economic impacts to landowners,
communities and local governments, 3) would cause substantial Environmental Injustice impacts, and 4) would
cause serious and permanent damage to the state's natural resources, it's clearly not in the best interests of
North Carolina and its people!
We further note that comments from NC DEQ and USEPA on the Draft EIS also raised several significant concerns
about the shortcomings in FERC's assessment of ACP impacts, including:
1) The substantial lack of information on vulnerable soils, steep slopes and other geologic hazards in the
Draft Environmental Impact Statement on which to assess ACP impacts
2) Blasting and other impacts to residents during construction
3) Given that the highest number of wetland impacts would occur in NC section of the ACP, the lack of
information about type and quality of wetlands indicates the inadequacy of the assessment. The
impacts of a large number of hundreds of stream crossings, and several major river crossings are also
inadequately characterized. Necessary spill and discharge prevention and monitoring requirements
during stream crossing activities are lacking.
4) There is gravely inadequate assessment of potential groundwater impacts. The need for more
protections and monitoring for wells at last 500 feet from the pipeline construction corridor, and
incorporation of key Source Water Protection information for public water supplies near the proposed
corridor.
5) Only direct impacts are analyzed in the DEIS, which fails to evaluate Indirect and secondary effects of
the ACP project, including industrial, road and other development that could occur as a result of pipeline
construction. The is no detailed cumulative impact analysis, either for stream crossings or for water
withdrawals during project construction, or for impacts of upsteam operations to extract gas.
6) The DEIS shows inadequate planning to prevent release of any hazardous wastes generated during ACP
construction.
We request that the Governor's staff, including the Energy and Environment Policy Advisor, the DEQ Secretary
and appropriate staff meet with us at your earliest opportunity to discuss significant concerns as well as the
ones raised in DEQ and EPA comments.
We believe that a commitment to Environmental Justice, to the economic well-being of ratepayers faced with
the pipeline construction costs plus inevitably rising fuel costs, to safety for residents near the pipeline corridor
and to the right of landowners and residents to use and enjoy their wells and property without facing eminent
domain for a lucrative pipeline project should give our elected and agency officials considerable pause. The
promised economic benefits of the ACP to the public are exaggerated to the point of fraud.
We ask that you take all available steps to protect North Carolina's people and natural resources, holding FERC
and the ACP owners accountable, through individual 401 WQ certifications for each portion of the proposed
project, critical review of Environmental Justice impacts, careful and critical permitting of the compressor
station and other above ground facilities along the pipeline, and requiring additional protections from

hazardous wastes and other potential groundwater contaminants, while bearing in mind the wider public
interest and vulnerability to the impacts of the ACP project, designed principally for the private profit of the
ACP owners.
Yours truly,
Hope Taylor, Executive Director. Clean Water for North Carolina ([e-mail], 919-401-9600)
Christine Ellis, Deputy Director/River Advocate, Winyah Rivers Foundation
Karen Bearden, Coordinator, 350.org Triangle
Belinda Joyner, President, Concerned Citizens of Northampton County
Denise Lee, Coordinator, Pee Dee Water, Air, Land and Lives (WALL)
Martha Girolami and Sharon Garbutt, Chatham Research Group
Keely Wood, Co -Chair, Environmental -EE
Kyle Dalton, Co -Chair, No Fracking in Stokes
Denise Bruce, GreenAction Coordinator, Sustainable Sandhills
June Blotnick, Executive Director, Clean Air Carolina
Joe McDonald, President, Save Our Sandhills
George Mathis, Executive Director, RiverGuardian Foundation
Elaine Chiosso, Executive Director and Haw RiverKeeper, Haw River Assembly
Amy Adams, NC Program Manager, Appalachian Voices
Larry Baldwin, Crystal Coast WaterKeeper, Exec. Director, Coastal Carolina Riverwatch
Marvin Winstead, President, Nash Stop the Pipeline
Avram Freidman, Executive Director, Canary Coalition
Lib Hutchby, Water Committee, Triangle Women's International League for Peace and Freedom
Bobby Jones, Coordinator, DownEast Coalition
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