20140957 Ver 2_ACP threatens our water is expensive and unneeded_20170719

Strickland, Bev
From:Beth Harvat or Peter Romeyn <[e-mail]>
Sent:Wednesday, July 19, 2017 7:33 AM
To:SVC_DENR.publiccomments
Subject:ACP threatens our water, is expensive and unneeded
I wish to comment for the 401 permit hearing for the Atlantic Coast Pipeline. As I read it, the draft permit has
serious flaws and contains little to no justification for the need of the pipeline. I urge that the permit not be
approved as written at this time.

Regarding the threat to water quality in eastern NC, the draft permit
 requires no monitoring or reporting to ensure that wetlands actually remain wetlands.
 There is no mitigation plan for offsetting the so-called “temporary” loss of forested wetlands. Nearly
600 acres of forested wetlands would be cleared for construction, which could take up to 30 years to
regrow, creating long-term adverse impacts to the ecologic functions of those wetlands. Those impacts
should not be considered temporary due to the extended time required for regeneration of mature
forested wetlands.
 Making an 8 foot deep trench for the pipeline through wetlands creates a preferential flow path for
contaminants to reach downstream waters and creating 75-foot wide rights of way through wetlands
creates fragmentation of forest that would be extremely deleterious to the fauna of the area.
 The Atlantic Coast Pipeline project will cross nearly 7 miles of streams and major rivers, which puts
large areas of watershed at risk for spills and explosions, including the uncontrolled release of drilling
fluids during pipeline construction. Impacts to any of these headwaters could negatively impact our
downstream fisheries and the economy of the state.
 In its 401 certification application, ACP, LLC acknowledges the project includes or is adjacent to
riparian buffers identified by the NC Riparian Buffer Protection Rule, but fails to include a “diffuse flow
plan” to reduce erosion and sedimentation, saying it would be developed under their Sedimentation and
Erosion Plan. As of July 11, DEQ reports they have not received a complete Sedimentation and Erosion
Plan, so the ability to protect downstream water quality can’t be evaluated in the absence of a plan to
ensure diffuse flow over disturbed buffer areas.
 The pipeline would impact rivers known to carry a wide variety of endangered, threatened or species of
concern, further impacting limited habitats of these species (such as the Carolina Madtom catfish, many
species of mussels, and numerous plants.)
 Several structures, such as compressors, metering stations, and valves, are proposed to be built within
the 100-year floodplain. Any such structures should be located outside of the floodplain, where they will
not impede the natural path of floodwaters or subject the pipeline to damage that may cause dangerous
leaks of gas or gas liquids.
 For most of its length in NC, the ACP would be located above the Northern Coastal Plain Aquifer
system, especially vulnerable to contamination, with uppermost sand aquifers at shallow depths being
susceptible to human activities. Given the large number of households within ½ mile of the ACP
corridor dependent on well water, construction could impact many household water supplies.
 There are a large number of private wells within 150 ft. of the pipeline workspace in Nash, Johnston and
Cumberland Counties. Well testing, both before and after construction, must include all water supply
wells within 500 feet of the construction workspace (rather than 150) and include ALL substances which
could impact groundwater, including explosives, lubricants, and components of natural gas liquids.
 The ACP is described as a pipeline to “serve the growing energy needs of multiple public utilities and
local distribution companies in Virginia and North Carolina.” ACP’s statements misleadingly include
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only estimates of growth in gas fired power demand, while failing to show that overall electric demand
for the region during this period has been essentially flat. Studies have shown that the pipeline is not
necessary to meet future demands, as projected demand is expected to stay static through 2030. As the
renewables market increases, the pipeline becomes even less relevant in future energy generation mixes.
I hope that the NC Division of Water Resources will find that the permit, as written, will NOT protect NC’s waters and
wetlands, nor the aquatic and human life that depend on them and therefore, refuse to approve the permit.

Sincerely,
Beth Harvat
Durham, NC
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