20140957 Ver 2_Email PN Comments - Please reject the ACP WQ Certification_20170713

Strickland, Bev
From:Brook Benadom <[e-mail]>
Sent:Thursday, July 13, 2017 11:13 PM
To:SVC_DENR.publiccomments
Subject:Please reject the ACP Water Quality Certification

Dear DEQ:
I am writing to urge you to reject the Water Quality Certification for the Atlantic Coast Pipeline.

Duke and Dominion have NOT shown that the ACP will not harm North Carolina's waters. In fact, I believe it will be
impossible to construct the ACP without adverse impacts to streams, rivers, wetlands, groundwater, aquatic life, human
health and Environmental Justice

Some of my concerns include:

— The ACP would cause adverse impacts to wetlands and waters.
• 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.
• During the directional drilling method of crossing, accidents often occur that would release drilling fluids into streams
and wetlands, degrading water quality. These are often hard to locate and impossible to reverse. No project with the
potential for violations of water quality standards on a short- or long-term basis can be approved by the Div. of Water
Resources.
• Several structures, such as compressors, metering stations, and valves, are proposed to be built within the 100-year
floodplain. While southeastern NC is still recovering from Hurricane Matthew, it is imperative to construct any such
structures 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.
• The ACP 401 application and construction detail fail to acknowledge the likely impacts of construction and pipeline
operation on local groundwater or to ensure measures will be taken to prevent them. The project could decrease
groundwater recharge, thus decreasing the groundwater discharge to streams and wetlands, as well, thus decreasing
stream baseflow and ability to maintain the water level in wetlands during dry periods.
• Trench construction and backfill changes the ability of water to flow through impacted soils, which can cause
preferential flow and ease the pathway for contaminants to reach wetlands and streams or it can cause blocked flow,
possibly diverting groundwater from its natural discharge point.

— The ACP is an Environmental Justice issue.
• Duke and Dominion describe letters sent to state recognized tribes asking for information related to recognized
historical or cultural sites. This is not adequate tribal consultation for either state recognized tribes and completely
excludes a non-recognized entity (Tuscarora Nation) that has experienced discrimination even relative to other tribal
groups. There has been a complete marginalization of tribal concerns and sites of long-standing tribal use.
• The ACP would bring disproportionate impacts to rural, low-income and communities of color as the route proposed
runs through some of the most rural and economically depressed counties of the state, most with higher populations of
color than the state as a whole.
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• Dominion states that the construction of the pipeline will lower customers’ energy costs, but this is a false hope. Duke
and Dominion customers will pay for the construction costs plus profit for the ACP, even if the pipeline is used at a
fraction of its full capacity. This creates a further unjustified burden for low-income residents

— The need for the ACP has NOT been justified.
• 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 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.
• Duke and Dominion make the completely unsubstantiated statement that “energy conservation measures alone (or in
conjunction with other alternatives) will be unlikely to offset more than a fraction of anticipated demand for the
foreseeable future.” In fact, the renewables market is growing rapidly in eastern NC and increased energy efficiency
measures in homes, businesses and industries have flattened electricity demand in the past decade, despite population
increases.

For all of the reasons listed above, I ask the Div. of Water Resources not to grant a 401 WQC permit for the Atlantic
Coast Pipeline.

Sincerely,

Ms. Brook Benadom
2352 Flat Top Rd Apt 3
Blowing Rock, NC 28605
9168340588
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