HomeMy WebLinkAbout20140957 Ver 2_Email PN Comments - Please reject the ACP WQ Certification_20170715 (291)
Strickland, Bev
From:Alvin Long <allong@cox.net>
Sent:Saturday, July 15, 2017 12:21 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.
• 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.
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• 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,
Alvin P. Long
Norfolk, VA
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