20140957 Ver 2_DO NOT GRANT a 401 permit for the Atlantic Coast Pipeline NO ACP_20170816

Strickland, Bev
From:Lynne Williams <[e-mail]>
Sent:Wednesday, August 16, 2017 4:26 PM
To:SVC_DENR.publiccomments
Subject:DO NOT GRANT a 401 permit for the Atlantic Coast Pipeline. NO ACP
Construction of the Atlantic Coast Pipeline would dig up, cut through, or clear cut more acres of wetlands than
the state of North Carolina permits for the entire state in a year. 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 for the next 30 years.
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.
Wetlands provide natural water filtration and protect and replenish surface waters. It would require more money
and resources to recreate the same benefit from local water treatment facilities to accomplish what the existing
wetlands are doing for free.
Making an 8 foot deep trench for the pipeline through wetlands creates a preferential flow path for contaminants
to reach downstream waters.
Loss of forested wetlands and clearing upland forests creates fragmentation of forest that threatens the habitat of
many endangered and threatened birds, reptiles, amphibians and bats. The deforestation from creating 75-foot
wide rights of way through wetlands will cause a loss of shade, more evaporation and unsuitable temperatures
for animals that live in the wetlands such as fish, amphibians and aquatic insects.

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 (conductivity) through impacted soils,
which can cause preferential flow of groundwater or blocked flow. Higher conductivity can cause an aquifer to
drain more quickly and ease the pathway for contaminants to reach wetlands and streams. Lower conductivity
backfill would restrict groundwater flow that intersects the trench. possibly diverting it from its natural
discharge point.

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. Also, areas of shallow bedrock must be
surveyed for heavy metals, radioactive materials and acid-producing rocks with potential to contaminate nearby
water sources.
Tribal Coordination: ACP describes 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.

In the past 30 years, FERC has granted “certificates” to all but two U.S. pipeline projects, with no credible
assessment of actual need project need. The Commission can’t be relied upon to protect the health and
environment of North Carolina. The Div. of Water Resources’ permit review must conscientiously require
measures to protect the waters and existing uses of water resources. Believing it will be impossible to construct
the ACP without adverse impacts to streams, rivers, wetlands, groundwater, aquatic life, human health and
Environmental Justice, we ask the Div. of Water Resources not to grant a 401 permit for the Atlantic Coast
Pipeline.

Sincerely,

Lynne Williams
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