HomeMy WebLinkAbout20140957 Ver 2_ACP_20170818
Strickland, Bev
From:Sam Davis <sam@dogwoodalliance.org>
Sent:Friday, August 18, 2017 12:32 PM
To:SVC_DENR.publiccomments
Subject:ACP - Atlantic Coast Pipeline Comments
To Whom It May Concern:
Dogwood Alliance recommends that North Carolina reject the application for permit for the Atlantic Coast
Pipeline project. The public input process has been inadequate for the scope of the project, and neither the
companies applying nor the state have provided appropriate evidence to suggest that water quality, precious
Southern wetland forests, endangered species, and low-income communities in the region will not be impacted
by construction or operations.
Nearly 600 acres of forested wetland would be destroyed to make way for the ACP in North Carolina. Some
reports estimate that up to 80% of forested wetlands in the US South have already been destroyed in the last
few hundred years.(NRDC 2015) Bottomland hardwood regeneration is challenging and requires specific
regimens of flood and drought to establish native, apex ecosystems.(Pietrzykowski et al. 2015; Aust et al.
1997; Conner et al. 1986) In an area already hit by devastating natural disasters,(Anon 2017) it is essential that
we maintain as much forested wetland as we can to buffer a storm’s worst effects.(Bradshaw et al. 2007)
Creating 75-foot right of ways can completely disrupt species’ ability to survive. For example, fragmentation
was blamed for local extinction of a native butterfly in Ohio. (Davis & Cipollini 2014) Likewise, many wetland-
dependent species (like salamanders) depend on specific depressions and small habitat areas to successfully
reproduce. (Gibbs 1998)
Additionally, the proposed ACP route will cross nearly 7 miles of streams and destroy buffers essential for
preserving water quality downstream. The permit application dismisses these concerns as temporary, but
there’s no meaningful analysis of the downstream effects, nor any proposed sites for buffer mitigation.
ACP has failed to adequately consult state-recognized and other tribes over concerns about the pipeline, which
may impact their historic and cultural sites. Letters are not adequate contact. There has been a complete
marginalization of tribal concerns and sites of long-standing tribal use.
Finally, 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. 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, who are often on fixed incomes and cannot afford
further rate hikes.
The potential costs to our water quality, wetlands, endangered species, and residents are too high to risk
allowing construction of a needless pipeline in the area. North Carolina communities should not bear higher
electricity rates to pay for a natural gas pipeline we do not need. The ACP is dirty, expensive, and
unnecessary. Reject the application for permit.
References
Anon, 2017. Hurricane Matthew Destroyed 177 Miles of East Coast Dunes, USGS Says. The Weather
Channel. Available at: https://weather.com/news/news/hurricane-matthew-dune-damage-usgs-report
\[Accessed March 7, 2017\].
1
Aust, W.M. et al., 1997. Recovery status of a tupelo-cypress wetland seven years after disturbance:
silvicultural implications. Forest ecology and management, 90(2-3), pp.161–169.
Bradshaw, C.J.A. et al., 2007. Global evidence that deforestation amplifies flood risk and severity in the
developing world. Global change biology, 13(11), pp.2379–2395.
Conner, W.H., Toliver, J.R. & Sklar, F.H., 1986. Natural regeneration of baldcypress (Taxodium distichum (L.)
Rich.) in a Louisiana swamp. Forest ecology and management, 14(4), pp.305–317.
Davis, S.L. & Cipollini, D., 2014. How Environmental Conditions and Changing Landscapes Influence the
Survival and Reproduction of a Rare Butterfly, Pieris virginiensis (Pieridae). Journal of the Lepidopterists’
Society, 68(1), pp.61–65.
Gibbs, J.P., 1998. Distribution of woodland amphibians along a forest fragmentation gradient. Landscape
ecology, 13(4), pp.263–268.
NRDC, 2015. In the U.S. southeast, natural forests are being felled to send fuel overseas, Natural Resources
Defense Council. Available at: https://www.nrdc.org/sites/default/files/southeast-biomass-exports-report.pdf.
Pietrzykowski, M., Daniels, W.L. & Koropchak, S.C., 2015. Microtopographic effects on growth of young bald
cypress (Taxodium distichum L.) in a created freshwater forested wetland in southeastern Virginia. Ecological
engineering, 83, pp.135–143.
--
2