20140957 Ver 2_RE ACP Clean Water Act 401 Certification_20170821

Strickland, Bev
From:Harvard Ayers <[e-mail]>
Sent:Monday, August 21, 2017 8:53 AM
To:SVC_DENR.publiccomments
Subject:RE: ACP Clean Water Act, 401 Certification
NCDEQ:
As you see, I sent my comment on the ACP Clean Water Act, 401 Certification for the
Atlantic Coast Pipeline on Saturday, August 19 at noon. In the interest of sending it off
on time, I found later that I made several relatively small errors. I apologize for this
oversight. The version immediately below is cleaner and I ask you to consider reading
this one. Thank you. Dr. Harvard Ayers

NC Department of Environmental Quality
217 W. Jones St.
Raleigh, NC 27603

Dear DEQ:
I am writing as a scientist to discuss how water will be impacted for not just the 600 mile path
of the Atlantic Coast Pipeline (ACP) from one end to the other from Harrison County, West
Virginia to Robeson County, North Carolina, but also throughout our country’s Southeast
region, the United States and indeed, even at a worldwide scale. The most significant
impact of this natural gas pipeline will be the resultant increase in the severity of
human-caused climate change.

To ignore this impact is to allow ourselves to segment the broad and many effects of the most
severe challenge that currently exists for our world. Certainly the worldwide climate change
impacts are known to include draughts and more severe storms as well as heat waves, crop
failures, mass movements of human populations to avoid the changes, and civil wars, to name
some of the more important effects. Already, we have witnessed the devastating effects of the
major storm that recently struck eastern North Carolina—just travel to a portion of the
proposed pipeline in the southern counties such as Robeson and Cumberland and witness the
lingering remains of the devastation. Was this storm “caused” by the forces of climate change?
Probably it was not, but it was likely made worse by it.

So what does climate change have to do with this pipeline? It’s simply because this pipeline is
being built to carry the most dangerous climate change fossil fuel of all, natural gas which
averages about 95% methane, (CH4). While carbon dioxide (CO2) is the most abundant
greenhouse gas in our atmosphere, fracked methane (100% of all methane available to us) is
1

so much more powerful a greenhouse gas, being 86 times more powerful than carbon dioxide
over its first 20 years.

Our best scientists tell us that unless we move immediately to eliminate especially fracked
methane from the fossil fuel mix, we may not stop the temperature rise soon enough to
prevent some of the worst effects of climate change. Why is this not well known to most
Americans? Simple, special interests in especially the fossil fuel industry take profits as more
important than the wellbeing of our citizens, and spend millions of dollars knowingly
dispensing disinformation which in this case maintains that natural gas is cleaner than coal or
oil. The fact is just the reverse: fracked gas (methane) is worse than coal or oil. And only
fracked gas (from PA, WV, and OH) will flow through the proposed Atlantic Coast Pipeline.

The good news according to the same scientists is that 10 years after methane is burned, only
about 11% of the original molecules of methane remains, as the rest has devolved to the much
less harmful CO2. Since methane is currently about a third of the greenhouse gas strength to
affect our temperatures (carbon dioxide is about 60%), to stop burning methane would have
an almost immediate and drastic positive cooling effect across our country and the world. Dr.
Robert Howarth of Cornell and other methane specialists tell us exactly this, and are backed by
research by many colleagues. Reducing carbon dioxide, while needed in the long run and
should be done now, would have no immediate effect on climate change because CO2 has a
very long lifetime in our atmosphere —especially compared to methane.

The impacts of the Atlantic Coast Pipeline will be no small matter. In North Carolina alone,
Duke Energy plans to construct some 15 natural gas power plants, assumedly of a similar size
to the new Asheville power plant that is already approved. Dominion Virginia, as I understand
it, plans to construct as many or more of these natural gas power plants. Together, these two
states’ would be adding 20,000 or more MW of energy powered by this dangerous fossil fuel.
Meanwhile, clean renewable energy would be essentially ignored by Duke and Dominion
Virginia. We would be looking at energy infrastructure that flies in the face of what the vast
majority of our U.S. scientists warn us against.

One last note, four days ago (8-17-17) a Federal Court of Appeals in New York state ruled
against the construction of the Constitution pipeline. The Court did so upholding the New York
Department of Conservation’s decision to block the Constitution pipeline based on concerns of
the Clean Water Act, 401 Certification, that the impacts of pipeline crossings of streams and
wetlands would be too severe. I thought this was particularly appropriate as a decision by the
state agency and the court to make the same decision that DEQ is called upon to make at this
time. It would likely have some of the same issues DEQ is now looking at closely.

2

Thank you for considering my concerns. Please feel free to contact me for more information
on this subject as I have close contacts with my methane colleague scientists at other
universities.

Dr. Harvard Ayers, Professor Emeritus of Anthropology and Sustainable Development;
Appalachian State University; Boone, North Carolina. 828-262-5238

From: Harvard Ayers \[mailto:[e-mail]\]
Sent: Saturday, August 19, 2017 12:01 PM
To: '[e-mail]' <[e-mail]>
Subject: ACP Clean Water Act, 401 Certification

NCDEQ:
Attached and pasted are my comments on your current concern with considering the
Clean Water Act, 401 Certification, for the Atlantic Coast Pipeline. Thanks for giving my
comments fair consideration. As a Professor at Appalachian State University, I have
lectured, have spoken at conferences (latest this March at New York University), have
done field research, and have written books on the subject of climate change and on
its effects on different cultures across North America. One of my books called Train
Wreck Earth is only weeks out from being published and which I will send you a
complementary copy if you would like. It represents the pinnacle of my career as an
Anthropologist and Sustainable Development Professor at ASU for 44 years.

Dr. Harvard Ayers
_______________________________________________________

NC Department of Environmental Quality
217 W. Jones St.
Raleigh, NC 27603

Dear DEQ:
I am writing as a scientist to discuss how water will be impacted for not just the 600 mile path
of the Atlantic Coast Pipeline (ACP) from one end to the other from Harrison County, West
Virginia to Robeson County, North Carolina, but also throughout our country’s Southeast
region, the United States and indeed, even at a worldwide scale. The most significant impact
of this natural gas pipeline will be the broad manifestations of the resultant increase in the
severity of human-caused climate change. I realize you may not consider climate change as
part of your purview, but I would ask why not if one of the results will be to significantly
exacerbate climate change .

3

To ignore this impact is to allow ourselves to segment the broad and many effects of the most
severe challenge that currently exists for our world. Certainly the worldwide climate change
impacts are known to include draughts and more severe storms as well as heat waves, crop
failures, mass movements of human populations to avoid the changes, and civil wars, to name
some of the more important effects. Already, we have witnessed the devastating effects of the
major storm that recently struck eastern North Carolina—just travel to a portion of the
proposed pipeline in the southern counties such as Robeson and Cumberland and witness the
lingering remains of the devastation. Was this storm “caused” by the forces of climate change?
Probably it was not, but it was likely made worse by it.

So what does climate change have to do with this pipeline? It’s simply because this pipeline is
being built to carry the most dangerous climate change fossil fuel of all, natural gas which
averages about 95% methane, (CH4). While carbon dioxide (CO2) is the most abundant
greenhouse gas in our atmosphere, fracked methane (100% of all methane available to us) is
so much more powerful a greenhouse gas, being 86 times more powerful than carbon dioxide
over its first 20 years.

Our best scientists tell us that unless we move immediately to eliminate especially fracked
methane from the fossil fuel mix, we may not stop the temperature rise soon enough to
prevent some of the worst effects of climate change. Why is this not well known to most
Americans? Simple, special interests in especially the fossil fuel industry take profits as more
important than the wellbeing of our citizens, and spend millions of dollars knowingly
dispensing disinformation which in this case maintains that natural gas is cleaner than coal or
oil. The fact is just the reverse: fracked gas (methane) is worse than coal or oil. And only
fracked gas (from PA, WV, and OH) will flow through the proposed Atlantic Coast Pipeline.

The good news according to the same scientists is that 10 years after methane is burned, only
about 11% of the original molecules of methane remains, as the rest has devolved to the much
less harmful CO2. Since methane is currently about a third of the greenhouse gas strength to
affect our temperatures (carbon dioxide is about 60%), to stop burning methane would have
an almost immediate and drastic positive cooling effect across our country and the world. Dr.
Robert Howarth of Cornell and other methane specialists tell us exactly this, and are backed by
research by many colleagues. Reducing carbon dioxide, while needed in the long run and
should ne done, would have no immediate effect on climate change because CO2 has a very
long lifetime in our atmosphere —especially compared to methane.

The impacts of the Atlantic Coast Pipeline will be no small matter. In North Carolina alone,
Duke Energy plans to construct some 15 natural gas power plants, assumedly of a similar size
to the new Asheville power plan that is already approved. Dominion Virginia, as I understand
it, plans to construct as many or more of these natural gas power plants. Together, these two
states’ would be adding 20,000 or more MW of energy powered by this dangerous fossil fuel.
4

Meanwhile, clean renewable energy would be essentially ignored by Duke and Dominion
Virginia. We would be looking at energy infrastructure that flies in the face of what the vast
majority of our U.S. scientists warn us against.

One last note, two days ago (8-17-17) a Federal District Court judge in New York state ruled
against the construction of the Constitution pipeline. The judge did so upholding the New York
Department of Conservation’s decision to block the Constitution pipeline based on concerns of
the Clean Water Act, 401 Certification, that the impacts of pipeline crossings of streams and
wetlands would be too severe. I thought this was particularly appropriate as a decision by the
state agency and the court to make the same decision that DEQ is called upon to make at this
time. It would likely have some of the same issues DEQ is now looking at closely.

Thank you for considering my concerns. Please feel free to contact me for more information
on this subject as I have close contacts with my methane colleague scientists at other
universities.

Dr. Harvard Ayers, Professor Emeritus of Anthropology and Sustainable Development;
Appalachian State University; Boone, North Carolina

5