20140957 Ver 2_Handouts_20170608

Agenda for June 8 Meeting With DEQ on Atlantic Coast Pipeline
(2 to 4 minute presentations, leave >20 minutes for discussion)
1. Intro and overview—range of issues, our "ask" for DEQ staff: Hope 2 min
2. Lack of need for pipeline, who would pay for it (FERC's history of granting all
certificates) John R 4 min
3. Methane emissions, climate impacts: Martha 4 min
4. Economic impacts: temporary and permanent jobs; costs to local
governments of hosting the ACP Hope 2 min
5. Impacts on landowners and local communities Marvin 6 min
6. Water and wetland impacts, 401 process, withdrawals for hydrostatic
testing Hope 4 min
7. Compressor station, air emissions Therese 4 min
8. Northampton County demographics, why ACP won't help economy,
compressor station and safety issues—Belinda 4 min
9. Environmental Justice, demographics of effected counties,
overview Naeema 4 min
Short summary and Discussion

RECEIVED
Office of the Secretary
Appalachian Voices — Canary Coalition Chatham Research Group PAY an Ai Carolina
L
Clean Water for North Carolina — Concerned Citizens of Northampton C�u2ngL Coastal
Carolina Riverwatch — DownEast Coalition — EnvironmentaLU — Haw River Assembly
Nash Stop the Pipeline — No Fracking in Stokes Pee Dee Water, Air,LanYan?%Qes'PJ
RiverGuardian Foundation — Save Our Sandhills Sustainable Sandhills — 350.org
Triangle — Triangle Womens' International League for Peace and Freedom — Winyah
Rivers Foundation
April 28, 2017
Governor Roy Cooper (via web form and US mail)
NC Office of the Governor
20301 Mail Service Center
Raleigh, NC 27699-0301
Via email: Jeremy Tarr, Office of the Gov. Policy Advisor Environment, Energy, Transportation
Jenni Owen, Director of Policy, Office of the Governor
NC DEQ Secretary Michael Regan (via email and US mail)
1601 Mail Service Center
Raleigh, N.C. 27699-1601
Via email: Tracy Davis, Director, DEQ Div. of Energy Mining and Land Resources
Lyn Hardison, DEQ EIS Coordinator; Sarah Rice, DEQ Environmental Justice Coordinator
Jay Zimmerman, Director, Div. of Water Resources
Linda Culpepper, Div. of Water Resources; Jennifer Burdette, Water Resources, 401 Unit
Dear Governor Cooper and Secretary Regan:
This letter is from 19 partner organizations in FrackFreeNC, a grassroots alliance working to
prevent fracking and unneeded and dangerous gas infrastructure in North Carolina, in order to
deepen the conversation about our still growing concerns about the Atlantic Coast Pipeline.
The Atlantic Coast Pipeline is Unneeded, Costly, Dangerous and Unjust for North Carolinians
We are writing on behalf of organizations deeply concerned about the impacts of the proposed
Atlantic Coast Pipeline (ACP) on landowners, local governments, vulnerable Environmental

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Justice Populations, and on the waters and economy of eastern NC. The owners of the
proposed 600 mile gas pipeline—including affiliates of Dominion Power and Duke Energy-- have
distributed materials and statements to the public as well as local and state officials in order to
garner support for the proposed ACP that contain significant unsubstantiated and misleading
information. We include below a summary of the major concerns we have articulated in official
comments to the Federal Energy Regulatory Commission (FERC), as well as some concerns
raised by the US EPA and DEQ staff in comments submitted to (FERC), and we also represent
members of a number of impacted communities along the proposed pipeline route.
I. The ACP is not needed for residential and economic development needs and increases our
climate vulnerability . FERC has carried out no regional analysis to assess either the need for,
nor impact of, several planned major gas pipeline projects in the Southeastern US. Numerous
studies, including a 2015 U.S. Department of Energy study and a FERC staff report the same
year, conclude that there is sufficient capacity in existing pipelines to meet foreseeable energy
requirements and that the nation, and especially our region, is headed toward a massive
overbuilding of natural gas pipelines, far in excess of demand. Many industry observers
acknowledge that the Transco pipeline, with some modifications, could accommodate their
needs for any planned gas- fired electric generation. Importantly, our organizations oppose the
utilities' transition to gas fired power production, as this approach would actually INCREASE
climate impacts, with unburned methane from pipelines, compressor stations and power plants
being over 80 times as powerful a greenhouse gas as carbon dioxide in the short term. Our
organizations favor an all-out effort to maximize energy efficiency in combination with a
conversion to renewable energy sources as the most cost-effective, job creating, socially just
and least polluting approach to NC's energy future.
2. The ACP will actually increase costs for NC electric ratepayers. A detailed analysis by the
Institute for Energy Economics and Financial Analysis shows that the overbuilding of gas
pipelines now under way, and particularly the ACP, will be paid for by ratepayers, as they will
be billed for cost of fuel delivery and pipelines construction through their planned rate recovery
($5.6B+ for the Atlantic Coast Pipeline) in addition to the profit that FERC approval would allow
(up to 15%!). Further, ACP's statements that the pipeline will help "keep costs low" for
ratepayers is based on assumptions of both 1) stable high production of natural gas in WV/PA
and 2) stable low natural gas prices. In fact, the price of gas is expected by federal and private
energy experts to rise in coming years and production is already dropping. That will further
increase fuel costs for natural gas, while our region would be trapped in a long term
commitment to gas. The ACP is a very costly and dangerous investment for NCI
3. Pipelines will be even LESS needed in the long term because renewables (wind and solar),
are already the predominate source of new and increasingly cost -competitive generating

capacity being built in the nation. In 2015, the latest year for which figures are available, two-
thirds of the new electrical generating capacity built in the United States was from wind and
solar projects. Further, implementing energy efficiency measures has essentially flattened the
demand for energy generation in recent years. Efficiency and renewable sources can reduce
climate changing emissions and create far more jobs than gas extraction, pipelines or new
power plants.
4. The ACP's claim of many new jobs that would be created by the ACP is a gross
exaggeration. The builders of the ACP claim that the project "holds the promise of thousands of
new jobs." Construction jobs would only be several hundred in NC --at least half of which would
be filled by people from outside the state --and would only last for a few months to a year. In
fact, the project is officially projected to create only 18 permanent jobs in NC! The indirect jobs
that ACP proponents say would be created through new industries, could only happen in a few
locations where there is enough investment to cover the cost of $500,000 to several $$ million
to tap onto the ACP. The poorest counties would see no taps at all. The ACP would impact
landowners and residents in many of the state's lowest income communities, with high
minority populations, with NO new available gas supply and NO economic benefits to local
populations. A study done of costs to VA local governments of hosting the ACP indicates that
costs could exceed any local tax revenues from the pipeline by several $$million.
5. Low income and minority communities and landowners would be disproportionately
impacted. The ACP proposed corridor passes through communities in 8 counties with higher
poverty levels than the state as a whole. The counties through which the pipeline would pass
also have significantly higher (51%) average minority populations (African American, Native
American, especially) than other counties in the state (30.5%), as shown in calculations by the
Research Triangle Institute. These two factors alone, in addition to the added pressure on our
most vulnerable landowners to lease for the project, present major environmental justice
impacts.
6. The pipeline would bring with it the risk of leakage, fire and explosions, and additional
expenses to local governments, as well as possible impacts to groundwater and private
wells. In the Draft Environmental Impact Statement, FERC dismisses concerns about pipeline
safety by simply saying the builders will follow the safety rules of the Pipeline and Hazardous
Materials Safety Administration (PHMSA, a federal agency). However, the agency's own data
show that pipelines built since 2010 have experienced a five -fold increase over the previous
decade in significant incidents, rising even higher than for pipelines built prior to the 1940s!
During this 2010-2016 period, FERC has permitted a larger number of interstate pipelines and
allowed profits of up to 14 or 15% for their owners, causing pipeline companies and utility
affiliates to undertake a "rush to build."
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7. Critical natural resources, unique to North Carolina, would be substantially impacted. Of
the three states that the ACP would cross, NC has hundreds of tributary streams and critical
wetlands,'in addition to several major rivers. Most of NC's economically important commercial
and tourism fisheries and all healthy aquatic life depend on the stability and cleanliness of
these waters, and would be adversely impacted by sediment, compaction and contamination
during construction of the many stream and wetland crossings required. FERC also
acknowledges that construction activities can impact groundwater in the shallow aquifers in
eastern NC, but fails to require common sense actions to prevent or compensate well owners
for damage.
In summary, the ACP would not serve the public good of North Carolina. If the ACP -receives
approval from FERC, it would be granted the right of eminent domain to take private property
for the project, designed by the ACP owners to be very profitable to them, without providing
economic or other benefits to almost any of the communities it passes through.
When a proposed pipeline project 1) is not needed, 2) would result in negative economic
impacts to landowners, communities and local governments, 3) would cause substantial
Environmental Injustice impacts, and 4) would cause serious and permanent damage to the
state's natural resources, it's clearly not in the best interests of North Carolina and its people!
We further note that comments from NC DEQ and USEPA on the Draft EIS also raised several
significant concerns about the shortcomings in FERC's assessment of ACP impacts, including:
1) The substantial lack of information on vulnerable soils, steep slopes and other geologic
hazards in the Draft Environmental Impact Statement on which to assess ACP impacts
2) Blasting and other impacts to residents during construction
3) Given that the highest number of wetland impacts would occur in NC section of the ACP,
the lack of information about type and quality of wetlands indicates the inadequacy of
the assessment. The impacts of a large number of hundreds of stream crossings, and
several major river crossings are also inadequately characterized. Necessary spill and
discharge prevention and monitoring requirements during stream crossing activities are
lacking.
4) There is gravely inadequate assessment of potential groundwater impacts. The need for
more protections and monitoring for wells at last 500 feet from the pipeline
construction corridor, and incorporation of key Source Water Protection information for
public water supplies near the proposed corridor.

5) Only direct impacts are analyzed in the DEIS, which fails to evaluate Indirect and
secondary effects of the ACP project, including industrial, road and other development
that could occur as a result of pipeline construction. The is no detailed cumulative
impact analysis, either for stream crossings or for water withdrawals during project
construction, or for impacts of upsteam operations to extract gas.
6) The DEIS shows inadequate planning to prevent release of any hazardous wastes
generated during ACP construction.
We request that the Governor's staff, including the Energy and Environment Policy Advisor, the
DEQ Secretary and appropriate staff meet with us at your earliest opportunity to discuss
significant concerns as well as the ones raised in DEQ and EPA comments.
We believe that a commitment to Environmental Justice, to the economic well-being of
ratepayers faced with the pipeline construction costs plus inevitably rising fuel costs, to safety
for residents near the pipeline corridor and -to the right of landowners and residents to use and
enjoy their wells and property without facing eminent domain for a lucrative pipeline project
should give our elected and agency officials considerable pause. The promised economic
benefits of the ACP to the public are exaggerated to the point of fraud.
We ask that you take all available steps to protect North Carolina's people and natural
resources, holding FERC and the ACP owners accountable, through individual 401 WQ
certifications for each portion of the proposed project, critical review of Environmental Justice
impacts, careful and critical permitting of the compressor station and other above ground
facilities along the pipeline, and requiring additional protections from hazardous wastes and
other potential groundwater contaminants, while bearing in mind the wider public interest and
vulnerability to the impacts of the ACP project, designed principally for the private profit of the
ACP owners.
Yours truly,
Hope Taylor, Executive Director. Clean Water for North Carolina (919-401-9600)
Christine Ellis, Deputy Director/River Advocate, Winyah Rivers Foundation
Karen Bearden, Coordinator, 350.org Triangle
Belinda Joyner, President, Concerned Citizens of Northampton County
Denise Lee, Coordinator, Pee Dee Water, Air, Land and Lives (WALL)

Martha Girolami and Sharon Garbutt, Chatham Research Group
Keely Wood, Co -Chair, Environmental -EE
Kyle Dalton, Co -Chair, No Fracking in Stokes
Denise Bruce, GreenAction Coordinator, Sustainable Sandhills
June Blotnick, Executive Director, Clean Air Carolina
Joe McDonald, President, Save Our Sandhills
George Mathis, Executive Director, RiverGuardian Foundation
Elaine Chiosso, Executive Director and Haw RiverKeeper, Haw River Assembly
Amy Adams, NC Program Manager, Appalachian Voices
Larry Baldwin, Crystal Coast WaterKeeper, Exec. Director, Coastal Carolina Riverwatch
Marvin Winstead, President, Nash Stop the Pipeline
Avram Freidman, Executive Director, Canary Coalition
Lib Hutchby, Water Committee, Triangle Women's International League for Peace and Freedom
Bobby Jones, Coordinator, DownEast Coalition

Methane & Climate Impacts June 8, 2017 Martha Girolami
In order to keep global warming well below 2 degrees centigrade, as agreed by a majority of
nations at last years year's Paris Climate Accord, our world must reduce Green House Gas
emissions (GHG) to pre -industrial levels. We must leave fossil fuels in the ground. But Right
now -have peak emissions of carbon dioxide, methane and other GHG been reached?
Not at all! Carbon dioxide is now around 410 ppm. Methane emissions increased by 30%
between 2002 and 2014 and still continues to rise. Based on satellite and ground observations,
the United States is responsible for 30 to 60% of this recent upsurge in global methane
concentration from fracking. These fracked gas emissions are from the oil and gas industry as
identified by isotopic fingerprinting.
Natural gas is a greater threat to the climate than climate scientists and the IPCC originally
thought. Now it is known that In a 20 year timeframe, methane has 86 times the potency of
carbon dioxide to cause warming. And over a 100 year period its is 34 times stronger GHG than
carbon dioxide. Methane has an immediate warming impact and then decays in less than 20
years.
Most methane emissions are inherent in gas technology and in equipment design and normal
operating use. They are impossible or expensive to eliminate. The oil and gas industry has
fought regulatory efforts to reduce emissions from leaks and losses. Every step of natural gas
production to final use looses methane. Fracking releases gas at very high pressure and it is
not immediately captured into piping. Large emissions come from gas storage tanks that
continuously vent methane to reduce pressure. Compressor stations lose methane in engine
exhaust and hundreds of vents and meters. Gas pipelines lose gas during maintenance and
cleaning and ruptures. Storage wells can fail. Remember the recent Aliso Canyon Gas blow
out. Over 112 days, 107 thousand tons of methane were released from the storage well.
Due to increasing methane concentrations in our atmosphere and methane potency as a GHG,
climate responds quickly to methane. Dr. Robert Howarth of Cornell University says "if we
reduce our methane emissions from fracking NOW, we will slow the rate of global warming .... in
fact, that is the only way to avoid irreversible harm to the climate." By stopping methane
emissions now, this buys the world some time to build out renewables everywhere. We have to
replace coal and aging nuclear with renewable energy and energy efficiency programs.
Additional fracking and natural gas infrastructure dependency and investment will lock in natural
gas use for decades to come. A "gas and more gas " policy will prevent investment,
construction, development and optimization of carbon free sustainable energies. It will enable
and promote Duke Energy's plan to build 19 gas power plants in North Carolina. This cannot
happen or We will have doomed the Paris Accord and our future.
If North Carolina signs on to "We Are Still In", this must mean "No ACP" in our State

Carboddef SCIENCE ENERGY v POLICY v IN FOCUS DAILY BRIEFING 4-. SUBSCRIBE
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RESOLUTION TO SL9W THE CLIMATE CRISIS BY REDUCING METHANE EMISSIONS
FRACKED GAS AND POWER INDUSTRIES
WHEREAS, an unprecedented, three-year global heat wave,' ongoing sea level rise and increasingly
intense weather extremes are alfeady devastating communities, wildlife and property in North Carolina
and around the world ;2 ;
WHEREAS, those least responsible for causing this crisis have been hurt first and worst, primarily low -
wealth communities and peopiLlof color, and humanity is quickly running out of time to slow this
enormous challenge before it accelerates under its own momentum beyond our control,
WHEREAS, methane is 80-100 times more potent than carbon dioxide at trapping Earth's heat,3 and has
become the driving force behind the rapid heating of the planet;4
WHEREAS, large -amounts of ntural gas — which is mostly methane — are being vented and leaked
directly into the air from various bas equipment, with emissions measured at rates of up to 12% of the,
total gas produced by wells using fracking technology;s
WHEREAS, these emissions maya burning natural gas for electricity at least three times worse for the
climate than coal,6 in addition td }other health impacts and explosion risks,'
E,
WHEREAS, the recent surge in rri ethane emissions is largely due to the US fracking boom,$ which is being
driven by Duke Energy and otheir;utilities' expanded use of gas to generate electricity,9
WHEREAS, most US gas and electricity corporations are fighting efforts to reduce methane emissions;'o
WHEREAS, reducing methane emissions can be achieved quickly and cost-effectively while creating
thousands of jobs;" and
'
WHEREAS, immediately reducin methane emissions from the US natural gas industry can slow global
warming enough to allow time tp.,replace fossil fuels with cheaper clean energy such as solar, wind and
storage technologies;' now therefore be it
RESOLVED that North Carolina Governor Roy Cooper shall use his constitutionally -granted executive
authority to ensure that:
by December 31, 2018 nolratural gas originating from fracking operations is used in or
transported through North Carolina;
by December 31, 2022 no other natural gas is used in or transported through North Carolina unless
it can be verified that the methane emissions associated with its production, transportation, and
end use are at most O.S% f gas pumped from the well, and
no new natural gas-fired power plants or pipelines are constructed in North Carolina, and all
existing gas plants and prelines are phased out expeditiously and replaced with clean, renewable
energy. j
March 2017

1 NOAA and NASA reported that 2016 was the hottest year on record for the gld al average, the third consecutive
record-setting year. "Earth sets heat record for third straight year,"Associated Pre s; January 19, 2017.
z "Global warming's fingerprints seen in 24 weird weather cases," Associated Press, December 15, 2016.
s Intergovernmental Panel on Climate Change, Climate Chance 2013 The Pl�vsic�l Science Basis 2013.
4 Dr. Robert Howarth from Cornell University stated at a December 13 2016 presl conference, "So the take-home
message is that shale gas and shale oil development in the United States is havin a demonstrable effect on
atmospheric methane and that is causing the increased rate of global warming we're seeing."
Leading climatologist James Hansen has cited the "resurging growth" of atmospheric methane as a leading cause of
the recent acceleration of global warming. James Hansen, et al., "Young People'; Burden: Requirement of Negative
COz Emissions," Earth System Dynamics, October 4, 2016.
s Fracking for natural gas leads to an average of 5.8% of natural gas produced le king into the atmosphere over the
Lifetime of the well. Dr. Robert W. Howarth, Cornell University, "A bridi to nowhere: methane emissions and the
_greenhouse gas footprint of natural gas," Energy Science & Engineering, May 20f5.
However, methane emissions rates have been observed to be as high as 12% ovr the supply chain from well head
to power plant. Howarth, "Methane emissions and climatic warming risk from h drauRc fracturing and shale as
development: implications for policy," Energy and Emission Control Technologic , October 2015.
6Howarth (footnote 5) says 5.8% of fracked gas is leaking but methane emissions exceeding a range of 1.1% to 1.9%
of total natural gas production make natural gas worse than burning coal for electricity in terms of global warming.
Dr. Drew T. Shindell, Duke University, "The social cost of atmospheric release, "E1ljmatic Change, May 2015.
Fracking causes myriad negative impacts beyond climate change, including harm to air and water quality, risks of
explosions, and increased earthquakes. People across the US are already beingitiarmed by this dangerous practice.
The natural gas industry is fighting regulation of methane emissions and drilling practices although this would also
protect the safety of its workers and local communities. This is why, while reducing methane emissions is the most
urgent and feasible measure, the total phase-out of fracking in favor of cheaper, clean energy is imperative.
$ See reference to Dr. Howarth in #4 above.
Over two-thirds of all natural gas produced in the US now comes from wells tha have been fracked (drilled using
hydraulic fracturing). US Energy Information Administration, "H drau icaLly fractured wells provide two-thirds of US
natural gas production," May 5, 2016.
9 The electric power industry accounted for 35% of US natural gas consumption in 2015. US Energy Information
Administration, "Natural gas explained: Use of natural gas," October 18, 2016.
to "EPA methane leak rules take aim at climate change," The New York Times, M6y 12, 2016.
11 A 2014 study prepared for the Environmental Defense Fund found that over 76 firms in the US — most of them
small businesses — provide methane mitigation technologies and services. Datu Research, The Emeraing US
Methane Mitioation lndustn,October 2014. I
Another 2014 Environmental Defense Fund study found that a 40% reduction 61 onshore US methane emissions is
achievable with existing technologies and techniques and would save the US ec nomy and consumers $100 million
per year. ICF International, Economic Analysis of Methane Emission Reduction=Opportunities in the US Onshore Oil
aj2d Natural Gas Industr, March 2014. 11
u Cornell University's Dr. Howarth has repeatedly said that, "The climate respokds very quickly to methane, so if we
reduce our methane emissions from shale gas now, we will slow the rate of glofal warming, in fact, that is the only
way to avoid irreversible harm to the climate." Dr. Robert W. Howarth, CornelliUniversity, "Methane ernissions: The
greenhouse gas footprint of natural gas," September 2016. I
NC WARN))) P.O. Box 61051, Durham, NC 27715.919-416-15077 • ncwarn.org
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