20140957 Ver 2_Comment Categories_20170822

Energy Polic
• In addition, this dangerous pipeline would keep us shackled to the dirty fuels of the past
and generate greenhouse gas pollution when there is no documented need for the
pipeline. Clean energy alternatives, including energy efficiency and renewable energy,
are readily available and increasingly affordable, yet the pipeline puts consumers at risk
of higher energy bills while Duke Energy will make guaranteed profits.
• We should encourage the use of renewable energy as in solar and wind, rather than putting our
land at risk for contamination.
• In addition, this dangerous pipeline would keep us shackled to the dirty fuels of the past and
generate greenhouse gas pollution when there is no documented need for the pipeline. Clean
energy alternatives, including energy efficiency and renewable energy, are readily available and
increasingly affordable, yet the pipeline puts consumers at risk of higher energy bills while Duke
Energy will make guaranteed profits.
• In addition, this dangerous pipeline would keep us shackled to the dirty fuels of the past
and generate greenhouse gas pollution when there is no documented need for the
pipeline. Clean energy alternatives, including energy efficiency and renewable energy,
are readily available and increasingly affordable, yet the pipeline puts consumers at risk
of higher energy bills while Duke Energy will make guaranteed profits.
• We need to get off fossil fuels asap and let North Carolina be a renewable energy leader.
• Additionally, the purpose of the Pipeline is to carry Frack Gas which itself has not been properly
insured and is already causing untold damage to Global Warming because of escaped Methane
to upper atmosphere where per pound effects are maybe 80 times worse than CO2 . The old
idea that NATURAL GAS is a cleaner source of energy than coal is rendered void by the extra
spilled - escaped Methane at fracking sights and beyond in transmission of this dangerous gas
to users . Our current Administration seems to taking on outlandish risks advising various
operators and developers to go ahead without bother with EPA standards but they will not be
able to protect violators long because the public image scores this administration
so low ( maybe 30% approval ) and courts have already issued warnings about taking these risky
steps and have stopped some actions. It is now apparent that Duke Energy and any supplier of
energy should take to obvious routes of going to Solar, Wind , and other non -fossil renewable
energy sources and skip entirely this obsolete step of switching from coal - at this time frack gas
is going backward from an overall basis. They should not spend public credit or public funds for
these backward steps.
Previous studies have shown that the ACP is not necessary because demand in the future will
not only remain static, but can be met by renewable energy sources. These renewables have far
less negative impact, if any, on the surrounding environment and any locations farther away
that could be impacted by spills. In addition, although corporations supporting the ACP claim
there will be "reduced energy costs "for customers, I have confidence that they will actually
raise rates to pay for the cost of the pipeline. Have utility rates ever been substantially reduced
due to increased construction? Continuing to rely on fossil fuels, particularly methane gas, which
generates more pollution than carbon dioxide, is folly. North Carolina and Virginia have even
greater potential to exploit wind and solar energy that will provide enough energy to meet
consumer demand. It is irresponsible to go forward with dirty energy options and not to pursue

these clean energy alternatives for our citizens. Speaking of our citizens, the environmental
impact will weigh heaviest on rural, low-income, mostly non-white communities. Morally
speaking, the state needs to ensure protection of those areas where people may not be able to
speak up on behalf of their own interests.
There is a lot of press for natural gas as being a clean energy resource compared to
other resource currently being used that produce large amounts of pollutions. No one
wants to talk about natural gas as a fuel source that itself contributes to pollution from
sulfur, mercury, particulates and produces nitrogen oxides which are precursors to smog
and again everyone wants to compare it to the other sources of energy that produce
pollution but in reality, natural gas is not any better that the other resources with its
own curse of pollutants it produces.
No one should have to trade their health or quality of life for what some call a cheaper,
environmentally friendly energy resource. When in the end the impact of the extraction
of natural gas and the negative environmental impact which it causes has previously and
recently been reported by news media. The additional negative effects from the
installation of a new pipeline, the additional negative effects of the acceptable approve
leakage percentage of a natural gas pipeline, the additional negative effects from using
an increase amount of natural gas with its own contaminates. In the end if one were to
add up all the negative impacts from start to finish with this product the negative
impact would no longer be mitigatable.
Climate Change
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 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, assurnedly 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.
I am amazed at the information provided by private studies reporting the negative
impact of natural gas has on the environment. Yet this information seems to be down
played. Natural gas produces methane gas which produces 25 times the amount of the
greenhouse gases than CO2 and other pollutants that cause global warming.
Economic Impacts
• This project will be significant for the economy and prosperity of North Carolina.
• I am opposed to the ACP because it only benefits the gas producers and utility company.
• Negative impacts to downstream communities from increased flooding impacts and water
treatment costs, and decreased sport fishing.
Environmental Justice
9 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
Cumulative Impacts
The combined threat to wetlands, forests, people and wildlife -- not to mention the lack of
demand for more electricity -- is more than enough to justify the rejection of the Atlantic Coast
Pipeline. I urge you to exercise the state's authority under the Clean Water Act to protect our
waters and reject the pipeline's 401 permit.
The application submitted by the Atlantic Coast Pipeline LLC doesn't provide enough
information on the cumulative water quality impacts of past, present, and reasonably
foreseeable projects related to the Atlantic Coast Pipeline.
Purpose and Need
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.
• 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.
The construction of another pipeline is not needed. There have been documented
studies and reports published that states the pipelines currently in place are sufficient to
meet the current and future needs. A study (Sept 12, 2016) by Synapes Energy
Economics, Inc. found that "given existing pipeline capacity, exiting natural gas storage,
the expected reversal of the direction of flow on the existing Transco pipeline, and the
expected upgrade of the existing Columbia pipeline, the supply capacity of the Virginia -
Carolinas region's existing nature gas infrastructure is MORE than sufficient to meet
expected future peak demands.
In 2011 the Energy Information Administration predicted the Marcellus gas field would
produce around 410 trillion cu.ft. of gas but later changed its figures to around 141
trillion cu.ft which will last the U.S. consumption of this product to their figures for only

6 years. With this mentioned why approve the ACP pipeline project with all the negative
impacts in which it creates, as mention in previous paragraphs — which is more
important, the short-term profit gain of the ones controlling the distribution of this
product with its energy contributing short life span of this gas field location or allowing
the long term or permanent negative environmental impact from it. This is no small area
that is affect from this. Avery large geographical area as to the Marcellus gas field and
a large geographical area with the proposed route of the ACP pipeline — if one were to
look at the map of the United States this overall project from gas extraction to the ACP
pipeline affects most of the eastern edge of the United states with all the negative
impacts it can have. This is no small area in which one can clean up damages but can be
things that will cause permanent damage which will be for all to deal with for all future
days to come.
Erosion control concerns
• As a resident of North Carolina, I am writing to urge you to reject the Water Quality Certification
for the disastrous Atlantic Coast Pipeline. Duke Energy hasn't shown that the pipeline won't
harm North Carolina's waters, yet the company wants to dynamite and dig deep trenches
through our creeks and wetlands, which could cause massive erosion and spell disaster for
threatened wildlife.
• Our streams and wetlands would be harmed by trenching, blasting, and stream bank erosion,
and we're going to lose important forested wetlands.
9 Erosion and sedimentation control plans are incomplete
Wildlife/T&E species
Our streams and wetlands are home to birds, bats, fish, salamanders, mussels -- including
threatened and endangered species. Some of the waters to be crossed are high quality waters
that provide drinking water to our towns.
• The construction of the pipeline could harm aquatic life and habitats, smothering spawning beds
and fish eggs. These spawning and nursery areas are essential to endangered species such as the
Atlantic sturgeon and the Shortnose sturgeon, and home to the Neuse River Waterdog, Carolina
Madtom, and several other species of concern in North Carolina.
• ACP has consulted extensively with WRC and FWS
Degradation of Water Quality
* The pipeline will cross more than 560 streams, rivers and wetlands in the state. It will put our
waters at risk of pollution and long-term damage. And harms to any of these waters could also
contaminate drinking water and hurt fisheries and the economy.
* This fracked gas pipeline would threaten hundreds of rivers, creeks and wetlands, local
farms and communities and the safety of families like mine.
* In it, they claim that they'll restore waterbodies and wetlands back to being healthy. However,
the applicant does not list any specific plans to measure or monitor the waterways they say

would be impacted. Protecting our waterways is important to me and the Atlantic Coast Pipeline
could put them in jeopardy.
The construction of the pipeline would harm nearly 37,000 feet of 326 waterbodies and at least
467.7 acres of valuable wetlands. Our wetlands, streams, and rivers are an important part of our
heritage and this pipeline could put them in danger.
The ACP will cross more than 560 streams, rivers, and wetlands in our state, and put our waters
at risk of pollution and long-term harm. Our streams and wetlands would be harmed by
trenching, blasting, and stream bank erosion, and we're going to lose important forested
wetlands. Our streams and wetlands are home to birds, bats, fish, salamanders, mussels --
including threatened and endangered species. Some of the waters to be crossed are high quality
waters that provide drinking water to our towns.
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.
Please consider the harm that the ACP will do to North Carolina water supplies
Today, the Second Circuit U.S. Court of Appeals denied a petition from Constitution Pipeline
Company and, in the process, upheld the authority of states to reject projects that impact
state water quality standards. This victory is an important reminder to all states that they
have the power to stop harmful pipeline projects.
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. This fracked

gas pipeline would threaten hundreds of rivers, creeks and wetlands, local farms and
communities and the safety of families like mine. Meanwhile, a comprehensive environmental
review has not yet been done — which means that we have no way of knowing the
impacts of this pipeline on our water supply or how our water could be adequately protected.
FERC has failed to account for the pipeline's full hazards to our environment, clean water, health
and climate — now it's up to North Carolina to act to protect our rivers, streams,
wetlands and groundwater.
This pipeline should not be allowed to cross North Carolina, mostly because of the negative
impacts on both the environment and individuals that live in it's path.
Our waterways (swamps, creeks, bays) are being affected by this project. The pipeline itself is
estimated to affect 474 acres along the route in Robeson County. The water in some of these
waterways will find itself to the Lumber River. If we have another event like Hurricane Matthew
contaminated water from this proposed project could make its way to the Lumber River. In
their reports and application they have failed to mention or evaluate these bodies of water
separately. I am Native American and my ancestors have used the Lumber River in this area for
thousands of years. My people have roamed these lands and used these waters for traveling,
hunting and fishing. We have swam in the Lumber River and used the swamps and other water
bodies as a source of life. This project looks to destroy that legacy and that tradition. These
companies have segmented this project and they aren't explaining that they plan to do with the
terminus and future projects. These companies will add this to their pipelines that run to
Hamlet and Wilmington. So this new ACP segment will eventually endanger the Lumber River in
one way or the other.
I oppose approval of Project #2014-0957 v2, and the construction of this methane gas pipeline
would cause massive disruption to ecosystems and waterways in North Carolina and in Robeson
County especially. All this for the purpose of advancing the private interests of the partners who
make up ACP LLC. ACP LLC's applications fails to acknowledge and address the likely impacts of
the construction and operation of the pipeline on our streams, rivers and wetlands.
Water is an extremely important resource for all of us, and we've learned in the past
when we take engineering measures that threaten our wetlands, streams, rivers,
springs, and wells, that often turns out poorly.
The DINT. of Water Resources' permit review for the 401 Water Quality Certification must
conscientiously require measures to protect the waters and existing uses of water resources. From
what I've read, it seems clear it win be impossible to construct the ACP without damage to streams,
rivers, wetlands, groundwater, aquatic life, human health and Environmental justice.
We cannot afford to ruin our waters and this sensitive ecosystem that are sources of livelihood and
enjoyment for our citizens. Keep North Carolina's waters beautiful and healthy and a wonderful
place to live and visit.
According to Clean Water for North Carolina (CWFNC), the ACP would cross "8 source water
protection watersheds, 3 of which are in Zones of Critical Concern." This compels NC DEQ to
require minimal impact to these areas to protect our drinking water supplies from any
contamination. Independent, third party inspectors are required to ensure autonomy from
business interests and full transparency. Negative changes in groundwater flow during and after
construction could impact many residential homes and those who depend on well water. The
Northern Coastal Plain Aquifer would easily be susceptible to contamination, thus a 150 -foot
buffer between wells and construction areas is not sufficient. A more reasonable buffer would
be 500 feet, within such area all pre- and post -construction well testing of water quality should
be performed by certified, independent labs and include any chemicals used during construction

and components of natural gas liquids. Because no Sedimentation and Erosion Plan has been
received thus far by DEQ from ACP, no evaluation of how to protect downstream water quality
may be made. There is also a lack of analysis concerning riparian buffer mitigation in addition to
a lack of discernment for possible problems leading to drilling fluids leaks such as what occurred
on the Rover Pipeline this year. What measures are in effect to prevent drilling leaks during the
use of directional drilling methods? What is being done to prevent drilling contaminants from
flowing downstream along the trenches being dug for the pipeline? The absence of data and
study increases the likelihood of possible damage to the environment.
Perhaps most troubling, the "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".
The importance of our wetlands cannot be overemphasized, providing natural water filtration
for both human and animal consumption. If gas, oil, or fuels contaminate our precious
resources, their function is lost for possibly forever. The price to reproduce this critical function
artificially would certainly not be free.
Lastly, continued wetland loss threatens the home of animal and plant life. Because no
Sedimentation and Erosion Plan has been received thus far by DEQ from ACP, no evaluation of
how to protect downstream water quality may be made. There is also a lack of analysis
concerning riparian buffer mitigation in addition to a lack of discernment for possible problems
leading to drilling fluids leaks such as what occurred on the Rover Pipeline this year. What
measures are in effect to prevent drilling leaks during the use of directional drilling methods?
What is being done to prevent drilling contaminants from flowing downstream along the
trenches being dug for the pipeline? The absence of data and study increases the likelihood of
possible damage to the environment.
The path of the pipeline will cross the timber and wetland area of our small farm in
Wilson County. We and our neighbors have legitimate concerns about the real possibility
of contamination to our environment and underground water supply. Like many
residences in Wilson County our water supply is from well water. The aquafers that
supply our well water could become contaminated during pipeline construction and
operation. Just a few months ago the Energy Transfer Partners' new Rover pipeline
construction was halted due to a spill of millions of gallons of drilling fluid. Spills such
as this and any natural gas leak can cause water contamination.
The route of the pipeline will cross nearly every water supply in the state of North
Carolina. In the thousands of pages of the FERC EIS there is documentation of the
negative impacts of the construction and operation of a natural gas pipeline. Quoted
from FERC final EIS, "approval of the projects would have some adverse and significant
environmental impacts; however, the majority of impacts would be reduced ... with
proposed mitigation and the additional measures recommended in the EIS." It states
proper mitigation can minimize the negative impact. Who is going to insure this is
done? What happens when the planned mitigation fails as previously mentioned with
the Rover pipeline spill.

Spills/Prior track record
0 Duke has a bad record on environmental issues.
Incomplete application
• The current application for 401 Water Quality Certification simply doesn't include enough
information about which streams would be subject to trenching, cofferdams or in -stream
blasting. Without site-specific details, it's impossible to know what the water quality impacts
would be. This is unacceptable.
• Meanwhile, a comprehensive environmental review has not yet been done —
which means that we have no way of knowing the impacts of this pipeline on our water
supply or how our water could be adequately protected.
• It's also concerning to me that the application put forward by Atlantic Coast Pipeline LLC doesn't
provide enough information for DEQ to make a sound decision on whether or not to move
forward with the pipeline.
• Duke has NOT shown that the ACP won't harm North Carolina's waters.
• The Application for 401 Water Quality Certification doesn't include enough details about which
streams would be subjected to trenching, cofferdams, or in -stream blasting. Without site-
specific details, it is impossible to know what the water quality impacts would be.
The application for 401 Water Quality Certification for the ACP doesn't include enough details
about which streams would be jeopardized by trenching, cofferdams, or in -stream blasting.
Without site-specific details, it's impossible to know what the water quality impacts would be.
The application hasn't shown that the Atlantic Coast Pipeline won't pollute our waterways.
Extensive Regulatory Review
Over the past three years, the ACP has sought review and input by various federal, state,
and local agencies, as well as hundreds of individuals with a stake in the project. The
ACP project team has provided more than 100,000 pages of reports and documentation
about everything from construction safety and economic impact to pollinators and water
safety—and much more. Throughout this extensive process, the Federal Energy
Regulatory Commission and many other agencies have carefully analyzed potential
impacts to the land, air and water quality, wildlife, and other resources.
Explosions/natural gas leaks
Please consider the harm that the ACP will do to North Carolina water supplies as well as
the non emergency plans that are non existence if something happens. Dominion and
Duke have no plan to help citizens with any money set aside for disasters.
My family has land that is adjacent to the terminus of the pipeline. A roadway separates
the properties and I assume that is why it is not being considered as directly adjacent. My
family's home and land are considered to be partially in the blast zone an evacuation
zone. The companies wanting to build this pipeline hasn't tried to contact them and let
them know they could be affected. The company for some reason hasn't contacted many

people on this route who could be affected. They are only contacting landowners who
they want to buy property from and they are threatening those people with eminent
domain and telling them they have to sell or they have to let people survey their land. I
know this personally because they haven't contacted my family that live on the land still
today and they haven't contacted me personally. I too live in what is called the
evacuation plan. I have not received any information from these companies by no means.
My family at one time had a well on the property. There was a huge bay (low area that
could collect water) behind my family's land. The county has come and put a huge water
tower on property adjacent to our land. Our well has run dry. Now our county is wanting
to allow a methane pipe bomb to be beside my family's land.
• what type and amount of liability Insurance is required to even submit an application for
a project like the Atlantic Coast Pipeline ? Remember that the Gulf spill a few years
ago cost BP over $20 Billion and the end is not yet in sight.
• Pipelines are the safest mode of transport for natural gas
• Hurricanes could impact the pipeline
• Pipelines are safe. We have thousands of miles of pipelines in the US
Eminent Domain
In addition, it is not right to seize the land of people who are trying to make their own
living, only to provide more monetary gain to private energy companies