20140957 Ver 2_ACP More Info 11-20-2017_20171120

Spencer,
The Division reviewed the revised Indirect and Cumulative Effects (ICE) Screening document received on
November 15, 2017. ACP completed this revision in response to additional information requested by
the Division in a conference call on November 7, 2017.
In our conference call, Division staff explained that ACP's ICE Screening lacked an analysis of the
project's potential to stimulate economic development and its potential impact on water quality. Staff
suggested maps of available water and sewer infrastructure overlaid with the pipeline route, water
resources, and existing developed areas and roadway infrastructure would be helpful to identify areas
with potential to experience project -induced growth (within the County, not County -wide). Once these
areas are identified, a more detailed discussion of the potential for each specific area to experience
project -induced growth must be provided. Although ACP provided the mapping suggested by staff,
there was no analysis of the information provided in the maps, specific areas were not identified, a
detailed analysis of each area's potential for project -induced growth was not completed, nor was there
a detailed discussion of the regulatory framework that may be in place or needed to protect water
quality.
Excerpts below from Guidance for Assessing Indirect and Cumulative Impacts of Transportation Projects
in North Carolina Volume 11' explains the analysis should include comparing forecasts of future
conditions with and without the proposed project along with an explanation of the underlying system of
logic used in the analysis.
Analyzing induced growth is an exercise in creating and comparing forecasts offuture conditions.
At least two forecasts are necessary:
• a Base or No -Action Forecast which describes future conditions in the absence of the project
or plan; and
• an Action Forecast describing conditions in a future point in time following implementation
of the project alternative or plan...
The key in forecasting is an underlying system of logic that can produce reproducible and
relatively consistent results regardless of the forecaster. It should be noted thatforecasting is
not the exact determination and prediction of the future, but the logical extrapolation of likely
effects that will occurfrom known associations among different critical parts of the system.
(from page IV -4)
This analysis should include a specific discussion of industries that need additional natural gas capacity
to operate in North Carolina. There should be a clear connect to support the conclusion statements.
In addition to the more robust analysis of ICE, please also provide more details regarding the terminus of
the project in the ICE document. On page 12 of the ICE, ACP states that there is no commitment to
potential customers or reasonably foreseeable plans to extend the ACP beyond the current terminus.
Include an explanation of the factors that led to proposed terminus of the project.
' Guidance for Assessing Indirect and Cumulative Impacts of Transportation Projects in North Carolina Volume 11:
Practitioner's Handbook. 2001. The Louis Berger Group, Inc.
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