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INDIRECT AND CUMULATIVE IMPACTS ASSESSMENT
Atlantic Coast Pipeline
November 2017
SCOPE AND PURPOSE
The purpose of this analysis is to supplement the qualitative cumulative analysis
requested by the North Carolina Department of Environmental Quality (NCDEQ) in its
September 14, 2017 and October 26, 2017 letters. In accordance with NCDEQ guidance,
"Cumulative Impacts and the 401 Water Quality Certification and Isolated Wetland Permitting
Programs," dated April 10, 2014, this analysis evaluates and describes secondary' (hereafter
referred to as indirect) and cumulative 2 impacts that could potentially result from construction
and operation of those portions of the Atlantic Coast Pipeline (ACP or Project) within the Study
Area, which has been defined by the NCDEQ as Johnston, Cumberland, and Robeson counties,
North Carolina (see Figure 1). Consistent with North Carolina guidance, this analysis focuses on
the cumulative impacts on downstream water quality standards and designated uses.' The
analysis addresses whether growth will be induced by the project, and how the water quality
impacts of such growth will be managed.
The categories listed on the Indirect and Cumulative Effects Screening Matrix below
have been shown to influence land development decisions in numerous areas statewide and
nationally. Each characteristic is assessed individually and the results of the table are analyzed
to determine the indirect effects potential of the proposed project.
This cumulative impacts analysis is focused on water quality, wetlands, and water
resources. A cumulative impact assessment of other resources affected by the ACP was included
in the previous submittal to the NCDEQ on September 29, 2017, and the final environmental
imp -act statement for the Project prepared by the Federal Energy Regulatory Commission
(FERC). Pursuant to guidance provided in the October 26, 2017, Information Request Letter
from NCDEQ, projects included in the cumulative impacts assessment for the Project were
limited to those within Johnston, Cumberland, and Robeson counties that would be constructed
in a similar timeframe to the Project. Attachment 1 summarizes the components of the Project
with potential cumulative impacts identified in each county.
"Secondary impacf' means actions, or actions directly linked to an activity, that may affect classified surface waters or
wetlands that would not occur bu for the proposed activity.
2 "Cumulative impact' 'means environmental impacts resulting from incremental effects of an activity when added to other
past, present, and reasonable forseeable future activities regardless of what entities undertake such other actions.
3 A cumulative impact assessment of other resources affected by the ACP was included in the previous submittal to the
NCDEQ on September 29, 2017, and the final environmental impact statement for the Project prepared by the FERC.

Cumulative
Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
Perribrolce M&R
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ACP M-1— Atlantic Coast Pipeline
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Johnston
41
County
Smithfield M&R
Contractor Yard"""
100
110
120
FayettevOle
M&R
130
Contractor Yard 140
Cumlerlan'd`"l
County
150
160
170
Perribrolce M&R
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County
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ACP M-1— Atlantic Coast Pipeline
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Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
In accordance with the National Environmental Policy Act and North Carolina State
Environmental Policy Act, the indirect and cumulative impacts of the Project and other projects
or actions in the same areas are considered. This analysis uses an approach consistent with the
guidelines set forth by the NCDEQ. Under these guidelines, the inclusion of actions within the
analysis is based on identifying commonalities of impacts from other actions to potential impacts
that would result from the Project.
Screening Tool Results
Based on the information gathered from local land use and development plans and
information from mapping and data reviews, a screening tool was developed.
SCREENING RESULTS
The results of the screening tool are summarized in Table I and discussed in more detail
below.
TABLE I
Indirect and Cumulative Effects Screening Matrix
Notable
Scope of
Population
Available
Water/Sewer
Natural Gas
Market for
Water
Rating
Project
Growth
Land
Availability
Availability
Development
0111"
Resources
Major
> 3% annual
5000+
All services
All services
Development
Less stringent,
Targeted or
More
new
population
acres of
existing/
existing/
activity
no growth
threatened
Concern
location
growth
land
available
available
abundant
management
resources
T
X
X
T
X
X
X
X
No
No service
Featured
Very
population
Limited
No service
available
Development
More stringent,
incorporated
Less
limited
growth or
land
available now
now or in
activity
growth
in local
Concern
scope
decline
available
or in future
future
lacking
management
protection
Atlantic Coast Pipeline, LLC (Atlantic) is proposing to construct approximately
600 miles of mainline natural gas transmission underground pipeline, 81 miles of lateral
underground pipeline, three compressor stations, nine metering and regulating (M&R) stations,
and various appurtenant facilities in West Virginia, Virginia; and North Carolina.
Approximately 100 miles of pipeline and 3 M&R stations would be constructed in Johnston,
Cumberland, and Robeson Counties, North Carolina. The proposed route and facility locations
within the 3 North Carolina counties under review are depicted in Figure 1, below. County -
specific descriptions of proposed facilities are provided as follows:

Cumulative frapacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
Johnston County
The ACP enters Johnston County from the northeast and extends approximately 3 8 miles
southwest to the border of Cumberland County. The proposed pipeline route passes near the
towns of Kenly, Micro, Selma, Smithfield, Four,Oaks, and Benson. Throughout Johnston
County, 12 permanent and 4 temporary access roads would be utilized along the pipeline.
Johnston County has one M&R station, the Smithfield M&R station, which is approximately
5.5 acre in size and located in central Johnston County. The M&R station is in a rural setting
approximately 2.5 miles west from the town of Smithfield.
The ACP would require approximately 616.4 acres of construction workspace in
Johnston County, of which 254.8 acres would be maintained during operations for the permanent
pipeline right-of-way, permanent access roads, and the Smithfield M&R station. Table 2
includes a summary of the construction and operations impacts.
TABLE2
Construction and Operational Impacts (in acres) in Johnston, Cumherland, and Robeson County, North CaroHna
Construction (Temporary and Permanent) Operation (Permanent)
Johnston County 616.4 254.8
Cumberland County 589.1 270.7
Robeson County 313.5 144.3
Total 1,519.0 669.8
Cumberland County
The ACP enters Cumberland County from the northwest and extends approximately
39.7 miles south, then east, to the border of Robeson County. The proposed pipeline route
passes near the towns of Godwin, Wade, Fayetteville, 'and Stedman. Throughout the county,
16 permanent access roads would be utilized along the pipeline. In Curnberland County, the
Project includes one M&R station, the Fayetteville M&R station, which is an approximately
7.3 acre site located in northern Cumberland County. The'M&R station is approximately ten
miles north of the city of Fayetteville and 1.5 miles west from the town of Wade. The area
immediately surrounding the site is rural and contains agricultural fields. The ACP would
require approximately 589.1 acres of construction workspace in Cumberland County, of which
270.7 acres would be maintained during operations for the permanent pipeline right-of-way,
permanent access roads, and the Fayetteville M&R station (see Table 2).
Robeson County
The Project enters Robeson County from the northeast and extends 22.4 miles southwest
to the southem terminus of the ACP. The proposed pipeline route passes by the towns of
St. Pauls and Remert, and ends approximately 3.3 miles northwest of the town of Pembroke.
The Pembroke M&R station is an approximately 2.5 acre site. The area immediately
surrounding the site is rural and contains agricultural fields. Throughout Robeson County,
12 permanent and four temporary access roads would be utilized along the pipeline. The ACP
would require approximately 313.5 acres of construction workspace in Robeson County, of
4

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
which 144.3 acres would be maintained during operation for permanent pipeline right-of-way,
permanent access roads, and the Pembroke M&R station (see Table 2).
Since the Project would impact 1,519 acres and crosses through multiple counties, the
potential for this project to contribute to growth and development was rated as High.
POPULATION GROWTH
According to the U.S. Census Bureau, Johnston, and Cumberland Counties have
experienced an estimated population increase of 13.3 and 2.3 percent, respectively, from 20 10
until early 2016. The population in Robeson County decreased an estimated 0.7 percent from
2010 until 2016. In comparison, the state of North Carolina had an estimated growth of
6.4 percent during this same period. In 2016, the total estimated population of the
three counties was estimated to be 651,812; approximately 6.4 percent of the total population of
North Carolina (U.S. Census Bureau, 2016). Based on the range of population growth from high
in Johnston County to negative in Robeson County, the potential for this project to contribute to
population growth was rated as Moderate.
AVAILABLE LAND,
Table 3 summarizes the undeveloped land in Johnston, Cumberland, and Robeson
Counties based on the U.S. Geological Survey (USGS) gap data (USGS, 2011). Attachment 2
provides figures illustrating the extent of developed and undeveloped land in each county.
Availability of land in Johnston, Cumberland, and Robeson Counties, does not appear to be
limiting; therefore, the potential for this Project to contribute to development based on the
availability of land is rated as High.
TABLE3
Developed and Undeveloped Land By County
Total Land (Acres) Developed Land (Acres) Undeveloped Land (Acres)
Johnston 372,241 30,754 341,487
Cumberland 369,271 69,063 300,208
Robeson 608,654 36422 572,232
WATER/SEWER AVAILABILITI�
Municipal water service is available for the majority of Johnston County; sewer services
are mainly only available for the western portion of the county (Johnston County, 2017).
Municipal water and sewer services are available for portions of Cumberland County, mainly in
the areas in and around the City of Fayetteville (Cumberland County, 2017). In Robeson
County, larger municipalities such as Lumberton, Pembroke, Fain-nont, Red Springs, and
St. Pauls, all have municipal water and sewer systems; however these services are lacking in
unincorporated towns (Robeson County, 2014). The figures in Attachment 2 illustrate the
general distribution of sewer and water services for the three counties. For Johnston and
Cumberland Counties, this information is based on the Geographic Information System (GIS)
mapping tools available online for each county (Johnston County, 2017; Cumberland County,
2017). Robeson County did not have available GIS data; as a result, the distribution of sewer

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
and water services depicted in the Robeson County figure is based on the boundaries of
municipalities identified as containing water and sewer service (Robeson County, 2014). Based
on the availability of municipal water and sewer in the developed or developing areas of
Johnston, Cumberland, and Robeson Counties, the potential for the Project to contribute to
water/sewer availability is rated as Moderately Low.
NATURAL GAS AVAILABILITY
Natural gas service is currently available in larger municipalities of Johnston County such
as Benson, Clayton, Smithfield, and Selma; expansion of these services is ongoing (Johnston
County, 2017). Natural gas utilities are available in the large municipalities of Cumberland
County such as Fayetteville; there is limited information available on the extent of distribution in
other areas of the county (Cumberland, 2010). Natural gas availability is limited in Robeson
County. In 2010, it was estimated that approximately 60 to 70 percent of homes in Robeson
County are farther than 0.25 mile away from a gas distribution line (Robeson County, 2014).
While county -specific data is limited, some data and analysis on a state-wide scale is
available. Increased natural gas use by power generators is driving demand in North Carolina.
The electric power sector is the state's largest natural gas -consuming sector. The industrial
sector led the state in natural gas consumption until 2012, when the electric power sector became
the largest user for the first time. The residential sector is the third-largest natural gas -
consuming sector in the state. About one-fourth of North Carolina households use natural gas
for home heating (U.S. Energy Information Agency, 2017).
Existing interstate pipelines have historically transported natural gas into North Carolina,
including Williams (Transco system), TransCanada (Columbia Gas system), and Enbridge (East
Tennessee system). ACP would be an additional carrier of natural gas supply into North
Carolina and would provide a new source of gas. According to the U.S. Energy Information
Agency, the State of North Carolina utilized 522 MM cubic feet of natural gas in 2016. ACP
would be capable of transporting up to 1.5 N4M cubic feet per day to delivery points in Virginia
and North Carolina. S-1
------------- 0
Based on the expected increase in availability of natural gas in the developed or
developing areas of Johnston, Cumberland, and Robeson Counties, the potential for the Project
to contribute to the availability of natural gas was rated as High.
MARKET FOR DEVELOPMENT
Johnston County:
With transportation improvements, approved development, and availability of suitable
land, The Johnston County 2030 Comprehensive Plan estimated 42,500 new dwelling units and
accompanying non-residential growth would occur across the County. It is suggested that future
growth demands should benefit from municipal planning initiatives, decisions and investments
already in place (Johnston County, 2009).
In northern Johnston County, a steady, long-term increase in economic activity due to the
County's proximity to the Research Triangle Park in Durham and Wake Counties has
Z

Cumulative hnpacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
transformed what had long been an agrarian area to a more diverse mix of 4,15an, agricultural,
and forested landscapes. Conversely, the southern portion of the county has seen little or no
growth due to a limited real estate market, less available public transportation, and limited water
and sewer infrastructure development. According to the County's 2009 comprehensive plan,
Johnston County has experienced significantly high growth rates overall since 1990, a trend that
has continued through 2017. 1
Urban development is most intdnse in the western part of the County; however,
residential developments are becoming increasingly dense in central Johnston County between
the towns of Selma and Pine Level. According to the County Comprehensive Plan, additional
development within these two communities "is both likely and desirable." The County
Comprehensive Plan anticipates future municipal annexations (Johnston County, 2009).
According to the Johnston County Planning and Zoning Department Annual Report
(Johnston County Planning and Zoning Department, 2016), there have been 611 plats for new
subdivisions reviewed and signed in 2016. This was the most plats signed in one year since the
County assumed map review responsibility in 2009. In 2015, there were 523 plats signed. The
County reported 1,200 subdivision lots recorded or permitted in 2016. Additionally, '
1,637 single-family housing units are proposed in the near future. The Report indicates that
development and housing demand is strong, due in -part to steady job and population growth, as
well as, the replacement of existing aging homes (Johnston, 2017).
Cumberland County:
Cumberland County is within the Fayetteville Metropolitan Statistical Area. Existing and
future development in the County is centered on Fayetteville and the surrounding area. Other
towns where growth is likely to occur include those along the 1-95 corridor. These towns include
Eastover, Falcon, Hope Mills, Spring Lake, and Wade. Another driver for development stems
from housing needs associated with Fort Bragg and Pope Air Force Base.
The Cumberland County Community Development published the Housing Market
Analysis in 2015 that gave a number of conclusions and recommendations regarding housing
needs and developments goals. The Analysis found that housing costs are relatively inflated and
workers in lower -wage jobs are priced out of affordable housing. The analysis acknowledges a
housing shortage that needs to be addressed through new construction and rehabilitation of
vacant properties (Cumberland County, 2015).
Robeson County:
Robeson County's future growth and market for development will likely occur near
Lumberton, Maxton, Pembroke, Red Springs, and Saint Pauls. Development corridors in the
County are generally adjacent to the 1-95 and 1-74 which bisect the County. Based on a review
of city and county websites, press releases, and public documents, there is no information on
Major developments pending as of November 2017.
Based on the current and planned development in Johnston, Cumberland, and Robeson
Counties, the potential for the Project to support the market for development was rated as
Moderate.
7

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
�fpuwuc POLICY
Johnston County:
Several public policy documents influence land use planning and development in
Johnston County. In addition to the County Comprehensive Plan many of the municipalities in
Johnston County have their own comprehensive plans to direct future growth. The towns of
Four Oaks, Clayton, Smithfield, and Selma all have such Plans. Planning efforts are coordinated
between municipality governing bodies and the County. Johnston County and local municipal
governments created the Municipal Transition District (MTD) to aid in land use planning and
development. The MTD allows for greater residential densities in some areas to promote
efficient development near existing urban areas. MTDs are more readily served by existing
services and utilities and discourage sprawling suburban development into agricultural areas in
rural Johnston County.
Development in Johnston County is anticipated to occur in existing communities along
the 1-95 corridor that have established MTDs. These communities include Kenly, Micro, Selma,
Smithfield, Four Oaks, and Benson. Other cities where development is likely to occur are
Clayton and Princeton. The Annual Report (2016) indicates that the majority of building permits
and recorded lots/subdivisions are within the MTDs of the aforementioned communities. This
demonstrates the general trends of planned and realized development scenarios.
Cumberland County:
Cumberland County has adopted a 2030 Growth Vision Plan and a Land Use Policies
Plan (Cumberland County, 2008). The Cumberland County Joint Planning Board divided the
County into several land use planning study areas. I
The Cumberland County 2030 Growth Vision Plan shows that the Northeast part of the
County includes open space, farmland, residential, commercial, and industrial land (Cumberland
County, 2011). Rural residential and suburban tract development is relatively dense in some
portions of this section of Cumberland County.
The Draft Wade Study Area Detailed Land Use Plan addresses the City of Wade and
surrounding areas. This includes the land -use designated "Farmland," and areas within the Wade
City limits which are planned for low density residential use, but are currently undeveloped.
The South Central Land Use Plan covers the section of the County south of the Cape
Fear River to the Robeson County line. With the exception of a one -mile strip of land south of
the Cape Fear River to Rainey Road, the land use is designated as "Farmland." Despite this
designation, there are numerous housing tracts with parcels of less than one acre. The land
between the Cape Fear River and Rainey Road is designated for "One Acre Mixed Housing
Types." The Cumberland County zoning ordinance does not specifically address natural gas
transmission pipelines; however, the ordinance contains a "Use Matrix7 indicating that
public/community utility stations/substations are allowable in all zoning districts (Cumberland
County, 2010).

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
The overarching goal of land use planning in Cumberland County is to concentrate
development around Fayetteville and maintain traditional agricultural land use in the rural areas
of the County. In general, the residents envision Southeast Cumberland Area remaining a rural
farming community intermixed with some small concentrated residential areas, very limited
commercial, and lots of natural areas. This is accomplished by establishing Farmland Protection
Areas throughout the County and limiting services and utilities to rural areas to control urban
development outside of established planning areas.
Robeson County:
Future development in Robeson County is directed, in part, by the goals stated in the
Robeson County Comprehensive Plan (Robeson County, 2014). The Robeson County
Comprehensive Plan was developed to outline goals for enhancing the quality of life for
residents. The plan supports long-term economic growth and protection of natural areas while
providing land -use patterns to support economic development.
The Plan's future land use map seeks to direct growth in and near Municipal Planning
Jurisdictions including Lumberton, Maxton, Pembroke, Red Springs, and Saint Pauls.
Robeson County is largely undeveloped with the majority of existing lands classified as
agricultural lands, rural residential, or vacant. There is no unincorporated land in the County that
is zoned. As an estimated minimum, 4,500 new dwellings will be required by 2030 correlating
with population growth (Robeson County, 2014).
Based on the Public Policy designed to control expected growth for Johnston,
Cumberland, and Robeson Counties, the potential for the Project to contribute to public policy
goals was rated as Moderate.
K
6NOTARL
�9�_WATERRVS -
OU VC E S, /
Johnston, Cumberland, and Robeson Counties include portions of 6 major watersheds in
the State of North Carolina:
Upper Cape Fear and Lumber Watersheds (Robeson and Cumberland
Counties);
Little Pee Dee Watershed (Robeson County);
Upper Neuse Watershed (Johnston County);
Contentnea Watershed (Johnston County);
Black Watershed (Johnston and Cumberland Counties); and
Lower Cape Fear Watershed (Cumberland County).
6

Cumulative hnpacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
The major rivers flowing through the counties include the middle or lower reaches of the
Neuse, Cape Fear, and Lumber rivers and their tributaries.
Table 4 summarizes the wetlands and waterbodies in Johnston, Cumberland, and
Robeson Counties based on National Wetlands Inventory data and the National Hydrography
Dataset (USGS, 2017; U.S. Fish and Wildlife Service [USFWS], 2017).
The figures in Attachment 2 illustrate the wetland and waterbodies present in the three
counties. Based on the amount of wetlands and waterb6dies in Johnston, Cumberland, and
Robeson Counties, this category is rated as Moderately -Low.
�f�0-TENTIAL-IAIP-ACT-CAUSING-ACT M-TIES,-
Waterbodies and Wetlands
Waterbodies are defined by the FERC as "any natural or artificial stream, river, or
drainage with perceptible flow at the time of crossing, and other permanent waterbodies such as
lakes and ponds." The term "waterbodies," as used here, is best understood as those water
features — excluding wetlands — that are potentially subject to jurisdiction under the Clean Water
Act. The U.S. Army Corps of Engineers (USACE) and Environmental Protection Agencyjointly
define wetlands as "those areas that are inundated or saturated by surface or groundwater at a
frequency and duration sufficient to suppo rt, and that under normal circumstances do support, a
prevalence of vegetation typically adapted for life in saturated soil conditions."
Atlantic corresponded with the USFWS to determine which streams are sensitive based
on the presence, or anticipated presence of species protected under the Endangered Species Act
(16 U.S. Code § 1531 et seq.). The FERC (lead federal agency) and the USFWS determined that
no North Carolina aquatic species would "likely be adversely affected" based on communication
between the two agencies. A summary of waterbodies and wetlands delineated along the ACP in
Johnston, Cumberland, and Robeson Counties is provided in Table 5. Figures illustrating the
wetlands and waterbodies crossed by the ACP are included as Attachment 3.
10
TABLE4
Waterbodies and Wedands
By County
Johnston County
Cumberland County
Robeson County
Waterbody Classifications
Miles of Waterbodies
Canal/Ditch
13
192
414
Intermittent
1,286
499
965
Perennial
748
812
1,031
Waterbody Total
2,047
1,503
2,410
Wetland Classifications
Acres of Wetlands
Open Water
7,538
7,241
3,306
Emergent
497
949
5,091
Scrub -Shrub
3,607
11,148
15,943
Forested
62,817
58,987,
147,366
Wetland Total
74,459
78,325
171,706
The figures in Attachment 2 illustrate the wetland and waterbodies present in the three
counties. Based on the amount of wetlands and waterb6dies in Johnston, Cumberland, and
Robeson Counties, this category is rated as Moderately -Low.
�f�0-TENTIAL-IAIP-ACT-CAUSING-ACT M-TIES,-
Waterbodies and Wetlands
Waterbodies are defined by the FERC as "any natural or artificial stream, river, or
drainage with perceptible flow at the time of crossing, and other permanent waterbodies such as
lakes and ponds." The term "waterbodies," as used here, is best understood as those water
features — excluding wetlands — that are potentially subject to jurisdiction under the Clean Water
Act. The U.S. Army Corps of Engineers (USACE) and Environmental Protection Agencyjointly
define wetlands as "those areas that are inundated or saturated by surface or groundwater at a
frequency and duration sufficient to suppo rt, and that under normal circumstances do support, a
prevalence of vegetation typically adapted for life in saturated soil conditions."
Atlantic corresponded with the USFWS to determine which streams are sensitive based
on the presence, or anticipated presence of species protected under the Endangered Species Act
(16 U.S. Code § 1531 et seq.). The FERC (lead federal agency) and the USFWS determined that
no North Carolina aquatic species would "likely be adversely affected" based on communication
between the two agencies. A summary of waterbodies and wetlands delineated along the ACP in
Johnston, Cumberland, and Robeson Counties is provided in Table 5. Figures illustrating the
wetlands and waterbodies crossed by the ACP are included as Attachment 3.
10

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
Cumulative effects on surface water resources impacted by construction and operation of
the Project in Johnston, Cumberland, and Robeson Counties, North Carolina would be limited to
waterbodies that are affected by other projects located within the same watershed (see
Attachment 1). Atlantic would minimize impacts on waterbodies and wetlands by implementing
its sediment and erosion control plan (S&ECP) and adhering to all applicable state and federal
permit conditions. Atlantic has developed the S&ECP using the FERC Plan and ProcedureS4,
and the North Carolina Erosion and Sediment Control Planning and Design Manual. To further
minimize impacts, USFWS identified sensitive waterbodies within the Project area. Atlantic
would implement enhanced erosion and sediment control measures at these crossings.
NUIRECT-EFFECTS CONCLUSION
Indirect Summary Statement
The North Carolina Administrative Code adopts the federal definition of indirect impacts
as impacts that "are later in time or further removed in distance." (Council on Environmental
Quality 1986, 40 Code of Federal Regulations [CFR] 1508.8). The majority of land
development outside of the proposed Project is expected to occur within or near urban areas of
Johnston, Cumberland, and Robeson Counties. The Project has been routed to avoid urban areas
and areas with planned developments identified during the routing process. According to the
counties' comprehensive plans, future development activities are anticipated for the areas around
Selma, Pine Level, Fayetteville, and Lumberton, which the ACP largely avoids, but with
additional infrastructure could be served by new sources of natural gas in the county.
Customers of the ACP in North Carolina have indicated that the majority of the gas
would be used for power generation, with the remainder for commercial, industrial, and
residential customers. Natural gas transported by the ACP would provide an alternate source of
fuel, increased reliability, and support projected growth, and would be but one of several factors
4 Refers to the 2013 versions of the FERC's Upland Erosion Control, Revegetation, and Maintenance Plan (Plan) and
Wetland and Waterbody Construction and Mitigation Procedures (Procedures)
11
)b
TABLE5
Waterbody and Wetlands Affected by the Atlantic Coast Pipeline By County
Johnston County
Cumberland County
Robeson County
Waterbody Classifications
Waterbody Affected Bank Length (Feet)
Ephemeral
560
2,205
540
Intermittent
2,215
5,055
1,813
Perennial
1,493
3,430
1,232
Waterbody Total
4,268 go,
2105,10 10,690 '7, 13f LP
3,584
Wetland Classifications
Wetlands Affected (Acres)'
�alustrme Emergent
1.2
4.6
2.6
Palustrine Forested
82.4
81.5
54.4
Palustrine Scrub -Shrub
4.5
21.2
18.0
Wedand Total 1
88.1
107.2
75.0
a Acreage of wetland within
the construction footprint.
Cumulative effects on surface water resources impacted by construction and operation of
the Project in Johnston, Cumberland, and Robeson Counties, North Carolina would be limited to
waterbodies that are affected by other projects located within the same watershed (see
Attachment 1). Atlantic would minimize impacts on waterbodies and wetlands by implementing
its sediment and erosion control plan (S&ECP) and adhering to all applicable state and federal
permit conditions. Atlantic has developed the S&ECP using the FERC Plan and ProcedureS4,
and the North Carolina Erosion and Sediment Control Planning and Design Manual. To further
minimize impacts, USFWS identified sensitive waterbodies within the Project area. Atlantic
would implement enhanced erosion and sediment control measures at these crossings.
NUIRECT-EFFECTS CONCLUSION
Indirect Summary Statement
The North Carolina Administrative Code adopts the federal definition of indirect impacts
as impacts that "are later in time or further removed in distance." (Council on Environmental
Quality 1986, 40 Code of Federal Regulations [CFR] 1508.8). The majority of land
development outside of the proposed Project is expected to occur within or near urban areas of
Johnston, Cumberland, and Robeson Counties. The Project has been routed to avoid urban areas
and areas with planned developments identified during the routing process. According to the
counties' comprehensive plans, future development activities are anticipated for the areas around
Selma, Pine Level, Fayetteville, and Lumberton, which the ACP largely avoids, but with
additional infrastructure could be served by new sources of natural gas in the county.
Customers of the ACP in North Carolina have indicated that the majority of the gas
would be used for power generation, with the remainder for commercial, industrial, and
residential customers. Natural gas transported by the ACP would provide an alternate source of
fuel, increased reliability, and support projected growth, and would be but one of several factors
4 Refers to the 2013 versions of the FERC's Upland Erosion Control, Revegetation, and Maintenance Plan (Plan) and
Wetland and Waterbody Construction and Mitigation Procedures (Procedures)
11
)b

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
potentially contributing to growth in the 3 counties. VVhile it is not possible to identify specific
growth or development that would be likely to result from the additional natural gas availability,
it is assumed that the Project would support existing planned development.
The Project would have direct wetlands/waterbodies impacts on the areas crossed, and
could have indirect impacts on wetlands/waterbodies outside of the immediate vicinity of the
pipeline right-of-way, aboveground facilities, and access roads depending on the scale and
location of development, acti * vities undertaken as a., result of increased natural gas availability.
Atlantic has no commitment to potential customers or reasonably foreseeable plans to
extend ACP beyond the current terminus. Because there is no planned expansion that can be
scoped or analyzed, the potential for extension of the pipeline is not addressed in this report.
Water Quality Statement
Atlantic would avoid or minimize direct impacts on wetlands and waterbodies by
implementing mitigation measures and requirements outlined in the federal, state, and local
authorizations issued to the Project. This includes measures outlined in the USACE Section 404
permit and the S&ECP plan developed for the ACP that incorporates requirements from the
FERC Plan and Procedures and the North Carolina General Permit to Discharge Stormwater
under the National Pollutant Discharge Elimination System for Construction Activities, general.
permit NCGOIOOOO. The S&ECP plan review is being coordinated with NCDEQ staff out of the
Raleigh and Fayetteville Regions. Atlantic would follow the requirements of the Section 404
permit, the general permit NCGO 10000, and the approved S&ECP plan to minimize potential
impacts on wetlands and waterbodies.
The ACP would cross one 303(d) impaired water, Moccasin Creek in Johnston County,
which is impaired for benthos. As noted above, Atlantic would follow the requirements of
general permit NCGO 10000 and the approved S&ECP plan to minimize potential impacts on
waterbodies, including Moccasin Creek.
It is unlikely that significant or permanent indirect effects to waterbodies would result
from construction activities within the stream channels and adjacent banks of the waterbodies.
Short term increases in sedimentation and turbidity could result from in -stream construction
activities, trench dewatering, and storm water runoff from construction areas. These impacts are
expected to primarily be limited to in -stream construction. Impacts are expected to be short-
term, given that waterbody crossings would occur as quickly as possible and stabilization of the
construction area would occur immediately after the crossing of each waterbody, so that
conditions would be stabilized shortly after stream restoration activities are complete.
Direct impacts to the majority of affected wetlands are anticipated to be short-term.
Temporary impacts on wetlands would occur within the construction limits of disturbance, with
long-term conversion of forested and scrub -shrub to emergent wetlands due to maintenance of
the pipeline right-of-way according to the FERC Procedures and U.S. Department of
Transportation requirements. The majority of the impacts would be temporary as revegetation
would occur through reseeding with and reestablishment of native vegetation after construction.
As a result, Atlantic does not anticipate significant direct and indirect impacts to water quality.
12

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
Some proposed access roads associated with the ACP would be built within floodplains.
Atlantic would implement design criteria based on the No -Rise Certification required for
construction projects within a designated Special Flood Hazard Area. Floodplain management
regulations (44 CFR Section 60.3 (d)(3)) prohibit any encroachment or modification. of
regulatory floodways unless hydrologic and hydraulic analysis can demonstrate that the action
would not increase flood levels. This analysis must be reviewed and approved by a professional
engineer. Review of the application and analysis would be conducted by either the county or
deferred to the State. The proposed pipeline for the ACP Project would be buried underground.
As a result, floodplains along the pipeline route would not be modified except temporarily during
construction. Following the completion of construction activities, contours would be restored to
preconstruction conditions to the extent practicable.
As noted in the sections above, there are various zoning restrictions, land use plans, and
regulatory programs that serve to control impacts to water resources in the three impacted
counties. These programs and instruments would apply to any direct or indirect development
that would result from the proposed ACP Project.
Cumulative Effects Statement
As with most linear projects, water resources such as wetlands and streams cannot be
completely avoided because of the extensive and reticulated nature of the waterbodies. Atlantic
has worked with the FERC, USACE, USFWS, and North Carolina Wildlife Resources
Commission staff to incorporate adjustments to the pipeline route or adopt alternative
construction measures to avoid waters of the U.S. with special ecological value where feasible.
In addition, Atlantic has incorporated dry crossing methods at each waterbody crossing in North
Carolina at the request of the NCDEQ, with an option of coordinating review of site-specific
conditions where dry or difficult construction conditions are present.
Loss of wetlands associated with the Project in the three Counties under review would be
limited to 0. 54 acre (0. 17 acre in Johnston County and 0. 3 7 acre in Cumberland County) which
are all attributable to improvements to permanent access roads. Where a permanent loss of
waters of the U.S. is unavoidable, Atlantic has proposed compensatory mitigation to offset
impacts within the associated watershed and to mitigate impacts to a no more than n-u'm*mal level.
In addition, as part of the Section 404 review process, Atlantic has proposed compensatory
mitigation for impacts that do not constitute a loss of waters of the U.S., but would result in a
permanent conversion of forested or scrub/shrub wetlands (e.g., forested wetlands converted to
emergent wetlands due to long term maintenance of the right-of-way).
The direct impacts associated with construction are planned to occur in an expedient and
efficient manner such that impacts on the waterbody and in the case of streams, the impacts to its
banks are temporary in nature. Based on the short duration and nature of the waterbody
crossings, Atlantic anticipates that cumulative impacts would result in minimal adverse impacts
on the waterbodies within the watershed basin and sub -basins crossed.
Atlantic has also identified other projects that are recent, underway, or planned within the
three counties crossed by the ACP (Attachment 1). Among these projects, 4 proposed projects
associated with Piedmont Natural Gas are connected to the ACP:
13

Cumulative Impacts Assessment for Johnston, Cumberland and Robeson Counties, North Carolina
0 Piedmont Natural Gas Facility Modifications at the Smithfield M&R
Station in Johnston County;
0 Piedmont Natural Gas Facility Modifications at the Fayetteville M&R
Station in Cumberland County;
0 Piedmont Natural Gas Facility Modifications at the Pembroke M&R
Station in Robeson County; and
0 Piedmont Natural Gas 26 miles of 20 -in Diameter Pipeline in Robeson
County.
The three Piedmont M&R station projects would involve modifications to piping
associated with connections to the ACP delivery and measurement of natural gas. The proposed
pipeline addition would provide a connection to an existing power plant. All of these projects
are subject to federal and state regulatory review and approval, which would address any impacts
to water resources.
It is expected that other projects, including housing and commercial developments,
Department of Transportation projects, and other energy projects would all be subject to state
and federal regulatory review and approval. Any project affecting wetlands or waterbodies
within the three counties would be required to obtain permits from the USACE and NCDEQ
Division of Water Resources and adhere to the permit requirements. Projects would also be
required to obtain and adhere to local floodplain permit requirements. Stormwater permitting in
Johnston, Cumberland, and Robeson Counties is mainly managed at the state level but
development projects also need to adhere to applicable local programs, including the Johnston
County Stormwater Management Program and the City of Fayetteville Stormwater Program. All
three counties are participants in the North Carolina Water Supply Watershed Protection
Program, which works to protect the States' drinking water supplies through inventorying and
establishing critical areas, protected'areas, and creating buffering requirements for protecting
surface waters. Based on the permitting programs discussed above, the cumulative impacts on
water resources from other projects would be adequately minimized.
In summary, due to the need to comply with existing watershed protection regulations
and programs, the implementation of specialized construction techniques, the relatively short
construction timeframe at any one location and carefully developed resource protection and
mitigation plans, minimal cumulative effects are anticipated when the impacts of the ACP are
considered along with the projects identified in Attachment 1. The-additionalrnatural-gas-being
brought -to Ahe - area- is -exp ected-to --result- in indirect developf hent:ifi4olff stUE,-C dffifi& ldfi�e, 7i di -d
Robesoir-County;zpartic-ular-lyAn areas -where -other utilities (i,e-.,-municipal-�-water-and-sewe7r-)-are
already -present-., As with the ACP, these other projects would also be required to adhere to state
and federal water quality regulations and permit requirements, limiting the potential for adverse
cumulative impacts on water quality. In addition, many of the projects are spatially separated
from the Project, reducing the likelihood of significant water quality impacts.
14

North Carolina Department of Environmental Quality —
Response to Information Request Dated October 26, 2017
Item 7
Attachment 1
PAST, PRESENT, AND REASONABLY FORESEEABLE FUTURE PROJECTS IN
JOHNSTON, CUMBERLAND, AND ROBESON COUNTIES, NORTH CAROLINA

1-1
ATTACHMENT I
Past, Present, and Reasonably Foreseeable Future
Projects in Johnston, Cumberland, and Robeson Counties, North
Carolina
Closest
Distance and
Potential
Direction
Weiland /
Common
From
Waterbody
ProjectName
Proponent
Counties
Description
Project
Status
Impacts?
Selma -Wake 230
Duke Energy
Johnston
Construction of line
12.6 miles
In Progress -
Yes
kV Line
tap
west of MP
Summer 2015
78.0
through Winter
2017
1-40 Widening —
North Carolina
Johnston
Road widening
20.4 miles
Anticipated in
Yes
Southeast Raleigh
Department of
northwest of
Fall 2018
to Clayton Project
Transportation
MP 86.5
(NCDOT)
U.S. 70 Corridor
NCDOT
Johnston
Raleigh to
Intersects
In development
Yes
Morehead City
near MP
major road
92.2
expansion from
U.S. Highway to
Interstate Highway
Piedmont Facility
Piedmont
Johnston
Piping
Intersects at
Construction in
No
Modifications
Natural Gas
modifications and
the
Winter of 2018
additions for
Smithfield
interconnect at the
M&R
Smithfield M&R
Station
Station
Lee-Sehna 115 kV
Duke Energy
Johnston
Line relocation
4.3 miles
Anticipated
Yes
Line
east of MP
Spring 2016
95.0
through
Summer 2017;
status unknown
Erwin -Selma 230
Duke Energy
Johnston
Line replacement
9.5 miles
Anticipated
No
kV Line
west of MP
Summer 2015
103.0
through
Winter 2016;
status unknown
Complete 540
North Carolina
Johnston
Completion of
Location
Anticipated
Yes
Department of
Highway 540 toll
unknown
Spring 2018 to
Transportation
road
Spring 2022
Solar Farm
Robert &
Johnston
New solar farm
Abutting
Completed 2015
Yes
Wellons Inc.
Smithfield
-2017
M&R
Station
R-3410 Road
NCDOT
Johnston
Widening NC 42
17 miles
Right-of-way
Yes
Widening
from NC 50 to US
northwest
acquisition is
70
not scheduled to
begin before
2023
1-4739
NCDOT
Johnston
Intersection
15 miles
In Development,
No
Intersection
Improvement at
west
Construction
Improvement
Cleveland Road and
date unknown
Cornwallis Road
1-5111
NCDOT
Johnston
Widening 1-40 from
18 miles
2019
Yes
1-440 to NC42
West
1-1

Switches 2016; status
unknown
Fayetteville Fort Duke Energy Cumberland Line relocation 16.4 miles Completed in Yes
Bragg 230 kV Line west of MP Winter 2015
— Clifdale Road 142.0
1-2
ATTACHMENT I
Past, Present, and Reasonably Foreseeable Future Projects in Johnston,
Cumberland, and Robeson Counties, North
Carolina
Closest
Distance and
Potential
Direction
Weiland /
Common
From
Waterbody
Project Name
Proponent
Counties
Description
Project
Status
Impacts?
U-3334
NCDOT
Johnston
Extending Booker
4 miles West
In Development,
Yes
Dairy Road
Construction
date unknown
Piedmont Facility
Piedmont
Cumberland
Piping
Within the
Construction in
No
Modifications
Natural Gas
modifications and
Fayetteville
Winter 2018
additions for the
M&R
interconnect at the
Station
Fayetteville M&R
Station
Fayetteville Outer
NCDOT
Cumberland
New road
6.3 miles
In progress —
Yes
Loop
construction and
west of MP
2016 through
existing road
133.0
2020
improvements
Fort Bragg
Duke Energy
Cumberland
Install reconductor
12.8 miles
In progress —
No
Woodruff —
line
west of MP
Fall 2014
Manchester
134.0
through
Spring 2017;
status unknown
Erwin -Fayetteville
Duke Energy
Cumberland
Relocate structures
7.7 miles
Completed in
Yes
115 kV —Change
for NCDOT project
northwest of
Spring 2015
and Relocate
MP 142.0
Fayetteville Fort
Duke Energy
Cumberland
Line relocation
15.0 miles
In progress —
Yes
Bragg 230 kV Line
west of MP
Winter 2014
— 1-295 Bypass
142.0
through Spring
2016; status
unknown
Fayetteville
Duke Energy
Cumberland
Install new tap line
2.7 miles
In progress —
No
Vander 115 kV
west of MP
Summer 2014
Line — Tap to
142.0
through Spring
Vander
2016; status
unknown
Fayetteville
Duke Energy
Cumberland
Install new tap line
6.8 miles
In progress —
No
Dupont 115 kV
west of MP
Winter 2014
Line — Cumberland
142.0
through Spring
Solar
2016; status
unknown
Fayetteville
Duke Energy
Cumberland
Install new tap line
6.8 miles
Completed in
No
Dupont 115 kV
west of MP
Summer 2015
Line — Grays Creek
142.0
Tap
Fayetteville
Duke Energy
Cumberland
Install line switches
6.8 miles
In progress —
No
Dupont 115 kV
west of MP
Winter 2014
Line — Line
142.0
through Winter
Switches 2016; status
unknown
Fayetteville Fort Duke Energy Cumberland Line relocation 16.4 miles Completed in Yes
Bragg 230 kV Line west of MP Winter 2015
— Clifdale Road 142.0
1-2

1-3
ATTACHMENT I
Past, Present, and Reasonably Foreseeable Future Projects in Johnston,
Cumberland, and Robeson Counties, North
Carolina
Closest
Distance and
Potential
Direction
Wetland /
Common
From
Waterbody
Project Name
Proponent
Counties
Description
Project
Status
Impacts?
Richmond — Fort
Duke Energy
Cumberland
Install transmission
21.8 miles
In progress —
Yes
Bragg 230 kV
loop
west of MP
Summer 2015
147.0
through Fall
2018
U.S. 401 Corridor
NCDOT
Cumberland
Road expansion
Unknown
Anticipated
Yes
Study
study
environmental
impact
statement date
2015; Not
funded
McClauren
McClauren
Cumberland
36 -lot residential
Crossed
Construction
Yes
Subdivision
Subdivision
development
schedule
unknown
St. Pauls Johnson
Johnson
Robeson
New asphalt plant
2.2 miles
In progress —
Yes
Brothers Facility
Brothers
southeast of
Phase I
Utility and
MP166.6
completed in
Paving
July 2014
Company
Weatherspoon
Duke Energy
Robeson
Install tap for solar
2.8 miles
In progress —
Yes
Plant — Fayetteville
facility
southeast of
Fall 2014
Solar Farm Tap
MP 167.0
through Spring
2016; status
unknown
Weatherspoon
Duke Energy
Robeson
Install tap for solar
2.3 miles
In progress —
Yes
Plant — Solar Tap
facility
southeast of
Fall 2014
MP 167.0
through
Summer 2016;
status unknown
Weatherspoon
Duke Energy
Robeson
Replace existing
10.6 miles
Anticipated —
No
Plant —LOF 115
structures
south of MP
Winter 2016
kV Structure
170.0
through Spring
Replace
2017; status
unknown
Weatherspoon-
Duke Energy
Robeson
Line relocation
11.6 miles
In progress —
Yes
Raeford 230 kV
northwest of
Summer 2015
Line Relocate
MP 170.0
through Fall
2018
Weatherspoon-
Duke Energy
Robeson
Line replacement
May
In progress —
Yes
Raeford 230 kV
intersect
Summer 2015
Line Replacement
near MP
through Spring
170.0
2017; status
unknown
1-95 Diverging
NCDOT
Robeson
Intersection
9.2 miles
In progress —
Yes
Diamond
improvement
south-
anticipated
Interchange in
project
southeast of
completion in
Lumberton
MP 178.0
Spring 2016;
status unknown
1-3

1-4
ATTACHMENT 1
Past, Present, and Reasonably Foreseeable Future Projects in Johnston, Cumberland, and
Robeson Counties, North
Carolina
Closest
Distance and
Potential
Direction
Wetland /
Common
From
Waterbody
Project Name
Proponent
Counties
Description
Project
Status
Impacts?
Weatherspoon —
Duke Energy
Robeson
Convert to remote
3.2 miles
Complete —
No
LOF 115 kV
control
south of MP
Spring 2014
180.0
through Fall
2015
Weatherspoon
Duke Energy
Robeson
Replace structures
21.4 miles
In progress —
No
Plant — Delco
southeast of
Winter 2015
MP 180.0
through
Summer 2016;
status unknown
Weatherspoon
Duke Energy
Robeson
Replace existing
14.2 miles
In progress —
No
Plant —Marion 115
structures
south of MP
Winter 2015
kV Structure
180.0
through Spring
Replace
2016; status
unknown
Piedmont Pipeline
Piedmont
Robeson
26 miles of 20 -inch
Intersects at
Anticipated
Yes
Natural Gas
natural gas pipeline
the
Winter of 2018
Pembroke
M&R
Station
Piedmont
Piedmont
Robeson
Piping
Within the
Construction in
No
Aboveground
Natural Gas
modifications and
Pembroke
Winter of 2018
Facilities
additions for the
M&R
interconnect at the
Station
Pembroke M&R
Station
1-4

North Carolina Department of Environmental Quality —
Response to Information Request Dated October 26, 2017
Item 7
Attachment 2
DEVELOPED AND UNDEVELOPED LAND IN JOHNSTON, CUMBERLAND, AND
ROBESON COUNTIES, NORTH CAROLINA