20140957 Ver 2_Public Comment Topics_20190813

Energy Policy
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.
Economic Impacts
0 This project will be significant for the economy and prosperity of North Carolina.
Environmental Justice
The ACP is an Environmental Justice issue.
• Duke and Dominion describe letters sent to state recognized tribes asking for information
rela'ted 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.
0 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 tojustify 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.
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.
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 Waterclog, Carolina
Madtom, and several other species of concern in North Carolina.
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. So ' me 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 ACID 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.
Spills/Prior track record
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 DEQto make a sound decision on whether or not to move
forward with the pipeline.
0 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.
0

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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.