20140957 Ver 2_Application with JAB Notes_20170501

Atlantic
Coast ATLANTIC COAST PIPELINE
Pipeline
Nationwide Permit 12
Pre -Construction Notification — Joint Permit Application
U.S. Army Corps of Engineers — Wilmington District
North Carolina Department of Environmental Quality, Division
of Water Resources
Supplemental Information
Prepared by
May 2017

Atlantic Coast Pipeline
Nationwide Permit No. 12 — Pre -Construction Notification — Joint Permit Application
U.S. Army Corps of Engineers — Wilmington District
TABLE OF CONTENTS
APPLICATION SUPPLEMENTAL INFORMATION DESIGN.............................................1
INTRODUCTION..........................................................................................................................1
5.
PROJECT OVERALL SUPPLEMENTAL INFORMATION ON PROPOSED
FACILITIES......................................................................................................................3
Buffer Impacts (for DWQ)........................................................................................33
A. APPLICANT INFORMATION.......................................................................................5
D. IMPACT JUSTIFICATION AND MITIGATION.......................................................36
1. Processing: This information is included on the PCN Form.....................................5
1.
2. Project Information.....................................................................................................5
3. Owner Information......................................................................................................5
4. Applicant Information.................................................................................................5
5. Agent/Consultant Information....................................................................................6
B. PROJECT INFORMATION AND PRIOR PROJECT HISTORY .............................6
1. Property Identification................................................................................................6
2. Surface Waters............................................................................................................6
3. Project Description......................................................................................................7
4. Jurisdictional Determinations...................................................................................27
5. Project History..........................................................................................................28
Energy Conservation to the ACP...........................................................................38
6. Future Project Plans
\
C. PROPOSED IMPACTS INVENTORY.........................................................................29
1. Impacts Summary.....................................................................................................32
2. Wetland Impacts.......................................................................................................32
3. Stream Impacts..........................................................................................................32
4.
Open Water Impacts.................................................................................................33
5.
Pond or Lake Construction.......................................................................................33
6.
Buffer Impacts (for DWQ)........................................................................................33
D. IMPACT JUSTIFICATION AND MITIGATION.......................................................36
1.
a.1 Avoidance and Minimization..............................................................................36
a.2
NEPA Alternatives from FERC Documentation......................................................38
No Action Alternative to the ACP.........................................................................38
Alternative Energy Sources to the ACP.................................................................38
Energy Conservation to the ACP...........................................................................38
System Alternatives to the ACP............................................................................39
Conceptual Route Alternatives..............................................................................40
b.I Construction Minimization -Wetlands ........................................................................74
b.2 Construction Minimization - Waterbodies...................................................................77
2.
Compensatory Mitigation for Impacts on Waters of the U.S. or Waters of the
State...........................................................................................................................
81
3.
Complete if Using a Mitigation bank........................................................................83
4.
Complete if Making a Payment to In -lieu Fee Program...........................................83
5.
Complete if Using a Permittee Responsible Mitigation Plan...................................84
6.
Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWR
....84
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
E. STORMWATER MANAGEMENT AND DIFFUSE FLOW PLAN
(REQUIRED BY DWR)..................................................................................................84
1. Diffuse Flow Plan.....................................................................................................85
2.
Stormwater Management Plan..................................................................................85
3.
Certified Local Government Stormwater Review....................................................85
4.
DWQ Stormwater Program Review.........................................................................85
5.
DWQ 401 Unit Stormwater Review.........................................................................85
F. SUPPLEMENTARY INFORMATION.........................................................................85
1.
Environmental Documentation (DWQ Requirement)..............................................85
2.
Violations (DWQ Requirement)...............................................................................86
3.
Cumulative Impacts..................................................................................................86
4.
Sewage Disposal (D)VR Requirement)....................................................................91
5.
Endangered Species and Designated Critical Habitat (USACE Requirement) ........91
6.
Essential Fish Habitat (USACE Requirement).........................................................95
7.
Historic or Prehistoric Cultural Resources (USACE Requirement) .........................95
8.
Tribal Coordination...................................................................................................96
9.
Flood Zone Designation (USACE Requirement).....................................................97
G. SECTION 408 AUTHORIZATION...............................................................................98
H. REFERENCES.................................................................................................................99
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
LIST OF JPA TABLES
Table 1
Proposed Aboveground Facilities in North Carolina for the Atlantic Coast
Johnston County Major Route Alternative for the Atlantic Coast Pipeline.....
46
Pipeline............................................................................................................12
Table 2
Permit Table for the Atlantic Coast Pipeline in North Carolina ......................
28
Table 3
HUC8 Wetland Impacts Table.........................................................................30
Table 4
HUC8 Waterbody Impacts in North Carolina.................................................31
Mush Island Route Variation for the Atlantic Coast Pipeline .........................58
Table 5
North Carolina Buffer Impacts........................................................................34
Table 6
Select Route Adjustments Incorporated into the Proposed Atlantic Coast
Red Oak Route Variation for the Atlantic Coast Pipeline...............................63
Pipeline in North Carolina...............................................................................72
Table 7
Route Avoidance Locations for Wetlands in North Carolina ..........................73
Swamp Road Route Variations for the Atlantic Coast Pipeline ......................70
Table 8
Federally Listed Species and Species Proposed for Federal Listing within
the U.S. Army Corps of Engineers — WilmingtonDistrict...............................93
Table 9
State -listed Endangered and Threatened Species within the U.S. Army
Corps of Engineers — Wilmington District......................................................94
LIST OF FERC ALTERNATIVE TABLES
Table 10.8.1-1
Table 10.8.1-12
Table 10.8.1-13
Table 10.8.1-14
Table 10.8.1-15
Table 10.9.1-11
Table 10.9.1-12
Table 10.9.1-13
Table 10.9.1-14
Table 10.9.1-15
Table 10.9.1-16
Table 10.9.1-17
Table 10.9.1-18
Table 10.9.1-19
Eastern and Western Route Alternatives for the Atlantic Coast Pipeline .........
41
Johnston County Major Route Alternative for the Atlantic Coast Pipeline.....
46
Progress Energy Carolinas Collocation Major Route Alternative for the
AtlanticCoast Pipeline....................................................................................49
Meherrin River Major Route Alternative for the Atlantic Coast Pipeline .......
51
Northampton Major Route Alternative for the Atlantic Coast Pipeline ..........53
Geenex Route Variation for the Atlantic Coast Pipeline.................................58
Mush Island Route Variation for the Atlantic Coast Pipeline .........................58
Halifax Route Variation for the Atlantic Coast Pipeline.................................60
Breeches Swamp Route Variation for the Atlantic Coast Pipeline..................63
Red Oak Route Variation for the Atlantic Coast Pipeline...............................63
City of Nashville Route Variation for the Atlantic Coast Pipeline..................65
Little River Route Variation for the Atlantic Coast Pipeline ...........................67
Swamp Road Route Variations for the Atlantic Coast Pipeline ......................70
Cape Fear Route Variations for the Atlantic Coast Pipeline ...........................70
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
1 LIST OF APPENDICES
()
Appendix A
Figures
Appendix B
Wetland and Waterbody Survey Report
Appendix C
Wetland and Waterbody Crossing Impact Table
Appendix D
Supplemental FERC Upland Construction Information
Appendix E
Right -Of -Way Cross Section Drawings and Select Construction Typical
Drawings
Appendix F
Section 10 Waters Site Specific Plans
Appendix G
Spill Prevention, Control, and Countermeasures Plan
Appendix H
Horizontal Directional Drill Fluid Monitoring, Operations, and
Contingency Plan
Appendix I
Agency Correspondence (NCDEQ Riparian Buffer/COE Section 408)
Appendix J
Restoration and Rehabilitation Plan
Appendix K
General, Regional, and Special Permit Conditions Tables
Appendix L
Cumulative Impacts Analysis - FERC Resource Report 1
Appendix M
Plan for Unanticipated Discovery of Historic Properties or Human
Remains during Construction
Appendix N
Correspondence with Federally Recognized Indian Tribes
Appendix O
Mainline Pipeline Hydrostatic Test Summary
Appendix P
HDD Design Report
Appendix Q
North Carolina Division of Mitigation Services Letter
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
NRCS Natural Resources Conservation Service
NWI National Wetland Inventory
NWP Nationwide Permit
PASPGP-5 Pennsylvania State Programmatic General Permit 5 -
t
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ACRONYMS AND
ABBREVIATIONS
ACP
Atlantic Coast Pipeline
APE
Area of Potential Effects
Atlantic
Atlantic Coast Pipeline, LLC
ATWS
additional temporary workspace
BA
Biological Assessment
bcf/d
billion cubic feet per day
CWA
Clean Water Act
DE
District Engineer
DMS
Division of Mitigation Services
DOE
U.S. Department of Energy
Dominion
Dominion Resources, Inc.
DTI
Dominion Transmission, Inc.
EFH
Essential Fish Habitat
EIA
U.S. Energy Information Administration
EIS
environmental impact statement
EPA
U.S. Environmental Protection Agency
FERC
Federal Energy Regulatory Commission
FR
Federal Register
FWS
U.S. Fish and Wildlife Service',
GDS-NWR
Great Dismal Swamp National Wildlife Refuge
GIS
geographic information system
HDD Plan
Horizontal Directional Drill Fluid Monitoring, Operations, and Contingency
Plan
HDD
Horizontal Directional Drill
HUC
Hydrologic Unit Code
IPaC System
Information Planning and Conservation System
M&R
metering and regulating
MBTA
Migratory Bird Treaty Act
MP
milepost
NCDEQ
North Carolina Division of Environmental Quality, Division of Water
Resources
NCWRC
North Carolina Wildlife Resources Commission
NEPA
National Environmental Policy Act
NOAA Fisheries
National Oceanic and Atmospheric Administration, National Marine Fisheries
Service
NRCS Natural Resources Conservation Service
NWI National Wetland Inventory
NWP Nationwide Permit
PASPGP-5 Pennsylvania State Programmatic General Permit 5 -
t
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
t PCN
Pre -Construction Notification
PEM
palustrine emergent
PFO
palustrine forested
Piedmont
Piedmont Natural Gas Co.
Plan
Upland Erosion Control, Revegetation, and Maintenance Plan
PRM
permittee responsible mitigation
Procedures
Wetland & Waterbody Construction & Mitigation Procedures
Project
Atlantic Coast Pipeline
PSS
palustrine scrub -shrub
SHP
Supply Header Project
SPCC Plan
Spill Prevention, Control, and Countermeasures Plan
TNC
The Nature Conservancy
Transco
Transcontinental Gas Pipe Line Company, LLC
USACE
United States Army Corps of Engineers
USGS
United States Geological Survey
WQC
Water Quality Certification
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
APPLICATION SUPPLEMENTAL INFORMATION DESIGN
Section numbering has been incorporated into this supplemental information documents
to match the sections of the Pre -Construction Notification (PCN) form (Version 1.4 January
2009) for a joint permit application between the U.S. Army Corps of Engineers (USACE) and
the North Carolina Department of Environmental Quality, Division Water Resources (NCDEQ)
for the proposed Atlantic Coast Pipeline (ACP or Project). Atlantic Coast Pipeline, LLC
(Atlantic) is seeking Nationwide Permit (NWP) 12 verification under Section 404 of the Clean
Water Act and Section 10 of the Rivers and Harbors Act. The USACE Wilmington District is
responsible for permitting the North Carolina portion of the ACP. From the NCDEQ, Atlantic is
seeking approval for a project -specific 401 Water Quality Certification (WQC) should any of the
single and complete projects not be covered by the State's General 401 WQC issued for the
USACE NWP 12 for North Carolina, and Riparian Buffer Authorization. The following sections
provide the necessary information to demonstrate that the ACP will comply with the
requirements for NWP 12, 401 WQC, the Riparian Buffer. Authorizations, and applicable general
and regional conditions. The ACP is a Federal Energy Regulatory Commission (FERC) 7(c)
regulated project and the USACE has agreed to participate in FERC's National Environmental
Policy Act (NEPA) process as a cooperating agency.
INTRODUCTION
Atlantic is a company fo ed b four ma'or U.S. energy companies= ominion
isou
rces, nc. Dominion • Duke Energy Corporation, i dmont Natura as Co., nc.
mon ; and outhern Gas Com any, nc. a company was ea a to eve op, own, and
operate the proposed ACP, an approximately 604.6 -mile -long interstate natural gas transmission
pipeline system designed to meet growing energy needs in Virginia and North Carolina
(Appendix A, Figure A-1). The ACP will be capable of delivering up to 1.5 million dekatherms
per day of natural gas that will be used to generate electricity, heat homes, and run local
businesses. By providing access to additional low-cost natural gas supplies in Virginia and
North Carolina, the ACP will facilitate cleaner air, increase the reliability and security of natural
gas supplies, and provide a significant economic boost in West Virginia, Virginia, and North
Carolina. More information is provided at the company's website at www.dom.com/acPineline.
Atlantic has contracted with Dominion Transmission, Inc. (DTI), a subsidiary of Dominion, to
permit, build, and operate the ACP on behalf of Atlantic.
DTI also proposes to construct and operate approximately 37.5 miles of pipeline loop and
modify existing compression facilities in Pennsylvania and West Virginia. This project is
referred to as the Supply Header Project (SHP) and will enable DTI to provide firm
transportation service of up to 1.5 million dekatherms per day to various customers, including
Atlantic. In addition to pursuing the appropriate USACE permits in West Virginia, DTI has
applied for authorization/verification under the Pennsylvania State Programmatic General
Permit 5 (PASPGP-5) in conjunction with the Pennsylvania Department of Environmental
Protection Chapter 105 General Permit for the SHP proposed impacts on waters of the U.S and
for proposed structures or work in navigable waters of the U.S. within Pennsylvania. The
PASPGP-5 is issued pursuant to Section 404(e) of the Clean Water Act (CWA) and is based
upon and consistent with the requirements of the Clean Water Act 404(b)(1) guidelines. The
USACE administers the PASPGP-5 jointly with the Pennsylvania Department of Environmental
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Protection to authorize the placement or discharge of dredged and/or fill material into waters of
the U.S under the provisions of Section 404 of the CWA and for structures or work in or
affecting navigable waters of the U.S. under the provisions of Section 10 of the Rivers and
Harbors Act of 1899.
Atlantic has prepared the following supplemental information document to accompany
the PCN form for the ACP proposed in North Carolina used by the Wilmington District for
authorization under NWP 12 and NCDEQ for permitting purposes involving water, wetlands,
and riparian buffer permitting.
Request for USACE NWP 12 for Single and Complete Projects of Waters of the U.S.
Atlantic is providing the following information as background information regarding the
ACP and the associated SHP to assist the USACE in understanding the overall undertaking being
permitted and authorized through the FERC. On September 18, 2015, Atlantic, for ACP, and
DTI, for the SHP, filed respective applications with FERC to construct, operate, and maintain
natural gas pipeline facilities in Pennsylvania, West Virginia, Virginia, and North
Carolina. FERC, through the NEPA process, is assessing the potential environmental impacts
that could result from constructing and operating the ACP and SHP; two separate, but related,
interstate natural gas transmission pipeline projects. On September 15, 2015, Atlantic submitted
PCN applications for NWP 12 for ACP to the USACE Wilmington, Norfolk, Pittsburgh, and
Huntington Districts for verification of the ACP multiple single and complete projects
(crossings) of waters of the U.S. including wetlands. On September 15, 2015, DTI submitted an
( application for authorization/verification for the SHP in Pennsylvania under the PASPGP-5 and
-- ' for the SHP in West Virginia within Pittsburgh District Regulatory boundaries under NWP 12
for proposed pipeline and facilities crossings of waters of the U.S. including wetlands. This
NWP 12 PCN application and supplement is only for the ACP activity (pipeline and facilities)
proposed crossings of waters of the U.S. including wetlands located in Wilmington District
within North Carolina.
In summary, for both the ACP and SHP, applications for all proposed impacts on waters
of the U.S. including wetlands have been submitted for authorization under General Permits
(i.e., NWP 12 or PASPGP-5), with none of the proposed impacts on waters of the U.S. including
wetlands requiring an Individual Permit. Atlantic understands the USACE is a cooperating
agency on the NEPA evaluation being conducted by FERC, including FERC's preparation of an
environmental impact statement (EIS), but provides the following information to the USACE to
provide context and understanding regarding the location of the multiple single and complete
crossings proposed for verification under NWP 12. The background information provided
within the application outlining the FERC process is intended to assist the USACE in
determining that verification of the single and complete projects of this linear project under
NWP 12 is appropriate and fully consistent with USACE regulations on scope of analysis and
the NWP Program. In particular, the FERC background information is intended to provide the
necessary basis for the USACE to determine that the avoidance of impacts on waters of the
United States, mitigation for unavoidable conversion of forested wetlands to scrub -shrub and/or
emergent wetlands results in no more than minimal impact, after considering compensatory
mitigation, at each single and complete project. Furthermore, the information provided below
demonstrates that the cumulative impacts on waters of the United States, after considering
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
compensatory mitigation, is minimal based on evaluating impacts within 8 -digit Hydrologic Unit
Code (HUC 8) watersheds.
Contextual information is provided in this supplement on the ACP to provide a basis for
the USACE minimal impact determinations, understanding that the USACE's scope of analysis
under NWP 12 is limited to the single and complete projects and the uplands in the immediate
vicinity of the single and complete pro ects that impact the location of such crossings of waters
of the United States. Approximately 1241 ercen of the overall ACP pipeline length of
604.6 miles crossing West Virginia, Virginia, and North Carolina is locate4 within waters of the
nited States)
Under the relevant USACE precedent (including without limitation, USACE regulations,
NEPA implementation procedures, NWP Program, and Memorandum of Understanding with
FERC), the "build/no build" decision and the overall pipeline alignment is determined throw
the FERC NEPA rocess. The USACE serves as cooperating agency on the FERC EIS through
w tc t e USACE can coordinate with FERC to determine that the overall pipeline alignment
properly considers avoidance of impacts to waters of the United States. Moreover, the FERC
licensing process has many policies and procedures to confirm that impacts on waters of the
United States are avoided and minimized to the extent practicable. Section D provides a
summary of the extensive avoidance and minimization that has occurred for the proposed
project.
As with most linear projects, waters of the United States cannot be completely avoided
because of the extensive and reticulated nature of the aquatic resource. The USACE evaluation
under NWP 12 ensures that the unavoidable impacts on waters of the United States at each single
and complete project are mitigated in order to ensure no more than minimal individual and
cumulative impacts on waters of the United States after considering the required compensatory
mitigation for unavoidable impacts. Atlantic has worked with the USACE field staff to provide
minor adjustments of the pipeline route to avoid waters of the United States with special
ecological value, r w ere ease e.
i
Atlantic has applied for a Preliminary Jurisdictional Determination from the USACE.
Appendix B includes a place holder for the Wetland and Waterbody Survey Report, which is
available upon request.
PROJECT OVERALL SUPPLEMENTAL INFORMATION ON PROPOSED
FACILITIES
Atlantic is seeking authorization from FERC to construct, own, operate, and maintain the
following proposed facilities for the ACP and from the USACE for impacts on waters of the U.S.
at each single and complete project:
Mainline Pipeline Facilities:
• AP -1: approximately 333.1 miles of underground 42 -inch outside diameter
natural gas transmission pipeline in Harrison, Lewis, Upshur, Randolph, and
Pocahontas Counties, West Virginia; Highland, Bath, Augusta, Nelson,
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Buckingham, Cumberland, Prince Edward, Nottoway, Dinwiddie, Brunswick, and
Greensville Counties, Virginia; and Northampton County, North Carolina.
• AP -2: approximately 186.0 miles of underground 36 -inch outside diameter
�v natural gas transmission pipeline in Northampton, Halifax, Nash, Wilson,
Johnston, Sampson, Cumberland, and Robeson Counties, North Carolina.
Lateral Pipeline Facilities:
• AP -3: approximately 83.2 miles of underground 20 -inch outside diameter natural
gas lateral pipeline in Northampton County, North Carolina; and Greensville and
Southampton Counties and the Cities of Suffolk and Chesapeake, Virginia.
AP -4: approximately 0.4 mile of underground 16 -inch outside diameter natural
gas lateral pipeline in Brunswick County, Virginia.
AP -5: approximately 1.0 mile of underground 16 -inch outside diameter natural
gas lateral pipeline in Greensville County, Virginia.
Compressor Station Facilities:
• Compressor Station 1 (Marts Compressor Station): a new, natural gas-fired
compressor station approximately at milepost 1 (MP) 7.6 of the AP -1 mainline in
Lewis County, West Virginia.
• Compressor Station 2 (Buckingham Compressor Station): a new, natural gas-fired
compressor station approximately at MP 191.5 of the AP -1 mainline in
^ , Buckingham County, Virginia.
• Compressor Station 3 (Northampton Compressor Station): a new natural gas-fired
compressor station approximately at MP 300.1 of the AP -1 mainline and MP 0.0
of the AP -2 mainline in Northampton County, North Carolina.
Other Aboveground Facilities:
Nine new metering and regulating (M&R) stations at receipt and/or delivery
points along the new pipelines (including one at Compressor Station 1 and one at
Compressor Station 2).
Thirty-eight valve sites at select points along the new pipelines, at intervals
specified by U.S. Department of Transportation regulations at Title 49 Code of
Federal Regulations Part 192.
The mileposts used in the initial FERC Application, which was filed on September 18, 2015 (FERC Accession Number 20150918-5212),
were based on three-dimensional changes in topography along the proposed pipeline routes In areas where a pipeline route has changed
due to the adoption of an alternative, the mileposts in the affected area have been scaled to account for the resulting difference in the length
of the route For these reasons, the straight-line distance between consecutive mileposts as indicated or depicted in tables and figures in this
updated Resource Report maybe greater than or less than 5,280 feet The mileposts should be considered as reference points only
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District ll
• Eight sets of pig launchers and/or receiver sites at 11 points along the new
pipelines (including launcher/receiver sites at Compressor Stations 2 and 3).
A. APPLICANT INFORMATION
1. Processing: This information is included on the PCN Form.
2. Project Information
2a. Name of Project: Atlantic Coast Pipeline (ACP, Project)
2b.Counties: Northampton, Halifax, Nash, Wilson, Johnston, Sampson, Cumberland,
Robeson, see Appendix A — Figure A-2
2c. Nearest municipality/town: Not Applicable — linear project, see Appendix A —
Figures A-1, A-2, and A-3.
2d. Subdivision name: Not Applicable
2e. NCDOT only, T.I.P. or state project number: Not Applicable
3. Owner Information
3a. Name(s) on Recorded Deed: Atlantic Coast Pipeline, LLC
3b. Deed Book and Page No. N/A
3c. Responsible Party (for LLC if applicable): Leslie Hartz
3d. Street Address: 707 E Main Street, 19th Floor
3e. City, State, Zip: Richmond, VA 23219
3f. Telephone no.: [phone]
3g. Fax no.: N/A
3h. Email address: [e-mail]
4. Applicant Information
4a. Applicant is: Atlantic Coast Pipeline, LLC
4b. Name: Leslie Hartz
4c. Business name (if applicable):
4d. Street address: 707 E Main Street, 19th Floor
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
1* 1 4e. City, State, Zip: Richmond, VA 23219
4f. Telephone no.: [phone]
4g. Fax no.: N/A
4h. Email address:[e-mail]
5. Agent/Consultant Information
5a. Name: Richard Gangle
5b. Business name (if applicable): Dominion Resources Services, Inc.
5c. Street address: 5000 Dominion Blvd
5d. City, State, Zip: Glen Allen, Virginia 23060
5e. Telephone no.: [phone]
5f. Fax no.: N/A
5g. Email address: [e-mail]
B. PROJECT INFORMATION AND PRIOR PROJECT HISTORY
1. Property Identification
Ia. Property Identification: N/A
lb. Site Coordinates: Site coordinates are included on the Waterbody and Wetland
Tables, see Appendix C.
lc. Property Size: 3,023 acres, consists of the Project work area.
2. Surface Waters
2a. Nearest Waterbody: Waterbody and Wetland location description and classification
can be found in Appendix C for Pipeline and Aboveground Facilities.
2b. Water Quality Classification of nearest receiving water: Waterbody and Wetland
location description and classification can be found in Appendix C for Pipeline and
Aboveground Facilities.
2c. River basin: Eight -digit HUC (HUC 8) watersheds have been provided in
Appendix A - Figure A-2 and the Wetland and Waterbody Impact tables included in
Appendix C for Pipeline Facilities. These codes provide the information necessary to
determine the river basin within which each wetland or waterbody crossing occurs.
r
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
3. Project Description
3a. Existing Site Conditions and General Land Use: Land use types within the
proposed AP -2 and AP -3 Project areas were classified according to current land
characteristics. Classifications were based on review of the U.S. Geological Survey
(USGS) National Gap Analysis Program Land Cover Data and recent digital aerial
photography (2013) augmented by field reconnaissance (2014) along the proposed
pipeline routes. Atlantic identified nine primary land use types in the ACP Project area.
These consist of the following:
• Agriculture — Cultivated Crop: actively cultivated cropland (e.g., wheat, grass
seed, alfalfa, hay, and vegetables);
• Agriculture — Pasture: uncultivated pasture lands and hay meadows;
• Agriculture — Tree Plantation/Harvested Forest: managed tree plantations and
harvested forests with shrub and grass/forb regeneration;
• Upland Forest/Woodland: conifer dominated forests and woodlands, deciduous
dominated forests and woodlands, deciduous dominated savannas and glades,
floodplain/riparian forests, and mixed deciduous/coniferous forests and
woodlands;
• Developed — Open to Low Intensity: herbaceous areas (e.g., golf courses, road
sides, parks, and air fields) and areas with a mixture of constructed materials and 4
vegetation where impervious surfaces account for 20 to 49 percent of total cover
(e.g., single-family housing units);
• Developed — Medium to High Intensity: areas with impervious surfaces
accounting for 50 to 100 percent of total cover, including single-family housing
units, apartment complexes, row houses, and commercial/industrial areas;
• Open Land: disturbed lands, grasslands, shrub lands, beach and shore lands, and
cliff, canyon, and talus lands;
• Wetlands: wetland areas identified by field surveys or in National Wetland
Inventory (NWI) data, including palustrine and estuarine wetlands; and
• Open Water: areas of open water, generally with less than 25 percent cover of
vegetation or soil, including inland waters of streams, river, ponds, and lakes, and
coastal and near -shore estuarine and/or marine waters.
3b. Existing wetland acreage: 1,775 Acres within the Project Study Area.
3c. Existing linear feet of stream: 40,744 Linear Feet within the Project Study Area.
3d. Project Purpose and Need and Background Regarding FERC NEPA Process:
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
USACE NWP 12 Purpose and Need
The purpose and need for purposes of NWP 12 verification of each single and complete
project is to cross wetlands, streams and other waters while avoiding impacts on those wetlands,
streams and other waters to the maximum extent practicable and offsetting unavoidable impacts
on the aquatic environment with compensatory mitigation. Additional details on the project
purpose and need are provided below.
FERC NEPA PROJECT PURPOSE STATEMENT
The following description of the purpose and need for the FERC NEPA process is
provided as background information. Information included has been compiled largely from
documents submitted to FERC, but is provided for the convenience of the USACE review. In
Section D of the application materials, below, within the Impact Justification and Mitigation,
Avoidance and Minimization, and FERC Alternatives sections, the numbering of many of the
referenced tables and figures has not been changed from their number in the FERC
documentation, to maintain consistency across documents (e.g., Table 3.10.5-1, Figure 10.8.1-1,
etc.).
The ACP is a proposed interstate natural gas transmission pipeline that will serve the
growing energy needs of multiple public utilities and local distribution companies in Virginia
and North Carolina. The natural gas transported by the ACP will be used as a fuel to generate
electricity for industrial, commercial, and residential uses. The natural gas will also be used
directly for residential, commercial, and industrial uses. By providing access to additional low-
cost natural gas supplies, the ACP will increase the reliability and security of natural gas supplies
in Virginia and North Carolina.
In recent years, demand for natural gas in Virginia and North Carolina has grown
significantly for natural gas for all uses grew by 37 and 0 percent respectively, in
Virginia and orth Carolina etween 2008 and 2012. errand for gas- Ire electric power
generation grew by 123 percent in Virginia and percen In orth Caro ina rom o 13
(U.S. Energy Information Administration [EIA], IA, 2015a, 20 c, 5d, and 2015e).2
Demand for natural gas in Virginia and North Carolina is expected to increase in coming
decades due to a combination of population growth and displacement of coal-fired electric power
generation. The U.S. Census Bureau predicts 2.7 million new residents in Virginia and
4.2 million new residents in North Carolina between 2000 and 2030 (U.S. Census Bureau,
U.S. Energy Information Administration.2015a. Annual Energy Outlook 2015.Available online at http://www.eia.gov/forecasts/aeo/.
Accessed June 2015.
U.S. Energy Information Administration.2015b. Market Trends; Electricity Demand. Available online at htto://www.eia.gov/forecasts/aeo/
MTelectric.cfm. Accessed June 2015.
U.S_Energy Information Administration.2015c. Market Trends; Natural Gas. Available online at htto://www.eia.gov/forecasts/aeo/mt nat
uralgas.cfm. Accessed June 2015.
U.S. Energy Information Administration.2015d. Natural Gas Summary for Virginia. Available online at httl2://www.eia.Rov/dnav/ne/ne
sum_Isum dcu_SVA a.htm. Accessed June 2015.
U.S. Energy Information Administration.2015e. Natural Gas Summary for North Carolina. Available online at htw://www.eia.gov/dnav/n
R/ng sum Isum dcu SNC a.htm. Accessed June 2015.
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
A
2014). At the same time, use of natural gas for power generation is expected to increase
significantly. By 2035, natural gas is expected to surpass coal as the most common fuel for
electric power generation due to coal-fired plant retirements and low natural gas prices. The EIA
(2015a) expects renewable generation to grow 1.9 percent per year, meeting a part of the demand
for power, but more than 70 percent of new generating capacity will be fueled by natural gas.
A study, prepared by ICF International (2014) for Atlantic, projects that electric power
generation in Virginia and North Carolina will increasingly rely on natural gas over the next two
decades. Between 2019 and 2038, the study predicts that approximately 9,900 megawatts of �lI
electric generating capacity from coal and nuclear fuels will be retired, while 20,200 megawatts ((y
of new generating capacity from natural gas will be built in Virginia and North Carolina. As a
result, demand for natural gas for power generation in Virginia and North Carolina is expected to
grow 6.3 percent annually between 2014 and 2035, increasing from 1 billion cubic feet per day
(bcf/d) to 3.7 bcf/d.
To meet the growing demand for natural gas, the EIA (2015a) projects total United States
natural gas production to increase by 56 percent from 2012 to 2040. At the same time, natural
gas transmission patterns across the United States are expected to change based on the growing
production from shale basins in the mid-Atlantic region. Historically, gas produced from the
Gulf of Mexico, Canada, and the Rocky Mountains was delivered to markets in the eastern
United States. Large increases in production from United States supply basins have created
abundant, competitively priced supplies to meet the demands of the region.
A study by the U.S. Department of Energy (DOE, 2015)3, dated February 2015,
examined the impact of increased demand for natural gas from the electric power sector on
natural gas pipeline infrastructure in the United States over a 15 year period from 2015 to
2030.4 The DOE (2015) study found that a projected 38 to 42 bcf/d of new and expanded
pipeline capacity will be necessary to meet demand over the 15 year study period. The DOE
study further found that flow reversal is projected to occur "to serve markets in the Southeast."
Furthermore, existing pipelines that historically transported natural gas from the Gulf Coast
region to points further north are expected to change the direction of flow in order to "serve the
Virginia and Carolina markets" (DOE, 2015). However, there are no existing long haul
interstate pipelines with available takeaway capacity from the Appalachian region directly
serving Virginia and North Carolina (see Figure 1 in the DOE [2015] study).
Moreover, market participants in the region have determined that their needs cannot be
adequately met by existing pipeline systems. In April 2014, Duke Energy Corporation and
Piedmont issued requests for proposals for incremental pipeline transportation service due to
their existing and future natural gas generation requirements, core load growth, and system
3 U.S. Department of Energy. 2015. Natural Gas Infrastructure Implications of Increased Demand from the Electric Power Section.
Available on line at: ftj/energy.gov/sites/p files/2015/02/fl9ADOE%2ORep2rt%2ONatural%2OGas%201nfrastructure%20V 02-02.odf.
Accessed February 2015.
In comments filed with the FERC, several individuals said that demand for natural gas in Virginia and North Carolina could be met by
existing pipeline systems citing this study by the DOE. The study did not conclude, as some suggested, that no additional pipeline capacity
is needed to meet the increased demand for natural gas. Instead, the study found that the expected increase in pipeline capacity over the
study period will be modest relative to previous expansions in pipeline capacity.
Atlantic Coast Pipeline 9

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
(� U.S. Army Corps of Engineers — Wilmington District
\
reliability and supply diversity goals. In June 2014 Virginia Power Services Ener Co Inc.
_-� tY pp Y tY g � g Energy �•,
issued a request for proposals for firm transportation service to serve Virginia. Following the
request for proposals processes, these companies contracted for transportation service on the
ACP, as did other companies in the region.
To meet the natural gas demand of its customers, the ACP will connect the growing
demand areas in Virginia and North Carolina with growing supplies. Interstate natural gas
pipelines act as common carriers to transport natural gas; they are not part of natural gas
exploration or production activities. The ACP will connect growing demand areas in Virginia
and North Carolina with growing supply areas in the Appalachian region and provide access to
the Dominion South Point supply hub, consisting of abundant supplies on the DTI system that
are sourced from a wide variety of upstream pipeline interconnects and diverse production areas.
More specifically, the ACP will provide up to 1.5 bcf/d of firm natural gas transportation service
into West Virginia, Virginia, and North Carolina.
The ACP will receive gas on behalf of its customers at two new interconnections: one
between the ACP and the SHP in Harrison County, West Virginia, to be known as the Marts
Junction Interconnection; and one between the ACP and existing Transcontinental Gas Pipe Line
Company, LLC (Transco) facilities in Buckingham County, Virginia, to be known as the
Buckingham Interconnects. The natural gas will be delivered to various new customer
interconnects in West Virginia, Virginia, and North Carolina. Additionally, the ACP will lease
capacity on a pipeline owned and operated by Piedmont to enable certain deliveries in North
Carolina.
- Of the new firm transportation capacity of up to 1.5 bcf/d proposed by the ACP,
1,360,000 dekatherms per day (approximately 1.33 bcf/d) is currently subscribed pursuant to
precedent agreements with six customers. These customers are major utilities and local
distribution companies in the region. The precedent agreements demonstrate the need for the
Projects, the demand for new gas supplies indicated in the studies noted above, and the desire for
access to a new supply region. The remaining unsubscribed capacity. would be awarded and
contracted for in accordance with the FERC policies applicable to open -access interstate
pipelines and the provisions of applicable FERC gas tariffs. The natural gas supplied to each
delivery point would be provided to local distribution companies, power generators, and other
interstate pipeline companies.
3e. Project Details (Project Description and Project Facilities)
Overall Project Description for ACP
The project description of the ACP for purposes of the USACE NWP 12 authorization is
to construct single and complete projects on waters of the United States that result in no more
than minimal individual and cumulative impacts on the aquatic environment and offsetting
5 The ACP and SBP are separate projects with separate applicants, but are being reviewed as connected actions by FERC through
development of a single Environmental Impact Statement
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
unavoidable impacts on the aquatic environment with compensatory mitigation. The overall Y
ACP project construction and operation to be authorized by FERC is a proposed 604.6 -mile -
long, interstate natural gas transmission pipeline that will serve the growing energy needs of
multiple public utilities and local distribution companies in the region. The natural gas
transported by the ACP will be used as a fuel to generate electricity for industrial, commercial,
and residential uses. The natural gas will also be used directly for residential, commercial, and
industrial uses. By providing access to additional low-cost natural gas supplies, the ACP will
increase the reliability and security of natural gas supplies in Virginia and North Carolina.
Project Details for North Carolina
A short segment of the AP -1 mainline, approximately 200 feet in length, will occur in
North Carolina. This short segment of AP -1 will not cross wetlands or waterbodies, and will not
be discussed further in the application. The AP -2 mainline, which will consist of 36 -inch outside
diameter pipeline, will originate at the southern terminus of AP -1 at Compressor Station 3 in
Northampton County, North Carolina. From this point, the pipeline will extend to the southwest
crossing through Northampton, Halifax, Nash, Wilson, and Johnston Counties, passing west of
Rocky Mount in Nash County, west of Wilson in Wilson County, and east of Selma in Johnston
County. At the Johnston/Sampson County line, the pipeline will turn west/southwest and
continue through Sampson County and southeast of Fayetteville in Cumberland County, before
terminating at a new interconnect with an existing Piedmont distribution pipeline in Robeson
County, North Carolina. Approximately 186.0 miles o t e -2 mainline occurs within the
USACE - Wilmington District and is a part of the proposed work under NWP 12 PCN.
The AP -3 lateral, which will consist of 20 -inch outside diameter pipeline, will originate
at Compressor Station 3 in Northampton County, North Carolina and extend to the east/northeast
to the Virginia State line. AP -3 will then continue northeast through Greensville and
Southampton Counties and the Cities of Suffolk and Chesapeake, Virginia. Approximately
12.2 miles of the AP -3 lateral occurs within the USACE— Wilmington District, all within
Northampton County, North Carolina and is a part of the proposed work under NWP 12 PCN.
In addition one compressor station, three M&R stations, 11 valve sites, and four sets of
pig launchers and receivers are planned within the Wilmington District. The location of each
aboveground facility in North Carolina, by MP and county is listed in Table 1.
Compressor Stations
Compressor Station 3 will be located approximately at MP 300.1 in Northampton
County, North Carolina at the intersection of the AP -1 and AP -2 mainlines and the AP -3 lateral.
The station will take natural gas from the AP -1 mainline and discharge into both the AP -2
mainline and the AP -3 lateral.
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 1
Proposed Aboveground Facilities in North Carolina for the Atlantic Coast Pipeline
Aboveground Facility
County/City and State
Approximate Milepost
Compressor Stations
AP -1 Mainline
Compressor Station 3
Northampton County, NC
300 1
Metering and Regulating Stations
AP -2 Mainline
Smithfield M&R Station
Johnston County, NC
927
Fayetteville M&R Station
Cumberland County, NC
132 9 -fir— —
Pembroke M&R Station
Robeson County, NC
182 9 ,<�
Valves
AP -2 Mainline
Valve Site 23
Northampton County, NC
94
Valve Site 24
Halifax County, NC
149
Valve Site 25
Nash County, NC
347
Valve Site 26
Nash County, NC
495
Valve Site 27
Nash County, NC
643
Valve Site 28
Johnston County, NC
787
Valve Site 29
Johnston County, NC
1081
Valve Site 30
Cumberland County, NC
1230
Valve Site 31
Cumberland County, NC
1366
Valve Site 32
Cumberland County, NC
1537
Valve Site 33
Robeson County, NC
1686
Pig Launcher/Receiver Sites
AP -1 Mainline
Site 4 (launcher/receiver)
Northampton County, NC
300 1
AP -2 Mainline
Site 5 (launcher/receiver)
Johnston County, NC
927
Site 6 (receiver)
Robeson County, NC
1829
AP -3 Lateral
Site 4 (launcher)
Northampton County, NC
00
Metering and Regulating Stations
Atlantic will construct three M&R stations in North Carolina at the locations identified in
Table 1. The M&R stations will be built at receipt or delivery points along the pipelines. In
general, each M&R station will contain two dekatherm buildings (used to house equipment such
as gas chromatographs, communications equipment, etc.), a regulation building, and possibly a
meter building. Equipment at each station will include gas filter/separators, gas meters, and
regulators, and may include gas heaters and/or odorization equipment. Each station will be
surrounded by a chain-link security fence.
Valve Sites
Eleven valves will be installed along the proposed pipelines at the locations identified in
Table 1. The valves will be installed below grade with aboveground valve operators, risers,
blowdown valves, and crossover piping connected on each side of the valve. A chain-link
Atlantic Coast Pipeline
12

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
t
security fence will be installed around the periphery of each valve site. The valves will allow
DTI, as operator, to segment the pipelines for safety, operations, and maintenance purposes.
Pig Launchers/Receivers
Four sets of pig launchers and/or receivers will be installed at the locations identified in
Table 1. One set of the pig launcher/receiver assemblies and one launcher will be built on the
same sites and within the same fencelines as other aboveground facilities. These include a pig
launcher/receiver assembly and a launcher assembly at Compressor Station 3, a launcher/receiver
assembly at the Smithfield M&R Station, and a pig receiver assembly at the Pembroke M&R
Stations. The pig launchers/receivers will be used to run pipeline inspection tools, called pigs,
through the pipeline system.
Right -of -Way Configuration_
The construction right-of-way width has been minimized following FERC's "Wetland &
Waterbody Construction & Mitigation Procedures" (Procedures) as prescribed for each land
type. For the AP -2 mainline, the construction corridor in non-agricultural uplands will measure
110 feet in width, with a 35 -foot -wide temporary side cast storage side and a 75 -foot -wide
working side. In areas where full width topsoil segregation is required (e.g., agricultural areas),
an additional 25 feet of temporary construction workspace will be needed on the working side of
the corridor to provide sufficient space to store topsoil. IIn wetlands, the width of the
^ construction right-of-way will be reduced to 75 feet, with 25 feet on the temporary side cast
storage side and 50 feet on the working side. Following construction, a 50 -foot -wide permanent
easement will be maintained for operation of the pipeline.
For the AP -3 pipeline lateral section in North Carolina, the construction corridor in non-
agricultural uplands and in wetlands will measure 75 feet in width, with a 25 -foot -wide
temporary side cast storage side and 50 -foot -wide working side. In areas where full width
topsoil segregation is required (e.g., agricultural areas), an additional 25 feet of temporary
construction workspace will be needed on the working side of the corridor to provide sufficient
space to store topsoil. Following construction, a 50 -foot -wide permanent easement will be
maintained for operation of each pipeline.
Atlantic will retain a 50 -foot -wide permanent right-of-way to allow operation and
maintenance of the pipeline along the AP -2 mainline. The majority of the permanent right-of-
way will be allowed to return to preconstruction uses, although permanent structures will not be
allowed within the 50- oot-wide permanent right-of-way. For maintenance of permanent right-
of-way in wetlands, Section VI. D. of the FERC's Procedures specifically requires:
"Do not conduct routine vegetation mowing or clearing over the full width of the
permanent right-of-way i wetlands. However, to facilitate periodic corrosion/leak
surveys, a corridor centered on the pipeline and up to 10 feet wide may be cleared at a
frequency necessary to maintain the 10 -foot corridor in an herbaceous state. In addition,
trees within 15 feet of the pipeline with roots that could compromise the integrity of
pipeline coating may be selectively out and removed from the permanent right-of-way.
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Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Do not conduct any routine vegetation mowing or clearing in wetlands that are between
horizontal directional drill (HDD) entry and exit points."
Therefore, after construction within the 50 -foot -wide permanent easement, the following
maintenance will occur:
(a) Ten feet centered over pipeline — maintained in an herbaceous state to facilitate
periodic aerial inspections. These areas will be reseeded with native wetland seed
mix.
(b) Thirty feet centered over pipeline — trees with roots that could compromise the
integrity of the pipeline coating would be selectively removed. These areas will
be reseeded with native wetland seed mix to stabilize the area within etlands
abO (c) Outside 30 -foot maintenance area in palustrine emergent (PEM) and palustrine
W�o-x scrub -shrub (PSS) etlands — vegetation allowed to regrow with no restrictions -
b no vegetation maintain�bytlantic. anttc will reseed these temporarily
isturbe wet an areasa wetland see mix to stabilize following
�) construction.
NWP 12 Regional Condition 4.1.3 (January 9, 2017 Wilmington District Public Notice
for NWP Program 2017-2022 Regional Conditions) for work in North Carolina states: "The
work area authorized by this permit, including temporary and/or permanent fills, will be
minimized to the greatest extent practicable. Justification for work corridors exceeding forty
(40) feet in width is required and will be based on pipeline diameter and length, size of
equipment required to construct the utility line, and other construction information deemed
necessary to support the request. The permittee is required to provide this information to the
USACE with the initial notification package." Construction of the ACP will require additional
workspace beyond 40 feet in wetland areas. Justification for the additional workspace is as
follows: AP -2 in North Carolina will be 36 -inch diameter pipe, which requires large construction
equipment to install. The construction space in wetlands consists of a trench necessary to
accommodate the pipe at an appropriate depth (3-5 feet beneath the surface), adjacent space to
place excavated material from the trench excavation, and travel of equipment alongside the
trench for pipe installation. Soils in wetlands areas are generally less stable than those in
adjacent upland areas, therefore additional shoring is necessary to achieve the appropriate trench
depth resulting in a trench that is wider than in adjacent upland areas. In addition, the extra
material that is excavated requires more space for temporary side -casting and the instability of
the soil requires that the travel corridor adjacent to the trench be at a safe distance so that failure
of the trench walls does not occur. In addition, the extra width of workspace maintains space for
safe operation of heavy equipment in the already reduced workspace in wetlands.
The FERC's Procedures specify a maximum right-of-way width of 75 feet in wetlands,
unless prior written approval is obtained. Atlantic has reduced workspace from 110 feet to
75 feet in wetlands and is not requesting a variance from this right-of-way limitation. Further
consideration was made regarding a reduction in workspace in wetlands to meet the 40 feet
recommended by Wilmington District NWP Regional and NCDEQ General WQC Conditions in
Atlantic Coast Pipeline 14

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
North Carolina, but for reasons outlined above, Atlantic has determined that the full 75 feet,
allowed by the FERC, will be necessary to safely install the ACP.
The NCDEQ Division of Water Resources has advised that the ACP will be reviewed as
an individual 401 Water Quality Certification. Atlantic acknowledges the importance of
working to comply with the general water quality conditions outlined for NWP 12. However,
Atlantic has communicated with NCDEQ and it has been discussed that NCDEQ has the ability
to waive the 40 -foot construction corridor restriction limitation associated with the General
WQC authorization for NWP 12. Atlantic requests that the NCDEQ consider the following
justification for General Condition 11, during the review of the 401 Water Quality Certification
for ACP, which states:
General WQC General Condition 11) Work in the Dry
All work in or adjacent to stream waters shall be conducted so that the flowing stream
does not come in contact with the disturbed area. Approved best management practices from the
most current version of the NC Sediment and Erosion Control Manual, or the NC DOT
Construction and Maintenance Activities Manual, such as sandbags, rock berms, cofferdams,
and other diversion structures shall be used to minimize excavation in flowing water. Exceptions
to this condition require application to and written approval from DWR.
Atlantic is requesting a waiver for General Condition 11 due to the fact that several
crossings are too large to feasibly work in the drry, but are not suitable�HDD The
smaller stream crossi-n-g-s—w—Mbe accomplished by working in the dry via flume, dam -and -pump,
and cofferdam construction methods, as previously described.
Along the Project in North Carolina, wetland-waterbody complexes occur that require
special crossing techniques. These complexes consist of broad inundated wetlands with a
waterbody channel located within the extents of the wetlands. The water is generally not
contained within the channel of the waterbody, thus resulting in a continuum of water that
extends from the channel to the upland extend of the wetlands edge. The crossing of these
complexes cannot be accomp isTed ut-ilizing a wa er o y crossing technique, thus a combination
of wetland/waterbody technique is required. The crossing cannot be accomplished "in the dry"
due to the difficulty in removing water from within the wetland. The channel crossing in these
complexes would be similar to the open cut method described in this section and the wetlands
crossing would be accomplished using the push-pull wetlands crossings method described in the
Wetland and Waterbody Construction Proce ec ionbelow.
The volume of water at the larger stream crossings is too great to safely and temporarily
[divert the flow around the work area. Rocky Swamp and Cypress Creek are proposed to be open
cut (i.e., wet crossings). As part of Atlantic's effort to avoid and minimize impacts on waters of
the United States and associated sensitive resources, crossings of seven large waterbodies are
proposed as HDD crossings (Roanoke River, Fishing Creek, Swift Creek, Tar River, Contentnea
Creek, Little River, and Cape Fear River) due to the resources present at these crossings; see
response to 5) below.
Atlantic Coast Pipeline 15

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
General WQC Activity Specific Condition 5) 50 foot Construction Corridor
Construction corridors in wetlands and'across stream channels shall be minimized to the
maximum extent practicable and shall not exceed 50 feet wide for gas utility lines and 40 feet
wide for all other utility lines. Exceptions to this condition require application to and written
approval from DWR.
Atlantic is requesting the waiver for Activity Specific Condition 5 due to the fact that a
50 foot work area through wetlands and across stream channels is not wide enough to safely
install a 36 -inch pipe. Construction of the ACP will require additional workspace beyond 50 feet
in wetland areas. Justification for the additional workspace is as follows: AP -2 in North Carolina
will be 36 -inch diameter pipe, which requires large construction equipment to install. The
construction space in wetlands consists of a trench necessary to accommodate the pipe at an
appropriate depth (3-5 feet beneath the surface)l adjacent space to place excavated material from
the trench excavation, and trave o equipment alongside the trench for pipe installation. Soils in
wetlands areas are generally less stable than adjacent upland areas, therefore additional shoring is
necessary to achieve the appropriate trench depth resulting in a trench that is wider than in
adjacent upland areas. In addition, the extra material that is excavated requires more space for
temporary side -casting and the instability of the soil requires that the travel corridor adjacent to
the trench be at a safe distance so that failure of the trench walls does not occur. In addition, the
extra width of workspace maintains space for safe operation of heavy equipment in the already
reduced workspace in wetlands.
In addition to the construction right-of-way, additional temporary workspace (ATWS)
~ - will be required at various locations along the construction right-of-way, such as at the beginning
of each construction spread for mobilization of construction equipment; for stringing -truck
turnaround areas; where the pipeline crosses under buried features (e.g., foreign pipelines, utility
lines); at road crossings, railroads, wetlands, waterbodies; residential areas, and at HDD
crossings.
ATWS also will be required in areas with side slopes to create a level and safe work
surface across the width of the right-of-way for equipment operation. For the AP -2 mainline,
ATWS measuring 25 by 100 feet will typically be required on both sides of the corridor and both
sides of the crossing at wetlands, waterbodies, roads, and railroads. The FERC's Procedures
require that ATWS be set back at least 50 feet from the wetland boundaries and the water's edge
of waterbodies, except where the adjacent lands consist of croplands or other disturbed areas.
Following construction of the pipelines, ATWS will be restored to pre-existing conditions and
uses.
Atlantic has identified roads which will be used to provide access to the Project
construction rights-of-way, permanent easement, and other facilities during construction and
operation of the ACP. Atlantic will utilize existing roads to the extent practicable, but some new
roads may need to be built in remote areas. Additionally, new roads will need to be built to
provide access to aboveground facility sites (i.e., compressor and M&R stations, valves, and pig
launcher/receiver assemblies) during operations. In some cases, existing roads will require
improvement (such as grading, gravelling, replacing or installing culverts, minor widening,
and/or clearing of overhead vegetation) to safely accommodate construction equipment and
C .
Atlantic Coast Pipeline 16

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
vehicles. A sufficient number of roads with regular spacing are needed to minimize congestion
of construction vehicles and equipment on the right-of-way; having fewer access roads would
increase the duration of construction and create unsafe work conditions for workers. If any
existing roads are damaged during construction, Atlantic will restore these roads to
preconstruction condition or better. See Appendix C for access road impacts.
General Construction Procedures
Refer to Appendix D for a discussion on general construction procedures.
Waterbody and Wetland Construction Procedures
Atlantic will use special construction techniques where warranted by site-specific
conditions, e.g., when constructing across waterbodies, and wetlands. Each of these specialized
measures is described below. Illustrations of select crossing methods are provided in
Appendix E and site-specific plans are provided in Appendix F for crossings of Section 10
waterbodies.
Waterbody Crossings
Atlantic will use the open -cut, flume, dam -and -pump, conventional bore, cofferdam, or
HDD methods to construct the pipelines across waterbodies. In each case and for each method,
Atlantic will adhere to the measures specified in the Procedures; site-specific modifications to
the Procedures as requested by Atlantic and approved by the FERC. As well as any additional
requirements identified in federal or state waterbody crossing permits, including applicable
permits and approvals from the USACE and various state agencies (see Section 135). A complete
list of the waterbodies along the proposed pipeline routes within the Wilmington Distict, and the
construction method proposed for each crossing, is provided in Appendix C. Construction
methods for waterbodies that isolate the pipeline trench from flowing water (e.g. flume, dam -
and -pump, cofferdam) will be utilized where these methods are proposed and perceptible flow is
present at the time of the crossing.
During the clearing and grading phase of construction, temporary bridges will be
yT Astalled across waterbodies in accordance with the Procedures to allow construction equipment
and personnel to cross. The bridges may include clean rock fill over culverts, timber mats
supported by flumes, railcar flatbeds, flexi-float apparatuses, or other types of spans.
Construction equipment will be required to use the bridges, except that the clearing and bride
installation crews will be allowed one pass through waterbodies before bridges are installed. The pV�
temporary bridges will be removed when construction and restoration activities are complete.
i
ATWS will be required on both sides of waterbody crossings to stage construction �S\ r V
_U
it equipment, fabricate the pipeline, and store construction materials. The ATWS will be located at
least 50 feet away from the water's edge at each waterbody (with the exception of site-specific
modifications as requested by Atlantic and approved by the FERC).
eAVL Clearing adjacent to waterbodies will involve the removal of trees and brush from the
), construction right-of-way and ATWS areas. Woody vegetation within the construction right-of-
Vll way will be cleared to the edge of each waterbody. Sediment barriers may be installed at the top
Atlantic Coast Pipeline 17

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
of the bank if no herbaceous strip exists. Initial grading of the herbaceous strip will be limited to
the extent needed to create a safe approach to the waterbody and to install temporary bridges.
During clearing, sediment barriers will be installed and maintained across the right-of-
way adjacent to waterbodies and within ATWS to minimize the potential for sediment runoff.
Erosion control devices located across the working side of the right-of-way will be removed
during the day when vehicle traffic is present, and will be replaced each night. Alternatively,
drivable berms may be installed and maintained across the right-of-way in lieu of silt fences, coir
logs, and/or straw bales.
Typically, equipment refueling and lubricating at waterbodies will take place in upland
areas that are 100 feet or more from the edge of the waterbody and any adjacent wetlands.
However, there will be certain instances where equipment refueling and lubricating may be
necessary in or near waterbodies. For example, stationary equipment, such as water pumps for
withdrawing hydrostatic test water, may need to be operated continuously on the banks of
waterbodies and may require refueling in place. In this event, the pumps would be refueled in a
secondary containment structure and all fuels stored more than 100 feet from the edge o t e
water o y or adjacent wetlands. Atlantic's Spill Prevention, Control, and Countermeasures Plan
(SP an)a resses, among other items, the handling of fuel and other materials associated
with the ACP. As required by the Procedures, the SPCC Plan will be available during
construction on each construction spread. The SPCC Plan is provided in Appendix G.
After the pipeline is installed across a waterbody using one of the methods described
below, the trench will be backfilled with native material excavated from the trench. If present
and moved prior to construction, larger rocks or boulders will be replaced in the stream channel
within the construction area following backfill of the trench. The streambed profile will be
restored to preconstruction contours and grade conditions to prevent scouring. The stream banks
will then be restored as near as practicable to preconstruction conditions and stabilized.
Stabilization measures will include seeding, installation of erosion control blankets, or
installation of riprap materials, as appropriate. Jute thatching or bonded fiber blankets will be
installed on banks of waterbodies or road crossings to stabilize seeded areas. Temporary erosion
controls will be installed immediately following bank restoration. The waterbody crossing area
will be inspected and maintained until restoration of vegetation is complete.
Open -Cut Method
The open -cut or wet trench crossing method will involve trenching through the
waterbody while water continues to flow through the trenching area. Prior to initiating
construction across the waterbody, the crossing section of pipeline will be fabricated (i.e., bent,
welded, and coated) in adjacent ATWS areas. Backhoe -type excavators will then be used to
excavate a trench in the flowing waterbody from one or both banks of the waterbody. Where the
waterbody is too wide to excavate the trench from the banks, equipment may operate from within
the waterbody with approval from the appropriate regulatory agencies. Equipment operating
within the waterbody will be limited to that needed to construct the crossing. During these I Vr
1� �
operations, flow will be maintained at the crossing as specified in the Procedures. Turbidity � U
curtains will be installed downstream of the crossing s necessary o minimize suspended solids �a,
in the wa
Atlantic Coast Pipeline 18

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Temporary sidecast material excavated from the trench will be placed on the bank above
the high water mark (at least 10 feet from the edge of the water) or placed adjacent to the trench
in the stream (major waterbodies only, in accordance with the Procedures) for use as backfill. A
prefabricated segment of pipeline will then be placed into the trench using side -boom tractors.
Concrete coating (installed in uplands in project workspace) or bag weights will be utilized, as
necessary, to provide negative buoyancy for the pipeline. Once the trench is backfilled, the
banks will be restored as near as practicable to pre -construction contours and stabilized as
described above. Excavated material not required for backfill will be removed and disposed of at
a' approved upland disposal sites•
0�
Ge Throughout the construction process, Atlantic will follow the Procedures to avoid or
minimize impacts on water quality. Construction activities will be scheduled so that ch is
not excavated across the waterbody until immediate)prior t2_pipe laying activities. The
_ wpntertmediacl
ion of in -stream construction activities (excluding blasting, if re ed) wi a limited to
ours aross minor waterbodies (those 10 feet in width or less) 48 ours across
^^� e waterbodies (those between 10 and 100 feet in width).
1v"
Flume Method
The flume crossing method consists of isolating and temporarily diverting the flow of
water across the trenching area through one or more large -diameter, steel flume pipes placed in
the waterbody. This method allows for trenching activities to occur within a relatively dry
stream or riverbed (beneath the flume pipes containing the water flow), thereby minimizing
sediment and turbidity within the waterbody. The flume method is typically used to cross small
to intermediate flowing waterbodies that support coldwater or other significant fisheries.
For each waterbody where the flume method is implemented, a sufficient number of
adequately sized flume pipes will be installed in the waterbody to accommodate the highest
anticipated flows during construction. Atlantic will use stream gauge data from the USGS to
determine the highest anticipated flows during the time the flume crossing is in effect. In the
absence of stream gauge data, Atlantic's engineers and Environmental Inspectors will estimate
the highest anticipated flows based on the width of the waterbody at the ordinary high water
mark, the depth of the waterbody, existing flows at the time of the crossing, and the weather
forecast at the time of the crossing. As a contingency, Atlantic will stage additional flume pipes
at the crossing in the event that the volume of flow increases due to a precipitation event.
Prior to installation, Atlantic will inspect the flume pipes to confirm that they are free of
dirt, grease, oil, or other pollutants. After placing the pipes in the waterbody, sand- or pea
gravel -filled bags, water bladders, or metal wing deflectors will be placed in the waterbody
around the flume pipes upstream and downstream of the proposed trench. These devices will
serve to dam the stream and divert the water flow through the flume pipes, thereby isolating the
water flow from the construction work area between the dams.
After installation of the flume pipes, any remaining standing water between the dams will
be pumped out. Pump intakes will be appropriately screened to prevent entrainment of aquatic
species. Fish trapped in the dewatered area will be removed and returned to the flowing
waterbody. Leakage from the dams or subsurface flow from below the waterbody bed may
Atlantic Coast Pipeline 19

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
cause water to accumulate in the trench once trenching has begun. If water accumulates in this
area, it may be pumped out periodically and discharged into energy dissi ation/sedi
filtration devices as require y t e Procedures. Such devices include geotextile filter bags and la�
straw bale structures. Alternatively, the water will be discharged into well -vegetated areas away
from the edge of the waterbody, to prevent silt -laden water from entering t e water o y.
Backhoe -type excavators located on the banks of the waterbody will be used to excavate
a trench under the flume pipe across the dewatered streambed. Temporary side -cast material
excavated from the waterbody trench will be placed and stored on the bank above the high water
mark and a minimum of 10 feet from the edge of the waterbody. Once the trench is excavated, a
prefabricated segment of pipe will be installed beneath the flume pipes. The trench will then be
backfilled with the native material excavated from the trench across the waterbody bed. The
banks will be stabilized before removing the dams and flume pipes and returning flow to the
waterbody channel.
The flume method has proven to be an effective technique for constructing pipelines
across sensitive waterbodies. The potential for the introduction of turbidity or suspended
sediments is limited because sediment generated during trench excavation and backfilling
operations is isolated to the dewatered area between dams. When flumes are installed properly,
the operation of the flume is generally stable and can be left in place for periods prior to and
following the installation of the waterbody pipeline crossing. The flume method also provides
for continued fish passage through the construction work area via the flume pipes during the
crossing.
Dam -and -Pump Method
The dam -and -pump method generally is preferred for smaller waterbodies, where
mechanical pumps can dependably convey stream flows. Int .s approach, pumps and hoses are
used instead of flume pipes to isolate and transport the stream flow around the construction work
area. Similar to the flume method, the objective of the dam -and -pump method is to create a
relatively dry work area to avoid or minimize the transportation of sediment and turbidity
downstream of the crossing during in -stream work.
As the first step in implementing the dam -and -pump method, one or more pumps and
hoses of sufficient size to transport anticipated flows will be installed adjacent to the waterbody.
Additional back-up pumps will be on site at all times as a contingency, in case of pump failure.
Once the pumps are operational, the waterbody upstream and downstream of the construction
area will be dammed with sandbags and/or steel plates. As the dams are installed, the pumps
will be started to maintain continuous flow in the waterbody.
Following the installation of the dams, the pumps will be run continuously until the
pipeline is installed across the waterbody and the streambed and banks are restored. Pump
intakes above the upstream dam will be appropriately screened to prevent entrainment or
impingement of aquatic species. Energy -dissipation devices, such as splash blocks, filter bags,
or energy dissipation sleeves, will be used to prevent scouring of the streambed at the discharge
location. Water flow will be maintained through all but a short reach of the waterbody at the
. actual crossing location.
Atlantic Coast Pipeline 20

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Backhoe -type excavators located on the banks of the waterbody will be used to excavate
a trench across the waterbody. Temporary sidecast material removed from the trench will be
placed and stored on the bank above the high water mark at a minimum of 10 feet from the edge
of the water. Trench plugs will be maintained between the upland trench and the waterbody
crossing. Once the trench is excavated, a prefabricated segment of pipe will be installed. The
trench will then be backfilled with the native material excavated from the trench across the
waterbody bed. After backfilling, the dams will be removed and the banks restored and
stabilized as described above.
Conventional Bore
In some cases, waterbodies may be crossed by conventional subsurface boring beneath
the waterbody. Boring involves installing pipeline through a hole bored through the substrate.
Where this method is implemented, equipment operating from pits excavated on either side of
the crossing will bore through the substrate beneath the waterbody. If dewatering of the pits is
necessary, it will be conducted in accordance with the Upland Erosion Control, Revegetation,
and Maintenance Plan (Plan) and Procedures and applicable permits in a manner that will
minimize erosion and prevent silt -laden water flowing into the waterbody or adjacent wetlands.
During a conventional bore crossing, the pipeline will be pushed through the bore hole
under the waterbody. Like the HDD method described later in this section, the conventional
bore can eliminate direct surface impacts on waterbodies. however. there are limitations to its
use. This method cannot typically be used to cross waterbodies with unconsolidated soils in tl
substrate because it is not possible to maintain the integrity of the borehole in this condition.
Because conventional bores in general are installed straight along a horizontal p ate, the
bore pits must be excavated to a depth sufficient to allow installation of pipe at the appropriate
depth beneath the streambed (i.e., 5 feet beneath the streambed) and to account for the height of
the boring machinery. Where waterbodies are entrenched or adjacent slopes are steep,
excavation to sufficient depths can require excessively large pits to address Occupational Safety
and Health Administration shoring requirements, which creates the potential to sink the stream or
flood the bore pits. These considerations limit the use of this crossing method for entrenched
waterbodies or those with steep slopes.
Cofferdam
Some waterbodies will be crossed using the cofferdam method. In this method, a
temporary diversion structure is installed from the bank around half the width of the crossing to
isolate that section of the stream from the rest of the waterbody. Once the temporary diversion
structure is installed, water is pumped from the isolated section to allow excavation of the pipe
trench from the bed of the waterbody in the dry. After the pipe is installed in the trench in the
isolated section of stream, the temporary diversion structure is disassembled and reinstalled from
the opposite bank of the crossing and the process is repeated. The cofferdam method allows
waterbodies to be crossed in the dry in discrete sections while water flows unimpeded around the
temporary diversion structure. The method is sometimes favored for wide, relatively shallow
waterbodies or waterbodies containing sensitive fisheries because it allows water and fish to pass
around the temporary diversion structure.
Atlantic Coast Pipeline 21

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
For waterbodies crossed using the cofferdam method, sections of steel frame for the
temporary diversion structure will be assembled in an upland area adjacent to the
crossing. Depending on size, the frame sections will be placed in the waterbody either manually
or by crane. The frame sections will be positioned around a predetermined perimeter in the
waterbody extending from one of the banks. The spacing of frame sections will be based on the
depth of the water, but a typical spacing will be 15 to 30 inches. The frame sections may be
reinforced, as necessary, with steel poles or other supports to increase stability of the structure,
especially in waterbodies with soft substrate. Fabric sheets will then be attached to the top of the
frame and unrolled down and out onto the bed of the waterbody on the exterior side of the
frame. The fabric sheets will create a liner around the frame with a seal on the bed of the
waterbody. The fabric may be covered in soft sediments or sandbags to help create the seal.
After the temporary diversion structure is installed, one or more pumps will be used to
dewater the area within the temporary diversion structure. Pump intakes will be appropriately
screened to prevent entrainment of aquatic species. Water will be discharged to the waterbody
outside the structure through an energy -dissipating device to prevent scouring of the bed at
locations of discharge.
Once dewatering is complete, any fish trapped in the temporary diversion structure will
be removed and returned to the flowing waterbody. Construction equipment will enter the
isolated section of the waterbody from the adjacent bank. This construction equipment will be
used to excavate the trench, install a pre -assembled section of pipe, backfill the trench, and
restore the bed as near as practicable to pre -construction contours. The equipment will be
J
removed from the temporary diversion structure via the adjacent bank.
After the section of pipeline is installed, the enclosed area within the temporary diversion
structure will be flooded. Then the fabric sheets and steel frame sections will be disassembled.
The structure will be reinstalled from the opposite bank, with enough overlap of the initial
excavation area so that the installed section is accessible for tie-in to the next section of
pipe. The dewatering and construction process is then repeated from the opposite bank, to
complete the crossing of the waterbody.
Horizontal Directional Drill Method
The HDD method allows for trenchless construction by drilling a hole beneath a surface
feature, such as a waterbody or other unique resource, and installing a prefabricated segment of
pipeline through the drill bore. The method avoids disturbance to the surface of the right of way
between the entry and exit points of the drill. The method is sometimes used to install pipelines
underneath sensitive resources or areas that present difficulties for construction or access using
typical installation methods. HDDs can provide certain advantages over typical construction
methods, such as avoidance of surface disturbance, riparian tree clearing, or in -stream
construction. Right-o£wav maintenance will not occur between the HDD entry and exit points
For each HDD crossing, electric grid guide wires will be laid by hand on the ground
along the pipeline centerline to create an electromagnetic sensor grid. The grid will be used by
the HDD operator to steer the drill head during drilling. The sensor grid will be fabricated by
installing several stakes along the drill path and wrapping them with an insulated coil wire. The
Atlantic Coast Pipeline 22

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
wire will be energized with a portable generator, which will create a magnetic field that can be
used to track the drill bit. No ground or surface disturbing activities will be required for
installation of the guide wires; however, in thickly vegetated areas a two- to three-foot wide path
may need to be cut with hand tools for the wires. Other methods such as gyroscope guidance
systems may be utilized in specific situations as an alternative to electric grid guidance to
accommodate the wires.
Prior to the final design and selection of the HDD method, geotechnical investigations
occur at each proposed crossing to ensure that the underlying geology supports the installation.
Minor disturbance may be necessary to conduct this investigation.
To complete each HDD, a drill rig will be placed on the entry side of the crossing and a
small -diameter pilot hole will be drilled along a predetermined path beneath the waterbody using
a powered drill bit. As drilling progresses, additional segments of drill pipe will be inserted into
the pilot hole to extend the length of the drill. The drill bit will be steered and monitored
throughout the process to maintain the designated path of the pilot hole. Once the pilot hole is
complete the hole will be enlarged to accept the pipeline. The HDD may require a drill rig on
both sides due to the complexity of the drill, for reasons including but not limited to, length,
substrate, noise, or duration.
To enlarge the pilot hole, a larger reaming tool will be attached to the end of the drill on
the exit side of the hole. The reamer will be drawn back through the pilot hole to the drill rig on
the entry side of the hole. Drill pipe sections will be added to the rear of the reamer as it
progresses toward the rig, allowing a string of drill pipe to remain in the drill bore at all times.
Several passes with progressively larger reaming tools will be required to enlarge the hole to a
sufficient diameter to accommodate the pipeline. The final hole will be approximately 12 inches
larger than the pipeline to be installed.
Throughout the drilling process, a fluid mixture consisting of water and bentonite clay (a
A/ naturally occurring mineral) will be pumped into the drill hole to lubricate the bit, transport
�1 cuttings to the surface, and maintain the integrity of the drill bore. Water for the mixture will be
`\Q' �N pumped from the waterbody to the drill site through a hose or tempLrar
LnetworTofirri -
type piping&ftrucked in from another source. The pump intake will be appropriately screened
to prevent entrainment of aquatic species. Small pits may be dug at or near the entry and exit
\ points for the HDD to temporarily store the drilling fluid and cuttings. The fluid and cuttings
will be pumped from the pits to an on-site recycling unit where the fluid will be processed for
reuse.
a
The pipeline segment (also called a pull section) to be installed beneath the surface
feature will be fabricated on the right of way or in the ATWS on the exit side of the crossing
while the drill hole is reamed to size. Once assembled, the girth welds of the pull section will be
coated with fusion -bonded epoxy. A sacrificial abrasion resistant overlay would be applied over
the fusion -bonded epoxy coating at the pipe mill for protection from abrasive materials that may
be encountered as the pull section is installed. These coating materials on girth welds will be
mixed in an area prepared to contain spills; splash pads, plastic or other material will be placed
on the ground in the mixing area to contain any potential spills. Activities will occur in
accordance with the SPCC Plan (see Appendix G). The pull section will be inspected and
Atlantic Coast Pipeline 23

Nationwide Permit No. 12, Pre-Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
hydrostatically tested prior to installation. A steel bullhead will be welded onto the front end of
the pull section to aid in pulling the pipe through the drill hole. After the hole is completed, the
pipeline segment will be attached to the drill string on the exit side of the drill bore and pulled
back toward the drill rig.
As the pipeline is being installed, excess drilling fluid will be collected and disposed of at
k an approved facility or, as allowed and apjrL6Ved bv the agencies an landowner. The HDD
t9\\ drilling fluid is a mixture of bentonite clay (a naturally occurring material) and water. Excess
drilling fluid will not be incorporated into soils under any circumstances within or adjacent to
habitats with known federally listed plant species. If water is left over from the drilling process,
it will be discharged in accordance with the Plan and Procedures and applicable permits into a
well-vegetated upland area or an energy dissipation/sediment filtration device, such as a
geotextile filter bag or straw bale dewatering structure, at the site.
Q/
S S Successful crossings utilizing HDD will result in little to no impact on the surface feature
being crossed. If a natural fracture or weak area in the ground is encountered during drilling, an
��� inadvertent return of drilling fluid to the environment could occur. Substrate consisting of
unconsolidated gravel, coarse sand, or fractured bedrock could increase the likelihood of an
w inadvertent return. Depending on the orientation of the natural fracture or substrate, the drilling
fluid may move laterally or vertically from the drill hole. If the drilling fluid moves laterally, the
release may not be evident on the ground. For an inadvertent return to be evident on the surface
there must be a preferential pathway extending vertically from the drill hole to the surface of the
ground. The volume of fluid released in an inadvertent return would depend on a number of
factors, including the size of the pathway, the permeability of the geologic material, the viscosity
of the fluid, and the pressure of the hydraulic drilling system. The drilling fluid is a closed
system that is monitored closely for changes in pressure and volume which may indicate
eve opment o an tna vertent return. If a change in pressure is identified, corrective action will
occur.
Atlantic has prepared a Horizontal Directional Drill Fluid Monitoring, Operations, and
Contingency Plan (HDD Plan) which describes the measures to be implemented in the event of
an inadvertent return and can be found in Appendix H. If a release occurs on land, including
within a wetland, a small pit will be excavated at the release site to contain the spread of the
fluid, and a pump will be used to transfer the fluid from the pit into a containment vessel. If an
inadvertent return occurs in a waterbody it will be more difficult to contain because the fluid may
be dispersed into the water and carried downstream. In this situation, thickening agents such as
additional bentonite, cottonseed hulls, or other non -hazardous materials will be added to the
drilling fluid, in order to plug the flow path. All drilling fluid additives will be non -hazardous.
Once a drilling contractor has been selected and the specific additives are identified, a list of
additives will be compiled in site-specific HDD Plans along with appropriate Material Safety
Data Sheets and product descriptions. Atlantic will consult with and obtain permission from the
appropriate state regulatory agencies regarding the use of additives during the HDD process and
confirm that additives will not violate water quality standards.
Atlantic will monitor source waters along and near the drill path, such as seeps and
springs, for inadvertent returns. Atlantic will implement the measures identified in the HDD
Atlantic Coast Pipeline 24

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Plan to control and clean up the inadvertent return, test the water for water quality, and provide
an alternate supply of water to affected landowners until the inadvertent return is remediated.
The HDD method is proposed on the AP -2 mainline in North Carolina for the following
seven large river crossings (five additional minor tributaries of these rivers would also be crossed
via HDD of the major waterbody):
• Roanoke River at approximate MP 9.8 at the Northampton/Halifax County line;
• Fishing Creek at approximate MP 33.9 at the Halifax/Nash County line;
• Swift Creek at approximate MP 40.6 in Nash County;
• Tar River at approximate MP 59.4 in Nash County;
• Contentnea Creek at approximate MP 73.6 in Wilson County;
• Little River at approximate MP 82.5 in Johnston County; and
• Cape Fear River at approximate MP 154.2 in Cumberland County.
Atlantic explored use of the HDD method at the Rocky Swamp crossing, but based on
geotechnical results, due to heavily weathered bedrock and overlying unconsolidated materials,
the likelihood of experiencing an inadvertent release was high. Therefore, the HDD method is
not proposed for the Rocky Swamp crossing. Appendix P contains the HDD Design Report and
discusses HDD crossings along with feasibility considerations for the ACP.
Wetlands
Construction across wetlands will be conducted in accordance with the Procedures, site-
specific modifications to the Procedures requested by Atlantic and approved by the FERC, and
additional requirements identified in federal or state wetland crossing permits. Typical methods
for construction across wetlands are described below. A list of wetland crossings along the
proposed pipeline route within the Wilmington Distict is provided in Appendix C.
In accordance with the Procedures, the width of the construction right-of-way will be
limited to 75 feet through wetlands, with ATWS on both sides of wetland crossings to stage
construction equipment and materials, fabricate the pipeline, and store materials and excavated
temporary sidecast material. ATWS will be located in upland areas a minimum of 50 feet from
the wetland edge (with the exception of site-specific modifications as requested by Atlantic and
approved by the FERC or where adjacent uplands consist of cultivated or rotated cropland or
other disturbed land).
Wetland boundaries will be clearly marked in the field prior to the start of construction
with signs and flagging. Construction equipment working in wetlands will be limited to what is
essential for right-of-way clearing, excavating the trench, fabricating and installing the pipeline,
y� backfilling the trench, and restoring the right of way. In areas where there is no reasonable
access to the right of way except through wetlands, non-essential equipment will be allowed to
travel through wetlands once, unless the ground is firm enough or has been stabilized to avoid
rutting. Stabilization may include use of rip -rap or prefabricated timber mats. Temporary
�h stabilization materials placed in the wetlands will be removed during the restoration of the right
of way.
Atlantic Coast Pipeline 25

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Clearing of vegetation in wetlands will be limited to trees and shrubs, which will be cut
flush with the surface of the ground and removed from the wetland. To avoid excessive
disruption of wetland soils and the native seed and rootstock within the topsoil, stump removal,
grading, topsoil segregation, and excavation will be limited to the area immediately over the
trenchline, except a limited amount of stump removal and grading may be conducted in other
areas if required by safety-related issues. Topsoil segregation over the trenchline will only occur
if the wetland soils are not saturated at the time of construction.
As part of the land clearing process, sediment barriers, such as silt fences or other
approved sediment barriers, will be installed and maintained adjacent to wetlands and within
ATWS areas as necessary to minimize the potential for sediment runoff. Sediment barriers will
be installed across the full width of the construction right-of-way at the base of slopes adjacent to
wetland boundaries. Erosion control devices installed across the working side of the right-of-
way will be removed during the day when vehicle traffic is present, and will be replaced each
night. Alternatively, drivable berms may be installed and maintained across the right-of-way in
lieu of silt fences, coir logs, or straw bales. Sediment barriers will also be installed within
wetlands along the edge of the right-of-way, where necessary, to minimize the potential for
sediment to run off the construction right-of-way and into wetlands outside the work area. If
rench dewatering is necessary, it will be conducted in accordance with the Prnned-ras and
c pplicable ermits. 1 t- aden trench water will be discharged into an energy
[minimize
isstpation/sediment filtration device, such as a geotextile filter bag and straw bale structure, to
the potential for erosion and sedimentation.
The method of pipeline construction used in wetlands will depend on site-specific
weather conditions, soil saturation, and soil stability at the time of construction. If wetland soils
are not excessively saturated at the time of construction and can support construction equipment
on equipment mats, they will be crossed using conventional open -trench construction. This will
occur in a manner similar to conventional upland cross-country construction techniques. In
unsaturated wetlands, topsoil from the trenchline will be stripped and stored separately from
subsoil.
Where wetland soils are saturated or in inundated lowlands areas where soils cannot
support conventional pipe -laying equipment, the pipeline may be installed using the push-pull
method. This method will involve stringing and welding the pipeline outside of the wetland and
excavating and backfilling the trench using a backhoe supported by equipment mats. A
prefabricated section of pipeline will be installed in the wetland by equipping it with buoys and
pushing or pulling it across the water -filled trench. After the pipeline is floated into place, the
floats will be removed and the pipeline will sink into place. In most cases, the pipeline will be
coated with concrete or equipped with set -on weights to provide negative buoyancy. Once the
pipeline is in place, the trench will be backfilled. The push-pull construction method minimize
the number of equipment passes, reducing wetland impactsan soil compaction in lowland
areas.
The application of concrete coating will generally occur in contractor yards identified for
the Projects. In areas where concrete coating of pipe is required within the construction right of
way, the coating activities will occur in accordance with the SPCC Plan. Concrete coating
activities will occur a minimum of 100 feet from wetlands, waterbodies and springs, and 300 feet
Atlantic Coast Pipeline 26

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
from karst features. Concrete -coated pipe will be installed after the concrete is dried and will not
be dispersed when submerged in water. Concrete coating is used to create negative buoyancy
along the pipeline when required for waterbody or wetland crossings if necessitated by site-
specific conditions.
Because little or no grading will occur in wetlands, restoration of contours will be
accomplished during backfilling. Prior to backfilling, trench breakers will be installed, where
necessary, to prevent subsurface drainage of water from wetlands. Where topsoil is segregated,
the subsoil will be backfilled first followed by the topsoil. Topsoil will be replaced to the
original ground level leaving no crown over the trenchline. In areas w ere we an s over ie
rocky soils, the pipe will e padded with rock -free soil or sand before backfilling with native
bedrock and soil. Equipment mats, gravel fill, and/or geotextile fabric will be removed from
wetlands following ac it m n addition, rench plugs will be installed at the boundaries of
wet ands to prevent sub -surface hydrology from following the trenchline and indirectly removing
hydrology from wetlands.
Where wetlands are located at the base of slopes, permanent slope breakers will be
constructed across the right of way in upland areas adjacent to the wetland boundary. Temporary
sediment barriers will be installed where necessary until revegetation of adjacent upland areas is
successful. Once revegetation is successful, sediment barriers will be removed from the right of
way and disposed of at an approved disposal facility.
4. Jurisdictional Determinations TI
Environmental Resources Management (ERM), on behalf of Atlantic, conducted wetland
and waterbody surveys for the proposed ACP. ERM contracted with Duncan & Duncan WEST,
LLC, Environmental Services Inc., and Woodard & Curran to complete the field efforts. The
survey area in North Carolina consists of a 300 -foot -wide corridor approximately 198.7 miles
long. Wetland and waterbody surveys have been on-going since June 2014 and will continue
until the wetland and waterbody surveys are complete on all land parcels along the proposed
pipeline route. As of January 2017, wetland and waterbody surveys in North Carolina for AP -2
and AP -3 are 98 percent complete. Where field surveys were not able to be completed, due to
lack of access to properties, a desktop assessment was completed to delineate wetlands and
waterbodies using a combination of National Wetlands Inventory data, the USGS topographic
maps, Soil Survey Geographic Database data, and high resolution aerial photography. Appendix
A - Figures A-3 and A-4 show the relative locations of delineated features along the AP -2 and
AP -3 lines within North Carolina.
The assessment of all wetlands, rivers, streams, open waterbodies (e.g., ponds), and seep
points were documented within the survey corridor and based on qualified wetland biologists'
best professional judgment and interpretation of the U.S. Army Corps of Engineers 1987
Wetlands Delineation Manual (USACE, 1987), the Regional Supplement to the Corps of
Engineers Wetland Delineation Manual: Atlantic and Gulf Coastal Plain Region (Version 2.0)
(USACE, 2010), the USACE Regulatory Guidance Letter regarding Ordinary High Water Mark
Identification (USACE, 2005), and other applicable USACE guidance documents and
regulations. }
Atlantic Coast Pipeline 27

fj
Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Atlantic has applied for a Preliminary Jurisdictional Determination from the USACE
identifying wetlands, streams and other waterbodies within the ACP project area. Appendix B
includes a place holder for the Wetland and Waterbody Survey Report, which is available upon
request.
5. Project History
In addition to the NWP 12, Atlantic is applying for several federal and state permits for
ACP. A list of the permits applied for are included in Table 2 below.
TABLE 2
Permit Table for the Atlantic Coast Pipeline in North Carolina
Atlantic Coast Pipeline
28
Filing/Anticipated
Anticipated
Agency
Permit/Approval/Consultation
Filing Date
Approval Date
Federal
Federal Energy Regulatory
Certificate of Public Convenience and
September 18, 2015
September 2017
Commission
Necessity under Section 7(c) of the Natural
Gas Act
Federal Aviation Administration
Notice of Proposed Construction or
November 2016
October 2017
Authorization
Federal Aviation Administration
Supplemental Notice
November 2016
October 2017
Federal Communications Commission
Application for Wireless Telecommunications
November 2016
October 2017
Bureau Radio Service Authority
National Oceanic and Atmospheric
Consultation under Section 7 of the
Ongoing
September 2017
Administration — National Marine
Endangered Species Act and Section 305 of
Fisheries Service
the Magnuson -Stevens Act
National Oceanic and Atmospheric
Consultation under the Marine Mammal
August 22, 2014
July 1, 2016
Administration — National Marine
Protection Act
Fisheries Service
National Park Service — Blue Ridge
Right -of -Way Grant and Special Use Permit to
September 17, 2015
September 2017
Parkway
cross the Blue Ridge Parkway
U S Army Corps of Engineers —
Department of the Army NWP 12 Verification
September 15, 2015
September 2017
Pittsburgh, Pittsburgh, Norfolk, and
under Section 404 of the Clean Water Act and
Wilmington Districts
Section 10 of the Rivers and Harbors Act
U S Army Corps of Engineers —
Department of the Army Permissions under
August 2016
September 2017
Norfolk District
Section 408 of the Rivers and Harbors Act
U S Army Corps of Engineers —
Department of the Army Permissions under
August 2016
September 2017
Wilmington District
Section 408 of the Rivers and Harbors Act
North Carolina
North Carolina Department of
Air Permit— Stationary Source Construction
September 16, 2015
June 2017
Environment and Natural Resources
and Operation Permit for Compressor Station 3
(original)
— Division of Air Quality
December 15, 2016
(equipment change
update)
North Carolina Department of
General Permit NCG 010000 to Discharge
December 2016
3Q 2017
Environment and Natural Resources
Stormwater under the National Pollutant
— Division of Energy, Mineral, and
Discharge Elimination System
Land Resources (or approved local
government)
North Carolina Department of
Water Quality Certificate under Section 401 of
NA
3Q 2017
Environment and Natural Resources
the Clean Water Act (including permission to
— Division of Water Resources
use State-owned bottom lands)
North Carolina Department of
Isolated and Other Non -404 Jurisdictional
September 15, 2015
3Q 2017
Environment and Natural Resources
Wetlands and Waters Permit (including
— Division of Water Resources
permission to use State-owned bottom lands)
Atlantic Coast Pipeline
28

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 2
Permit Table for the Atlantic Coast Pipeline in North Carolina
Table includes all applications for the Wilmington District
6. Future Project Plans
See Section 13.6 of the PCN Form.
C. PROPOSED IMPACTS INVENTORY
The ACP pipeline facilities, access roads, and aboveground facilities will require a total
of 563 single and complete projects across waters of the U.S. in North Carolina, detailed within
Appendix C-1. Appendix C provides details of wetlands that include location information,
HUC 8 codes, wetland type classifications, and an analysis of impacts proposed, and details of
waterbodies that include location information, HUC 8 codes, state special designations, tributary
information, and an analysis of impacts proposed. AP -2 and AP -3 cross a total of 10 HUC 8
watersheds across North Carolina. The HUC 8 watersheds and the impacts anticipated for
wetlands and waterbodies crossed by the pipeline workspace are summarized in tables 3 and 4,
below. No permanent loss to wetlands or waterbodies is anticipated for mainline pipeline
construction or associated facilities. However, permanent loss impacts to 0.80 acres of wetlands
are proposed for construction and improvements to permanent access roads in the Wilmington
District, as discussed below in the subsection on Access Roads and Aboveground Facilities.
Outside of the 30 -foot maintained right-of-way, Atlantic will replant non -inundated forested
deciduous hardwood wetlands. Temporary wetland impacts, conversion of type impacts, and
permanent losses are noted below for HUC 8 watersheds and in Appendix C-1 for individual
projects (crossings). A summary of single and complete projects can be found in Appendix C-2.
Table 3 provides a summary of the proposed wetland impacts within eight -digit HUC
watersheds crossed by the ACP in the Wilmington District. -f
Atlantic Coast Pipeline 29
Filing/Anticipated
Anticipated
Agency
Permit/Approval/Consultation
Filing Date
Approval Date
North Carolina Department of
Buffer Authorization (for riparian zone
September 15, 2015
3Q 2017
Environment and Natural Resources
disturbance)
— Division of Water Resources
North Carolina Department of
Natural Heritage/Protected Species
Ongoing
3Q 2017
Environment and Natural Resources
Consultation
—Natural Heritage Program
North Carolina State Historic
Consultation under Section 106 of the National
Ongoing
3Q 2017
Preservation Office
Historic Preservation Act
North Carolina Wildlife Commission
Protected Species Consultation
October 13, 2014
3Q 2017
County/City/Local
Floodplain Permit (expected to be required in
2Q 2017 — 3Q 2017
2Q 2017 — 3Q 2017
all Counties and Cities along the routes)
County/City/Local
Special or Conditional Use Permit (where
2Q 2017
3Q 2017
required)
Table includes all applications for the Wilmington District
6. Future Project Plans
See Section 13.6 of the PCN Form.
C. PROPOSED IMPACTS INVENTORY
The ACP pipeline facilities, access roads, and aboveground facilities will require a total
of 563 single and complete projects across waters of the U.S. in North Carolina, detailed within
Appendix C-1. Appendix C provides details of wetlands that include location information,
HUC 8 codes, wetland type classifications, and an analysis of impacts proposed, and details of
waterbodies that include location information, HUC 8 codes, state special designations, tributary
information, and an analysis of impacts proposed. AP -2 and AP -3 cross a total of 10 HUC 8
watersheds across North Carolina. The HUC 8 watersheds and the impacts anticipated for
wetlands and waterbodies crossed by the pipeline workspace are summarized in tables 3 and 4,
below. No permanent loss to wetlands or waterbodies is anticipated for mainline pipeline
construction or associated facilities. However, permanent loss impacts to 0.80 acres of wetlands
are proposed for construction and improvements to permanent access roads in the Wilmington
District, as discussed below in the subsection on Access Roads and Aboveground Facilities.
Outside of the 30 -foot maintained right-of-way, Atlantic will replant non -inundated forested
deciduous hardwood wetlands. Temporary wetland impacts, conversion of type impacts, and
permanent losses are noted below for HUC 8 watersheds and in Appendix C-1 for individual
projects (crossings). A summary of single and complete projects can be found in Appendix C-2.
Table 3 provides a summary of the proposed wetland impacts within eight -digit HUC
watersheds crossed by the ACP in the Wilmington District. -f
Atlantic Coast Pipeline 29

Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information
U.S. Army Corps of Engineers - Wilmington District
TABLE 3
Atlantic Coast Pipeline Project - U.S. Army Corps of Engineers Wilmington District
RUC 8 Wetland Impacts Table
Cowardm
HUC 8 Watershed
03010107
Conversion Impacts
Permanent Loss
Classification'
Subtotal
(acre)b
03010204
(acre)
PEM
374
Subtotal
000
03020101
PFO
4,118
843
Subtotal
000
03020102
135
034
003
Subtotal
03020201
9.60
2.91
0.00
Subtotal
/-1
03020203
000
000
PFO
9,983
2205
799
Subtotal
PSS
03030004
057
005
000
Subtotal
14,204
03030005
8.04
0.01
PEM
Subtotal
139
03030006
000
PFO
23,719
Subtotal
1632
03040203
PSS
116
021
Subtotal
000
Project
Total
TABLE 3
Atlantic Coast Pipeline Project - U.S. Army Corps of Engineers Wilmington District
RUC 8 Wetland Impacts Table
Cowardm
Crossing Length
Temporary Impacts
Conversion Impacts
Permanent Loss
Classification'
(feet)
(acre)b
(acre)`
(acre)
PEM
374
084
000
000
PFO
4,118
843
287
000
PSS
135
034
003
000
4,626
9.60
2.91
0.00
PEM
4,003
433
000
000
PFO
9,983
2205
799
001
PSS
219
057
005
000
14,204
26.96
8.04
0.01
PEM
702
139
000
000
PFO
23,719
4121
1632
000
PSS
116
021
003
000
24,537
42.82
16.35
0.00
PEM
1,856
3 14
000
0 13
PFO
19,628
3406
1343
0 13
PSS
3,531
634
081
000
25,015
43.53
14.24
0.25
PEM
714
134
000
000
PFO
44,342
7958
30 19
017
PSS
2,340
448
054
000
47,396
85.41
30.72
0.17
PEM
139
0 18
000
000
PFO
24,929
4431
1715
000
PSS
360
065
008
000
25,428
45.14
17.23
0.00
PEM
91
016
000
000
PFO
5,196
983
357
000
PSS
257
046
006
000
5,545
10.45
3.63
0.00
PEM
0
043
000
000
PFO
17,571
3037
1203
000
PSS
978
181
023
000
18,549
32.61
12.25
0.00
PEM
1,518
467
000
003
PFO
34,727
5777
2340
000
PSS
10,342
1784
237
034
46,587
80.28
25.78
0.37
PEM
1,564
258
000
000
PFO
30,859
5530
2126
000
PSS
10,611
18 81
243
000
43,035
76.69
23.70
0.00
254,922
453.49
154.84
0.80
Indicates Cowardm classification PEM- emergent, PSS - scrub -shrub, PFO -forested
b Temporary impacts include all permanent, temporary, and extra temporary workspace
Conversion of PFO and PSS wetlands consists of acreage that will be maintained as herbaceous/scrub-shrub wetlands following
construction to facilitate inspection and maintenance of the pipeline
Note The totals shown in this table may not equal the sum of addends due to rounding
Atlantic Coast Pipeline
30

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Atlantic Coast Pipeline 31
Table 4 provides a
summary
of the waterbody impacts by eight -digit HUC watersheds
crossed by the
ACP.
TABLE
4
Atlantic Coast Pipeline
Project-- US Army Corps of Engineers Wilmington District
HUC 8 Waterbody Impacts in North Carolina
II
FeA1�%Y
Temporary
AffectedI
Waterbody
Permanent
Waterbody
Permanent
Length
4�f"
Impact
Impact
Approximate
Pipeline Centerline
within
Mainline
P V (acre)
J
(feet)
Waterbody
Total
Crossing Width
Workspace
HUC 8 Watershed
Type
Count
(feet)
(feet)
03010107
Ephemeral
1
3
124
000
0
Intermittent
11
65
1,432
000
0
Perennial
11
418
800
000
0
Open
17
N/A
Water/Pond
2
000
0
Subtotal
25
503
2,356
0.00
0
03010204
Ephemeral
4
19
344
000
0
Intermittent
7
27
488
000
0
Perennial
8
115
846
000
0
Subtotal
19
161
1,679
0.00
0
03020101
Ephemeral
1
3
767
000
0
Intermittent
9
44
900
000
0
Perennial
30
619
3,076
000
0
Open
Water/Pond
1
N/A
N/A
000
0
Subtotal
41
666
4,743
0.00
0
! �1
03020102
Ephemeral
1
0
107
000
0
Intermittent
18
67
1,969
000
0
Perennial
12
264
1,483
000
0
Subtotal
31
332
3,558
0.00
0
03020201
Ephemeral
4
7
560
000
0
Intermittent
21
87
2,184
001
31
Perennial
16
<2!�D ^ 138
1, 5
— 113 002
32
Open Water
4
N/A ---
N/A
1 000
1
0
Subtotal
45
442
4,294
0.02
63
03020203
Ephemeral
11
33
1,315
000
0
Intermittent
12
60
1,201
000
0
Perennial
15
198
1,760
000
0
Open
N/A
N/A
Water/Pond
3
000
0
Subtotal
41
291
4,198
0.00
0
03030004
Ephemeral
4
11
442
000
30
Intermittent
10
44
1,293
000
0
Perennial
10
147
1,046
001
31
Open
Water/Pond
1
N/A
N/A
0,00
0
Subtotal
25
203
2,780
0.01
61
03030005
Ephemeral
5
23
1,097
000
0
Intermittent
15
81
1,396
000
0
Perennial
14
506
1,426
001
30
Subtotal
34
610
3,918
0.01
30
03030006
Ephemeral
7
27
835
000
0
Intermittent
11
46
1,964
006
545
Perennial
14
467
1,944
002
67
Open
102
N/A
Water/Pond
2
000
0
Atlantic Coast Pipeline 31

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 4
Atlantic Coast Pipeline Project— U S Army Corps of Engineers Wilmington District
HUC 8 Waterbody Impacts in North Carolina
Subtotal
34
641
4,743
0.08
612
03040203
Ephemeral
5
26
540
000
0
Intermittent
17
80
1,813
000
0
Perennial
7
128
1,250
000
0
Open
28
N/A
Water/Pond
2
000
0
Subtotal
31
261
3,603
0.00
0
Project Total
3264,1
2
35,951 rf
0
7660.12 KJ_
Note The totals shown in this table may
' (7
not eoual the sum of due to
roundme
\[
Access Roads and Aboveground Facilities
Impacts resulting in loss of waters of til U.S. are not anticipated ��5; result of mainline
pipeline construction. However, loss of waters cif the U.S. will occur as�r� result of permanent
access road construction and improvements, where necessary. Existing access roads will be
utilized where feasible. Where improvements are necessary for use, loss impacts to waters of the
U.S. have been minimized to the maximum extent practicable, and kept below 0.5 acre for each
single and complete project.
Atlantic has designed access roads to minimize impacts on waterbody and wetlands.
Culverts will be installed to conform to NWP Regional Condition 3.6 Safe Passage
Requirements for Culvert Placement. Since the project does not cross coastal counties the
primary conditions include: proper sizing of culverts based on average historical low flow and
spring flow to minimize potential for altering the stream channel, and constructed in a manner
that minimizes destabilization and head cutting. Where culverts over 48 inches in diameter are
utilized the culvert will be buried at least one foot below the bed o the stream, and other_culvers
should be placed on the stream bed or buried to mailit-a-inacivatic passage. Where these
requirements cannot e met a waiver will be requested.
Aboveground facilities (i.e., compressor stations, M&R stations, and valves) have been
sited to avoid permanent wetland loss.
1. Impacts Summary
Ia. See Section Cla of the PCN Form.
2. Wetland Impacts
Impacts on wetlands are summarized in Tables 3 above, and provided in detail in
Appendix C-1.
3. Stream Impacts
Impacts on waterbodies are summarized in Table 4 above, and provided in detail in
Appendix C-1. Site specific plans for Section 10 waters are provided in Appendix F.
Section 10 waters within the Wilmington District include:
Atlantic Coast Pipeline 32

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
• Roanoke River at MP 9.8
• Neuse River at MP 98.5
• Cape Fear River at MP 154.2
4. Open Water Impacts
Impacts on Open Waters are summarized in Tables 4 above, and provided in detail in
Appendix C-1.
5. Pond or Lake Construction
No pond, lake, or impoundments are proposed to be constructed as part of ACP in North
Carolina. Temporary above -ground structures designed to hold water for hydrostatic testing will
be installed. These water holding containments will be filled by mechanical pumps from nearby
municipal water sources or approved surface waters. Therefore, NWP 2017-2022 condition 8,
which refers to impoundment of "waters of the U.S." and NWP 2017-2022 condition 24, which
refers to dam safety are not applicable to the Project. Hydrostatic test water requirements and
location of discharges can be found in Appendix O — Table 0-1.
6. Buffer Impacts (for DWQ)
AP -2 will cross riparian buffer zones within the Neuse and Tar -Pamlico river basins.
Based on coordination with the NCDEQ, waterbodies subject to the buffer rules are provided in
Table 5 below. Atlantic has worked closely with the NCDEQ staff to field verify waterbodies ("
that are subject to the buffer rule in the Neuse and Tar -Pamlico basins. On November 23, 2016
Atlantic submitted a compiled package of correspondence to the NCDEQ that documents
waterbodies subject to the riparian buffer rule. Subsequent to this submittal additional site visits
were completed and the NCDEQ replied with an additional letter. Documentation of site visits
and subject waters determinations are compiled for the NCDEQ convenience in Appendix I.
Atlantic utilized the determinations made with the NCDEQ to further evaluated impacts
within the buffers of subject waterbodies. According to 15A North Carolina Administrative
Code 2B.0233 (Neuse watershed) for waterbodies that are subject to the buffer rule, the
treatment of the buffer depends on whether or not the crossing is perpendicular to the
waterbody.6 Table 5 provides a summary of buffer Zone 1 and Zone 2 impacts for all
waterbodies subject to the rule, and provides a determination of those waterbodies that are
perpendicular versus not perpendicular.
6 Perpendicular crossings are defined as those that intersect the surface water at an angle between 75° and 105°
Atlantic Coast Pipeline 33

Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information
U.S. Army Corps of Engineers - Wilmington District
TABLES
North Carolina Riparian Buffer Impacts within the Tar -Pamlico and Neuse Watersheds'
Atlantic Coast Pipeline 34
Area of
Workspace
Workspace
Wetland
Area of Wetland
within Zone 1
within Zone 2
Overlap Zone 1
Overlap Zone 2
Buffer
Buffer
Buffer
Buffer
Watershed
MP
Unique ID
(Square Feet)
(Square Feet)
(Square Feet)
(Square Feet)
Required Mitigation
Tar -Pamlico
185
shlb050
9,765
5,443
0
0
37,460
185
shIg009
44,620
27,302
0
0
174,813
200
shIh008
4,673
3,116
4,673
3,116
0
205
sh1h007
7,347
4,997
0
0
29,537
228
shIh016
6,005
4,677
5,295
869
7,841
231
shlh017
5,454
4,426
5,454
4,426
0
240
shJg012
5,934
4,060
2,387
1,605
14,322
250
shlbloo
5,215
3,542
5,215
3,542
0
265
sh1h009
5,098
3,527
5,098
3,527
0
D�
A
274
277
shlh011
shlhol2
8,695
4,621
5,672
3,075
8,695
4,621
5,672
3,075
0
0
298
shla001
5,514
3,966
5,514
3,886
119
312
shl000l
382
1,280
350
372
1,455
312
shlo002
4,494
2,922
4,490
11799
1,698
334
shIh022
1,911
1,226
1,060
1,179
2,623
33 8
sh1g0ll
3,062
2,039
2,397
1,022
3,519
340
snag0ol
3,290
2,207
0
0
13,181
348
suag002
4,514
3,552
4,432
1,752
_2,945 _
494
snah002
7,709
5,347
0
0
31,147
40 6
snah003
3,266
2,149
0
0
13,022
®I
409
snah006
6,757
4,718
2,854
1,981
15,812
I416
snah0o5
5,551
3,970
3,345
1,353
10,542
417
snah004
5,631
3,883
5,620
3,134
1,156
420
snah029
5,030
3,301
3,630
1,635
6,699
421
snah025
24,489
12,254
23,331
8,841
8,594
422
suah026
7,261
4,465
5,927
2,754
6,568
428
snab103
5,440
4,074
3,246
284
12,267
440
snabl04
2,053
2,941
2,053
2,941
0
444
snabl05
1,563
2,721
1,563
2,379
512
445
snac0ol
7,688
6,838
6,839
3,473
7,593
448
snag012
5,966
5,481
5,377
4,317
3,512
454
onac002
688
688
0
472
snah008
7,642
5,030
1,482
130
25,833
476
snah010
8,395
4,811
0
0
32,402
DKSQNC_
488
002'
7,342
4,860
7,319
4,860
71
495
snah017
9,308
6,043
0
0
36,988
503
snag006
935
2,355
659
1,309
2,400
50 8
snag005
9,194
7,802
6,447
3,616
14,519
515
snag009
12,793
9,360
9,895
5,339
14,726
515
snag0ll
2
0
3
520
onag004
4,810
2,133
0
0
17,630
520
snab101
1,690
1,593
0
0
7,460
520
onag002
527
2,074
0
1,193
2,902
53 3
snah021
6,267
3,635
6,267
3,603
47
548
snah020
4,868
3,409
4,868
3,409
0
563
snah024
7,081
3,431
7,081
3,431
0
Atlantic Coast Pipeline 34

Nationwide Permit No. 12, Pre -Construction Notification - Supplemental Information
U.S. Army Corps of Engineers - Wilmington District
Atlantic Coast Pipeline 35
TABLES
North Carolina Riparian Buffer Impacts within the
Tar -Pamlico and
Neuse Watersheds'
Area of
Workspace
Workspace
Wetland
Area of Wetland
within Zone I
within Zone 2
Overlap Zone 1
Overlap Zone 2
Buffer
Buffer
Buffer
Buffer
Watershed
MP
Unique ID
(Square Feet)
(Square Feet)
(Square Feet)
(Square Feet)
Required Mitigation
567
snah022
42,834
18,619
42,834
18,619
0
57.1
snah019
5,596
4,082
5,596
4,082
0
58 8
snap004
5,405
4,477
1,912
215
16,874
594
snao011
4,097
2,713
424
104
14,933
Neuse
633
snao004
4,731
3,261
4,731
2,355
359
660
swio015
7,323
5,557
0
0
30,303
663
swio016
13,138
9,226
0
0
53,252
DKSQ_NC_
669
008'
6,695
4,452
6,695
4,452
0
678
swio002
4,694
3,129
4,689
2,880
388
691
swic004
523
1,833
0
0
4,319
691
swio004
17,632
11,909
11,651
2,678
31,790
693
swio005
5,989
3,862
5,989
3,862
0
697
swio007
5,027
3,931
4,066
1,598
6,384
704
swio009
5,769
3,989
4,083
1,620
8,612
705
swio008
6,458
5,009
2,141
725
19,378
710
swi0011
4,778
549
4,778
549
0
710
swio012
3,505
1,517
3,505
1,517
0
710
swio013
14,573
9,293
14,573
9,293
0
72 3
swic00l
-7,852
5,807
46
379
31,559
731
swib100a
10,041
8,913
6,947
1,310
20,688
732
swib100b
7,257
4,983
5,825
1,957
8,834
733
swibl00c
7,011
4,824
6,682
4,606
1,316
736
swic002
4,240
2,774
0
0
16,881
758
swip009
2,739
2,509
874
184
9,083
WeV b (
75 8
swip017
5,064
4,076
5,054
3,272
1,238
792
sjobl03
22,318
18,781
8,398
4,871
62,626
795
sjobl04
5,925
4,702
5,842
3,183
2,527
82 5
sjoe002
3,209
2,153
1,612
853
6,740
83 5
sjoe006
10,146
5,024
0
0
37,975
84 5
siop001
8,142
5,107
5,678
3,121
10,371
85 9
sjoo003
4,558
3,036
4,558
3,036
0
865
sjoo004
7,906
4,921
7,906
4,921
0
889
sjop005
8,635
7,749
0
0
37,528
89 8
sjop007
6,798
3,903
0
1,077
24,634
912
sjop009
1,747
9,158
0
425
18,342
921
sjopOl0
6,606
4,795
0
0
27,010
951
sjob011
5,408
4,576
5,408
3,408
1,753
DKSQ_NC_
953
009,
5,938
3,927
0
0
23,704
n( cc pp
95 3
sjop018
13,609
9,251
0
54,704
4102
GVH
4
sjob006
8,023
5,300
0
0
32,019
1028
sjob004
5,819
4,555
5,519
3,974
1,771
103 9
sjob003
4,870
3,142
4,870
3,142
0
107 7
sjob001
18
2,116
18
2,116
0
Atlantic Coast Pipeline 35

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLES
North Carolina Riparian Buffer Impacts within the Tar -Pamlico and Neuse Watersheds'
Area of
Workspace Workspace Wetland
Area of Wetland
within Zone I within Zone 2 Overlap Zone 1
Overlap Zone 2
Buffer Buffer Buffer
Buffer
Watershed MP Unique ID (Square Feet) (Square Feet) (Square Feet)
(Square Feet)
Required Mitigation
DKSQ_NC_
1103 010' 9,188 4,971 0
0
35,021
1103 sjop017 211 699 0
'I
0
1,683
1131 sjoo007 6,681 4,225 2,090
1,256
18,226
1137 sjoe007 262 5,590 262
5,590
0
TOTALS 655,608 459,896 362,742
203,743
1,262,826
("4gVgI y551315
' Feature extended subsequent to agency field review, requires confirmation with NCDEQ
Note The totals shown in this table may not equal the sum of addends due to rounding
D. IMPACT JUSTIFICATION AND MITIGATION
1. a.1 Avoidance and Minimization
For purposes of the USACE evaluation of single and complete projects, the "alternatives
analysis" is to ensure that the crossing of each wetland, stream and other waterbody is made in a
manner that avoids and minimizes impacts on the aquatic environment to the maximum extent
practicable, after considering the approach to the crossing in the uplands immediately adjacent to
the water of the United States. For example, to the extent practicable, crossings will be
perpendicular to the aquatic feature to minimize the length of the pipeline in the particular
aquatic system.
The FERC NEPA process includes the evaluation of alternative route alignments that
reduce the overall impacts on the human environment of the proposed pipeline including
avoiding and minimizing impacts to wetlands, streams, and other waterbodies. In addition all
crossings within the Wilmington District have been designed to meet NWP 12 criteria also
resulting in further avoidance and minimization of impacts. As background, information on the
FERC alternatives analysis follows, including discussion of the various alternatives FERC is
considering. The USACE is a cooperating agency on the FERC NEPA EIS and is working with
FERC to ensure that USACE comments regarding the overall pipeline alternatives analysis are
fully considered in that process. The fact that the ACP will be subject to an EIS does not
preclude the use of NWP 12 for the affected waterbody crossings. As provided for in the
USACE 2012 NWP Federal Register (FR) final NWPs:
"One commenter requested clarification that individual permits are not automatically
required for NWP 12 activities when a Corps district participates as a cooperating
agency for an environmental impact statement. [Response] "Even though an
environmental impact statement may be prepared for a particular utility line, the
National Environmental Policy Act process does not prohibit the Corps from using
NWP 12 to authorize the construction, maintenance, repair, and removal of utility lines
and associated facilities in waters of the United States, as long as the activity complies
with all applicable terms and conditions and results in minimal individual and
Atlantic Coast Pipeline 36

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
cumulative adverse effects on the aquatic environment. NEPA requires consideration of
all environmental impacts, not only those to aquatic resources, so there may well be
situations where aquatic impacts are minimal even though environmental impacts more
generally are not. These other environmental impacts would be addressed by the lead
agency preparing the environmental impact statement. " [77 FR, Vol 77, No. 34]
Atlantic will restore the wetlands to preconstruction elevations and will re -vegetate
emergent, scrub -shrub and forested wetlands within the 75 -foot construction corridor. In
addition, Atlantic has placed the following additional protective language into the landowner
easement agreements on parcels which contain waters of the US that are being negotiated for the
pipeline project. This language has been reviewed and approved by Wilmington District.
"If Local, State or Federally -regulated waters or wetlands (collectively and individually
"Regulated Waters or Wetlands') within the Permanent Easement or Temporary Easement are
disturbed by Grantee, Grantor acknowledges that Grantee may be required by law to restore
and/or re -vegetate any such disturbed Regulated Waters or Wetlands. Additionally, Grantor
agrees to: (a) cooperate with Grantee to ensure any such restored or re -vegetated Regulated
Waters or Wetlands are maintained as required by applicable laws; (b) notify Grantee
in advance of any proposed plans to disturb any Regulated Waters or Wetlands within the
Permanent Easement or Temporary Easement; and (c) notes Grantee of Grantor's efforts to
obtain any required permits, permit modifications and/or approvals, prior to conducting any
proposed disturbance of Regulated Waters or Wetlands within the Permanent Easement or
Temporary Easement. Grantor agrees that any permitting and/or disturbance of Regulated
Waters or Wetlands by Grantor within the Permanent Easement or Temporary Easement,
including any required mitigation and/or penalties, will be at Grantor's own risk and cost.
FERC NEPA ALTERNATIVES ANALYSIS INFORMATION
For purposes of the USACE evaluation of single and complete projects, the "alternatives
analysis" is to ensure that the crossing of each wetland, stream and/or other waterbody is made in
a manner that avoids and minimizes impacts on the aquatic environment to the maximum extent
practicable, after considering the approach to the crossing in the uplands immediately adjacent to
the water of the United States. For example, to the extent practicable, crossings will be
perpendicular to the aquatic feature to minimize the length of the pipeline in the particular
aquatic system.
As background, information on the FERC alternatives analysis follows, including
discussion of the various alternatives FERC is considering. Within the sections below, the
numbering of many of the referenced tables and figures has not been changed from their
numbering in the FERC documentation, to maintain consistency across documents
(e.g., Table 10.8.1-1, Figure 10.8.1-1, etc.).Atlantic has identified and evaluated a number of
alternatives to the proposed ACP. These include a no -action alternative; alternative energy
sources, including traditional and renewable sources; energy conservation measures; systems
alternative; and conceptual collocation route alternatives.
Atlantic Coast Pipeline 37

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
a.2 NEPA Alternatives from FERC Documentation
No Action Alternative to the ACP
Under the no -action alternative, the ACP would not be built and the environmental
impacts associated with construction and operation of the proposed facilities would not occur.
By not constructing this Project, however, Atlantic would be unable to meet its existing
customers' demands for natural gas and the projected demand by other industrial, commercial,
and domestic customers (including power -generating facilities) in Virginia and North Carolina.
The projected demand is due to a combination of population growth and displacement of coal-
fired electric power generation. In addition, other benefits from the ACP, such as future
economic development opportunities, reduced energy costs in the region, and the repowering of
coal-fired electric generation to gas-fired electric generation, would not be realized.
Under the no -action alternative, other natural gas transmission companies could propose
to construct new facilities similar to the ACP to meet the demand for new natural gas
transportation service in Virginia and North Carolina. Such actions would likely result in
impacts similar to or greater than those associated with the ACP, and might not meet Atlantic's
objectives to satisfy demand from existing customers within the proposed time frames. For these
reasons, the no -action alternative is not practical and provides no advantage over the Project.
Alternative Energy Sources to the ACP
The use of alternative energy sources is an option to meet some of the short-term and
long-term demands for energy in the target market areas. Potential alternative energy sources to
natural gas include traditional fuels, such as coal and oil, nuclear energy, and electricity
(including electricity generated from oil, coal, and nuclear power); and renewable energy
sources, such as wind, solar, hydroelectric, biomass, and tidal and wave. Like the ACP, all of
these alternative energy sources, depending on the location of the source, would require new
infrastructure, including transmission facilities, to connect supply and demand areas. Additional
information regarding the analysis of alternative energy sources is available in Resource
Report 10, Alternatives, filled with FERC as part of the licensing documentation, which is
available through the FERC Project Docket (No. CP15-554-000) to all cooperating agencies,
including the USACE.
Energy Conservation to the ACP
Energy conservation could help alleviate some of the growing demand for energy in the
United States and in the states/commonwealths to be serviced by the ACP. State/
commonwealth and federal energy conservation measures will likely play an important role in
slowing the growth of energy demand in the coming decades. However, it is unlikely that these
measures will offset the demand for new natural gas sources. The EIA predicts that United
States energy use per capita will decrease by approximately 8 percent through 2040, as higher
Atlantic Coast Pipeline 38

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
efficiency standards for vehicles and appliances take effect. Nevertheless, the EIA indicates that,
even with the recently enacted energy efficiency policies, total primary energy consumption,
including fuels used for electricity generation, will grow by 8.9 percent from 2013 to 2040.To
meet this demand, the EIA predicts that total domestic production of natural gas in the United
States will grow from 24.4 trillion cubic feet per year in 2013 to 35.5 trillion cubic feet per year
by 2040, and that shale gas production will make up 53 percent of total United States production
in 2040, up from 40 percent in 2012. The anticipated growth in natural gas demand will be
driven primarily by its increased use for electric power generation an industrial applications.
Reduction in the need for additional energy is the preferred option wherever possible.
Conservation of energy reduces the demand for limited existing reserves. Although energy
conservation measures will be important elements in addressing future energy demands, it is
unlikely that they will be able to offset more than a fraction of anticipated demand in the
foreseeable future. As a result, energy conservation alone (or in conjunction with other
alternatives) is not a viable alternative because it does not preclude the need for natural gas
infrastructure projects like the ACP to meet the growing demand for energy.
System Alternatives to the ACP
System alternatives would make use of other existing, modified, or proposed pipeline
systems to meet the same objectives as the ACP. Use of a system alternative would make it
unnecessary to construct all or part of the ACP, though modifications or additions to existing or
proposed systems could be required. The modifications or additions would result in _
environmental impacts that could be less than, similar to, or greater than those associated with I
the ACP.
Several existing, high-pressure, high-volume natural gas pipeline systems provide
transportation services to delivery points in the Mid -Atlantic and southeast regions. These
include Transco; Columbia Gas Transmission, LLC; and East Tennessee Natural Gas, LLC.
Additionally, several new pipeline projects have been proposed to provide natural gas
transportation service in the same regions, including the Spectra Energy Carolina Pipeline
Project; Mountain Valley, LLC Mountain Valley Pipeline Project; and Transco Appalachian
Connector Pipeline Project. Significant modifications to each of these systems would be
necessary to access the same supply areas and/or provide transportation service to the same
customers or at the same delivery points as the ACP. The environmental impacts associated with
the upgrades and new pipeline construction modifying existing or proposed systems would likely
be equal to or greater than those of the ACP. Therefore, the theoretical modifications to the
existing systems or proposed systems would provide no environmental advantage over the ACP.
FFr this reason, and the fact that the existing system does not meet the ACP's purpose and nee ,
se system alternatives are not considered viable alternatives to ACP.
U S Energy Information Administration 2015 Annual Energy Outlook 2015 with Projections to 2040 U S Department of Energy,
Washington, District of Columbia
Atlantic Coast Pipeline 39

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
�l -57 Conceptual Route Alternatives
Where practical, and depending on site-specific conditions, new natural gas transmission
pipelines can sometimes be collocated with existing linear corridor facilities (e.g., other
pipelines, electric transmission lines, highways, or railroads) to minimize impacts on
environmental and other resources. A pipeline is considered collocated with an existing linear
corridor facility if the new right-of-way for the pipeline is adjacent to or very near (within a few
hundred feet) of the existing facility. A pipeline can parallel an existing linear corridor facility
without being collocated with the existing facility, but this often results in multiple clear -cuts
along similar paths with no reduction in impacts on environmental and other resources.
The three criteria listed below are generally used to identify and evaluate opportunities to
route a new natural gas transmission pipeline adjacent to existing linear corridor facilities.
The location and orientation of existing facilities relative to the new pipeline. The
existing facilities must provide a relatively direct path between the proposed
receipt and delivery points for the new pipeline. Otherwise, routing adjacent to
these existing facilities increases the length of the pipeline, which results in
greater environmental impact and added cost to the project.
• The nature of terrain along existing facilities. In some areas, the landforms
crossed may not allow for the construction of a pipeline adjacent to an existing
facility due to factors such as side slope, limitations on the amount of space
available for new construction, or the orientation of landforms crossed.
• The nature of land uses along the existing facilities. Developed lands (including
residential, commercial, and industrial lands) are often found along linear corridor
facilities such as highways and railroads. Routing a new pipeline to avoid these
developed areas often results in parallel (as opposed to adjacent) alignments and
increases the length (and therefore the environmental impact and cost) of a new
pipeline.
In addition to these conceptual alternatives, Atlantic evaluated potential collocation
alternatives for the ACP in areas where existing pipelines, electric transmission lines, or roads
either intersect or run parallel to and near the proposed ACP. Potential route alternatives and
variations adjacent to existing facilities which would meet the purpose and need of the ACP and
avoid or minimize impacts are discussed below. Desktop review of other potential collocation
route alternatives identified significant impediments with the routes with regard to terrain,
existing developments, or increased length of the ACP.
4 Eastern and Western Conceptual Route Alternatives
During the initial planning stages for the ACP, Atlantic identified and evaluated two
conceptual route alternatives: an eastern route alternative and a western route alternative
(Figure 10.8.1-1). Both routes originate south of Clarksburg in West Virginia and terminate near
Lumberton in North Carolina, with laterals extending to Hampton Roads in Virginia and Clayton
in North Carolina. Comparative information on each route is provided in Table 10-8.1-1.
Atlantic Coast Pipeline 40

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
The eastern route alternative, including the laterals, measures approximately 538.0 miles
in length, of which 22.6 miles is adjacent to existing linear corridor facilities. It crosses
approximately 66.4 miles of Federal lands, including lands managed by the U.S. Forest Service,
U.S. Fish and Wildlife Service (FWS), U.S. Army, and National Park Service. The eastern route
crosses both the Blue Ridge Parkway and Appalachian Trail on Federal lands. The route crosses
2.8 miles of state/commonwealth lands, 12.2 miles of conservation easements, 328 miles of
forested land, 60.6 miles of wetland, and 362 perennial waterbodies. It additionally crosses
13.5 miles of areas identified as historic properties, historic landscapes, or historic landmarks,
consisting mostly of Civil War battlefields.
The western route alternative, including the laterals, measures approximately 607.2 miles
in length, of which 16.8 miles is adjacent to existing linear corridor facilities. The route crosses
68.4 miles of Federal lands, including lands managed by the U.S. Forest Service, FWS, U.S.
Army, USAGE, and National Park Service. Like the eastern route alternative, the western route
crosses both the Blue Ridge Parkway and Appalachian Trail on Federal lands. It crosses
7.0 miles of State/Commonwealth lands, 18.3 miles of conservation easements, 414.7 miles of
forested lands, 45.7 miles of wetland, and 425 perennial waterbodies. It also crosses 10.4 miles
of areas identified as historic properties, historic landscapes, or historic landmarks, mostly Civil
War battlefields.
Relative to the eastern route alternative, the western route alternative is approximately
69.2 miles longer and crosses 2.0 more miles of Federal lands, including lands managed by the
USACE, which the eastern route avoids. Both routes cross the Blue Ridge Parkway and
Appalachian Trail on Federal lands. The western alternative crosses 4.2 more miles of
State/Commonwealth land and 6.1 more miles of conservation easements than the eastern
alternative. The western alternative crosses 15.0 miles less of wetland and 3.1 miles less of
historic places, but 85.9 more miles of forested land and 63 more perennial waterbodies than the
eastern route.
TABLE 10 8 1-1
Eastern and Western Route Alternatives for the Atlantic Coast Pipeline
Features
Unit
Eastern Route a
Western Route
Length
miles
5380
6072
Primary U S or State/Commonwealth highways crossed
number
115
103
Adjacent to existing linear corridor facilities
miles
226
168
Federal lands crossed (total)
miles
664
684
National Park Service
miles
06
04
U S Forest Service
miles
469
440
U S Fish and Wildlife Service
miles
72
72
US Army
miles
117
140
U S Army Corps of Engineers
miles
00
28
Blue Ridge Parkway crossings
number
1
1
Appalachian Trail crossings
number
1
1
State/Commonwealth lands crossed (total)
miles
28
70
West Virginia
miles
00
00
Virginia
miles
02
00
North Carolina
miles
26
70
Conservation easements crossed
miles
122
183
Forested lands crossed
miles
3288
4147
Atlantic Coast Pipeline 41

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 10 8 1-1
Eastern and Western Route Alternatives for the Atlantic Coast Pipeline
Features Unit
Eastern Route a
Western Route
National Wetland Inventory wetlands crossed (total) miles
607
457
Forested miles
550
40 1
Emergent miles
47
40
Other miles
10
16
Intermittent waterbodies crossed number
342
481
Perennial waterbodies crossed number
362
425
Historic properties, historic landscapes, and historic landmarks crossed miles
135
104
a The eastern route alternate is similar, but not identical, to the baseline route for the ACP The eastern route alternative was refined
into the baseline route based on customer needs and identification of delivery points for the ACP
In addition, after the receipt and delivery points were confirmed for the ACP, it was
determined that the western route alternative does not provide a direct connection to the deliver
point in Randolph, County, West Virginia (i.e., the Long Run M&R Station), or to the receipt
and delivery point in Buckingham County, Virginia (i.e., Compressor Station 2). Additional
laterals would need to be built to reach these locations if the western route was selected as t e
preferred alternative. Depending on the routes selected, these laterals would add an additional 75
to 85 miles of oineline to the ACP, which would result in greater environmental impact and
additional cost.
For all these reasons, Atlantic identified the eastern route as the preferred alternative for
the ACP. This route subsequently was refined into the baseline route for the ACP.
Southern Conceptual Route Alternative
The southern conceptual alternative route originates approximately at MP 6.0 of the
currently proposed AP -3 lateral route in Northampton County, North Carolina (see
Figure 10.8.1-20). From this point, the conceptual route heads due east for approximately
64 miles crossing Northampton, Hertford, Gates, Pasquotank, and Camden Counties, North
Carolina, passing south of the Great Dismal Swamp National Wildlife Refuge (GDS-NWR) and
Dismal Swamp State Park. The conceptual route then heads north for approximately 20 miles,
crossing Camden County, North Carolina and the City of Chesapeake, Virginia, passing east of
the GDS-NWR. The route terminates approximately at MP 79.2, on the east side of the Southern
Branch Elizabeth River. The conceptual route is approximately 13 miles longer than the
corresponding segment of the GDS 1 route.
Although the southern conceptual route alternative avoids the GDS-NWR, construction
along this route would result in an additional 13 miles of impacts, including crossings of many
miles of wetlands along the Chowen River, in the area south of the Dismal Swamp State Park,
and along the Pasquatank River. Based on National Wetlands Inventory data, the southern
conceptual route crosses approximately 30.6 miles of wetlands, while the corresponding segment
of the currently proposed route crosses approximately 20.1 miles of wetlands. The southern
conceptual route additionally crosses large blocks of land identified by The Nature Conservancy
(TNC) as sensitive floodplain forest in areas south and east of the GDS-NWR. Also, the
southern conceptual route alternative is almost entirely a greenfield corridor, as there are no
existing pipelines, electric transmission lines, railroads, or major roads to follow in the vicinity
Atlantic Coast Pipeline 42

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
of the route. By contrast, the corresponding segment of the proposed route is collocated with
existing linear corridor facilities for approximately 13 miles.
Because the southern conceptual route is longer and would result in greater impacts than
the currently proposed route, particularly to wetlands, the route is not considered a viable
alternative.
MAJOR ROUTE ALTERNATIVES
Atlantic identified initial or "baseline" routes for the proposed ACP and SHP pipelines
based on locations of receipt and dEf very points, engineering and constructability criteria,
terrain, and existing land use. Atlantic subsequently evaluated environmental and other_
constraints along each -of the routes in an effort to refine the baseline configurations. Route
alternatives, -variations, and minor adjustments were identified based on a review of desktop
constraint data, consultations and discussions with agency staff or other stakeholders, and field
review in an effort to optimize the routes. The objective of the process was -to identify the
shortest possible route between the proposed receipt and delivery points taking into account the
ACP purpose and need, engineering constraints, crossings of public lands, issues identified by
stakeholders, and the potential for impacts on sensitive environmental resources. 8
1
8 The mileposts depicted on the figures in this and subsequent sections of this document are based on three-dimensional modeling of the
proposed routes, which takes into account changes in elevation along the routes As a result, the distance between two mileposts may be
greater than 1 mile (5,280 feet) in length Measurements of feature crossings along the proposed and alternative routes are based on two-
dimensional crossing lengths so comparisons between the proposed and alternative routes are comparable and normalized
Atlantic Coast Pipeline 43

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
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Atlantic Coast Pipeline 44

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DRAWN BY: THohn

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Atlantic's analysis of route alternatives and variations used a geographic information
system (GIS) to characterize crossings of environmental features and other constraints along the
routes. A digital centerline for each route alternative and the corresponding segment of the
baseline was compared with a variety of datasets and map resources in the GIS. Features and
constraints considered in the analysis included: length, public lands crossed, roads crossed,
conservation easements crossed, forested lands crossed (based on the National Land Cover
Database), wetlands crossed (based on the NWI), waterbodies crossed (based on the National
Hydrography Dataset), and known cultural resources sites crossed, such as Civil War
battlefields.
Once a baseline route was determined using desktop data, a field oriented routing team
consisting of a lead construction router, civil survey staff, and an ecological specialist adjusted
the route based on site-specific conditions while weighing competing constraints associated with
environmental, tribal, and historical resource protection, constructability, available technology,
and logistical constraints. Where practicable, adjustments to the route were made to avoid and/or
minimize impacts on wetlands and waterbodies.
t Johnston County, North Carolina Major Route Alternative
Atlantic identified and evaluated an alternative route for the AP -2 mainline at the request
of the Johnston County, North Carolina Economic Development Authority in an effort to move
the pipeline closer to existing industrial properties along the I-95 corridor and U.S. Highway 701
south of the town of Four Oaks. The Johnston County Economic Development Authority would
r- } like to introduce natural gas into the industrial park. The baseline route for the AP -2 mainline in
1 this area crosses Johnston County east of the towns of Smithfield and Four Oaks.
Beginning at MP 92.9 near Smithfield, the alternative route follows an existing electric
transmission line southwest of the baseline for approximately 7 miles to a point just south of
Four Oaks. The route then heads to the south-southwest for approximately 14 miles, where it
rejoins the baseline west of Jumping Run Swamp at MP 114.5. The baseline and Johnston
County route alternative are depicted on Figure 10.8.1-14, and comparative information on each
route is provided in Table 10.8.1-12.
TABLE 10 8 1-12
Johnston County Major Route Alternative for the Atlantic Coast Pipeline
Features
Unit
Baseline (Proposed) Route
Johnston County Route Alternative
Length (total)
miles
215
207
Primary U S or State highways crossed
number
7
7
Other State or local roads crossed
number
23
22
Adjacent to existing linear corridor facilities
miles
00
6 1
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Conservation easements crossed
miles
00
00
Forested land crossed
miles
80
54
Wetlands crossed — forested/shrub
miles
25
07
Intermittent waterbodies crossed
number
33
28
Perennial waterbodies crossed
number
8
8
Bentonville Battlefield (total)
miles
0 1
02
Atlantic Coast Pipeline 46

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
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Atlantic Coast Pipeline 47

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
The Johnston County route alternative is approximately 4.0 miles closer to the town of
Four Oaks than the baseline. Consistent with this proximity, the proposed alternative route
crosses 239 parcels of property, compared to the baseline route which affects 163 parcels.
The alternative route is 0.8 mile shorter and crosses 2.6 fewer miles of forested lands and
1.8 fewer miles of forested wetland than the baseline. Of particular note, the alternative route
minimizes the crossing of a forested wetland complex adjacent to the Neuse River. Both routes
cross a portion of the Bentonville Battlefield area, though the alternative crosses 0.1 mile more
than the baseline. Both routes cross similar numbers of roads and waterbodies; however, the
alternative route would involve more difficult construction with regard to crossing existing
utilities.
As noted above, the alternative route is adjacent to an existing electric transmission line
for approximately 6.1 miles. The towers for the power line are anchored by guy wires, which
could require shifting the pipeline further away from the electric transmission line. This would
reduce the benefits of collocation, such as use of previously cleared areas for workspace or
temporary sidecast storage during construction.
Representatives of the Johnston County Economic Development Authority met with
Piedmont, the local distribution company and both a partner and customer of the ACP, to discuss
the natural gas supplies that will be provided by the Project. Based on this meeting, the Johnston
County Economic Development Authority stated that it is satisfied that the current proposed
route will support the County's interests in getting new supplies of natural gas to its targeted
industrial zones.
Balancing the various considerations presented, Atlantic retained the baseline route in
this area.
-�L, Progress Energy Carolinas Collocation Major Route Alternative
Atlantic evaluated an alternative for the AP -2 mainline route adjacent to an existing
Progress Energy Carolinas 500 kV electric transmission line in Cumberland County, North
Carolina. Atlantic worked closely with the Wilmington District to evaluate alternatives
associated with the Progress Energy Carolinas route alternative. During a meeting on January
28, 2016, Atlantic introduced the general concept of the route alternative that would increase
collocation, while potentially result in crossing of additional wetlands. On February 12, 2016
Atlantic provided the Wilmington District a map depicting the route alternative and included a
table comparing routing constraints, similar to the Table 10.8.1-13, below. Based on feedback
from the Wilmington District, as well as the preferred collocation and other routing constraints,
Atlantic adopted the route alternative as the proposed ACP route in this area.
The baseline route in this area extends to the south/southeast generally parallel to the I-95
corridor on the east side of Fayetteville. Starting approximately at MP 125.3 near an intersection
with I-95, the alternative route adjacent to Progress Energy Carolinas initially heads south for
approximately 8.1 miles to a point south of U.S. Highway 13. It then heads south for
approximately 17.3 miles, crossing Clinton Road, Cedar Creek Road, and Tabor Church Road.
The route then turns to the west for approximately 5.2 miles, crossing the Cape Fear River and
i North Carolina State Highway 87, reconnecting with the baseline route at MP 157.5. The
Atlantic Coast Pipeline 48

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
baseline route and the Progress Energy Carolinas Major Route Alternative are depicted on _
Figure 10.8.1-15, and comparative information on each route is provided in Table 10.8.1-13.
TABLE 10 8 1-13
Progress Energy Carolinas Collocation Major Route Alternative for the Atlantic Coast Pipeline
Baseline
Progress Energy Carolinas
Features
Unit
Route
Collocation Route Alternative
Length
miles
320
303
Primary U S or State highway crossed
number
12
9
Other State or local roads crossed
number
37
23
Adjacent to existing linear corridor facilities
miles
15
3030
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
320
303
Conservation easements crossed
miles
00
00
Forested uplands crossed (not including forested wetlands)
miles
' 6 1
1 1
Wetlands crossed — forested/shrub
miles
3
7
Wetlands crossed — freshwater emergent
miles
<0 1
0
Wetlands crossed — other
miles
01
01
Intermittent waterbodies crossed
number
14
5
Perennial waterbodies crossed
number
33
27
The baseline route is 1.7 miles longer than the alternative route. Both the baseline and
alternative avoid Federal and State lands, as well as conservation easements. The baseline route
crosses 15 more waterbodies than the route alternative, six of which are perennial waterbodies.
However, the alternative route crosses 4.3 more miles of wetland (an additional 24.8 acres), most
of which is forested wetland. Many of the wetland complexes along the alternative route are
large forested wetlands greater than 100 acres in size. Collocation of the AP -2 mainline with the
Progress Energy Carolinas line would cause significant additional impacts on these forested
wetland areas, as additional tree clearing along the maintained transmission line corridor would
be required to install the pipeline adjacent to the high-voltage electric transmission line.
Even though the Progress Energy Carolinas route alternative would be collocated with an
existing corridor, it would require substantially more disturbance and permanent clearing of
forested wetlands than the baseline route. For this reason, Atlantic retained the baseline route in
this area.
'1 Meherrin River Major Route Alternative
In a letter dated September 8, 2014, and in a meeting on November 12, 2014, The Nature
Conservancy asked Atlantic to consider an alternative route for the proposed AP -3 lateral to
avoid or minimize crossings of the Meherrin River and Fountains Creek watersheds in
southeastern Virginia. These watersheds are part of TNC's Albemarle Sound Whole System
project area, which encompasses approximately 6 million acres of freshwater -dominated
estuarine habitat in southeastern Virginia and northeastern North Carolina. TNC states that the
Albemarle Sound System contains "areas of large intact wetland forest that support high levels of
use by migratory and breeding birds and buffer some of the best migratory fish spawning and
nursery habitats on the East Coast." TNC has worked with public agencies, corporations,
landowners, and communities to protect and restore public and private lands in this area.
Atlantic Coast Pipeline 49

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
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Atlantic Coast Pipeline 50

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
The baseline route for the AP -3 lateral crosses floodplain forest in the Meherrin River
and Fountains Creek watersheds between MPs 0.0 and 12.0, including areas which TNC has
recommended for avoidance. Atlantic identified and evaluated a route alternative which avoids
Fountains Creek altogether and minimizes crossings of floodplain forest in areas recommended
by TNC for avoidance. The baseline route and Meherrin River Route Alternative are depicted on
Figure 10.8.1-16, and comparative information on each route is provided in Table 10.8.1-14.
The baseline route for the AP -3 lateral trends southwest to northeast across Greensville
and Southampton Counties, Virginia, crossing Fountains Creek approximately 4.7 miles from the
AP -1 mainline and the Meherrin River just north of Haley's Bridge approximately 8.4 miles
from the AP -1 mainline. Starting at Compressor Station 3, the Meherrin River Route Alternative
initially extends to the east-southeast for approximately 5.8 miles across Southampton County,
North Carolina, passing south of the Fountains Creek watershed. It then heads to the northeast
for approximately 7.6 miles, mostly adjacent to existing power lines, roads, or railroads. It
crosses the Meherrin River along the Virginia Commonwealth/North Carolina State line adjacent
to an existing railroad. The alternative route then heads north-northeast for approximately
3.4 miles, where it intersects the baseline route in Southampton County, Virginia.
Atlantic Coast Pipeline 51
TABLE 10 8 1-14
Meherrin River Major
Route Alternative for the Atlantic Coast Pipeline
Baseline
Meherrin River Route
Features
Unit
Route
Alternative
Length
miles
147
168
Primary U S or State highway crossed
number
1
2
Other State or local roads crossed
number
20
19
Adjacent to existing linear corridor facilities
miles
00
68
Federal lands crossed
miles
00
00
State lands crossed
miles
00
<0 1
Private lands crossed
miles
147
168
Conservation easements crossed
miles
00
<0 1
Forested lands crossed
miles
36
35
Wetlands crossed — freshwater emergent
miles
00
03
Wetlands crossed — freshwater forested/shrub
miles
65
62
Wetlands crossed — other
miles
00
0 1
Intermittent waterbodies crossed
number
9
7
Perennial waterbodies crossed
number
13
14
TNC floodplain forest recommended for avoidance
miles
41
14
The baseline route for the AP -3 lateral trends southwest to northeast across Greensville
and Southampton Counties, Virginia, crossing Fountains Creek approximately 4.7 miles from the
AP -1 mainline and the Meherrin River just north of Haley's Bridge approximately 8.4 miles
from the AP -1 mainline. Starting at Compressor Station 3, the Meherrin River Route Alternative
initially extends to the east-southeast for approximately 5.8 miles across Southampton County,
North Carolina, passing south of the Fountains Creek watershed. It then heads to the northeast
for approximately 7.6 miles, mostly adjacent to existing power lines, roads, or railroads. It
crosses the Meherrin River along the Virginia Commonwealth/North Carolina State line adjacent
to an existing railroad. The alternative route then heads north-northeast for approximately
3.4 miles, where it intersects the baseline route in Southampton County, Virginia.
Atlantic Coast Pipeline 51

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
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Atlantic Coast Pipeline 52

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
The Meherrin River Route Alternative is 2.1 miles longer than the baseline, but avoids
Fountains Creek and crosses 2.7 miles less of floodplain forest areas recommended for avoidance
by TNC. About 70 percent (1.0 mile) of the floodplain forest along the alternative route occurs
at the Meherrin River crossing, which is adjacent to an existing railroad. This will minimize
impacts in the watershed due to forest fragmentation. The alternative route additionally is
adjacent to existing linear corridor facilities (power lines and roads) for approximately 6.8 miles
(40 percent) compared to 0.0 miles for the baseline. The baseline avoids conservation
easements, while the alternative route crosses within less than 0.1 mile of a North Carolina
Department of Environmental Quality conservation easement. 9 Crossings of forested lands,
wetlands, and waterbodies are similar for both routes.
Based on the feasibility of collocation with other utility corridors in this area, and the
relative similarity of the impact on other major resource considerations, Atlantic incorporated the
Meherrin River Route Alternative into the proposed route.
3 Northampton Major Route Alternative
Atlantic identified and evaluated two major route alternatives (Northampton 1 and
Northampton 2) at the beginning of the AP -3 lateral in Northampton County, North Carolina,
portions of which parallel an existing DVT 115 kV electric transmission line. Northampton 1
initially follows the proposed AP -2 mainline south of Compressor Station 3 for approximately
4.3 miles, and then follows the existing electric transmission line for about 7.8 miles to the
northeast. Northampton 2 would require moving Compressor Station 3 from its current proposed
site to a new location in Northampton County near MP 4.3 of the AP -2 mainline, and then follow
the existing electric transmission line from this new site for about 7.8 miles to the northeast. The
baseline and alternative routes are depicted on Figure 10.8.1-17, and comparative information on
each route is provided in Table 10.8.1-15.
TABLE 10 8 1-15
Northampton Major Route Alternative for the Atlantic Coast Pipeline
Baseline
Northampton I Route
Northampton 2 Route
Features
Unit
Route
Alternative
Alternative
Length
miles
61
121
78
Primary U S or State highway crossed
number
0
0
0
Other State or local roads crossed
number
7
14
4
Adjacent to existing linear corridor facilities
miles
00
78
78
Adjacent to proposed linear corridor facilities
miles
00
42
00
Federal lands crossed
miles
00
00
00
State lands crossed
miles
00
00
00
Conservation easements crossed
miles
00
00
00
Forested lands crossed
miles
26
55
14
Wetlands crossed — freshwater emergent
miles
00
01
0 1
Wetlands crossed — freshwater forested/shrub
miles
09
12
08
Intermittent waterbodies crossed
number
4
6
3
Perennial waterbodies crossed
number
1
3
2
TNC floodplain forest recommended for avoidance
miles
03
05
00
9 Atlantic is current evaluating route variations to avoid this easement
Atlantic Coast Pipeline 53

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
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Atlantic Coast Pipeline _54
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Figure 10.8.1-17
Northampton Route Alternative 1
Major Route Alternatives
Northampton Route Alternative
Northampton
FILE: M:1ClienWD-FOOM\SRPP1 AmGIS%Resoume ReportstRREP lOTiguresl ACP RR10 Northampton Maior RA. mad. REVISED: OR!2812015. SCALE- 1.70.000
DRAM BY., THohl
Atlantic Coast Pipeline _54

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
At 6.1 miles in length, the baseline is the shortest of the three routes, though none of the
baseline is adjacent to existing linear corridor facilities. The baseline crosses four waterbodies,
including two perennial waterbodies, 0.9 mile of wetlands, and 2.6 miles of forested land. The
baseline additionally crosses 0.3 mile of floodplain forest areas identified by TNC, mostly along
Jacks Swamp. It avoids crossings of State lands and conservation easements.
At 12.1 miles in length, Northampton 1 is 6.0 miles longer than the baseline. About
4.2 miles of the route is adjacent to the proposed AP -2 mainline and 7.8 miles is adjacent to the
existing electric transmission line. The route crosses five waterbodies, including three perennial
waterbodies, 1.3 miles of wetlands, and 5.5 miles of forested land. Of these, one perennial and
three intermittent waterbodies, 0.4 mile of wetlands, and 4.1 miles of forested land are adjacent
to the AP -2 mainline; the remainder are along the existing electric transmission line. The route
alternative crosses 0.5 mile of floodplain forest areas identified by TNC along Jacks Swamp (all
adjacent to the AP -2 mainline). Like the baseline, the alternative route avoids State lands and
conservation easements.
In a letter filed with the FERC, the North Carolina Wildlife Resources Commission
suggested avoiding crossings of Cypress Creek by shifting the route for the AP -3 lateral farther
to the north. The proposed route for the AP -3 lateral crosses Cypress Creek at four locations.
These crossings resulted from the Meherrin River Major Route Alternative (see
Section 10.8.1.13 above), which was designed to avoid sensitive floodplain forest areas along the
Meherrin River and Fountains Creek. Relative to the baseline, Northampton 1 would result in
one additional crossing of Cypress Creek in addition to a crossing of a tributary (Ivy Creek)
approximately at its confluence with Cypress Creek at Jordan's Mill Pond. The baseline route
avoids both Ivy Creek and Jordan's Mill Pond.
Relative to the baseline, Northampton 1 is longer and crosses more waterbodies and more
miles of wetlands, forested land, and floodplain forest areas than the baseline (though some of
the crossings occur along the segment of the route alternative adjacent to the AP -2 mainline).
The alternative route additionally adds a crossing of Cypress Creek and a tributary relative to the
baseline. For all these reasons, Northampton 1 provides no environmental advantage over the
ACP as proposed.
As noted above, Northampton 2 would require moving the location of Compressor
Station 3 to a new site. This would require 4.3 miles of AP -2 to be upsized to 42 -inch -diameter
pipeline and an additional 2.0 miles in the length of the AP -3 lateral. These modifications could
require changes in the location or configuration of other aboveground facilities for the Project.
Additionally, the new site would be in actively cultivated farmland, which would require a
permanent conversion of farmland to developed land. In contrast, the proposed site is located on
recently replanted commercial timber land. Atlantic additionally notes that the landowner of the
preferred site has indicated a willingness to sell the property as evidenced by the execution of an
option agreement for the property.
At 7.8 miles in length, Northampton 2 is 1.7 miles longer than the baseline, though the
entire route is adjacent to the existing electric transmission line. Northampton 2 crosses five
waterbodies, including two perennial waterbodies, 0.8 mile of wetlands, and 1.4 miles of forested
land, all of which are similar to the baseline. The route avoids floodplain forest areas identified
Atlantic Coast Pipeline 55

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
by TNC, but requires an additional crossing of Cypress Creek and a tributary (Ivy Creek)
approximately at its confluence with Cypress Creek at Jordan's Mill Pond. The baseline route
avoids both Ivy Creek and Jordan's Mill Pond. Like the baseline and Northampton 1,
Northampton 2 avoids State lands and conservation easements.
Relative to the baseline, Northampton 2 is longer, crosses one additional perennial
waterbody, and results in an additional crossing of Cypress Creek and a tributary. Northampton
2 would require moving Compressor Station 3 to a new site, which would require approximately
4.3 miles of AP -2 to be upsized to 42 -inch -diameter pipeline and increase the length of the AP -3
lateral by about 2.0 miles. These changes in the configuration of the ACP potentially could
require changes in the location or configuration of other aboveground facilities. Additionally,
the new site for the compressor station would permanently encumber actively cultivated areas,
whereas the proposed site is located in a commercial timbering area. For all these reasons,
Northampton 2 provides no environmental advantage over the ACP as proposed.
Based on the above analysis and discussion, Atlantic retained the baseline route in this
area.
ROUTE VARIATIONS IN NORTH CAROLINA
Atlantic identified and evaluated a number of route variations designed to avoid or
minimize impacts on geographically distinct and localized resources, such as conservation
easements, cultural resource sites, and wetlands. Route variations were also considered to
r` resolve engineering or constructability issues or address stakeholder concerns, where feasible.
The route variations measured between approximately one and five miles in length and passed
within a couple miles of the baseline route. The primary criterion for comparing route variations
to the baseline route was cumulative impact avoidance relative to the objective of the route
variation. Similar to the major route alternatives described above, if a route variation was
adopted, it became part of the proposed route and the corresponding segment of the baseline
route was rejected. Descriptions of each route variation are provided in the subsections below.
Geenex Route Variation
Atlantic identified and evaluated a route variation approximately between MPs 4.3 and
7.5 of the AP -2 mainline in Northampton County, North Carolina, to avoid a property with the
option site of a future solar power generation development (see Figure 10.9.1.11 and
Table 10.9.1.11). Relative to the baseline route, the Geenex Route Variation heads southwest
from Cornwallis Road, then heads south and crosses Highway 301 where it rejoins the baseline
east of Garysburg, North Carolina. The Geenex route variation is 0.9 mile longer than the
baseline, but it avoids the option site for the future solar development. The route variation
additionally reduces wetland impacts by 0.3 mile and avoids five intermittent waterbody
crossings, but it increases crossings of forested land by 0.4 mile. Atlantic incorporated the
Geenex Route Variation into the proposed route because it avoids the option site for the future
solar development and reduces wetland and waterbody impacts.
Atlantic Coast Pipeline 56

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
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Atlantic Coast Pipeline 57

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 10 9 1-11
Geenex Route Variation for the Atlantic Coast Pipeline
Features
Unit
Baseline Route
Geenex Route Variation (Proposed)
Length
miles
26
35
Roads crossed
number
7
5
Adjacent to existing linear corridor facilities
miles
00
00
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
26
35
Conservation easements crossed
miles
00
00
Forested land crossed
miles
05
09
Wetlands crossed — freshwater forested/shrub
miles
03
00
Intermittent waterbodies crossed
number
5
0
Perennial waterbodies crossed
number
0
0
Mush Island Route Variation
Atlantic identified a route variation between MPs 11.1 and 12.5 of the AP -2 mainline
route in Halifax County, North Carolina to avoid a conservation easement enrolled in the U.S.
Department of Agriculture's Natural Resources Conservation Service's (MRCS) Wetland
Reserve Program (see Figure 10.9.1-12 and Table 10.9.1-12). Relative to the baseline route, the
Mush Island Route Variation initially extends to the southwest of the baseline route for
approximately 0.7 mile, and then turns due south for another 0.7 mile back to the baseline. The
route variation is approximately 0.2 mile longer than the baseline route, but it avoids the
conservation easement. The route variation additionally crosses approximately 0.6 mile more of
forested land, 0.2 more mile of wetland, and one more intermittent waterbod . _Because it avoids
the conservation easement, however, Atlantic incorporated the Mush Island Route Variation into
the proposed route.
TABLE 10 9 1-12
Mush Island Route Variation for the Atlantic Coast Pipeline
Features
Unit
Baseline Route
Mush Island Variation (Proposed)
Length
miles
12
14
Roads crossed
number
1
1
Adjacent to existing linear corridor facilities
miles
00
00
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
12
14
Conservation easements crossed
miles
01
00
Forested land crossed
miles
04
10
Wetlands crossed — freshwater forested/shrub
miles
02
04
Intermittent waterbodies crossed
miles
00
<0 1
Perennial waterbodies crossed
number
1
2
Cumberland Church Battlefield study area
number
1
1
Atlantic Coast Pipeline 58

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
v _
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Atlantic Coast Pipeline 5 9

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Halifax Route Variation
Atlantic evaluated a route variation (the Halifax Route Variation) approximately between
MPs 19.1 and 21.1 of the AP -2 mainline in Halifax County, North Carolina, in an effort to
reduce crossings of fo ed land (see Figure 10.9.1-13 and Table 10.9.1-13). Starting about
0.3 mi e east of Grapevine Road, the Halifax Route Variation initially heads south for 1.1 miles,
crossing State Route 561. It then heads west for 1.2 miles, crossing Marsh Swamp, and
terminating at the baseline just west of Justice Branch Road. The route variation reduces
crossings of forested land by 0.2 mile and wetlands by 0.1 mile, but is 0.4 mile longer and
crosses one more waterbody and one more road than the baseline. Because potential impacts for
both routes are similar, the route variation provides no environmental advantage over the
baseline. Therefore, Atlantic retained the baseline as the proposed route in this area.
TABLE 10 9 1-13
Halifax Route Variation for the Atlantic Coast Pipeline
Features
Unit
Baseline Route
Halifax Route Variation
Length
miles
19
23
Roads crossed
number
2
3
Adjacent to existing linear corridor facilities
miles
00
00
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
19
23
Conservation easements crossed
miles
00
00
Forested land crossed
miles
0 7
0 5
Wetlands crossed — freshwater forested/shrub
miles
03
02
Intermittent waterbodies crossed
number
1
2
Perennial waterbodies crossed
number
1
1
Battlefield study areas
miles
00
00
Breeches Swamp Route Variation
Atlantic identified a route variation between MPs 28.3 and 30.4 of the AP -2 mainline
route in Halifax County, North Carolina to avoid two conservation easements enrolled in the
MRCS's Conservation Reserve Program (see Figure 10.9.1-14 and Table 10.9. - . Starting at
a point just south of Ringwood Road, the Breeches Swamp Route Variation extends west of the
baseline route for approximately 0.7 mile, crossing I-95. It then heads due south for
approximately 1.4 miles parallel to and west of I-95, rejoining the baseline route approximately
0.3 mile south of Sneed Road. The route variation is approximately 0.2 mile longer than the
baseline route and crosses approximately 0.1 more mle of wetland, but it avoids
conservation easements, crosses mI e ess of forested land, and crosses oaQ less intam item
proposed route.
Atlantic Coast Pipeline 60
Route Variation into

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
ISA
J1 -
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Grove
9 = N
111
0 0.25 0.5
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COaA N Halifax Baseline Figure 10.9.1-13
Route Variation � t
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Atlantic Coast Pipeline 61

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
,
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Atlantic Coast Pipeline 62

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 10 9 1-14
Breeches Swamp Route Variation for the Atlantic Coast Pipeline
Features
Unit
Baseline Route
Breeches Swamp Route Variation (Proposed)
Length
miles
19
2 1
Roads crossed
number
4
6
Adjacent to existing linear corridor facilities
miles
00
00
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
19
21
Conservation easements crossed
miles
0 1
00
Forested land crossed
miles
04
03
Wetlands crossed — freshwater forested/shrub
miles
01
02
Intermittent waterbodies crossed
number
3
2
Perennial waterbodies crossed
number
1
I
Red Oak Route Variation
Atlantic identified a route variation (Red Oak 1) between MPs 42.5 and 45.9 of the AP -2
mainline route in Nash County, North Carolina, to avoid a former landfill (see Figure 10.9.1-15
and Table 10.9.1-15). Starting north of the town of Red Oak, Red Oak 1 initially heads southeast
for approximately 1.0 mile, and then turns south for approximately 1.5 miles, passing east of an
existing subdivision along Flat Rock Road and Red Oak Battleboro Drive. The route then heads
west for approximately 0.6 mile, rejoining the baseline at a point just north of Big Jim Road.
Atlantic Coast Pipeline 63
TABLE 10 9 1-15
Red Oak Route Variation for the Atlantic Coast Pipeline
Features
Unit
Baseline Route
Red Oak 1 Route Variation
Red Oak 2 Route Variation
Length
miles
22
32
34
Roads crossed
number
4
5
5
Adjacent to existing linear corridor
miles
00
00
00
facilities
Federal lands crossed
miles
00
00
00
State lands crossed
miles
00
00
00
Private lands crossed
miles
22
32
34
Conservation easements crossed
miles
<0 1
<0 1
00
Forested land crossed
miles
10
12
12
Wetlands crossed — forested/shrub
miles
02
02
02
Intermittent waterbodies crossed
number
3
4
3
Perennial waterbodies crossed
number
1
3
3
Historic landfill area
miles
0 1
00
00
Atlantic Coast Pipeline 63

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
i
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Coast Figure 10.9.1-15
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Red Oak Route Variation 1
Red Oak Route Variation :.•
♦ Red Oak Route Variation 2 ��
FILE: MNCIiealslD FOOMISRPP% AmGISIResoume Re orts%RREP Iffi rest ACP RR10 Red Oak.mxd, REVISEO: 0812412015, SCALE: 1:36,000 DRAWN BY: GIS
Atlantic Coast Pipeline 64

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Red Oak 1 avoids an approximately 0.1 mile long crossing of the Red Oak Landfill,
which operated from 1969 to 1977. The North Carolina Department of Environmental Quality
reported the one-time disposal of 135 pounds of pesticides and a three-year weekly disposal of
waste rags containing the solvent methyl isobutyl ketone at the landfill. Red Oak 1 is
approximately 1.1 mile longer than the baseline, but avoids the former landfill. Crossings of
other features are similar or identical for the two routes. In light of the avoidance of the former
landfill, and the similar impact on other major resource considerations, Atlantic initially
incorporated the Red Oak 1 Route Variation into the proposed route.
Subsequent to incorporation of the Red Oak 1 Route Variation, and based on the results
of civil surveys, Atlantic optimized Red Oak I into Red Oak 2. The optimized route is similar to
Red Oak 1, but it improves the crossing angle of Flat Rock Branch and also avoids paralleling
this creek. In addition, Red Oak 2 avoids an existing conservation easement, which is crossed by
both the baseline and Red Oak 1. Like Red Oak 1, Red Oak 2 avoids the former landfill. Other
environmental impacts are similar to the baseline and Red Oak 1. Therefore, Atlantic
incorporated the Red Oak 2 Route Variation into the proposed route.
City of Nashville Route Variation
Atlantic identified and evaluated a route variation for the AP -2 mainline route at the
request of the City of Nashville, in an effort to avoid the proposed route running between two
existing subdivisions on the south side of Oak Level Road (see Figure 10.9.1-16 and
Table 10.9.1-16). Starting at MP 50.3, the route variation initially heads south for approximately
1.5 miles, passing east of these subdivisions and crossing East Old Springs Hope and Oak Level
Roads. It then heads southwest for 2.2 miles, crossing North Carolina State Road 58, and
intersecting the baseline at MP 53.3. The City of Nashville Route Variation is approximately
0.7 mile longer than the baseline. It crosses 0.8 mile more of forested land, but 0.2 mile less of
forested wetland. While the route variation avoids the subdivisions west of East Old Spring
Hope Roads, it crosses between other subdivisions along Oak Level Road and Sherrod Road.
For these reasons, Atlantic retained the baseline route in this area.
TABLE 10 9 1-16
City of Nashville Route Variation for the Atlantic Coast Pipeline
City of Nashville Route
Features
Unit
Baseline Route
Variation
Length
miles
3 0
37
Roads crossed
number
4
5
Adjacent to existing linear corridor facilities
miles
00
00
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
30
37
Conservation easements crossed
miles
00
00
Forested land crossed
miles
05
13
Wetlands crossed — freshwater forested/shrub
miles
03
01
Intermittent waterbodies crossed
number
2
1
Perennial waterbodies crossed
number
0
1
Atlantic Coast Pipeline 65

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
m
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Figure 10.9.1-16
Pin „ /V City of Nashville Route City of Nashville; ,
Variation Route Variation©�
FILE: M:%COentslO-F10OM%SRPP AmGIS%Resouroe Re rts1RREP l0+Pi resl ACP RR10 CltyoNasnWlle.m d, REYISEO: 08!2412015. SCALE:1:34.202 ORAIAM 8Y: GIS
Atlantic Coast Pipeline 66

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers —Wilmington District
Little River Route Variation
In response to a meeting with the FWS and North Carolina Wildlife Resources
Commission, Atlantic identified the Little River Route Variation in Johnston County, North
Carolina (see Figure 10.9.1-17 and Table 10.9.1-17). Starting at MP 82.3, the route variation
heads to the southwest, crossing Little River, and passing south of Buffalo Creek before
terminating at MP 83.8. The route variation avoids Buffalo Creek, reduces crossings of wetlands
by 0.6 mile, reduces crossings of forested land by 0.4 mile, and is 0.2 mile shorter than the
baseline route. Atlantic incorporated the Little River Route Variation into the proposed route.
TABLE 10 9 1-17
Little River Route Variation for the Atlantic Coast Pipeline
Features
Unit
Baseline Route
Little River Route Variation
Length
miles
15
13
Roads crossed
number
1
1
Adjacent to existing linear corridor facilities
miles
00
00
Federal lands crossed
miles
00
00
State lands crossed
miles
00
00
Private lands crossed
miles
15
13
Conservation easements crossed
miles
00
00
Forested land crossed
miles
13
9
Wetlands crossed — freshwater forested/shrub
miles
09
03
Intermittent waterbodies crossed
number
0
0
Perennial waterbodies crossed
number
2
1
Swamp Road Route Variation
Atlantic identified a route variation between MPs 131.3 and 134.1 of the AP -2 mainline
route in Cumberland County, North Carolina to minimize crossings of forested wetland (see
Figure 10.9.1-18 and Table 10.9.1-18). Swamp Road Route Variation 1 generally parallels the
initial baseline route beginning at a point just north of River Road and extending 2.7 miles south-
southwest to Rick Walker Road. It passes east of a forested wetland near MP 131.1 and west of
a forested wetland near MP 132.0. It crosses 0.8 mile less of forested wetland, 0.6 mile less of
forested land, and three fewer perennial waterbodies than the baseline route. However, Swamp
Road Route Variation 1 reduced collocation with existing linear corridors by 0.7 mile.
Subsequent to evaluating Swamp Road Route Variation 1, Atlantic identified the Swamp
Road Route Variation 2 to avoid a planned housing development and to collocate the route with
an existing Piedmont natural gas pipeline. The route variation is 0.1 mile longer than the
baseline and Swamp Road Route Variation 1, but it is further away from a residence, avoids an
area for a planned housing development, and is collocated with an existing Piedmont pipeline for
0.6 mile. It also reduces wetland impacts by 0.4 mile compared to the baseline route (though it
would have greater impact than Swamp Road Route Variation 1). For all these reasons, Atlantic
incorporated Swamp Road Route Variation 2 into the proposed route.
Atlantic Coast Pipeline 67

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
J
tr (/
57
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jr
3 �J
r
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ifal_.. ° Creek c,:_,
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0 M Iles
Athn&j/V Baseline Atlantic Coast Pipeline
Coast N Little River Baseline Figure 10.9.1-17
'F'� „ /�/ Little River Route Variation Little River
Route Variation
FILE: M:1ClientslD•FIDOWSRPM AmGISNResource Reports\RREP iGWi rest ACP RR10 LiMe River RV.mxd, REVISED: 0812512015, SCALE: 1:15,000 DRAWN BY: JSSuess
Atlantic Coast Pipeline 68

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Atlantic Coast Pipeline 69
k
.r
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-131.3
I
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Atlantic Coast Pipeline 69
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~
fJC'
1
NWI Wetland
0 05
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v easeline
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N Swamp Road Baseline
Atlantic Coast Pipeline
Coast
Pl
Swamp Road Route Variation 1
Figure 10.9.1-18
pe'i r* ,_
� �� Swamp Road Route Variation 2
Swamp Road Route Variation
-0.vsw.Wwa.
FILE: M:\CI*nts'D-F{DOM%SRPP1 ArcG151Resource Reporls\RREP IOVigures\ ACP RRIIi RA Map SttmaC. REVISE0.00MMIS. SCALE:1:40.000 DOM By, Oi15
Atlantic Coast Pipeline 69

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Cape Fear Route Variation
Atlantic identified and evaluated a route variation (the Cape Fear 1 Route Variation)
between MPs 146.6 and 152.2 of the AP -2 mainline in Cumberland County, North Carolina to
avoid a conservation easement enrolled in the NRCS's Wetland Reserve Program (see
Figure 10.9.1-19 and Table 10.9.1-19). From a point near Cedar Creek Road, the Cape Fear 1
Route Variation heads approximately 1.5 miles to the southwest of the baseline route to Evans
Dairy Road. It then continues to the south-southwest for approximately 3.8 miles, crossing the
Cape Fear River and rejoining the baseline route near Tyson Road. Cape Fear 1 is
approximately 0.2 mile longer than the baseline route, crosses 0.2 mile more of forested land,
and crosses two more perennial waterbodies than the baseline route. However, it avoids the
conservation easement and reduces crossings of forested wetlands by 0.1 mile.
TABLE 10 9 1-19
Cape Fear Route Variations for the Atlantic Coast Pipeline
TABLE 10 9 1-18
Swamp Road Route Variations for the Atlantic Coast Pipeline
Cape Fear Route
Features
Unit
Baseline
Swamp Road Route
Swamp Road
Features
Unit
Route
Variation I
Route Variation 2
Length
miles
27
27
28
Roads crossed
number
3
2
2
Adjacent to existing linear corridor facilities
miles
07
00
06
Federal lands crossed
miles
00
00
00
State lands crossed
miles
00
00
00
Private lands crossed
miles
27
27
27
Conservation easements crossed
miles
00
00
00
Forested land crossed
miles
14
08
12
Wetlands crossed — freshwater forested/shrub
miles
09
01
05
Intermittent waterbodies crossed
number
2
2
2
Perennial waterbodies crossed
number
4
1
3
Cape Fear Route Variation
Atlantic identified and evaluated a route variation (the Cape Fear 1 Route Variation)
between MPs 146.6 and 152.2 of the AP -2 mainline in Cumberland County, North Carolina to
avoid a conservation easement enrolled in the NRCS's Wetland Reserve Program (see
Figure 10.9.1-19 and Table 10.9.1-19). From a point near Cedar Creek Road, the Cape Fear 1
Route Variation heads approximately 1.5 miles to the southwest of the baseline route to Evans
Dairy Road. It then continues to the south-southwest for approximately 3.8 miles, crossing the
Cape Fear River and rejoining the baseline route near Tyson Road. Cape Fear 1 is
approximately 0.2 mile longer than the baseline route, crosses 0.2 mile more of forested land,
and crosses two more perennial waterbodies than the baseline route. However, it avoids the
conservation easement and reduces crossings of forested wetlands by 0.1 mile.
TABLE 10 9 1-19
Cape Fear Route Variations for the Atlantic Coast Pipeline
Cape Fear Route
Cape Fear Route
Features
Unit
Baseline Route
Variation F
Variation 2 (Proposed)
Length
miles
52
54
55
Roads crossed
number
3
6
4
Adjacent to existing linear corridor facilities
miles
00
00
00
Federal lands crossed
miles
00
00
00
State lands crossed
miles
00
00
00
Private lands crossed
miles
52
54
55
Conservation easements crossed
miles
05
00
00
Forested land crossed
miles
17
19
20
Wetlands crossed — freshwater forested/shrub
miles
03
02
02
Intermittent waterbodies crossed
number
4
3
4
Perennial waterbodies crossed
number
2
4
4
Atlantic Coast Pipeline 70

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
I. V
7
9
5. 1
A
4
4
A
4
Conservation Easement
NWI Wetland
0 0.5 1
M Iles/
Baseline
AflarI& 0**V Cape Fear Baseline Atlantic Coast Pipeline
Coast Figure 10.9.1-19
/%./ Cape Fear Route Variation 1
PipeUr* -1 Cape Fear Route Variation 2 Cape Fear Route Variation
®�
FILE M1CfientsT-FOOMISRPM ArcGIS\Resource-ReportskRREP-lOVsgures\_ACP -RRIO_Cape Fear—d, REVISED 0812412015, SCALE 150000 DRAWN BY GIS
Atlantic Coast Pipeline 71

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
Subsequent to evaluating the Cape Fear 1 Route Variation, Atlantic identified and
evaluated a second route variation (Cape Fear 2) that optimizes the crossing angle of the Cape
Fear River. Cape Fear 2 is approximately 0.1 mile longer, crosses 0.1 more mile of forested
land, and crosses one more road than Cape Fear 2, but improves the crossing angle of the river.
Other environmental impacts are comparable to Cape Fear 1. For these reasons, Atlantic adopted
the Cape Fear 2 Route Variation into the proposed route.
ROUTE ADJUSTMENTS IN NORTH CAROLINA
Atlantic made a number of minor route adjustments to optimize the baseline routes as a
result of routing, biological, cultural resources, and civil field surveys. The route adjustments
generally measure less than two miles in length, pass within a quarter mile or less of the baseline
routes, and do not significantly affect the total length of the routes. The route adjustments were
adopted without a formal alternatives analysis, as the basis for the adjustment was intuitive and
practical (e.g., a slight shift in the centerline to avoid a wetland). Individually, the refinements to
the routes are small, but collectively they reduce impacts on environmental resources. Table 6
lists the route adjustments that have been incorporated into the proposed ACP pipeline route in
North Carolina and the rationale for each adjustment.
TABLE 6
Select Route Adjustments Incorporated into the Proposed
Atlantic Coast Pipeline in North Carolina
Atlantic Coast Pipeline 72
Approximate
Route Adjustment
Mileposts
State
Rationale
AP -2 Mainline
Jacks Swamp
0 7 to 2 4
NC
Adjustment to minimize a wetland crossing length
Big John Store Road
2 5 to 3 1
NC
Adjustment to avoid a cemetery
Cornwallis Road
3 7 to 4 2
NC
Adjustment to avoid a wetland
Quankey Creek
16 0 to 17 3
NC
Adjustment to avoid a proposed future development by the Halifax Airport Authority
Bryant Road
25 9 to 26 0
NC
Adjustment to avoid a wetland
Jacket Swamp
26 9 to 27 7
NC
Adjustment to avoid a conservation easement
Massengale Road
40 0 to 40 3
NC
Adjustment to avoid a future home site development
Wollett Mill Road
42 2 to 42 4
NC
Adjustment to avoid a cemetery
Cambridge Drive
48 8 to 49 1
NC
Adjustment to increase distance from residences
Boykin Road
70 5 to 70 8
NC
Adjustment to avoid a wetland
Contentnea Creek
73 1 to 74 4
NC
Adjustment to optimize creek crossing angle
Hales Road
80 1 to 815
NC
Adjustment to avoid a waterbody crossing and minimize a wetland crossing
Old Beulah Road
84 0 to 84 5
NC
Adjustment to avoid a wetland
Yelverton Grove Road
92 3 to 93 3
NC
Adjustment to connect to M&R Station
Gum Road
98 5 to 99 0
NC
Adjustment to avoid a waterbody crossing and minimize a wetland crossing
Coats Road
103 5 to 1038
NC
Adjustment to address a landowner request
NC -50 South
109 5 to 110 0
NC
Adjustment to avoid a wetland
Godwin Lake Road
110 1 to 110 7
NC
Adjustment to avoid a blueberry farm
Holly Grove Road
112 4 to 112 7
NC
Adjustment to avoid a wetland
NC DOT Easement
113 9 to 114 4
NC
Adjustment to avoid a North Carolina Department of Transportation Nutrient Easement
Green Path Road
117 8 to 1182
NC
Adjustment to reduce wetland impacts
Godwin Falcon Road
126 2 to 126 8
NC
Adjustment to reduce the pipeline length
Sisk Culbreth Road
129 4 to 129 7
NC
Adjustment to avoid existing structures
Jackie Lee Road
133 8 to 1342
NC
Adjustment to reduce the pipeline length
Tobacco Road
138 6 to 139 0
NC
Adjustment to avoid a wetland
Atlantic Coast Pipeline 72

Nationwide Permit No. 12, Pre -Construction Notification — Supplemental Information
U.S. Army Corps of Engineers — Wilmington District
TABLE 6
Select Route Adjustments Incorporated into the Proposed
Atlantic Coast Pipeline in North Carolina
Route Adjustment
Mileposts
State
Rationale
Approximate
142 0 to 142 2
NC
Adjustment to avoid a wetland
Pleasant View Drive
Unique ID
Avoided
Rationale
Sids Mill Road
143 2 to 143 5
NC
Adjustment to reduce a wetland crossing
John B Carter Road
144 5 to 145 0
NC
Adjustment to avoid being parallel to a waterbody
Clark West Road
146 7 to 148 6
NC
Adjustment to reduce road crossings
Canadian Avenue
152 9 to 153 3
NC
Adjustment to reduce wetland impacts
Highway 87
153 8 to 154 0
NC
Adjustment to optimize road crossing angle
Thrower Road
155 0 to 155 2
NC
Adjustment to avoid new residential development
Odom Road
156 6 to 157 5
NC
Adjustment to avoid a wetland crossing and reduce tree clearing
Little Marsh Swamp
162 0 to 164 8
NC
Adjustment to minimize a wetland crossing and parallel an existing utility corridor
Great Marsh Church
168 3 to 169 3
NC
Adjustment to meet a landowner request
Rennert Road
1715 to 172 3
NC
Adjustment to reduce the length of the pipeline and address a landowner request
McQueen Road
175 0 to 175 4
NC
Adjustment to avoid a wetland
AP -3 Lateral
wcmp002f
Yes
Highway 186
9 9 to 10 3
NC
Adjustment to reduce tree clearing and optimize a railroad crossing
In addition to the route variations and adjustments, Atlantic optimized the route at a
localized scale to further minimize impacts on wetlands and waterbodies where feasible. Route
optimization efforts that have occurred to minimize impacts on wetlands and waterbodies within
the Wilmington District are listed in Table 7.
Appendix A — Figures A-3 and A-4 include detailed route maps that illustrate how
Atlantic has also minimized impacts on wetlands and waterbodies by reducing workspace at
Atlantic Coast Pipeline 73
TABLE 7
Route Avoidance Locations for Wetlands in North Carolina
Approximate
Wetland
Wetland
Milepost
Unique ID
Avoided
Rationale
AP -2 Mainline
3 8
wnrg003f
Yes
40
wnrh015f
Yes
253
whlh013f
Yes
353
wnah016f
Yes
423
wnac00If
Yes
570
wnagOlOf
Yes
701
wwio0IIf
Yes
836
wjop00lf
Yes
1089
wjop023f
Yes
1104
wjoo026f
No
The proposed shift may impact a house in an adjacent parcel
1310
wcmp002f
Yes
1377
wcmp014f
Yes
Shift to minimize crossing
1431
wcmo012f
No
Shift - alignment avoids power poles for high voltage lien as well as maintains a buffer from adjacent
residence (-260-ft) The proposed shift may impact existing structures on parcel 22-256
1454
wcmp021f
No
Current alignment avoids power poles for high voltage line as well as maintains a buffer from adjacent
residence (--260-ft)
1522
wcmp012f
Yes
Shift to minimize crossing
1742
wroh012s
Yes
Appendix A — Figures A-3 and A-4 include detailed route maps that illustrate how
Atlantic has also minimized impacts on wetlands and waterbodies by reducing workspace at
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wetland crossings and in the vicinity of wetlands and waterbodies, where feasible. In addition, to
avoid impacts on wetlands along the periphery of the construction workspace, modifications to
workspace have been incorporated into the project design to minimize impacts on wetlands and
waterbodies.
ACP is a FERC regulated pipeline project and subject to certain procedures to avoid and
minimize impacts on wetland and waterbody crossings to satisfy FERC's own NEPA
requirements that also include minimization of environmental impacts. These procedures are
outlined in the Plan and Procedures and are applicable to all FERC regulated pipelines.
Despite Atlantics efforts to avoid and minimize impacts, there will be impacts that cannot
be avoided. These impacts will be offset with compensatory mitigation, as discussed in
Section D2.
U Construction Minimization - Wetlands
During the routing phase of the Project, NWI data was used to provide a preliminary
analysis of wetland resources and to assess where wetland impacts could be avoided or
minimized. In addition, a field oriented routing team consisted of an ecological specialist that
assisted in identifying water resources during field routing by civil survey crews. Minor
adjustments to the route were made to minimize impacts on wetlands, where feasible.
Clearing and grading of wetlands, trenching, backfilling, and trench dewatering can affect
wetlands through the alteration of wetland vegetation and hydrology; loss or change to wildlife
habitat; deposition or erosion of sediment; and exposure to accidental spills of fuels and
lubricants.
Atlantic will minimize impacts on wetlands by following the wetland construction and
restoration guidelines contained in the Plan and Procedures. The proposed wetland mitigation
measures are intended to avoid wetland impacts to the greatest extent practicable; minimize the
area and duration of disturbance; reduce soil disturbance; and enhance wetland reestablishment
after construction. Some of the measures proposed include:
• limiting the construction right-of-way width to 75 -feet through wetlands (unless
alternative, site-specific measures are requested by Atlantic and approved by the
FERC and other applicable agencies);
• clearly marking wetland boundaries with signs and flagging in the field prior to
the start of construction;
• locating ATWS within uplands at least 50 feet away from wetland boundaries
(unless alternative, site-specific measures are requested by Atlantic and approved
by the FERC and other applicable agencies);
• installing and maintaining sediment barriers, such as silt fences or other approved
barriers during clearing
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• limiting the operation of construction equipment within wetlands to only
equipment essential for clearing, excavation, pipe installation, backfilling, and
restoration;
• preventing the compaction and rutting of wetland soils by operating equipment on
equipment mats or timber riprap in wetlands that are not excessively saturated;
• restricting grading in wetlands to the area directly over the trenchline, except
where necessary to provide necessary safety;
• installing trench breakers or trench plugs at the boundaries of wetlands to prevent
draining of wetlands;
• segregating topsoil from the trench in non -saturated wetlands and returning
topsoil to its original location during backfilling to avoid changes in the
subsurface hydrology and to promote re-establishment of the original plant
community by replacing the seed bank found in the topsoil;
• installing temporary and permanent erosion and sediment control devices, and re-
establishing vegetation on adjacent upland areas, to avoid erosion and
sedimentation into wetlands;
• removing woody stumps only from areas directly above the trenchline, or where
they will create a safety hazard, to facilitate the re-establishment of woody species
by existing root structures;
• returning graded areas to their preconstruction contours to the greatest extent
practicable, and returning excavated soil from the trench within the wetlands back
to their original soil horizon to maintain hydrologic characteristics;
• prohibiting the storage of chemicals, fuels, hazardous materials, and lubricating
oils within 100 feet of a wetland;
• prohibiting parking and/or fueling of equipment within 100 feet of a wetland;
unless the Environmental Inspector determines there is no reasonable alternative,
and appropriate steps (such as secondary containment structure) are taken;
• prohibiting the use of live concrete as a building material so that wet concrete
does not come into contact with water;
• dewatering the trench at a controlled rate into an energy dissipation/sediment
filtration device, such as a geotextile filter bag and properly installed straw bale
structure, to minimize the potential for erosion and sedimentation;
• preventing the invasion or spread of undesirable exotic vegetation in accordance
with a project -specific invasive plant species management plan;
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• limiting post -construction maintenance of vegetation to removal of trees with
roots that could compromise the integrity of the pipeline within 15 feet of the
pipeline centerline, and the maintenance of a 10 -foot wide corridor centered over
the pipeline as herbaceous vegetation;
reseeding with a native wetland seed mix in both the temporary construction and
permanent right of way to stabilize wetland areas; and
annual monitoring wetland reestablishment following construction until
reestablished wetlands achieve success. See Appendix J for the Restoration and
Rehabilitation Plan.
Prior to construction, wetland boundaries will be clearly marked in the field with signs
and flagging. Construction equipment working in wetlands will be limited to what is essential
for right-of-way clearing, excavating the trench, fabricating and installing the pipeline,
backfilling the trench, and restoring the right-of-way. In areas where there is no reasonable
access to the right-of-way except through wetlands, non-essential equipment will be allowed to
travel through wetlands only once, unless the ground is firm enough or has been stabilized to
avoid rutting.
Clearing of vegetation in wetlands will be limited to trees and shrubs, which will be cut
flush with the surface of the ground and removed from the wetland. To avoid excessive
disruption of wetland soils and the native seed and rootstock within the topsoil, stump removal,
grading, topsoil segregation, and excavation will be limited to the area immediately over the
trenchline, except a limited amount of stump removal and grading may be conducted in other
areas if required by safety-related issues. Topsoil segregation over the trenchline will only occur
if the wetland soils are not saturated at the time of construction.
During clearing, sediment barriers, such as silt fences or other approved sediment
barriers, will be installed and maintained adjacent to wetlands and within ATWS areas as
necessary to minimize the potential for sediment runoff. Sediment barriers will be installed
across the full width of the construction right-of-way at the base of slopes adjacent to wetland
boundaries. Erosion control devices installed across the working side of the right-of-way will be
removed during the day when vehicle traffic is present, and will be replaced each night.
Alternatively, drivable berms may be installed and maintained across the right-of-way in lieu of
silt fences or straw bales. Sediment barriers will also be installed within wetlands along the edge
of the right-of-way, where necessary, to minimize the potential for sediment to run off the
construction right-of-way and into wetlands outside the work area. If trench dewatering is
necessary, it will be conducted in accordance with the Procedures and applicable permits. Silt -
laden trench water will be discharged into an energy dissipation/sediment filtration device, such
as a geotextile filter bag and straw bale structure, to minimize the potential for erosion and
sedimentation.
Temporary access roads through wetlands will be provided, when necessary, by altered
for use during construction by installing timber construction mats or other removable materials
to minimize rutting in wetlands. Where intended for temporary use, the access roads
improvements within wetlands will be removed after pipeline construction and wetland
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reestablishment is complete. Permanent access road improvements will require minor fill of
wetlands. Where feasible, Atlantic minimized impacts through necking down permanent access
roads or improving areas within adjacent uplands to minimize wetland impacts. After avoidance
and minimization to the extent practicable, 1.72 acres of permanent fill/loss wetland loss impacts
will result from the proposed permanent access roads within the Wilmington District.
The impacts associated with construction are planned to occur in an expedient and
efficient manner such that impacts on the wetlands are minimized to the extent practicable, and
long-term impacts are associated with minimal conversion of type but not loss of wetlands. In
addition, while there are a number of wetland crossings associated with across the ACP in North
Carolina are numerous, the crossings are distributed across many watersheds. Tables 3 and 4 in
section C, Proposed Impacts Inventory, summarize the impacts on wetlands by watershed
(HUC 8). Based on the short duration of construction thru wetlands, minimization of long-term
conversion by implementing FERC procedures (i.e., minimizing clearing to of a 10 feet along the
pipeline centerline to maintain a herbaceous wetland condition, and minimizing trimming to
15 feet either side of the pipeline centerline for larger trees), and providing compensatory
mitigation within both the 30 foot permanently maintained right of way (15 feet either side of the
pipeline centerline) and the temporarily disturbed 75 foot construction right of way by reseeding
with native wetland seed mix, and replanting of the temporarily disturbed right of way in non -
inundated deciduous hardwood wetlands (e.g., bottomland hardwood, hardwood riparian, and
hardwood flat wetlands) with saplings (minimization and compensatory mitigation), mitigating
at a 1:1 ratio for permanent conversion of non -inundated deciduous hardwood wetlands (e.g.,
bottomland hardwood, hardwood riparian, and hardwood flat wetlands) to scrub -shrub and
emergent wetlands, Atlantic anticipates that cumulative impacts will result in no more than no
more than minimal adverse impacts on the basin and sub -basins crossed.
b.2 Construction Minimization - Waterbodies
Because little or no grading will occur in wetlands, restoration of contours will be
accomplished during backfilling. Prior to backfilling, trench breakers will be installed, where
necessary, to prevent subsurface drainage of water from wetlands. Where topsoil is segregated,
the subsoil will be backfilled first followed by the topsoil. Topsoil will be replaced to the
original ground level leaving no crown over the trenchline. In areas where wetlands overlie
rocky soils, the pipe will be padded with rock -free soil or sand before backfilling with native
bedrock and soil. Equipment mats, gravel fill, and/or geotextile fabric will be removed from
wetlands following backfilling.
Where wetlands are located at the base of slopes, permanent slope breakers will be
constructed across the right-of-way in upland areas adjacent to the wetland boundary.
Temporary sediment barriers will be installed where necessary until revegetation of adjacent
upland areas is successful. Once revegetation is successful, sediment barriers will be removed
from the right-of-way and disposed of at an approved disposal facility.
Restoration/revegetation of wetlands will be considered successful when the affected
wetland satisfies the federal definition of a wetland (i.e., soils, hydrology, and vegetation); the
vegetation is at least 80 percent of the cover documented for the wetland prior to construction, or
at least 80 percent of the cover in adjacent, undisturbed areas of the wetland; or the plant species
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Lecoregion
osition is consistent with early successional wetland plant communities in the affected
(if seeding is used in lieu of planting); and invasive plant species are absent, unless
are abundant in adjacent areas that were not disturbed by construction.
Impacts on waterbodies crossed by the proposed ACP facilities could occur as a result of
construction activities in stream channels and on adjacent banks. Clearing and grading of stream
banks, in -stream trenching, trench dewatering, and backfilling could each result in temporary,
local modifications of aquatic habitat involving sedimentation, increased turbidity, and decreased
dissolved oxygen concentrations. In almost all cases, these impacts will be limited to the period
of in -stream construction, and conditions will return to normal shortly after stream restoration
activities are completed. Agency recommended time of year restrictions are listed in
Appendix C.
Vegetative clearing, grading for construction, and soil compaction by heavy equipment
near stream banks could promote erosion of the banks and the transport of sediment into
waterbodies by stormwater runoff. To minimize these potential impacts, Atlantic will install
equipment bridges, mats, and pads, as necessary. Additionally, Atlantic will locate ATWS at
least 50 feet from stream banks (with the exception of site-specific modifications requested by
Atlantic and approved by the FERC). Temporary sediment barriers will be installed around
disturbed areas as outlined in the Plan and Procedures. Upon completion of construction,
Atlantic will install pennanent erosion control measures at stream crossing locations to provide
long -tern protection of water quality according to the Plan and Procedures and all permit
requirements.
Sedimentation and increased turbidity can occur as a result of in -stream construction
activities, trench dewatering, or stormwater runoff from construction areas. In slow moving
waters, increases in suspended sediments (turbidity) may increase the biochemical oxygen
demand and reduce levels of dissolved oxygen in localized areas during construction. Suspended
sediments also may alter the characteristics of the water column (e.g., color and clarity) on a
temporary basis. Atlantic will use material excavated from the pipeline trench to backfill the
trench once the pipe is installed to avoid introduction of foreign substances into waterbodies.
Atlantic will install temporary equipment bridges to reduce the potential for turbidity and
sedimentation resulting from construction equipment and vehicular traffic crossing waterbodies.
Temporary bridges will be installed across waterbodies in accordance with the Procedures to
allow construction equipment and personnel to cross. The bridges may include clean rock fill
over culverts, timber mats supported by flumes, railcar flatbeds, flexi-float apparatuses, or other
types of spans. Construction equipment will be required to use the bridges, except that the
clearing and bridge installation crews will be allowed one pass through waterbodies before
bridges are installed. The temporary bridges will be removed when construction and restoration
activities are complete.
After the pipeline is installed across a waterbody using one of the methods described
above, the trench will be backfilled with native material excavated from the trench. The
streambed profile will be restored to pre-existing contours and grade conditions to prevent
scouring. The stream banks will then be restored as near as practicable to pre-existing conditions
and stabilized. Stabilization measures would include seeding, installation of erosion control
i
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blankets, or installation of riprap materials, as appropriate. Temporary erosion controls will be
installed immediately following bank restoration. The waterbody crossin area will be inspected
and maintained until restoration of vegetation is comp
During construction, the open trench may accumulate water, either from a high water
table and seepage of groundwater into the trench or from precipitation. In accordance with the
Plan and Procedures, and when necessary, trench water will be removed and discharge I into an
energy dissipation/sediment filtratjmdevice such as a geotexti e filter bag and straw bale
struc Ere, to minimize the potential for erosion and sedimentation.
In areas where concrete -coated pipe is required, and in accordance with the SPCC Plan,
concrete coating activities will occur a minimum of 100 feet from wetlands, waterbodies, and
springs. Concrete -coated pipe will be installed after the concrete is dried and will not be
dispersed when submerged in water.
The SPCC Plan for the ACP will describe measures that personnel and contractors will
implement to prevent and, if necessary control, inadvertent spill of fuels, lubricants, solvents, and
other hazardous materials that could affect water quality. As required in the Procedures and the
SPCC Plan, hazardous materials, chemicals, lubricating oils, and fuels used during construction
will be stored in upland areas at least 100 feet from wetlands and waterbodies. Refueling of
construction equipment will be conducted at least 100 feet from wetlands and waterbodies,
whenever possible. However, there will be certain instances where equipment refueling and
lubricating may be necessary in or near waterbodies. For example, stationary equipment, such as
water pumps for withdrawing hydrostatic test water, may need to be operated continuously on
the banks of waterbodies and may require refueling in place. In this event, the pumps would be
refueled within secondary containment structures and fuel will be stored more than 100 feet from
the edge of waterbodies or wetlands. The SPCC Plan addresses the handling of fuel and other
materials associated wjth the ACP. As required by the Procedures, the SPCC Plan will be
available during construction on each construction spread.
It is possible that previously undocumented sites with contaminated soils or groundwater
could be discovered during construction of the ACP. Atlantic has prepared and will implement a
Contaminated Media Plan to address these circumstances. The Contaminated Media Plan
describes measures to be implemented in the event that signs of contaminated soil and/or
groundwater are encountered during construction. Signs of potential contamination could
include discoloration of soil, chemical -like odors, or sheens on soils or water. Containment
measures will be implemented to isolate and contain the suspected soil or groundwater
contamination and collect and test samples of the soil or groundwater to identify the
contaminants. Once the contaminants are identified, a response plan will be developed for
crossing or avoiding the site.
Use of the HDD method avoids impacts on waterbodies because it allows for the pipe to
be installed underneath the ground surface without disturbance of the streambed or banks.
However, a temporary, localized increase in turbidity could occur in the event of an inadvertent
release of drilling fluid to the waterbody. Drilling fluid to be used on the ACP will be composed
of water and bentonite clay (a naturally occurring mineral). The U.S. Environmental Protection
Agency (EPA) does not list bentonite as a hazardous substance, and no long-term adverse
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_ environmental impacts are expected should an inadvertent release occur. Similarly, while native
soils may mix with the drilling fluid as a result of the drilling process, drilling fluid is still not
considered fill material and no adverse environmental impacts from these materials are expected
should an inadvertent return occur.
Due to the possibility of drilling fluid loss during HDD operations, Atlantic has prepared
and will implement a HDD Plan. The plan describes measures to prevent, detect, and respond to
inadvertent returns, including but not limited to, monitoring during drilling operations, the types
of equipment and materials that must be readily available to contain and clean up drilling mud,
containment and mitigation measures, notification requirements, and guidelines for abandoning
the directional drill, if necessary.
The use of HDD was considered for wetland and waterbody crossings, but was
determined to not be feasible in all crossing locations based on logistical, economic, temporal,
and engineering constraints, additional environmental impacts, and potential environmental risks.
The HDD method requires that a prefabricated segment of pipe at least the length of the bore
hole be staged in line with the drill path at the exit hole, opposite the placement of the drilling
rig. This "pullback" generally requires a false right-of-way that can deviate from the right-of-
way approaching the crossing, unless the drill alignment is directly in-line with the construction
right-of-way for the length of the prefabricated pipe segment. In many cases the drill path is not
in-line with the construction right-of-way and additional workspace that extends well outside of
the standard construction right-of-way must be cleared and graded to accommodate the
prefabrication of the pipe segment described above.
The path of the drill is constrained by the flexibility of the pipe; the depth beneath the
wetland and/or waterbody needed to achieve a successful installation; and the elevation of the
entry and exit points. The entry and exit points should be similar in elevation to prevent a
significant pressure differential that can contribute to failure of the HDD operation and by
maintaining consistent pressure this helps maintain predictable flow of drilling mud and thus
greater likelihood of a successful HDD.
As a rule of thumb used in evaluating the feasibility of the HDD method, the 36 -inch
diameter pipe requires a minimum drill path of 1,800 feet to achieve an acceptable radius of
curvature that will prevent a catastrophic "crinkling" of the pipe as it conforms to the path of the
drill hole. All proposed HDD crossings have been designed based on specific site constraints at
the crossing and geologic conditions, therefore site-specific designs may vary from the planning
guidelines.
Atlantic explored use of the HDD method at the Rocky Swamp crossing, but based on
geotechnical results, due to heavily weathered bedrock and overlying unconsolidated materials,
the likelihood of experiencing an inadvertent release was high. Therefore, the HDD method is
not proposed for the Rocky Swamp crossing.
A large drill can be more expensive than traditional crossing methods and can take as
long as several months to install. Traditional crossing methods of major waterbodies can
typically be completed in less than 30 days for major waterbody crossings, whereas typical
f
minor or intermediate waterbody crossings can be completed within a day or a few days. Due to
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the extended time of exposure of additional workspace associated with HDD coupled with the ( ;�
potential for an inadvertent return, traditional crossing methods can often reduce the
environmental impact when compared with HDD. Based on these constraints and design
considerations the HDD method is feasible and practicable where large, deep waterbodies are
encountered and sufficient space to place the pullback and work area for drilling equipment is
available.
The proposed HDD crossing locations on ACP constitute those where it is feasible and
the potential for a successful drill is acceptable.
Once construction is complete, the pipeline will be buried below the ground surface and,
therefore, will not impact water retention or floodplain storage within riparian corridors.
Atlantic is routing the proposed pipelines to avoid sharp angle crossings or crossing streams
where high stream energy could result in bank erosion. Atlantic will implement measures
outlined in the Procedures to minimize impacts on the waterbodies crossed, including the
installation of trench plugs to prevent water from flowing along the trenchline during and after
construction. These measures will minimize potential impacts on surface and below ground
hydrology. All waterbody crossings will be in accordance with the requirements identified in the
federal or state waterbody crossing permits obtained for the ACP.
During operations, the proposed pipelines will transport natural gas, which consist
primarily of methane. Methane is buoyant at atmospheric temperatures and pressure, and
disperses rapidly in air. The proposed pipelines will not carry liquids. Therefore, in the unlikely
event of a leak, impacts on surface waters or groundwater ftom methane are not anticipated.
Moreover, Atlantic will utilize a rigorous Integrity Management Plan to prevent leaks on the
system.
The impacts associate with construction are planned to occur in an expedient and
efficient manner such that impacts on the waterbody its banks are temporary in nature. In
addition, while there are numerous of waterbody crossings across the project in North Carolina,
the crossings are distributed across many watersheds. Tables 3 and 4 in section C, Proposed
Impacts Inventory, summarize the impacts on waterbodies by sub -basin (HUC 8). Based on the
short duration and distant nature of the waterbody crossings, Atlantic anticipates that cumulative
impacts will result in no more than minimal adverse impacts on the basin and sub -basins crossed.
See Appendix K — Tables K-1 to Table K-3 for a list of General, Regional and Specific
NWP 12 permit conditions and how Atlantic will comply with the conditions.
2. Compensatory Mitigation for Impacts on Waters of the U.S. or Waters of the State
In order to authorize any activity under the NWP Program the USACE must determine
that the authorized activity in waters of the U.S. meets the terms and conditions of the relevant
NWP, in this case NWP 12, which allows no more than 0.5 acre loss at each single and complete
project (crossing). Furthermore, provided the activity meets the terms and conditions of NWP 12
USACE must determine that the activity will result in no more than minimal individual or
cumulative impacts on the aquatic environment after considering proposed compensatory
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_ mitigation. Such impacts would include the conversion impacts from one type of wetland to
another. As stated in the Preamble to 33 CFR 330/NWP Rule issued on November 22, 1991
(56 FR 59118-59119) mitigation can be used to reduce impacts on the aquatic environment to the
minimal level:
"In response to the comments concerning whether the District Engineer (DE) should
allow an activity to proceed under a relevant NWP when the mitigation reduces the adverse
environmental effects to the minimal level (the "buy down" or "write down" concept), we
believe it is indeed appropriate for the DE to consider mitigation in determining whether the
proposed activity will result in no more than a minimal level of adverse environmental effects.
and "In summary, the net impact concept regarding the determination of minimal is consistent
with NEPA, the Army/EPA Mitigation Memorandum of Agreement and the Section 404(b)(1)
Guidelines as they pertain to general permits."
Atlantic will provide compensatory mitigation for the conversion within the 30 foot
permanently maintained right of way (15 feet either side of the pipeline centerline) reseeding
with native wetland seed mix and mitigating at a 1:1 ratio for permanent conversion of palustrine
forested
construction right of way reseeding with
ACP right-of-way.
Ti-in—the ,-_ tempos disturbed
to stabilize the area, along the
Permanent loss of wetlands is not proposed for anticipated to occur as a result of the ACP
mainline pipeline construction or associated facilities in North Carolina. However, loss of
l waters of the U.S. will occur as a result of access road improvements. Existing access roads will
be utilized as much as possible where feasible. Where access road improvements are necessary
for use, impacts will be minimized to the maximum extent practicable, and, in conjunction with
other impacts will not result in more than 0.5 acre loss of waters of the U.S. at any single and
complete project.
Permanent losses of wetlands, streams, and other waters as a result of access roads are
proposed to be mitigated at a 2:1 ratio for riparian wetland type and 1.5:1 ratio for non -riparian
wetland type through the purchase of commercially available mitigation credits from an agency -
approved mitigation bank as a first option, and from the Department of Mitigation Services
(DMS), which offers In -Lieu Fee mitigation programs, as a second option. Atlantic requested
authorization from DMS to reserve 100% of the credit need for the permanent loss of wetlands
and streams while submitting requests for letters of credit availability from mitigation banks
servicing the HUC 8 watershed or approved service area where the loss will occur. In-kind
mitigation bank credits will be purchased from mitigation banks servicing the areas (HUC 8
watershed, or approved service area) where the conversion or loss occurs. Atlantic received
notification that DMS is willing to accept payment for compensatory mitigation for the total
permanent loss of wetlands and streams associated with the construction and maintenance of
access roads. Should mitigation banks indicate that credits are available, Atlantic will purchase
all available credits before making a payment to DMS for the balance.
In addition, in the event that a conversion or loss occurs in a service area where
mitigation bank credits are not available, Atlantic will seek authorization to participate in an
agency approved In -Lieu Fee program and/or, Atlantic will seek authorization to purchase
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credits from outside the service area of the next nearest mitigation bank and/or conduct permittee
responsible mitigation (PRM) under an umbrella approach. These options will be based on
practicality to replace the ecological function of the temporal loss and amount of compensation
required. Atlantic will coordinate with Wilmington District in such cases in order to obtain
approval of either option in instances where credits are not available from an agency -approved
mitigation bank.
Atlantic has completed research to identify wetland mitigation banks with available
credits, and will continue to contact wetland mitigation banks to identify available wetland
mitigation banks as the primary source of compensatory mitigation for the ACP. As a secondary
source of compensatory mitigation, Atlantic will pursue participation in the North Carolina In -
Lieu Fee program and/or conduct PRM if adequate wetland mitigation bank credits are not
available from an agency -approved bank.
For purposes of NCDEQ for the 401 Water Quality Certification Atlantic has received a
response letter from DMS outlining required mitigation for loss of wetlands, loss of linear feet of
stream bed, and for riparian buffer impacts. Atlantic has attached this letter as evidence of intent
to satisfy NCDEQ required mitigation. The letter is included in Appendix P.
With respect to PRM, Atlantic's team is currently in the process of identifying HUC's
where an umbrella PRM approach may be applicable. Based on this research, Atlantic's team has
begun coordinating with landowners to identify suitable sites and is in the process of negotiating
with landowners in order to conduct site research and assessments. Once suitable sites are
selected and upon coordination with Wilmington District, Atlantic's team will be available to )
coordinate and schedule site visits to review the selected sites prior to final approval of the
umbrella PRM approach.
Atlantic intends to complete field survey on remaining inaccessible parcels, analyze and
confirm impacts, and finally purchase adequate mitigation credits and/or secure sites to support
the umbrella PRM approach. Atlantic will pursue this sequence of steps to provide for
compensatory mitigation prior to final issuance of the JPA.
3. Complete if Using a Mitigation bank
See Section D2 above for mitigation options. Additional details will be provided in the
final application regarding Atlantic's plans for mitigation bank use and availability in North
Carolina. At the time of this a lication, Atlantic continues to plan for mitigation and has
provided a conceptual plan in Section D2 love.
4. Complete if Making a Payment to In -lieu Fee Program
See Section D2 above for mitigation options. Additional details will be provided in the
final application if Atlantic plans to utilize payment to the North Carolina in -lieu fee program as
a compensatory mitigation option.
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5. Complete if Using a Permittee Responsible Mitigation Plan
See Section D2 above for mitigation options. Additional details will be provided in the
final application regarding proposed sites, if Atlantic plans to utilize permittee responsible
mitigation as a compensatory mitigation option.
6. Buffer Mitigation (State Regulated Riparian Buffer Rules) — required by DWR
Buffer rules for the Tar -Pamlico River Basin and Neuse River Basin watersheds provide
that mitigation will be required for certain surface water buffer impacts. The buffer rules define
two zones for eligible streams. Zone 1 extends 30 feet from the top of the bank landward and
Zone 2 extends another 20 feet from the end of Zone 1 landward for a total buffer of 50 feet.
Impacts to Zone 1 buffer areas may be allowed with mitigation. The buffer applies to:
intermittent streams, perennial streams, lakes, ponds, estuaries and modified natural streams that
are depicted on the most recent printed version of the soil survey map prepared by the Natural
Resources Conservation Service or the 1:24,000 scale quadrangle topographic map prepared by
the USGS. Atlantic has been consulting with the NCDEQ to determine which streams in the
ACP pipeline corridor are subject to the buffer rule and to determine mitigation impacts.
A package was submitted to the NCDEQ in November 2016 with Atlantic's proposed
determinations for review. A response letter from the NCDEQ was received by Dominion in
November 2016 (provided in Appendix I). Table 5 provides a summary of impacts to waters that
are subject to the buffer rule and tabulates associated mitigation requirements according to
r guidance provided by and discussions with NCDEQ. In accordance with NCDEQ guidance
provided by and discussions with NCDEQ, Atlantic is providing compensatory mitigation for
impacts to buffers where other wetlands mitigation would not occur. Atlantic will provide
compensatory mitigation for wetland impacts within buffers of subject waters according to the
requirements of the USACE through the Section 404 review.
In addition, as required by NCDEQ, Atlantic will mitigate for permanent losses of stream
bed and wetlands based on the impacts summarized in Tables 3 and 4in Section C, above.
E. STORMWATER MANAGEMENT AND DIFFUSE FLOW PLAN (REQUIRED
BY DWR)
Atlantic has developed erosion and sediment control (ESC) plans that incorporate
requirements in the FERC Upland Erosion Control, Revegetation and Maintenance Plan (Plan),
FERC Wetland and Waterbody Construction and Mitigation Procedures (Procedures) and North
Carolina -specific ESC regulations. In March 2017 Atlantic submitted applications for a North
Carolina General Permit to Discharge Stormwater under the National Pollutant Discharge
Elimination System for Construction Activities (NCG 010000) to the Raleigh and Fayetteville
regions of NCDEQ.
Atlantic is currently coordinating with local and state agencies in North Carolina
regarding the applicability of post -construction stormwater management requirements for the
project. Following this evaluation the appropriate post -construction stormwater management
- analysis and permitting will be completed.
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1. Diffuse Flow Plan
Atlantic is currently coordinating with local and state agencies in North Carolina
regarding the applicability of post -construction stormwater management requirements for the
project. Diffuse flow plans, if necessary, will be submitted as part of the post -construction
stormwater management permitting for the project.
2. Stormwater Management Plan
Due to the nature of the proposed project, the majority of disturbed areas will be restored
to existing condition and the post -construction hydrologic condition will be equivalent to pre -
construction conditions. Certain elements, such as permanent access roads and aboveground
facilities, may result in a change in the pre -construction hydrologic condition and Atlantic is
currently evaluating the applicability of post -construction stormwater management
requirements. Atlantic will develop post -construction stormwater management plans, where
required, and coordinate with NCDEQ and/or the appropriate local government agencies, as
applicable, that are responsible for review and approval of post -construction stormwater
management permitting in North Carolina.
3. Certified Local Government Stormwater Review
The project is located within the boundaries of multiple municipal and county -level
stormwater management program areas. Atlantic is currently coordinating with local and state
agencies regarding the applicability of post -construction stormwater management requirements
for the project. Following this evaluation the appropriate post -construction stormwater
management analysis and permitting will be completed.
4. DWQ Stormwater Program Review
The project is located within the boundaries of multiple state -level stormwater
management program areas. Atlantic is currently coordinating with local and state agencies
regarding the applicability of post -construction Stormwater management requirements for the
project. Following this evaluation the appropriate post -construction stormwater management
analysis and permitting will be completed.
S. DWQ 401 Unit Stormwater Review
Atlantic is currently coordinating with local and state agencies in North Carolina
regarding the applicability of post -construction stormwater management requirements for the
project. Following this evaluation the appropriate post -construction stormwater management
analysis and permitting will be completed.
F. SUPPLEMENTARY INFORMATION
1. Environmental Documentation (DWQ Requirement)
Atlantic filed an application with FERC for a Certificate of Public Convenience and
Necessity under Section 7(c) of the Natural Gas Act on September 18, 2015. As a part of the /
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FERC filing process an Environmental Impact Statement will be produced by the FERC for the
ACP. A Draft Environmental Impact Statement was published by the FERC on December 30,
2016.
2. Violations (DWQ Requirement)
See Section F2 of the PCN Form
3. Cumulative Impacts
As part of the USACE evaluation of the single and complete projects of waters of the
United States for applicability of coverage under NWP 12, the USACE must determine if the
individual and cumulative impacts on the aquatic environment are no more than minimal after
considering compensatory mitigation for unavoidable impacts. The single and complete project
impacts are presented by HUC 8 watershed in Appendix C and summarized in tables 3 and 4 in
Section C. By avoiding impacts to higher ecological value waters of the United States,
narrowing the corridor width to 75 feet in wetlands, and otherwise minimizing impacts to the
maximum extent practicable, including minimizing the duration of construction thru wetlands
and the long-term conversion by implementing FERC Procedures, Atlantic has made substantial
efforts so that impacts of single and complete projects are no more than minimal. Specific
measures to minimize impacts include: following FERC Procedures that minimize right-of-way
clearing to 10 feet along the pipeline centerline to maintain herbaceous wetland conditions;
minimizing deep rooted vegetation trimming to 15 feet either side of the pipeline centerline;
( providing compensatory mitigation for permanent conversion of palustrine forested wetlands
(PFO) to scrub -shrub or emergent wetlands within the 30 foot permanently maintained right o
way (15 feet either side of the pipeline centerline) at a 1:1 ratio, and for loss of wetlands as a
result of proposed access roads at a 2:1 mitigation ratio; and mitigating further by reseeding both
the temporarily disturbed and permanently maintained right of ways with native wetland seed
mix,. As with all impact evaluation under the NWP program, the determination whether there
would be no more than minimal cumulative adverse impacts on the aquatic environment is made
after considering proposed mitigation (Preamble to 33CFR330;1991 NWPs - 56 FR 59118-
59119). Furthermore, based on the level of conversion impacts occurring within each HUC 8
watershed, and the fact that all conversion impacts to palustrine forested wetlands will be have
been offset by compensatory mitigation, t e cumulative impacts on the aquatic environment have
been reduced to no more than minimal as described in Section D.1., above.
"In response to the comments concerning whether the DE should allow an
activity to proceed under a relevant NWP when the mitigation reduces the adverse
environmental effects to the minimal level (the "buy down " or "write down " concept),
we believe it is indeed appropriate for the DE to consider mitigation in determining
whether the proposed activity will result in no more than a minimal level of adverse
environmental effects. " and "In summary, the net impact concept regarding the
determination of minimal is consistent with NEPA, the Army/EPA Mitigation MOA and
the Section 404(b) (1) Guidelines as they pertain to general permits. "
The Preamble of the March 2012 NWP issuance package also indicates that cumulative
effects will normally be evaluated on a watershed basis.
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Each separate and distant crossing should be evaluated to determine if it meets
the terms and conditions of the NWP, and cumulative effects of the overall utility line
should be evaluated to determine if the adverse cumulative effects on the aquatic
environment are more than minimal and therefore do not qualms for NWP
authorization. Separate utility line crossings are usually on different water bodies, and
may also be in widely separated watersheds. Such factors should be considered when
assessing cumulative impacts. " (77 FR 10196) "
"For single and complete linear projects, each separate and distant crossing of
a waterbody, as well as each crossing of other waterbodies along the corridor for the
linear project maybe permitted by separate NWP authorizations. The acreage and
other applicable limits for an NWP would be applied to each crossing, as long as those
crossings are far enough apart to be considered separate and distant. District
engineers will evaluate the cumulative effects of those linear projects when determining
whether authorization by NWP is appropriate. The approach to cumulative effects
analysis for linear projects is little different than the cumulative effects analysis for
other types ofNWP activities, including those circumstances in which more than one
NWP is used to authorize a single and complete non-linear project, because cumulative
effects are evaluated on a regional basis. Cumulative effects analysis may be done on a
watershed basis, or by using a different type of geographic area, such as an
ecoregion. " (77 FR 10264)
The Preamble of the January 6, 2017 NWP Program Final Rule states in addition:
"We are retaining the %-acre limit for this NWP because we believe it is an `
appropriate limit for authorizing most utility line activities that have no more than
minimal individual and cumulative adverse environmental effects. Division engineers
can modem this NWP on a regional level to reduce the acreage limit if necessary to
ensure that no more than minimal adverse environmental effects occur in that region.
We do not agree that the acreage limit should apply to the entire utility line because the
separate and distant crossings of waters of the United States are usually at separate
waterbodies scattered along the length of the utility line, and are often in different
watersheds especially for utility lines that run through multiple counties, states, or
Corps districts. For utility lines that cross the same waterbody (e.g., a river or stream)
at separate and distant locations, the distance between those crossings will usually
dissipate the direct and indirect adverse environment effects so that the cumulative
adverse environmental effects are no more than minimal. If the district engineer
determines after reviewing the PCN that the cumulative adverse environmental effects
are more than minimal, after considering a mitigation proposal provided by the project
proponent, he or she will exercise discretionary authority and require an individual
permit. " (FR Notice, January 6, 2017 Final Rule Preamble p1885)
The USACE mitigation rule at 33 Code of Federal Regulations 332.8(d)(6)(ii)(A), and
North Carolina General Statutes §143-214.11, provides that normally mitigation service areas
would be at the HUC 8 watershed level. HUC 8 has been used as the size of watershed in which
to present the cumulative impacts of the proposed Project.
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The vast majority of the ACP impacts on waters of the U.S. would result from the
temporary discharge of earthen fill material associated with trench excavation for pipeline
installment within the rights-of-way. Furthermore, to facilitate construction equipment for
pipeline installation forested and scrub/shrub wetlands would be cleared and stumps removed
only where required for safe passage during pipe menstallment. Where temporary discharges
of fill or excavation is necessary, Atlantic will immediately restore the wetland to its pre -
construction contours. The center 30 -feet of the cleared rights-of-way that previously consisted
of forested wetlands will be permanently maintained free of trees. The center 10 -feet of the
cleared rights-of-way that previously consisted of forested or scrub -shrub wetlands will be
permanently maintained in an emergent wetland state. This maintenance for the life of the
project, while not resulting in a loss of waters of the U.S., will result in a permanent impact to
wetland function and value, which would otherwise exist had the vegetative cover of the wetland
no een altered. These functional losses will be offset by proposed compensatory mitigation at
2:1 atio. This has been described as permanent conversion in associated tables.
Atlantic has taken great steps to avoid permanent loss of waters of the U.S. and has
successfully avoided loss of waters of the U.S. for the pipeline and at permanent aboveground
facilities in the Wilmington District. However, loss of waters of the U.S. will occur as a result of
access road improvements totaling 1.72 acres with no loss at each single and complete crossing
exceeding the 0.5 acre NWP 12 threshold. However, the proposed pipeline will result in the
permanent conversion of 148.8 acres of palustrine forested wetlands to scrub -shrub or to
emergent wetland along with ACP construction. These impacts are included in Appendix C.
The temporary impacts and permanent conversion impacts of the proposed ACP are
provided in detail in Appendix C, and summarized by HUC 8 watershed in Section C above. A
total of 453.5 acres of temporary wetland impacts, and conversion of 148.2 acres of palustrine
forested wetland to scrub -shrub or emergent wetland impacts are planned along with ACP
construction. There will be no loss of waters of the U.S. due to mainline pipeline crossings of
waters of the U.S. Despite minor loss of waters of the U.S. for access road improvements and
the wetland conversion impacts, the compensatory mitigation plan will provide for impact offsets
and Atlantic does not anticipate a net loss in aquatic functions and services of the waters of the
U.S. The reestablishment of the wetland area outside of the 30 -foot maintained corridor will
assist in minimizing the temporary impacts due to clearing for construction.
Assessment of cumulative effects also involves a general characterization of impacts on
waters of the U.S. from similar types of projects in the past and reasonably foreseeable future.
The area that the pipeline would traverse largely involves a mix of small community
development, agricultural use and open undisturbed forested land. Past impacts would be those
of typical rural development with road and various utility line crossings of streams and wetlands
in support of agriculture and dispersed human development. Reasonably foreseeable impacts
would include continued slow additional growth in the small human communities with
associated road and utility line crossings of waters of the U.S.
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As provided in the USACE 2017 NWP issuance document at 77 FR 10197, cumulative
impacts on the human environment other than impacts on waters of the U.S. will be evaluated by
FERC in its NEPA EIS process.
"Even though an environmental impact statement may be prepared for a
particular utility line, the National Environmental Policy Act process does not prohibit
the Corps from using NWP 12 to authorize the construction, maintenance, repair, and
removal of utility lines and associated facilities in waters of the United States, as long as
the activity complies with all applicable terms and conditions and results in minimal
individual and cumulative adverse effects on the aquatic environment. NEPA requires
consideration of all environmental impacts, not only those to aquatic resources, so there
may well be situations where aquatic tMEacts are minimal even though environmental
impacts more generally are nom. These other environmental impacts would be addressed
by the lead agency preparing the environmental impact statement. "
The purpose of the proposed pipeline is to transport natural gas from West Virginia and
Pennsylvania to use in areas of Virginia and North Carolina. Other pipelines, subject to future
approvals with mitigation as appropriate and practicable, may be required to transport natural gas
that may in the future be produced from the Marcellus Shale and Utica Shale formations. Other
pipeline development in the areas traversed by the Project would involve mostly temporary
impacts on waters of the U.S. that would be restored after pipeline construction is completed.
Permanent loss and wetland conversion impacts of waters of the U.S. would be mitigated to
achieve no more than minimal impact through the USACE and state permit actions offsetting the \
impacts on streams and wetlands. Moreover, the USACE Headquarters evaluated the cumulative
impacts on waters of the U.S. in its decision document supporting reissuance of NWP 12 in
2017. The USACE evaluation of impacts nationwide determined that there would be no more
than minimal cumulative impacts on waters of the U.S. Part of the USACE Headquarters
evaluation of cumulative impacts identified that USACE districts wouldevaluate cumulative
impacts on waters of the U.S. of the "overall pipeline project" it authorized based on evaluation
of impacts on the aquatic environment on a watershed basis. The USACE Headquarters
cumulative impact evaluation was partially base on urestoration of temporary impacts,
districts requiring compensatory mitigation for permanent loss of waters and conversion impacts
such as the compensatory mitigation proposed by Atlantic for the ACP and that high ecological
value aquatic areas would be avoided as has been done on the ACP through coordination with
the USACE districts.
Based on the fact that the majority of the overall pipeline project impacts on waters of the
U.S. are temporary with restoration of aquatic areas immediately after construction and that
permanent conversion of forested and scrub -shrub wetlands to other wetland types and small
unavoidable road fills will be mitigated, the impacts at each single and complete project will
result in no more than minimal impact. Furthermore, the proposed impacts including loss of
waters of the U.S. at each single and complete project are of such minimal impact that they will
qualify for NWT 12 in North Carolina. The fact that these impacts, resulting in no more than
minimal impact on wetlands, streams and other waters of the U.S., at each single and complete
project, are spread widely over numerous watersheds and over approximately 198.7 miles in the
North Carolina, clearly indicates that the cumulative aggregate impacts of the overall pipeline
project to waters of the U.S. will be no more than minimal as well. Therefore the cumulative
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impacts of the overall pipeline project on each HUC 8 watershed are not of a nature or extent that
would result in the requirement of an individual permit for the Project.
As provided in the Preamble of the January 6, 2017 USACE 2017-2022 NWP Program
Final Rule:
"We are retaining the long-standing practice articulated in the NWP regulations at
33 CFR 330.2 (i), which each separate and distant crossing of waters of the United States is
authorized by NWP.....For the purpose of this NWP, the term "crossing" refers to regulated
activities. ...The substations, tower foundations, roads, and temporary fills that are also
authorized by NWP 12 (when those activities require DA authorization) are integral to the
fulfilling the purpose of utility lines, and thus fall within the "categories of activities that are
similar in nature" requirement for general permits stated in section 404(e) of the CWA." .... The
Corps does not regulate oil and gas pipelines, or other types of pipelines, per se. For utility lines,
including oil and gas pipelines, our legal authority is limited to regulating discharges of dredged
or fill material into waters of the United States and structures or work in navigable waters of the
United States, under section 404 of the Clean Water Act and section 10 of the Rivers and
Harbors Act of 1899, respectively. We do not have the authority to regulate the operation of oil
and gas pipelines, and we do not have the authors to address spills or leaks from oil and gas
pipe mes.... n a i ion, we do not have the legal authority to regulate the construction,
maintenance, or repair of upland segments of pipelines or other types of utility lines. For
example, for a recent oil pipeline (e.g., the Flanagan South pipeline), the segments of the oil
pipeline that were subject to the Corps' jurisdiction (i.e., the crossings of waters of the United
States, including navigable waters of the United States, that were authorized by the 2012 NWP
12) was only 2.3 percent of the total length of the pipeline; the remaining 97.7 percent of the oil
pipeline was constructed in upland areas outside of the Corps' jurisdiction. Interstate natural gas
pipelines are regulated by the FERC. The FERC also regulates some electric transmission
projects. There are other federal laws that address the operation of pipelines and spills and leaks
of substances from pipelines. Those laws are administered by other federal agencies." (FR
Notice, January 6, 2017 Final Rule Preamble pp. 1883-1884)
The cumulative impacts analysis submitted with the FERC Resource Report 1, in
support of the project NEPA analysis, is provided in Appendix L for additional details. As part of
the NEPA review by FERC, Atlantic completed an analysis of past/present/and reasonabl
foreseeable projects within the vicinitv of the ACP. majority of the projects identified have
been eva uated as having negligible cumulative impacts, a few identified as minor cumulative
impacts within the area -of direct overlap with the ACP, while none were determined as having
major cumulative impacts. A majorrty of the projects identified in the project area that may result
in cumulative impacts have no direct connection tote or the gas being transporte by the
ACP. These different types of projects generally include electric transmission lines; highway
and roadway projects; and various building facilities and subdivisions.
FPiedmont Natural Gas has several projects that are planned as a result of the expanded
city of natural gas that the ACP interstate natural gas transmission pipeline will provide.
mont has plans for piping modifications and additions for a pipeline interconnect at the
hfield, Fayetteville, and Pembroke Metering and Regulating stations. Piedmont is also
planning a 26 -mile -long, 20 -inch -diameter pipeline project that will tie into the ACP at the
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broke M&R station. These Piedmont projects will be separate permitting actions from the
P and will adhere to all applicable federal and state permitting requirements.
The ACP is an interstate transmission natural gas pipeline which is subject to FERC
authorization. Transmission pipelines are generally larger diameter pipelines that operate at a
higher pressure to transport natural gas across long distances. Transmission lines bring the
natural gas to a connection with a local distribution company or large natural gas customer (e.g.,
power plant), that have either a network of distribution pipelines to connect the grid of existing
pipeline infrastructure and natural gas customers (homes and businesses), or need for large
volumes of natural gag. The companies that utilize the natural gas supplied by the ACP are
separate business entities that will require separate review and approval of the projects proposed
or that may be proposed in the future for their customers and business needs. The ACP will
transport natural gas to the delivery point, or connection with Atlantic customer. Once the
natural gas has been delivered to Atlantic's customer it is no longer under the purview of
Atlantic or the FERC review of the ACP.
As with the ACP, projects that stem from new supply of gas and the available gas that is yet
unsubscribed will require their own due -diligence environmental review Process and will adhere
to applicable federal and state ermitting requirements. ese projects will be separate actions
om the ACP and t e ass ciated permits an environmental review requirements will not be
associated with the ACP.
4. Sewage Disposal (DWR Requirement)
See Section F4 of the PCN Form
5. Endangered Species and Designated Critical Habitat (USACE Requirement)
The ACP is a FERC 7c regulated project and the USACE is participating in the pre -filing
process as a cooperating agency. FERC is coordinating the review of Section 7 Endangered
Species Act compliance with the FWS.
Pursuant to the General Conditions 18 and 31 for NWPs, Atlantic initiated Section 7
Endangered Species Act coordination with the FWS. In a technical assistance letter dated
August 15, 2014 Atlantic initiated the Section 7 review with the FWS North Carolina Raleigh
Ecological Field Services Office. Agency correspondence can be found in Appendix I.
Section 7 of the Endangered Species Act requires federal agencies to verify that any
actions authorized, funded, or carried out by the agencies do not jeopardize the continued
existence of a federally listed threatened or endangered species, or result in the destruction or
adverse modification of designated critical habitat for a federally listed species. The law is
jointly administered by the FWS, which is responsible for terrestrial and freshwater species, and
National Oceanic and Atmospheric Administration National Marine Fisheries Service (NOAA
Fisheries), which is responsible for marine and anadromous species. As the lead Federal agency
for authorizing the ACP, FERC is required to coordinate with the FWS and NOAA Fisheries to
determine whether federally listed endangered or threatened species or designated critical habitat
are found in the vicinity of the ACP, and to evaluate the potential effects of the proposed actions
on those species or critical habitat.
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f
For actions involving major construction activities with the potential to affect listed
species or designated critical habitat, the FERC must report its findings to the FWS and NOAA
Fisheries in a Biological Assessment (BA) for those species that could be affected. If it is
determined that the proposed action is likely to adversely affect listed species or designated
critical habitat, the FERC is required to initiate formal consultation with the appropriate federal
agency.
Atlantic reviewed the Information Planning and Conservation System (IPaC System) to
determine which federally listed species could occur in the ACP Project area. Atlantic
additionally coordinated with the FWS Ecological Field Services Office in North Carolina to
introduce the Project and begin discussing and addressing potential impacts on federally listed
species and designated critical habitat. Correspondence with agencies is located in Appendix I.
For the ACP, Atlantic sent letters to the North Carolina FWS EFSO and the NOAA
Fisheries' Office of Protected Resources in August 2014 requesting early coordination and
technical assistance based on the species lists obtained through the IPaC System. These letters
requested verification of the species that could be impacted by the ACP Project as well as
direction on field survey protocols for species-specific surveys.
Atlantic requested and received National Heritage Inventory data for a two -mile -wide
corridor centered on the proposed pipeline centerlines which includes the locations of
aboveground facilities. This data identifies occurrences of state and federal -listed species as well
as sensitive or significant habitats including parks, forests, or nature preserves located along or
( adjacent to the proposed pipeline routes.
Based on information obtained through IPaC System, National Heritage Inventory, and
agency consultations, Atlantic has compiled a preliminary list of 20 federally listed, proposed, or
under review species that potentially occur within the ACP Project area within the USACE —
Wilmington District (Table 8).
Atlantic has prepared a final draft BA (version 5) evaluating the potential impacts of the
Projects on federally listed species. Atlantic filed the final draft BA with FERC on January 27,
2017, and a copy was also provided to the FWS and the USAGE.
State -listed species in North Carolina are separated into three categories: North Carolina
Endangered, North Carolina Threatened, and North Carolina Special Concern. Species listed in
these categories have been recognized as needing additional conservation by the North Carolina
Wildlife Resources Commission (NCWRC) under the State Endangered Species Act (G. S. 113-
331 to 113-337).
Atlantic requested and received data on known occurrences of State -listed species within
a two -mile -wide corridor centered on the proposed ACP pipeline routes from the NCDEQ.
Table 9 summarizes this data.
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TABLE 8
Atlantic Coast Pipeline Project
Federally Listed Species and Species Proposed for Federal Listing within the U.S. Army Corps of Engineers — Wilmington District
Species
Status'
Areas of Potential Occurrence
Bird
Red -cockaded Woodpecker
E
All counties crossed by the Project
(Picoides borealis)
Wood Stork
E
Sampson County
(Mycteria Americana)
Fish
Atlantic Sturgeon
E
Roanoke and Neuse Rivers
(Acipenser oxyrinchusoxynnchus)
Cape Fear Shiner
E
Cape Fear River Drainage
(Notropts mekistocholas)
Carolina madtom
UR
Tar and Neuse River Basins
(Noturusfuriosus)
Shortnose Sturgeon
E
Downstream occurrences in adjacent Bladen County
(Cipenser brevirostrum)
Freshwater Mussels
Atlantic pigtoe
UR
Northampton, Halifax, Nash, Wilson, Johnston, and Cumberland Counties
(Fusconaia masons)
Dwarf Wedgemussel
E
Wilson, Johnston, and Nash Counties
(Alasmidonta heterodon)
Tar River Spmymussel
E
Halifax, Johnston, and Nash Counties
(Elliptio stemstansana)
Green floater
UR
Roanoke, Tar, and Neuse River basms
(Lasmigona subvindis)
Yellow Lance
P
Halifax, Johnston, and Nash Counties
(Elliptio lanceolata)
Invertebrate
Saint Francis' Satyr
E
Cumberland County
(Neonympha mitchellitfrancisci)
Chowanoke crayfish
UR
Roanoke River basin
(Orconecies virgimensis)
Rusty patched bumble bee
P
Entire project area
(Bombus ajfinrs)
Mammals
Northern long-eared bat
T
All counties crossed by the Project
(Myotis septentrionahs)
Plants
American Chaffseed
E
Cumberland County
(Schwalba americana)
Michaux's Sumac
E
Cumberland, Johnson, Nash, Robeson, and Wilson Counties
(Rhus michauxii)
Pondbeny
E
Cumberland and Sampson Counties
(Lindera melisstfolia)
Rough -leaved Loosestrife
E
Cumberland County
(Lysimachia asperuhfolia)
Amphibians
Neuse River waterdog
UR
Tar and Neuse River Basins
(Necturus lewist)
° Abbreviations for species federal status are as follows
E = Endangered
T = Threatened
UR — Under review
P - Proposed
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TABLE 9
State -listed Endangered and Threatened Species within the U.S. Army Corps of Engineers —Wilmington District
Species
Status'
Area of Potential Occurrence
Amphibians
Neuse River Waterdog
SC
Halifax, Nash, Johnston, Wilson
Mammals
Rafinesque's Big -eared Bat (Coastal Plain subspecies)
SC
All Counties Crossed
Southeastern Myotis
SC
All Counties Crossed
Birds
Bachman's Sparrow
SC
Halifax, Sampson, Cumberland, Robeson
Cerulean Warbler
SC
Halifax, Northampton
Fish
Carolina Madtom
T
Halifax, Nash, Johnston, Wilson
Crayfish
SC
Halifax, Northampton
North Carolina Spiny Crayfish
SC
Nash
Reptiles
Southern Hog -nosed Snake
SC
Robeson
Freshwater Mussels
Alewife Floater
T
Halifax, Nash, Johnston, Wilson
Atlantic Pigtoe
E
Halifax, Nash, Johnston, Wilson
Cape Fear Spike
SC
Halifax, Nash, Johnston, Wilson
Creeper
T
Halifax, Nash, Johnston, Wilson
Eastern Lampmussel
T
Halifax, Nash, Johnston, Wilson
Eastern Pondmussel
T
Halifax, Nash, Johnston, Wilson
Green Floater
E
Halifax, Nash, Johnston, Wilson
Notched Rainbow
SC
Halifax, Nash, Johnston, Wilson
Roanoke Slabshell
T
Halifax, Nash, Johnston, Wilson
Tidewater Mucket
T
Halifax, Nash, Johnston, Wilson
Triangle Floater
T
Halifax, Nash, Johnston, Wilson
Yellow Lampmussel
E
Halifax, Nash, Johnston, Wilson
Yellow Lance
E
Halifax, Nash, Johnston, Wilson
Plants
American Bluehearts
E
Sampson
Awned Meadow -beauty
SC
Cumberland, Robeson, Sampson
Bog Spicebush
P
Cumberland, Johnston, Robeson
Boykin's Lobelia
E
Cumberland, Robeson
Buffalo Clover
T
Halifax
Canby's Bulrush
SR
Cumberland, Johnston
Cape Fear Spatterdock
P
Cumberland, Nash, Robeson, Sampson
Carolina Bogmmt
E
Johnston, Robeson, Sampson
Georgia Indigo -Bush
E
Cumberland, Robeson
Long Beach Seedbox
P
Cumberland, Johnston, Robeson, Sampson
One -flower Hardscale
SR
Cumberland, Robeson, Sampson
Raven's Seedbox
T
Sampson
Running Oak
SR
Robeson
Sandhills Lily
E
Cumberland
Sessile -flowered Trillium
T
Halifax, Northampton
Small -flower Blueberry
SR
Cumberland, Robeson
Spring -flowering Goldenrod
SR
Cumberland, Johnston, Sampson
Thin-wall Quillwort
T
Sampson
Winter Quillwort
P
Johnston, Sampson
Abbreviations for state -listed species are as follows
E = Endangered
T = Threatened
SC = Special Concern
SR= Significantly Rare
P = Petitioned for Federal listing
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In addition to this data, Atlantic solicited and received comments in a letter dated
November 21, 2014 from the NCWRC regarding known occurrences of State -listed aquatic
species along the proposed routes. The NCWRC requested a mussel survey in streams that are
second order or larger within the Neuse and Tar River basins. For any streams where mussels
are present at the crossing, a second mussel survey is planned to relocate mussels that could be
impacted during pipeline installation. Surveys for Carolina madtoms will be completed at the
same time as the mussel surveys in the Tar and Neuse basins. The NCWRC also requested
mussel surveys in the Roanoke and Cape Fear Rivers immediately prior to pipeline installation to
relocate mussels that will be impacted by construction.
Migratory Bird Treaty Act and Bald and Golden Eagle Protection Act
Atlantic will comply with the applicable portions of both the Migratory Bird Treaty Act
(MBTA) and the Bald and Golden Eagle Protection Act. Atlantic plans to clear the pipeline
right-of-way outside of the migratory bird nesting season to reduce potential impacts on
migratory birds and other sensitive species. Atlantic will avoid impacts on nests observed within
the construction right-of-way in accordance with the MBTA. In the event that an active bald
eagle nest is identified in the vicinity of the project, Atlantic will adhere to the requirements of
the National Bald Eagle Management guidelines to minimize potential impacts on nesting eagles.
Migratory Bird Plan to describe measures it has implemented or will implement to avoid,
minimize and mitigate potential impacts on migratory birds, including bald and golden eagles,
consistent with the MBTA and Bald and Golden Eagle Protection Act Plan to the FERC on May
5, 2017, with a copy sent also to the FWS and the USAGE.
6. Essential Fish Habitat (USACE Requirement)
Atlantic consulted with NOAA Fisheries' Southeast and Northeast Regional Offices to
introduce the ACP and request technical assistance (Dominion, 2014a; Dominion, 2014b). In
their reply, the Southeast Regional Office (NOAA Fisheries, 2014a) concurred with Atlantic that
no Essential Fish Habitat (EFH) will be affected by the proposed ACP in North Carolina because
the AP -2 mainline route does not cross or pass near EFH. In addition, the AP -3 mainline does
not cross or pass near EFH in North Carolina.
7. Historic or Prehistoric Cultural Resources (USACE Requirement)
The ACP is a FERC 7c regulated project and the USACE is participating in the FERC
NEPA process as a cooperating agency. FERC, as the lead agency for the project, will be
coordinating with the North Carolina State Historic Preservation Office for the review of
compliance with Section 106 of the National Historic Preservation Act, as well as coordinating
its government -to -government consultation with federally recognized Indian Tribes.
For the FERC process, the area of potential effect (APE) for archaeological sites was
defined horizontally as the proposed pipeline corridor and associated workspace, footprints of
aboveground facility sites, and footprints of other work areas; and vertically as the maximum
depth of trenching and other excavations or the depth to which evidence of human occupation --
could be found. The APE for aboveground historic resources was defined to include the
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proposed pipeline corridor and associated workspace, footprints of aboveground facility sites,
and footprints of other work areas. The APE for aboveground historic resources also included
viewsheds to and from historic sites along or near the proposed facilities. The linear extent of
the viewsheds varied by site depending on changes in topography, vegetation cover, and the
presence of structures or other obstructions in sight lines to and from aboveground historic
resources.
The reports presenting the results of the cultural resources surveys for the Project can be
provided to the USACE — Wilmington upon request, along with copies of documentation of State
Historic Preservation Office review and comment when they become available. See Appendix M
for the Plan for Unanticipated Discovery of Historic Properties or Human Remains During
Construction.
Cultural resources that are listed eligible or recommended eligible for the National
Register of Historic Places (NRNP) that are within the direct or visual APE and cannot be
avoided by the project will be subject to Section 106 regulations at 36 CFR § 800.6(b)(1)(i-iv).
Those regulations require the federal agency, in this case FERC, to consult with the State and/or
Tribal Historic Preservation Officer (SHPO, THPO) and other parties to negotiate and execute a
Section 106 agreement document that sets out the measures the federal agency will implement to
resolve those adverse effects through avoidance, minimization, or mitigation.
8. Tribal Coordination
The ACP is a FERC 7c regulated project and the USACE is participating in the pre -filing
process as a cooperating agency. FERC will be coordinating with the North Carolina State
Historic Preservation Office for the review of Section 106 of the National Historic Preservation
Act compliance, as well as coordinating its government -to -government consultation with
federally recognized Indian Tribes as part of the Section 106 consultation process. Project
introduction letters for the entire ACP/SHP were sent to 15 federally recognized Indian Tribes
that might have interest in the Project area based on historic information. See Appendix N for a
summary of communications with these Indian Tribes. The 15 federally recognized Indian tribes
that were contacted regarding the ACP and/or SHP are listed below:
• Absentee -Shawnee Tribe of Indians of Oklahoma;
• Catawba Indian Nation;
• Cherokee Nation;
• Delaware Nation;
• Delaware Tribe of Indians;
• Eastern Band of Cherokee Indians;
• Eastern Shawnee Tribe of Oklahoma;
• Pamunkey Tribe;
• Seneca -Cayuga Tribe of Oklahoma;
• Seneca Nation of Indians;
• Shawnee Tribe;
• Stockbridge Munsee Community;
• Tonawanda Band of Seneca Indians of New York;
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r
• Tuscarora Nation of New York; and
• United Keetoowah Band of Cherokee Indians.
Atlantic contacting state recognized tribes in the ACP project area in Virginia and North
Carolina. The following seven state recognized tribes identified by the North Carolina
Commission of Indian Affairs were contacted for the ACP:
1. Coharie Tribe;
2. Haliwa-Saponi Indian Tribe;
3. Lumbee Tribe of North Carolina;
4. Meherrin Indian Tribe;
5. Occaneechi Band of the Saponi Nation;
6. Sappony Tribe; and
7. Waccamaw Siouan Tribe.
The following 10 state recognized tribes identified by the Secretary of the
Commonwealth of Virginia Commission of Indian Affairs were contacted for the ACP:
1.
Cheroenhaka (Nottoway) Tribe;
2.
Chickahominy Tribe;
3.
Eastern Chickahominy Tribe
4.
Monacan Indian Nation;
5.
Mattoponi Tribe;
6.
Nansemond Tribe;
7.
Nottoway Tribe;
8.
Patawomeck Tribe;
9.
Rappahannock Tribe; and
10.
Upper Mattaponi Tribe.
There are no state recognized Indian tribes in West Virginia.
Atlantic sent introductory Project letters to the Indian tribes which included a Project
description and location maps, and invited each tribe to comment on the Project. In addition, the
letters requested input from each of the tribes regarding the potential of the Project to affect
archaeological sites, burials, and traditional cultural properties of concern to each tribe. Atlantic
received confirmation of delivery of all of the letters. Communication with the tribes is ongoing
as part of the Section 106 consultation process.
9. Flood Zone Designation (USACE Requirement)
The ACP Project will cross several Federal Emergency Management Agency -designated
100 -year floodplains throughout North Carolina. Atlantic will apply for local permits as required
by regulations and local agencies. Federal Emergency Management Agency 100 -year
floodplains crossed by the ACP can be found in Appendix A — Figure A-5. Atlantic has been
working with the counties in North Carolina and will apply for applicable floodplain permits.
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G. SECTION 408 AUTHORIZATION
Section 14 of the Rivers and Harbors Act of 1899 and codified in 33 U.S. Code 408
(commonly referred to as "Section 408") authorizes the Secretary of the Army, on the
recommendation of the Chief of Engineers of the USACE, to grant permission for the alteration
or occupation or use of a USACE Civil Works project if the Secretary determines that the
activity will not be injurious to the public interest and will not impair the usefulness of the
project.
Atlantic submitted a letter to the USACE — Wilmington District on June 15, 2016
requesting a review of the USACE projects within Wilmington District Civil Works boundaries
that may be crossed by the ACP, to determine if a Section 408 permission would be required.
Wilmington District reviewed the location of proposed ACP pipeline and facilities and determined that
the crossing of the Cape Fear River would require a Section 408 permission. The District, in a
letter dated November 3, 2016 signed by Colonel Kevin P. Landers, Sr., Commander Wilmington
District, granted the request for the pipeline to cross the Cape Fear River for the following reasons:
"(1) the proposed action will not be injurious to the public interest, and (2) the proposed action will not
impair the usefulness ofthe federal project. As the requestor, Atlantic is solely responsible for any
remedial action needed to correct any deficiency in the design or construction of the requested
alteration. " Correspondence is included in Appendix I.
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H. REFERENCES
Dominion. 2014a. Letter to David Dale (NOAA Fisheries EFH Southeast Region Coordinator)
from William Scarpinato (Dominion) dated September 9, 2014.
Dominion. 2014b. Letter to Karen Greene (NOAA Fisheries EFH Northeast Region
Coordinator) from William Scarpinato (Dominion) dated September 9, 2014.
ICF International. 2014. The Economic Impacts of the Atlantic Coast Pipeline. Prepared by
ICF International for Dominion Transmission, Inc. February 9, 2015. Available online
at: https://www.dom.com/library/domcom/pdfs/gas-transmission/atlantic-coast-pipeline/
acp-icf-study.pdf. Accessed May 2015.
U.S. Army Corps of Engineers. 1987. Corps of Engineers Wetlands Delineation Manual.
Technical Report Y-87-1, U.S. Army Engineer Waterways Experiment Station,
Vicksburg, Miss.
U.S. Army Corps of Engineers. 2005. Ordinary High Water Mark Identification. Regulatory
Guidance Letter No. 05-05. Available online at: http://www.usace.army.mil/Portals/2/
docs/civilworks/RGLS/r l0�pdf. Accessed January 22 2015.
U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Atlantic and Gulf Coastal Plain Region (Version 2.0). ERDC/EL
TR -10-20. Vicksburg, MS: U.S. Army Engineer Research and Development Center.
U.S. Census Bureau. 2014. 2005 Interim State Population Projections. Available online at:
https://www.census.gov/population/projections/data/state/proiectionsagesex.html.
Accessed October 2014.
U.S. Department of Energy. 2015. Natural Gas Infrastructure Implications of Increased
Demand from the Electric Power Section. Available online at: http://energy.gov/sites/
prod/files/2015/02/f19/DOE%20Report%20Natural%20Gas%20Infrastructure%20V 02-
02.pdf. Accessed February 2015.
U.S. Energy Information Administration.2015a. Annual Energy Outlook 2015.Available online
at: http://www.eia.gov/forecasts/aeo/. Accessed June 2015.
U.S. Energy Information Administration.2015b. Market Trends; Electricity Demand. Available
online at: http://www.eia.gov/forecasts/aeo/MT electric.cfrn. Accessed June 2015.
U.S. Energy Information Administration.2015c. Market Trends; Natural Gas. Available online
at: http://www.eia.gov/forecasts/aeo/mt natural ag s.cfm. Accessed June 2015.
U.S. Energy Information Administration.2015d. Natural Gas Summary for Virginia. Available
online at: http://www.eia.gov/dnav/ng/ng_sum lsum dcu SVA a.htm. Accessed June
2015.
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U.S. Energy Information Administration.2015e. Natural Gas Summary for North Carolina.
Available online at: http://www.eia.gov/dnav/ng/ng sum lsum dcu SNC a.htm.
Accessed June 2015.
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