SACE Comments Opposing Water Quality Certification of the Enbridge T15

SACE filed comments on July 25th in the NC DEQ Section 401 water quality certification proceeding for the PSNC/Enbridge T15 Reliability Project. The T15 Project would place a new large diameter, high-pressure fracked gas pipeline next to the existing T15 pipeline that starts at an interconnection with Williams’ Transco pipeline near the Dan River in Rockingham County. The pipeline would stretch for 45 miles across Rockingham, Caswell, and Person Counties, including an 8-mile lateral up to Duke Energy’s proposed 2,720 MW gas plant complex on Hyco Lake next to the Roxboro coal plant.

SACE’s comments focused on two concerns:

1. The proposed pipeline’s upland construction activities cannot be effectively mitigated enough to offset the impacts of increasingly torrential rainfall exacerbated by climate change. 

There simply are no protection or mitigation strategies that will prevent damage to North Carolina’s streams when upland land clearing activities meet the ferocious rain and flooding that now routinely occur in North Carolina. SACE shared photos from a 2018 pipeline project in the Upstate of South Carolina, where the topology is similar to the impacted North Carolina counties, that demonstrate the catastrophic failure of erosion control devices even on gentle slopes (see below). 

We included stills from WRAL’s video footage of Hyco Lake right after Tropical Storm Chantal to illustrate just how extensive sedimentation of streams after a climate change-fueled rain event can be (see below).

 2. Enbridge has not been transparent with stakeholders, and this creates a more dangerous and damaging project.

SACE documented that Enbridge evaded answering our questions, answers to which would be readily available if the pipeline were a FERC-regulated pipeline. Because the T15 is a state-regulated pipeline, Enbridge is not held to the standards of information-sharing required by NEPA, and this leads to a less thorough and robust process that endangers the North Carolinians who live, work, and attend school near the pipeline blast zone. Further, SACE is concerned that neither the NC DEQ nor the NC Utilities Commission Natural Gas Pipelines Safety Section has adequate staff to provide oversight of such a consequential project.

For these reasons:

Damage to our waters is guaranteed.

There is no transparency in the process.

There is no reason to trust that PSNC/Enbridge will adhere to the highest standards.

North Carolina doesn’t have the oversight staffing capacity to hold PSNC/Enbridge accountable.

SACE recommends that the NC DEQ deny the certification. Read our full comments here.

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