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Dear Deputy Secretary Davis:

Thank you for the opportunity to comment on the Draft Environmental Impact Statement (DEIS) prepared by the Federal Energy Regulatory Commission (FERC) on the Atlantic Coast Pipeline (ACP) and related Supply Header Project (SHP).

Please accept these comments on behalf of Earthworks, a national nonprofit organization committed to protecting communities and the environment from the impacts of mining and energy development while seeking sustainable solutions. For more than 25 years, we have fulfilled our mission by working with communities and grassroots groups to reform government policies, improve corporate practices, influence investment decisions and encourage responsible materials sourcing and consumption.

Earthworks’ comments focus both on the general approach and scope of the DEIS and on specific air quality considerations related to ACP and SHP. Since 2015, we have conducted over 650 individual investigations into air emissions from oil and gas facilities in 16 states using an Optical Gas Imaging camera (specifically a Forward Looking Infrared GF320). This includes three facilities in Virginia owned and operated by Dominion Energy, the videos of which we are submitting along with these comments.

Earthworks is also submitting along with these comments our 2017 report Permitted to Pollute: how oil & gas operators and regulators exploit clean air protections and put the public at risk.1 To conduct this in-depth investigation, we researched the permits, plan approvals, operators’ estimated and reported emissions, and conducted air pollution sampling at three natural gas facilities in southwestern Pennsylvania. Some of our key findings are directly related to the gaps in the DEIS for ACP and SHP.