Siler City, NC – In the formal request posted below, veteran biologist John Alderman urges the U.S. Army Corps of Engineers to conduct a comprehensive Environmental Impact Statement for a proposed natural gas pipeline in Chatham County. Alderman argues that the project threatens the Rocky River-Deep River system, which serves as the primary critical habitat for the endangered Cape Fear Shiner. Beyond immediate construction damage such as sedimentation and blasting, the letter highlights the need to evaluate indirect development and cumulative stressors on the local watershed. Furthermore, the letter emphasizes the need for public transparency regarding the project’s necessity and its potential to disrupt working farms through eminent domain. Ultimately, John Alderman contends that the region’s ecological rarity warrants the most rigorous federal scrutiny to ensure long-term environmental and agricultural preservation.
July 6, 2026
Colonel Brad A. Morgan
District Commander
U.S. Army Corps of Engineers, Wilmington District
69 Darlington Avenue
Wilmington, NC 28403-1343
Re: Request for Preparation of an Environmental Impact Statement for the Proposed 28- Mile-Long Enbridge Gas North Carolina Chatham County Pipeline Section 404 Permit (Expected Permit Application During 2026)
Dear Colonel Morgan:
I respectfully request that the U.S. Army Corps of Engineers prepare a full Environmental Impact Statement (EIS) pursuant to the National Environmental Policy Act (NEPA), 42 U.S.C. §§ 4321-4370m-12, before making any decision on Enbridge Gas North Carolina’s anticipated application for a Section 404 permit under the Clean Water Act, 33 U.S.C. § 1344, for its proposed natural gas transmission pipeline across rural Chatham County.
As a retired aquatic endangered species biologist with more than forty years of professional experience (NC Wildlife Resources Commission, NC DOT, and private sector) evaluating southeastern river systems and federally protected aquatic species, my comments are offered to assist the Corps in fulfilling its responsibilities under NEPA, the Clean Water Act, the Endangered Species Act (ESA), 16 U.S.C. § 1536, and the Fish and Wildlife Coordination Act, 16 U.S.C. §§ 661-667e. Based upon my professional experience and familiarity with the affected watershed, this proposal presents substantial questions regarding significant environmental effects that warrant preparation of an EIS rather than a more limited Environmental Assessment.
The most compelling reason for preparing an EIS is the extraordinary biological importance of the Rocky River-Deep River system. The North Carolina Natural Heritage Program identifies this interconnected river system as containing the only A-Ranked (Excellent Viability) Element Occurrence of the federally endangered Cape Fear Shiner (Notropis mekistocholas). This represents the highest-quality documented occurrence of the species throughout its entire range and gives this river system exceptional importance to the species’ long-term survival and recovery.
Portions of the Rocky and Deep rivers occupied by the Cape Fear Shiner have also been designated as Critical Habitat under the Endangered Species Act because they contain the physical and biological features essential to the species’ conservation and recovery. Accordingly, the Corps’ permitting decision involves not only potential effects on a federally endangered vertebrate, but also on habitat that the federal government has determined is essential to the species’ recovery.
The Cape Fear Shiner occupies localized reaches associated with beds of water willow (Justicia americana) during much of the year. Because this habitat is naturally patchy and limited, disturbances affecting even relatively small portions of these rivers may have consequences that are disproportionately important to the long-term viability of the species. These biological circumstances alone warrant comprehensive environmental review.
The Corps should evaluate all direct environmental effects associated with pipeline construction, including stream crossings, wetland impacts, sedimentation, erosion, blasting through bedrock, horizontal directional drilling, groundwater alteration, riparian vegetation removal, construction access, heavy equipment operation, accidental releases of fuels, hydraulic fluids, and other contaminants, and degradation of habitat supporting federally protected aquatic species. Because the continued existence and recovery of a federally endangered vertebrate species are at issue, the analysis should not be limited to perennial streams but should include the complete network of perennial, intermittent, and ephemeral tributaries that contribute flow, sediment, water quality, and ecological functions to occupied habitat.
The direct effects analysis should also evaluate construction in steep or erodible terrain, cutting or blasting through extremely hard metavolcanic bedrock, stream-bank disturbance, temporary and permanent access roads, staging areas, trench dewatering, blasting-related changes in groundwater movement, effects on springs and private wells, and post-construction right-of-way maintenance. These impacts should be evaluated in relation to the function of the entire tributary network, not merely the acreage of wetlands or linear feet of stream channel directly filled or excavated.
Equally important, this project presents a compelling need for the transparency that only the EIS process provides. Throughout the state and federal review processes, Enbridge is not otherwise required to publicly present a comprehensive analysis demonstrating the project’s public need or a detailed comparison of reasonable alternatives. As a result, affected landowners, local governments, resource agencies, and the public may never have a meaningful opportunity to understand why this project is proposed, whether the selected route is justified, or whether less environmentally damaging alternatives exist.
The EIS process is unique because it requires a rigorous evaluation of the project’s purpose and need together with a comparison of reasonable alternatives before irreversible federal decisions are made. This comprehensive alternatives analysis also complements the Corps’ Section 404 public interest review and evaluation of the least environmentally damaging practicable alternative. For a project involving the exercise of eminent domain, impacts to private property, bona fide farms, Voluntary Agricultural District farms, other important farmlands, and nationally significant aquatic resources, that level of transparency is essential.
The Corps should evaluate whether reasonable alternatives could accomplish the project’s stated objectives while substantially reducing environmental impacts. Those alternatives should include greater use of existing gas pipeline easements where practicable, route adjustments to avoid high-value aquatic resources, route adjustments to reduce impacts to working farms and Voluntary Agricultural District farms, and construction methods designed to avoid or minimize impacts to streams, wetlands, groundwater, and designated Critical Habitat.
The Corps should also evaluate all reasonably foreseeable indirect effects associated with the proposed project. Publicly available information indicates that additional natural gas transmission capacity is expected to support continued industrial expansion within central North Carolina, including development associated with large data centers and other energy-intensive facilities, which Enbridge’s own shareholder documents acknowledge.
These indirect effects are particularly important because the proposed pipeline is not an isolated construction project. Its apparent purpose is to increase gas transmission capacity in a region already experiencing rapid land-use change and increasing infrastructure demand. The EIS should therefore evaluate whether the federal permit would facilitate additional development, energy infrastructure, increased water withdrawals, wastewater discharges, stormwater runoff, transportation improvements, and other reasonably foreseeable secondary effects that may affect the Rocky River-Deep River system and downstream aquatic resources.
A comprehensive cumulative effects analysis is equally important. The Rocky River-Deep River watershed is already experiencing numerous environmental stressors, including altered flow regimes associated with reservoirs and water withdrawals; increasing municipal and industrial water demand; rapid subdivision and industrial development; expanding impervious surfaces; increased stormwater runoff; erosion and sedimentation; lack of local government control over distribution of water and sewer infrastructure; and wastewater discharges and treatment challenges, including concerns associated with the Siler City wastewater treatment system. An extremely important component of cumulative effects analysis is whether North Carolina state monitoring of pipelines is sufficient to protect resources, including violation warnings and Notices of Violations when necessary, stopped projects to correct inadequacies, and fines levied to ensure compliance. A state-by-state comparison with Virginia would be helpful in this analysis.
The EIS should evaluate these existing watershed conditions together with the direct and reasonably foreseeable indirect effects of the proposed pipeline. The central question is not whether any individual crossing or construction activity, viewed in isolation, appears small. The relevant question is whether the proposed federal action, when added to existing and reasonably foreseeable watershed stressors, may significantly affect the quality of the human environment, designated Critical Habitat, and the long-term survival and recovery of the federally endangered Cape Fear Shiner.
Agricultural impacts should also be evaluated as part of the EIS. The proposed pipeline would cross or affect private farms, bona fide farms, Voluntary Agricultural District farms, managed forestland, and other important farmlands. Potential impacts include fragmentation of working farms, interference with farm roads and access, disruption of drainage systems, soil compaction,
loss of productive soils, constraints on forestry and agricultural operations, long-term right-of way maintenance restrictions, and reduced viability of affected farm enterprises. These impacts are part of the human environment and should not be treated as secondary concerns.
The Fish and Wildlife Coordination Act recognizes that fish and wildlife conservation must be fully considered whenever federal actions involve the control or modification of waters. Accordingly, I respectfully request that the Corps ensure close coordination with the U.S. Fish
and Wildlife Service, the North Carolina Wildlife Resources Commission, and other appropriate resource agencies throughout preparation of the EIS.
Because of the exceptional biological importance of the affected watershed, the presence of designated Critical Habitat for the only viable population of the Cape Fear Shiner, the presence of several aquatic species which may become federally listed, the substantial questions regarding direct, indirect, and cumulative environmental effects, and the need for a transparent public evaluation of the project’s purpose, need, and reasonable alternatives, I respectfully request that the Wilmington District announce its intent to prepare a full EIS before making any permitting decision under Section 404 of the Clean Water Act.
The Corps’ decision on this permit will have consequences extending well beyond the immediate construction corridor. It will influence the long-term protection of one of North Carolina’s most significant aquatic ecosystems, one of the nation’s rarest freshwater fishes, and conservation of rapidly declining farmland. I respectfully urge the Corps to exercise the highest level of environmental review for this anticipated permit application before authorizing any activities under Section 404 of the Clean Water Act.
Thank you for your consideration of this request and for your continued commitment to carrying out the Corps’ responsibilities under federal law.
Respectfully,
John M. Alderman