would have banned the treatment, discharge, disposal or storage of hydraulic fracturing waste in New Jersey. Pennsylvania sends its waste to New Jersey companies interested in processing and disposing of waste water or "flowback" from hydraulic fracturing within the state. Christie claimed the Senate bill would have undercut the state's ongoing study of hydraulic fracturing, and would discriminate against other states, a violation of the Dormant Commerce Clause of U.S. Constitution. North Carolina In 2012, the state had estimated reserves of 83 million barrels of natural gas liquids, which was said to equal a 5-year supply. On July 2, 2012, hydraulic fracturing (fracking) and horizontal drilling were legalized under Session Law 2012-143 (S. 820). The North Carolina Department of Environmental Quality (NCDEQ) requires companies to still obtain a permit before they allow any drilling. This 2012 legalization comes after a 1945 law that banned horizontal drilling, a key component of fracking. Legislation was then passed in 2014 to create the Oil and Gas Commission which would replace the Mining and Energy Commission. Despite the fact that laws were passed to make fracking legal, as of July 2017 there have been no steps to drill or even build a well. In late 2017, the construction of the Atlantic Coast Pipeline started. A $6 billion project, the pipeline is planned to be routed parallel to I-95 in North Carolina. The Atlantic Coast Pipeline is being built by energy companies Duke Energy and Dominion Energy with the goal of providing natural gas to residential and industrial areas of North Carolina. The natural gas that will be transported in the pipeline is from Pennsylvania and West Virginia, fracked from the Marcellus Shale. The North Carolina portion of the pipeline will cross 320 North Carolina streams. In December 2018, the construction was halted in Virginia due to its impact on endangered species, and its crossing of the Appalachian Trail. There has been argument over the pipeline between North Carolina politicians and the governor over the funding of the pipeline. Ohio According to the Ohio Department of Natural Resources, approximately 80,000 oil and gas wells in Ohio have been hydraulically fractured since 1951. Ohio does not allow frac flowback or produced brine to be disposed of to surface streams; 98 percent of produced water is injected into Class II disposal wells, the remaining 2 percent is used for dust and ice control on roads, subject to