DOCKET # P-2197-060

APPLICANT: Alcoa Power Generating Inc.

Name of Project:  Yadkin



As stated in our previous filings on Feb. 19, 2003 (Ferris submittal 20030228-0063)  and subsequently on Feb. 26, 2003 (Ferris submittal 20030226-5042), we are requesting that Alcoa Power Generating Inc.’s Yadkin Drought Contingency Plan for 2003 be rejected as inadequate and incomplete. 

 The directive from the FERC stated the plan should examine alternative management practices, early reduction in discharges and describe an implementation schedule.  It also stated that one of the principle goals of the plan should be to ensure that the elevation of High Rock Lake is maintained within five feet of full pool.  Finally, the directive offered the assistance of the FERC staff to assist in the development of the plan.   

The Plan submitted by APGI actually contains no steps to address the items specifically mentioned in the directive from the FERC and contains no specific implementation schedule.  More importantly, the creators of the Plan specifically chose to ignore the input of the NCDENR after recognizing them as being “experts” in natural resource management and protection.  Finally, after stating in the footnotes that they did not understand why they were being asked to create such a plan, there is no evidence of any request for assistance from the FERC staff as had been offered.  

The events of 2001 and 2002 proved beyond any reasonable doubt that the “rule curve” and drawdown schedules included in the current license are inadequate to properly protect this valuable natural resource.  The current “rule curve” appears to contain conflicting goals of maintaining reservoir levels and discharge levels without clear guidance as to which should take priority if both conditions can not be maintained.  The current terminology states that the discharge from Project 2197 should be “limited to” specific figures based on the time of the year but does not distinguish if this is a minimum limit or a maximum limit.  APGI interprets this to be a minimum discharge which is in direct conflict with the elevation limits if inflow is not considered.  In most situations where a “limit” is imposed, such as a “speed limit”, it is a maximum limit.  Management of the river basin during low flow conditions must include all of the reservoirs to adequately protect the interests of all stakeholders.    

We have survived what we all hope will be the worst case scenario for the Yadkin-Pee Dee river basin and have the actual measured stream flow data available to use for modeling future operational scenarios.  In the absence of a detailed Drought Contingency Plan designed to protect the interests of all of the stakeholders in the Yadkin-Pee Dee River basin during periods of drought and/or low flow conditions, we respectfully request that ALL of FERC Project 2197 and FERC Project 2206 be directed to operate as “run of the river” facilities.  

We realize that a simple “run of the river” operation for both projects would be easiest regime to implement and should cover the basic environmental considerations downstream.  Riparian areas downstream have no reasonable right to expect any more water to be discharged from the projects than comes into them at any time.  As an organization concerned about the welfare of the whole river basin, we feel that when evaluating the benefit of the projects to the public, reasonable consideration of downstream areas should be included during periods of drought.  LIMITED consumption of the storage capabilities of the reservoirs should be considered during periods of prolonged or extreme drought but only within boundaries that will ensure the protection of the reservoirs themselves and the communities surrounding them.  

At this time we appear to be the only organization who has taken the time to do any analysis of the actual flow data recorded by the USGS sensors around the two Projects during this period of extreme drought.  We developed a spreadsheet model using the actual flow readings from the Yadkin College and Rocky River sensors for 2001 and 2002.  We tested several different management scenarios to evaluate the effects of different discharge limits on total storage capacity at High Rock Lake .  The calculations in the spreadsheet assumed the following, based on the concept of being in extreme drought conditions:

We understand that the very rigid process of daily reaction to river flow conditions would be difficult to duplicate in the real world but the concept is used to allow for trend analysis and comparisons to the exact same concept using higher minimum discharge readings at the Rockingham NC USGS sensor.  Since the discharge adjustments for different times of the year included in the present license are not included in the calculations, the current discharge limit figures were averaged together and the simulation was run using the average of 1626 cfs.  Below is a graph of the results.

The results clearly indicate that proper prioritization and management of the watershed during extreme drought conditions with quick reaction to decreasing river flow conditions and a realistic minimum discharge figure at the Rockingham NC USGS sensor would have resulted in a greatly reduced impact to the entire river basin.  For the sake of simplicity, this graph only indicates the potential acre foot depletion at High Rock Lake and assumes that every other lake was maintained at or near full pool.  Including the proportional drawdowns in our proposal, it is possible that no lake would have been drawn down more than 4 or 6 feet during 2002 and the discharge into the Pee Dee River would have been maintained at a 25 percent higher level.   

We would like to propose the following Operating Guidelines for Project 2197 and Project 2206 for consideration.  

  1. Establish a “ Target Range ” of full pool to -4 feet for High Rock, Badin, Falls, Tillery and Blewett Falls Lakes and full pool to -3 feet for Tuckertown.
  2. Establish a “Target Level” at High Rock Lake of 2 to 3 feet below full pool.
  3. Establish a maximum drawdown of 8 feet below full pool for High Rock, 3 feet below full pool for Tuckertown, 12 feet below full pool for Badin, Falls and Tillery and 6 feet below full pool for Blewett Falls Lake .
  4. Establish a “minimum discharge target” at the Rockingham NC USGS sensor of 1200 cfs.
  5. Operate all of project 2197 and project 2206 as “run of the river”.  Any time inflow to High Rock Lake drops below the “minimum discharge target”, attempt to hold each lake within it’s target range by discharging no more from project 2197 than is necessary to maintain the “minimum discharge target” at the Rockingham NC USGS sensor.
  6. Once High Rock Lake is 4 feet below full pool, begin a 3 foot drawdown at Tuckertown then a 4 foot drawdown at Badin Lake , Falls Lake , Lake Tillery and finally Blewett Falls Lake .
  7. Once every lake is 4 feet below full pool, have a group of stakeholders (state agencies and representatives from other stakeholder groups) determine a new value for the “minimum discharge target” at the Rockingham NC USGS sensor.  Reduce the Blewett Falls discharge as measured at the Rockingham NC USGS sensor to that value and begin an additional 2 foot drawdown at each lake beginning with Blewett Falls Lake and working progressively back up the chain toward High Rock Lake.
  8. Continue this down the chain, up the chain process until each lake has reached its maximum allowable drawdown.  On each successive 2 foot drawdown pass have the stakeholder group establish a reduced value for the “minimum discharge target” and use this value for the target at the Rockingham NC USGS sensor.  If every lake has reached its maximum drawdown, discharge no more from any of the lakes than is flowing into that lake (true run of the river).
  9. Once stream inflow to High Rock Lake rises above the “minimum discharge target” refill all reservoirs proportionally until each has reached its target level of within 4 feet of full pool before returning the discharge from the Blewett Falls dam to full “run of the river” levels.

Actual modeling of the above scenario using a watershed modeling program like OASIS and the measured flow figures from 2001 and 2002 would provide more accurate information concerning the impact to each reservoir and the flows in the Pee Dee River during that period.  If modeling of this scenario truly supports the conclusions derived from our spreadsheet model, we respectfully request that these rules be adopted and used until the relicensing of both Projects is completed.

 We feel that these guidelines give appropriate consideration to all of the stakeholders interests.  Under normal conditions, on a weekly basis almost all of the water coming into project 2197 and project 2206 would be used for hydropower generation and discharged into the Pee Dee River .  This would more closely approximate the conditions of an unencumbered river system and provide for more natural seasonal fluctuations.  If High Rock Lake is maintained at a target level of about -2 to -3 feet, there would be a modest level of storage capacity (30,000 to 35,000 acre feet) there to allow for short term regulation of downstream flows.   The 4 foot “target range” at each lake would provide a total of approximately 120,000 acre feet of storage capacity in the river basin that would be available without needing to make variance requests.  Drawdowns beyond this level would be pre-approved under the guidance of the recognized natural resource management experts with appropriate limits necessary to protect the environment, municipal water supplies and the rights of other defined stakeholders.  This should maintain the shortest retention period for the water in each lake and hopefully contribute toward better water quality and provide the highest quality environment for the fish and wildlife.  It should maintain all lakes at a level that is acceptable for safe recreational use.  Reaction to stream flows as low as 1200 cfs would become part of weekly power generation scheduling and should minimize the impact to the reservoirs and flows in the Pee Dee River .  Delays introduced by inadequate or unclear regulations requiring variance requests would be eliminated.  The life of the stored reserves during periods of extended or extreme drought would be maximized and the time needed to replenish those reserves should be minimized.  We feel that this is an operational model that contains clear and concise goals and limits.  When flow conditions are extremely low for extended periods of time, those most knowledgeable in natural resource management and protection would be empowered to make the appropriate “judgment call” decisions.  In conclusion, we feel that it meets all of the requirements of the directive issued by the FERC to APGI on December 20, 2002 .

 The key to successful drought management is the establishment of reasonable minimum and maximum flow and reservoir elevation limits as well as the REQUIREMENT to react quickly to changing stream flow conditions.

 Respectfully submitted,


Robert W. Petree

Chairman of the Board