UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Applicant: Alcoa Power Generating, Inc.
Name of Project: Yadkin
SaveHighRockLake.org, an unincorporated association that has been formed to represent those with environmental and recreational interests in High Rock Lake, wishes to comment on the request by Alcoa Power Generating Inc. to reduce the discharge from Project 2197 to 900 c.f.s. until Sept. 15, 2002.
We agree that this reduction is prudent and necessary to reduce further destruction of the eco-system at High Rock Lake and preserve what is left of the wildlife habitat during this unprecedented drought. The management of project 2197 during this time has been devastating to the lake area businesses of Davidson and Rowan counties, the local tourism related businesses, property values, wildlife habitat and recreational activities for tens of thousands of people.
We further believe that pursuant to the statement from Myrtle Beach that 700 c.f.s was all that was necessary to avoid contamination of their drinking water supplies by salt water that the recommended discharge should be reduced to 700 c.f.s. or "Run of River", whichever is less during this period.
In light of the "Motion to Intervene" filed by the Pee Dee River Coalition we would like to also point out that the TRUE riparian rights of the downstream users gives them no right to demand anything more than the natural flow of the river.
Considering the fact that the current license and amendments were written prior to the enactment of the Electric Consumers Protection Act of 1986 by the Congress of the United States, we also respectfully request that the following modifications to the applicants request for variance to their license be made to bring the license into compliance with the intent of that Act.
ALL discharge from High Rock Lake be discontinued immediately until at least 75 percent of the available storage capacity for hydro generation of the rest of the lakes in project 2197 has been depleted as well as 75 percent of the available storage capacity for hydro generation of CP&L's Tillery and Blewett Falls developments.
That the MAXIMUM allowable drawdown of High Rock Lake be limited to no more than 10 feet. This is a reasonable limit considering the overall shallow nature of High Rock Lake and when compared to the maximum allowable drawdown of the other lakes in Project 2197. This would provide for adequate protection of fish and wildlife. This would also allow Duke Power to resume operation of their Buck generating facility at or near full capacity. Since Duke's facility is capable of producing considerably more energy than project 2197 without depleting our very limited water resources in the upper Yadkin River basin. It is much more beneficial to the surrounding communities for this plant to be fully operational.
In light of Alcoa Aluminum's recent announcement to close the Aluminum Smelting Plant at Badin NC., that Project 2197 be limited to minimal generation in a "peaking" capacity at least until such time as the current "exceptional" drought has ended. Because of the nature of Hydro generating facilities, they are best suited as peaking facilities that can be started up very quickly and run for reasonably short periods of time. There is plenty of generating capacity available via other power generating companies without endangering the environment, fish and wildlife habitat and drinking water supplies of the upper parts of the Yadkin River basin. Since the price per Megawatt Hour is generally much higher during periods that peaking plants are needed, the increased revenue generated per Megawatt Hour would help offset any potential losses from shortened periods of generation.
That the current "rule curve" that is listed as the Operations Guide for Badin Works in article 33 of the 1968 amendment to the applicants license and allows High Rock Lake to be operated similar to a flood control reservoir be modified to maintain High Rock Lake at a target level between 651 and 655 feet at all times. This would give the most efficient "head" elevation for power generation at High Rock Lake and would maintain recreationally friendly levels year round, similar to the rest of the lakes in Project 2197 as well at Lake Tillery and Blewett Falls. The current rule curve has completely destroyed almost all of the aquatic shoreline vegetation, which is listed in APGI's Shoreline Management Plan as the Premier wildlife habitat and it has been instrumental in causing the current devastation of High Rock Lake due to the arbitrary inclusion of minimum discharge requirements without consideration to the amount of water coming into the lake. This would also be beneficial to the local economies of Davidson and Rowan counties due to increased tourism, higher property values, increased lake area business development and an enhanced ability to recruit new industries to the area.
Thank you for giving us this opportunity to comment on Docket #P-2197-052 and giving the appropriate equal consideration to all interests involved as mandated in the Electric Consumers Protection Act of 1986.
469 Robin Hood Road
Lexington, NC 27292