UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
MOTION TO INTERVENE
Applicant: Aloca Power Generating, Inc.
Name of Project: Yadkin
The Pee Dee River Coalition (the “Movant”), respectfully moves the Commission for leave to intervene in the proceedings by Alcoa Power Generating, Inc. (the “Applicant):
The Movant is an unincorporated association representing more than fifty (50) municipalities, counties, special purpose districts, and industries located in South Carolina and which are users in one manner or another of the lower reaches Yadkin/Pee Dee River Basin from the North Carolina border to the mouth of the Waccamaw River.
The member entities are either public water suppliers with raw water intakes withdrawing from the Pee Dee River system or they own and operate wastewater treatment facilities which either directly or indirectly discharge into the Pee Dee River system. The provision of adequate public drinking water is essential to the public health of these citizens and is the responsibility of many of the member entities. Conversely, adequate means of disposing of treated wastewater effluent is any the responsibility of many of the member entities and is also essential to the public health and the environment of South Carolina. Each of these member entities will be adversely affected if the Licensee’s request to reduce minimum releases from the Yadkin Project. The member entities serve or employ in the aggregate over one hundred thousand citizens of South Carolina who will be also directly affected by the outcome of these proceedings.
The Movant believes that its participation is in the public interest and that its interests may not be adequately represented by any of the present parties to this proceeding.
The Movant requests to be made a party to these proceedings in order to ensure that it is properly informed as to the possible effects of the drought as well as possible reductions in minimum water releases from the Project Area and the effect upon downstream riparian users, and, moreover, to fully participate in these proceedings to the fullest extent allowed by law.
Dated: August 1, 2002 Nexsen Pruet Jacobs Pollard & Robinson, LLC
s/Neil C. Robinson, Jr.
Attorneys for PeeDee River Coalition
200 Meeting Street, Suite 301
Charleston, SC 29401
Tele: 843-577-9440 Fax: 843-720-1777