DOCKET # P-2197-060

APPLICANT: Alcoa Power Generating Inc.

Name of Project:  Yadkin


SaveHighRockLake.org (the “Movant”), on behalf of its membership, respectfully moves for intervener status in the request by Alcoa Power Generating Inc. (the “Applicant”) for approval of their “Yadkin Drought Contingency Plan for 2003” which was filed with the Federal Energy Regulatory Commission (FERC) on February 14, 2003.  The Movant files this motion pursuant to C.F.R. * 385.214 (a) (3) (2002).  The Movant seeks intervener status based on the following:


1.      The Movant is an unincorporated organization that has been formed to represent and protect the interests of stakeholders in Project 2197 from July 2002 through the issuance of a new license to operate Project 2197.  The organizations membership consists of more than 6000 stakeholders who have environmental, economic and/or recreational interests in High Rock Lake as well as the other impoundments that are part of Project 2197 and the Upper Yadkin River Basin , and is growing daily.

2.      The applicant was instructed in a letter from the FERC on December 20, 2002 to develop a drought contingency plan for the operation of Project 2197 during 2003 should drought conditions return to the river basin.  One of the principal goals of the plan requested by the FERC was to ensure that the elevation of High Rock Lake is maintained within five feet of full pool.  The directive from the FERC requested a Plan that examined alternative management practices, early reduction in discharges, and contained an implementation schedule.  The help of the Commission Staff was offered assist the applicant with the development of the plan.  

3.      The Movant believes the Plan submitted by the applicant is inadequate in incomplete.  The Plan submitted does little more than review the events of 2002.  There are no specific steps included in the Plan for mitigation of drought conditions.  The Plan specifically attempts to exclude representatives of recognized stakeholder groups.

4.      The submission of the Applicant specifically states they do not understand why they are being asked to create such a plan yet there was no evidence of any request for the assistance of the Commission Staff as had been offered.


This Movant respectfully requests to granted intervener status and be made a party to these proceedings.  We ask the following name be placed on the service list for the purpose of receiving notices, pleadings, motions, rulings, etc.:


Mr. Robert W. Petree, Founder


P.O. Box 628

Southmont, NC  27351

Telephone (336) 798-3227

E-Mail:  pete@savehighrocklake.org


Respectfully submitted,

Robert W. Petree

Chairman of the Board                                      Dated:  March 25, 2003






I certify that I have this 25th day of March, 2003, served this Motion to Intervene via U.S. Mail upon all persons on the service list maintained by the Federal Energy Regulatory Commission for Project 2197


Respectfully submitted,


Robert W. Petree