UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
MOTION TO INTERVENE
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:
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
The applicant was instructed in a letter from the FERC on
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
Chairman of the Board
CERTIFICATE OF SERVICE
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