DOCKET # P-2197-056

APPLICANT: Alcoa Power Generating Inc.

Name of Project:  Yadkin

SaveHighRockLake.org, an unincorporated organization that has been formed to represent those with 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, wishes to comment on the request by Alcoa Power Generating Inc. to implement the management protocol for Project 2197 known as the “Post Sept. 15th Protocol”

We agree that continued variations from the operations of the past is necessary during this time of unprecedented drought but feel that there are several issues that are not adequately addressed or are inappropriate in the variance request.

  1. The “Post Sept. 15th Protocol” has been used for the last three weeks and has already demonstrated several failures. 
  2. The stated maximum allowable drawdown for High Rock Lake in tier 2 has already proven to be unacceptable and will certainly result in additional fish kills.
  3. The request allows for ongoing dynamic changes to the stated targets which while possibly advantageous in certain situations does not allow for any control by the Federal Energy Regulatory Commission or input form affected stakeholders.
  4. The request asks for relief from license requirements that High Rock Lake be within 5 feet of full pond by May 15, 2003.  While this may be necessary, there is more than adequate time to request this in the future and have the appropriate required hearings and periods of time for Comments and Motions to be filed.
  5. The request states that what has been learned to date and what will be learned throughout the process of implementation of the Protocol concerning acceptable management practices of the Yadkin watershed will NOT “create a precedent for any issue or future period”.  This is ABSURD!!  So far almost every time a question has been asked or a problem has arisen, the response has been that we are working with conditions that have never occurred before and that we are learning daily what are and what are not acceptable limits to use to protect our important natural resources, environment and wildlife.  Protection of these elements is vital and to ask that we ignore the knowledge gained is ridiculous.

Since FERC is the official regulatory agency responsible for the protection of all stakeholder interests in Hydro Electric projects it appears that closer scrutiny of all aspects of the operations of Project 2197 might be necessary.  The track record to date of protecting the environment, wildlife, recreational interests and beneficial use of our natural resources is questionable at best. At this time it appears that the generation of electricity for the benefit of private industry has been the most protected beneficial use with only minor consideration given to other stakeholders and most of those were areas where there were clearly defined federal Acts or regulations with specific punishment clauses for violations.  Only FERC has the authority to regulate what most people would consider “Common Sense” and enforce it for the good of the public now and in the relicensing of Project 2197


Robert W. Petree


P.O. Box 628

Southmont, NC  27351