April 6, 2017

Today Cube Hydro representatives met with State Agency and Stakeholder groups representatives to begin discussions concerning the revisions to the existing Shoreline Management Plan.  Article 407 of the new project license identified 9 specific items that should be included in the revised SMP which must be filed for approval by FERC by September 1, 2018.  The consensus of the participants was that many of the updates could likely be addressed by updating the terminology used previously with terminology supplied by FERC as the currently accepted standard.  Those verbiage updates as well as the changes negotiated between stakeholders and Alcoa during the relicensing process and included in the Relicensing Settlement Agreement appear to address the bulk of the changes required by FERC and could reasonably be accomplished in a very timely manner.  Cube appeared to agree but stated the remaining changes would take more effort on their part to complete and noted the possibility of a few NEW changes that have not been discussed in the past.  These included potential changes to the existing "Lap Tree" policy, potential additional regulations concerning Water Willow, Ski Jump or Slalom Courses and Floating Trampolines as well as new "Guidance" documents for pier specifications  

FERC has also mandated updates to the project Recreation Plan, Rare Threatened and Endangered Species Plan and the Historic Properties Plan.  All of these plan updates must be completed and submitted to FERC by September 1, 2017.  Cube has proposed the following time schedule to complete the SMP revision process.

April 22, 2016

 Update Goals and Objectives

May 5, 2016

 Revise the Project Description

June 30, 2016

 Update Appendices A, B, C, D, and Project Maps

August 30, 2016

 Revise Recreation Resources Plan

September 29, 2016

 Revise Environment and Natural Resources Plan

November 15, 2016

 Produce completed DRAFT of the revised SMP

November 16 thru December 25

 Provide 30 day review period

January 12, 2017

 Submit the revised SMP to FERC for approval

While this schedule does not accomplish the implementation of the negotiated SMP changes included in the RSA within 3 months of license issuance as specified in section 2.4.2 of the RSA, it does provide an accelerated implementation schedule compared to the two year timeframe specified in Article 407 of the new license.  Cube agreed to investigate the possibility of a two stage filing with FERC to allow implementation of negotiated RSA items prior to the complete RSA revision but appeared doubtful this approach would be allowed by FERC.

At the conclusion of this meeting there were some additional discussions concerning the Recreation Plan updates, updates to the Cube Website specified in Appendix B of the new license and their general intentions concerning future operations as they relate to water levels at all lakes. 

Many of the participants were surprised to learn the NEW access area specified in the RSA for Rowan County and identified in the Recreation Plan was specified by Alcoa as a "swimming and beach" facility with NO launch ramps for boats.  As there are no existing "Access Areas" within the project without boat launch ramps the negotiators for this new facility intended it to be a full and complete "Access Area" as they exist at all other locations. 

Cube is still working on the required updates to their website to provide the information specified in Appendix B of the license and was receptive to some usability recommendations as they go forward.  Some of the required data is already available but is scattered on different pages of the site making it more difficult to view and understand the related information.  One of the welcome additions is the page that allows you to renew your pier permits online instead of having to mail documentation back and forth.  If you need to contact Cube Hydro Carolinas concerning any permitted activities please contact Karen Baldwin at (704) 422-5525 or kbaldwin@cubecarolinas.com

As for project operations, they stated there general intent is to operate within the new lake level regulations as closely as possible to the way the project has been voluntarily operated over the last ten years. This would mean keeping High Rock within a 1 to 3 foot below full Pool (-4 foot maximum) during the recreation season (April 1st thru November 1st) and the remaining lakes within 1 foot of full pool (-5 foot Maximum at Badin).  Most exceptions to this philosophy would be driven by low inflow to the project as compared to the discharge requirements throughout the year and the implementation of the Low Inflow Protocol if necessary.