Hi Guys,


Im not sure exactly who is participating in the Drought Contingency Plan conference calls with APGI so if you are not representing your agency in the calls I would appreciate it if you could pass this on to the appropriate person.


Last week I traveled from here to Knoxville Tennessee and was stunned to see many of the large mountain streams and rivers were completely dry.  I also did not see a single drop of water leaching from the rock faces along the side of the highway as you normally do in many places through the mountains.  Needless to say the drive dramatically emphasized exactly how bad the conditions upstream are getting.  


Im sure you can understand that many of the stakeholders in the upper part of the river basin and specifically at High Rock are starting to become very concerned about the current drought and river flow conditions.  If you take a quick look at the USGS gauge at Yadkin College it wont take long to understand why.  Our year to date rainfall is way below normal and average river flows have been steadily dropping all year.  We are currently only slightly above the flow levels in 2002 and the continuing decline is a clear indicator that ground water resources are once again becoming very depleted.  High Rock has fallen 3 feet in the last 30 days and  without significant rainfall it appears it will continue to fall at a rate of somewhere between 6 to 10 inches a week with the current discharge requirement of 1400 cfs. Thats based purely on an inflow vs. outflow calculation with no offset to account for evaporation. We are already 5.5 feet below full pond and many residents have found their boats are hopelessly grounded.  Continuing to operate under the old Rule Curve will likely have High Rock 8 feet or more below full pond by the end of the defined recreation season on September 15th.  Ironically, once Rule 8 of the existing Rule Curve expires on September 15th, APGI could actually increase their power production and accelerate the rate at which High Rock Lake would fall.  


I am writing on behalf of our membership to ask that your Agency recommend some operational changes at High Rock as allowed for in the Drought Contingency Plan until the drought conditions have improved and the upstream ground water resources have been at least partially replenished and also to require that the Conference calls be held on a more frequent basis going forward.  I am sure everyone is hoping the prediction of an active hurricane season will eventually push some significant precipitation into the area but it will take more than a couple of high flow events to bring the river basin back to normal.  As you can see from the USGS graphs, occasional high flow events from earlier in the year have helped delay the dramatic effects of the dwindling river flows until later in the year this time but in the last 30 days the gap between current and normal river flows is widening on a daily basis.  We were all very disappointed in the time it took APGI to react to the conditions in 2002 and are hopeful that this time the Agencies will exert the authority given to them by the Drought Contingency Plan the FERC directed APGI to operate under until their new license is issued.  If you go back and read the FERC documents directing APGI to continue use of the DCP going forward, they clearly state that August through October are historically dry months and One of the goals of the drought contingency plan, as stated in our December 20, 2002 letter, was to ensure that the elevation of High Rock Lake is maintained within five feet of full pool during the recreational season. 


Thanks for your efforts to protect our precious natural resources.


Robert Pete Petree