In the April meeting of the Recreation, Aesthetics, and Shoreline Management IAG, and the High Rock Lake Association both submitted requests for review of many aspects of the existing Shoreline Management Plan (SMP) for Project 2197.   As noted in the published summary of the meeting, APGI only recognized one of the issues included in our review requests as a request for a study to be done.  Therefore, the only study APGI agreed to was our request for a comparison of the SMP for Project 2197 to the FERC approved SMP for other comparable projects.  The ensuing conversations actually identified several specific elements that should be included in the study to address many of the issues listed in the requests from us and HRLA.  At this time, the draft SMP Comparison study plan has not been created for review.  

In preparation for discussions concerning the draft SMP Comparison study plan, we began reviewing the SMP for Project 2232 (Duke Power) and Project 2206 (Progress Energy).  These two projects encompass 13 licensed hydropower impoundments within approximately 100 miles of Project 2197.  Lake Wylie is about 3000 acres smaller than High Rock in size.  While the average water depth is almost 50% greater (23 ft. vs. 16 ft.) it appears to be a reasonably comparable facility.  There appear to be several lakes that would work as reasonable comparisons for Narrows ( Badin Lake ) in the other two projects.  

After reviewing the meeting summary and the other SMPs, we felt there were a couple of issues for which specific elements of the study request may not have been adequately detailed.  They are pier regulations, private boat houses and/or boat launch facilities, erosion control techniques and permit fees.  Consequently we would like to request that the following elements be added to the things already identified in the April Meeting and included in the SMP comparison study.  

  1. Pier regulations
    1. Required shoreline footage for qualification
    2. Minimum water depth requirements
    3. Allowable length
    4. Allowable pier designs and specifications (total square footage, covered boat slips, covers/decks or gazebos, stationary vs. floating, ramps vs. steps, etc.)
    5. Beneficial fish habitat of piers compared to coarse woody debris
    6. Environmental and Aesthetic considerations
  1. Private terrestrial Boat Houses and Boat Launch facilities
    1. Determination of types of boat houses allowed (none, open sided or enclosed)
    2. Restrictions and Regulations determining which types are allowed
    3. Specifications (setback, size, height, width, square footage, etc.)
    4. Legal jurisdictional authority of FERC and APGI outside the project boundary
    5. Specifications used to determine length/width of allowed boat launch ramps
    6. Environmental and Aesthetic considerations
  1. Erosion Control Techniques
    1. Determination of types allowed
    2. Restrictions and Regulations determining which types are allowed
    3. Specifications
    4. Environmental impacts of seawalls vs. rip rap
    5. Aesthetic considerations
  1. Permits and Fees
    1. Permit Requirements
    2. Fees Charged
    3. Determination of “Reasonable and Customary” fees


We have also noticed, based on a review of the FERC “Form 80 - Licensed Hydropower Development Recreation Report” filed by each of the above mentioned project licensees, there seems to be a disparity of almost 60 days in the “defined recreation season” between Project 2197 and the other licensed projects.  Therefore we would like to request that a review/study be added to the Recreation Studies to establish a more appropriate “defined recreation season” for Project 2197 that is at least comparable to that which is approved and accepted for similar Licensed Hydropower Developments or even longer if supported by the data from the recreation studies. 

 Respectfully submitted,

Robert W. Petree

Robert W. Petree