In the April meeting of the Recreation, Aesthetics, and
Shoreline Management IAG, SaveHighRockLake.org
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
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.
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.
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.
Robert W. Petree