In response to the statement that APGI did not receive any public comments concerning the Shoreline Management Plan, SaveHighRockLake.org conducted a poll of its members who are adjacent property owners.  In response to this poll, the respondents identified the following specific issues that they would like to have restudied during relicensing.  

·        The restriction on building a boat house on private property above the 655 ft. project elevation is beyond the regulatory authority of a private corporation. The allowable types of structures and setback requirements are officially the domain of the county governmental authorities.  The construction of a boat house is no more visually obstructing than a densely wooded 100 foot buffer zone.

·        As a boat ramp poses no visual impairment to neighbors and minimizes erosion there is no reason to deny property owners with reasonable grade to the waters edge a permit to construct a boat ramp.

·        As a private company Alcoa has no authority to mandate usage or impose restrictions on private property above the 655 ft. elevation.  This type of authority is the domain of the county government.  

·        This effectively eliminates everyone but the wealthy from being able to obtain a pier permit.  Requiring those with less than 200 feet of waterfront to build shared piers is the equivalent of forcing neighbors to share facilities as personal as their family rooms with their neighbors.

·        The requirement that a pier must be able to extend to a certain depth is ridiculous.  If there is adequate water depth available to float a boat at full pond, fish, swim or just enjoy the view, it should be the decision of the homeowner whether to invest in constructing a pier.

·        Restricting the length of a pier and requiring it to extend to a minimum water depth is especially restrictive on High Rock Lake .  Due to the shallow nature of High Rock Lake this is often impossible.  

·        Piers with overhead decks pose no visual or aesthetic impairments and should be allowed

·        Requiring ramps to connect and access floating piers often makes the most important portions of the pier inaccessible in impoundments with fluctuating water levels.  Floating piers riding up and down on rails or posts and accessible via adjacent steps are much safer and more accessible at any water level.  This also reduces the stress on the stationary pier from the torque and leverage associated with the attachment of the floater via a 16 foot ramp.

·    The removal of fallen trees in developed areas with permitted piers should not be restricted.  Studies done during the development of the Shoreline Management Plan at Lake Norman showed that the pier itself provided a comparable beneficial fish habitat.  The presence of downed or “lap” trees at a permitted private recreational facility can create personal hazards.  

·        Sea walls offer an effective form of erosion control with little environmental impact.  The fees charged for erosion control/shoreline stabilization are exceptionally high.

In many of the issues above, the regulations exceed the authority of a private corporation to regulate the use of private property and Alcoa has forced compliance by denying private recreational facility permits.  Only the local county governmental agencies have the authority to enact zoning and building regulations or restrictions.  Denying pier permits to enforce these rules is the equivalent of extortion.

In light of the number of issues identified, SaveHighRockLake.org requests that the Shoreline Management Plan be compared to the plans for other area hydropower reservoirs.  To the extent possible, many of the rules and regulations applying to FERC licensed hydropower projects should be very similar with only minor variations due to any unique attributes of a given impoundment.