20030147 Ver 2_More Info Received_20070718

Comments, hearing request re Progress Energy Tillery and Blewett Fa...
Subject: Comments, hearing request re Progress Energy Tillery and Blewett Falls dam relicensing
From: "Hope Taylor-Guevara" <[e-mail]>
Date: Wed, 18 Ju12007 23:43:30 -0400
To: <[e-mail]>
Clean Water for North Carolina
~~ Yadkin Pee Dee River Trail Association
c% CWFNC, 2009 Chapel Hill Rd. Durham, NC 27707, 919-401-9600
July 18, 2007
Mr. John Dorney
Division of Water Quality
Wetlands and Stormwater Branch
NC Dept. of Environment and Natural Resources
2321 Crabtree Blvd.
Raleigh, NC 27604
John. [e-mail]
Clean Water for North Carolina is a statewide environmental justice organization that works for safe, accessible water for
all, polluter accountability and empowered, safe communities. For over a decade we have had two or more Yadkin-based
members of our Board of Directors, and we have had a long commitment to the communities and water needs of the basin.
Our staff and interns have researched and authored a report in 2002 "A River in Jeopardy," which reviewed a wide range of
water quality and other environmental impacts in the basin, and in 2006, "A Fairly Watered State," which studied the
impact of water supply policies on Yadkin communities. We are particularly concerned that the water quality and quantity
of the river system be protected, conserved and restored in the interest of current and future drinking water consumers,
improved aquatic habitat and native fisheries, and sustainable recreational and economic activities.
In Spring of 2007, Clean Water for NC hosted four meetings, in partnership with leadership of the Yadkin Pee Dee River
Trail Association, along the Yadkin River, basin to talk with our members and the public about forming a new grassroots
organization to protect the River system and those who depend on it, with a stated commitment to protecting the water
quality and quantity downstream of whatever geographic area of the basin is selected for the organization, to protect values
critical to the health, drinking water, recreation and economy of downstream communities. The Yadkin Pee Dee River Trail
Association's mission is to provide stewardship, conservation and support public access along the River. Both
organizations believe that enhanced recreational access is critical for the public's education and motivation to protect the
River and its tributaries and ease of volunteer monitoring efforts.
We have reviewed portions of Progress Energy's application for Water Quality Certification for the Yadkin-Pee Dee River
Hydroelectric Project. As a result, we are writing to request a public hearing prior to the Department of Environment and
Natural Resources' (DENR) final decision on conditions for this certification. We believe that such a hearing would
provided much needed opportunity to increase public understanding of and participation in critiquing the There are several
reasons for concern that Progress Energy does not propose providing adequate mitigation for the impacts caused by the
operation of Tillery and Blewett Falls Development. Among these reasons are: 1) the impacts to the Yadkin-Pee Dee River
are not sufficiently quantified within the application; 2) most of the proposed mitigation is not within the impacted 8-digit
hydrological unit code (HUC); and 3) there may be more effective/appropriate mitigation opportunities available (e.g.,
Little River dam removals and/or further improvements in flow regime) within the affected HUC.
Progress Energy's application does not quantify the complex impacts to the aquatic resources of the Yadkin-Pee Dee River
associated with the Tillery and Blewett Falls hydroelectric developments. For reasons of transparency, Progress Energy
and DENR should provide such detail. Further, it is difficult to determine if the applicant has proposed adequate mitigation
in the absence of this information.
Progress Energy's application materials are explicit in stating that the impacts originate from inadequate continuous
instream flows downstream of Tillery Dam. Therefore, the impacts-as well as both impoundments-are located within
the 8-digit HUC referred to as the Yadkin 04. To mitigate for the unspecified impacts, Progress has proposed to donate
lands to the state of North Carolina or otherwise conserve (through conservation easements) ~ 1900 acres of riparian buffers
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Comments, hearing request re Progress Energy Tillery and Blewett Fa...
along the Yadkin-Pee Dee River. While our organization recognizes the importance of buffer preservation, we are
concerned by the fact that 1600 acres of the proposed preservation is located outside of the affected HUC, and would
prefer the implementation of in-kind mitigation that will more directly affect the water quality and biological diversity
through substantially improved flow regime.
Finally, we understand there is a mitigation strategy that we feel could be seriously considered by both Progress Energy and
DENR. The removal of Eury and Hurley (or Robertson) dams in the Little River (Montgomery County) has been proposed
by Restoration Systems. These dams are located within the appropriate HUC, and their removal would provide access to
high-quality habitat for diadromous fishes-once passage is provided over Blewett Falls Dam. We also support a
substantially improved flow regime for increasing healthy habitat for shad and eels in the Tillery Reach. Because the Little
River merges with the Yadkin-Pee Dee between Tillery and Blewett Falls dams, the proposed removals would also provide
benefits to the aquatic communities directly impacted by the current inadequate instream flows released from the Tillery
development.
We formally request that a public hearing be held with extensive public notification in the counties affected, with an
extended public comment period prior to the final decision for the Water Quality Certification. This hearing should, at a
minimum, address the concerns discussed in this letter.
Sincerely yours,
Hope Taylor-Guevara
Executive Director,
Clean Water for North Carolina
Montie Hamby
President
Yadkin Pee Dee River Trails Association
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