20030147 Ver 2_More Info Letter_20071113

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\O~~ RQG Michael F. Easley, Governor
~ ~ William G. Ross Jr., Secretary
> r North Carolina Department of Environment and Natural Resources
~ ~ Coleen H. Sullins, Director
Division of Water Quality
November 13, 2007
DWQ Project # 2003-0147, version 2
Montgomery County
CERTIFIED MAIL: RETURN RECEIPT REQUESTED
#7003 2260 0001 3494 4188
Progress Energy
410 South Wilmington Street, PEB 13
Raleigh, NC 27602
Attention: Charles M. Gates
Subject Project: Yadkin-Pee Dee Project for Tillery and Blewett Falls Reservoirs
FERD No. 20006-030
REQUEST FOR MORE INFORMATION
Dear Mr. Mann:
On September 18, 2007, the Division of Water Quality (DWQ) conducted a Public
Hearing for the subject project in order to issue a 401 Water Quality Certification for the FERC
relicensing of the Tillery and Blewett Falls Reservoirs. Based on the information received at the
hearing and our review of the record, the DWQ has determined that your application was
incomplete, provided conflicting information or required additional information as discussed
below. Therefore, the DWQ will require additional information in order to process your
application. Unless we receive the additional information requested below, we will have to
move toward denial of your application as required by 15A NCAC 2H .0506 and will place this
project on hold as incomplete until we receive this additional information. Please provide the
following information so that we may continue to review your project.
Additional Information Requested:
Minimum flows
a. Economic analysis -Please provide a detailed economic analysis which describes
the process and supports the ultimate conclusion that minimum flows higher than
330 cfs are not economically practical for this project. Also please clarify how the
flows below Blewett Falls dam correspond with the in-stream flow study.
b. Flow projections with and without dams -Please provide a detailed description of
minimum flow projections with and without the existing dams so we can compare the
proposed flows to what would have occurred naturally in the river.
c. Flow Rate Exceedances -Please provide a breakdown on the percentage of time the
flows at both Tillery and Blewett Falls would have exceed the proposed minimum
flow rates (including fish spawning time frames and proposed minimum flow rates)
over the past two years. Also include two years worth (June 1, 2005 -June 1, 2007)
of daily flow rate averages for both Tillery and Blewett Falls Reservoirs.
d. Effects of projected increased flow rates -Detail effects (economic, aquatic,
biological integrity, etc) of projected minimum continuous flow rates of 800-1000 cfs
401 Oversight/Express Review Permitting Unit
1650 Mail Service Center, Raleigh, North Cazolina 27699-1650
2321 Crabtree Boulevazd, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone] /Internet: htt :/p /h2o.enr.state.no.us/nc~~etlands
l~''o,,~` Carolina
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Progress Energy
Page 2 of 2
November 8, 2007
(year-round) and 1,500-1,800 cfs (During spring spawning season, see item e) for
the Lake Tillery reach.
e. Please clarify the minimum continuous flow scheduling since there appears to be a
discrepancy in the proposed time frame for minimum flow within the application. For
instance, page 15 (note 2) of the application states that the minimum flow schedule
has a projected start date of March 15 while on page 9, the schedule has an April 1,
;~ mate. Please cl~Irifp~this conflict.
2. Mitigation
a) Calculations and comparison to DWQ policy guidance -Please provide a detailed
analysis of your mitigation proposal as compared to DWQ's policy guidance on
FERC mitigation dated August 24, 2007 (version 1.5) (attached).
Please respond in writing within 30 calendar days of the date of this letter by sending a
copy of this information to Mr. John Dorney of the DWQ Central Office at 2321 Crabtree Blvd,
Raleigh, NC 27604 and myself at 610 East Center Avenue, Suite 301, Mooresville, NC 28115.
If you will not be able to provide the requested information within that timeframe, please provide
written confirmation that you intend to provide the requested information, and include a specific
timetable delineating when the requested materials will be provided. If we do not hear from you
in 30 calendar days, we will assume that you no longer want to pursue this project and we will
consider the project as returned.
This letter only addresses the application review and does not authorize any impacts to
wetlands, waters or protected buffers. Please be aware that any impacts requested within your
application are not authorized (at this time) by the DWQ. Please call Mr. Dorney at 919-733-
9646 or myself at 704-663-1699 if you have any questions regarding this letter or would like to
set up a meeting to discuss this matter.
Sincerely,
~~~ .~ r~
Robert B. Krebs
Mooresville Regional Office, Surface Water
Protection Section Supervisor
CBK/jrd
cc: Larry Mann, Progress Energy (w/ Attachment)
John Dorney, DWQ Central Office
Tom Reeder, DWQ Central Office
Mike Lawyer, DWQ Fayetteville Regional Office
Honorable Gene McLaurin, Mayor -City of Rockingham, 514 Rockingham Rd., Rockingham, NC 28379
Gerrit Jobsis, American Rivers, Southeast Division, 2231 Devine Street, Suite 202, Columbia, SC 29205
Heather Preston, Water Quality Division, Bureau of Water, 2600 Bull Street, Columbia, SC 29201-1708
Adam Rigsbee, Restoration Systems, 1101 Haynes Street, Suite 107, Raleigh, NC 27604
Steve Reed, NC Division of Water Resources
File Copy
Central Files
Attachment
Filename: 20030147version 2ProgressEnergyFERC(Montgomery)onhold