20030147 Ver 2_Fax_20070724

~'F W A TFj9 Michael F. Easley, Governor
Q
~
~ ~ Willi
G
R
J
S
i
~ r.,
ecretary
am
.
oss
~ ~- North Cazolina Department of Environment and Natural Resources

~ ~ Coleen H. Sullins, Director
Division of Water Quality
Division of Water Quality
Department of Environmental and Natural Resources
401 Oversight/Express Review, Program Development and
Transportation Permitting Units
Street Address: 2321 Crabtree Boulevard, Suite 250
Raleigh, NC 27604-2260
Mailing Address: 1650 Mail Service Center
Raleigh, NC 27699-1650
Contact Information: Phone #:
Fax #:
Fax To: ~~
Company: 1-I<~ 'l ~i
Number of pages including cover sheet:
919-733-1786
919-733-6893
Fax #: l ~a ~ ~~ ~ '- 0 ~f~
Date: ? Z 7
F
401 OversighUExpress Review Permitting Unit
1650 Mail Service Center, Raleigh, North Carolina 27699-1650
2321 Crabtree Boulevard, Suite 250, Raleigh, North Carolina 27604
Phone: [phone] /FAX [phone] /Internet: httn://h2o.enr.state.nc.us/ncwetlands
No°C hCarolina
~aturallr~
An Equal Opportunity/Affirmative Action Employer - 50% Recycled/10% Post Consumer Paper
1~T~L~_ ~.. ..~-. ... ,.1 _~...L..._..4_..~...

TECHNICAL PROPOSAL
LOWER UWHARRIE DAMS MITIGATION SITE
MONTGOMERY COUNTY, NORTH CAROLINA
Submitted by:
D ~ L~ ~ !~
Restoration Systems, LLC
1101 Haynes Street, Suite 211
Raleigh, North Carolina 27604
www. restorationsystems. com
July 18, 2007
JUL ~. ~ 2007
VETLAhtU,`, R;Jb 570RF:~~1!ATER BRANCH
0
FULL DELIVERY PR0.7ECT
TO PROVIDE STREAM MITIGATION
IN THE YADKIN RIVER BASIN
CATALOGING UNIT 03040104

' I'~ I
Natui ~tl Resourc e
® Restoration & Conservation
® John Dorney
® NC Division of Water Quality
2321 Crabtree Boulevard
~ Raleigh, NC 27604
! Dear Mr. Dorney:
~ I have recently reviewed Progress Energy's application for Water Quality Certification (WQC)
~ for the Yadkin-Pee Dee River Hydroelectric Project. As a result, I am writing to request a public
' hearing prior to the Department of Environment and Natural Resources' (DENR) final decision.
There are several reasons for concern that Progress Energy is not providing adequate mitigation
~ for the impacts caused by the operation of Tillery and Blewett Falls Development. Among these
1 reasons are: 1) "preservation only" mitigation strategies do not recover lost functions and values;
~ 2) most of the proposed mitigation is not within the impacted 8-digit hydrological unit code
(HUC); 3) there is a more effective/appropriate mitigation opportunity available (i.e., dam
removals on the Little River) within the affected HUC; and 4) the impacts to the Yadkin-Pee Dee
1 River are not quantified within the WQC application.
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 along the Yadkin-Pee Dee River. While buffer preservation is commendable, we are
concerned by the fact that 1600 acres of the proposed preservation is located outside of the
affected HUC, and this preservation strategy does nothing to offset the impacts to the affected
reach.
Restoration Systems is proposing a mitigation alternative that should be seriously considered by
both Progress Energy and DENR-see the accompanying technical proposal for the Lower
Uwharrie Dams River Restoration Site. The removal of Eury and Hurley (or Robertson) dams
in the Little River (Montgomery County) will provide ecological benefits to a Yadkin-Pee Dee
River tributary that drains the Uwharrie National Forest (Little River watershed is 85% forested).
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.
Further, because the Little River merges with the Yadkin-Pee Dee between Tillery and Blewett
Falls dams, the proposed removals would provide habitat building sediments and stream flows to
the aquatic communities directly impacted by the operation of the Tillery development.
Pilot Mil] • 11Q1 Haynes St., Suite 107 • Raleigh, NC 27604 • www.restorationsystems.com • Phone [phone] • Fax [phone]

~•.
t
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
1
Finally, Progress Energy's application does not quantify the impacts to the aquatic resources of
the Yadkin-Pee Dee River associated with the Tillery and Blewett Falls hydroelectric
developments. For reasons of transparency and public interest, Progress Energy and DENR
should provide such detail. Further, it is hard to determine if the applicant has proposed
adequate mitigation in the absence of this information.
We formally request that a public hearing is held prior to the final decision for the Water Quality
Certification. This hearing should, at a minimum, address the concerns detailed within this
letter, and the mitigation proposed herein.
Sincerely,
J Adam Riggsb ,
Environmental Scientist
Restoration Systems, LLC

}
Part 'i ~ Executive Summary
~~ This Technical Proposal describes the Lower Uwharrie Dams River Restoration Project
~} through removal of the Hurley and Eury dams (Lower Uwharrie Dams) on the Little River in
1
~ Montgomery County, NC; near the Town of TroythFigure 1). These two structures are contiguous
and collectively impound 30,100 linear feet of 4 order mainstem and 3,000 linear feet of 1St
"d
~, and 2
order perennial tributaries.
Both dams are located immediately downstream of a reach of the Little River designated as a
~ priority area by the NC Natural Heritage Program (Figure 2). Hurley Dam is actively impounding
a minimum of 16,100 linear feet of mainstem channel habitat. Eury Dam is impounding a
mi
i
f 15
000
i
n
mum o
,
l
near feet of mainstem habitat.
~
i As described in this proposal, stream mitigation units (SMUs) were calculated based on the
methods outlined i
D
t

~ n
e
erminina Appropriate Compensatory Mitigation Credit for Dam
Removal Projects (March 22, 2004). The proposed removals could provide 21,070 SMUs. It is
estimated that Progress Energy's impacts to the Yadkin-Pee Dee River require an offset of
18,942 SMUs (DENR internal memo; Appendix A). Therefore, the removal of the Lower

"' Uwharrie Dams could adequately and effectively mitigate for the ecological impacts
associated with the operation of Tillery Dam.
s
. _
The primary goals of this project are as follows:

1) Restoration of rare, threatened and endangered aquatic species habitat. Seven species listed
by the state as endangered
threatened
rare and special concern will di
tl
b
,
,
rec
y
enefit from the
removals of the Lower Uwharrie Dams. These dams are located immediately downstream of a
reach of the Little River that is designated as conservation priority habitat by the NC Natural
Heritage Program (NHP).
2) Improvement of water quality within the impounded reach, which has been degraded by the
recurrence of algal blooms and low dissolved oxygen (DO) concentrations associated with stagnant
conditions during low-flow summer months.

3) Restoration of lotic communities within the project reach as a result of restored
h
ydrogeomorphic character and improved water quality.
Dam removal is a passive restoration technique that initiates profound physical responses within
affected fluvial systems. This technique has been utilized before as a mechanism for river
restoration in North Carolina. Restoration Systems has twice used this innovative approach for
NC Ecosystem Enhancement Program (EEP) stream restoration projects in the Neuse River and
Cape Fear River basins. Dam removal has been accepted as a method for stream restoration b
y
the US Army Corps of Engineers, the Environmental Protection Agency, the US Fish and Wildlife
S
ervice, the NC Wildlife Resources Commission (WRC), the NC Division of Water Quality
(DWQ), as well as the EEP.
We look forward to discussing the merits of this project with the NC Department of Environment
and Natural Resources (DENR) in the near future. If you, or your staff, have questions or
comments regarding our proposal, please feel free to contact me at your convenience at the
number belo
W
'
w.
e appreciate DENR
s consideration of this innovative and ecologically
~ beneficial project.
Sincer I ,
J. Ad m Riggsbee, hD
Authorized Representative
Restoration Systems, LLC
919-755-9490
adam@restorationsystems. com

Olt, -lux
MIT
vxr
Y.-77
Little River Dam Locations
i
RESTORATION Montgomery County, NC
SYSTEMS, LK