20070812 Ver 1_Public Comments_20080501 (2206)

Alcoa Power Generation CWA401 Cert.
Subject: Alcoa Power Generation CWA401 Cert.
From: "Eric Krueger" <[e-mail]>
Date: Thu, 1 May 2008 14:57:47 -0400
To: <John. Domey@ncmail. net>
Hello, John.
I'm writing with respect to APGI's application for 401 Certification for the relicensing of the four
APGI facilities on the Yadkin River. Quickly by way of background, I have a MS Degree in
Geosciences focused on Hydrogeology, and have worked for 14 years in various environments around
the country in pursuit of conservation and restoration of sensitive aquatic ecosystems. I have been with
TNC in the South Carolina Chapter for six years, and have focused my work on hydropower and
freshwater mussel conservation.
As you may know, The Nature Conservancy is a signatory to the Relicensing Settlement Agreement
for this project, and was a full participant in the process that developed the RSA. We continue to
support the RSA and FERC's recent issuance of the Final EIS incorporating the RSA measures along
with several FERC staff enhancements. We support the issuance of the associated 401 Certification
from the State of North Carolina.
Stanly County representatives are legitimately concerned about the health of their citizens with respect
to contamination at Badin, NC. But, the FERC relicensing and associated 401 Cert is not the venue to
address this. And, based on the reports and data I have reviewed from the ongoing Resource
Conservation and Recovery Act process in Badin, these issues are being addressed adequately and
appropriately through this venue. To deny a 401 Cert based on this concern would essentially accuse
the EPA and NC DENR of failing to act appropriately under RCRA, which does not appear to be the
case.
And, while it is true that Alcoa Aluminum has moved significant amounts of workforce overseas, the
state of the global metals economy has virtually nothing to do with the need for hydropower energy in
the Southeast. Hydropower is becoming an ever-more important energy resource in the face of climate
change. What possible relationship can there be between the number of aluminum smelting jobs in
Badin and the need for appropriately generated electrical power, which is just as or more important to
the region and also generates high-paying jobs? In the face of the growing climate change threat, what
would be solved by transporting aluminum ore vast distances to be processed at Badin? Economies
grow, shrink and change all the time. No one has a right to a lifelong guaranteed vocation.
Lastly, I and many other signatories take issue with how these disputes have arisen. Stanly County
representatives were present in both the APGI and Progress Energy relicensing processes throughout,
but neglected to raise any of these issues until the RSA was near total completion. The FERC record
will bear this out. The gains and positive compromises that the relicensing stakeholders achieved
were accomplished through years of continued active engagement and discussion that at times became
heated, but was always substantive and in search of solutions. To countervene the results of the
relicensing based on these frankly unrelated issues is unfair to the four years of hard work that NC and
SC agencies, NGO's, and the hydropower operators put in together to reach a best-fit solution.
The health of the Yadkin and Pee Dee Rivers have suffered from 50 years under hydropower licenses
that failed to incorporate water quality, quantity and ecological concerns. The new license makes
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Alcoa Power Generation CWA401 Cert.
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significant remedy to these issues, brings tremendous value to NC and SC citizens alike, and should be
implemented as soon as possible. Approval of the 401 Certification will facilitate this solution greatly.
Thank you for your time.
Eric
Eric Krueger The Nature Conservancy I
Director of Science and Stewardship South Carolina Field Office
960 Morrison Drive, Suite 100
[e-mail] PO Box 20246
[phone] Ext. 16 (Phone) Charleston, SC 29413
[phone] (Mobile)
[phone] (Fax)
nature.org
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