20160742 Ver 2_More Info Received_20190816

Strickland, Bev
From: Mularski, Eric <[e-mail]>
Sent: Friday, August 16, 2019 12:27 PM
To: Homewood, Sue
Subject: RE: [External] SAW-2015-02543 Permit Modification 01 - Cedar Cliff Auxiliary Spillway
Upgrades
Attachments: Cedar Cliff -Aux Spillway Upgrade_Drawdown Plan -Rev 06.25.2019 FINAL.PDF
CAUTION: External email. Do not click links or open attachments unless you verify. Send all suspicious email as an
attachment to [e-mail]<mailto:[e-mail]>
Hi Sue. Thank you for returning my call. Attached is the Cedar Cliff drawdown plan. Agency comments and responses are
included in Attachment 3. Please let me know if you need me track down any additional information for you for
clarification of 401 Condition 8.
Thanks again!
Eric
-----Original Message -----
From: Mularski, Eric
Sent: Friday, August 9, 2019 12:37 PM
To: Homewood, Sue ([e-mail]) <[e-mail]>
Cc: Wise, Jon <[e-mail]>; 'John. [e-mail]' <John. [e-mail]>; 'Karably,
Ken' <[e-mail]>; Banta, Tim <[e-mail]>; Kulpa, Sarah <Sarah.Kul [e-mail]>;
Little, Michael <[e-mail]>; Anderson, Emily ([e-mail])
<[e-mail]>
Subject: RE: [External] SAW-2015-02543 Permit Modification 01 - Cedar Cliff Auxiliary Spillway Upgrades
Hi Sue,
I left you a voicemail this morning. Your message indicated that you are out of the office and will be returning next
Tuesday (8/13). We had a question regarding 401 Condition 8 which states, "The Permitted shall secure approval of an
Erosion and Sediment Control (E&SC) Plans prior to commencing drawdown of the water level in the reservoir." Is this
statement pertaining to the erosion and sediment control measures detailed in the drawdown plan (see attached
drawdown plan including agency comments in Attachment 3) or approved E&SC plans for the entire site? Please
confirm.
The E&SC plans for the project construction are scheduled to be submitted the week of August 19th and an express
review will be initiated with the NCDEQ's Asheville Regional Office. The drawdown is scheduled for September 3rd. We
want to be certain that we comply with Condition 8 and identify any potential delays in the proposed drawdown
schedule. We appreciate your immediate response to our question above.
Thank you,
Eric Mularski, PWS
D 704-973-6878 M 704-806-1521

hdrinc.com/follow-us
-----Original Message -----
From: Homewood, Sue [mailto:[e-mail]]
Sent: Wednesday, July 17, 2019 4:07 PM
To: [e-mail]; Mularski, Eric <[e-mail]>
Cc: Brown, David W CIV USARMY CESAW (US) <[e-mail]>; Mitchell, Robert K
<[e-mail]>; Leslie, Andrea J <[e-mail]>; [e-mail]; Bowers, Todd
<[e-mail]>
Subject: RE: [External] SAW-2015-02543 Permit Modification 01 - Cedar Cliff Auxiliary Spillway Upgrades
Please see the attached 401 approval
Thanks,
Sue Homewood
Division of Water Resources, Winston Salem Regional Office Department of Environmental Quality
336 776 9693 office
336 813 1863 mobile
Sue. Homewood @ ncden r.gov
450 W. Hanes Mill Rd, Suite 300
Winston Salem NC 27105
Email correspondence to and from this address is subject to the North Carolina Public Records Law and may be disclosed
to third parties.
-----Original Message -----
From: Brown, David W CIV USARMY CESAW (US) <[e-mail]>
Sent: Friday, June 21, 2019 1:02 PM
To: [e-mail]
Cc: Mularski, Eric <[e-mail]>; Price, Zan (George) <[e-mail]>; Homewood, Sue
<[e-mail]>; Mitchell, Robert K <[e-mail]>; Leslie, Andrea J
<[e-mail]>; [e-mail]
Subject: [External] SAW-2015-02543 Permit Modification 01 - Cedar Cliff Auxiliary Spillway Upgrades
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attachment to [e-mail]<maiIto: [e-mail]>
Jonathan Wise,
Please find the attached Permit Modification for the Cedar Cliff Auxiliary Spillway Upgrades. Hard copies will be mailed
today. Let me know if you have any questions.
Sincerely,

David Brown, PG
Regulatory Specialist/Geologist
USACE Wilmington District -Asheville Regulatory Field Office
151 Patton Avenue, Room 208
Asheville, NC 28801-5006
828-271-7980, ext. 4232
[e-mail]

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Hydroelectric Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
1.0 INTRODUCTION
The East Fork Hydroelectric Project (Project) is owned and operated by Duke Energy Carolinas, LLC
(Duke Energy) under a license issued by the Federal Energy Regulatory Commission (FERC) on
May 4, 2011.' The Project consists of three hydroelectric developments which include, from
upstream to downstream, Tennessee Creek (includes the Wolf Creek Dam and the Tanasee Creek
Dam), Bear Creek, and Cedar Cliff. The Cedar Cliff Development includes Cedar Cliff Dam located
on the East Fork of the Tuckasegee River near river mile (RM) 52.1 in Jackson County, North
Carolina. The FERC Project boundary for the East Fork Project encompasses approximately 1,462
acres, including 23.15 acres of the Nantahala National Forest administered by the U.S. Forest
Service (USFS) adjacent to the Bear Creek and Tennessee Creek Developments.
Via letter dated April 24, 2014, the FERC Atlanta Regional Office (ARO) required Duke Energy to
satisfy safe passage of the Inflow Design Flood (IDF), which is defined as the Probable Maximum
Flood (PMF), without overtopping Cedar Cliff Dam. The proposed remedial alternative to safely pass
the PMF involves modifications to the existing auxiliary spillway channel, installation of a Fusegate
system within the auxiliary spillway control section, placement of an 8.5-foot (ft)-high concrete
parapet wall along the crest of the dam, and other appurtenant components. Related activities will
include the new redundant hoist installation at the principal spillway, Tainter gate maintenance,
powerhouse transformer replacement, new access road construction and modifications to an
existing private access road, construction of a new principal spillway bridge, and construction of an
approximately 0.5-acre laydown area at the upstream approach channel to the auxiliary spillway.
In order to complete the aforementioned work, Cedar Cliff Lake will need to be drawn down
approximately 30 feet from Full Pond Elevation (Attachment 1) for the duration of construction
(anticipated to be approximately 25 months). In accordance with the Hydro Project Maintenance &
Emergency Protocol (HPMEP) for the Project (Appendix A of the license order), Duke Energy has
prepared this Drawdown Plan to describe the procedures and schedule associated with the Cedar
Cliff Lake drawdown and measures to maintain compliance with the state water quality certification,
FERC license and associated plans, and the Tuckasegee Cooperative Stakeholder Team
Settlement Agreement, as applicable. Under a separate cover letter, Duke Energy has consulted
Duke Energy Carolinas, LLC, 143 FERC 162,203 (2013).

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
with the North Carolina State Historic Preservation Office (NCSHPO) and the Eastern Band of
Cherokee Indians Tribal Historic Preservation Officer (EBCI THPO) regarding measures to be taken
for extended drawdowns (Attachment 2).
Duke Energy is submitting this Drawdown Plan to FERC for approval as part of a request for a
temporary variance of the reservoir elevation requirements for the Cedar Cliff Development,
pursuant to Article 401 of the Project license. As explained below in Section 4.1, this approval is
being requested by Duke Energy because the proposed drawdown is outside of the typical
maintenance activities or circumstances established by the Low Inflow Protocol and the Hydro
Project Maintenance & Emergency Protocol.
2.0 PROJECT DESCRIPTION
The Cedar Cliff Development consists of a 590-foot-long, 173-foot-wide, earth -and -rock fill dam with
a crest elevation of 2,343.5 feet above mean sea level (ft AMSL). The dam impounds Cedar Cliff
Lake with a surface area of 121 acres and approximately five miles of shoreline at Full Pond
Elevation 2,330 ft AMSL. A principal spillway with one Tainter gate is located at the right abutment of
the dam. An auxiliary spillway with two erodible fuse plug sections is located at the left abutment of
the dam. Water is conveyed to the Cedar Cliff powerhouses via a tunnel intake opening near the
right upstream toe of the dam and travels down the 1,138-foot-long power tunnel and penstock. The
main powerhouse contains one vertical Francis -type generating unit with an installed capacity of
8,187 horsepower (hp) and a hydraulic capacity of 555 cubic feet per second (cfs). In 2012, Duke
Energy installed a new minimum flow unit, which is housed in a new small powerhouse adjacent to
the main powerhouse and has nameplate -rated capacity of 526 hp and a hydraulic capacity of 35
cfs. Cedar Cliff Dam creates a 0.46-mile-long Bypassed Reach from the base of the dam to the
Cedar Cliff powerhouse discharge and back to the East Fork Tuckasegee River. No continuous
minimum flow from the reservoir is provided to the Bypassed Reach.
Operation of the upstream Tennessee Creek and Bear Creek Developments is coordinated with the
operation of the Cedar Cliff Development. The Tennessee Creek and Bear Creek powerhouses
typically operate during the afternoon to support system loads and to refill Cedar Cliff Lake for off-
peak generation and water releases. Water from Tanasee Creek Lake and Wolf Creek Lake is
released downstream into Bear Creek Lake. Water is released from the Bear Creek Powerhouse to
Cedar Cliff Lake. Cedar Cliff Lake is normally operated between elevations 2,330 ft AMSL and 2,326
ft AMSL year-round, with a normal target elevation of 2,328 ft AMSL.

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
The FERC Project boundary around Cedar Cliff Lake encompasses the dam and reservoir, the
Project structures, the Bypassed Reach, and two formal public recreation sites, the Cedar Cliff
Access Area, located on Cedar Cliff Lake, and the Shook Cove Access Area, located downstream of
the powerhouses. Operation and maintenance of both sites are provided by the North Carolina
Wildlife Resources Commission (NCWRC). No federal lands are included in the FERC Project
boundary for the Cedar Cliff Development.
3.0 DRAWDOWN PLAN
3.1 Drawdown and Refill Rate
Cedar Cliff Lake will be drawn down to approximately 2,300 ft AMSL (30 ft below Full Pond Elevation
2,330 ft AMSL) to allow for the new redundant hoist installation/Tainter gate maintenance and
construction of the auxiliary spillway upgrade. Cedar Cliff Lake elevation will be lowered by releasing
flows through the generating units at a rate no greater than three feet per 24 hours (average of 0.13
ft per hour) on a continuous basis until the desired lake elevation is achieved. During the reservoir
drawdown process, Duke Energy will perform inspections of the exposed shoreline areas for the
occurrence of erosion or fish standing in shallow lake areas. If erosion or fish stranding is observed,
Duke Energy will consult with the resource agencies to determine if a decreased drawdown rate is
necessary to reduce the likelihood of the erosion or stranding to occur.
Cedar Cliff Lake will be held at approximately 2,300 ft AMSL for the duration of construction activities
by releasing flows through the generating units or over the principal spillway. In the event of Cedar
Cliff Development inflow exceeding approximately 590 cfs or the available powerhouse capacity,
inflow will be passed over the sill of the principal spillway (elevation 2,305 ft AMSL), as the Tainter
gate will remain in a partially open condition throughout construction .
Upon completion of construction activities, Cedar Cliff Lake will be refilled based on inflows, but at a
rate no greater than three feet per 24 hours (average of 0.13 ft per hour) on a continuous basis until
the Normal Target Elevation (i.e., 2,328.0 ft AMSL) is achieved.
3.2 Schedule
Duke Energy anticipates the duration of construction activities at the Cedar Cliff Development will be
approximately 25 months, with construction planned for September 2019 through September 2021.
To facilitate the start of construction in early September 2019 (post Labor Day weekend), the Cedar
Cliff Lake drawdown will begin on September 3, 2019, and the refill will begin in October 2021.

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
3.3 Public Outreach
Based on the duration and extent of the Cedar Cliff Lake drawdown, Duke Energy will perform public
outreach measures to notify land owners abutting Cedar Cliff Lake and primary lake users of the
planned drawdown. Duke Energy public outreach will include the following:
■ Provide information related to the schedule and associated impacts of the Cedar Cliff
Lake drawdown on the existing Duke Energy Lakes & Recreation website and telephone
system;
■ Post a sign(s) at the Cedar Cliff Lake Access Area notifying users of the schedule of the
drawdown and associated impacts and restrictions;
■ Provide written notification of the drawdown to land owners abutting the Cedar Cliff Lake
including information for an appropriate contact at Duke Energy to report concerns;
■ Provide written notification of the drawdown to primary lake users such as local
recreation outfitters;
■ Coordinate with the NCWRC pursuant to the existing agreement between Duke Energy
and the NCWRC;
■ Assist the NCWRC with external communications regarding any NCWRC activities or
schedules for 2019 through 2021 that will be impacted by the drawdowns; and
■ Provide press releases in local news outlets.
In addition to the measures listed above, Duke Energy provided preliminary notification of the
planned drawdown to affected homeowners and via local news outlets in the fall of 2018.
3.4 Sediment and Erosion Control
Sediment and erosion control measures will be implemented and maintained, as necessary, per the
requirements of the state water quality certification and to maintain compliance with the state water
quality standards, statutes, or rules.
During drawdown and immediately after the drawdown elevation is reached at each facility,
inspections will be performed by Duke Energy once per week and after significant rainfall events
(e.g., precipitation estimates for the Project area of 1 inch or greater within 24 hours), as feasible.
Approximately one month after the drawdown is reached and based on the condition of the exposed
lake bottom, inspections will occur at least monthly for the duration of the drawdown. Inspections will
identify mass wasting and sloughing on the banks and remediation measures will be installed as
needed. Remedial measures may include installation of straw bales along the banks or similar

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
measures to decrease velocity of waters, decrease erosion, and minimize the amount of sediment
released to Cedar Cliff Lake through erosion. Erosion control materials (i.e., straw bales) will be
available onsite in the event such materials need to be rapidly deployed via barge.
4.0 LICENSE COMPLIANCE
4.1 Article 401 — Reservoir Level Management
License Article 401 requires Duke Energy to operate the Project according to specific reservoir level
management provisions, as required by Condition 6 of the North Carolina water quality certification
to protect the aquatic and recreational resources in the Tuckasegee River and to provide required
downstream flows. More specifically, the Licensee is required to maintain the elevation of the Project
reservoirs between the designated Normal Minimum and Normal Maximum elevations (2,326 ft
AMSL and 2,330 ft AMSL, respectively), except when the Licensee is permitted to vary from the
Normal Operating Range as established in the Low Inflow Protocol (as outlined in Appendix A of the
license order) and in the HPMEP (also included in Appendix A of the license order).
The reservoir level requirements may be temporarily modified from the Normal Operating Range if
required by conditions beyond the control of the Licensee, for short periods during annual inspection
and repair events, or by operating emergencies or maintenance needs as defined in the Low Inflow
Protocol and the HPMEP. If operations or reservoir levels are so modified, the Licensee shall notify
the FERC as soon as possible, but no later than 10 days after each such incident, and shall provide
the reason for the change in reservoir levels.
Consistent with the consultation requirement of the HPMEP, Duke Energy has prepared this Cedar
Cliff Lake Drawdown Plan in consultation with the NCWRC, the United States Fish and Wildlife
Service (USFWS), and the North Carolina Division of Water Resources (NCDWR). An early draft of
the Drawdown Plan was distributed for review in December 2016. The Drawdown Plan has been
revised to incorporate comments received from this review, as well as applicable comments received
during the 2017-2018 consultation process for the East Fork Project Comprehensive Drawdown Plan
for Required Maintenance Activities in 2018-2019. Updated versions of this Drawdown Plan were re-
distributed to the NCWRC, USFWS, and NCDWR for review and concurrence in August 2018 and
May 2019, prior to being submitted to the FERC with the original and updated requests for approval
of a temporary variance of the reservoir elevation requirements for the Cedar Cliff Development.

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
4.2 Article 402 — Recreation Plan
Under License Article 402, Duke Energy has prepared and maintains a Recreation Plan for the
Project, which was approved by FERC by order dated November 27, 2012. As described in the
Recreation Plan, with respect to the Cedar Cliff Development, a single formal recreation access area
is maintained by Duke Energy in partnership with NCWRC at Cedar Cliff Lake, the Cedar Cliff
Access Area. As stated above and in the Recreation Plan, the Cedar Cliff Development includes one
recreation area, the Cedar Cliff Lake Access Area that provides a boat ramp, pier, seasonal portable
toilet, and parking. Duke Energy does not currently charge a fee for public use of the access area
facilities, which are open for use at all times. The Cedar Cliff Lake Access Area is currently
maintained through a cooperative maintenance agreement with NCWRC.
The boat ramp at the Cedar Cliff Access Area will be unusable during the drawdown. The 30-foot
drawdown described in this plan will result in closure of the Cedar Cliff Access Area when Cedar Cliff
Lake reaches elevation 2,323 ft AMSL. The site will remain closed until Cedar Cliff Lake returns to
elevation 2,323 ft AMSL or greater. Pursuant to the requirements of the FERC-approved Recreation
Plan and associated agreement with the NCWRC, Duke Energy will coordinate with the NCWRC for
methods for closure of the Cedar Cliff Lake Access Area and public notification during the drawdown
period. As mitigation for the approximately 25-month closure of this facility, NCWRC requested that
Duke Energy use this opportunity to perform additional maintenance at the site, including paving and
limited removal of accumulated sediment under dewatered/dry conditions. Flow from Kiesee Creek
has eroded the existing floating boat dock and sediment has been deposited in the shallow portion of
the reservoir. Duke Energy plans to excavate the excess sediment from the reservoir to elevation
2,322 ft msl, with all excavated material to be deposited in upland areas. Installation of a permanent
rock vane is proposed to deflect flow from Kiesee Creek away from the boat launch.
4.3 Article 403 — Public Information at East Fork Project
In accordance with the requirements of License Article 403, Duke Energy will continue to provide
information on its website and telephone system regarding reservoir levels and recreation flows for
Bear Creek, Cedar Cliff, Wolf Creek, and Tanasee Creek Lakes.

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
4.4 Article 404 — Minimum Flow
License Article 404 (as amended)z requires the licensee to release minimum flow from the Cedar
Cliff reservoir to the East Fork of the Tuckasegee River, as required by Condition 6 of the North
Carolina water quality certification, which consists of 1) during non -generation hours, a flow of 10 cfs
from December 1 through June 30, and 35 cfs from July 1 through November 30, or 2) during low
inflow periods3, a flow of 6 cfs from December 1 through June 30, and 11 cfs from July 1 through
November 30. Duke Energy expects to continue to provide the required minimum flow from the
Cedar Cliff Development throughout the duration of the drawdown.
In the event the required minimum flows cannot be provided during the drawdown period due to low
inflow, Duke Energy will provide written notification pursuant to the FERC-approved Minimum Flow
and Flow Monitoring Plan and Low Inflow Protocol.
4.5 Article 405 — Recreation Flow
License Article 405 requires the Licensee to operate the East Fork Project to provide scheduled
recreation flow releases at or above the best efficiency flow of the Cedar Cliff unit into the main stem
of the Tuckasegee River during the recreation season. Throughout the duration of the drawdowns
described herein, Duke Energy will continue to provide recreation flows required by Article 405.
4.6 Article 414 — Programmatic Agreement
License Article 414 requires the licensee to implement the "Final Programmatic Agreement Among
the Federal Energy Regulatory Commission and the North Carolina State Historic Preservation
Officer for Managing Historic Properties that may be Affected by a License Issuing to Duke Power
Company, LLC for the Continued Operation and Maintenance of the East Fork Hydroelectric Project
in Jackson County, North Carolina," executed on September 19, 2006, and including but not limited
to the approved Historic Properties Management Plan (HPMP), filed August 7, 2006, for the Project.
The 2006 HPMP includes special provisions associated with large, planned, extended drawdowns,
which is defined as any planned drawdown where the pond elevation will remain at least 10 feet
below the Normal Minimum Elevation for a minimum of 30 consecutive days. Specifically, the
provision states that in the event of a large, planned, extended drawdown, the Licensee will consult
with the North Carolina State Historic Preservation Office (NCSHPO) and the Eastern Band of
2 Duke Energy Carolinas, LLC, 138 FERC 162,146
3 As defined by the Low Inflow Protocol (Appendix A of the license order)

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
Cherokee Indians (EBCI) Tribal Historic Preservation Office (THPO) regarding the need to conduct
archaeological surveys of the exposed area
Pursuant to the requirements of the 2006 HPMP, Duke Energy sent a letter dated August 5, 2016 to
the NCSHPO and EBCI THPO providing notification and description of the planned construction
activities and associated drawdown at the Cedar Cliff Development. No response was received by
Duke Energy from the EBCI THPO. Via letter dated August 30, 2016, the NCSHPO indicated it is
unlikely that any archaeological resources that may be eligible for inclusion in the National Register
of Historic Places will be adversely affected by the planned construction activities and drawdown.
The NCSHPO requested that Duke Energy take photographs to document the current condition of
the dam and its surroundings pursuant to their guidelines. Via a submittal to NCSHPO dated June
25, 2019, Duke Energy completed the photographic documentation of the Cedar Cliff Dam and its
surroundings pursuant to the NCSHPO's request and guidelines. Copies of the above -referenced
letters are provided in Attachment 2.
Duke Energy also distributed a copy of the East Fork Project Comprehensive Drawdown Plan for
Required Maintenance Activities in 2018-2019 (including a 10-foot drawdown of Cedar Cliff Lake) to
the NCSHPO and EBCI THPO, to provide notification and description of the planned activities and
associated drawdowns at the Bear Creek, Cedar Cliff, and Tennessee Creek Developments and
initiate consultation regarding the need to conduct archaeological surveys of the exposed area. By
letter to Duke Energy dated October 23, 2017, NCSHPO stated that they had conducted a review of
the Project and are aware of no historic resources that would be affected, and therefore NCSHPO
has no comments on the proposed activities. No response was received from EBCI THPO, so,
consistent with Chapter 4 of the 2006 HPMP, Duke Energy therefore assumed concurrence with
Duke Energy's determination of no effect and that no additional surveys are required.
5.0 CONSULTATION
On December 15, 2016, Duke Energy provided a draft of this Drawdown Plan for 30-day review to
NCDWR, NCWRC, and USFWS, all of which provided comments on the draft plan. Duke Energy
incorporated the comments received into this Drawdown Plan, as applicable. A summary of the
comments received and how they were addressed as well as the record of consultation is provided
in Attachment 3.

Duke Energy Carolinas, LLC
East Fork Hydroelectric Project (P-2698)
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Cedar Cliff Lake Drawdown Plan (2019 Update)
Duke Energy provided an updated draft version of this Drawdown Plan to the aforementioned parties
for 30-day review in August 2018 (no additional comments were received) and May 2019 (no
additional comments were received).

Attachment 1
Cedar Cliff Development
Drawdown Reservoir Water Surface Map

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Drawdown Reservoir Water Surface s V ` , "`=
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n Existing Reservoir Water Surface
Hatched centerline is distance in feet from
Cedar Cliff Dam.
The distance from the 2,300-foot contour to the FY} 'i`�, ;. :~� 4 •
Bear Creek Powerhouse is approximately -'?�
2,140 feet.

Attachment 2
SHPO and THPO Consultation Pursuant to License Article 414

North Carolina Department of Natural and Cultural Resources
State Historic Preservation Office
Ramona M. Bartos, Administrator
Governor Pat McCrory
Secretary Susan Kluttz
August 30, 2016
Office of Archives and History
Deputy Secretary Kevin Cherry
Christy Churchill Christy. Churchillgduke-energy. com
Duke Energy
550 South Tryon Street
Charlotte, NC 28202
Re: Cedar Cliff Development Auxiliary Spillway Upgrade Project, East Fork Hydroelectric Project,
FERC 2698-033, Jackson County, ER 16-1388
Dear Ms. Churchill:
Thank you for your letter of August 5, 2016, regarding the above -referenced undertaking. We have
reviewed the materials submitted and offer the following comments.
Based on our knowledge of the area, it is unlikely that any archaeological resources that may be eligible for
inclusion in the National Register of Historic Places will be adversely affected by the project.
The East Fork Hydroelectric Project is eligible for listing in the National Register of Historic Places
(NRHP) under Criterion A for "Engineering." However, when the East Fork Hydroelectric Project was
evaluated in 2014, the Cedar Cliff Development (JK0729), was determined to be a non-contributing
element of the historic property. Therefore, proposed improvements to the Cedar Cliff Development dam
will not diminish the integrity for which the East Fork Hydroelectric Project is considered to be historic.
Before improvements to the dam at Cedar Cliff are initiated, we request photographs thoroughly
documenting the current condition of the dam and its surroundings. Please refer to our guidelines for labeling
and submitting digital images at hqp://www.hpo.ncdcr. og v/digital/NCHPO_Digital_Photo_Policy.html.
The above comments are made pursuant to Section 106 of the National Historic Preservation Act and the
Advisory Council on Historic Preservation's Regulations for Compliance with Section 106 codified at 36
CFR Part 800.
Location: 109 East Jones Street, Raleigh NC 27601 Mailing Address: 4617 Mail Service Center, Raleigh NC 27699-4617 Telephone/Fax: [phone]-6599

Thank you for your cooperation and consideration. If you have questions concerning the above comment,
contact Renee Gledhill -Earley, environmental review coordinator, at 919-807-6579 or
environmental.review(abncdcr.gov. In all future communication concerning this project, please cite the
above referenced tracking number.
Sincerely,
61,W"Ramona A Bartos
cc: John Eddy, John.Eddy(aduke-energy.com
Jon Wise, Jon.Wisegduke-energy com
Tim Banta, Tim.Bantaandrinc.com
David Brown, ACOE

DUCE
ENERGY
August 3, 2016
Ms. Renee Gledhill -Earley
State Historic Preservation Officer
North Carolina State Historic Preservation Office
4617 Mail Service Center
Raleigh, NC 27699-4617
Mr. Russell Townsend
Tribal Historic Preservation Officer
Eastern Band of Cherokee Indians
P.O. Box 455
Cherokee, NC 28719
Duke Energy
550 South Tryon Street
Charlotte, NC 28202
Mailing Address:
Mail Code EC13K/ P.O. Box 1006
Charlotte, NC 28201-1006
SUBJECT: East Fork Hydroelectric Project No. 2698-033, Jackson County, North Carolina
Cedar Cliff Development Auxiliary Spillway Upgrade Project
Dear Ms. Gledhill -Earley and Mr. Townsend:
Duke Energy Carolinas, LLC (Duke Energy) is the Licensee of the East Fork Hydroelectric Project
No. 2698-033 (Project). As specified in Article 414 of the Federal Energy Regulatory Commission
(FERC) operating license for the Project, Duke Energy is required to consult with the North
Carolina State Historic Preservation Office (NC SHPO) and the Eastern Band of Cherokee Indians
Tribal Historic Preservation Office (EBCI THPO) regarding activities and undertakings within the
Project Area of Potential Effect (APE) that are not categorically excluded in the Project's Historic
Properties Management Plan (HPMP).
Background
A letter (dated April 24, 2014) issued by the FERC placed Duke Energy on notice to satisfy safe
passage of the Inflow Design Flood (IDF) that is defined as the Probable Maximum Flood (PMF)
without overtopping the Cedar Cliff Dam. Duke Energy proposes to perform upgrades to the
existing auxiliary spillway and main dam toe berm as a remedial alternative to safely pass the PMF
at the Cedar Cliff Development. The proposed undertaking will require federal approval through the
FERC and a Section 404 permit from the U.S. Army Corps of Engineers (USACE). Remediation
measures to the existing dam and auxiliary spillway are categorically excluded activities in the
HPMP, but the reservoir drawdown required to facilitate construction will initiate Section 106
consultation under 36 CFR 800.(3) of the National Historic Preservation Act.
Project Description and History
The Project began commercial operation in 1952 and is currently owned and operated by Duke
Energy. The Project consists of three developments, which are (from upstream to downstream) the
Tennessee Creek Development, Bear Creek Development, and Cedar Cliff Development. The
FERC issued a new license for the Project on May 4, 2011. The Project is currently classified by
the FERC as having "High" hazard potential based on the probable loss of human life and potential
for economical losses, environmental damage, and/or disruption to lifelines caused by failure or

Ms. Renee Gledhill -Earley East Fork Hydroelectric Project No. 2698-033, Jackson County, North Carolina
Mr. Russell Townsend Cedar Cliff Development Auxiliary Spillway Upgrade Project
August 3, 2016
mis-operation of a dam or appurtenances. The Cedar Cliff Development includes an earth and rock
fill dam, 15-foot-diameter tunnel, and powerhouse located on the East Fork of the Tuckasegee
River in Jackson County, North Carolina, approximately 6 miles southeast of the town of
Cullowhee (Figure 1).
The Project area is situated in the Blue Ridge physiographic province, a mountainous zone that
extends northeast -southwest from southern Pennsylvania to central Alabama. The physiography of
Jackson County consists of high, intermediate, and low mountains; floodplains; and low stream
terraces (Figure 2). The East Fork Project is located in the Tuckasegee River watershed, which
typically drains to the north. The Project area is surrounded by open water, rural residential,
pastureland, and forested undeveloped lands (see attached site photographs).
Proposed Project
A Core Team was assembled consisting of representatives from Duke Energy, FERC, and HDR to
develop remedial alternatives for safely passing the PMF at the Cedar Cliff Development. The
preferred alternative developed by the Core Team involves modifications to the existing auxiliary
spillway channel and main dam toe berm, placement of an 11-foot-high concrete parapet wall
along the crest of the dam, and installation of Fusegates within the auxiliary spillway control
section. Rock spoil from the auxiliary spillway excavation will be loaded onto a barge and
deposited in Cedar Cliff Lake to eliminate potential impacts to environmental resources at
alternative rock spoil locations. This activity will result in approximately 316,600 cubic yards of
permanent fill within an approximate 9.6-acre footprint of the reservoir.
As part of the proposed upgrade project, Cedar Cliff Lake will be drawn down approximately 30
feet (Elevation 2,330 feet mean sea level) for a duration of 14 to 16 months to facilitate
construction of the spillway modifications (Figure 3). The drawdown footprint and excavation area
north of the existing auxiliary spillway will serve as the APE not categorically excluded by the
proposed remediation activities. The HPMP specifies that Duke Energy will consult with the NC
SHPO and the EBCI THPO in the event of a large, planned extended drawdown to determine if an
archaeological survey of the exposed area should be conducted. Duke Energy requests your
comments and opinions on whether an archaeological survey of the exposed area should be
conducted.
We also request that you review the attached information and verify that no additional cultural
resources surveys are required for the proposed upgrade project under Section 106 of the National
Historic Preservation Act. Should you have any questions regarding this project or require
additional information, please do not hesitate to contact Christy Churchill at [phone] or
Christv.Churchilladuke-eneray.com.
Sincerely,
Duke Energy Carolinas, LLC
Christy Churchill
Cultural/Historical Resources Coordinator
Attachments: Figure 1. Project Location
Figure 2. USGS Quadrangles
Figure 3. Aerials
Site Photographs
cc: Jon Wise — Duke Energy
John Eddy — Duke Energy
21

LEGEND
r--j Area of Potential Effect
DATA SOURCE: ESRI, DeLorme,
Tom Tom, Intermap, USGS, FAO, NPS,
OpenStreetMap contributors Jackson County, North Carolina
2 Brown wunrap
VTAIN
o Miles 1
j
yt,0 Cedar Cliff
Powerhouse
:>
Bear Creek
Powerhouse
Cedar Cliff
Dam
C'P)Lge Rdg
pibf
"oun tivn H) C A 0 1 y
4f
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DUKE CEDAR CLIFF AUXILIARY SPILLWAY UPGRADE PROJECT
F'l *'ENERGY. PROJECT LOCATION
I FIGURE 1
PATH: QTROJECT&DUKE-ENERGY%228731 CEDARCLIFF-IDF-SUPPORT%MXDISHPO\PROJECTLOCATION.MXD - USER: EMULARSK - DATE: 811/2016 SECTION 106 CONSULTATION

LEGEND
Area of Potential Effect
DATA SOURCE: USGS Big Ridge Quad
1991; USGS Tuckasegee Quad 1987
1�
J 0 Feet 2,000
A n L :» M V 1, 11
LM
16
i/ 3 L 1
't s
BIG RIDGE_QUADRANGLE' �•4 V ""
v
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r DUKE CEDAR CLIFF AUXILIARY SPILLWAY UPGRADE PROJECT
` USGS QUADRANGLES
ENERGY- FIGURE 2
PATH: O:IPR0JECTS\DUKE_ENERGY\228731_CEDARCLIFF_IDF_SUPPORTIMXD\SHPO\CEDARCLIFFUSGS.MXD - USER: EMULARSK - DATE: 81112016 SECTION 106 CONSULTATION

M' 1Qn°' r
N:
'Soo'
N N c
� r � • i h'
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Cedar Cliff �. o
Dam Auxiliary
Spillway
wool
Ln
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�. 2300'L•r.
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a
LEGEND
_f ,l
R Area of Potential Effect } die w 1T
_ k 233�r 2300,
Drawdown Reservoir Water Surface
y� M
Existing Reservoir Water Surfacer r'r'- �. ► s o N •. uw, Bear Creek
® Photograph Locations 4b 2300' pQo Powerhouse
HATCHED CENTERLINE IS DISTANCE IN FEET FROM
CEDAR CLIFF DAM it
0 Feet 1,000 '{'
DUKE CEDAR CLIFF AUXILIARY SPILLWAY UPGRADE PROJECT
01 ENERGY AERIALS
FIGURE 3
PATH: 0:IPROJECTSIDUKE_ENERGYM8731_CEDARCLIFF_IDF_SUPPORTIMXDISHPO\CEDARCLIFFAERIAL.MXD - USER: EMULARSK - DATE: S11Q01S SECTION 106 CONSULTATION

Duke Energy — Cedar Cliff Auxiliary Spillway Upgrade Project
Photograph 3 — Auxiliary Spillway and Proposed Blasting Area
Photograph 4 — Cedar Cliff Auxiliary Spillway and Fuse Plugs

s � .-,
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Attachment 3
Agency Consultation Pursuant to License Article 401

Cedar Cliff Drawdown Plan Comments/Responses
Date
Form
Name
Organization
Comment
Response
1. The periodicity of shoreline inspection of at least once per month should be
During the drawdown and immediately after the drawdown is reached, inspections will be
shorter during and immediately after reaching the -30 ft target when the lake
performed once per week and after significant rainfall events (e.g., forecasts of 0.5 inches
bottom is saturated and more susceptible to erosion. During this early phase
or greater within 24 hrs). Approximately one month after the drawdown is reached and
January 18, 2017
Email
Fred R Tarver III
NCDWR
inspections should follow rain events. The time between inspections could be
based on the condition of the exposed lake bottom, inspections will occur at least monthly
lengthened as the exposed lake bottom hardens and the weather patterns, and the
for the duration of the drawdown. Inspections will look to identify mass wasting and
associated drought, change.
sloughing of the banks.
January 18, 2017
Email
Fred R Tarver III
NCDWR
2. Duke Energy should be responsive to the observations and concerns of the
Duke Energy will provide contact information to communicate concerns from the property
adjacent land owners regarding erosion and water quality.
owners.
1. Duke Energy is proposing to lower the lake level at a rate of about 3-feet per day
Duke Energy notes this comment and acknowledges that the drawdown will not exceed a
until the desired lake level is achieved. We generally recommend a drawdown rate
rate of 3 feet per 24 hours.
January 9, 2017
Letter
Janet Mizzi
USFWS
of between one and three feet per day. Although the three feet per day drawdown
is at the upper end of our recommended range, we do not object to the proposal
submitted by Duke Energy.
2. Throughout the drawdown process we recommend that consistent monitoring be
Duke Energy will not perform the drawdown during fish spawning season. Duke Energy
conducted for erosion of exposed shoreline areas and for the occurrence of fish
will utlize existing lake bottom topography maps of to identify areas that may be
stranding in shallow lake areas. If shoreline erosion/destabilization or fish
susceptible for fish stranding (i.e., low gradient shoreline). Duke Energy will perform
January 9, 2017
Letter
Janet Mizzi
USFWS
stranding occurs, we recommend that the instances be documented and submitted
inspections of areas identified during the lake bottom topography evaluation for evidence
to the resource agencies for review. The drawdown rate may need to be decreased
of fish stranding during the drawdown process. Duke Energy will provide documentation
to reduce the likelihood of these impacts from continuing to occur.
to the resource agencies of the inspection findings and consult with the agencies as
necessary to determine if changes to the drawdown rate is required.
3. Additionally, we recommend that the following measures be implemented to
January 9, 2017
Letter
Janet Mizzi
USFWS
further minimize the effects of the proposed project on fish and wildlife resources:
Page 1 of 3

Date
Form
Name
Organization
Comment
Response
3a. Develop a plan to monitor and mitigate for erosion along the exposed
Section 3.2 of drawdown plan references Erosion and Sediment Control Plan and
reservoir banks. After rain events, areas near storm water outfall pipes or
describes monitoring to be performed, as follows:
culverts that release high velocity discharges onto exposed banks should be
'Duke Energy has developed and will implement an Erosion and Sediment Control Plan to
inspected for erosive reels or mass wasting. The plan should include
prevent sedimentation impacts to water resources. Best Management Practices (BMP) in
measures that will be implemented should erosive/mass wasting areas be
the vicinity of construction activities will include, but not be limited to, installing
found that are contributing sediment to the river channel. We recommend
protective silt fence, restricting the use of wet concrete within surface waters, and
the use of straw bales or other devices at problem sites to decrease velocity
implementing and maintaining a spill prevention plan for heavy equipment. The work area
of water, decrease erosion, and minimize the amount of sediment released.
will be inspected daily for signs of erosion or degradation and device failure. Following
Any problem areas should be documented. Information on documented
construction, all disturbed areas will be restored and re -graded to preconstruction grades
problem areas should be maintained to focus efforts on erosion control
and re -vegetated with native vegetation.
during any future drawdowns.
During the drawdown and immediately after the drawdown is reached, inspections will be
January 9, 2017
Letter
Janet Mizzi
USFWS
performed once per week and after significant rainfall events (e.g., forecasts for the
Project area of 0.5 inches or greater within 24 hours). Approximately one month after the
drawdown is reached and based on the condition of the exposed lake bottom, inspections
will occur at least monthly for the duration of the drawdown. Inspections will look to
identify mass wasting and sloughing on the banks and install remediation measures as
needed. Remedial measures may include use of straw bales or similar to decrease velocity
of waters, decrease erosion, and minimize the amount of sediment released to Cedar Cliff
Lake.
Sediment and erosion control measures will be implemented and maintained, as necessary
per the requirements of the state water quality certification and to maintain compliance
with the state water quality standards, statutes, or rules."
3b. Establish a specific plan to have a qualified biologist identify and
Section 3.1 of drawdown plan now includes the following provision:
enumerate stranded fish during the upcoming drawdown. Duke Energy
'During the reservoir drawdown process, Duke Energy will perform inspections of the
should assess the data, and consult with resource agencies to determine if
exposed shoreline areas for the occurrence of erosion or fish standing in shallow lake
fish populations are being distressed by the drawdown. If it is determined
areas. If erosion or fish stranding is observed, Duke Energy will consult with the resource
January 9, 2017
Letter
Janet Mizzi
USFWS
that fish are being stranded at levels that will impact fishery populations, we
agencies to determine if a decreased drawdown rate is necessary to reduce the likelihood
recommend that Duke Energy arrange for additional stocking of fish (based
of the erosion or stranding to occur."
on the number and species of stranded fish observed during the drawdown)
following the return of the reservoir to normal operating levels.
3c. Mitigate for the loss of recreational fishing at Cedar Cliff Lake by
NCWRC requested enhancements to the Access Area rather than the fish attractors.
providing financial support to North Carolina Wildlife Resources
January 9, 2017
Letter
Janet Mizzi
USFWS
Commission to install fish habitat/attractors within the reservoir during the
drawdown.
3d. Develop a Spill Prevention, Control, and Countermeasure (SPCC) Plan
The contractor(s) retained for the auxiliary spillway upgrade project will develop,
January 9, 2017
Letter
Janet Mizzi
USFWS
to describe measures to prevent, contain, and clean up petroleum spills from
maintain, and implement SPCC Plan(s), as necessary during construction.
construction activities associated with the auxiliary spillway upgrade.
Page 2 of 3

Date
Form
Name
Organization
Comment
Response
4. According to our records and a review of the information presented, we do not
Duke Energy will implement the protective measures identified by USFWS prior to and
believe that federally listed species or their habitats will be impacted by the
during the auxiliary spillway upgrade project.
proposed drawdown of Cedar Cliff Lake. Due to potential impacts to Northern
Long -Eared Bat (Myotis septentrionalis ), currently federally listed as a threatened
species, and Indiana Bat (Myotis sodalis ), currently federally listed as an
endangered species, informal consultation on the construction activities associated
with the auxiliary spillway upgrade portion of the project began on March 23,
2016. Duke Energy has agreed to implement the following protective measures
into the auxiliary spillway upgrade plans to avoid impacts to these species: 1)
Trees within the 3-acre blasting and clearing area will be cut during the winter
(October 15-April 15) to avoid the maternity roost period for Indiana Bat and
Northern Long -Eared Bat; 2) If any random trees must be cut during the summer
January 9, 2017
Letter
Janet Mizzi
USFWS
roost period, this office will be notified and an experienced biologist will conduct
an on -site habitat assessment to determine if trees are suitable maternity roost
trees; 3) If the tree(s) to be cut are suitable roost trees, an emergence survey will be
conducted before tree removal; and 4) All potential suitable roost trees identified
adjacent to the project area will be marked and protected during clearing activities.
With the implementation of these measures, we have concurred with Duke
Energy's "not likely to adversely affect" determination for the project. Informal
consultation for the auxiliary spillway upgrade project was concluded on August
19, 2016. Thus, we believe the requirements under section 7 of the Act are
fulfilled.
5. Obligations under section 7 of the Act must be reconsidered if: (1) new
Duke Energy will consult with the USFWS if new information becomes available during
information reveals impacts of this identified action that may affect listed species
the auxiliary spillway upgrade project.
or critical habitat in a manner not previously considered, (2) this action is
January 9, 2017
Letter
Janet Mizzi
USFWS
subsequently modified in a manner that was not considered in this review, or (3) a
new species is listed or critical habitat is determined that may be affected by the
identified action.
1. NCWRC staff have reviewed the drawdown plan and does not have objections.
Comment noted.
We appreciate the opportunity to review the plan and your efforts to maintain
January 3, 2017
Email
Chris Goudreau
NCWRC
minimum flows and recreational flows in the Tuckasegee River.
January 3, 2017
Email
Chris Goudreau
NCWRC
2. Please keep John Macemore informed of the drawdown schedule so we can
Duke Energy will continue to coordinate closely with the NCWRC regarding the
properly notify boat access area users of the closure.
drawdown schedule and duration.
Page 3 of 3

Kulpa, Sarah
Subject: FW: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake
From: Tarver, Fred [mailto:[e-mail]]
Sent: Wednesday, January 18, 2017 2:46 PM
To: Johnson, Steve; Barnett, Kevin
Cc: Bryan Tompkins; Goudreau, Chris J.; Higgins, Karen
Subject: RE: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake
Steve,
Without prejudice to any terms and conditions of a subsequent 401 Certification issued by DWR for the proposed
project modifications, the proposal seems reasonable with the following observation:
The periodicity of shoreline inspection of at least once per month should be shorter during and immediately after
reaching the -30 ft target when the lake bottom is saturated and more susceptible to erosion. During this early phase
inspections should follow rain events. The time between inspections could be lengthened as the exposed lake bottom
hardens and the weather patterns, and the associated drought, change. Also, Duke Energy should be responsive to the
observations and concerns of the adjacent land owners regarding erosion and water quality.
Thanks for the opportunity to comment.
Fred
Fred R Tarver III
Instream Flow Program Supervisor
Department of Environmental Quality
919-707-9029 office
[e-mail]
Division of Water Resources
1611 Mail Service Center
Raleigh NC 27699-1611
Email correspondence to and from this address is subject to the
North Carolina Public Records Law and may be disclosed to third parties.
From: Johnson, Steve [mailto:[e-mail]]
Sent: Wednesday, January 18, 2017 8:49 AM
To: Tarver, Fred <[e-mail]>; Barnett, Kevin <[e-mail]>
Cc: Bryan Tompkins <bryan [e-mail]>; Goudreau, Chris J. <[e-mail]>
Subject: FW: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake

Fred and Kevin: Just a friendly reminder, we would like to have your comments on the drawdown plan for Cedar Cliff
Reservoir associated with the Spillway Expansion. If you don't have any comments please let me know by responding to
this email.
Thanks guys.
Steve Johnson
Duke Energy Carolinas
Water Strategy and Hydro Licensing
704-382-4240
704-754-6618
[e-mail]
From: Johnson, Steve
Sent: Thursday, December 15, 2016 3:57 PM
To: Bryan Tompkins; Goudreau, Chris; Fred Tarver; Barnett, Kevin
Subject: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake
Good Afternoon:
Attached is a letter concerning a drawdown planned for Cedar Cliff Lake in conjunction with the Auxiliary Spillway
Upgrade. As described in the attachment Duke Energy would appreciate your input within 30 days. Please let me know
if you have any questions.
Thanks for all your help and I hope you have a great Christmas and New Year holiday!
Steve Johnson
Duke Energy Carolinas
Water Strategy and Hydro Licensing
704-382-4240
704-754-6618
[e-mail]

United States Department of the Interior
FISH AND WILDLIFE SERVICE
Asheville Field Office
160 Zillicoa Street
Asheville, North Carolina 28801
January 9, 2017
Mr. Jeffrey Lineberger
Duke Energy Carolinas, LLC
526 South Church Street
Charlotte, North Carolina 28202
Dear Mr. Lineberger:
Subject: Duke Energy Carolinas, LLC East Fork Hydroelectric Project (P-2698), Draft Cedar
Cliff Lake Drawdown Plan for the Cedar Cliff Hydroelectric Development Auxiliary
Spillway Upgrade Project, in Jackson County, North Carolina
On December 15, 2016, we received (via e-mail) your letter including details of the project and
project plans. We have reviewed the information presented and are providing the following
comments in accordance with the provisions of the Fish and Wildlife Coordination Act, as
amended (16 U.S.C. 661-667e), and section 7 of the Endangered Species Act of 1973, as
amended (16 U.S.C. 1531-1543) (Act).
According to the information presented, Duke Energy Carolinas, LLC (Duke Energy) is
proposing a reservoir drawdown at Cedar Cliff Lake to facilitate upgrade construction on the
emergency (auxiliary) spillway. The proposed auxiliary spillway upgrade project will require
that the lake level of Cedar Cliff Lake be dropped about 30 feet from full pond elevation (2,330
ft amsl) for about 16 months beginning in August 2018. Cedar Cliff Lake elevation will be
lowered by releasing flows through a combination of the generating units and /or spillway gate at
a rate no greater than three feet per 24 hours (average of 0.13 ft/hr) until the desired lake
elevation of 2,300 ft amsl is achieved. Upon completion of the project, Cedar Cliff Lake will be
refilled based on inflows but no greater than three feet per 24 hours until Normal Target
Elevation is achieved.
Comments and Recommendations. Duke Energy is proposing to lower the lake level at a rate
of about 3-feet per day until the desired lake level is achieved. We generally recommend a
drawdown rate of between one and three feet per day. Although the three feet per day drawdown
is at the upper end of our recommended range, we do not object to the proposal submitted by
Duke Energy. However, throughout the drawdown process we recommend that consistent
monitoring be conducted for erosion of exposed shoreline areas and for the occurrence of fish

stranding in shallow lake areas. If shoreline erosion/destabilization or fish stranding occurs, we
recommend that the instances be documented and submitted to the resource agencies for review.
In that case, the drawdown rate may need to be decreased to reduce the likelihood of these
impacts from continuing to occur. Additionally, we recommend that the following measures be
implemented to further minimize the effects of the proposed project on fish and wildlife
resources:
Develop a plan to monitor and mitigate for erosion along the exposed reservoir banks.
After rain events, areas near storm water outfall pipes or culverts that release high
velocity discharges onto exposed banks should be inspected for erosive reels or mass
wasting. The plan should include measures that will be implemented should
erosive/mass wasting areas be found that are contributing sediment to the river channel.
We recommend the use of straw bales or other devices at problem sites to decrease
velocity of water, decrease erosion, and minimize the amount of sediment released. Any
problem areas should be documented. Information on documented problem areas should
be maintained to focus efforts on erosion control during any future drawdowns.
2. Establish a specific plan to have a qualified biologist identify and enumerate stranded fish
during the upcoming drawdown. Duke Energy should assess the data, and consult with
resource agencies to determine if fish populations are being distressed by the drawdown.
If it is determined that fish are being stranded at levels that will impact fishery
populations, we recommend that Duke Energy arrange for additional stocking of fish
(based on the number and species of stranded fish observed during the drawdown)
following the return of the reservoir to normal operating levels.
3. Mitigate for the loss of recreational fishing at Cedar Cliff Lake by providing financial
support to North Carolina Wildlife Resources Commission to install fish habitat/attractors
within the reservoir during the drawdown.
4. Develop a Spill Prevention, Control, and Countermeasure (SPCC) Plan to describe
measures to prevent, contain, and clean up petroleum spills from construction activities
associated with the auxiliary spillway upgrade.
Endangered Species. According to our records and a review of the information presented, we
do not believe that federally listed species or their habitats will be impacted by the proposed
drawdown of Cedar Cliff Lake. Due to potential impacts to Northern Long -Eared Bat (Myotis
septentrionalis), currently federally listed as a threatened species, and Indiana Bat (Myotis
sodalis), currently federally listed as an endangered species, informal consultation on the
construction activities associated with the auxiliary spillway upgrade portion of the project began
on March 23, 2016. Duke Energy has agreed to implement the following protective measures
into the auxiliary spillway upgrade plans to avoid impacts to these species: 1) Trees within the 3-
acre blasting and clearing area will be cut during the winter (October 15-April 15) to avoid the
maternity roost period for Indiana Bat and Northern Long -Eared Bat; 2) If any random trees
must be cut during the summer roost period, this office will be notified and an experienced
biologist will conduct an on -site habitat assessment to determine if trees are suitable maternity
roost trees; 3) If the tree(s) to be cut are suitable roost trees, an emergence survey will be
N

conducted before tree removal; and 4) All potential suitable roost trees identified adjacent to the
project area will be marked and protected during clearing activities. With the implementation of
these measures, we have concurred with Duke Energy's "not likely to adversely affect"
determination for the project. Informal consultation for the auxiliary spillway upgrade project
was concluded on August 19, 2016. Thus, we believe the requirements under section 7 of the
Act are fulfilled. However, obligations under section 7 of the Act must be reconsidered if:
(1) new information reveals impacts of this identified action that may affect listed species or
critical habitat in a manner not previously considered, (2) this action is subsequently modified in
a manner that was not considered in this review, or (3) a new species is listed or critical habitat is
determined that may be affected by the identified action.
We appreciate the opportunity to provide these comments. If we can be of assistance or if you
have any questions, please do not hesitate to contact Mr. Bryan Tompkins of our staff at
828/258-3939, Ext. 240. In any future correspondence concerning this project, please reference
our Log Number 4-2-17-133.
Sincerely,
- original signed —
Janet Mizzi
Field Supervisor
E-Copy: Mr. Chris Goudreau, North Carolina Wildlife Resources Commission
Mr. Fred Tarver, North Carolina Division of Water Resources
Mr. Kevin Barnett, North Carolina Division of Water Resources
Mr. Steve Johnson, Duke Energy Carolinas, LLC

Kulpa, Sarah
Subject: FW: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake
From: Goudreau, Chris J. [mailto:[e-mail]]
Sent: Tuesday, January 03, 2017 10:21 AM
To: Johnson, Steve; Bryan Tompkins; Tarver, Fred; Barnett, Kevin
Cc: Leslie, Andrea J; Wheeler, A. Powell; Macemore, John W.
Subject: RE: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake
Steve,
NCWRC staff have reviewed the drawdown plan and does not have objections. We appreciate the opportunity to review
the plan and your efforts to maintain minimum flows and recreational flows in the Tuckasegee River. Please keep John
Macemore informed of the drawdown schedule so we can properly notify boat access area users of the closure.
Happy New Year,
Chris
Chris Goudreau
Hydropower & Special Projects Coordinator
Habitat Conservation Division
NC Wildlife Resources Commission
645 Fish Hatchery Road
Marion, NC 28752
office: 828-652-4360 ext. 223
mobile: [phone]
[e-mail]
ncwildlife.ora
Vl Lj
From: Johnson, Steve [mailto:[e-mail]
Sent: Thursday, December 15, 2016 3:57 PM
To: Bryan Tompkins <bryan [e-mail]>; Goudreau, Chris J.<[e-mail]>; Tarver, Fred
<[e-mail]>; Barnett, Kevin <[e-mail]>
Subject: East Fork Hydro Project - Drawdown Plan for Cedar Cliff Lake
Good Afternoon:
Attached is a letter concerning a drawdown planned for Cedar Cliff Lake in conjunction with the Auxiliary Spillway
Upgrade. As described in the attachment Duke Energy would appreciate your input within 30 days. Please let me know
if you have any questions.
Thanks for all your help and I hope you have a great Christmas and New Year holiday!
Steve Johnson
Duke Energy Carolinas
Water Strategy and Hydro Licensing

(� DUKE
ENERGY
December 15, 2016
Via electronic mail
Mr. Kevin Barnett
NC Division of Water Resources
2090 U.S. 70 Highway
Swannanoa, NC 28778
Mr. Fred Tarver
NC Division of Water Resources
1611 Mail Service Center
WATER STRATEGY, HYDRO
LICENSING AND LAKE SERVICES
Duke Energy Corporation
526 South Church Street
Charlotte, NC 28202
Mr. Chris Goudreau
NC Wildlife Resources Commission
645 Fish Hatchery Road
Marion, NC 28752
Mr. Bryan Tompkins
Asheville Field Office
U.S. Fish and Wildlife Service
Raleigh, NC 27699-1611 160 Zillicoa Street
Asheville, North Carolina 28801
Subject: East Fork Hydroelectric Project (FERC No. 2698)
Cedar Cliff Hydroelectric Development Auxiliary Spillway Upgrade
Consultation for Scheduled Drawdown
Dear Messrs. Barnett, Tarver, Goudreau and Tompkins:
Duke Energy Carolinas, LLC (Duke Energy) herein provides the enclosed information for your review and
comment on an upcoming scheduled drawdown at the Cedar Cliff Hydroelectric Development of the
East Fork Hydroelectric Project (Project). The Cedar Cliff Development is located on the East Fork of the
Tuckasegee River in Jackson County, North Carolina. The Cedar Cliff Development is the most
downstream of the three developments in the Project. The Bear Creek Development is immediately
upstream of Cedar Cliff and the Tennessee Creek Development is immediately upstream of the Bear
Creek Development.
As further discussed in the enclosed information, the proposed drawdown is necessary to complete
modifications of the Cedar Cliff Dam and associated auxiliary spillway as required by the Federal Energy
Regulatory Commission (FERC) Atlanta Regional Office (ARO) to satisfy safe passage of the Inflow Design
Flood (IDF), which is defined as the Probable Maximum Flood (PMF), without overtopping Cedar Cliff
Dam. In order to complete the aforementioned work, Cedar Cliff Lake will need to be drawn down
approximately 30 feet for the duration of construction (anticipated to be approximately 16 months)
planned for August 2018 through November 2019.
Duke Energy is in the process of obtaining applicable federal and state permits and licenses to perform
this work, including a Section 404/Section 10 permit from the U.S. Army Corps of Engineers and a
Section 401 Water Quality Certification from the North Carolina Department of Environmental Quality,
Division of Water Resources (NCDWR).

East Fork Hydroelectric Project (P-2698)
Cedar Cliff Hydroelectric Development Auxiliary Spillway Upgrade
Consultation for Scheduled Drawdown
December 15, 2016
Page 2
In addition to the aforementioned permits, Duke Energy is required to maintain compliance (or obtain
approval for a variance) with the existing FERC License and associated plans and water quality
certification as well as the Tuckasegee Cooperative Stakeholder Team Settlement Agreement, as
applicable.
Accordingly, Duke Energy will be seeking FERC approval for a temporary variance from License Article
401 Reservoir Level Management for the Cedar Cliff Lake drawdown necessary to complete the FERC-
required auxiliary spillway modifications.
Duke Energy respectfully requests submittal of any comments on the enclosed information within 30
days of the date of this letter. Subsequently, Duke Energy will address any comments received and
submit the final Cedar Cliff Lake Drawdown Plan to FERC requesting approval of the temporary reservoir
level variance.
If you have any questions about the enclosed information, please contact Mr. Steve Johnson at (704)
382-4240 or [e-mail].
Sincerely,
Jeffrey G. Lineberger, PE
Director, Water Strategy & Hydro Licensing
Duke Energy Carolinas, LLC
Enclosure: Draft Cedar Cliff Lake Drawdown Plan
cc w/enclosure: Steve Johnson, Duke Energy
Phil Fragapane, Duke Energy
Brad Keaton, Duke Energy
Lynne Dunn, Duke Energy