20070812 Ver 2_Public Comments_20090205 (4)

Dorney, John
From: John Dorney [e-mail]]
Sent: Thursday, February 05, 2009 8:22 AM
To: Ellis, H. Gene; Bromby, Craig A.
Subject: [Fwd: DWR comments on Alcoa application for 401 certificate]
Attachments: DWR comments on Alcoa application for 401 certificate.eml
okay this is not a form letter but it is a comment!
John Dorney
Wetland Program Development Unit
Parkview Building
2321 Crabtree Blvd.
Raleigh, NC 27604
(o) 919-733-9646
/E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties./
1
Dorney, John
From: Jim Mead [e-mail]]
Sent: Wednesday, February 04, 2009 4:53 PM
To: Dorney, John
Cc: Matt Matthews; Reeder, Tom; Ewing, Todd D.; Bernstein, Marc
Subject: DWR comments on Alcoa application for 401 certificate
Attachments: DWR yadkin 401 Comments 02-04-09.doc
John,
I have attached a Word file with DWR's comments on Alcoa's application for a 401 certificate
for the relicensing of it's hydro development on the Yadkin River. I'll drop off a signed
hard copy at your office sometime this week.
If the new 401 certificate contains conditions that are significant changes from what was
issued last year, Tom Reeder and I would like to have the opportunity to review the changes
before the new 401 is signed.
Thanks
Jim
Jim Mead, Environmental Specialist
Jim.Mead(@ncmail.net
919/715-5428
fax - 919/733-3558
*************************************
NC Division of Water Resources - DENR
1611 Mail Service Center
Raleigh, NC 27699-1611
(for overnight mail, UPS, or FedEx - contact me for street address)
E-mail correspondence to and from this address may be subject to the North Carolina Public
Records Law and may be disclosed to third parties.
1
NCDENR
North Carolina Department of Environment and Natural Resources
Beverly Eaves Perdue
Governor
Division of Water Resources
Thomas A. Reeder
Director
Dee Freeman
Secretary
Mr. John Dorney
Division of Water Quality
Wetlands and Stormwater Branch
2321 Crabtree Boulevard
Raleigh, NC 27604
February 4, 2009
Subject: Application for 401 Water Quality Certification
Yadkin Hydroelectric Project (FERC No. 2197)
Alcoa Power Generating Inc., Stanly County
DWQ project Number 2007-0812
Dear Mr. Dorney:
The Division of Water Resources (DWR) has reviewed the Public Notice for this action issued by the Division
of Water Quality on December 4, 2008. DWR provided comments on the initial Application for a 401 Water
Quality Certification for the Yadkin Hydroelectric Project in a letter to you dated July 11, 2007. When the
Public Notice for this project was re-issued on April 16, 2008, we resubmitted those same comments as an
attachment to a letter dated May 1, 2008.
We have no additional comments or recommendations to add to what has been previously submitted. A copy of
our July 11, 2007 letter to you is attached and we ask that these comments be included in the record for
developing the new 401 Certification.
As you are aware, the Federal Energy Regulatory Commission (FERC) cannot issue a new license for this
project until a 401 certificate has been issued. Furthermore, FERC is also unable to issue a new license for the
Progress Energy hydroelectric project downstream on the Pee Dee River until it can simultaneously issue a
license for the Alcoa project. The license for the downstream project (Progress Energy) will contain operational
requirements that depend on the operational requirements for the upstream Alcoa project - including delivery of
water to maintain instream flows. Both of these new FERC licenses are expected to include provisions that
greatly improve conditions from what exists under the current licenses and provide significant benefits to
natural resources. We look forward to the 401 certificate for the Alcoa project being issued so that FERC can
move forward with its relicensing for both Alcoa and Progress Energy, and avoid further delays in
implementing improvements under the new licenses.
1611 Mail Service Center, Raleigh, North Carolina 27699-1611
Phone: [phone] FAX: [phone] Internet: www.ncwater.org
An Equal Opportunity 1 Affirmative Action Employer - 50% Recycled 110% Post Consumer Paper
No thCarofina
Natitrally
DWQ project Number 2007-0812
DWR comments - 2/4/09, Page 2
Please contact me at 715-5428 or Jim.Meadgncmail.net if you have any questions regarding our comments.
Sincerely,
Jim Mead
Environmental Senior Specialist
attachment
cc: Tom Reeder (DWR)
Todd Ewing (WRC)
Marc Bernstein (NC DOJ)
NCDENR
North Carolina Department of Environment and
Division of Water Resources
Michael F. Easley, Governor
July 11, 2007
William G. Ross Jr., Secretary
John Morris, Director
Mr. John Dorney
Division of Water Quality
Water Quality Section
2321 Crabtree Boulevard
Raleigh, NC 27604
Subject: Application for 401 Water Quality Certification
Yadkin Hydroelectric Project (FERC No. 2197)
Alcoa Power Generating Inc., StanlyCounty
Dear Mr. Dorney:
The Division of Water Resources (DWR) has reviewed Alcoa Power Generating Incorporated's (APGI)
application for a 401 water quality certification in conjunction with the license application submitted to the
Federal Energy Regulatory Commission (FERC) for APGI's Yadkin Hydroelectric Project. DWR has been an
active participant during the relicensing process and our involvement has included: scoping and refining issues
to be addressed; review and/or design of technical studies; participation in field studies; participation on various
technical work groups; and review and providing comments on technical studies. We have reached consensus
with other resource agencies and other interests regarding the protection, mitigation, and enhancement measures
needed for this project. DWR along with other DENR divisions, fellow resource agencies, APGI, and the
majority of stakeholders involved in the relicensing process signed an relicensing Settlement Agreement (RSA)
on March5, 2007. Components of the RSA provide an enhanced instream flow regime for the Pee Dee River
downstream of Blewett Falls Dam, project modifications to meet State water quality standards for dissolved
oxygen in tailwaters, improved reservoir levels, modification of the shoreline management plan, and donation
or sale of important conservation lands.
We recommend that the following conditions be included in the 401 certification. These recommendations are
some of the Proposed License Articles in the Relicensing Settlement Agreement related to project operations,
instream flows, water quality, land protection and compliance monitoring for a New FERC License for the
Yadkin Project. References herein to the "License" are to the new FERC license for which DWQ is considering
401 certification, and the reference includes the new license and all annual licenses thereafter. (Note -
References herein to "Commission " refer to the FERC, 214109 addendum).
NorthCarohna
Naturally
Natural Resources
An Equal Opportunity / Affirmative Action Employer - 50 % Recycled 110 % Post Consumer Paper
Proposed License Articles
Project Operations
Unless in accordance with the Hydro Project Maintenance and Emergency Protocol and Low Inflow Protocol,
Project minimum flows take priority over reservoir water elevations, as specifically described in Articles PO-1
and PO-2, below.
Article PO-1- Reservoir Operations
High Rock Reservoir Operations
The Licensee shall operate High Rock Reservoir at or above the normal minimum elevation (NME) as depicted
on the High Rock Operating Curve (Figure PO-1), except as needed in order to maintain minimum flows or as
provided under the Low Inflow Protocol (LIP) or the Hydro Project Maintenance and Emergency Protocol
(HPMEP). High Rock Reservoir may be drawn down below its NME in order to meet the Required Minimum
Instream Flow at Falls, as specified in License Article PO-2, only after Narrows Reservoir has reached its NME.
If High Rock Reservoir water elevation is below NME at 12:01 AM on any operating day, where the operating
day is defined as 12:01 AM through 12:00 midnight, the Licensee shall reduce releases from High Rock
Reservoir for that operating day up to the maximum of the daily average flow equivalent of the minimum flow
requirement at Falls, as specified in License Article PO-2. Under this condition, releases from Falls will be
limited to the those defined in License Article PO-2.
Figure PO-1. High Rock Reservoir Operating Curve
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
624.9
623.9
622.9
621.9
W 620.9
y
619.9
x
616.9
c
0
617.9
d
W 616.9
615.9
N
614.9
613.9
612.9
611.9
610.9
F II Pond Ele vation (62 .9 ft)

i I

?
?
High Rock
Note: During periods for fill and drawdown during March and November
Reservoir would transition between the 4 foot and 10 Operating Curve, with water
elevations increasing or decreasing, as applicable, generally along a straight line.
Normal Minimum Elevation - -Full Pond
Tuckertown Reservoir Operations
The Licensee shall operate Tuckertown Reservoir at or above the NME as depicted on the Tuckertown
Operating Curve (Figure PO-2), except as provided in the HPMEP.
565.7
564.7
563.7
562.7
W 561.7
N
560.7
x
559.7
c
0
.' 558.7
d
W 557.7
Z 556.7
d
N
555.7
554.7
553.7
552.7
551.7
Figure PO-2. Tuckertown Reservoir Operating Curve
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Ful Pond Elevation (564.7 ft)
I
I 1
I '
i
}
i
- - - - T- -
i '
Normal Minimum Elevation - -Full Pond
Narrows Reservoir Operations
The Licensee shall operate Narrows Reservoir at or above the NME as depicted on the Narrows Operating
Curve (Figure PO-3), except as needed in order to maintain minimum flows, or as provided under the LIP or
HPMEP.
510.8
509.8
508.8
507.8
506.8
uJ
505.8
x
504.8
c
0
m 503.8
d
w 502.8
Z 501.8
m
500.8
499.8
498.8
497.8
496.8
Figure PO-3. Narrows Reservoir Operating Curve
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
Full and Elev lion (609.11 ft)
i
I
i
? J
I
j I
Normal Minimum Elevation - -Full Pond
Falls Reservoir Operations
The Licensee shall operate Falls Reservoir at or above the NME as depicted on the Falls Operating Curve
(Figure PO-4), except as provided in the HPMEP.
Figure PO-4. Falls Reservoir Operating Curve
Jan Feb Mar Apr May Jun Jul Aug Sep Oct Nov Dec
333.8
332.8
331.8
330.8
V) 329.8
N
328.8
x
327.8
0
0
326.8
m
w 325.8
0
t 324.8
N
323.8
322.8
321.8
320.8
319.8
Full Pond Elevation (332.8 ft
i
I
i
i
----- --- ----- -----
Normal Minimum Elevation - -Full Pond
Reservoir Stabilization to Enhance Fish Spawning
From April 15 through May 15 of each year, the Licensee will endeavor to maintain reservoir water elevations
at all four Project reservoirs no lower than -1.0 feet below the elevation of each reservoir on April 15 in order to
enhance conditions for fish spawning in the reservoirs. No later than August 31 of each year, the Licensee will
report the resulting reservoir water elevations at each reservoir during the April 15 through May 15 period in a
letter report to the North Carolina Wildlife Resources Commission (NCWRC). The letter report will provide an
explanation of any circumstances that prevented the Licensee from maintaining the target water elevations.
Within 60 days of filing the letter report with the NCWRC, a copy of the letter report will be filed with the
Commission. Satisfaction of these reporting commitments shall constitute compliance with this License
Article.
Article PO-2 - Project Instream Flows
Required Minimum Instream Flows
Commencing no later than six months from the effective date of this License and except when operating under
the LIP or HPMEP, the Licensee shall operate the Project so as to provide a daily average minimum flow from
the Falls Development in accordance with the following schedule:
June 1 - January 31 1,000 cfs
February 1 - May 15 2,000 cfs
May 16 - May 31 1,500 cfs
Article PO-3 - Flow and Reservoir Elevation Monitoring
Within six months of the effective date of this License, the Licensee shall file with the Commission a final Flow
and Reservoir Elevation Monitoring and Compliance Plan for the Yadkin Project. The Flow and Reservoir
Elevation Monitoring and Compliance Plan shall be developed in consultation with the North Carolina Division
of Water Resources (NCDWR), the North Carolina Division of Water Quality (NCDWQ), the South Carolina
Department of Natural Resources (SCDNR), the U.S. Geological Survey (USGS) and the Downstream Licensee
(the Licensee of the Yadkin-Pee Dee River Project, FERC No. 2206), and shall include detailed provisions for
monitoring reservoir water elevations and for monitoring flows from both the Narrows and High Rock
developments.
The Licensee shall include with the final plan documentation of consultation, copies of comments and
recommendations on the draft plan after it has been prepared and provided to the agencies and Downstream
Licensee, and specific descriptions of how comments are accommodated by the final plan. The Licensee shall
allow a minimum of 30 days for the agencies and Downstream Licensee to comment prior to filing the plan
with the Commission. If the Licensee does not adopt a recommendation, the filing shall include the Licensee's
reasons, based on Project-specific information.
The Commission reserves the right to require changes to the plan. Upon Commission approval, the Licensee
shall implement the plan, including any changes required by the Commission. The Licensee shall file the final
plan with the North Carolina Division of Water Quality within 30 days of receiving Commission approval.
Flow monitoring through the High Rock Development powerhouse will measure flow release from the High
Rock development required under License Article PO-1 or under the Low Inflow Protocol. Daily average flows
within +25% of the applicable maximum flow, measured from 12:01 AM to 12:00 midnight, shall be considered
compliant for each operating day.
Flow monitoring in the Falls Development outflow will serve as the compliance measure for the minimum flow
release from the Falls Development required under License Article PO-2 or under the Low Inflow Protocol.
Daily average flows within -5% of the applicable minimum flow, measured from 12:01 AM to 12:00 midnight,
shall be considered to be in compliance for any operating day so long as the applicable daily average minimum
flow is achieved on a weekly average basis, measured from 12:01 a.m. Saturday to 12:00 p.m. midnight Friday.
Whenever High Rock is drawn down below its NME, releases from Falls shall be limited to +/- 5% of the cfs
equivalent of the Required Instream Minimum Flow at Falls, as measured on a weekly average basis from 12:01
a.m. Saturday to 12:00 p.m. midnight.
The Licensee shall endeavor to meet the Required Minimum Instream Flows required in Article PO-2 and shall
not intentionally utilize the flow variances provided above. The Licensee shall prepare an annual flow
monitoring report documenting its compliance with minimum releases, including a record of any days during
the year when the daily average required minimum instream flow fell within the -5% and was made up as part
of the weekly average, a record of flows during any period when High Rock was below its NME, and a record
of any LIP events. The Licensee shall file the report with the Commission and NCDENR summarizing its
evaluation by no later than March 31 of the following year. Article PO-4 - Low Inflow Protocol
The Licensee shall comply with the requirements of the Low Inflow Protocol shown below to the extent such
requirements are enforceable by this License.
Article PO-4 - Low Inflow Protocol
This License Article highlights the responsibilities of the Licensee from Appendix A, "Low Inflow Protocol for
the Yadkin-Pee Dee River Hydroelectric Projects" (LIP), of the Yadkin Hydroelectric Project, FERC No. 2197,
Relicensing Settlement Agreement.
3.1.4.1 Definitions
The following definitions shall be applicable to this Article PO-4:
1. Stream Gage Three-Month Rolling Average Flow - The three-month rolling average of streamflow at the
following U.S. Geological Survey (USGS) stream gages:
• Yadkin River at Yadkin College (02116500)
• South Yadkin River near Mocksville (02118000)
• Abbotts Creek at Lexington (02121500)
• Rocky River near Norwood (02126000)
On the last day of each month, the Licensee shall calculate the arithmetic mean of (a) the daily flows of the
current month and (b) the arithmetic mean of the daily flows of each of the two preceding months. The sum
of the three-month rolling average for these four gage stations shall be compared by the Licensee to the
Historic Stream Gage Three-Month Rolling Average Flow for the corresponding period and a percentage of
Historic Three-Month Rolling Average shall be calculated.
2. Historic Stream Gage Three-Month Rollin Average Flow - The historical three-month rolling average flow
for each of the four designated USGS stream gages for the period 1974 through 2003 (except for the
Abbotts Creek gage, for which the period is 1988 through 2003) are set forth in Table LIP-1 below:
Table LIP-1. Historic Stream Gage Three-Month Rolling Average Flow
For Evaluation of
Flow Trigger on: Average of daily flows
during: Historic Three-Month
Rolling
Average Flow, cfs
January 1 Oct-Nov-Dec 4,000
February 1 Nov-Dec-Jan 5,200
March 1 Dec-Jan-Feb 6,250
April 1 Jan-Feb-Mar 7,700
May 1 Feb-Mar-Apr 7,550
June 1 Mar-Apr-May 6,850
July 1 Apr-May-Jun 5,350
August 1 May-Jun-Jul 4,200
September 1 Jun-Jul-Aug 3,600
October 1 Jul-Aug-Sep 3,200
November 1 Aug-Sep-Oct 3,300
December 1 Sep-Oct-Nov 3,550
3. Full Pond Elevation -The Full Pond Elevation for each development's reservoir is listed in Table LIP-2.
Table LIP-2. Full Pond Elevations
Reservoir Full Pond Elevation
(feet, USGS datum - NGVD 1929)
High Rock 623.9
Tuckertown 564.7
Narrows 509.8
Falls 332.8
4. Normal Minimum Elevation (NME) - NME for each Project reservoir is listed in Table LIP-3.
Table LIP-3. Normal Minimum Elevations (feet, USGS datum - NGVD 1929)

Month High
Rock Tucker-
town
Narrows
Falls
Full Pond 623.9 564.7 509.8 332.8
January 1 613.9 561.7 504.8 328.8
February 1 613.9 561.7 504.8 328.8
March 1 transition 561.7 504.8 328.8
April1 619.9 561.7 504.8 328.8
May 1 619.9 561.7 504.8 328.8
June 1 619.9 561.7 504.8 328.8
July 1 619.9 561.7 504.8 328.8
August 1 619.9 561.7 504.8 328.8
September 1 619.9 561.7 504.8 328.8
October 1 619.9 561.7 504.8 328.8
November 1 transition 561.7 504.8 328.8
December 1-15 613.9 561.7 504.8 328.8
Decemberl6-31 613.9 561.7 504.8 328.8
5. U.S. Drought Monitor Three-Month Numeric Average - The Licensee shall calculate a three-month rolling
average of U.S. Drought Monitor (http://www.drought.unl.edu/dm/monitor.html.) values by (a) assigning a
numeric value equal to the highest U.S. Drought Monitor designation (e.g. D0=0, D1=1, D2=2, D3=3 and
D4=4) for any part of the Yadkin-Pee Dee River Basin draining to Blewett Falls development as of the last
day of that month; and (b) calculating an arithmetic mean of that numeric value and numeric values
correspondingly assigned for the previous two months. A normal condition in the basin, defined as the
absence of a drought designation, shall be assigned a numeric value of negative one (4).
6. Yadkin-Pee Dee River Basin Drought Management Advisory Group (YPD-DMAG) -The YPD-DMAG
shall consist of one representative from each of the following organizations (to the extent that they are
willing to participate): Alcoa Power Generating Inc. (APGI), Progress Energy (PE), North Carolina
Department of Environment and Natural Resources (NCDENR), North Carolina Division of Water
Resources (NCDWR), North Carolina Division of Water Quality (NCDWQ), North Carolina Wildlife
Resources Commission (NCWRC), South Carolina Department of Natural Resources (SCDNR), South
Carolina Department of Health and Environmental Control (SCDHEC), the United States Fish and Wildlife
Service (USFWS), High Rock Lake Association (HRLA), Badin Lake Association (BLA), Duke Power
Company, Lake Tillery Homeowners Association, South Carolina Pee Dee River Coalition (SCPDRC) and
owners of intakes that withdraw more than one million gallons of water per day from the impoundments of
either the Yadkin Project (P-2197) or the Yadkin-Pee Dee Project (P-2206).
3.1.4.2 Implementation Procedure
Table LIP-4 sets forth the combinations of conditions under which the LIP shall be implemented. The
determination of the applicable LIP Stage shall be made using the High Rock Reservoir water elevation as
of midnight between the last day of the previous month and the first day of the current month in
combination with the U.S. Drought Monitor Three-Month Numeric Average and the Stream Gage Three-
Month Rolling Average Flow to determine the need to declare or change a Stage of the LIP. The LIP shall
be implemented beginning at Stage 0 and, if the combination of conditions becomes more severe, the Stages
shall increase in one Stage increments.
Table LIP-4. Summary of LIP Triggers
US Drought Monitor Stream Gage Three-Month
Stage High Rock Reservoir Three-Month Numeric Rolling Average
Elevation Average as a percent of the
Historical Average
< NME minus 0.5 ft and any or any
0 OR
< NME and either >_ 0 or <48%
1 < NME minus 1 ft and either >_ 1 or <41 %
2 < NME minus 2 ft and either >_ 2 or <35 %
3 < NME minus 3 ft and either 3 or <30 %

4 <'/z of ( NME minus Critical
and either
>
4
or
<30 %
Reservoir Water Elevation) _
2. The average daily flows set forth in Table LIP-5 shall be initiated no later than seven days after the
determination of the applicable LIP Stage and shall be in effect for the balance of the month except as
provided in Section 3.1.4.3.
Table LIP-5. LIP Flows(1), CA
High Rock Falls (2)
(daily average (daily average flow target)
Stage maximum flow target)
Feb 1-May 15 May 16-31 Jun 1- Jan 31 Feb I1-May May 16-31 Jun 1- Jan 31
0 2000 1500 1000 2000 1500 1000
1 1450 1170 900 1450 1170 900
2 1080 950 830 1080 950 830
3 770 770 770 770 770 770
4 dditional measures may be determined by consensus of the Licensee and State Agencies, subject to FERC approval
(1) Developments shall be operated to achieve the target flows to the extent practicable as a first priority and to supplement inflows equitably from the
storage reservoirs as a second priority. For LIP Stages 1, 2, 3 and 4, APGI shall achieve the indicated average daily flows set forth in this table by
supplementing Project inflows by drawing proportionally from High Rock and Narrows reservoirs such that the difference between the respective
drawdowns below NME of High Rock and Narrows reservoirs shall be approximately one foot.
(2) For LIP Stages 0-3, the values shown in this table reflect flow targets. These values cannot be met exactly as shown and shall likely vary slightly
on a real time basis from the values shown here, but it is expected that the variances from the target flows shall be minimal.
3. The Licensee shall notify via email the Commission and NCDWR of LIP implementation or a change in
Stage as soon as practicable but no later than (i) three business days after a Stage 0 determination; (ii) two
business days after a Stage 1 or a Stage 2 determination; or (iii) 48 hours after a Stage 3 or Stage 4
determination.
4. The Licensee shall consult with the YPD-DMAG with respect to issues relating to or arising out of
implementation of the LIP, including, but not limited to, (i) notification to the public of the possible effects
of and/or continuance of drought; (ii) issues relating to the effects of drought conditions on life, health,
property, wildlife, aquatic life; (iii) possible public health concerns; and (iv) short and long term prospects
for recovery from drought.
The Licensee shall develop and provide information on its website to inform the public on reservoir water
elevations, Project releases, usability of public access areas, reservoir inflows, meteorological forecasts,
Historic and Actual Stream Gage Three-Month Rolling Average Flow calculations, U.S. Drought Monitor
Three-Month Numeric Average calculations, LIP status, YPD-DMAG meeting summaries, and
implementation of maintenance or emergency operation plans.
Article PO-5 - Hydro Project Maintenance and Emergency Protocol
If conditions so warrant, the Licensee shall operate the Project in accordance with the Hydro Project
Maintenance and Emergency Protocol (HPMEP).
Water Quality
Article WQ-1 -Water Quality
The Licensee shall operate the Project in accordance with the conditions of the water quality certification
submitted by the North Carolina Division of Water Quality under section 401 of the Clean Water Act.
Article WQ-2 - Dissolved Oxygen Monitoring
The Licensee shall conduct dissolved oxygen (DO) monitoring pursuant to the DO Monitoring Plan approved
by the North Carolina Division of Water Quality (NCDWQ) as part of the water quality certification issued by
that agency and attached to this License as an Appendix. Any subsequent amendments to the DO Monitoring
Plan approved in writing by NCDWQ shall also be approved by the Commission prior to implementation.
Copies of the annual DO monitoring reports submitted to NCDWQ shall be filed with the Commission within
30 days of their filing with NCDWQ.
Shoreline Management
Article SMP-1 - Shoreline Management Plan
The Licensee shall file a revised Shoreline Management Plan (SMP) for the Project with the Commission within
two years of the effective date of this License. The Licensee shall revise the SMP in consultation with state and
federal resource agencies and other interested parties. The Licensee shall provide the consulted parties with a
30-day period to review and comment on a draft revised SMP. The Licensee shall include with its filing copies
of all comments received on the draft revised SMP and a discussion of those comments, including whether the
Licensee adopted the comments or the Licensee's rationale for not incorporating the comments in the final
revised SMP.
The Commission reserves the right to require changes to the SMP. Upon Commission approval, the Licensee
shall implement the approved SMP, including any changes required by the Commission.
If you have questions regarding these recommendations, please contact me at 919-715-5424 or
[e-mail]. The Division of Water Resources would appreciate receiving a draft version of the
401 certification before it is released for public comment, so that we can review it and discuss any questions we
might have with you and your staff.
Sincerely,
Steve Reed
Hydropower Licensing Coordinator
cc: Jim Mead (DWR) Darlene Kucken (DWQ)
Todd Ewing (WRC) Marc Bernstein (NC DOJ)