20031113 Ver 6_401 Application_20091208

I P Duke
Energye
Carolinas
December 7, 2009
Mr. John Dorney
North Carolina Division of Water Quality (NCDWQ)
2321 Crabtree Boulevard
Raleigh, NC 27604
HYDRO LICENSING AND LAKE SERVICES
Duke Energy Carolinas, LLC
526 South Church St.
Charlotte, NC 28202
Mailing Address:
EC12K / PO Box 1006
Charlotte, NC 28201-1006
5kO1,NV i5
DEC - 03 2009
DENR - WATER QUALITY
WETLANDS AND STORAIWATER BRANCH
Re: Withdrawal and Re-submittal of Application for 401 Water Quality Certification
West Fork Hydroelectric Project, FERC No. 2686
DWQ # 2003-1113 V 10
Dear Mr. Dorney:
By a letter dated December 8, 2008, Duke Energy Carolinas, LLC ("Duke") filed a 401 Water
Quality Certification (401 WQC) application with the NCDWQ for relicensing of the West Fork
Project. Since the one-year timeframe that FERC allows states to process 401 WQC
applications expires on December 10, 2009 (i.e., one year following the date that Duke's WQC
application was stamped accepted by NCDWQ) for the West Fork Project, Duke hereby
Withdraws the previous 401 WQC application that was stamped received by NCDWQ on
December 10, 2008 and is simultaneously submitting a new 401 WQC application to NCDWQ
for the West Fork Project. Enclosed is the application fee of $570 for the West Fork Project.
At this time, Duke is also requesting that the NCDWQ place a hold on the processing of the
West Fork Project 401 WQC application. Duke is requesting this hold because final disposition
of the Dillsboro Project is an important consideration in the Tuckasegee Cooperative
Stakeholder Team Settlement Agreement (which also addresses the West Fork Project) and
regulatory approvals related to the Dillsboro Project are not fully resolved. We request that you
provide public notice of this application within 20 days of the day of receipt. We will be glad to
work with you to identify local newspapers as well as place and pay for the appropriate notices.
The demolition and removal of the Dillsboro Dam and Powerhouse is anticipated to be
completed by March, 2010, at which time Duke will request that NCDWQ begin processing the
West Fork 401 WQC application.
If there are any questions, please call Steve Johnson at 704-382-4240 or Phil Fragapane at
704-382-4138.
Sincerely,
Z e--111
,4,e tcl
Steven D. Jester, Vice President
Hydro Strategy, Licensing and Lake Services
Duke Energy Carolinas, LLC
SDJ/sj
www. duke-energy. com
c: Mr. Kevin Barnett, Asheville NCDWQ Regional Office
Mr. Jim Mead, NC Division of Water Resources
Secretary, FERC
Jeff Lineberger, Duke Energy Carolinas, LLC
Steve Johnson, Duke Energy Carolinas, LLC
Phil Fragapane, Duke Energy Carolinas, LLC
Garry Rice, Duke Energy
2
DWQ ID: 03-1113
FERC 401 WATER QUALITY CERTIFICATION
APPLICATION
For existing Federal Energy Regulatory Commission (FERC) Permits
* SEND SEVEN (7) COPIES AND THE
APPROPRIATE FEE (SEE ITEM # 16)* OF THIS APPLICATION TO:
THE NC DIVISION OF WATER QUALITY
ATTN: JOHN DORNEY
2321 CRABTREE BLVD., SUITE 250
RALEIGH, NC 27604
(PLEASE PRINT OR TYPE)
1. OWNER'S NAME:
Duke Energy Carolinas, LLC ("Duke")
Note: Duke is the both the applicant for the 401 Water Quality Certificate,
and the Owner and Licensee of the West Fork Tuckasegee River Hydroelectric
Proiect.
2. MAILING ADDRESS:
526 South Church Street,
CITY: Charlotte STATE: North Carolina ZIP CODE: 28202
PROJECT NAME:
West Fork Tuckasegee River Hydroelectric Proiect, FERC No. 2686
("Proiect")
PROJECT LOCATION ADDRESS (IF DIFFERENT FROM MAILING
ADDRESS ABOVE):
Thorpe Station
13201 Highway 107
Tuckasegee, NC 28783
Tuckasegee Station
41 Disney Lane
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Tuckasegee, NC 28783
)382-5942
3. TELEPHONE NUMBER: (WORK) (294
4. IF APPLICABLE: AGENT'S NAME OR RESPONSIBLE CORPORATE
OFFICIAL, ADDRESS, and PHONE NUMBER:
Mr. Jeffrey G. Lineberger, Director, Hydro Strategy and Licensing
Duke Energy Carolinas, LLC
526 South Church Street, Charlotte, NC 28202
5. LOCATION PROJECT (PROVIDE A MAP, INCLUDING A COPY OF USGS
TOPOGRAPHIC MAP OR AERIAL PHOTOGRAPHY WITH SCALE):
COUNTY: Jackson NEAREST TOWN: Glenville
SPECIFIC LOCATION (INCLUDE ROAD NUMBERS, LANDMARKS, ECT.)
See attached map
6. IMPACTED STREAM/RIVER: West Fork Tuckasegee River
RIVER BASIN: Little Tennessee River Basin
CURRENT DIVISION OF WATER QUALITY (DWQ) CLASSIFICATION:
West Fork Tuckasegee River and all regulated tributaries: WS-III, Class B,
Class C, OWR, TR
7. (a) IS THE PROJECT LOCATED WITHIN A NORTH CAROLINA DIVISION
OF COASTAL MANAGEMENT AREA OF ENVIRONMENTAL CONCERN
(AEC)? YES 1 NO
(b) IF THE PROJECT IS LOCATED WITHIN A COASTAL COUNTY (SEE
PAGE 7 FOR LIST OF COASTAL COUNTIES), WHAT IS THE LAND USE
PLAN (LUP) DESIGNATION?
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(a) ARE ADDITIONAL PERMIT REQUESTS EXPECTED FOR THIS
PROPERTY IN THE FUTURE? YES ? NO H IF YES, DESCRIBE
ANTICIPATED WORK:
(a) ESTIMATED TOTAL NUMBERS OF ACRES IN PROJECT: The total
West Fork Proiect includes 1,470 acres (surface area at full pond of
reservoirs) and approximately 323 acres of land. The West Fork Proiect
includes the following reservoirs:
¦ Lake Glenville -1,462 acres at a full pond elevation of 3,491.7 feet above
mean sea level (msl); and
¦ Tuckasegee Lake - 7.9 acres at a full pond elevation of 2,278.75 feet msl
10. PROVIDE AN APPROPRIATE ENVIRONMENTAL DOCUMENT. THE
DOCUMENT SHOULD ADDRESS:
(a) DATA SHOWING THAT A 7Q10 MINIMUM FLOW WILL BE
PROVIDED
The West Fork Proiect hydro stations are operated as peaking stations under
normal flow and water conditions. During periods of high stream flow and
high reservoir elevation, the stations are operated at maximum load, 24
hours a day, if necessary, to minimize spilling.
In accordance with the Tuckasegee Cooperative Stakeholder Team (TCST)
Settlement Agreement, several flow-related Protection, Mitigation, and
Enhancement Measures (PM&E) were agreed upon by the stakeholder team,
including the NCDWQ (see the attached Settlement Agreement- Section 4.0
for details). These minimum flow related measures are as follows:
¦ Duke shall provide minimum flows of 20 cfs or inflow into Tuckasegee
Lake, whichever is less, from Tuckasegee Lake into the West Fork of the
Tuckasegee River at Tuckasegee Dam from January 1 to December 31 of
each year. These flows will begin on January 31, 2006 or upon acceptance
of the new FERC license by Duke, whichever is later.
Duke may temporarily vary from the minimum flows identified above if
required by conditions beyond its control or by operating emergencies or
maintenance needs as defined in Attachments B and C of the attached
Settlement Agreement. Such temporary variances shall be in accordance
with the Low Inflow Protocol or the Hydro Proiect Maintenance &
Emergency Protocol, incorporated into the attached Settlement
Agreement.
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¦ Duke shall calibrate the existing staff gage located just upstream of the
Tuckasegee Powerhouse tailrace within 60 days following acceptance of
the new FERC license by Duke and at least once every two years
thereafter.
¦ The Parties to the Settlement Agreement agree that Duke will continue
providing each minimum flow for each release point as specified by the
current license, even after expiration of the current license, until the new
minimum flow, pursuant to the New License, for any specific release
point is required to be implemented under terms of the New License.
(b) A COST BENEFIT ANALYSIS OF THE PROJECT SHOWING WHY THE
PROJECT IS STILL NECESSARY
Please see Exhibit H (Supplemental Information), Section H2.0 of the West
Fork License Application for pertinent cost benefit information. A summary
is as follows:
The benefits of the West Fork Project as a resource for both capacity and
energy can be expressed in terms of avoided costs. For the purposes of this
evaluation, avoided costs are energy and capacity costs, which would be
incurred by Duke if the hydro project was not available. These costs can be
estimated to evaluate alternative resources, which have a similar impact on
system energy and capacity costs.
Duke can connect to the main Duke Energy system at the Tuckasegee
Substation in Jackson County. Duke can also acquire additional power from
the Tennessee Valley Authority (TVA) thru an interconnection at the
Santeetlah Substation in Graham County. Under normal conditions, either of
these two suppliers is capable of providing the necessary replacement energy
although at a higher system price.
The average annual generation for the West Fork Project is approximately
95,474 MWh. This figure is based on a Thorpe Hydroelectric Station average
of 84,805 MWh (1946-2002) and a Tuckasegee Hydroelectric Station average
of 10,669 MWh (1951-2002). If the license were not granted, Duke would
incur an additional expenditure. Using the average annual generation and
the SCHEDULE PP-H (NC) 15-year fixed rates for a small hydro project
with storage capability and transmission connection as the proxy alternative,
the annual cost of replacement would be approximately $3,084,333.
The Thorpe and Tuckasegee Hydroelectric facilities, in addition to Duke's
other hydro facilities, produce the lowest cost energy available to Duke and
its Nantahala Area customers. By keeping its costs low, Duke can in turn
keep its electric rates low for its retail and wholesale customers. The increase
in energy costs to customers if a license is not granted is computed as the
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January, 1999
difference in the cost of replacement power and the cost of power produced
by the Proiect. If the license is not granted, the subsequent increase in
energy costs from purchased replacement power (estimated currently at
$3,084,333 annually as described above) may result in higher electric rates
for Duke's retail and wholesale customers.
When water is available to run Duke's conventional hydro units in the
Nantahala Area, this is the least cost option for Duke and its Nantahala area
customers. However, Duke has a shortage of generation capacity relative to
its current Nantahala Area demand during all times of the year. Because of
this, Duke must acquire additional power from either the Tennessee Valley
Authority (TVA) or the rest of Duke's system to satisfy the demand in the
Nantahala Area. Loss of the Thorpe and Tuckasegee Hydroelectric facilities
would therefore increase the generation shortfall and increase dependence on
external power supplies.
(c) DESCRIPTION OF LENGTH OF BYPASS REACH (IF ANY) AND
MEASURES TO PROVIDE FLOW TO THE REACH IN LOW FLOW
CONDITIONS.
There are two separate bypassed reaches associated with the West Fork
Hydroelectric Proiect; West Fork (Glenville) Bypassed Reach and
Tuckaseaee Bypassed Reach. The Glenville Bypassed Reach is
approximately 7.3 miles long from the Glenville Dam to the full pond water
level of Tuckaseue Lake. The Tuckasegee Bypassed Reach is approximately
1.4 miles long from the Tuckasegee Dam to the Tuckasegee Powerhouse.
Combined for the entire Proiect, the bypassed reaches total 8.7 miles.
The current License for the West Fork Proiect has PM&E measures in place
to protect water quality within the Project. Duke agreed to the following
PM&E measures on May 5, 1999 under the current FERC license:
The 1999 settlement agreement requires Duke to release a minimum
instantaneous flow of 20 cfs or the stream flow entering Tuckasegee Lake
from the West Fork of the Tuckasegee River, whichever is less, into the West
Fork of the Tuckasegee River. Duke will also install and maintain a
calibrated staff gage on the West Fork of the Tuckasegee River downstream
of the Tuckasegee Development at an agreed-upon location.
The 2003 TCST Settlement Agreement provides for minimum flow measures
as described in 10(a) of this application and found in Section 4.0 of the
attached Settlement Agreement. These flows are summarized as follows:
¦ Minimum Flows in the Tuckasegee River Main Stem - Assuming that the
new licenses for the West Fork Proiect and the associated East Fork
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Project will include the following minimum flow requirements for the
main stem of the Tuckasegee River:
1. 30 cfs combined minimum flow from December 1 through June 30 (assuming
inflow into Tuckasegee Lake is greater than or equal to 20 cfs) and provided
by the same means as the existing provision:
a. Continue existing minimum flow at Tuckasegee Dam (20 cfs or inflow,
whichever is less).
b. Continue existing minimum flow at the East Fork Project's Cedar
Cliff Powerhouse (10 cfs from a valve at the hydro station during non-
generation hours only). When Cedar Cliff Powerhouse is generating,
the minimum flow valve is turned off.
2. 55 cfs combined minimum flow from July 1 through November 30 (assuming
inflow into Tuckasegee Lake is greater than or equal to 20 cfs) and provided
by.
a. Continue existing minimum flow at Tuckasegee Dam (20 cfs or inflow,
whichever is less).
b. Increase the minimum flow valve capacity at the East Fork Proiect's
Cedar Cliff Powerhouse and provide 35 cfs minimum flow during
non-generation hours only. When Cedar Cliff Powerhouse is
generating, the minimum flow valve is turned off. The non-generation
minimum flow requirements of 10 cfs from December 1 through June
30 and 35 cfs for the remainder of the year will be met by construction
of a either a new turbine and powerhouse adjacent to the existing
Cedar Cliff Powerhouse or with a modification to the existing 10 cfs
valve. The new minimum flow facility will be able to pass
continuously the anticipated requirement of 10 cfs of water for 7
months (December through June) of the year and 35 cfs of water for
the remaining 5 months (July through November).
¦ The following TCST Protection, Mitigation and Enhancement measures
also are associated with the relicensing of the West Fork Project and are
important to an overall Settlement Agreement (see Section 6.0 of the
TCST Settlement Agreement):
1. Duke will provide a one-time funding contribution, in-kind services or
a combination of the two, at Duke's option, not to exceed a total cost
of $40,000* to support a proiect by the USFWS, NCWRC and the
USFS to restore the native strain of brook trout to a selected stream in
the vicinity of the Tennessee Creek Hydro Station.
2. Within 1 to 15 vears following its acceptance of the new licenses for
the Duke Hydro Projects, Duke will provide Cherokee, Clay, Jackson,
Macon and Swain counties $40,000* each to implement the Duke-
selected initiatives from a prioritized list identified by each county's
Soil and Water Conservation District board as of July 1, 2005 that (1)
make physical improvements that protect soil or water resources, (2)
educate landowners or school children on proper soil or water
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January, 1999
conservation practices, and/or (3) improve soil or water conservation
programs that affect lands that drain to any of the Duke Hydro
Projects or the river sections between the Duke Hydro Projects and
reservoirs belonging to the TVA.
3. Within 1 to 15 years following its acceptance of the new licenses for
the Duke Hydro Projects, Duke will provide a total of $200,000* for
the purpose of supporting Duke-selected riparian habitat
enhancement projects on lands that drain to any of the Duke Hydro
Protects or the river sections between the Duke Hydro Projects and
reservoirs belonging to the TVA where such proiects (1) protect or
enhance fish or wildlife habitat directly, or (2) educate landowners or
school children about the importance of healthy riparian areas for
fish and wildlife habitat.
4. By January 1, 2006 or within one vear following its acceptance of the
new licenses for the East Fork Project, West Fork Project and the
Nantahala Project (FERC Project No. 2692), Duke will purchase and
convey the approximately 150-ac tract of land identified in
Attachment J of the TCST Settlement Agreement to the USFS.
o Duke worked with the USFWS, NCDWR, NCDWQ, NCWRC, the
North Carolina State Historic Preservation Officer (NCSHPO) and
the Eastern Band of Cherokee Indians (EBCI) and completed the
necessary environmental, cultural resource, and engineering
assessments regarding removal of Dillsboro Dam and potentially the
Dillsboro Powerhouse (see Attachment F of the TCST Settlement
Agreement for a summary). These assessments evaluated the potential
effects of dam removal on aquatic species; determined the extent of
any cultural resources impacts, and considered the options for
removing the powerhouse (i.e. removal, closure, or leave as-is). (Note
- the final assessment report is included in the Dillsboro Project
License Surrender Application that was filed with the FERC on June
1, 2004 as noted below). The FERC issued a License Surrender Order
for Dillsboro Dam on July 19, 2007. This Order required the
Dillsboro Dam and Powerhouse to be removed by July 19, 2010. After
the License Surrender Order was issued by the FERC, Duke received
a 401 Water Oualitv Certification from NCDWO which requires the
removal of 70,000 vd3 of sediment prior to the demolition and removal
of the dam and powerhouse. Duke has also had many legal challenges
associated with the Dillsboro Dam Removal. At the time of this
application Duke has successfully removed 34,336 vd3 of sediment and
is planning to remove the remaining available sediment by December
31, 2009 with Dam Removal scheduled to beOn on 1/4/2010, assuming
all appropriate approvals have been received.
* Amount increases annually subject to escalation clause in the Tuckasegee Cooperative
Stakeholder Team Settlement Agreement.
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(d) MEASURES PLANNED OR TAKEN TO MAINTAIN DOWNSTREAM
WATER QUALITY SUCH AS ADEQUATE DISSOLVED OXYGEN.
The two-year historical monthly data indicates that the area downstream of
the Proiect dams consistently had oxygen concentrations greater than the
State water quality minimum in 2001 and 2002. Even though oxygen
concentrations in the deeper depths of the upstream storage reservoirs
decreased throughout the stratified period, the DO concentrations in deep
water released from the reservoirs were at least 3 mg/1 greater than the
minimum standard for North Carolina trout waters. Based upon dissolved
oxygen data collected in 2001 and the NCDENR-DWQ historical data,
oxygen concentrations consistently exceeded the minimum concentrations
established by State water quality standards for the Tuckasegee River. For a
full data set, please refer to Exhibit E, Section E2.9 of the West Fork Proiect
License Application.
11. WHAT IS THE SIZE OF THE WATERSHED?
The drainage area associated with the Proiect is 91.4 square miles combining
the two developments. The Thorpe Development has an incremental
drainage area of 36.7 square miles and the Tuckasegee Development has an
incremental drainage area of 54.7 square miles.
WHAT IS THE FULL-POND SURFACE AREA?
The Proiect includes approximately 1,470 acres of reservoir surface area at
full pond. This figure is derived from the total surface acres associated with
the two Proiect reservoirs. The Thorpe Development has a reservoir surface
area of approximately 1,462 acres at full pond at a surface elevation of
approximately 3,491.7 ft msl. The Tuckasegee Development has a reservoir
surface area of approximately 7.9 acres at full pond at a surface elevation of
approximately 2,278.75 ft msl.
12. YOU ARE REQUIRED TO CONTACT THE US FISH AND WILDLIFE
SERVICE AND/OR NATIONAL MARINE FISHERIES SERVICE
REGARDING THE PRESENCE OF ANY FEDERALLY LISTED OR
PROPOSED FOR LISTING ENDANGERED OR THREATENED SPECIES OR
CRITICAL HABITAT IN THE PERMIT AREA THAT MAY BE AFFECTED
BY THE PROPOSED PROJECT. DATE CONTACTED:
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Letter from Brian Cole (USFWS-Asheville) on March 8, 2000 in association
with Proiect Section 7 consultation and subsequent letters/discussions with
the USFWS during the relicensing process.
13. YOU ARE REQUIRED TO CONTACT THE STATE HISTORIC
PRESERVATION OFFICER (SHPO) REGARDING THE PRESENCE OF
HISTORIC PROPERTIES IN THE PERMIT AREA WHICH MAY BE
AFFECTED BY THE PROPOSED PROJECT. DATE CONTACTED:
Letter from Renee Gledhill-Earley (NC Dept. of Cultural Resources) on
December 16, 1999 in association with cultural resource consultation and
subsequent letters/discussions with the NCDCR during the relicensing
process.
14. DOES THE PROJECT INVOLVE AN EXPENDITURE OF PUBLIC FUNDS
OR THE USE OF PUBLIC (STATE) LAND? YES I NO © (IF NO, GO TO
15)
(a) IF YES, DOES THE PROJECT REQUIRE PREPARATION OF AN
ENVIRONMENTAL DOCUMENT PURSUANT TO THE REQUIREMENTS
OF THE NORTH CAROLINA ENVIRONMENTAL POLICY ACT? YES NO
(b) IF YES, HAS THE DOCUMENT BEEN REVIEWED THROUGH THE
NORTH CAROLINA DEPARTMENT OF ADMINISTRATION STATE
CLEARINGHOUSE YES ? NO
IF ANSWER 17b IS YES, THEN SUBMIT APPROPRIATE
DOCUMENTATION FROM THE STATE CLEARINGHOUSE WITH THE
NORTH CAROLINA ENVIRONMENTAL POLICY ACT. QUESTIONS
REGARDING THE STATE CLEARINGHOUSE REVIEW PROCESS
SHOULD BE DIRECTED TO MS. CHRYS BAGGETT, DIRECTOR STATE
CLEARINGHOUSE, NORTH CAROLINA DEPARTMENT OF
ADMINISTRATION, 116 WEST JONES STREET, RALEIGH, NORTH
CAROLINA 27603-8003, TELEPHONE [phone].
15. THE FOLLOWING ITEMS SHOULD BE INCLUDED WITH THIS
APPLICATION IF PROPOSED ACTIVITY INVOLVES THE DISCHARGE OF
EXCAVATED OF FILL MATERIAL INTO WETLANDS: N/A
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January, 1999
(a) WETLAND DELINEATION MAP SHOWING ALL WETLANDS, STREAMS,
LAKES, AND PONDS ON THE PROPERTY (FOR NATIONWIDE PERMIT
NUMBERS 14, 18, 21,26, 29, AND 38). ALL STREAM (INTERMITTENT
AND PERMANENT) ON THE PROPERTY MUST BE SHOWN ON THE
MAP. MAP SCALES SHOULD BE 1 INCH EQUALS 50 FEET OF 1 INCH
EQUALS 100 FEET OF THEIR EQUIVALENT.
(b) IF AVAILABLE, REPRESENTATIVE PHOTOGRAPH OF WETLANDS TO
BE IMPACTED BY PROJECT.
(c) IF DELINEATION WAS PERFORMED BY A CONSULTANT, INCLUDE
ALL DATA SHEETS RELEVANT TO THE PLACEMENT OF THE
DELINEATION LINE.
(d) ATTACH A COPY OF THE STORMWATER MANAGEMENT PLAN IF
REQUIRED.
(e) WHAT IS LAND USE OF SURROUNDING PROPERTY?
(f) IF APPLICABLE, WHAT IS PROPOSED METHOD OF SEWAGE
DISPOSAL?
16. CERTIFICATION FEE
(a) IF THE IMPACT IS LESS THAN 1 ACRE OF WETLAND OR WATER AND
LESS THAN 150 FEET OF STREAM, PLEASE ENCLOSE A CHECK FOR
$240.00 MADE OUT TO THE NORTH CAROLINA DIVISION OF WATER
QUALITY.
(b) IF THE IMPACT EXCEEDS EITHER OR BOTH OF THE LEVELS IN (a),
PLEASE ENCLOSE A CHECK FOR $570.00 MADE OUT TO THE NORTH
CAROLINA DIVISION OF WATER QUALITY.
17. PUBLIC NOTICE IS REQUIRED FOR ALL FERC PROJECTS. PLEASE
NOTE THAT THE APPLICANT IS REQUIRED TO REIMBURSE THE
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DIVISION OF WATER QUALITY FOR THE COSTS ASSOCIATED WITH
THE PLACEMENT OF THE PUBLIC NOTICE. REFERENCE 15A NCAC 2H
.0503 (f).
SIGNED AND DATED AGENT AUTHORIZATION LETTER, IF APPLICABLE.
NOTE: WETLANDS OR WATERS OF THE US MAY NOT BE IMPACTED
PRIOR TO:
ISSUANCE OF A SECTION 404 CORPS OF ENGINEERS PERMIT,
2. EITHER THE ISSUANCE OR WAIVER OF A 401 DIVISION OF
WATER QUALITY CERTIFICATION, AND
3. (IN THE TWENTY COASTAL COUNTIES ONLY), A LETTER FROM
THE NORTH CAROLINA DIVISION OF COASTAL MANAGEMENT
STATING THE PROPOSED ACTIVITY IS CONSISTENT WITH THE
NORTH CAROLINA COASTAL MANAGEMENT PROGRAM,
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January, 1999
OWNER'S/AGENT'S SIGNATURE
Steven D. Jester, Vice President
Hydro Strategy, Licensing and Lake Services
Duke Energy Carolinas, LLC
DATE
(AGENT'S SIGNATURE VALID ONLY IF AUTHORIZATION LETTER FROM
THE OWNER IS PROVIDED).
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January, 1999
WEST FORK HYDROELECTRIC PROJECT FERC No. 2686
SECTION 401 WATER QUALITY CERTIFICATION
APPLICATION TO THE NORTH CAROLINA
DIVISION OF WATER QUALITY
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