20011729 Ver 1_Public Comments_20040816

WILSON A. LACY, COMMISSIONER PUBLIC WORKS COMMISSION 955 OLD WILMINGTON RD
TERRI UNION, COMMISSIONER OF THE CITY OF FAYETTEVILLE P.O. BOX 1089
LUIS J. OLIVERA, COMMISSIONER FAYETTEVILLE, NORTH CAROLINA 28302-1089
MICHAEL G. LALLIER, COMMISSIONER TELEPHONE (AREA CODE 910) 483-1401
STEVEN K. BLANCHARD, CEO/GENERAL MANAGER ELECTRIC & WATER UTILITIES FAX (AREA CODE 910) 829-0207
August 10, 2004
Mr. John Thomas
WETLANDS / 401 GROUP
AUG 1 6 2004
Department of the Army
Wilmington District, Corps of Engineers WATER QUALITY SECTION
P.O. Box 1890
Wilmington, NC 28402-1890
Re: TOWN OF SILER CITY PROPOSED ROCKY RIVER LOWER RESERVOIR
EXPANSION - DEPARTMENT OF THE ARMY PERMIT (Action ID No. 200220234)
Dear Mr. Thomas:
The City of Fayetteville Public Works Commission (PWC) wishes to thank the
Corps of Engineers for this opportunity to provide comments on the Town of Siler City's
proposed Department of the Army permit for construction of a new dam on the Rocky
River (within the Cape Fear River Basin) approximately 65 feet below an existing dam to
expand the existing Rocky River Lower Reservoir.
We obtained and reviewed the Applicant's May 24, 2004 draft Wetland and
Stream Mitigation Plan. That document does not appear to address a prior concern we
expressed to the North Carolina Division of Water Quality concerning the proposed
minimum reservoir release conditions. Specifically, PWC is concerned that releases from
the expanded reservoir will be less than adequate under recurrent drought conditions such
as the Cape Fear River Basin has experienced in recent years. Although minimum
releases will be required from the proposed reservoir, these releases will be quite small
for the watershed area of 54.8 square miles that drains to the proposed dam site. As
shown in the graph provided to us by the North Carolina Division of Water Resources,
these proposed monthly releases would be only 0.3 to 0.5 cfs during "Tier 3" Conditions
(i.e., significant reservoir drawdown). Assuming an average flow on the order of 1 cfs
per square mile, this level of release would represent less than 1 percent of average flow,
and only 0.55 percent of average flow during what are normally the lowest flow months
of the year. During an extended drought period in which reservoir drawdown and slow
refill occurs, this minimum release regime could significantly reduce flows that would
otherwise occur in response to rainfall events over the watershed.
We respectfully ask that this concern be addressed as part of this permit
application process. Fayetteville has long been on record with the State that already
depressed flow levels in the Cape Fear River Basin upstream of Fayetteville are being
further reduced by withdrawals and dam operations. We specifically ask for responses to
the following questions:
BUILDING COMMUNITY CONNECTIONS SINCE 1905
AN EQUAL EMPLOYMENT OPPORTUNITY / AFFIRMATIVE ACTION EMPLOYER

1. What efforts have been made to use existing tools such as the Cape Fear River Basin
Hydrologic Model to assess the effect on minimum flow levels from this proposed
dam in concert with other withdrawals and dams such as Jordan Lake and Randleman
Lake?
2. What studies have been conducted to show that extended periods of the low flow
regime associated with the proposed minimum releases (as during an extended period
of reservoir drawdown and refill) will not have an adverse affect on downstream
water quality, aquatic biota, downstream wetlands, and other municipal withdrawals?
3. We are aware of other recent permitting processes for other reservoir projects in the
Mid-Atlantic region where new dams are being proposed, such as in Siler City's case,
or when proposals are made to raise existing dams.
Rocky River Lower Reservoir Expansion - Siler City
Comparison of Minimum Releases

10.0
I I I I I 1 I I I I I
I I I I I I I I I I I

9.0 - I I I 1 I I I I I I I
t I I 1 I I I I I I I
------ L__-_-I-_-_-_I__ _------ ------ ______I_--_-J-_-__J___-_J_____1_____
I I I I I I I I
I I I ?
?
I I I ? • I I I I I I 1 I
I I I ? I I I I I I I
I I I 1 I I I
I I ? I
?
I I• 1 ------
I I 1 I \ I I I I I I I
I I ? 1 I I I I 1 I I
I I ?I I \ I I I I I I I
7.0 _----I I I \ I 1 I
1 I I I I I I I I I I I ?
I I I I \I I I I I 1 I
I I , I I • I I I I I I ?
I I ? I I I I I I I I 1?

.V.. I I I I I\ I I I I I
I I I I I \ I I I I I ? I
0 I I 1 I I I I I I I ? I
?p I I I I I ` I I I I I ? I
d -----I I I I I -I I I I
1 I I I I I
I I
E I I I
\
I I I I I I I ? I
I I I ?? I I ` I I I I 1/ I
I • ? I \ I .4
C 4.0 - ------ L_____I______L?_____I_?_ _____J_____ J------ -___yJ_____
?
I I I I I I I
I I
I I ? I I ` I ? I I I ? I I
®?y...-.®??y \ \ 1
1 I I I \ I I I I I I I
1 I I I I I ` I I I ? I I,

I I I I I\ I \ 1 I ?l I I
_ I I 1 1 I \ I . I I . I I A I
I I I I I • 1 I I I

2.0 ----- F----------- F-----------I - - --_--
I I I I I I I I I I
I
I 1 I ? I I `• I I I h I I I
I I I I I• I I ? I I I
I I I I I I ? I I I I I
I I I I I I I I I I
I I I I I 1 I I I I I
I I I ? I I i I I I 1 L

0.0
JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC
--@-Existing Tier 1 -®- Existing Tier 2 --@---Existing Tier 3
- ¦ - Proposed Tier 1 - ? - Proposed Tier 2 - ? - Proposed Tier 3

In most cases, we have seen much more significant releases now being required (as a
percentage of average flow) than in this case. Why, in this case, are proposed minimum
releases still so low?
Very truly yours,
` PUBLIC WORKS COMMISSION
Noland, P.E.
Chief Operating Officer
Water Resources Division
cc: John Dorney, N.C. Division of Water Quality
John Thomas, U.S. Army Corps of Engineers, Raleigh Regulatory Field Office
3