NC0000272_Pubic Comments_20220401

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WWATER
www.americanwhitewater.org
[e-mail]
April 27, 2021
Kevin Colburn
National Stewardship Director
P.O. Box 1540
Cullowhee, NC 28723
828-712-4825
Re: Comments on Blue Ridge Paper (National Pollutant Discharge Elimination System (NPDES)
discharge permit NC0000272)
Dear NCDEQ,
American Whitewater is a national non-profit 501(c)(3) river conservation organization founded
in 1954. We have over 6,200 members and 100 local -based affiliate clubs, representing
approximately 80,000 whitewater paddlers across the nation. American Whitewater's mission is
to protect and restore America's whitewater rivers and to enhance opportunities to enjoy them
safely. The Pigeon River is one of the most popular paddling rivers in the Southeast and the
nation thanks to regular summer dam releases, fun rapids, and improved water quality.
As recently as the 1990's the dark brown water of the Pigeon River burned paddlers' eyes and
caused infection and other concerns. Brown foam was common. Many people would not paddle
the Pigeon for fear of chemical poisoning impacts and because color, odor, and other water
quality elements diminished the paddling experience. Since that time much progress has been
made, with ample credit due to Blue Ridge Paper, state regulators, and public river advocates.
The result of water quality improvements is now a river that according to American Outdoors
was the most rafted river nationwide in 2020. Pandemic aside, the recreational use has
ballooned in recent years on the Pigeon, despite rafting trends elsewhere falling. Western North
Carolina has a burgeoning whitewater gear building industry in part because of the Pigeon
River, and a game -changing whitewater rafting economy in East Tennessee is based on the
Pigeon. Smallmouth bass fishing has also picked up to the point that the river supports
professionally guided fishing trips. The Pigeon River has long been a working river, and now it is
working for more people.
With all of this said, the river is still obviously impaired. Fecal coliform levels and algal blooms
occasionally threaten public health, temperature impacts can harm fish, dioxin remains in
sediment and fish tissue, the water remains stained brown, and like nearly all inhabited river
basins the risks of polyfluoroalkyl substances (PFAS) are becoming more clear. These
impairments continue to threaten public and environmental health and diminish the beneficial
uses of paddling, fishing, and swimming.

Paddlers ingest Pigeon River water. When we flip and get splashed the water enters our bodies
through our ears, nose, mouth, eyes, and any cuts we may have. Over even a single day, this
can add up to be a significant amount of water. Because of this fact, American Whitewater
requests that progress continue to be made toward a clean and healthy Pigeon River that fully
supports it's beneficial uses. In practice this means the issuance of a new permit that is certainly
no less protective than the prior permit, and that requires and inspires ongoing improvements.
Color
Part of the proposed new permit would remove the color variance, essentially finding that the
color of the river is normal and acceptable. It is not. The water is stained brown - more so than
any other regional river. This fact is obvious to paddlers who travel around the region paddling
rivers flowing through a wide array of watersheds. Color matters - no one wants to drink brown
tap water or swim in a brown pool - yet that is what paddlers must do to enjoy the Pigeon River.
Importantly, the color studies cited in the permit documents likely were not based on surveys of
people who regularly immersed themselves in rivers or who drink/ingest the river water in
question via recreation. Also, these studies are 25-30 years old, when perceptions and
expectations of river quality were likely different. Color is an indication of impurities in the water
which rightly concern river recreationists. For us, river water is drinking water, so color is not just
an aesthetic consideration to be left to casual observers 30 years ago to decide. The mill
operations significantly change the color of the water, and improvements should continue to be
a goal. While we wholeheartedly appreciate the improvements made to improve the color
impacts on the Pigeon River thus far, a variance should be maintained.
Fecal Coliform
The mill treats the town's sewage along with the mill's waste, and there have been a number of
instances in which there have been bacteria levels released that violate state standards. The
new permit should strive to prevent these releases given the large number of people enjoying
the river downstream. This issue is certainly not unique to the mill, but as more people are
getting outside and enjoying Western North Carolina's and Tennessee's rivers, releases of
dangerous levels of bacteria pose a real public health threat, and an economic impact, and
should be avoided to the extent possible.
Dioxin
Perhaps no chemical pollutant is as notorious in the Pigeon River as dioxin, a dangerous
carcinogen that is still present in fish tissues. Fish tissue should be regularly tested and those
tests should not be reduced in the new permit.
Water Temperature

Paddlers know that warm waters are not as healthy, especially for fish, and the new permit
should reduce the temperature fluctuations allowed by mill discharges. Average temperatures
are simply not relevant to aquatic life, any more so than average flows are relevant to assessing
flood risks. The biological impacts occur based on instantaneous temperature spikes (not
average), something that is routinely measured by USGS gages and other instrumentation. We
suggest continuous temperature monitoring.
Polyfluoroalkyl Substances (PFAS)
Toxic pollutants called polyfluoroalkyl substances (PFAS) do not biodegrade, often persist in
organisms, and pose significant health concerns. The more scientists learn about PSAS the
more clear it becomes that chemicals that produce PFAS should be tracked and when possible
not discharged into waterways. We request analysis and protections regarding PFAS in the new
permit.
Thank you for considering these comments and the interests of the tens of thousands of people
who immerse themselves in the pigeon river while paddling each year. We are hopeful that Blue
Ridge Paper can continue it's progress toward a healthy Pigeon River.
Sincerely,
Kevin Colburn
National Stewardship Director
American Whitewater
PO Box 1540
Cullowhee, NC 28723
828.712.4825
[e-mail]