20150403-5053(30459531)

Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
Mail Code PJ -12.3
888 First Street, NE
Washington, DC 20426
Re: Comments and Recommendations for the Review of Application Accepted for Filing, Ready
for Environmental Analysis for the Keowee — Toxaway Hydroelectric Project
FERC 9 P- 2503 -154
Dear Ms. Bose:
The United States Department of the Interior (Department) has reviewed the Application for
Filing, Ready for Environmental Analysis for the Keowee — Toxaway Hydroelectric Project.
The following comments are submitted in accordance with the provisions of the Fish and
Wildlife Coordination Act, as amended (16 U.S.C. 661- 667e); section 7 of the Endangered
Species Act of 1973, as amended (16 U.S.C. 1531- 1543); the Federal Power Act (16 U.S.C.
803(a) and 0)); the Migratory Bird Treaty Act (16 U.S.C. 1536, 1538); the National
Environmental Policy Act (42 U.S.C. 4321 et seq.); the Clean Water Act (33 U.S.C. 1251
et seq.); and the Electric Consumers Protection Act of 1986 (100 Stat. 1243).
Protect
The Keowee- Toxaway Hydroelectric Project is part of an energy production complex located on
a set of headwaters tributaries to the Savannah River, including the Toxaway, Keowee, and Little
Rivers in Oconee County and Pickens County, South Carolina and Transylvania County, North
Carolina. The project does not occupy any federal lands. The Keowee- Toxaway Hydroelectric
Project consists of two developments: the 175.5- megawatt (MW) Keowee Development and the
710 -MW Jocassee Development. The Keowee- Toxaway Project interacts directly with several
adjacent energy and water uses. Lake Keowee serves as the cooling water source for Duke's
existing 2,538 -MW Oconee Nuclear Station. Immediately below the project are the U.S. Army
Corps of Engineers' (Corps) Hartwell Lake and Thurmond Lake, both located on the Savannah

Keowee Toxaway Hydroelectric Project FERC Nog 2503 -154 — ER 15 -0084
River. Above the project, Duke's existing 1,065 -MW Bad Creek Hydroelectric Project (P -2740)
uses Lake Jocassee as the water source for pumped storage operations. Water is withdrawn from
the reservoirs by the City of Seneca, South Carolina and by the Greenville South Carolina Water
System.
Jocassee Development
The Jocassee Pumped Storage Development (Jocassee Development), located in Oconee and
Pickens County, South Carolina and Transylvania County, North Carolina, is located on the
Keowee River approximately 20 miles north of Seneca, South Carolina. The Jocassee
Development has four generating units with an installed generating capacity of 710 megawatts
(MW). The Jocassee Development consists of a reservoir (Lake Jocassee), dam, two saddle dikes
and the powerhouse. The reservoir has a surface area at ftull pond (elevation 1,110 feet above
mean sea level) of 7,980 acres and total storage volume of 1,160,298 acre -feet. Normal
minimum reservoir elevation is 1,080 feet msl. Water is conveyed to the generating units via
two circular intake structures leading: to steel penstocks. The four pump turbines are located in
an outdoor -type powerhouse. The pump - turbines release water into submerged draft tubes
leading directly to Lake Keowee which serves as the lower pool for the pumped- storage
operations. The normal full pond elevation of Lake Keowee is 800 feet msl.
Keowee Development
The Keowee Development is a conventional hydroelectric generating plant that has two units
with an installed capacity is a 157.5 MW. The Keowee Development includes the Keowee
Hydro Station, Lake Keowee, the Little River Dam, the Keowee Dam, and four saddle dikes.
Keowee Hydro Station is located on the Keowee River approximately eight miles north of
Seneca, South Carolina. The full pond elevation is 800 feet AMSL. At full pond, the reservoir
has approximately 17,660 surface acres with approximately 388 miles of shoreline. The
drainage area for Lake Keowee is 439 sq mi. Water released from Keowee Hydro Station flows
directly into Hartwell Lake, a U.S. Army Corps of Engineers reservoir, on the Savannah River.
Associated Energy Proiects
In addition to the Project hydro stations, two additional generating facilities utilize the Project
reservoirs. The Bad Creek Hydroelectric Project (FERC Project No. 2740) is a 1,065 MW
pumped storage station that utilizes Lake Jocassee as its lower reservoir. Oconee Nuclear
Station (ONS) is a 2,538 MW nuclear station that utilizes Lake Keowee as a cooling water
source and Keowee Hydro Station as a backup power supply. The combination of the subject
Project, the Bad Creek Hydroelectric Project, and ONS represents approximately 22 percent of
Duke's generating capacity in North and South Carolina. The Bad Creek Project is licensed
separately by the FERC and ONS is licensed by the Nuclear Regulatory Commission (NRC).
Relicensing Process
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By letter dated March 11, 2011, Duke Energy Carolinas, LLC (Duke) filed a Pre - Application
Document (PAD) and Notice of Intent with the Commission for a new license for Keowee -
Toxaway Hydroelectric Project (Keowee- Toxaway Project), FERC Project No. 2503. The
current license for the Keowee- Toxaway Project was issued with an effective date of September
1, 1966, for a term of 50 years and expires on August 31, 2016. In its PAD and accompanying
NOI filed with the Federal Energy Regulatory Commission (FERC or Commission), Duke
declared its intent to apply for a New License for the existing 867.60 megawatt (MW) Keowee -
Toxaway Hydroelectric Project (Project) using the Integrated Licensing Process (ILP) as defined
under FERC Regulations (18 CFR Part 5). On March 31, 2014, Duke Energy Carolinas, LLC
filed its draft License Application. On August 27, 2014, Duke Energy Carolinas, LLC filed its
license application, along with a Relicensing Agreement signed by Duke Energy and 16 other
organizations US Fish and Wildlife Service (USFWS) and DOI were not signatories to the
Relicensing Agreement).
The Department previously commented on scoping, studies, and relicensing matters during the
relicensing process. Duke Energy Carolinas LLC submitted its license application and request
for a new major license on August 27, 2014.
According to the schedule provided in the Notice, Federal Energy Regulatory Commission
(Commission) staff anticipates a draft Environmental Assessment for the proposed relicensing in
October 2015.
Our goals for the upper Savannah River system are to protect, enhance, and restore aquatic and
riparian habitats and species as well as species diversity and to seek mitigation that directly
benefits the affected ecosystem(s). The Department is specifically interested in enhancing
minimum and instream flows for aquatic habitat, restoring flows to bypassed reaches, inundating
floodplains, and restoring populations of native resident and diadromous fish.
Mitigation Policy
Consistent with our Mitigation Policy, we recommended the development of adequate measures
to compensate for the ongoing impacts of this Project and its operation on the natural resources
of the area. These measures should include mitigation for impacts from the continued operation
of the Project on fish and wildlife populations and their habitats, including wetlands. The
U.S. Fish and Wildlife Service published its Mitigation Policy in the Federal Register, Vol. 46,
No. 15, January 23, 1981 (Federal Register 46:7656- 7663), with corrections in the Federal
Register of February 4, 1981. We use the Mitigation Policy to develop consistent and effective
recommendations to protect and conserve valuable fish and wildlife resources and to allow
federal and private developers to anticipate our recommendations and incorporate mitigation
measures into the early stages of the planning process. Our Mitigation Policy helps assure
consistent and effective recommendations by outlining the levels of mitigation needed and the
various methods for accomplishing that mitigation. The Mitigation Policy includes a description
of resource categories that are used to ensure that the level of mitigation recommended will be
consistent with the fish and wildlife resource values involved. This Mitigation Policy applies to
our review and evaluation of impacts of the project and our subsequent recommendations to
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mitigate any adverse impacts. In the interest of serving the public, it is the policy of the
U.S. Fish and Wildlife Service to seek to mitigate the losses of fish and wildlife and their
habitats, and uses thereof, from land and water developments. The Mitigation Policy is
established in accordance with the Fish and Wildlife Act of 1956 (16 U.S.C. 742(a) -754), the
Fish and Wildlife Coordination Act (16 U.S.C. 661- 667(e)), the Watershed Protection and Flood
Prevention Act (16 U.S.C. 1001 - 1009), and the National Environmental Policy Act (42 U.S.C.
4321- 4347).
We recommend the development of adequate measures to compensate for the impacts of this
Project and its operation on the natural and recreational resources of the area. These measures
should include mitigation for project impacts on fish and wildlife populations and their habitats,
as well as the provision of accessible facilities (in accordance with the Americans with
Disabilities Act) for fish- and - wildlife -based recreation.
The U.S. Fish and Wildlife Service's Mitigation Policy, 46 Federal Register, 7656 -5663, states:
In the interest of serving the public, it is the policy of the U.S. Fish and Wildlife
Service to seek to mitigate losses of fish and wildlife, their habitats, and use
thereof from land and water developments.
In seeking mitigation, we will first recommend avoidance and minimization of losses of fish and
wildlife and their habitats. If losses are likely to occur, we will recommend measures to reduce
or eliminate them over time. If losses are likely to continue to occur, we will recommend those
losses be compensated by replacement of the same kind of habitat value so that the total loss of
such in -kind habitat value will be eliminated.
In developing our recommendations for protection, mitigation, and enhancement measures for
the continuing impacts of this project, we seek to reduce adverse impacts to aquatic, riparian, and
terrestrial resources and to enhance fish and wildlife resources where feasible. The Department
recommends mitigation for inadequate in- stream flows, dewatered bypass river reaches, impaired
water quality, and adverse effects to aquatic communities and high - quality forested wetlands
within the floodplain. Sources of mitigation include, but are not limited to, enhanced in- stream
flows; watering of bypass reaches; improvements to water quality; spawning flows for native
fish; ecologically sound inundation of floodplains; protection and enhancement of rare,
threatened, and endangered species; protection of shoreline through riparian buffers; and
acquisition of land.
National Environmental Policy Act
In the Notice, you indicate that pursuant to the National Environmental Policy Act (NEPA) of
1969, as amended, Commission staff intends to prepare an environmental assessment (EA),
which the Commission will use to determine whether, and under what conditions, to issue a new
license for the project. In accordance with NEPA, the environmental analysis you propose will
consider the following alternatives, as appropriate: (1) the no- action alternative; (2) Duke's
proposed action; and (3) Commission staff's alternative.
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Scope of Environmental Document
In general, we believe the proposed relicensing of this major hydroelectric project is a significant
undertaking for which preparation of an Environmental Impact Statement (EIS) is appropriate;
we assent to your approach that will initially lead to production of an Environmental Assessment
(EA), with the possibility of a subsequent EIS if appropriate. We believe an EA will be an
appropriate initial vehicle to consider the environmental effects of the proposed Project, if you
are prepared to quickly include the additional information and effort required in an EIS. The
geographic scope of the environmental document should include not only the footprint of the
Project, but also the area of effect of the Project, including any area of Project- induced effects,
and those effects on riparian and other fish and wildlife habitats. So, the project boundary and
areas affected by the operation of the project should be included within the geographic scope of
analysis. Accordingly, we recommend geographic area to include all reaches between facilities
and tributaries of the main rivers affected by project operations. Along with Duke Energy, we
have identified resource issues that we believe will need to be addressed. These issues include
aquatic, cultural, recreational and terrestrial resources, water quality in Project releases, and
operations and water supply issues.
Alternatives
We recommended that the EA should consider the continued operation of the Project under its
current condition as one alternative, while another separate alternative should be the proposed
relicensing with staff recommendations. In the PAD, Duke has proposed to defer development
of its operation until later in the relicensing process. No new facilities or operational changes are
proposed at this time. Presumably the Licensee's proposal will become available in time for
consideration in the Commission's EA. Additionally, the Commission should consider the
development of adequate mitigation measures for fish and wildlife resources as an alternative, or
part of its own alternative in the EA.
Cumulative Effects
We recommend that a thorough analysis of the cumulative adverse impacts of the hydroelectric
facilities on the Savannah River and its tributaries be included in the EA for the proposed
relicensing of the Project. In addition to habitat fragmentation, and blockage of fish migration
routes, other cumulative impacts, including the continuing effects of the project over time should
be fully evaluated by the FERC. Ways to enhance or mitigate cumulative effects on the
environment should be given equal consideration in the development of the EA and in the
licensing proceedings.
Water Quality
We recommend the EVEIS consider the potential effects of the Project and its operation on
restoration, protection, and enhancement of water quality. Water quality is important for healthy
fish and wildlife communities. We consider this one of the most significant issues to be
addressed in the EA.
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The EA should consider the need for adequate, permanent water quality monitoring stations at
each of the tailwaters, bypassed reaches, and reservoirs. Water quality monitoring should at a
minimum, include collecting temperature, turbidity, pH, dissolved oxygen, and total dissolved
gas information on an hourly basis. In addition, these water quality parameters should be
evaluated along with stage- discharge data to evaluate their relationships with Project operation.
We do not believe it is possible to analyze water quality without also considering the inter-
related effects of water quantity. We recommend the EA analyze the appropriate balance of
water use in the Savannah system and to provide the baseline for multi - jurisdictional decision -
making, long -term water needs study for the entire river basin. We are quite concerned about the
growing trend in conflicting and increasing demands for water from the Savannah system,
especially the consumptive losses, inefficient uses during periods of extreme scarcity, and out -of-
basin transfers to other rivers. We recommend the EA assess the impacts of inter -basin transfers
to the Savannah, and establish a baseline for future water uses.
Endangered Species
By letter dated October 24, 2008, the Commission designated Duke Energy as the non - federal
representative for the purposes of informal consultation with the USFWS pursuant to §7 of the
Endangered Species Act. This designation authorizes Duke to conduct informal consultation,
conduct studies, develop a draft biological assessment and participate in informal consultation
with the USFWS.
Current federal regulations (50 CFR, subsection 402.12(b)(1)) require federal agencies to assess
the effects of their actions and to consult with the USFWS on any action that "may affect" a
listed species. These regulations require the preparation of a biological assessment (of any
endangered and threatened species impacts) for any "major Federal activity affecting the quality
of the human environment," such as the significant changes in these project licenses. The
consultation must include an assessment of not only direct impacts associated with the projects
but also those cumulative and secondary impacts associated with the actions or that are likely to
result from the actions.
Enclosed is a complete list of the federally endangered and threatened species and federal species
of concern known from Oconee and Pickens Counties, South Carolina, and Transylvania County,
North Carolina. In particular, we believe the EA should include a biological assessment of the
potential effects of the new license to these species and their habitats as well as any designated
critical habitat. In its License Application, Duke Energy determined there would be no effect to
listed species.
Migratory Birds
The Migratory Bird Treaty Act (16 U.S.C. 703 -712) prohibits the taking, killing, possession,
transportation, and importation of migratory birds, their eggs, parts, and nests, except when
specifically authorized by the Department of the Interior. Implementing regulations define
"take" under the Migratory Bird Treaty Act as to "pursue, hunt, shoot, wound, kill, trap, capture,
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possess, or collect." Unlike the Endangered Species Act, neither the Migratory Bird Treaty Act
nor its implementing regulations at 50 CFR Part 21, provides for the permitting of "incidental
take" of migratory birds. To avoid impacts to migratory birds, we recommend conducting a
visual inspection of migratory bird nesting habitat within the project area during the nesting
season of March through September. If migratory birds are discovered nesting in the project
impact area, avoid impacting the nests during the migratory bird nesting season (March through
September). Bald and golden eagles are afforded additional legal protection under the Bald and
Golden Eagle Protection Act (16 U.S.C. 668 - 6684).
Migratory birds are protected under the Migratory Bird Treaty Act ([MBTA] -16 U.S. Code 703-
711) and Bald and Golden Eagles are additionally protected under the Bald and Golden eagle
Act QBGEPA] — 16 U.S. Code 668 - 6684). Executive Order 13186 (66 FR 3853) directs federal
agencies to identify where unintentional take is likely to have a measurable negative effect on
migratory bird populations and to avoid or minimize adverse impacts on migratory birds through
enhanced collaboration with the USFWS. The destruction or disturbance of a migratory bird
nest that results in the loss of eggs or young is also a violation of the MBTA.
On March 30, 2011, the USFWS and the Commission entered into a Memorandum of
Understanding (MOU) that focuses on avoiding or minimizing adverse impacts on migratory
birds and strengthening migratory bird conservation through enhanced collaboration between the
Commission and the USFWS by identifying areas of cooperation. This voluntary MOU does not
waive legal requirements under the MBTA, BGEPA, the Endangered Species Act (ESA), the
NGA, or any other statutes and does not authorize the take of migratory birds.
Many of the bird species that occur in the Project area are protected under MBTA. Migratory
birds are those species that breed in Canada and the United States during the summer, and then
spend the winter in the southern U.S., Mexico, Central, or South America, or the Caribbean
Islands. Many bird species pass through the Project area during migration to and from tropical
regions. Some migratory species also winter in the Project area. Since some construction may
occur during the breeding season, the reproductive success of migratory birds may be adversely
affected.
The USFWS Division of Migratory Bird Management provides regional lists of Birds of
Conservation Concern (BCC), which consist of migratory nongame bird species that are likely to
become candidate species for listing under the Endangered Species Act (USFWS, 2008). The
BCC list is divided into regional lists based on Bird Conservation Regions (BCR) and USFWS
Regions. The Project is located at the juncture of the Appalachian Mountains BCR 28 (Jocassee
Development) and the Piedmont BCR 29 ( Keowee Development). Observational data on
migration timing are available from the Breeding Bird Atlas species maps. We recommend you
consider the BCC likely to occur within the Project area, their nesting habitats, and their
potential to occur within the Project area. Also pursuant to the MOU, consider the Important
Bird Areas (IBA) in the Project area, including those designated at Jocassee Gorges and the Blue
Ridge Escarpment Gorges, which support Swainsons Warblers, Worm - eating, Black- throated
Green, and Black- and -white Warblers. The cove hardwood forests support a significant diversity
and abundance of birds associated with this habitat type.
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In order to comply with the provisions of the MBTA, and the USFWS -FERC MOU, we
recommend that you develop Project - specific conservation measures and best management
practices to protect migratory birds and their habitat, and to consider these measures in the EA,
and to include these measures in the Project license.
EA Preparation Schedule
We appreciate the advance schedule for preparation of the draft and final EA in order to meet the
relicensing schedule. We plan to timely file any comments consistent with the EA and
relicensing schedule.
RECOMMENDATIONS
Recensin2 Agreement
While USFWS and DOI did not sign the Recensing Agreement, we believe many of the
measures included in the agreement will minimize and enhance environmental conditions in the
Project area.
Species Protection Plans
The Licensee will implement species protection plans for all federally listed Threatened and
Endangered species affected by the Project. The Licensee shall develop Species Protection Plans
for Federal Threatened and Endangered Species within the Project Boundaries.
Shoreline Woody Debris
In order to provide woody debris for habitat and carbon - nutrient cycling, the Licensee should
manage the shoreline to retain as much woody debris as possible at Lake Jocassee and Lake
Keowee, and should not routinely remove or allow anyone to remove woody debris from the
Project Boundary. Floating hazards to navigation may be moved from the lake and anchored
along the shoreline at appropriate locations.
Habitat Enhancement Program (HEP)
In order to mitigate the impacts to shallow -water and riparian environmental values of the
Project from non - project uses, the Licensee shall establish a HEP as described in Appendix H to
create, enhance, and protect aquatic and wildlife habitat within the Project Boundaries, including
the Project Reservoirs and islands, plus any part of the watershed draining into Project
Reservoirs. The HEP will exist for the term of the New License, or as long as non - project
impacts to shoreline occur. The HEP can be funded by a fee charged to those requesting lake use
permits from the Licensee. The Licensee shall begin collecting the HEP fee upon the SMP
Effective Date (September 1, 2014). The Licensee shall match HEP fee payments from lake use
permit applicants for the first three years up to an annual cap of $100,000. Any user fees
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associated with the HEP may be amended over time. Any fee changes will be determined after
considering the costs associated with mitigation for the shoreline and shallow -water impacts of
non - project uses.
Rare Botanical Species and Natural Communities
In order to protect natural communities from project - related effects, the Licensee shall protect
Special Status Species and botanical Priority Species at known sites within the Project
Boundaries by classifying shoreline with these species as Environmental or Natural; ensure
recreation facility development at Project Access Areas avoids these species; and providing
appropriate signage for these species located within the Project Boundaries in proximity to
Project structures (powerhouses, dams, and dikes).
Entrainment
Entrainment of aquatic (and other) organisms should be mitigated. We recommend the new
license require mitigative measures to reduce entrainment risks as described in the Relicensing
Agreement at 8.5.3 Fish Entrainment. These measures are supported by the results of the
entrainment studies. We recommend:
• Intake Lighting Modifications. The Licensee shall develop a detailed plan for review
by USFWS and other natural resource agencies to redesign and modify lighting for
lighting at the intake towers to eliminate or reduce the amount of light shining on the lake
surface. Such a plan will consider replacing white lights with red lights and illuminating
signage from below rather than above the safety devices.
Tailwater Lighting Modifications are necessary. The Licensee shall develop a detailed
plan for review by USFWS and other natural resource agencies to redesign and modify
lighting illuminating the tailwater area to eliminate or reduce the amount of light shining
on the lake surface immediately downstream of the hydro units. The Lighting
Modification Plan shall include detailed descriptions of the type of lighting, fixtures,
seasonal and daily schedule of operation, testing illumination effects, as well as
maintenance and replacement of bulbs and fixtures. The Licensee shall consult with the
SCDNR and the USFWS on its plan for lighting modifications prior to implementation.
The design of the lighting modifications shall conform with FERC public safety
requirements and shall provide for the continued safety of hydro station personnel and the
continued security of hydro station personnel and facilities. The Licensee shall implement
the lighting modifications within one year following the issuance of the New License
Hydro Unit Starting Sequence Modifications. When operating the hydro units in
pumping mode, the Licensee shall employ a start -up sequence of Unit 3, Unit 4, Unit 1,
and Unit 2, to the extent practicable. The Licensee shall implement the pumping start -up
sequence within 60 days following the issuance of the New License, the end of all
appeals, and the closure of all rehearing and administrative challenge periods. Additional
operational tests may be need to supplement those performed by the Licensee in July
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2013 at the Jocassee Pumped Storage Station is adequate for testing the efficacy of the
fish entrainment reduction actions identified.
Monitoring. In order to detect effects of project operation on fish community
composition and abundance, the Licensee shall develop and submit a plan to the USFWS
and natural resource agencies to monitor fish communities in the reservoirs and adjacent
tributaries, with a focus on native species. Such a plan shall include details about
monitoring intervals, gear types, analyses, trend detection, and reporting.
SECTION 18 FISHWAY PRESCRIPTION
Section 18 Fishway Prescription
Section 18 of the Federal Power Act provides that the Commission must require a licensee to
construct, operate, and maintain such fishways as may be prescribed by the Secretary of the
Interior or the Secretary of Commerce, as appropriate. We do not expect to file prescriptions for
upstream or downstream fish passage facilities at the Project; rather, we plan to reserve our
authority to prescribe fishways at a later date, if determined to be necessary. The fishway
provisions are submitted under separate cover letter from the USFWS Southeast Regional
Director as Section 18 reservation of authority.
SUMMARY
We look forward to working with the Commission and its staff, Duke Energy and others to
ensure impacts to fish and wildlife resources are minimized during the next license period for the
Keowee- Toxaway Hydroelectric Project. In summary, we agree with the plan for continued
operation of the Project. We have provided recommendations to address our concerns regarding
fish and wildlife resources. We look forward to reviewing your EA and its consideration of
potential effects to fish and wildlife resources. If you have any questions about these comments,
please contact Mark Cantrell (mark — [e-mail]) at (828) 258 -3939, Ext. 227, or Byron
Hamstead (Byron _hamstead @fws.gov) at (843) 727 -4707 ext 205. I can be reached at (404)
331 -4524 or via email at [e-mail].
cc:
Christine Willis — FWS
Gary Lecain - USGS
Anita Barnett — NPS
Harold Peterson - BIA
OEPC — WASH
Sincerely,
Joyce Stanley, MPA
Regional Environmental Protection Specialist
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