20150759 Ver 1_NCWRC License Comments to FERC_20151118

Burdette, Jennifer a
From: Goudreau, Chris J.
Sent: Wednesday, November 18, 2015 11:50 AM
To: acgivens @cardinalenergy.com; Tarver, Fred; harriet.deal @sol.doi.gov;
jweese @ncdoj.gov; rupak @hydroreform.org; Bryan Tompkins; Burdette, Jennifer a
Cc: Virginia Ward (vcward @skybest.com)
Subject: Ward Mill Hydro (P -9842) - NCWRC comments
Attachments: 2015 -11 -18 ncwrc rea comments.pdf
The North Carolina Wildlife Resources Commission today filed the attached Comments with the
Federal Energy Regulatory Commission ( "Commission ") in Docket No. P- 9842 -006. This email
constitutes service pursuant to Rule 2010 of the Commission's regulations.
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Gordon Myers, Executive Director
November 18, 2015
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Subject: COMMENTS and RECOMMENDATIONS
Notice of Application Ready for Environmental Analysis and Soliciting Comments,
Recommendations, Terms and Conditions, and Prescriptions
Ward Mill Hydroelectric Project, FERC Project No. P- 9842 -006
Dear Secretary Bose:
Submitted are comments and recommendations in response to the Federal Energy Regulatory
Commission's (FERC) September 30, 2015 Notice requesting comments and recommendations
on the License Application for the subject project. The North Carolina Wildlife Resources
Commission ( NCWRC) provides these comments and recommendations in accordance with
provisions of the Federal Power Act (16 U.S.C. 791a et seq.) and the Fish and Wildlife
Coordination Act (48 Stat. 401, as amended; 16 U.S.C. 661 et seq.).
The NCWRC has reviewed the License Application for the Ward Mill Hydroelectric Project
dated August 28, 2014 and the applicant's January 16, 2015 response to FERC's Additional
Information Request. We have participated throughout the relicensing process for this project to
ensure that fish and wildlife affected by this project, their habitats, and the recreational
opportunities they provide will be protected, restored, and enhanced as an outcome of FERC's
licensing decision. The applicant, Mr. Ray Ward, has been receptive to our input and
recommendations during the relicensing process. We submitted comments to the license
applicant or FERC on June 27, 2011 (pre -NOI comments), September 27, 2011 (request to use
TLP), February 3, 2012 (first stage consultation and study requests), April 7, 2014 (draft license
application), and May 15, 2015 (scoping document). We intervened in this relicensing on
February 16, 2015.
The NCWRC manages fish and wildlife resources of the Watauga River basin according to the
2005 North Carolina Wildlife Action Plan (NCWAP) which emphasizes management of
nongame species. Our general management goals are to protect rare, threatened and endangered
species, manage fish and wildlife resources for diverse ecosystems and public use, and ensure
Habitat Conservation Division • 645 Fish Hatchery Road • Marion, NC 28752
Telephone: [phone] • Fax: [phone]

Ward Mill Hydro — REA Comments Page 2 November 18, 2015
adequate public access to the project and vicinity. The NCWAP plan is listed in Scoping
Document 2 as a comprehensive plan in this proceeding, but is incorrectly attributed to the North
Carolina Department of Environment & Natural Resources. It should be referenced as authored
by the NCWRC. The 2015 edition of the NCWAP will be finalized and is scheduled to be
published by the end of the year, at which time we will submit it to FERC for inclusion as a
comprehensive plan.
The NCWRC recommends the following measures be incorporated as terms and conditions of
the new license for the project pursuant to Section 10 0) of the Federal Power Act.
10 (j) Recommendations
The project shall be operated in run -of -river mode, such that outflow equals inflow at all
times. If the reservoir level drops below the crest of the dam, the turbine(s) should stop
running so that water can immediately spill over the dam. Run -of -river operation may be
temporarily modified if required by operating emergencies beyond the control of the
Licensee, and for short periods upon mutual agreement between the Licensee and the
NCWRC and other agencies.
2. Records of inflow and outflow shall be maintained to ensure run -of -river operation, and
to document maintenance and emergency drawdowns. Inflow to the project is available
on a 15- minute interval from the U.S. Geological Survey gage (403479000) located just
upstream of the reservoir. If the USGS gage is no longer maintained, the licensee shall
install a stream gage or other recording device after consulting with the FERC and
appropriate resource agencies. Records of pond stage and generation should be made
available to the NCWRC and other agencies upon request to compare project outflow to
inflow.
3. A reservoir drawdown and refill management plan should be developed with the
NCWRC and other resource agencies prior to any actions to lower the reservoir level
substantially below the crest of the dam.
4. A sediment management plan should be developed with the NCWRC and other resource
agencies prior to any actions to open the sand gates, dredge sediment from the reservoir
or otherwise release sediment from the project.
Justification for Recommendations 1, 2 and 3: The recommendation for run -of -river operation is
based upon the negative impacts of peaking flows on downstream riverine habitat. Many studies
have documented the negative impacts of fluctuating flows on fish and invertebrates (Corning
1970, Cushman 1985, Gislason 1985, Nelson 1986, Bain and Finn 1988, Travnichek and
Maceina 1994, Gehrke and Harris 2001, Murchie et al. 2008). Run -of -river operation would
provide stable flows, thus stable habitat, in the river below the dam.
Monitoring of flows, pond levels and generation is necessary to document that the project is
operating in run -of -river mode and minimizing resource impacts. Therefore, monitoring
qualifies as a Section 10 0) recommendation.

Ward Mill Hydro — REA Comments Page 3 November 18, 2015
Finally, should the Licensee need to lower the reservoir substantially, it will be necessary to
avoid rapid dewatering or prolonged periods of low flows downstream of the dam which can
damage aquatic resources. The intent of the plan is to maintain adequate flows downstream of
the dam during scheduled and unplanned maintenance and emergency operations.
Justification for Recommendation 4: The rapid release of sediment from the dam has the
potential to smother downstream aquatic habitats, injure or kill aquatic organisms, and reduce
biological productivity. Impacts can be minimized if the sediment discharge is scheduled to
avoid critical biological periods and to coincide with high flow events.
Literature Cited
Bain, M.B., J.T. Finn and H.E. Booke. 1988. Stream flow regulation and fish community
structure. Ecology 69(2):382 -392. DOI: 10.2307/1940436
Corning, R.V. 1970. Water fluctuation, a detrimental influence on trout streams. Proceedings
of the Twenty -Third Annual Conference of the Southeastern Association of Game and
Fish Commissioners 23: 431 -454.
Cushman, R.M. 1985. Review of ecological effects of rapidly varying flows downstream from
hydroelectric facilities. North American Journal of Fisheries Management 5:330 -339.
DOI: 10. 1577/ 1548- 8659(1985)5 <330:ROEEOR >2.0.CO;2
Gehrke, P.C. and J.H. Harris. 2001. Regional -scale effects of flow regulation on lowland
riverine fish communities in New South Wales, Australia. Regulated Rivers: Research
and Management 17:369 -391. DOI: 10.1002/rrr.648
Gislason, J.C. 1985. Aquatic insect abundance in a regulated stream under fluctuating and
stable diel flow patterns. North American Journal of Fisheries Management 5:39 -46.
DOI: 10. 1577/ 1548- 8659(1985)5 <39:AIAIAR >2.0.CO;2
Murchie, K.J., K.P.E. Hair, C.E. Pullen, T.D. Redpath, H.R. Stephens and S.J. Cooke. 2008.
Fish response to modified flow regimes in regulated rivers: research methods, effects and
opportunities. River Research and Applications 24:197 -217. DOI: 10.1002 /rra.1058
Nelson, F.A. 1986. Effect of flow fluctuations on brown trout in the Beaverhead River,
Montana. North American Journal of Fisheries Management 6:551 -559. DOI:
10.1577/ 1548- 8659(1986)6 <551:EOFFOB >2.0.CO;2
Travnichek, V.H. and M.J. Maceina. 1994. Comparison of flow regulation effects on fish
assemblages in shallow and deep water habitats in the Tallapoosa River, Alabama.
Journal of Freshwater Ecology 9(3): 207 -216. DOI: 10.1080/02705060.1994.9664888
If you have any questions concerning these comments, please call me at 828 - 652 -4360 ext. 223.

Ward Mill Hydro — REA Comments Page 4 November 18, 2015
Sincerely,
Christopher Goudreau
Hydropower & Special Projects Coordinator
cc: Jennifer Burdette — NCDWR
Fred Tarver — NCDWR
Bryan Tompkins — USFWS
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