20080915 Ver 3_Request for Consultation_NCWRC Comments_20160718 (2)

Strickland, Bev
From: Goudreau, Chris J.
Sent: Monday, July 18, 2016 11:31 AM
To: Oakley, Mark; Higgins, Karen; Tarver, Fred; [e-mail];
'[e-mail]'; Dick Christie; '[e-mail]'; 'Bill Marshall
([e-mail])'; [e-mail]; '[e-mail]'; 'Tom
McCoy - FWS'; '[e-mail]'; '[e-mail]';
'[e-mail]'; '[e-mail]'; [e-mail]
Cc: Lineberger, Jeff, Finley, Keith A; Fragapane, Phil
Subject: RE: Request for Consultation - Draft application to amend Duke Energy's water quality
certifications for the Catawba-Wateree Hydroelectric Project
Attachments: Draft application to amend C -W WQCs (NC and SC) - Consultation version - July 15
2016 - WRC comments.docx; Draft application to amend C -W WQCs (NC and SC) -
Consultation version - July 15 2016 - WRC comments.docx
Mark,
As we discussed on the phone, I have a few questions/comments/edits on Appendix F (Water Quality Monitoring
Plan). I've attached the necessary pages with my comments.
Provided those items are addressed, the NCWRC supports the revised amendments to the North Carolina water quality
certification.
Chris
Chris Goudreau
Hydropower & Special Projects Coordinator
Habitat Conservation Division
NC Wildlife Resources Commission
645 Fish Hatchery Road
Marion, NC 28752
office: 828-652-4360 ext. 223
mobile: [phone]
chris.goudreau(cDncwildlife.org
ncwildlife.org
y
From: Oakley, Mark [mailto:[e-mail]]
Sent: Friday, July 15, 2016 5:40 PM
To: Higgins, Karen <[e-mail]>; Tarver, Fred <[e-mail]>; Goudreau, Chris J.
<[e-mail]>; [e-mail];'[e-mail]' <[e-mail]>; Dick
Christie <dchristie@compori um. net>; '[e-mail]' <[e-mail]>; 'Bill Marshall
(Marshal [e-mail])' <[e-mail]>; [e-mail];'[e-mail]'
<[e-mail]>;'Tom McCoy- FWS'<[e-mail]>;'[e-mail]'

<[e-mail]>;'[e-mail]'<[e-mail]>;'[e-mail]'
<[e-mail]>; '[e-mail]' <[e-mail]>; [e-mail]
Cc: Lineberger, Jeff <[e-mail]>; Finley, Keith A <[e-mail]>; Fragapane,
Phil <[e-mail]>
Subject: Request for Consultation - Draft application to amend Duke Energy's water quality certifications for the
Catawba-Wateree Hydroelectric Project
Duke Energy Carolinas, LLC (Duke Energy) is initiating resource agency consultation on the attached draft
application for amendment of the Water Quality Certifications (WQC) issued for the Catawba-Wateree
Hydroelectric Project (Project). In keeping with FERC requirements to provide a minimum of 30 days for
agency consultation, please return your comments to me on or as soon as possible after August 16, 2016 (1
will not complain about comments received early!!!). If there are any problems with delivering or opening
the attached Word file, I'll be glad to send a .pdf version. I welcome you to contact me anytime for questions
or further information. Thank you in advance.
Background Information
Duke Energy is preparing to submit applications for amendment of the Water Quality Certifications (WQC)
issued for the Catawba-Wateree Hydroelectric Project (Project). These amendments are necessary due to
the changes listed below. These changes affect certain appendices of the Catawba-Wateree Comprehensive
Relicensing Agreement (CRA) dated December 22, 2006 which are also incorporated by reference as
conditions of the original WQCs.
1. CRA Parties have found it to be beneficial to improve regional drought resiliency by raising reservoir
summer target elevations on Lakes James, Norman, and Wylie by an additional 6" from May 1 —
October 1 and to make a public safety improvement by modifying the 6,000 cubic feet per second
(cfs) recreation flow release from the Wylie Development to 3,000 cfs. (Several of you who represent
CRA Parties have already seen these two CRA modifications. The CRA modifications are the some as
presented in the attached draft amendment application. In the event either or both of these
modifications are not approved by all CRA Parties, it will have to be withdrawn from the attached draft
amendment application.)
2. Duke Energy has voluntarily initiated revisions to update the Low Inflow Protocol (LIP) and the
Maintenance and Emergency Protocol (MEP) in accordance with
PEI

the CRA based on experience gained during voluntary implementation of these protocols since
2006.
3. The license issued for the Catawba-Wateree Hydroelectric Project on November 25, 2015 requires
Duke Energy to file both a Water Quality Monitoring Plan (WQMP) and a Flow and Water Quality
Implementation Plan (FWQIP). In the interim, since these CRA provisions were developed in 2006,
the status and implementation schedule for these requirements have changed.
For consistency and simplicity, Duke Energy plans to file the attached amendment application with both the
North Carolina Department of Environmental Quality (NCDEQ) to amend North Carolina Certification No. 3767
issued November 14, 2008 and with the South Carolina Department of Environmental Control (SCDHEC) to
amend South Carolina Certification DHEC 08-C-001 issued February 12, 2015. Most revisions apply to both states
and one applies to South Carolina only. The applicability of each revision to each state is clearly identified
within the descriptions of the individual revisions. Duke Energy acknowledges each state will process this
application independently and are under no constraint to synchronize their processing of this application
with the other state. After the two WQC certification processes are complete, Duke Energy will submit all
approved changes to the Federal Energy Regulatory Commission (FERC) requesting the license issued
November 25, 2015 for the Project be amended.
Affected WQC Conditions
The affected WQC conditions are those incorporating by
reference the following CRA appendices.
Appendix A
A-1.0 Reservoir Elevation Articles; Reservoir Elevations (applies to NC and SC)
A-2.0 Flow Articles; Recreation Flows (applies to SC only)
A-3.0 Low Inflow Protocol (LIP) Article (applies to NC and SC)
A-4.0 Maintenance and Emergence Protocol (MEP) Article (applies to NC and SC)
Appendix F: Water Quality Monitoring Plan (WQMP) (applies to NC and SC)
Appendix L: Flow and Water Quality Implementation Plan (FWQIP) (applies to NC and SC)
Email correspondence to and from this sender is subject to the N.C. Public Records Law and may be disclosed to third parties.
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