20150759 Ver 2_FERC Draft EA_20160719

Burdette, Jennifer a
From: Andrew Givens <[e-mail]>
Sent: Tuesday, July 19, 2016 6:51 PM
To: Burdette, Jennifer a
Cc: [e-mail]
Subject: Fwd: Document Service in P-9842-006
Jennifer, I am forwarding to you the notification of the issuance of the draft environmental assessment related
to the Ward Mill dam project, which I received today. The document can be downloaded from the elibrary link
shown below. I have not reviewed this document at this time.
There was a subsequent email that indicated that there is a 45 day comment period, with comments due on
September 2, 2016.
Andy Givens
919-605-6125
Begin forwarded message:
From: <[e-mail]>
Date: July 18, 2016 at 11:05:42 AM PDT
To: <ac ig [e-mail]>
Subject: Document Service in P-9842-006
This notification is served on you in accordance with the requirements set forth in Section 385.2010 of the
Commission's rules.
On 7/18/2016, the Federal Energy Regulatory Commission (FERC), Washington D.C., published the following
issuance:
Docket(s): P-9842-006
Description: Notice of Availability of Draft Environmental Assessment re Mr. Ray F. Ward under P-9842.
You can view the issuance at:
http://elibrary.FERC.gov/idmws/file_list.asp?accession num=20160718-3016
You may also eSubscribe to the docket number(s) in the issuance by clicking on the following link to login to
FERC Online.
https://ferconline.ferc.gov/eSubscription.aspx
------------------------------------------------------------------------
Please do not respond to this email.
Online help is available here:
http://www.ferc.gov/efiling-help.asp
or for phone support, call 866-208-3676.
Comments and Suggestions can be sent to this email address: mailto:[e-mail]

20160718-3016 FERC PDF (Unofficial) 07/18/2016
UNITED STATES OF AMERICA
FEDERAL ENERGY REGULATORY COMMISSION
Mr. Ray F. Ward
Project No. 9842-006
NOTICE OF AVAILABILITY OF DRAFT ENVIRONMENTAL ASSESSMENT
(July 18, 2016)
In accordance with the National Environmental Policy Act of 1969 and the Federal
Energy Regulatory Commission's (Commission) regulations, 18 C.F.R. Part 380 (Order
No. 486, 52 FR 47879), the Office of Energy Projects has reviewed the application for a
new license for the Ward Mill Hydroelectric Project, located on the Watauga River near
Boone, Watauga County, North Carolina, and has prepared a draft Environmental
Assessment (draft EA) for the project. The project would not occupy federal land.
In the draft EA, Commission staff analyze the potential environmental effects of
relicensing the project and conclude that continued project operation under a new license,
with appropriate measures, would not constitute a major federal action significantly
affecting the quality of the human environment.
A copy of the draft EA is available for review at the Commission in the Public
Reference Room or may be viewed on the Commission's web site at www.ferc.gov using
the "eLibrary" link. Enter the docket number, excluding the last three digits, in the
docket number field to access the document. For assistance, contact FERC Online
Support at [e-mail] or toll-free number at 1-866-208-3676, or for
TTY, 202-502-8659.
You may also register online at www.ferc.gov/docs-filing/esubscription.asp to be
notified via email of new filings and issuances related to this or other pending projects.
For assistance, contact FERC Online Support.
For further information, please contact Adam Peer by telephone at [phone]
or by email at [e-mail].
Kimberly D. Bose,
Secretary.

20160718-3016 FERC PDF (Unofficial) 07/18/2016
DRAFT ENVIRONMENTAL ASSESSMENT
FOR
HYDROPOWER LICENSE
Ward Mill Hydroelectric Project
FERC Project No. 9842-006
North Carolina
Federal Energy Regulatory Commission
Office of Energy Projects
Division of Hydropower Licensing
888 First Street, NE
Washington, D.C. 20426
July 2016

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TABLE OF CONTENTS
TABLEOF CONTENTS..................................................................................................... i
LISTOF FIGURES............................................................................................................ iv
LISTOF TABLES............................................................................................................... v
ACRONYMS AND ABBREVIATIONS...........................................................................vi
EXECUTIVE SUMMARY............................................................................................... vii
1.0 INTRODUCTION...................................................................................................1
1.1 APPLICATION...................................................................................................1
1.2 PURPOSE OF ACTION AND NEED FOR POWER ........................................ 3
1.2.1 Purpose of Action............................................................................................ 3
1.2.2 Need for Power................................................................................................3
1.3 STATUTORY AND REGULATORY REQUIREMENTS ................................ 4
1.3.1 Federal Power Act........................................................................................... 4
1.3.2 Clean Water Act.............................................................................................. 5
1.3.3 Endangered Species Act.................................................................................. 5
1.3.4 Coastal Zone Management Act....................................................................... 5
1.3.5 National Historic Preservation Act.................................................................. 6
1.4 PUBLIC REVIEW AND COMMENT............................................................... 6
1.4.1 Scoping............................................................................................................ 6
1.4.2 Interventions.................................................................................................... 7
1.4.3 Comments on the License Application........................................................... 7
2.0 PROPOSED ACTION AND ALTERNATIVES.................................................... 8
2.1 NO -ACTION ALTERNATIVE.......................................................................... 8
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2.2 APPLICANT'S PROPOSAL..............................................................................8
2.2.1 Project Description.......................................................................................... 8
2.2.2 Proposed Project Operation............................................................................. 8
2.2.3 Project Safety................................................................................................... 9
2.2.4 Proposed Environmental Measures...............................................................10
2.3 STAFF ALTERNATIVE..................................................................................11
3.0 ENVIRONMENTAL ANALYSIS........................................................................13
3.1 General Description of the Area........................................................................13
3.2 Scope of Cumulative Effects Analysis..............................................................14
3.3 Proposed Action and Action Alternatives.........................................................14
3.3.1 Geological and Soil Resources......................................................................15
3.3.2 Water Resources............................................................................................ 21
3.3.3 Fishery Resources..........................................................................................29
3.3.4 Terrestrial Resources..................................................................................... 43
3.3.5 Recreation and Land Use............................................................................... 46
3.3.6 Cultural Resources......................................................................................... 50
3.4 No -Action Alternative....................................................................................... 52
4.0 DEVELOPMENTAL ANALYSIS....................................................................... 53
4.1 POWER AND ECONOMIC BENEFITS OF THE PROJECT ......................... 53
4.2 COMPARISON OF ALTERNATIVES............................................................ 54
4.2.1 No -Action Alternative................................................................................... 55
4.2.2 Mr. Ward's Proposal..................................................................................... 55
4.2.3 Staff Alternative............................................................................................ 55
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4.3 COST OF ENVIRONMENTAL MEASURES.................................................56
5.0 CONCLUSIONS AND RECOMMENDATIONS................................................64
5.1 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED
ALTERNATIVE........................................................................................................... 64
5. 1.1 Measures Proposed by Mr. Ward.................................................................. 64
5.1.2 Additional Measures Recommended by Staff ............................................... 65
5.1.3 Measures Not Recommended by Staff.......................................................... 68
5.2 UNAVOIDABLE ADVERSE EFFECTS.........................................................72
5.3 FISH AND WILDLIFE AGENCY RECOMMENDATIONS ......................... 72
5.4 CONSISTENTCY WITH COMPREHENSIVE PLANS ................................. 79
6.0 FINDING OF NO SIGNIFICANT IMPACT ....................................................... 80
7.0 LITERATURE CITED.......................................................................................... 81
8.0 LIST OF PREPARERS......................................................................................... 85
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LIST OF FIGURES
Figure 1. Location of the Ward Mill Project.................................................................. 2
Figure 2. Recreation facilities....................................................................................... 48
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LIST OF TABLES
Table 1. Monthly flow data (cfs) for the Ward Mill Project from USGS gage number
03479000 Watauga River near Sugar Grove, North Carolina .......................... 22
Table 2. North Carolina water quality standards relevant to the Ward Mill Project...... 23
Table 3. Fish species and number collected in the vicinity of the Ward Mill Project
during initial surveys conducted between June 6 and August 7, 2013, and a
supplemental survey conducted in the impoundment on October 31, 2013..... 31
Table 4. Minimum flow required for fish in streams identified by Tennant .................. 39
Table 5. Burst swim speeds of the five species found in the Ward Mill impoundment. 41
Table 6. Parameters for the economic analysis for Ward Mill Project ........................... 54
Table 7. Summary of the annual cost of alternative power and annual project costs for
alternatives for the Ward Mill Project.............................................................. 55
Table 8. Cost of environmental mitigation and enhancement measures considered in
assessing the environmental effects of the proposed Ward Mill Project.......... 57
Table 9. North Carolina WRC section 100) recommendations for the Ward Mill
Project............................................................................................................... 74
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ACRONYMS AND ABBREVIATIONS
APE
area of potential effects
certification
water quality certification
°C
degrees Celsius
Cfs
cubic feet per second
Corps
U.S. Army Corps of Engineers
CWA
Clean Water Act
CZMA
Coastal Zone Management Act
DO
dissolved oxygen
EA
environmental assessment
EPA
OF
FERC or Commission
FPA
fps
FWS
Interior
kW
MWh
mg/L
National Register
U.S. Environmental Protection Agency
degrees Fahrenheit
Federal Energy Regulatory Commission
Federal Power Act
feet per second
U.S. Fish and Wildlife Service
U.S. Department of the Interior
kilowatt
megawatt -hour
Milligrams per liter
Nation Register of Historic Places
NERC North American Electric Reliability Corporation
NHPA National Historic Preservation Act
North Carolina SHPO North Carolina State Historic Preservation Officer
North Carolina DENR North Carolina Department of Environment and
Natural Resources
North Carolina DEQ
North Carolina Department of Environmental
Quality
North Carolina DWR
North Carolina Division of Water Resources
North Carolina WRC
North Carolina Wildlife Resources Commission
NRI
Nationwide Rivers Inventory
RM
river mile
SCORP
State Comprehensive Outdoor Recreation Plan
USGS
U.S. Geological Survey
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EXECUTIVE SUMMARY
Proposed Action
On August 28, 2014, Mr. Ray F. Ward (Mr. Ward or applicant), filed an
application for a new license for the Ward Mill Hydroelectric Project (Ward Mill Project
or project) with the Federal Energy Regulatory Commission (FERC or Commission).
The 168 -kilowatt (kW) project is located on the Watauga River near Boone, in Watauga
County, North Carolina. The project does not occupy federal land.
Project Description
The Ward Mill Project is located on the Watauga River in northwestern North
Carolina. The project includes: (1) a 130 -foot -long, 20 -foot -high rock and concrete dam;
(2) an impoundment with a surface area of 4.6 acres and an estimated gross storage
capacity of 16.3 acre-feet; (3) a 14 -foot -long, 5 -foot -wide, and 7.5 -foot -tall penstock
made of rock, reinforced concrete and steel; (4) a 60 -foot -long, 20 -foot -wide powerhouse
integrated into the south end of the dam, containing two generating units with a total
capacity of 168 kW; (5) interconnection with the utility, at the meter point on the
southwest, exterior wall of the powerhouse; and (6) appurtenant facilities. Project
recreation facilities include a 250 -foot -long portage trail with a boat takeout about 150
feet upstream of the dam and a boat put -in below the dam.
The project's average annual energy production is 374,403 megawatt -hours
(MWh). Mr. Ward proposes no additional capacity and no modifications to project
facilities.
Current Project Operation
Article 401 of the current license' requires Mr. Ward to operate the Ward Mill
Project in a run -of -river mode, and at all times minimize the fluctuation of the project
impoundment's surface elevation by maintaining a continuous discharge from the project,
such that flow as measured downstream from the project tailrace approximates the sum of
inflow to the project impoundment.
' See 36 FERC ¶ 62,283 (1986).
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Proposed Project Operation
Mr. Ward proposes to continue to operate the Ward Mill Project in a run -of -river
mode, whereby water flowing into the project impoundment equals water flowing out.
To verify run -of -river operation, Mr. Ward proposes to continue to monitor flows
daily, continue to operate a float gage controlling an automatic cut-off switch on the
turbines so that generation would be taken off-line when the water level drops below the
crest of the dam, and provide access to 15 -minute interval generation data. Mr. Ward
also proposes to install and operate a flow gage to record inflow to the project if the
United States Geological Survey (USGS) discontinues operation of gage number
03479000, which is located 200 feet upstream of the impoundment.
Mr. Ward proposes to implement a drawdown and refill plan that would allow
water in the impoundment to be drawn down about 10 feet below the top of the dam
during any necessary maintenance or emergencies.3 Mr. Ward's plan includes provisions
to: (1) refill the impoundment when inflow to the impoundment is greater than or equal
to 60 cubic feet per second (cfs); (2) release a minimum of 60 cfs into the tailrace during
refill; (3); visually monitor water level and flow downstream of the dam at all times
during drawdown and refill; and (4) notify the Commission and resource agencies prior
to beginning a drawdown.
Proposed Environmental Measures
In addition to the operation -related measures noted above, Mr. Ward proposes to:
• Implement a sediment management plan with provisions to: (1) manage
sediment build-up if it occurs in the impoundment; (2) notify the
Commission and resource agencies if sediment accumulates and must be
2 Mr. Andy Givens (agent to Mr. Ward) stated, in a letter filed February 11, 2016,
that Mr. Ward has access to 15 -minute interval generation data from the utility that could
be used to show whether the project was generating during low flow events.
3 In a letter filed December 9, 2015, Mr. Ward states that dropping the water level
to about 10 feet below the top of the dam is adequate for most repair and maintenance
activities.
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removed; and (3) consult with the Commission and resource agencies to
identify steps necessary to remove sediment from the impoundment.
• Implement a plan to prevent erosion of the impoundment shoreline, with
provisions to: (1) monitor the shoreline for damage caused by floods or
recreational activities along the shoreline; (2) notify the Commission and
the resource agencies if shoreline erosion is identified; and (3) consult with
the Commission and the resource agencies to identify steps necessary to
protect the shoreline after damage is identified.
• Continue to operate and maintain the existing recreation facilities at the
project, which include: (1) a canoe portage trail with put -in and take-out
areas; (2) a parking area in the vicinity of the dam and mill buildings; and
(3) informal bank -fishing areas along the full length of the impoundment.
Public Involvement and Areas of Concern
Before filing his license application, Mr. Ward conducted a pre -filing consultation
process under the traditional licensing process. The intent of the Commission's pre -filing
process is to initiate public involvement early in the project planning process and to
encourage citizens, governmental entities, tribes, and other interested parties to identify
and resolve issues prior to an application being formally filed with the Commission.
After the application was filed, we conducted scoping to determine what issues and
alternatives should be addressed. A scoping document was distributed to interested
parties on March 18, 2015. On September 30, 2015, we issued the ready for
environmental analysis notice, requesting comments, recommendations, terms and
conditions, and prescriptions.
Alternatives Considered
This draft environmental analysis (draft EA) analyzes the effects of the proposed
action and recommends conditions for any subsequent minor license that may be issued
for the project. This draft EA considers the following alternatives: (1) Mr. Ward's
proposal, as outlined above; (2) Mr. Ward's proposal with staff modifications (staff
alternative); and (3) no action, meaning that the project would continue to operate under
the terms of the existing license.
Staff Alternative
Under the staff alternative, the project would be operated as proposed by Mr.
Ward, with modifications and additional measures described below.
Our recommended modifications and additional environmental measures include,
or are based on, Mr. Ward's proposed measures and recommendations made by federal
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and state resource agencies that have an interest in resources that may be affected by
operation of the proposed project.
• File a report with the Commission and resource agencies if the float gage and
cut-off system fails, or if the water level in the impoundment drops below the
crest of the dam to ensure that the Commission and stakeholders could react to
any deviation from run -of -river.
• Implement impoundment drawdown and refill procedures for emergency and
maintenance drawdowns with provisions to: (1) conduct emergency and
maintenance drawdowns when inflow is greater than 60 cfs; (2) limit the
drawdown rate to 1 foot per day; (3) release inflow to the tailrace while the
impoundment is drawn down; (4) refill only when inflow is greater than 60 cfs;
(5) when refilling, release a minimum of 60 cfs in the tailrace; (6) establish a
low -flow rating curve of minimum flow releases during drawdowns; and (7)
notify the resource agencies and the Commission as soon as possible, but no
later than 10 days after each drawdown event. These measures would help to
ensure adequate protection of aquatic resources in the impoundment and
downstream from the dam during drawdown events.
The staff alternative does not include Mr. Ward's proposal to implement a plan to
prevent erosion of the impoundment shoreline, because erosion is unlikely to occur
during normal run -of -river operation, and because any potential erosion that could occur
in the impoundment during drawdown events would be limited by staff s
recommendation to limit the drawdown rate to 1 foot per day. The staff alternative also
does not include Mr. Ward's proposal to install and operate a flow gage to record inflow
to the project if the USGS discontinues operation of gage number 03479000, because Mr.
Ward proposes to continue to operate a float gage and cut-off switch to prevent water
from falling below the crest of the dam to ensure the project could not operate in any
mode other than run -of -river, and to visually monitor flow daily to ensure proper
operation of the float gage and cut-off switch.
No -Action Alternative
Under the no -action alternative, the project would continue to operate and generate
about 374,403 MWh annually, and the environmental conditions at the project site would
remain the same.
Environmental Effects of the Staff Alternative
The primary issues associated with licensing the project include maintenance of
run -of -river operations, sediment management in the impoundment, impoundment
drawdown and refill management for maintenance activities, and availability of adequate
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recreation amenities. Below we summarize the environmental effects of the staff
alternative and the measures recommended to address those effects.
Geological and Soils Resources
Impoundment drawdowns that occur during routine maintenance could lead to
shoreline erosion along the impoundment. Specifically, if drawdowns occur rapidly,
saturated streambank soils could become more susceptible to sloughing and lead to
erosion. Staffs recommendation to limit the drawdown rate to 1 foot per day, as part of
the impoundment drawdown and refill plan, would protect the project's shoreline
(including established native vegetation) from erosion associated with maintenance and
emergency drawdowns.
Water Resources
Field observations indicate that dissolved oxygen (DO) can fall below the state
standard of 6.0 milligrams per liter (mg/L) in the impoundment (but not in the tailrace)
during drawdown events that occur during summer low flow periods. Limiting
maintenance drawdowns and refills to periods when flow is sufficient (greater than 60
cfs) to allow rapid refill of the impoundment, would shorten the duration of any low DO
events that might occur. Requiring adequate minimum flows in the tailrace (60 cfs)
during drawdown and refill of the impoundment would help buffer against low DO
conditions that could occur if insufficient flows were released into the tailrace during
these events.
Fishery Resources
Continued operation in run -of -river mode would continue to minimize water level
fluctuations in the impoundment or downstream resulting from project operation, and
would maintain flow conditions, water quality, and habitat for aquatic life in the
impoundment and downstream of the project during all flow conditions. Requiring that
Mr. Ward continue daily, visual monitoring of flows and operation of a float gage
controlling a cut-off switch, which would shut down the project turbines when water falls
below the crest of the dam, would ensure that the project could not function in any
operational mode other than run -of -river. Staff recommends adding a measure for Mr.
Ward to file a report if the float gage and cut-off switch fail, or if the water level in the
impoundment drops below the crest of the dam, which would ensure that the Commission
and stakeholders could react to any deviation from run -of -river operations. Staff s
alternative would help maintain and verify run -of -river operation and protect aquatic
resources at the project.
Periodic maintenance drawdowns would dewater portions of the littoral zone in
the project impoundment, which could strand and isolate aquatic organisms, and expose
them to greater predation risk and degraded water quality. The release of water that
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occurs while drawing down the impoundment also has the potential to rapidly increase
flows downstream of the project, which could flush organisms from their respective
habitats. If downstream flow releases are not sufficient during impoundment refills,
dewatering of the project tailrace and downstream reaches could occur, causing
reductions in physical habitat, increases in water temperature, and decreases in DO.
Limiting the drawdown rate to 1 foot per day would reduce the likelihood of aquatic
organisms becoming stranded in the impoundment, and flushed downstream from
habitats in the tailrace. Requiring adequate inflows (60 cfs) to the project prior to
drawdown and adequate minimum flows in the tailrace (60 cfs) during refill, would
ensure that drawdowns do not begin during the most biologically stressful low flow and
drought conditions, and ensure that minimum flow releases during drawdown and refill
are adequate to sustain aquatic life downstream from the dam.
Recreation and Land Use
The existing recreation facilities at the Ward Mill Project provide a portage route
at the dam, several bank -fishing opportunities along the full length of the impoundment,
and a small parking area in the vicinity of the dam and mill buildings. These facilities
provide adequate recreation opportunities for visitors to the project. Regular Form 80
filings would ensure that Mr. Ward monitors and documents the adequacy of recreation
use at the project over the term of a license.
Cultural Resources
No historic or cultural resources have been identified within the Ward Mill
Project's area of potential effects. The North Carolina SHPO concurred that the project
would have no effect on resources listed or eligible for listing on the National Register of
Historic Places. If unknown archeological or historic resources are discovered over the
term of a license, requiring Mr. Ward to cease project activities and consult with the
North Carolina SHPO about the treatment of any newly discovered resources would help
avoid, lessen, or mitigate potential adverse effects to previously -unidentified historic
properties.
Conclusions
Based on our analysis, we recommend licensing the project as proposed by
Mr. Ward, with staff modifications and additional measures.
In section 4.2 of the draft EA, Comparison of Alternatives, we estimate the likely
cost of alternative power for each of the alternatives identified above. Our analysis
shows that during the first year of operation under the no -action alternative, the project
power would cost $ 139,030, or 371.34/MWh less than the likely alternative cost of
power. Under Mr. Ward's proposal, project power would cost $137,682 less than the
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likely alternative cost of power. Under the staff alternative, project power would cost
$138,599 less than the likely alternative cost of power.
Based on our independent review of agency comments filed on this project and
our review of the environmental and economic effects of the proposed project and its
alternatives, we selected the staff alternative as the preferred option. The staff alternative
includes the elements of the applicant's proposal with additional staff -recommended
measures and mandatory conditions. We chose the staff alternative as the preferred
alternative because: (1) the project would provide a dependable source of electrical
energy for the local area; (2) the 168 kW of electric capacity comes from a renewable
resource that does not contribute to atmospheric pollution, including greenhouse gases;
and (3) the environmental measures recommended by staff would adequately protect and
enhance environmental resources affected by the project. The overall benefits of the staff
alternative would be worth the cost of the recommended environmental measures.
We conclude that issuing a subsequent minor license for the project, with the
environmental measures we recommend, would not be a major federal action
significantly affecting the quality of the human environment.

20160718-3016 FERC PDF (Unofficial) 07/18/2016
DRAFT ENVIRONMENTAL ASSESSMENT
Federal Energy Regulatory Commission
Office of Energy Projects
Division of Hydropower Licensing
Washington, D.C.
Ward Mill Hydroelectric Project
FERC Project No. 9842-006 — North Carolina
1.0 INTRODUCTION
1.1 APPLICATION
On August 28, 2014, Mr. Ray F. Ward (Mr. Ward or applicant) filed a license
application for the Ward Mill Hydroelectric Project (Ward Mill Project or project) with
the Federal Energy Regulatory Commission (FERC or Commission).' The 168 -kilowatt
(kW) project is located on the Watauga River near Boone, in Watauga County, North
Carolina (figure 1). The average annual energy production is about 374,403 megawatt -
hours (MWh). The project does not occupy federal land.
' The current license for the Ward Mill Project was issued with an effective date of
September 1, 1986, for a term of 30 years and expires on August 31, 2016.

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1.2 PURPOSE OF ACTION AND NEED FOR POWER
1.2.1 Purpose of Action
The purpose of the proposed project is to continue to provide a source of
hydroelectric power for Mr. Ward's adjacent saw mill, with excess power being sold to
the Blue Ridge Electric Membership Cooperative. Under the provisions of the Federal
Power Act (FPA), the Commission must decide whether to issue a license to Mr. Ward
for the project and what conditions should be placed on any license issued. In deciding
whether to issue a license for any hydroelectric project, the Commission must determine
that the project will be best adapted to a comprehensive plan for improving or developing
a waterway. In addition to the power and developmental purposes for which licenses are
issued (such as flood control, irrigation, or water supply), the Commission must give
equal consideration to the purposes of. (1) energy conservation; (2) the protection of,
mitigation of damage to, and enhancement of fish and wildlife resources; (3) the
protection of recreational opportunities; and (4) the preservation of other aspects of
environmental quality.
Issuing a new license for the project would allow Mr. Ward to continue to
generate electricity, making electric power from a renewable resource available for use in
his saw mill and to the Blue Ridge Electric Membership Cooperative.
In this draft environmental assessment (draft EA), we assess the effects of
operating, and maintaining the project: (1) as proposed by Mr. Ward and (2) with staffs
recommended measures (staff alternative). For the purposes of conducting our
environmental analysis, we also consider the effects of no -action. Under the no -action
alternative, the project would continue to operate and no new environmental protection,
mitigation, or enhancement measures would be implemented. Important issues that are
addressed include compliance with run -of -river operations, management of sediment
accumulation in the impoundment, the effects of maintenance drawdowns and associated
dewatering and flow fluctuations on aquatic resources, and the provision of adequate
recreation amenities.
1.2.2 Need for Power
The Ward Mill Project provides power for Mr. Ward's adjacent saw mill, with
excess power being sold to the Blue Ridge Electric Membership Cooperative, which
helps meet part of North Carolina's power requirements, resource diversity, and capacity
needs. The project has an installed capacity of 168 kW and generates an average of about
374,403 MWh per year.
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The North American Electric Reliability Corporation (NERC) annually forecasts
electrical supply and demand nationally and regionally for a 10 -year period. The project
is located within SERC -North (SERC -N), a subregion of SERC Reliability Corporation
(SERC), a region of the NERC. According to NERC's most recent (2015) forecast, the
summer internal demand for this subregion is projected to increase by 0.84 percent from
2016 to 2025.
We conclude that power from the Ward Mill Project would help meet a need for
power in the SERC -N subregion in both the short and long term. The project would
provide power that could displace non-renewable, fossil -fired generation and contribute
to a diversified generation mix. Displacing the operation of non-renewable facilities may
avoid some power plant emissions and create an environmental benefit.
1.3 STATUTORY AND REGULATORY REQUIREMENTS
A license for the Ward Mill Project is subject to numerous requirements under the
FPA and other applicable statutes. We describe the major regulatory requirements below.
1.3.1 Federal Power Act
1.3.1.1 Section 18 Fishway Prescriptions
Section 18 of the FPA, 16 U.S.C. § 811, provides that the Commission shall
require the construction, maintenance, and operation by a licensee of such fishways as
may be prescribed by the Secretary of the Interior or the Secretary of Commerce, as
appropriate. The U.S. Department of the Interior (Interior) filed a letter on November
17, 2015 requesting that a reservation of authority to prescribe fishways under section 18
of the FPA be included in any license issued for the project.
1.3.1.2 Section 106) Recommendations
Under section 100) of the FPA, 16 U.S.C. § 8030), each hydroelectric license
issued by the Commission must include conditions based on recommendations provided
by federal and state fish and wildlife agencies for the protection, mitigation, or
enhancement of fish and wildlife resources affected by the project. The Commission is
required to include these conditions unless it determines that they are inconsistent with
the purposes and requirements of the FPA or other applicable laws. Before rejecting or
modifying an agency recommendation, the Commission is required to attempt to resolve
any such inconsistency with the agency, giving due weight to the recommendations,
expertise, and statutory responsibilities of such agency.
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North Carolina Wildlife Resource Commission (North Carolina WRC) timely
filed, on November 18, 2015, recommendations under section 100), as summarized in
table 9, in section 5.3, Recommendations of Fish and Wildlife Agencies. In section 5.3,
we also discuss how we address the agency recommendations and comply with
section 100).
1.3.2 Clean Water Act
Under section 401 of the Clean Water Act (CWA), 33 U.S.C. § 1341, a license
applicant must obtain certification from the appropriate state pollution control agency
verifying compliance with the CWA. On July 29, 2015, Mr. Ward applied to the North
Carolina Division of Water Resources (North Carolina DWR) for a section 401 water
quality certification (certification) for the Ward Mill Project, and on the same date the
North Carolina DWR received Mr. Ward's application requesting a certification for the
project. On December 18, 2015, North Carolina DWR filed a letter indicating that Mr.
Ward's application cannot be processed, and is on hold until the environmental review
process is completed.
1.3.3 Endangered Species Act
Section 7 of the Endangered Species Act, 16 U.S.C. § 1536, requires federal
agencies to ensure that their actions are not likely to jeopardize the continued existence of
any endangered or threatened species or result in the destruction or adverse modification
of the critical habitat of such species. There are no federally listed endangered or
threatened species or critical habitat known to occur in the Ward Mill Project vicinity.
By letter dated April 8, 2014 (filed with the license application on August 28, 2014), the
U.S. Fish and Wildlife Service (FWS) concurred, and on November 12, 2015, FWS filed
a letter stating that no federally listed species or their habitats will be adversely affected
by the project. Therefore, licensing the project would not affect listed species and no
further consultation under section 7 is needed.
1.3.4 Coastal Zone Management Act
Under section 307(c)(3)(A) of the Coastal Zone Management Act (CZMA), 16
U.S.C. § 1456(c)(3)(A), the Commission cannot issue a license for a project within or
affecting a state's coastal zone unless the state CZMA agency concurs with the license
applicant's certification of consistency with the state's CZMA program, or the agency's
concurrence is conclusively presumed by its failure to act within 180 days of its receipt of
the applicant's certification.
The project is not located within the state -designated Coastal Management Zone,
which is limited to 20 coastal North Carolina counties on the eastern edge of the state.
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The Ward Mill Project is about 200 miles west of the Coastal Management Zone. In an
email dated June 30, 2014 (filed with the license application on August 28, 2014), the
North Carolina Coastal Management Program confirmed that a CZMA consistency
certification is not required for the project.
1.3.5 National Historic Preservation Act
Section 106 of the National Historic Preservation Act (NHPA), 54 U.S.C.
§ 306108, and its implementing regulations, 36 C.F.R. Part 800, requires that every
federal agency "take into account" how each of its undertakings could affect historic
properties. Historic properties are districts, sites, buildings, structures, traditional cultural
properties, and objects significant in American history, architecture, engineering, and
culture that are eligible for inclusion in the National Register of Historic Places (National
Register).
Pursuant to section 106, the applicant consulted with the North Carolina State
Historic Preservation Officer (North Carolina SHPO) and affected Indian tribes to locate,
determine National Register eligibility, and assess potential adverse effects to historic
properties associated with the project. By letter dated October 3, 2011 (filed with the
license application on August 28, 2014), the North Carolina SHPO stated that there were
no historic properties which would be affected by the project.
1.4 PUBLIC REVIEW AND COMMENT
The Commission's regulations, 18 CFR § 4.38, require that applicants consult with
appropriate resource agencies, tribes, and other entities before filing an application for a
license. This consultation is the first step in complying with the Fish and Wildlife
Coordination Act, the Endangered Species Act, NHPA, and other federal statutes. Pre-
filing consultation must be complete and documented according to the Commission's
regulations.
1.4.1 Scoping
Before preparing this draft EA, we conducted scoping to determine what issues
and alternatives should be addressed. A scoping document (SDI) was distributed to
interested agencies and others on March 18, 2015. The SDI was noticed in the Federal
Register on March 25, 2015. Two scoping meetings, both advertised in the Watauga
Democrat, were held on April 21, 2015, in Boone, North Carolina, to request oral
comments on the project. A court reporter recorded the comments and statements made
at the scoping meetings, and these are part of the Commission's public record for the
project. In addition to the comments provided at the scoping meetings, written comments
were filed by North Carolina WRC (May 15, 2015), Interior (May 19, 2015), and
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Mr. Ward (May 22, 2015). A revised Scoping Document (SD2), addressing these
comments, was issued on July 8, 2015.
1.4.2 Interventions
On January 28, 2015, the Commission issued a notice that Mr. Ward's application
to license the Ward Mill Project had been accepted for filing. This notice set
March 29, 2015, as the deadline for filing protests and motions to intervene. In response
to the notice, the following entities filed notices of intervention or motions to intervene
(none opposed issuance of a license):
Intervenor Date filed
North Carolina WRC February 16, 2015
North Carolina Department of Environment
and Natural Resources (North Carolina DENR) March 24, 2015
Interior March 26, 2015
American Rivers March 27, 2015
1.4.3 Comments on the License Application
On September 30, 2015, the Commission issued a notice that Mr. Ward's
application was ready for environmental analysis. This notice set November 29, 2015 as
a deadline for filing comments, recommendations, terms and conditions. The following
entities commented:
Commenting agencies
FWS
FWS
North Carolina WRC
Interior
North Carolina DWR
7
Date filed
November 12, 2015
November 17, 2015
November 18, 2015
November 20, 2015
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2.0 PROPOSED ACTION AND ALTERNATIVES
2.1 NO -ACTION ALTERNATIVE
Under the no -action alternative, the project would continue to operate under the
terms and conditions of the existing license, and no new environmental protection,
mitigation, or enhancement measures would be implemented. We use this alternative to
establish the baseline environmental conditions for comparison with other alternatives.
2.2 APPLICANT'S PROPOSAL
2.2.1 Project Description
The Ward Mill Project is located on the Watauga River in northwestern North
Carolina. The Ward Mill Project consists of the following facilities: (1) a 130 -foot -long,
20 -foot -high, rock and concrete dam; (2) an impoundment with a surface area of 4.6 acres
and an estimated gross storage capacity of 16.3 acre-feet; (3) a 14 -foot -long, 5 -foot -wide,
and 7.5 -foot -tall penstock made of rock, reinforced concrete and steel; (4) a 60 -foot -long,
20 -foot -wide powerhouse integrated into the south end of the dam, containing two
generating units with a total capacity of 168 kW; (5) interconnection with the utility, at
the meter point on the southwest, exterior wall of the powerhouse; and (6) appurtenant
facilities. The average annual energy production is about 374,403 MWh.
Mr. Ward proposes no additional capacity and no modifications to project
facilities.
2.2.2 Proposed Project Operation
Mr. Ward proposes to continue to operate the Ward Mill Project in a run -of -river
mode, whereby water flowing into the project impoundment equals water flowing out.
Instantaneous run -of -river mode may be temporarily modified if required by operating
emergencies beyond the control of the licensee, and for short periods upon mutual
agreement among the licensee and the resource agencies.
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Operation Compliance
To verify run -of -river operation, Mr. Ward proposes to continue to monitor flows
daily, continue to operate a float gage controlling an automatic cut-off switch on the
turbines so that generation would be taken off line when the water level drops below the
crest of the dam, and provide access to 15 -minute interval generation data.s Mr. Ward
also proposes to install and operate a flow gage to record inflow to the project if the
United States Geological Survey (USGS) discontinues operation of gage number
03479000.
Impoundment Drawdown and Refill Plan
Mr. Ward proposes to implement a drawdown and refill plan that would allow
water in the impoundment to be drawn down about 10 feet below the top of the dam
during any necessary maintenance or emergencies.6 Mr. Ward's plan includes provisions
to: (1) refill the impoundment when inflow to the impoundment is greater than or equal
to 60 cubic feet per second (cfs); (2) release a minimum of 60 cfs into the tailrace during
refill; (3); visually monitor water level and flow downstream of the dam at all times
during drawdown and refill; and (4) notify the Commission and resource agencies prior
to beginning a drawdown.
2.2.3 Project Safety
As part of the licensing process, the Commission would review the adequacy of
the existing project facilities. Special articles would be included in any license issued, as
appropriate. Commission staff would also inspect the project after any license is issued.
Operational inspections would focus on the continued safety of the structures,
identification of unauthorized modifications, efficiency and safety of operations,
5 Mr. Andy Givens (agent to Mr. Ward) stated, in a letter filed February 11, 2016,
that Mr. Ward has access to 15 -minute interval generation data from the utility that could
be used to show whether the project was generating during low flow events.
6 In a letter filed December 9, 2015, Mr. Ward states that dropping the water level
to about 10 feet below the top of the dam is adequate for most repair and maintenance
activities.
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compliance with the terms of the license, and proper maintenance. In addition, any
license issued would require an inspection and evaluation every 5 years by an
independent consultant and submittal of the consultant's safety report for Commission
review.
2.2.4 Proposed Environmental Measures
Mr. Ward, working with the consulted entities, has identified measures to protect
and enhance environmental resources of the project area. Mr. Ward proposes to operate
the Ward Mill Project with the environmental protection and enhancement measures
described below.
• Implement a sediment management plan with provisions to: (1) manage
sediment build-up if it occurs in the impoundment; (2) notify the
Commission and resource agencies if sediment accumulates and must be
removed; and (3) consult with the Commission and resource agencies to
identify steps necessary to remove sediment from the impoundment.
• Implement a an erosion control plan to prevent erosion of the
impoundment shoreline, with provisions to: (1) monitor the shoreline for
damage caused by floods or recreational activities along the shoreline; (2)
notify the Commission and the resource agencies if shoreline damage is
identified; and (3) consult with the Commission and the resource agencies
to identify steps necessary to protect the shoreline after damage is
identified.
• Continue to operate and maintain the existing recreation facilities at the
project, which include: (1) a canoe portage trail with put -in and take-out
7 Mr. Ward describes this plan as a shoreline management plan; however, because
this plan is primarily focused on erosion of the shoreline, we will refer to this plan as an
erosion control plan in all subsequent sections of the environmental analysis.
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areas; (2) a parking area in the vicinity of the dam and mill buildings; and
(3) informal bank -fishing areas along the full length of the impoundment .8
2.3 STAFF ALTERNATIVE
Under the staff alternative, the project would be maintained as proposed by
Mr. Ward, with the modifications and additional measures described below. However,
the staff alternative does not include Mr. Ward's proposal to implement an erosion
control plan, or Mr. Ward's proposal to install and operate a flow gage to record inflow to
the project if the USGS discontinues operation of gage number 03479000.
Our recommended modifications and additional environmental measures include,
or are based on, Mr. Ward's proposed measures and recommendations made by federal
and state resource agencies that have an interest in resources that may be affected by
operation of the proposed project.
• File a report if the float gage and cut-off system fails, or if the water level in
the impoundment drops below the crest of the dam.
• Implement impoundment drawdown and refill procedures for emergency and
maintenance drawdowns with provisions to: (1) conduct emergency and
maintenance drawdowns when inflow is greater than 60 cfs; (2) limit the
drawdown rate to 1 foot per day; (3) release inflow to the tailrace while the
impoundment is drawn down; (4) refill only when inflow is greater than 60 cfs;
(5) when refilling, release a minimum of 60 cfs in the tailrace; (6) establish a
low -flow rating curve of minimum flow releases during drawdowns; and
(7) notify the resource agencies and the Commission as soon as possible, but
no later than 10 days after each drawdown event.
8 Although Mr. Ward does not explicitly propose to continue operating and
maintaining the project's recreation facilities as a protection, mitigation, and
enhancement measure, based on the contents of the application, it seems Mr. Ward
intends to continue operating and maintaining these recreation facilities over the term of
any new license issued for the project.
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Cease project activities and notify the North Carolina SHPO if any unknown
archaeological or historic resources are discovered as a result of operation or
other project -related activities to avoid, lessen, or mitigate potential adverse
effects to unknown historic properties.
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3.0 ENVIRONMENTAL ANALYSIS
In this section, we present: (1) a general description of the project vicinity; (2) an
explanation of the scope of our cumulative effects analysis; and (3) our analysis of the
proposed action and other recommended environmental measures. Under each resource
area, historic and current conditions are first described. The existing conditions are the
baseline against which the environmental effects of the proposed action and alternatives
are compared, including an assessment of the effects of proposed mitigation, protection,
and enhancement measures, and any potential cumulative effects of the proposed action
and alternatives. Staff s conclusions and recommended measures are discussed in
section 5. 1, Comprehensive Development and Recommended Alternative of the DEA.9
3.1 General Description of the Area
The Watauga River Basin drains about 816 square miles. The river flows
northwest from North Carolina into Tennessee. In North Carolina, the basin drains about
205 square miles entirely within the Blue Ridge Physiographic Province (North Carolina
WRC, 2005). In Tennessee, the basin drains about 611 square miles within the Blue
Ridge and Valley and Ridge Physiographic Provinces in parts of Carter, Johnson,
Sullivan, Unicoi, and Washington Counties. The headwaters of the Watauga River, and
its major tributary, the Elk River, are at Sugar Mountain and Grandfather Mountain in
southwestern Watauga and eastern Avery counties, North Carolina. The Watauga River
flows about 77 miles before joining the South Fork Holston River near the Washington
and Sullivan county line in Tennessee. The Holston River flows into the Tennessee
River, which flows into the Ohio River, and subsequently the Mississippi River, and the
Gulf of Mexico.
Ward Mill Dam is the only dam along the North Carolina portion of the Watauga
River. Downstream of the project in Tennessee, there are two additional dams on the
Watauga River. The first dam is the Tennessee Valley Authority's Watauga Dam, which
9 Unless otherwise indicated, our information is taken from the application for
license filed by Mr. Ward on August 28, 2014, and the response to deficiencies and
requests for additional information filed on January 16, 2015 and August 31, 2015.
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is about 25 miles downstream from the Ward Mill Project, and creates the 6,430 acre
Watauga Lake. Nearly 28 miles below the Ward Mill Project, on the Horseshoe section
of the Watauga River, is the Tennessee Valley Authority's Wilbur Dam, which forms a
much smaller (72 acres), but very deep impoundment known as Wilbur Lake.
Land use in the basin is 87 percent forest and wetland, 13 percent pasture and
managed herbaceous cover, and less than 1 percent urban development (North Carolina
DENR, 2007). Most development and agricultural activities are located in the valleys
because of the abundance of steep slopes within the watershed. However, development
(primarily home construction) is rapidly increasing on steeper slopes. The majority of
land is privately owned with less than 10 percent of the area consisting of public lands
(i.e., Pisgah National Forest and the Blue Ridge Parkway) (North Carolina WRC, 2005).
3.2 Scope of Cumulative Effects Analysis
According to the Council on Environmental Quality's regulations for
implementing the National Environmental Policy Act, 40 C.F.R. § 1508.7, an action may
cause cumulative impacts on the environment if its impacts overlap in time and/or space
with the impacts of other past, present, and reasonably foreseeable future actions,
regardless of what agency or person undertakes such actions. Cumulative effects can
result from individually minor but collectively significant actions taking place over a
period of time, including hydropower and other land and water developmental activities.
Based on our review of the license application and agency and public comments,
we have not identified any resources that may be cumulatively affected by the proposed
operation and maintenance of the Ward Mill Project.
3.3 Proposed Action and Action Alternatives
Only resources that would be affected, or about which comments have been
received, are addressed in detail in this DEA and discussed in this section. We have not
identified any substantive issues related to wildlife resources, threatened and endangered
species, aesthetic resources, or socioeconomics associated with the proposed action;
therefore, we do not assess environmental effects on these resources in this DEA. We
present our recommendations in section 5. 1, Comprehensive Development and
Recommended Alternative section.
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3.3.1 Geological and Soil Resources
3.3.1.1 Affected Environment
The Ward Mill Project is located in the Blue Ridge Mountain Physiographic
Province (USDA, 2001). The topography of the area is characterized by high plateaus
surrounded by mountains rising up to 2,000 feet above the valleys. The southern edge of
Watauga County is on the Blue Ridge and Valley, which is a highly dissected landscape
with a repeating pattern of ridges and valleys that drain into the Piedmont. The landscape
in Watauga County varies from gently sloping to very steep on the uplands, and nearly
level and gently sloping along flood plains. Flood plains are wide along the Watauga
River, but are narrow along the smaller streams. The steep valley sides of the region are
underlain by Precambrian schists and gneisses, with Precambrian and lower Cambrian
metavolcanic and metasedimentary rocks forming many of the higher peaks (Gryta and
Bartholomew, 1983).
The soils of the Blue Ridge Mountain Physiographic Province are primarily
composed of Craggey, Dellwood, Unicoi, and Watauga series soils.10 Craggey soils are
composed of shallow, somewhat excessively -drained, loamy" soils on ridges and side
slopes at high elevations (4,800 feet and above). Dellwood soils consist of moderately
well drained, and moderate- to rapidly -permeable soils formed on flood plains. Dellwood
soils are primarily shallow and sandy material that is composed of more than 35 percent
by volume of gravel and cobbles. Unicoi soils are shallow and somewhat excessively
drained soils, with a brown loamy surface layer and subsoil, and are found on upland
ridges and side slopes. Watauga soils are very deep and well drained soils, with a brown
loamy surface layer and subsoil that contains many flakes of mica, and are found on
upland ridges and side slopes.
Narrow and fully -cleared riparian corridors along portions of the Watauga River
and many of its tributaries have contributed to excessive stream bank erosion, sediment
deposition, and over -widening of channels (North Carolina WRC, 2005). Impacts from
to See Soils of North Carolina available at: http://soilscience.info/soilsofnc/
southern -blue -ridge.
11 Loamy soils contain relatively equal amounts of sand, silt, and clay.
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row -crop agriculture and poor livestock pasture management (e.g., sedimentation from
runoff and stream bank erosion) are also significant. Stormwater run-off also has the
potential to contribute to sedimentation as development (e.g., vacation homes, golf
courses) increases in the area.
3.3.1.2 Environmental Effects
Mode of Operation
To minimize the fluctuation of the water surface in the impoundment and of the
flow and water surface in the tailrace, Mr. Ward proposes to continue to operate the
project in run -of -river mode. As mentioned above, North Carolina WRC's report
highlights a concern about bank erosion in portions of the Watauga River. Interior, North
Carolina WRC, and North Carolina DWR recommend that the project be operated as run -
of -river at all times, such that inflow to the project equals outflow, except for operating
emergencies beyond the control of the applicant (e.g., emergency and maintenance
drawdowns, which are discussed further below and in section 3.3.3.2, Fishery Resources,
Environmental Effects).
Our Analysis
While there were no comments to indicate that there were erosion issues at the
Ward Mill Project, fluctuations in impoundment levels and instream flows downstream of
hydropower projects have the potential to contribute to shoreline erosion and
sedimentation of instream aquatic habitat, and the geology of the region tends to foster
erodible soils on the stream and river banks. The extent of such effects can be strongly
influenced by the timing, magnitude, and frequency of the impoundment or instream flow
fluctuations. Continuing to operate the project in a run -of -river mode would limit water
level fluctuations in the impoundment and downstream of the project. Therefore, the
proposed project operation would continue to minimize the potential for shoreline
erosion, as well as the incidence of dewatering and flooding of riparian vegetation.
Maintenance Drawdowns and Refill
Impoundment drawdowns for routine maintenance have the potential to lead to
shoreline erosion along the impoundment and downstream from the project. Mr. Ward
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proposes to implement a drawdown and refill plan that includes: (1) lowering the water
level in the impoundment and refilling it in stages; 12 (2) a provision to refill the
impoundment when inflow to the project is greater than or equal to 60 cfs;13 (3) a
provision to release a minimum of 60 cfs into the tailrace during refill; (4) a provision to
visually monitor water level and flow downstream of the dam at all times during
drawdown and refill; and (5) a provision to notify the Commission and the resource
agencies prior to beginning a drawdown.
Interior recommends that Mr. Ward develop an impoundment drawdown and refill
plan in coordination with FWS, North Carolina WRC, and North Carolina DWR.
Similarly, North Carolina WRC and North Carolina DWR recommend that Mr. Ward
develop an impoundment drawdown and refill plan with North Carolina WRC, North
Carolina DWR, and other agencies prior to any actions to lower the impoundment level
substantially below the crest of the dam. Interior states that Mr. Ward should avoid
drawdown of the impoundment when the USGS gage number 03479000, located 200 feet
upstream of the impoundment, reads less than 60 cfs, in order to protect resources from
dewatering. Interior also states that refilling of the impoundment following maintenance
or emergency drawdowns should be conducted when inflows to the project are greater
than 60 cfs, in order to avoid adverse effects to tailrace water quality and flow. 14
Our Analysis
12 In a letter filed December 9, 2015, Mr. Ward states that the drawdown could be
completed in three stages that include: (1) opening the turbine wicket gates and allowing
water to flow through the turbines; (2) removing boards of the south gate to allow the
water to drop to approximately 10 feet below the top of the dam; and (3) opening the
north gate, which is at the base of the dam to lower or divert water.
13 We interpret Mr. Ward's proposal for refill procedures to mean that if flows
drop below 60 cfs while the impoundment is drawdown, then no refill would occur until
flow is at least 60 cfs.
14 We interpret Interior's recommendation for refill procedures to mean that if
flows drop below 60 cfs while the impoundment is drawdown, then no refill would occur
until flow is greater than 60 cfs.
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Project impoundments may need to be drawn down periodically for scheduled or
unscheduled maintenance, as well as emergencies beyond the control of the operator.
Mr. Ward proposes to implement a drawdown and refill plan that would allow water in
the impoundment to be drawn down about 10 feet below the top of the dam during any
necessary maintenance or emergencies. 15 If a drawdown occurs rapidly, saturated
streambank soils could become more susceptible to sloughing as the resistance of the
soils decrease upon dewatering. Although streambank erosion does not appear to be an
issue at the project, sloughing of streambank soils is known to cause areas of streambank
erosion. Limiting the drawdown rate of the impoundment to 1 foot per day would
minimize the potential for streambank sloughing by allowing streambank soils to dewater
slowly, thereby increasing the shear resistance of the soils by providing an opportunity
for exposed areas to dry prior to further impoundment drawdown. 16 Therefore, the
development of a drawdown and refill management plan with a provision to limit the
drawdown rate of the impoundment to 1 foot per day would protect the project's
shoreline (including established native vegetation) from erosion associated with
maintenance or emergency drawdowns. 17
Sediment Management
Mr. Ward proposes to implement a sediment management plan to: (1) manage
sediment build-up if it occurs in the impoundment; (2) notify the Commission and the
resource agencies if sediment accumulates and must be removed; and (3) consult with the
Commission and the resource agencies to identify steps necessary to remove sediment
from the impoundment.
15 In a letter filed December 9, 2015, Mr. Ward states that dropping the water level
to about 10 feet below the top of the dam is adequate for most repair and maintenance
activities.
16 Mr. Ward did not propose and the agencies did not recommend a drawdown
rate.
17 The analysis of applicant proposed and agency recommended provisions of a
drawdown and refill plan is discussed further in section 3.3.2, Water Resources and
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Interior, North Carolina WRC, and North Carolina DWR recommend that
Mr. Ward develop a sediment management plan in consultation with resource agencies,
prior to any actions that involve opening the sand gates, dredging sediment from the
impoundment, or releasing sediment from the impoundment. Interior recommends that
the plan include provisions for: (1) monitoring; (2) developing a schedule; (3) removal of
sediment from the impoundment if build-up occurs; and (4) requiring approval of the
resource agencies prior to opening the sand gates.
Our Analysis
If sediment build-up were to occur behind the project dam, sediment could be
released accidentally during scheduled or unscheduled maintenance activities, such as
opening the sand gates, dredging sediment, or scouring of sediment from the
impoundment. High loads of suspended sediment can increase turbidity in riverine
habitats leading to reduced light penetration and decreased primary productivity (i.e.,
plant and algae growth), which then can lead to adverse effects to the rest of the food
chain. Sedimentation can also modify the substrate surfaces and morphology of a stream
channel, reducing habitat availability and smothering and killing aquatic flora and fauna
(Wood and Armitage, 1997).
However, there has not been any sustained build-up of sediment in the project
impoundment during the last 30 years, possibly because of periodic floods that wash
sediments from the impoundment (Ward, 2014). Based on the lack of sediment build-up
that has occurred in the impoundment under the current license, there does not appear to
be an existing issue with sediment build-up, and there is no indication that sediment
build-up is likely to occur in the future.
Shoreline Monitoring and Maintenance
Currently, vegetation along the project impoundment is dense, the shoreline
remains stable during floods and periods of high water, and no erosion issues are known
to exist.
To prevent any future erosion of the impoundment shoreline, Mr. Ward proposes
to implement a plan with provisions to: (1) monitor the shoreline for damage caused by
floods or recreational activities occurring along the shoreline; (2) notify the Commission
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and the resource agencies if shoreline damage is identified; and (3) consult with the
Commission and the resource agencies to identify steps necessary to protect the shoreline
if damage is identified.
Interior recommends that Mr. Ward develop an erosion control plan 18 in
consultation with the resource agencies. Interior recommends that the plan include: (1) a
monitoring schedule; (2) a time frame for stabilization efforts; (3) a provision to stabilize
any disturbed or eroding areas with straw within 48 hours; and (4) a provision for
monitoring and managing invasive exotic species within the project's boundary.
Our Analysis
As discussed above, shoreline erosion is unlikely to occur during normal run -of
river operations. However, during emergency or maintenance drawdowns, shoreline
erosion has the potential to occur if drawdowns occur rapidly. Also, as discussed above,
limiting the drawdown rate of the project impoundment to I foot per day would help to
minimize the potential for streambank sloughing and impacts to native riparian
vegetation within the project impoundment, and would be sufficient mitigation to protect
against future areas of shoreline erosion from developing within the project
impoundment. Further, as discussed above, erosion of shoreline areas, and sediment
mobilization would continue to be minimized during normal run -of -river operations, and
native riparian vegetation along the shoreline would be maintained. Therefore,
developing an erosion control plan, as proposed by Mr. Ward and recommended by
Interior19 would be unnecessary.
18 Because the shoreline management plan recommended by Interior is primarily
focused on erosion of the shoreline, we will refer to this plan as an erosion control plan in
all subsequent sections of the environmental analysis.
19 Interior's recommended plan to prevent erosion of the impoundment shoreline
included a provision for a monitoring and management plan for invasive exotic species
within the project boundary. This provision is discussed further in section 3.3.4,
Terrestrial Resources.
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3.3.2 Water Resources
3.3.2.1 Affected Environment
Water Quantity
The project impoundment has a surface area of about 4.6 acres, with an estimated
gross storage capacity of 16.3 acre-feet. The impoundment is about 2,500 feet long, and
extends from just downstream of the Rominger Road bridge to the project dam. The
width of the impoundment is about 100 feet for most of its length, but widens to 130 feet
near the dam. The impoundment drainage area is 92.6 square miles, and the estimated
mean annual daily flow (MADF) at the project is 174 cfs.20
Flows at the project are highest during winter and spring, and lowest during the
summer and early fall (table 1).
In August 2012, during low flow conditions (i.e., inflow to the project was 42 to
45 cfs; 87 to 88 percent exceedance flows), Cantrell et al. (2014) conducted a
demonstration impoundment drawdown and refill study at the project to evaluate river
stage and water quality (discussed below) in the impoundment and tailrace. During the
drawdown (two generators operating), which lasted 2 hours, water depth in impoundment
dropped about 3 feet, and water depth in the tailrace increased about 0.7 feet.
Impoundment refill (one generator operating) lasted about 20 hours, during which water
depth in the impoundment increased by about 3 feet and water depth in the tailrace
decreased by about 0.7 feet.
20 This MADF is based on data collected from January 1, 1993 through December
31, 2014 at USGS gage No. 03479000, located on the Watauga River near Sugar Grove,
NC.
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Table 1.
Monthly flow data (cfs) for the Ward Mill Project from USGS gage number
03479000 Watauga River near Sugar Grove, North Carolina (USGS, 2015, as
modified by staff).
90 Percent
75 Percent
25 Percent
10 Percent
Month
Min
Mean
Max
Exceedance
Exceedance
Exceedance
Exceedance
Jan
30
75
107
264
249
405
10300
Feb
50
90
125
222
240
380
2660
Mar
77
119
143
279
287
481
3330
Apr
65
100
129
238
264
406
3260
May
40
68
95
174
189
272
5270
Jun
27
50
67
134
161
249
931
Jul
25
42
57
143
119
220
3810
Aug
15
27
39
109
115
192
6950
Sep
8
23
36
127
88
175
8970
Oct
15
27
37
94
92
165
5460
Nov
25
32
44
142
147
246
6220
Dec
28
52
77
167
201
293
1620
Note: Period of Record is January 1, 1993 through December 31, 2014. The gage is
located about 200 feet upstream of the project impoundment.
Water Quality
North Carolina DWQ designates the Watauga River waters at the project as
freshwaters protected for primary recreation,21 secondary recreation,22 fishing, aquatic
21 Primary recreation includes swimming on a frequent or organized basis.
22 Secondary recreation includes wading, boating, and other uses involving body
contact with water where such activities take place in an infrequent, unorganized, or
incidental manner.
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life (including propagation and survival), and wildlife. Waters at the project are also
protected for natural trout propagation and survival of trout (i.e., designated Trout
Waters, which have specific water quality standards described in table 2). Waters at the
project are also considered high quality waters, which are waters that are rated excellent
based on biological, physical, and chemical characteristics. State water quality standards
that would be applicable to project waters are described in table 2.
Table 2. North Carolina water quality standards relevant to the Ward Mill Project
(North Carolina DWQ, 2007).
Parameter North Carolina Water Quality Standard
Temperature Not to exceed 2.8 °C (5.04 °F) above the natural water temperature.
Not to exceed 29 °C (84.2 °F) for mountain and upper piedmont
waters.
Trout Watersa: Not to be increased by more than 0.5 °C (0.9 °F)
and in no case exceed 20 °C (68 °F) due to discharge of heated
liquids.
Dissolved Oxygen Trout Waters: Not less than 6.0 mg/L daily
pH 6.0-9.0
Turbidity Not to exceed 10 NTUs in trout waters.
Phosphorus N/A
Nitrogen N/A
Chlorophyll a Not greater than 40 µg/L
Note: N/A — not applicable; µg/L — micrograms per liter; mg/L — milligrams per
liter; NTU — nephelometric turbidity units.
a The water quality standards for trout waters impose more restrictive limits on
wastewater discharges (North Carolina DENR, 2007).
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In the Watauga River Basin and in the Watauga River itself, water quality is
considered good to excellent based on benthic macroinvertebrate bioclassification.23 In
the Watauga River, water quality is good to fair based on fish bioclassification.24 The
primary water quality issue in the basin is nonpoint source runoff (i.e., sediments and
nutrients).
Throughout the basin, there is evidence of increased development activities,
resulting in narrow riparian corridors, sediment, and periphyton25 growth along the
river's edge. Periphyton growth can be an indication of nutrient enrichment from both
point and nonpoint sources (North Carolina DENR, 2007). Waters near the project (i.e.,
monitoring site near Sugar Grove) receive runoff form several forested, agricultural, and
residential areas, as well as discharge from several waste water treatment facilities. The
velocity of the river is also slower at this section of the river, and fine sediments tend to
settle on the bottom near the streambanks.
23 Benthic macroinvertebrate bioclassification is a tool used to detect water quality
degradation, and is based on taxa present in pollution intolerant aquatic insect groups
(e.g., Ephemeroptera, Plecoptera, and Trichopertera [EPT]) and the Biotic Index, which
summarizes tolerance data for all taxa. Waters with excellent or good water quality
based on benthic macroinvertebrate bioclassification contain diverse, stable, and
pollution -sensitive communities of aquatic macroinvertebrates
(http://portal.ncdenr.org/web/wq/ess/bau).
24 Fish bioclassification is based on the North Carolina Index of Biotic Integrity,
which is a method for assessing a stream's biological integrity by examining the structure
and health of its fish community. A fish community rated excellent is comparable to the
best situations with minimal human disturbance; all regionally expected species for the
habitat and stream size, including the most intolerant forms, are present along with a full
array of size classes and a balanced trophic structure. Conversely, a fish community
rated poor deviates greatly from the reference condition. The number of fish is fewer
than expected, usually fewer than expected number of species, an absence of intolerant
species, and an altered trophic structure. Communities rated good, good -fair, or fair fall
within this disturbance gradient (North Carolina DENR, 2013).
25 Biota (usually a mixture of algae and bacteria) and detritus that attaches to
submersed surfaces in aquatic ecosystems.
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Cantrell et al. (2014) continuously monitored water temperature in the project
impoundment from February 2012 to January 2013, and demonstrated that water
temperature was always below the state standard of 84.2°F, and never above about
78.8°F. Cantrell et al. (2014) also measured water temperature and DO during the low
flow demonstration impoundment drawdown and refill study discussed above.
Immediately prior to the 33 -hour demonstration, under normal run -of -river operations,
the water temperature in both the impoundment and tailrace was about 71.6°F and the
DO was between 6.8 mg/L and about 8.9 mg/L. During the demonstration, flows were
between 42 to 45 cfs and water temperatures averaged 70.7°F and 74.1°F in the
impoundment and tailrace, respectively. Average DO levels were 5.78 mg/L and 7.35
mg/L in the impoundment and tailrace, respectively. After the impoundment was drawn
down to 4 feet below the crest of the dam, the water temperature increased by 5.4°F to
77°F in the impoundment and the tailrace and the DO remained relatively high, near 7.0
mg/L and 7.5 mg/L, respectively. During impoundment refill, which occurred at night,
impoundment water temperature dropped back to about 71.6°F. The impoundment DO
dropped to a low of about 3.85 mg/L, but returned to 6.0 to 6.2 mg/L by the time the
impoundment was completely refilled. The tailrace water temperature dropped to 71.6°F,
and the DO declined to a low of 6.29 mg/L, but then increased to about 8.0 mg/L
following full refill.
3.3.2.2 Environmental Effects
Mode of Operation
Operation of a hydropower project can cause fluctuations in impoundment levels
that can contribute to shoreline erosion, increase turbidity, and thereby decrease water
quality. Some modes of project operation also have the potential to reduce flows
downstream of a project, which can lead to increases in water temperature and decreases
in DO.
Mr. Ward's proposed run -of -river operation and the agency recommended run -of -
river operation were previously described in section 3.3.1, Geological and Soil
Resources.
Our Analysis
Operating the project in a run -of -river mode would minimize the time water is
retained behind the dam and would minimize increases in water temperature within the
upper levels of the impoundment from solar heating. Run -of -river operation would
reduce the potential for increases in turbidity and sedimentation of the river bottom
associated with unnatural fluctuations in flow (as discussed in section 3.3.1, Geological
and Soil Resources). Sedimentation associated with unnatural fluctuations can negatively
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impact aquatic organisms, by altering habitat suitability, reducing oxygen uptake, and
reducing the density and nutritional value of food (Harrison et al., 2007).
Run -of -river operation would also maintain the water temperature and DO
conditions that exist at the project and are quite good. As discussed above in section
3.3.2.1, Water Resources, Affected Environment, water temperature was maintained
below the 84.2°F standard during continuous monitoring from February 2012 to January
2013. In addition, during the normal run -of -river operations that occurred prior to the
demonstration drawdown, water temperature remained below the 84.2°F standard and
DO stayed above the 6.0 mg/L standard in both the impoundment and tailrace. Thus,
continuing to operate the project in a run -of -river mode would not negatively affect water
quality, even when flows are very low.
Maintenance Drawdowns and Refill
The project impoundment may need to be drawn down periodically for
maintenance, as well as for operating emergencies beyond the control of the licensee.
During these times, run -of -river operation would be temporarily interrupted, and water
levels in the impoundment would be reduced, with potential negative effects on water
quality in the impoundment and tailrace, such as decreased DO and increased water
temperature. Low DO and high water temperature can cause physiological stress in
aquatic organisms.
Mr. Ward's proposed measures and the agency recommended measures for
maintenance and emergency drawdowns were previously described in section 3.3.1,
Geological and Soil Resources.
To protect against the negative effects that emergency and maintenance
drawdowns and refills can have on aquatic resources and water quality, Mr. Ward
proposes a drawdown and refill plan that would include provisions to refill the
impoundment when inflow to the project is greater than or equal to 60 cfs, and release a
minimum of 60 cfs into the tailrace during refill. Mr. Ward does not propose any
provisions during drawdown.
Interior recommends a plan for drawdown and refill. Like Mr. Ward, Interior
recommends refill when inflow to the project is greater than 60 cfs. Interior also
recommends that drawdowns occur only when inflow is greater than or equal to 60 cfs.
Our Analysis
Cantrell et al. (2014) demonstrated that water quality was generally good in the
project impoundment and tailrace during a demonstration drawdown and refill study
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(study) conducted under very low flows. In the tailrace, DO did not decline below the
state standard 6.0 mg/L and water temperature did not exceed the state standard 84.2°F,
including during refill when no flow (other than leakage) was released to the tailrace.
Although there was no evidence of water quality degradation in the tailrace during the
study, if sufficient flows are not released to the tailrace during an actual26 impoundment
refill, DO could decline due to biological consumption of oxygen without replenishment
from upstream aeration, and temperature could increase due to stagnation and solar
heating in the tailrace.
To protect water quality and aquatic resources downstream of the dam during
refill, Mr. Ward proposes to release a minimum of 60 cfs in the tailrace during refill.
Although the study conducted by Cantrell et al. (2014) did not include minimum flow
releases during refill, the study did show that during low flow conditions (of 42 cfs to 45
cfs), when the project was operated in run -of -river mode (i.e. prior to and following the
drawdown and refill observed during their study), water temperature and DO in the
tailrace met the state standards. A flow of 60 cfs is 33 percent to 43 percent greater flow
than received in the tailrace during the low flow, run -of -river conditions observed by
Cantrell et al. (2014). Based on this information, as well as the lack of water quality
degradation when no flow was being released to the tailrace (other than leakage) during
the refill portion of the study, a minimum flow of 60 cfs in the tailrace would be
protective of water quality in the tailrace.
In order to release 60 cfs into the tailrace during refill and still allow the
impoundment to fill -up, inflows to the project would need to be greater than 60 cfs.
Therefore, Interior's recommendation to conduct refills when inflow is greater than 60
cfs would be necessary to allow Mr. Ward to protect water quality by releasing a
minimum flow of 60 cfs into the tailrace and still allow the impoundment to refill.
26 During the study, water in the impoundment only dropped 4 feet below the crest
of the dam. Actual maintenance drawdowns may require water to drop 10 feet below the
crest of the dam, and thus the study might not be indicative of water quality conditions
during a full maintenance drawdown. There would be a reduced volume of water in the
impoundment under a 10 foot drawdown and a longer refill time, which could result in
more degraded water quality than reflected in the demonstration study.
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Although a requirement to begin a refill only when inflow is greater than 60 cfs
would allow for protection of the water quality in the tailrace, as discussed above, it
could also result in the impoundment remaining in a drawn down state for an extended
period, if a drawdown event begins when inflow is not greater than 60 cfs. If the
impoundment is in a drawn down state for an extended period, water temperature could
increase and DO could decrease in the dewatered impoundment. As shown by Cantrell et
al. (2014) during the study, when the impoundment was being drawdown, DO began
declining, but remained above 6.0 mg/L in the impoundment and tailrace. During the
impoundment refill, DO in the impoundment continued to decline, and eventually
dropped below the state standard of 6.0 mg/L (but never less than 3.85 mg/L) for about
18 hours before returning to 6.0 mg/L or greater after the impoundment was refilled.
Thus, under an extended drawdown scenario, water quality could degrade in the project
impoundment. To reduce the probability of extended drawdown events occurring,
impoundment drawdowns would need to begin when inflow to the project is greater than
60 cfs. A requirement to only begin impoundment drawdowns when inflow is 60 cfs or
greater would increase the probability that flows would be at or above 60 cfs when
maintenance is complete, allowing refill to occur quickly, and preventing the
impoundment from being drawn down for an extended period. 27
As discussed in section 3.3.1, Geological and Soil Resources, if a drawdown
occurs rapidly, saturated streambank soils could become more susceptible to sloughing.
Although streambank erosion does not appear to be an issue at the project, sloughing of
streambank soils is known to cause areas of streambank erosion, which could lead to
suspension of sediments in the water column and increased turbidity at the project.
Increased turbidity could lead to reduced light penetration, which can affect the ability of
visual organisms like fish to find food. Limiting the drawdown rate of the impoundment
to 1 foot per day would minimize the potential for streambank sloughing, and the
potential for sediment suspension and increased turbidity.
27 Interior recommends that Mr. Ward only begin drawing the impoundment down
when inflows are greater than or equal to 60 cfs. However, if an impoundment
drawdown begins when inflow is 60 cfs and remain at 60 cfs when maintenance is
complete, then a refill could not occur, if a minimum flow of 60 cfs is needed in the
tailrace. Requiring Mr. Ward to only begin drawing the impoundment down when
inflows are greater than 60 cfs would slightly decrease the probability of delaying an
impoundment refill after maintenance is complete.

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Finally, to ensure that a minimum flow of 60 cfs would be released into the
tailrace after the impoundment is drawn down and during impoundment refill, a
mechanism is needed to estimate the minimum flow release from the project. For this
purpose, a low -flow rating curve 28
would be developed to capture the river stage at 60 cfs
downstream of the project dam. The rating curve would be used to ensure that a
minimum of 60 cfs is being released to the tailrace after the impoundment is drawn down
and during impoundment refill.
Based on our analysis above, the procedures for impoundment drawdown and
refill would be most protective of aquatic resources if they included measures to: (1)
conduct emergency and maintenance drawdowns when inflow is greater than 60 cfs; (2)
limit the drawdown rate to 1 foot per day; (3) release inflow to the tailrace while the
impoundment is drawn down; (4) refill only when inflow is greater than 60 cfs; (5) when
refilling, release a minimum of 60 cfs in the tailrace; (6) establish a low -flow rating curve
of minimum flow releases during drawdowns; and (7) notify the resource agencies and
the Commission as soon as possible, but no later than 10 days after each drawdown
event. These measures would help to ensure adequate protection of aquatic resources,
including special status aquatic species such as the green floater mussel and eastern
hellbender salamander (discussed below in section 3.3.3, Fishery Resources).
3.3.3 Fishery Resources
3.3.3.1 Affected Environment
Fisheries Resources
The 4.6 -acre impoundment is about 100 -feet -wide along most of its length, and
extends about 2,500 feet upstream of the dam. The impoundment is mostly riverine in
nature and surrounded by wooded hillsides along the north shoreline, and mostly non -
woody vegetation, such as grasses and herbs, along the south shoreline. At the upstream
end of the impoundment, substrates are predominantly gravel (65.1 percent), sand (15.5
28 A rating curve provides the relationship between river stage and river discharge.
Once established at a site, the curve can be used to estimate river discharge by measuring
river stage. A low -flow rating curve for this project would only need to capture the
relationship between river stage and discharge at low -flows just above and below 60 cfs.
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percent), and bedrock (11.2 percent), and during a summer 2013 survey, water depth
averaged 2 -feet -deep (Gangloff, 2013).
Substrates immediately downstream from the dam are mostly large boulders and
cobbles. About 328 feet downstream from the dam, substrates become more
heterogeneous and predominantly gravel (70.6 percent), sand (13.4 percent), and bedrock
(13.4 percent) (Gangloff, 2013). During summer 2013, water depths downstream from
the dam averaged 2.3 -feet -deep between 0 and 492 feet downstream from the dam, and
1.6 -feet -deep between 1,969 and 2,461 feet downstream from the dam (Gangloff, 2013).
To characterize the fisheries resources within the Ward Mill Project area, Gangloff
(2013) conducted an initial survey upstream and downstream of the dam between
June 6 and August 7, 2013, and an additional supplemental survey exclusively in the
impoundment on October 31, 2013. During the initial survey, two sites were sampled
upstream of the dam (1,312-1,804 feet upstream and 4.6 miles upstream) and two sites
were sampled downstream from the dam (0-492 feet downstream and 1,969-2,461 feet
downstream). During the initial survey, 16 freshwater fish species in 6 families were
collected (table 3). The highest number of species occurred 4.6 miles upstream of the
dam (14), but similar numbers of species occurred at the other three locations (11-12)
(table 3). During the supplemental survey, five species were collected in the
impoundment. No state or federally listed fish species, or fish species of concern were
collected during the surveys.
WE

Table 3. Fish species and number collected in the vicinity of the Ward Mill Project during initial surveys conducted
between June 6 and August 7, 2013, and a supplemental survey conducted in the impoundment on October 31,
2013. (Source: Ward, 2014; supplemental data filed August 31, 2015)
Sampling location
Family/Common
0 - 492 feet
1,969 - 2,461
1,312 - 1,804
4.6 miles
Species
downstream
feet downstream Impoundment feet upstream of
upstream
name
from dam
from dam
dam
of dam
totals
Catostomidae
Northern hogsucker
3
2
0
1
7
13
Blacktail redhorse
1
0
0
0
0
1
Centrarchidae
Rock bass
19
23
4
24
11
81
Redbreast sunfish
15
4
4
7
14
44
Smallmouth bass
6
4
0
4
2
16
Cyprinidae
Central stoneroller
3
0
0
3
28
34
Whitetail shiner
3
4
0
4
15
26
Warpaint shiner
4
4
1
9
River chub
7
5
5
41
3
61
Tennessee shiner
9
9
0
26
19
63
Creek chub
0
0
0
0
1
1
31

Sampling location
Family/Common 0 - 492 feet 1,969 - 2,461 1,312 - 1,804 4.6 miles Species
name downstream feet downstream Impoundment feet upstream of upstream totals
from dam from dam dam of dam
Ictaluridae
Margined madtom
12
24
1
16
12
65
Percidae
Greenfin darter
7
5
0
7
7
26
Tangerine darter
1
1
0
0
0
2
Salmonidae
Rainbow trout
0
1
0
0
1
2
Brown trout
0
0
0
1
2
3
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Special Status Aquatic Species
Green floater mussel (Lasmigona subviridis) is currently under review for federal
listing and is a North Carolina State Endangered Species. Recently, the species has been
found less frequently and in lower numbers than in the past, with many documented
extirpations throughout its range, which extends from North Carolina to the Hudson
River in New York (North Carolina WRC, 2014). The species typically inhabits streams,
small rivers, and canals of low to medium gradient with slow pools and eddies, fine
gravel, and sand bottom (Ortmann, 1919). The species is a bradytictic brooder ,29 with the
reproductive season extending from August, when spawning occurs, to May when
glochidia 30 are released (Ortmann, 1919). Host fish have not been determined for the
green floater; however, there is documentation for direct transformation of glochidia into
juvenile mussels (Barfield and Watters 1998, Lellis and King 1998). Although many
mussel species require fish hosts for glochidial dispersal and transformation to the
juvenile stage, there is evidence that juveniles can metamorphose within the gills of the
adult female and without a host (Barfield and Watters, 1998; Lellis and King, 1998).
Eastern hellbender salamander is a North Carolina State Special Concern Species
(North Carolina WRC, 2014). The species has healthy populations in some eastern
portions of its range (e.g., West Virginia, Tennessee), but has declined substantially in
western regions (e.g., Missouri) (Mathis and Crane, 2009). Threats to eastern hellbenders
are not thoroughly understood, but likely include habitat alterations (i.e., siltation, water
impoundment, and changes in water quality), and potentially limited recruitment,
predation by exotic species (e.g., rainbow trout), and low genetic variability (Mayasich et
al., 2003, Mathis and Crane, 2009). The species typically inhabits swift running, fairly
shallow, highly oxygenated waters. The presence of riffles with flat rocks, logs, and
other cover is essential for feeding and breeding activities (Mayasich et al., 2003).
Eastern hellbenders generally have a short breeding season that occurs from mid- or late -
August through mid-September (Mayasich et al., 2003).
29 Bradytictic mussel brooders spawn late in the year, their embryos and glochidia
overwinter in the marsupia, and larvae are released in the spring (Cummings and Graf,
2010).
30 Glochidia are mussel larvae.
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Eastern Hellbender Salamander
Gangloff (2013) surveyed for the eastern hellbender salamander, a North Carolina
State Special Concern Species, during summer 2013 at the same sites surveyed for
fishery resources. No eastern hellbender salamanders were observed; however, anecdotal
reports from anglers suggest that the species is occasionally seen near the dam, and thus
the species may be present near the project in low numbers.
Freshwater Mussels
Gangloff (2013) also surveyed for mussels during summer 2013 at the same sites
surveyed for fishery resources. At the site located between 1,929 and 2,461 feet
downstream from the dam, the survey yielded relict shell fragments from two green
floater mussels (Lasmigona subviridis), which is currently under review for federal listing
and is a North Carolina State Endangered Species. No live green floater mussels were
encountered, and no other mussel species were documented during the survey. However,
the species may be present in low numbers near the project (Ward, 2014).
3.3.3.2 Environmental Effects
Mode of Operation
Mr. Ward's proposed run -of -river operation and the agency recommended run -of -
river operation were previously described in section 3.3.1, Geological and Soil
Resources.
Our Analysis
Operating the project in a run -of -river mode would minimize water level
fluctuations in the impoundment and downstream, and would maintain downstream flow
conditions for aquatic life, including during natural low -flow and drought periods.
Maintaining run -of -river flows would reduce the potential for fish and
macroinvertebrate stranding within the impoundment, which is often a consequence of
unnatural water level fluctuations. Run -of -river operations would also minimize water
level and flow disruption to any spawning and rearing habitat that might exist both within
the project impoundment and in the reach downstream from the project. Maintaining
relatively stable impoundment levels would also benefit fish and other aquatic organisms
that rely on near -shore habitat for feeding, spawning, and cover. By operating the project
in a run -of -river mode, habitat in the project impoundment and habitat in the Watauga
River downstream of the tailrace would be unchanged compared to current conditions.
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Aquatic organisms, including fish and benthic macroinvertebrates, would be unaffected
by continued run -of -river operations.
Operation Compliance Monitoring
To verify run -of -river operation, Mr. Ward proposes to continue to monitor flows
daily, visually evaluating water levels in the impoundment relative to the height of the
project dam daily, continue to operate a float gage controlling an automatic cut-off switch
on the turbines so that generation would be taken off line when the water level drops
below the crest of the dam, and provide access to 15 -minute interval generation data. Mr.
Ward also proposes to continue to implement the provision of the amended Article 6 of
the 1986 license order, which would require Mr. Ward to file a plan to gage inflow to the
project impoundment, within 3 months, should the USGS cease stream flow monitoring
at gage number 03479000.
North Carolina WRC and North Carolina DWR recommend that if the
impoundment level drops below the crest of the dam, the turbines be stopped so that
water can immediately spill over the dam .31 North Carolina WRC and North Carolina
DWR also recommend that records of inflow and outflow be maintained to verify run -of -
river operation and to document maintenance and emergency drawdowns. 32 Specifically,
North Carolina WRC and North Carolina DWR recommend that Mr. Ward: (1) install a
stream gage to record inflow, if the USGS gage number 03479000 is no longer
maintained; (2) maintain records of impoundment stage and project generation; and
(3) make records of impoundment stage and project generation available to resource
agencies.
31 We consider North Carolina WRC and North Carolina DWR's recommendation
to shut -down the turbines when the water level drops below the crest of the dam to be the
same as Mr. Ward's proposal to continue to operate a float gage controlling an automatic
cut-off switch on the turbines so that generation would be taken off line when the water
level drops below the crest of the dam.
32 North Carolina WRC and North Carolina DWR do not specify what should be
documented, but for the purposes of our analysis, staff assumes that the occurrence,
timing, and duration of maintenance and emergency drawdowns should be documented.
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Our Analysis
Given the small size of the project impoundment (4.6 acres) and its small storage
capacity (16.3 acre-feet), the project has limited ability to store water. To maintain
compliance with run -of -river operation, Mr. Ward proposes to continue to use the float
gage and automatic cut-off system. Although the cut-off system does not document
compliance with run -of -river operation, it does ensure that the project could not function
in any operational mode other than run -of -river, when the cut-off system is operating
properly.
Mr. Ward also proposes to monitor flows daily, by visually evaluating water levels
in the impoundment relative to the height of the project dam. By visually monitoring
water levels in the impoundment, Mr. Ward would be able to verify whether the float
gage and automatic cut-off switch are operating properly, and thereby ensure the project
is operating in run -of -river mode.
Using the project generation data in 15 -minute intervals, Mr. Ward could provide
documentation of when the project is generating, which could be used to determine
whether the project is operating in a mode other than run -of -river (i.e., as a peaking
project).
Regarding North Carolina WRC and North Carolina DWR recommendation that
Mr. Ward maintain records of inflow and outflow to ensure run -of -river operation and to
document maintenance and emergency drawdowns, records of inflow to the project are
currently available at USGS gage number 03479000, but no records of outflow are
currently available at the project. Outflow measurements would require the installation
of a flow gage downstream of the project. North Carolina WRC and North Carolina
DWR also recommend that Mr. Ward maintain records of impoundment stage.
Recording impoundment stage (or water level) at the project could be accomplished by
installing a water level data logger or pressure transducer within the project
impoundment.
Although maintaining records of inflow and outflow data, or impoundment stage
could be used to monitor compliance with run -of -river conditions, the installation of flow
gages (including replacement of USGS gage number 0347900 if USGS ceases
monitoring upstream of the project), or water level data loggers is unnecessary given the
availability of other less sophisticated, yet equally effective, options for ensuring that run -
of -river operations are maintained at the Ward Mill Project. As discussed above, the
project cannot be operated in any other mode. Also, a float gage and automatic cut-off
switch would ensure that the project could not function in any operational mode other
than run -of -river. Further, requiring Mr. Ward to report when the cut-off system fails, or
when the water level in the impoundment drops below the crest of the dam, would ensure
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that the Commission and stakeholders would be notified and could react to any deviation
from run -of -river operation.
Maintenance Drawdown and Refill
Periodically, the project impoundment may need to be drawn down for
maintenance or emergencies. During these times, run -of -river operation would be
temporarily interrupted, and water levels in the impoundment would be reduced, with
potential negative effects on aquatic biota. Refilling the impoundment following a
drawdown could disrupt flows downstream of the project and affect water quality and
aquatic habitat.
Mr. Ward's proposed measures and the agency recommended measures for
maintenance and emergency drawdowns were previously described in section 3.3.1,
Geological and Soil Resources.
To protect against the negative effects that emergency and maintenance
drawdowns and refills can have on aquatic resources and water quality, Mr. Ward
proposes a drawdown and refill plan that would include provisions to refill the
impoundment when inflow to the project is greater than or equal to 60 cfs, and release a
minimum of 60 cfs into the tailrace during refill. Mr. Ward does not propose any
provisions that would restrict when a drawdown could occur.
Interior recommends a plan for drawdown and refill. Like Mr. Ward, Interior
recommends refill when inflow to the project is greater than 60 cfs. Interior also
recommends that drawdowns occur only when inflow is greater than or equal to 60 cfs.
Our Analysis
Under the proposed drawdown and refill plan, which would involve drawdowns of
up to 10 feet for maintenance or emergencies, dewatering of a large portion of the littoral
areas of the project impoundment would occur. The dewatering that occurs during a
drawdown also has the potential to strand and isolate aquatic organisms within the littoral
areas of the project impoundment, which could expose aquatic organisms to greater
predation risks and degraded water quality (e.g., high water temperatures and low DO
concentrations). Drawing down the project impoundment also has the potential to rapidly
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increase flows downstream of the project, which could flush aquatic organisms from their
respective habitats. Limiting the drawdown rate to 1 foot per day33 would reduce the
likelihood of aquatic organisms becoming stranded in the impoundment, and flushed
downstream from habitats in the tailrace.
During an impoundment refill that follows a drawdown and maintenance
activities, flows downstream of the project dam could be reduced if insufficient flows are
released downstream. Reduced flows and dewatering, reduces the volume of habitat
available, and could lead to increased water temperature and decreased DO (section 3.3.2,
Water Resources). While most adult fish successfully move to more suitable habitats
when flow decreases, many juvenile fish and macroinvertebrates are not as mobile, and
could even become stranded in off -channel habitats. These isolated off -channel habitats
often expose fish to greater predation risk, lower DO, and higher water temperature,
which can lead to stranding mortality (Nagrodski et al., 2012). Even if aquatic biota do
not become stranded, both fish and macroinvertebrates are more likely to be preyed on or
stressed by the increased water temperatures and decreased DO levels that could occur
during lower flow, especially in the summer.
Maintaining sufficient flow downstream of the project during project maintenance
activities (i.e., when the impoundment is in a drawn down state) and impoundment refill
would help protect aquatic biota. Mr. Ward proposes to release a minimum of 60 cfs in
the tailrace during refill. A minimum flow of 60 cfs represents 34 percent of MADF (175
cfs) at the project during the period from 1993 to 2015. According to the Tennant
method 34 of assessing the suitability of flows for fish, 34 percent of MADF would
provide between excellent and outstanding conditions during the dry season (i.e.,
summer, early fall) and between fair and good conditions during the wet season (i.e.,
33 This impoundment drawdown rate was first discussed in section 3.3.1.2
Geological and Soil Resources, Environmental Effects, and was not proposed by Mr.
Ward or recommended by the agencies.
34 The Tennant method is based on the assumption that a proportion of MADF
would maintain suitable depths and water velocities for fish (Tennant, 1976). Although
Tennant's method is derived from rivers in Montana, Wyoming, and Nebraska, analyses
in the southeast exhibit general agreement with his recommendations (Wood and Whelan,
1962).

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winter, spring; table 4). Thus, during any temporary drawdowns that might occur for
maintenance or emergencies, a minimum flow of 60 cfs would provide adequate flows to
sustain aquatic life downstream of the project. Although not proposed or recommended,
it would also be necessary to release 60 cfs in the tailrace while the impoundment is
drawn down to provide the same protection discussed above.
As discussed in section 3.3.2, Water Resources, in order to release 60 cfs into the
tailrace and still allow the impoundment to refill, inflows to the project would need to be
greater than 60 cfs. Therefore, we believe Interior's recommendation to conduct refills
when inflow is greater than 60 cfs would be necessary, to allow Mr. Ward's proposed
minimum flows.
Also as discussed in section 3.3.2, Water Resources, Interior's recommendation to
only begin drawing the impoundment down when inflows are greater than or equal to 60
cfs, would help ensure that a complete drawdown and refill event occurs when flows can
adequately protect aquatic resources. It would also ensure that scheduled maintenance
drawdowns do not occur during times of very low flow, or drought conditions, which are
stressful periods for aquatic life.
Table 4. Minimum flow required for fish in streams identified by Tennant (1976).
Description of flow
Percent of MADF
dry season wet season
Outstanding
40
60
Excellent
30
50
Good
20
40
Fair or degrading
10
30
Poor or minimum
10
10
Severe degradation
0-10
0-10
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Entrainment and Impingement
Water intake structures at hydropower projects can injure or kill fish that come
into contact with intake screens/trash racks or turbines. Fish that are wider than the
intake screen or trash rack bar spacing and have burst swim speeds35 lower than approach
velocities36 can become trapped against intake screens or bars of a trash rack. This
process is known as impingement, and can cause physical stress, suffocation, and death
of some organisms (EPRI, 2003).
Entrainment can occur if fish are small enough to pass between trash rack bars,
and they do not behaviorally avoid passage into the intake structures. Generally, even if
fish are small enough to fit through trash rack bar spacing, they will behaviorally avoid
entrainment if their burst swim speeds exceed the approach velocity in front of the trash
racks. If entrainment occurs, fish injury or mortality can result from collisions with
turbine blades or exposure to pressure changes, sheer forces in turbulent flows, and water
velocity accelerations created by turbines (Knapp et al., 1982). The number of fish
entrained and at risk of turbine mortality at a hydroelectric project is dependent upon site-
specific factors, including physical characteristics of the project, as well as the size, age,
and seasonal movement patterns of fish present within the impoundment (EPRI, 1992).
Fish that are entrained and killed are removed from the river population and no longer
available for recruitment to the fishery.
The project includes an intake structure consisting of trash racks with 1 -inch bar
spacing. Mr. Ward does not propose any additional measures to minimize fish mortality
related to entrainment and impingement.
35 Burst swimming speed is the maximum swimming speed that can only be
sustained for a few seconds. It is usually used to escape danger (Murray, 1974).
36 Approach velocity is the calculated water flow velocity component
perpendicular to the trash rack face.

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Our Analysis
To determine the risk of impingement and entrainment, we first estimated the
approach velocity (Vo, feet per second [fps]) in front of the trash racks, using the
following equation (EPRI, 2000):
= intake flow
intake cross—sectional area
where intake flow is the maximum hydraulic capacity of the project (158 cfs; Ward,
2014) and cross-sectional area is 355 square -feet (Ward, 2015). Based on this equation,
the maximum approach velocity at the trash racks is 0.45 fps.
At the Ward Mill Project, the species most likely to encounter the trash racks are
rock bass, redbreast sunfish, margined madtom, warpaint shiner, river chub (table 5).37
The burst swimming speeds of each of these species exceeds the approach velocity of
0.45 fps by a minimum of 1.35 fps (table 5). Thus, all of the species found in the
impoundment and of the size ranges shown in table 5 are capable of swimming to avoid
impingement and entrainment.
Table 5. Burst swim speeds of the five species found in the Ward Mill impoundment.
Surrogate Total Burst swim speed
Species Speciesa length (fps, feet per second)
(inches)
Redbreast sunfish Bluegill 2 1.8
M
2.4
37 These five fish species are also the most abundant species directly upstream of
the impoundment, could also potentially encounter the trash racks.
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Surrogate Total Burst swim speed
Species length
ecies Speciesa (inches) (fps, feet per second)
6 4.3
Warpaint shiner Emerald shiner 2.5 4
a Burst swim speeds were not available for the species included in our analysis.
Surrogate species used were fish in the same family and with similar body
morphometry to the species included in our analysis.
b Source: Appalachian Power Company (2009)
Burst swim speeds were estimated from the prolonged swim speeds of Gardner
(2006). Based on Bell (1991), burst swim speed was calculated at 2 times the
prolonged speed.
d Source: Bell (1991)
e River chub burst swim speeds are assumed to be equivalent to 10 lengths per
second. Beamish (1978) considered 10 lengths per second to be a conservative
measure of burst swim speed for fish.
Our analysis indicates that the five species in the impoundment are not likely to be
entrained, and thus would not be affected by turbine mortality. However, data on the
burst swim speeds of the youngest and smallest individuals of these species were not
available, and could be lower than the approach velocity in front of the trash racks. Thus,
it is possible that these younger and smaller fish could pass through the trash racks and
become entrained. In fact, as other studies have shown, the majority of fish entrained
consists of small individuals (EPRI, 1997). However, the survival of smaller individuals
is likely to be relatively high because they are less prone to mechanical injury from
turbine passage than larger fish. Smaller fish are also less prone to injury resulting from
shear stresses and rapid pressure changes associated with turbine passage. Furthermore,
the younger individuals in a population generally have high rates of natural mortality,
even in the absence of hydropower operations. Fish populations have generally evolved
to withstand losses of these smaller and younger individuals with little or no impact to
long-term population sustainability. Thus, entrainment and turbine mortality of smaller
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individuals could occur, but it is expected to be very low and have minimal consequences
to the sustainability of the fish community in the impoundment.
Based on our analysis, impingement is unlikely to occur, and any entrainment and
turbine mortality that could occur is likely to be minimal and exclusive to younger and
smaller fish. Consequently, continued operation of the project would likely have little to
no adverse effect on the overall fish community in the project impoundment.
Special Status Species
The green floater and eastern hellbender salamander are North Carolina State
Endangered Species and Special Concern Species, respectively, and green floater is under
review for federal listing. Neither species was observed during surveys conducted in the
project impoundment and downstream of the dam in 2013; however, each may occur in
the project vicinity in low numbers.
Mr. Ward proposed no measures relating to the protection of these species. FWS
made no recommendations, but did state that it is important to implement measures into
plans to avoid impacts to green floater and eastern hellbender salamander.
Our Analysis
As stated above in section 3.3.2 Water Resources and section 3.3.3 Fishery
Resources, continuing to operate the project in run -of -river mode would maintain good
water quality conditions and stable water levels in the project vicinity, which would serve
to benefit all aquatic organisms, including the green floater mussel and the eastern
hellbender salamander. However, aquatic organisms could be negatively affected by
emergency and maintenance drawdowns that have the potential to cause water level
fluctuations and reduced flows. As stated above in section 3.3.2, Water Resources and
section 3.3.3, Fishery Resources, a drawdown and refill plan would protect all aquatic
organisms from the negative effects that emergency drawdowns and refills could have on
water quality, water depth, flow, erosion, and sedimentation.
3.3.4 Terrestrial Resources
3.3.4.1 Affected Environment
Vegetation
The Ward Mill Project is located in the Appalachian — Blue Ridge ecoregion,
which is one of the world's richest temperate broadleaf forests. Over 50 genera of plants
occur in this region, including magnolias, hickory, sassafras, ginseng, mayapple, skunk
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cabbage, several species of orchids, coffee -tree, stewartia, witch hazel, dogwoods,
persimmons, hollies, and maples. The woody vegetation of this region, which covers 79
percent of the land cover in the Watauga River Basin is characterized by varying species
assemblages that correspond to elevational gradients (Homer et al., 2011). At lower
elevations (820 to 4,430 feet) mixed oak forests dominate. At elevations above 4,430
feet, spruce -fir forests occur, with red spruce, Fraser fir, and balsam fir dominating along
high elevational ridges (Stephenson et al., 1993).
Kudzu and Japanese privet are invasive plant species38 known to occur in the
project vicinity.39 Kudzu is a climbing, semi -woody, perennial vine native to Asia that
was introduced to the United States for erosion control and is now found throughout most
of the Southeast. Although kudzu grows best in disturbed areas such as forest edges,
abandoned fields, and along roads and trails, this species thrives in a wide range of
conditions. Kudzu is an ecological concern because it grows rapidly at a rate of
approximately one foot daily. It also can envelope and eventually kill other plants by
shading them out, breaking limbs, and even uprooting trees under the mass of its tangled
vines (Bergmann and Swearingen, 2005).
Japanese privet is an invasive shrub that prefers moist soil conditions, but will
tolerate more well -drained upland sites. The shrub colonizes by root and stem sprouts,
and by seeds dispersed by wildlife, particularly birds. Privet is capable of forming dense
stands in the understory of bottomland forests, can outcompete native plants, and
drastically alter wildlife habitat. Japanese privet is especially successful along fence -
rows and roadsides, where it can readily expand its range.
38 Invasive species are not native to an ecosystem.
39 FWS indicated, by letter filed May 19, 2015, that kudzu and Japanese privet are
present at the project, but in unknown densities.

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3.3.4.2 Environmental Effects
Invasive Species
When unchecked, invasive plants, such as kudzu and Japanese privet have the
potential to spread, causing declines in the abundance and diversity of native plants,
which can be important food and habitat to wildlife.
Mr. Ward does not propose any specific measures to control these invasive plants.
Interior recommended an erosion control plan (discussed in more detail in section 3.3.1.2
Geological and Soil Resources, Environmental Effects) with a provision to include a
monitoring and management plan for invasive exotic species within the project boundary.
Our Analysis
Kudzu and Japanese privet have the potential to expand if soil along the shoreline
is disturbed or becomes exposed through natural causes, project operation, or recreation
use. Continuing to operate the project in run -of -river mode, as proposed Mr. Ward,
would limit exposure of shoreline soil to those periods that occur during natural river
fluctuations. There is the potential that soil could become exposed during emergency or
maintenance drawdowns; however, these events would be temporary, and are unlikely to
be of sufficient duration to allow kudzu or Japanese privet to establish new plants along
the shoreline. Any plants that do become established would die soon after being
submerged after the impoundment is refilled.
Foot traffic by anglers and boaters using the canoe portage could spread the seeds
of these species and result in further expansion of their presence within the project
boundary. However, recreation activity at the project is generally low, which likely helps
to limit the spread of these species. Mr. Ward's proposed signage directing visitors to
specific areas for portaging would also help minimize the effects of foot traffic.
There is no indication that invasive species are problematic within the project
boundary, or would be problematic under a new license. Thus, the benefits of developing
and implementing an invasive species management plan that includes monitoring and site
and species-specific control as needed, would be limited.
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3.3.5 Recreation and Land Use
3.3.5.1 Affected Environment
Land Use
The project is located in a remote, rural area where the dominant land cover is
deciduous forest. Watauga County is very mountainous, and all of the county's terrain is
located within the Appalachian Mountains. Land in the watershed is typically
undeveloped, with forest lands composing 56.2 percent of the watershed and agricultural
lands composing an additional 23.8 percent. However, development (primarily
residential construction) has rapidly increased on steep slopes in the area (North Carolina
WRC, 2015). The family of the applicant has lived along the Watauga River for over 100
years, and the Wards continue to live less than 100 yards from the Ward Mill Dam.
Lands within the project boundary have been used for milling and hydroelectric power
dating to 1890, when the first gristmill began operating.
There are no lands in the immediate vicinity of the project that are included in the
national trails system, or designated as wilderness lands. No portion of the Watauga
River is included on the list of wild and scenic rivers; however, the reach of the Watauga
River from river mile (RM) 77, north of Grandfather Mountain (upstream of the Ward
Mill Dam), to RM 51 at the Tennessee state line (downstream of the Ward Mill Dam) is
listed on the Nationwide Rivers Inventory (NRI) for its outstanding values in scenery,
recreation, geology, fish, wildlife, history, and cultural significance. The NRI, which was
created in 1982 and amended in 1993, identifies river segments in the United States that
are believed to possess one or more "outstandingly remarkable" natural or cultural values
judged to be of more than local or regional significance (NPS, 2011).
Recreation
Statewide Recreation Plan
The 2015 — 2020 North Carolina State Comprehensive Outdoor Recreation Plan
(SCORP) guides recreation planning and development in the state (North Carolina DPR,
2015). The plan has no specific recommendations for the project area; however, it does
identify goals for recreation within the state. These goals include: maintaining,
protecting, conserving and enhancing the state's outdoor recreation resources; increasing
opportunities for physical activity; improving the visibility of, and public access to public
recreation areas, and fostering cooperation between public recreation managers;
promoting the economic benefits of the state's recreation opportunities for communities
across the state; and increasing public awareness of the state's natural resources and
outdoor recreation opportunities through interpretation, education, and outreach. The

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SCORP also identifies issues associated with recreation supply and demand. The plan
indicates there is demand for continuing to: operate existing parks; acquire new parks
and open space, especially linear and nature parks; link trail networks; and develop or
improve trails, picnic shelters, and wildlife/nature observation sites.
Regional Recreation
The Watauga River has historically been a fishing destination (North Carolina
WRC, 2012). The Watauga River Basin contains native brook trout, along with hatchery
raised rainbow, brown, and brook trout. Rock bass and smallmouth bass are other sport -
fishes in the basin (North Carolina OEEPA, 2007).
The area is a regionally -important destination for outdoor recreation activities such
as fishing, skiing, hiking, camping, biking, hunting, and sightseeing. Watauga County is
home to two state parks and the Blue Ridge Parkway. County parks and recreation
facilities provide additional recreation resources.
Recreation at the Ward Mill Project
The Watauga River is used for canoeing, kayaking, and rafting in the project
vicinity. The river is accessible from Old Watauga River Road, which runs along the
south side of the impoundment. There are several sites along this road, outside of the
project boundary, where fishing and boating access is available. For boaters that are
floating the river, Mr. Ward maintains a cleared takeout for boat portage approximately
150 feet above the dam with a return to the river below the dam. The portage trail is
approximately 250 feet long. A portage sign is visible from the river and directs boaters
to the trail. Another portage sign directs the boaters to the put -in below the dam (see
figure 2).
Bank fishing access is provided within the project boundary and lands around the
project may be used for hunting. Limited parking for visitors is available along the Old
Watauga River Road, but is not designated by the licensee.
EVA

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Figure 2. Recreation facilities (Source: Google Earth, 2014, as modified by staff).
Recreation Use
Recreation use data for the project were historically collected through the
Licensed Hydropower Development Recreation Report (Form 80). Mr. Ward filed the
project's most recent Form 80 in 2001, after which the project was exempted from future
Form 80 filings. These 2001 recreation season data indicate that annual daytime
visitation was between 300 and 400 recreation days with no annual nighttime visitation.
All facility use was well below capacity.
Recreation estimates provided by Mr. Ward in the license application indicate that
spring recreation use is approximately 10 to 15 fishermen per day. During late -spring,
and through summer and fall, recreation use is estimated at approximately four fishermen
per day. Canoe and kayak trips, which typically occur during the summer tourist season,
increase the total recreational use level at the project.

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3.3.5.2 Environment Effects
Effects of Continued Project Operation on Recreation Opportunities
Mr. Ward proposes to continue to operate the project in run -of -river mode,
shutting down generation during low -flow periods in order to maintain impoundment
levels. Mr. Ward also proposes to continue operating and maintaining the project
recreation facilities as -is. No new project features or changes in land use within the
project boundary are proposed.
Our Analysis
Continued operation of the project is unlikely to affect recreationists, because Mr.
Ward proposes to continue to operate the project in run -of -river mode, keeping the
impoundment level at the crest of the dam. Run -of -river operations would ensure that
natural flow conditions, rather than project operations, would continue to have the largest
and most significant effects on the boatability of the Watauga River in the project
vicinity.
The Watauga River's designation on the NRI would not be affected by continued
operation of the project. The reach of the Watauga River from RM 51 to RM 77 was
listed on the NRI in 1982, and the project was operating at that time. Continuing to
operate and maintain the existing recreation facilities, including the canoe portage and
bank -fishing area would protect recreation opportunities in the project vicinity.
Existing Public Access and Recreation Facilities
Over the term of a new license, Mr. Ward would continue allowing public access
of the portage trail, put -in, and take-out, as well as the multiple bank -fishing areas along
the impoundment. Mr. Ward proposes to maintain the existing portage's informational
signage. In the license application, Mr. Ward also requested an exemption from the
Commission's Form 80 filing requirement over the term of any new license issued for the
project.
Interior and North Carolina DWR comment that Mr. Ward maintain the existing
portage path and provide adequate signage and parking for recreational users. Interior
also recommends that adequate bank -fishing areas be provided.
.J

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Our Analysis
The existing recreation facilities meet a public need for North Carolina's current
and future citizens, which is a goal of the North Carolina SCORP (2015). The Watauga
River's listing on the NRI for its outstanding recreation value means that it will likely
continue to be sought out for recreational activities. Operating and maintaining the
facilities over the term of a license, as proposed by Mr. Ward, would benefit
recreationists in the area by providing opportunities for anglers and a safe portage route
for boaters.
Regarding Mr. Ward's request for an exemption from the Form 80 filing
requirements, filing at least one Form 80 after issuance of a new license would allow
Commission staff to assess current use levels and the need for further Form 80 filings.
3.3.6 Cultural Resources
3.3.6.1 Affected Environment
Area of Potential Effects
Under section 106 of the NHPA of 1966, as amended, the Commission must take
into account whether any historic properties within a project's area of potential effects
(APE) could be affected by the project. The Advisory Council on Historic Preservation
defines an APE as the geographic area or areas in which an undertaking may directly or
indirectly cause alterations in the character or use of historic properties, if any such
properties exist. We define the APE for the Ward Mill Project as: (1) lands enclosed by
the project boundary; and (2) lands or properties adjoining the project boundary, where
authorized project uses may cause changes in the character or use of historic properties, if
historic properties exist.
Cultural History Overview
The Ward Mill project lies in central Watauga County, in the high mountains of
northwestern North Carolina. Very little information exists about native populations in
the region; however, one archeological site, known as the Ward Site, indicates the
presence of a village and farming center, most intensively occupied around A.D. 1400
(Pezzoni, 2009). At the time of European contact, the project area was used as seasonal
hunting territory by the Cherokee (Arthur, 1915).
European settlers began establishing farmsteads in the region during the 1770s.
The area, known as the District of Washington, was annexed under the government of
North Carolina in 1776 and incorporated into Wilkes County in 1777 (Corbitt, 1950). In
1779, David Hicks (or Hix) and Benjamin Ward filed the first recorded land grant
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application on the Watauga River, where they had already established homesteads
(Pezzoni, 2009). Watauga County, North Carolina was formed in 1849 from parts of
Ashe, Caldwell, Wilkes, and Yancy Counties (Corbitt, 1950).
Bill Ward first established a water -powered gristmill at the Ward Mill Project site
in 1890. In May 1901, a flood destroyed the mill. Soon after, Ward began construction
of a hemlock dam and wooden forebay (penstock) structure to provide power for a
gristmill and sawmill at the site. In 1906, the project was completed with a 26 -inch
Samson hydroturbine installed to power the mills. In the 1920s, a hammer mill for
producing cattle feed from corn was added at the site and the grist mill was phased out.
Operation of the mill transferred to Benjamin O. (Ben) Ward in 1932. Ben Ward
reworked the buildings and penstock, and added an 18 -inch turbine. In addition to
making modifications to the sawmill, he connected a small electric generator to the new
turbine. In 1934, Ward Mill began supplying power to nearby homes. In 1940, a flood
destroyed the sawmill buildings. Following the flood, Ward constructed a new concrete
penstock. In 1947, Ben Ward replaced the existing turbines with two 30 -inch turbines
and constructed a machine shop at the site.
In 1970, the mill transferred to Ray Ward. In 1982, the turbines were overhauled
and new generating equipment was installed, with the power being sold to Blue Ridge
Electric Membership Cooperative. The project has been licensed by the Commission
since 1986.
Historic Properties
There are no known archeological sites or historic architectural resources that
would be affected by the Ward Mill Project. As discussed previously, at the project site,
the Watauga River has been used for water -powered mill operations since 1890 and
hydroelectric generation has occurred since the early 20th century. The facilities have
been in continuous ownership of the Ward family since their initial construction and have
been modified over time to adapt to economic and technological change.
3.3.6.2 Environmental Effects
On October 21, 2011, the Commission initiated consultation with the North
Carolina SHPO regarding the relicensing of the Ward Mill Project, pursuant to section
106 of the NHPA. By letter filed August 28, 2014, the North Carolina SHPO determined
there were no historic properties listed in, or eligible for listing in, the National Register
which would be affected by the project (letter from R. Bartos, North Carolina Department
of Cultural Resources, Raleigh, North Carolina to A. Givens, Cardinal Energy Service,
Inc., Raleigh, North Carolina, October 3, 2011).
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Our Analysis
Based on the assessment of the North Carolina SHPO and the information in the
record for this proceeding, continued operation of the proposed project would not alter
the historic character of the existing structures. At this time, there is no evidence
indicating the presence of historic properties within the project's APE. However, it is
possible that unknown archaeological or historic resources may be discovered in the
future as a result of project operation or other project -related construction or maintenance
activities. If such resources are discovered, immediately stopping work and consulting
with the North Carolina SHPO to define appropriate treatment would prevent any further
harm to previously unidentified resources.
3.4 No -Action Alternative
Under the no -action alternative, the project would continue to operate as it has in
the past. None of the applicant's proposed measures or the resource agencies'
recommendations would be required. No new environmental protection, mitigation, or
enhancement measures would be implemented.ao
ao We use this alternative only for the purposes of establishing the baseline
environmental conditions for our analysis contained in this EA.
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4.0 DEVELOPMENTAL ANALYSIS
In this section, we look at the project's use of the Watauga River for hydropower
purposes and assess the effect various environmental measures would have on the
projects' costs and power generation. Under the Commission's approach to evaluating
the economics of hydropower projects, as articulated in Mead Corp.,41 the Commission
compares the current project cost to an estimate of the cost of obtaining the same amount
of energy and capacity using a likely alternative source of power for the region (cost of
alternative power). In keeping with Commission policy as described in Mead Corp., our
economic analysis is based on current electric power cost conditions and does not
consider future escalation of fuel prices in valuing the hydropower project's power
benefits.
For each of the licensing alternatives, our analysis includes an estimate of. (1) the
cost of individual measures considered in the draft EA for the protection, mitigation, and
enhancement of environmental resources affected by the project; (2) the cost of
alternative power; (3) the total project cost (i.e., for continued operation of the project
and environmental measures); and (4) the difference between the cost of alternative
power and total project cost. If the difference between the cost of alternative power and
total project cost is positive, the project produces power for less than the cost of
alternative power. If the difference between the cost of alternative power and total
project cost is negative, the project produces power for more than the cost of alternative
power. This estimate helps to support an informed decision concerning what is in the
public interest with respect to a proposed license. However, project economics is only
one of many public interest factors the Commission considers in determining whether,
and under what conditions, to issue a license.
4.1 POWER AND ECONOMIC BENEFITS OF THE PROJECT
Table 6 summarizes the assumptions and economic information we use in our
analysis for the project. This information was provided by Mr. Ward, in his license
application and subsequent submittals. We find that the values provided by the applicant
are reasonable for the purposes of our analysis. Cost items common to all alternatives
41 See Mead Corp., Publishing Paper Division, 72 FERC ¶ 61,027 (1995). In most
cases, electricity from hydropower would displace some form of fossil -fueled generation,
in which fuel cost is the largest component of the cost of electricity production.
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include: taxes and insurance costs; estimated capital investment required to develop the
project; licensing costs; normal operation and maintenance cost; and Commission fees.
Table 6. Parameters for the economic analysis for Ward Mill Project. (Source: Mr.
Ward and staff.)
Economic Parameter Value Source
Proposed capacity (MW)
0.168
Mr. Ward
Proposed average annual
3,744
Mr. Ward
generation (MWh)
Annual operation and
Mr. Ward
maintenance (O&M ) cost
2,500
($/year)
Cost to prepare license
40,000
Mr. Ward
application ($)
Period of economic analysis
30 years
Staff
Term of financing
20 years
Staff
Cost of capital (Long-term
7.0
Staff
interest rate)
Federal tax rate (%)
34
Staff
Local tax rate (%)
3
Staff
Insurance rate Included in the Mr. Ward
O&Mcost
Energy rate ($/MWh) 44.34 Staff
Capacity rate ($/kWh -yr) 165 Staff
4.2 COMPARISON OF ALTERNATIVES
Table 7 summarizes the installed capacity, annual generation, cost of alternative
power, estimated total project cost, and the difference between the cost of alternative
power and total project cost for each of the action alternatives considered in this draft
EA: no -action, Mr. Ward's proposal, and the staff recommended alternative.
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Table 7. Summary of the annual cost of alternative power and annual project costs for
alternatives for the Ward Mill Project. (Source: Staff.)
No -Action
Mr. Ward's
Staff
Alternative
Proposal
Alternative
Installed capacity (MW)
0.168
0.168
0.168
Annual generation (MWh)
3,744
3,744
3,744
Annual cost of alternative power
$217,570
$217,570
$271,570
($/MWh)
$581.11
$581.11
$581.11
Annual project cost
$78,540
$79,886
$78.968
($/MWh)
$209.77
$213.37
$210.92
Difference between cost of
$139,030
$137,682
$138,599
alternative power and project cost
($/MWh)
$371.34
$367.74
$370.19
4.2.1 No -Action Alternative
Under the no -action alternative, the Ward Mill Project would continue to operate
under the terms and conditions of the existing license, and no new environmental
protection, mitigation, or enhancement measures would be implemented. There are no
costs associated with this alternative, other than applicants' costs for preparing the license
application.
4.2.2 Mr. Ward's Proposal
Under Mr. Ward's proposal, the Ward Mill Project would have an installed
capacity of 0.168 MW and generate an average of 3,744 MWh of electricity annually.
The average annual cost of alternative power would be $271,570, or $581.1 I/MWh. In
total, the average annual project cost would be $79,886, or about $213.37/MWh.
Overall, the project would produce power at a cost that is $137,682, or $367.74/MWh,
less than the cost of alternative power.
4.2.3 Staff Alternative
Under the staff recommended alternative with mandatory conditions, the Ward
Mill Project would have an installed capacity of 0.168 MW and generate an average of
3,744 MWh of electricity annually. The average annual cost of alternative power would
be $271,570, or $581.11/MWh. The average annual project cost would be $78,968, or
about $210.92/MWh. Overall, the project would produce power at a cost which is
$138,599, or $370.19/MWh, less than the cost of alternative power.
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4.3 COST OF ENVIRONMENTAL MEASURES
Table 8 gives the cost of each of the environmental enhancement measure
considered in our analysis. We convert all costs to equal annual (levelized) values over a
30 -year period of analysis to give a uniform basis for comparing the benefits of a
measure to its cost.
56

Table 8. Cost of environmental mitigation and enhancement measures considered in assessing the environmental effects
of the proposed Ward Mill Project. (Source: Staff.)
Enhancement/mitigation measure
Entities
Capital cost
Annual cost
Levelized
Notes
(2016$)
(2016$)
cost (2016$)
Geological and Soil Resources
I . Implement a sediment management plan with
Mr. Ward,
$0
$500
$330
a
provisions to: (1) manage sediment build-up if it
Staff
occurs in the impoundment; (2) notify the
Commission and resource agencies if sediment
accumulates and must be removed; and (3)
consult with the Commission and resource
agencies to identify steps necessary to remove
sediment from the impoundment.
2. Develop and implement, in consultation with
Interior
$2,000
$600
$542
a
resource agencies, a sediment management plan
to aid in the removal of sediment from the
impoundment when necessary with provisions
for: (1) monitoring sediment accumulation; (2)
developing a monitoring schedule; (3) removal
of sediment from the impoundment if build-up
occurs; and (4) requiring approval of the
resource agencies prior to opening the sand
gates.
3. Develop and implement, in consultation with
North
$0
$0
$0
d
resource agencies, a sediment management plan
Carolina
prior to any actions that involve opening the
WRC, North
sand gates, dredging sediment from the
Carolina
impoundment, or releasing sediment from the
57

Enhancement/mitigation measure
Entities
Capital cost
Annual cost
Levelized
Notes
(2016$)
(2016$)
cost (2016$)
impoundment.
DWR
4. Implement an erosion control plan to prevent
Mr. Ward
$0
$1,000
$660
b
erosion of the impoundment shoreline, with
provisions to: (1) monitor the shoreline for
damage after floods and recreational activities
along the shoreline; (2) notify the Commission
and the resource agencies if shoreline damage is
identified; and (3) consult with the Commission
and the resource agencies to identify steps
necessary to protect the shoreline after damage
is identified.
5. Develop and implement, in consultation with
Interior
$2,000
$1,500
$1,136
a
resource agencies, an erosion control plan to
prevent erosion along the impoundment and
sedimentation in the impoundment with
provisions to: (1) establish a monitoring
schedule; (2) develop a time frame for
stabilization efforts; (3) stabilize any disturbed
or eroding area with straw within 48 hours; and
(4) monitor and manage invasive exotic species
within the project's boundary.
W.

Enhancement/mitigation measure
Entities
Capital cost
Annual cost
Levelized
Notes
(2016$)
(2016$)
cost (2016$)
Aquatic Resources
6. Operate the project in run -of -river mode.
Mr. Ward,
$0
$0
$0
b
Interior,
North
Carolina
WRC, North
Carolina
DWR, Staff
7. Instantaneous run -of -river mode may be
Mr. Ward,
$0
$0
$0
b
temporarily modified if required for emergency
Interior,
situations, necessary repairs and maintenance, or
North
short periods agreed upon by Mr. Ward, the
Carolina
Commission, and resource agencies.
WRC, North
Carolina
DWR, Staff
8. Visually monitor flow daily to ensure run -of-
Mr. Ward,
$0
$0
$0
b
river operation.
Staff
9. Operate a float gage and cut-off switch on the
Mr. Ward,
$0
$50
$33
turbines so that generation will be taken off line
North
when the water level drops below the crest of the
Carolina
dam.
WRC, North
Carolina
DWR, Staff
59

Enhancement/mitigation measure
Entities
Capital cost
Annual cost
Levelized
Notes
(2016$)
(2016$)
cost (2016$)
10. Provide access to 15 -minute interval generation
Mr. Ward,
$0
$0
$0
b
data upon request of the Commission.
Staff
11. Maintain records of inflow and outflow to
North
$4,000
$50
$325
c
ensure run -of -river operation and document
Carolina
maintenance and emergency drawdowns.
WRC, North
Carolina
DWR
12. Install and operate a flow gage to record inflow
Mr. Ward,
$4,000
$50
$325
a
to the project, if the USGS discontinues
North
operation of gage number 03479000.
Carolina
WRC, North
Carolina
DWR
13. Maintain records of impoundment water stage,
North
$1,700
$23
$139
a
and make information available to resource
Carolina
agencies.
WRC, North
Carolina
DWR
14. Maintain records of project generation, and
North
$0
$0
$0
b
make information available to resource agencies.
Carolina
WRC, North
Carolina
DWR

Enhancement/mitigation measure
Entities
Capital cost
Annual cost
Levelized
Notes
(2016$)
(2016$)
cost (2016$)
15. File a report if the float gage and cut-off system
Staff
$0
$0
$0
b
fails, or if the water level in the impoundment
drops below the crest of the dam.
16. Implement a drawdown and refill plan for
Mr. Ward
$0
$0
$0
b
emergency and maintenance drawdowns that
includes provisions to: (1) refill the
impoundment when inflow to the impoundment
is greater than or equal to 60 cfs; (2) release a
minimum of 60 cfs into the tailrace during refill;
(3); visually monitor water level and flow
downstream of the dam at all times during
drawdown and refill; and (4) notify the
Commission and resource agencies prior to
beginning a drawdown.
17. Develop and implement, in consultation with
Interior
$2,000
$0
$146
a
resource agencies, a drawdown and refill plan
for emergency and maintenance drawdowns
with provisions to: (1) avoid drawdown of the
impoundment when the USGS gage 03479000
reads less than 60 cfs; and (2) avoid refilling the
impoundment after drawdowns when inflows to
the project are less than or equal to 60 cfs.
18. Develop an impoundment drawdown and refill
North
$2,000
$0
$146
a
plan in consultation with resource agencies,
Carolina
prior to any actions to lower the impoundment
WRC, North
level substantially below the crest of the dam.
Carolina
61

Enhancement/mitigation measure
Entities
Capital cost
Annual cost
Levelized
Notes
(2016$)
(2016$)
cost (2016$)
DWR
19. Implement, drawdown and refill procedures for
Staff
$0
$0
$0
a
emergency and maintenance drawdowns with
provisions to: (1) conduct emergency and
maintenance drawdowns when inflow is greater
than 60 cfs; (2) limit the drawdown rate to I foot
per day; (3) release inflow to the tailrace while
the impoundment is drawn down; (4) refill only
when inflow is greater than 60 cfs; (5) when
refilling, release a minimum of 60 cfs in the
tailrace; (6) establish a low-flow rating curve of
minimum flow releases during drawdowns; and
(7) notify the resource agencies and the
Commission as soon as possible, but no later
than 10 days after each drawdown event.
Recreation Resources
20. Continue to operate and maintain existing
Interior,
$0
$100
$66
a
recreation facilities
North
Carolina
WR, Staff
21. Monitor all recreation areas for erosion and
Interior,
$0
$0
$0
a
abate if found
North
Carolina
WR
62

Enhancement/mitigation measure
Entities
Capital cost
(2016$)
Annual cost
(2016$)
Levelized
cost (2016$)
Notes
Cultural Resources
22. Cease project activities and notify the North
Staff
$0
$0
$0
b
Carolina SHPO if any unknown archaeological
or historic resources are discovered as a result of
operation or other project -related activities.
a. Cost estimated by staff.
b. Staff estimates that the cost to implement this measure would be negligible.
c. Staff estimates the cost to implement this measure based on the need for one gage to monitor outflows from the
project. Currently, the USGS operates a gage upstream of the project (USGS number 03479000), which can be used
to monitor inflows.
d. We have not assigned a capital cost for these measures because North Carolina WRC and North Carolina DWR did
not specify the types of measures that would be included in a sediment management plan.
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5.0 CONCLUSIONS AND RECOMMENDATIONS
5.1 COMPREHENSIVE DEVELOPMENT AND RECOMMENDED
ALTERNATIVE
Sections 4(e) and 10(a) of the FPA, 16 U.S.C. §§ 797(e), 803(a), require the
Commission to give equal consideration to the power development purposes and to the
purposes of energy conservation; the protection, mitigation of damage to, and
enhancement of fish and wildlife; the protection of recreational opportunities; and the
preservation of other aspects of environmental quality. Any licenses issued shall be such
as in the Commission's judgment will be best adapted to a comprehensive plan for
improving or developing waterway or waterways for all beneficial public uses. This
section contains the basis for, and a summary of, our recommendations for licensing the
Ward Mill Project. We weigh the costs and benefits of our recommended alternative
against other proposed measures.
Based on our independent review of agency comments filed on this project and
our review of the environmental and economic effects of the proposed project and
economic effects of the project and its alternatives, we selected the staff alternative as the
preferred alternative. We recommend the staff alternative because: (1) the project would
provide a dependable source of electrical energy for the Ward Mill and the local area;
(2) the 168 kW of electric capacity comes from a renewable resource that does not
contribute to atmospheric pollution, including greenhouse gases; (3) the public benefits of
this alternative would exceed those of the no -action alternative; and (4) the proposed
measures would protect or enhance geological and soils, aquatic, terrestrial, recreational,
and cultural resources.
In the following sections, we make recommendations as to which environmental
measures recommended by agencies or other entities should be included in any license
issued for the project. We also recommend additional environmental measures to be
included in any license issued for the project.
5.1.1 Measures Proposed by Mr. Ward
Based on our environmental analysis of Mr. Ward's proposal discussed in
section 3 and the costs discussed in section 4, we conclude that the following
environmental measures proposed by Mr. Ward would protect and enhance
environmental resources and would be worth the cost. Therefore, we recommend
including these measures in any license issued for the project:
• Operate the project in instantaneous run -of -river mode.

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Implement a sediment management plan with provisions to: (1) manage
sediment build-up if it occurs in the impoundment; (2) notify the Commission
and resource agencies if sediment accumulates and must be removed; and (3)
consult with the Commission and resource agencies to identify steps necessary
to remove sediment from the impoundment.
• Visually monitor flow daily to ensure run -of -river operation.
• Provide access to 15 -minute interval generation data.
• Operate a float gage and cut-off switch on the turbines so that generation will
be taken off line when the water level drops below the crest of the dam.
• Continue to operate and maintain the existing recreation facilities at the
project, which include: (1) a canoe portage trail with put -in and take-out areas;
(2) a parking area in vicinity of dam and mill buildings; and (3) informal bank -
fishing along the full length of the impoundment.
5.1.2 Additional Measures Recommended by Staff
In addition to Mr. Ward's proposed measures noted above, we recommend the
following measures in any license issued to Mr. Ward.
Implement impoundment drawdown and refill procedures for emergency and
maintenance drawdowns with provisions to: (1) conduct emergency and
maintenance drawdowns when inflow is greater than 60 cfs; (2) limit the
drawdown rate to I foot per day; (3) release inflow to the tailrace while the
impoundment is drawn down; (4) refill only when inflow is greater than 60 cfs;
(5) when refilling, release a minimum of 60 cfs in the tailrace; (6) establish a
low -flow rating curve of minimum flow releases during drawdowns; and (7)
notify the resource agencies and the Commission as soon as possible, but no
later than 10 days after each drawdown event.
• File a report if the float gage and cut-off system fails, or if the water level in
the impoundment drops below the crest of the dam.
Cease project activities and notify the North Carolina SHPO if any unknown
archaeological or historic resources are discovered as a result of operation or
other project -related activities.
Below, we discuss the rationale for modifying Mr. Ward's proposal and the basis
for our additional staff -recommended measures.
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Drawdown and Refill Plan
As discussed in section 3.3.3, Fishery Resources, Mr. Ward may need to
periodically draw down the project impoundment for maintenance or emergencies.
During drawdowns, run -of -river operation would be temporarily interrupted, and water
levels in the impoundment would be reduced, with potential negative effects on aquatic
biota. The refill of an impoundment following a drawdown can also disrupt flows
downstream of a project and affect water quality and aquatic habitat. To mitigate for
the potential negative effects of an impoundment drawdown and refill, Mr. Ward
developed an impoundment drawdown and refill plan with provisions to: (1) refill the
impoundment when inflow to the impoundment is greater than or equal to 60 cfs; (2)
release a minimum of 60 cfs into the tailrace during refill; (3); visually monitor water
level and flow downstream of the dam at all times during drawdown and refill; and (4)
notify the Commission and resource agencies prior to beginning a drawdown. Interior
recommends that Mr. Ward develop and implement, in consultation with resource
agencies, a drawdown and refill plan for emergency42 and maintenance drawdowns with
provisions to: (1) avoid drawdown of the impoundment when the USGS gage number
03479000 reads less than 60 cfs; and (2) avoid refilling the impoundment after
drawdowns when inflows to the project are less than or equal to 60 cfs. North Carolina
WRC and North Carolina DWR also recommend that Mr. Ward develop an
impoundment drawdown and refill plan in consultation with resource agencies, prior to
any actions to lower the impoundment level substantially below the crest of the dam.
Although Mr. Ward developed an impoundment drawdown and refill plan, it does
not include the flow conditions needed to begin impoundment drawdown. In addition,
neither Mr. Ward nor the resource agencies proposed or recommended, respectively,
the development of a rating curve for minimum flow releases or a drawdown rate. As
discussed in section 3.3.2, Water Resources, a rating curve would be needed to ensure
that a minimum of 60 cfs is being released to the tailrace after the impoundment is
drawn down and during refill. As discussed in section 3.3.3, Fishery Resources,
limiting the drawdown rate of the impoundment to I foot per day would reduce the
likelihood of aquatic organisms becoming stranded in the impoundment, and flushed
downstream from habitats in the tailrace.
42 We assume that the only emergencies that apply to this recommendation are
those that allow time for the measures to be implemented without endangering lives.

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Based on our analysis, we recommend the procedures for impoundment drawdown
and refill include measures to: (1) conduct emergency and maintenance drawdowns
when inflow is greater than 60 cfs; (2) limit the drawdown rate to 1 foot per day;
(3) release inflow to the tailrace while the impoundment is drawn down; (4) refill only
when inflow is greater than 60 cfs; (5) when refilling, release a minimum of 60 cfs in
the tailrace; (6) establish a low -flow rating curve of minimum flow releases during
drawdowns; and (7) notify the resource agencies and the Commission as soon as
possible, but no later than 10 days after each drawdown event.
Staff recommended provision (1) varies slightly from Interior's recommendation
to avoid drawdowns when inflow is less than 60 cfs (see section 3.3.3, Fishery
Resources). Nevertheless, staff s recommended provision is generally consistent with
Interior's recommendation, and the minor differences are inconsequential to the
protection of aquatic resources.
Because our recommended impoundment drawdown and refill procedures are
generally consistent with the procedures recommend by Interior, North Carolina WRC
and North Carolina DWR, and because these procedures would be protective of aquatic
resources during drawdown events, we recommend that the impoundment drawdown
and refill procedures be required in any new license in lieu of developing a plan in
consultation with resource agencies, as recommended by the Interior, North Carolina
WRC and North Carolina DWR.
In section 4.0, Developmental Analysis, we determined that there would be no
increase in the levelized annual cost as a result of implementing the impoundment
drawdown and refill procedures. We find the adding our measures and providing the
necessary detail to ensure that project maintenance does not adversely affect aquatic
resources in the project area would be worth the cost.
Operation Compliance
As discussed in section 3.3.2, Water Resources, and 3.3.3, Fishery Resources,
continued operation of the project in run -of -river mode, as proposed by Mr. Ward, would
maintain the best available flow, water quality, and habitat for aquatic biota. Mr. Ward
proposes to continue operating the project in a run -of -river operation. To ensure run -of -
river operation, Mr. Ward proposes to: (1) continue visually monitoring flows daily; (2)
continue operating a float gage and cut-off switch on the turbines so that generation
would be taken off line when the water level drops below the crest of the dam; and
(3) provide access to 15 -minute interval generation data from the utility.
As discussed in section 3.3.3, Fishery Resources, we find these measures to be
sufficient to ensure that the project continues to protect aquatic resources by operating in
run -of -river mode. In addition, we recommend that Mr. Ward file a report with the
67

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Commission and resource agencies if the cut-off system fails, and/or if the water level in
the impoundment drops below the crest of the dam. This measure would provide an
additional means to protect run -of -river conditions at the project. There would be no
additional cost incurred for filing a report with the Commission and resource agencies.
Cultural Resources
There are no known historic properties within the proposed project's APE.
However, there is a possibility that unknown archaeological or historic resources may be
discovered due to project operation or other project -related activities. To ensure proper
treatment of any unknown cultural resources that may be discovered at the project, we
recommend that, in the case of any such discovery, Mr. Ward notify and consult with the
North Carolina SHPO and: (1) cease project -related activities and determine if the
discovered archaeological or historic resource is eligible for the National Register; (2)
determine if continued operation of the project would adversely affect the resource; and
(3) if the resource would be adversely affected, obtain guidance from the North Carolina
SHPO on how to avoid, lessen, or mitigate for any adverse effects. Also we recommend
that Mr. Ward inform the Commission of any discovery of unknown cultural resource,
and any measures proposed if the resource is eligible for the National Register and is
adversely affected by project construction or operation. There is no additional estimated
cost associated with this measure.
5.1.3 Measures Not Recommended by Staff
Sediment Management Plan
To prevent accidental release of sediments from the impoundment during
maintenance activities, Mr. Ward proposes to implement a sediment management plan
with provisions to: (1) manage sediment build-up if it occurs in the impoundment;
(2) notify the Commission and resource agencies if sediment accumulates and must be
removed; and (3) consult with the Commission and resource agencies to identify steps
necessary to remove sediment from the impoundment. Interior, North Carolina WRC,
and North Carolina DWR recommend that Mr. Ward develop a sediment management
plan in consultation with resource agencies, prior to any actions that involve opening the
sand gates, dredging sediment from the impoundment, or releasing sediment from the
impoundment. Further, Interior recommends that the plan include provisions for:
(1) monitoring; (2) developing a schedule; (3) removal of sediment from the
impoundment if build-up occurs; and (4) requiring approval of the resource agencies
prior to opening the sand gates.
As discussed in section 3.3.1, Geological and Soil Resources, there has not been
any sustained build-up of sediment in the project impoundment during the last 30 years,
possibly because of periodic floods that wash sediments from the impoundment (Ward,

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2014). Based on the lack of sediment build-up that has occurred in the impoundment
under the current license, there does not appear to be an existing issue with sediment
build-up, and there is no indication that sediment build-up is likely to occur in the future.
Therefore, the project is unlikely to release large quantities of sediment that would
negatively affect downstream aquatic resources.
Although sediments are unlikely to build-up and be released from the project
impoundment, Mr. Ward has proposed to notify the Commission and resource agencies if
sediment build-up does occur in the future, and consult with the Commission and
resource agencies to identify the steps needed to remove any sediment from the
impoundment. Mr. Ward's proposed measures would be adequate to protect aquatic
resources from any large sediment releases. In addition, as recommended by the Interior,
North Carolina WRC and North Carolina DWR, Mr. Ward's proposes to consult with the
resource agencies on a plan for sediment removal prior to any sediment removal action.
There is no need for Mr. Ward to conduct scheduled sediment monitoring as
recommended by the Interior, because: (1) there is no indication that sediment build-up
is an issue at the project; and (2) it is in Mr. Ward's own best interest to maintain the
depth of the impoundment in order to maximize the operational efficiency of the project.
Given the lack of historical sediment build-up at the project, the unlikelihood of
future build-up, and the adequacy of Mr. Ward's proposal to protect aquatic resources if
sediment build-up were to occur, we conclude that Interior's recommended sediment
management plan is not worth the annual levelized cost of $542.43
Shoreline Monitoring and Maintenance
To prevent any future erosion of the impoundment shoreline, Mr. Ward proposes
to implement a an erosion control plan with provisions to: (1) monitor the shoreline for
damage caused by floods and recreational activities along the shoreline; (2) notify the
Commission and the resource agencies if shoreline damage is identify; and (3) consult
with the Commission and the resource agencies to identify steps necessary to protect the
shoreline if damage is identified. Interior also recommends that Mr. Ward develop an
erosion control plan in consultation with the resource agencies. Interior recommends that
the plan include: (1) a monitoring schedule; (2) a time frame for stabilization efforts;
43 North Carolina WRC and North Carolina DWR recommended a sediment
management plan, but did not include enough detail to estimate an annual levelized cost
(see table 8).
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(3) a provision to stabilize any disturbed or eroding area with straw within 48 hours; and
(4) a provision for monitoring and managing invasive exotic species within the project's
boundary.
As discussed in section 3.3.1, Geological and Soil Resources, shoreline erosion is
unlikely to occur during normal run -of -river operations, but has the potential to occur
during emergency or maintenance drawdowns. However, as discussed in section 3.3.1,
Geological and Soil Resources, limiting the drawdown rate of the impoundment to 1 foot
per day would be sufficient to minimize future shoreline erosion within the project
impoundment, and is recommended by staff in the revised impoundment drawdown and
refill plan (discussed above in section 5.1.2, Additional Measures Recommend by Staff).
In addition, as discussed in section 3.3.4, Terrestrial Resources, kudzu and
Japanese privet are invasive plants present within the project boundary. There is the
potential for these species to spread by colonizing exposed soil in the impoundment
during emergency or maintenance drawdowns; however, if plants do become established
during these short events, resumption of normal operations would submerge and kill any
terrestrial plants. Mr. Ward's proposed signage directing visitors to specific areas for
portaging would help minimize the effects of foot traffic on the spread of invasive
species.
Given the adequate alternative mitigation discussed above, we conclude that an
erosion control plan would provide little benefit in limiting erosion or spread of invasive
plants, and thus the Interior's recommended shoreline management plan is not worth the
annual levelized cost of $1,136, and Mr. Ward's proposed erosion control plan is not
worth the annual levelized cost of $660.
Operation Compliance
As discussed in section 5.1.2, Additional Measures Recommended by Staff, Mr.
Ward proposes measures to ensure that the project continues to operate in run -of -river
mode. North Carolina WRC and North Carolina DWR recommend that if the
impoundment level drops below the crest of the dam, the turbines should stop running so
that water can immediately spill over the dam. North Carolina WRC and North Carolina
DWR also recommend that records of inflow and outflow be maintained to verify run -of -
river operation and to document maintenance and emergency drawdowns. Specifically,
North Carolina WRC and North Carolina DWR recommend that Mr. Ward: (1) install a
stream gage to record inflow, if the USGS gage number 03479000 is no longer
maintained; (2) maintain records of impoundment stage and project generation; and
(3) make records of impoundment stage and project generation available to resource
agencies.
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As discussed in section 3.3.3, Fishery Resources, North Carolina WRC and North
Carolina DWR's recommendations to maintain records of inflow and outflow data, and
impoundment stage data could be used to monitor compliance with run -of -river
operation, and thereby help maintain the best available flow, water quality, and habitat
for aquatic biota that exist under existing run -of -river operations.
The ability to record inflow to the project is currently available at USGS gage
number 03479000; however, if USGS were to discontinue operation of the gage, North
Carolina WRC and North Carolina DWR recommend that Mr. Ward install a gage to
record inflow. The annual levelized cost of installing an inflow gage would be $325.
Mr. Ward does not currently record outflow at the project, and thus North Carolina WRC
and North Carolina DWR's recommendation would require installation of an outflow
gage at an annual levelized cost of $325. Mr. Ward also does not record the stage (or
water level) of the impoundment, and thus North Carolina WRC and North Carolina
DWR's recommendation, would require installation of a water level logger at an annual
levelized cost of $ 139.
Compared to the recommendations above to record inflow, outflow, and water
level, less sophisticated, yet equally useful options are available that would ensure run -of -
river operations at the project. Specifically, Mr. Ward's proposal to continue operating
the float gage and cut-off switch, would prevent the impoundment water level from
falling below the crest of the dam, and thereby avoid disruptions in downstream flow.
The float gage and cut-off switch would also ensure that the project could not function in
any operation mode other than run -of -river. This proposed measure would only require
maintenance costs at an annual levelized cost of $33.
Mr. Ward also proposes to visually monitor flows daily, which would ensure the
float gage and cut-off switch were operating properly and that water does not fall below
the crest of the dam. In addition, and as discussed above in section 5.1.2, Additional
Measures Recommended by Staff, we recommend that Mr. Ward file a report to the
Commission if the cut-off system fails, and/or the water level in the impoundment drops
below the crest of the dam, which would provide additional means to protect run -of -river
conditions at the project at an annual levelized cost of $0. Mr. Ward would also provide
access to project generation data, which could be used to determine whether the project is
operating in a mode other than run -of -river (i.e., as a peaking project). There is no
additional estimated cost associated with this measure.
In consideration of the costs and benefits of the proposed and recommended
measures, the ability of each measure to protect run -of -river conditions at the project, the
limited ability of the project to operate in a mode other than run -of -river, and Mr. Ward's
historical compliance with run -of -river operation, we conclude that the appropriate
balance of the benefits and costs is best met with staffs alternative. For this reason, we
recommend a license condition requiring Mr. Ward to: (1) continue visually monitoring
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flows daily; (2) continue operating a float gage and cut-off switch on the turbines so that
generation would be taken off line when the water level drops below the crest of the dam;
(3) file a report with the Commission if the cut-off system fails, and/or if the water level
in the impoundment drops below the crest of the dam; and (4) provide access to
15 -minute interval generation data from the utility.
5.2 UNAVOIDABLE ADVERSE EFFECTS
During any maintenance or emergency drawdowns or refills, there would still be a
temporary interruption of run -of -river operation, water levels in the impoundment would
be reduced, and water levels in both the impoundment and tailrace would fluctuate.
However, under the staff recommended plan, these temporary events would only occur
when inflow is greater than 60 cfs. Further, the staff recommended plan would prevent
significant dewatering and degradation of water quality, and maintain a minimum flow of
60 cfs in the tailrace during refill that would sustain aquatic life downstream of the
project. There is still the possibility that DO could fall below 6.0 in the impoundment
during portions of the day, but as discussed in section 3.3.2, Water Resources, these low
DO may only last a few hours. Further, the maintenance events themselves are
temporary. Thus, maintenance and emergency drawdowns are likely to only have a very
minor negative effect on aquatic resources.
Continued operation of the project would result in some unavoidable fish
impingement or entrainment. The existing trash rack with 1 -inch clear bar spacing and
an intake velocity of about 0.45 fps, would help to limit any impingement and
entrainment to smaller and younger fish with slower swim speeds. However, the survival
of smaller individuals is likely to be relatively high because they are less prone to
mechanical injury from turbine passage than larger fish. Smaller fish are also less prone
to injury resulting from shear stresses and rapid pressure changes associated with turbine
passage. Furthermore, the younger individuals in a population generally have high rates
of natural mortality, even in the absence of hydropower operations. Fish populations
have generally evolved to withstand losses of these smaller and younger individuals with
little or no impact to long-term population sustainability. Thus, entrainment and turbine
mortality of smaller individuals could occur, but it is expected to be very low and have
minimal consequences to the sustainability of the fish community at the project.
5.3 FISH AND WILDLIFE AGENCY RECOMMENDATIONS
Under the provisions of section 100) of the FPA, 16 U.S.C. § 8030), each
hydroelectric license issued by the Commission shall include conditions based on
recommendations provided by federal and state fish and wildlife agencies for the
protection, mitigation, or enhancement of fish and wildlife resources affected by the
project.
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Section 100) of the FPA states that whenever the Commission believes that any
fish and wildlife agency recommendation is inconsistent with the purposes and the
requirements of the FPA or other applicable law, the Commission and the agency shall
attempt to resolve any such inconsistency, giving due weight to the recommendations,
expertise, and statutory responsibilities of such agency. In response to our Notice of
Application Ready for Environmental Analysis and Soliciting Comments,
Recommendations, Terms and Conditions, and Prescriptions, North Carolina WRC filed
four recommendations on November 18, 2015, for the proposed project, of which we
determined two to be within the scope of section 100). Of the section 100)
recommendations, we recommend adopting one (table 9).
73

Table 9. North Carolina WRC section 100) recommendations for the Ward Mill Project. (Source: Staff, 2016.)
Recommendation
Agency
1. Develop a sediment management North
plan in consultation with resource CarolinaWRC
agencies, prior to any actions that
involve opening the sand gates,
dredging sediment from the
impoundment, or releasing
sediment from the impoundment,
or releasing sediment from the
impoundment.
Within
the
Scope of
Section
106)
Annualized Adoption? And Basis for Preliminary
Cost Determination of Inconsistency
Nob sod Not adopted. Instead, staff recommends
a sediment management plan that
contains specific provisions to monitor
sediment build-up, determine triggers for
sediment removal, and remove sediment
if necessary.
74

2. (a) Operate the project in run -of- North
river mode, such that outflow Carolina
equals inflow at all times, except WRC
during operating emergencies
beyond the control of the
applicant, and for short periods
upon mutual agreement between
the applicant, North Carolina
WRC, and other resource
agencies.
2. (b) Shut the project down if the North
Carolina
impoundment level drops below WRC
the crest of the dam so that water
can immediately spill over the
dam.
Yes $0C Adopted. Staff recommends that the
project operate in a mode that would be
consistent with North Carolina WRC's
recommendation.
Yes $0C Adopted. Staff recommends that Mr.
Ward continue operating a float gage and
cut-off switch on the turbines so that
generation would be taken off line when
the water level drops below the crest of
the dam.
75

2. (c) Instantaneous run -of -river North
Carolina
mode may be temporarily WRC
modified if required for
emergency situations, necessary
repairs and maintenance, or short
periods agreed upon by Mr. Ward,
the Commission, and resource
agencies.
3. (a) Maintain records of inflow and North
outflow to ensure run -of -river CarolinaWRC
operation and document
maintenance and emergency
drawdowns.
Nob $0C Adopted. Staff recommends that the
applicant develop and implement an
impoundment drawdown and refill plan
that includes this measure.
Nob $325a Not adopted. Staff recommends that Mr.
Ward: (1) continue visually monitoring
flows daily; (2) continue operating a float
gage and cut-off switch on the turbines
so that generation would be taken off line
when the water level drops below the
crest of the dam; (3) file a report with the
Commission if the cut-off system fails,
and/or if the water level in the
impoundment drops below the crest of
the dam; and (4) provide access to 15 -
minute interval generation data from the
utility.
76

3. (b) Install and operate a flow gage North
Carolina
to record inflow to the project, if WRC
the USGS discontinues operation
of gage number 03479000.
Nob $325a Not adopted. Staff recommends that Mr.
Ward: (1) continue visually monitoring
flows daily; (2) continue operating a float
gage and cut-off switch on the turbines
so that generation would be taken off line
when the water level drops below the
crest of the dam; (3) file a report with the
Commission if the cut-off system fails,
and/or if the water level in the
impoundment drops below the crest of
the dam; and (4) provide access to 15 -
minute interval generation data from the
utility.
3. (c) Maintain records of North Yes $13 ga Not adopted. Staff recommends that Mr.
Carolina Ward: (1) continue visually monitoring
impoundment water stage, and WRC flows daily; (2) continue operating a float
make information available to gage and cut-off switch on the turbines
resource agencies. so that generation would be taken off line
when the water level drops below the
crest of the dam; (3) file a report with the
Commission if the cut-off system fails,
and/or if the water level in the
impoundment drops below the crest of
the dam; and (4) provide access to 15 -
minute interval generation data from the
utility.
77

3. (d) Maintain records of project North Yes
Carolina
generation, and make information WRC
available to resource agencies.
$0C Adopted. Staff recommends that Mr.
Ward provide access to 15 -minute
interval generation data from the utility.
4. Develop and implement North Nob $146a
impoundment drawdown and refill CarolinaWRC
management plan in consultation
with North Carolina WRC and
other resource agencies prior to
any actions to lower the
impoundment substantially below
the crest of the dam.
a. Cost estimated by staff.
Not adopted. Instead, staff recommends
an impoundment drawdown and refill
plan that contains specific provisions for
drawdown and refill.
b. Not a specific measure to protect, mitigate, or enhance fish and wildlife resources.
c. Staff estimates this cost would be negligible.
d. We have not assigned a capital cost for these measures because North Carolina WRC did not specify the types of
measures that would be included in a sediment management plan.

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5.4 CONSISTENTCY WITH COMPREHENSIVE PLANS
Section 10(a)(2)(A) of the FPA, 16 U.S.C. § 803(a)(2)(A), requires the
Commission to consider the extent to which a project is consistent with the federal or
state comprehensive plans for improving, developing, or conserving a waterway or
waterways affected by the project. We reviewed seven comprehensive plans that are
applicable to the project. No inconsistencies were found.
North Carolina Department of Environment & Natural Resources. 2000. Sub -chapter
213 -Surface water and wetland standards. Raleigh, North Carolina. August 1,
2000.
North Carolina Department of Environment, Health & Natural Resources. 2000. Water
Quality Progress in North Carolina 1998-1999 305(b) Report. Raleigh, North
Carolina. April 2000.
North Carolina Department of Environment & Natural Resources. North Carolina State
Outdoor Recreation Plan (SCORP): 2009-2013. Raleigh, North Carolina.
December 2008.
North Carolina Department of Environment & Natural Resources. 2005. North Carolina
wildlife action plan. Raleigh, North Carolina. December 2005.
Southern Appalachian Forest Coalition and Pacific Rivers Council. n.d. Protection of
aquatic biodiversity in the Southern Appalachian National Forests and their
watersheds.
U.S. Fish and Wildlife Service. Canadian Wildlife Service. 1986. North American
Waterfowl Management Plan. Department of the Interior. Environment Canada.
May 1986.
U.S. Fish and Wildlife Service. Undated. n.d. Fisheries USA: the recreational fisheries
policy of the U.S. Fish and Wildlife Service. Washington, DC.
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6.0 FINDING OF NO SIGNIFICANT IMPACT
On the basis of our independent analysis, the issuance of an original license for the
proposed Ward Mill Project with our recommended environmental measures would not
constitute a major federal action significantly affecting the quality of the human
environment.
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7.0 LITERATURE CITED
Appalachian Power. 2009. Claytor Hydroelectric Project fish entrainment and
impingement assessment. Prepared by Normandeau Associates, Inc., Drumore,
PA.
Arthur, J. P. 1915. A History of Watauga County, North Carolina with Sketches of
Prominent Families. Everett Waddey Co. Richmond, Virginia.
Barfield, M. L., and E. T. Watters. 1998. Non -parasitic life cycle in the green floater,
Lasmigona subviridis (Conrad, 1835). Triannual Unionid Report, 16:22.
Beamish, F. W. H. 1978. Swimming capacity. Fish Physiology, Vol. VII: 101-187.
Bell, M. C. 1991. Fisheries Handbook of Engineering Requirements and Biological
Criteria. Prepared for U.S. Army Corps of Engineers, North Pacific Division, Fish
Passage Development and Evaluation Program, Portland, OR. Third Edition.
Bergmann, C., and J.M. Swearingen. 2005. Fact Sheet: Kudzu (Pueraria Montana var.
lobata (Willd.)). Plant Conservation Alliance's Alien Plant Working Group.
<http://www.nps.gov/plants/alien/fact/pdf/pumol.pdf> Accessed October 1, 2015.
Cantrell, M. A., C. Goudreau, and F. Tarver. 2014. Ward Mill Dam Hydropower Project
- Run of River Operation.
Corbitt, D. L. 1950. Formation of the North Carolina Counties, 1663-1943. North
Carolina Department of Archives and History. Raleigh, North Carolina.
Cummings, K. S., and D. L. Graf. 2010. Chapter 11: Bivalvia. In J. H. Thorp, and A. P.
Covich (editors), Ecology and Classification of North American Invertebrates.
Academy Press, London, UK.
Electric Power Research Institute (EPRI). 1992. Fish entrainment and turbine mortality
review and guidelines. Prepared by Stone and Webster Environmental Services,
Boston, Massachusetts. EPRI Report No. TR -101231, Project 2694-01. September
1992.
1997. Turbine entrainment and survival database — field tests. Prepared by Alden
Research Laboratory, Inc., Holden, Massachusetts. EPRI Report No. TR -108630.
RE

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2000. Technical evaluation of the utility of intake approach velocity as an
indicator of potential adverse environmental impact under Clean Water Act
Section 316(b). Palo Alto, CA. EPRI Report No. 1000731.
2003. Evaluating the effects of power plant operations on aquatic communities:
Summary of impingement survival studies. Palo Alto, CA. EPRI Report No.
1007821.
Fraley, S. J., and J. W. Simmons. 2006. An assessment of selected rare mussel
populations in western North Carolina following extraordinary floods of
September 2004. Report to North Carolina Department of Environment and
Natural Resources, 33 pages.
Gangloff, M. M. 2013. Effects of Ward's Mill Dam on fishes, mussels, and hellbenders
in the Watauga River, Watauga County, North Carolina. Prepared for Ray and
Virginia Ward, Sugar Grove, North Carolina.
Gardner, A. 2006. Fish passage through road culverts. Master's Thesis. North Carolina
State University, Raleigh, North Carolina.
Google Earth Pro 6.1.0.5001. 2014. Location of the Ward Mill Hydroelectric Project,
Latitude 36° 14'22.71" N and Longitude 81° 49' 35.69" W. Imagery date:
November 7, 2013. Viewed February 3, 2016.
Gryta, J. J., and M. J. Bartholomew. 1983. Debris -avalanche types features in Watauga
County, North Carolina. Carolina Geological Society, Guidebook for 1983
Annual Meeting, pages 53-61.
Homer, C. G., Dewitz, J. A., Yang, L., Jin, S., Danielson, P., Xian, G., Coulston, J.,
Herold, N. D., Wickham, J. D., and Megown, K., 2015, Completion of the 2011
National Land Cover Database for the conterminous United States -Representing a
decade of land cover change information. Photogrammetric Engineering and
Remote Sensing, v. 81, no. 5, p. 345-354.
Harrison, E. T., R. H. Noris, S. N. Wilkinson. 2007. The impact of fine sediment
accumulation on benthic macroinvertebrates: Implications for river management.
In: Wilson, A.L. (Ed.), Proceedings of the 5th Australian Stream Management
Conference. Australian Rivers: Making a Difference. Charles Sturt University,
Thurgoona, New South Wales, Australia, pp. 139-144.
Knapp, W. E., B. Kynard, and S. P. Gloss (eds.). 1982. Potential effects of Kaplan,
Osseberger, and bulb turbines on anadromous fishes of the northeastern United
States. FWS/OBS-82/62. U.S. Fish and Wildlife Service, Newton, Massachusetts.
September 1982. 132 pp.
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Lellis, W. A., and T. L. King. 1998. Release of metamorphosed juveniles by the green
floater, Lasmigona subviridis. Triannual Unionid Report, 16:23.
Mathis, A., and A. Crane. 2009. Saving a giant salamander. IRCF Reptiles and
Amphibians, 16(1):19-23.
Mayasich, J., D. Grandmaison, and C. Phillips. 2003. Eastern Hellbender Status
Assessment Report. Final Report, U.S. Fish and Wildlife Service, Region 3. Fort
Snelling, Minnesota.
Murray, D.E. 1974. A review of literature dealing with the swimming speeds of fishes
of the Lake Erie vicinity. The Ohio State University Center for Lake Erie Area
Research, Columbus, Ohio. Clear Technical Report No. 157.
Nagrodski, A., G. D. Raby, C. T. Hasler, M. K. Taylor, and S. J. Cooke. 2012. Fish
stranding in freshwater systems: Sources, consequences, and mitigation. Journal of
Environmental Management 103:133-141.
North Carolina Department of Environment and Natural Resources (North Carolina
DENR). 2007. Watauga River Basinwide Water Quality Plan. Prepared by
Michelle Raquet. January 2007.
2013. Standard Operating Procedure Biological Monitoring. Stream Fish
Community Assessment Program. December 1, 2013.
North Carolina Division of Parks and Recreation (North Carolina DPR). 2015. North
Carolina Outdoor Recreation Plan. May 2015.
North Carolina Office of Environmental Education and Public Affairs (North Carolina
OEEPA). 2007. Watauga River Basin.
North Carolina Wildlife Resources Commission (North Carolina WRC). 2015. 2015
North Carolina Wildlife Action Plan. Raleigh, North Carolina
2012. Public access closed to a portion of the Delayed Harvest Trout Water on
Watauga River. September 28, 2012.
. 2005. North Carolina Wildlife Action Plan. Raleigh, North Carolina.
2014. Protected Wildlife Species of North Carolina. Raleigh, North Carolina.
February 2014.

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NPS (National Park Service). 2011. Nationwide Rivers Inventory — North Carolina
Segments. Available online at: http://www.nps.gov/ncrc/programs/rtca/nri/
states/nc.html. Accessed July 1, 2016.
Ortmann, A. E. 1919. Monograph of the naides of Pennsylvania. Part III. Systematic
account of the genera and species. Memoirs of the Carnegie Museum 8(1):1-385.
Pezzoni, J. D. (Ed.). 2009. The Architectural History of Watauga County, North
Carolina. Watauga County Historical Society. Boone, North Carolina.
Stephenson, S. L., A. N. Ash, and D. F. Stauffer. 1993. Appalachian oak forests. Pages
255-304 in W. H. Martin, S. G. Boyce, and A. C. Echternacht, eds., Biodiversity of
the Southeastern United States, Upland Terrestrial Communities. John Wiley and
Sons, Inc. New York. 373 pages.
Tennant, D. L. 1976. Instream flow regimens for flush, wildlife, recreation and related
environmental resources. Fisheries 1(4):6-10.
Ward, R. F. (Ward). 2014. Application for license for the Ward Mill Hydroelectric
Project, FERC No. 9842-006. Prepared by Andrew C. Givens, Cardinal Energy
Service, Inc. on behalf of Ray F. Ward, Raleigh, NC. Filed August 28, 2014.
2015. Response to October 30, 2014, FERC Letter Detailing License
Application Deficiencies on the Ward Mill Hydroelectric Project, FERC No.
9842-006. Prepared by Andrew C. Givens, Cardinal Energy Service, Inc. on
behalf of Ray F. Ward, Raleigh, NC. Filed on January 16, 2015.
Wood, P. J., and P. D. Armitage. 1997. Biological effects of fine sediment in the lotic
environment. Environmental Management 21(2):203-217.
Wood, R. K. and D. E. Whelan. 1962. Low -flow regulation as a means of improving
stream fishing. Proceedings of the Annual Conference of the Southeast
Association of Fish Commissioners 16:375-386.
United States Department of Agriculture (USDA). 2001. Soil Survey of Watauga
County, North Carolina. Publication of the Natural Resources Conservation
Service.

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8.0 LIST OF PREPARERS
Adam Peer — Project Coordinator, Fishery Resources, Water Resources, Terrestrial
Resources, Geological and Soil Resources, Threatened & Endangered Species
(Fisheries Biologist, B.S. Biology, M.S. Fisheries Science, PhD Marine, Estuarine,
and Environmental Sciences)
Rachel McNamara — Cultural Resources (Outdoor Recreation Planner, B.A. Public Policy
and Environmental Studies, M.C.P., Land Use and Environmental Planning)
Michael Spencer — Need for Power, Engineering and Developmental Analysis (Civil
Engineer; B.S., Civil Engineering)
Dustin Wilson — Recreation and Land Use (Outdoor Recreation Planner, B.S. Parks and
Recreation Management, M.P.A., Ph.D. Parks, Recreation and Tourism
Management)

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Document Content(s)
P-9842-006Notice5.DOC.................................................1-100