20150759 Ver 2_DWR Draft EA Comments_20160902

Burdette, Jennifer a
From: Tarver, Fred
Sent: Friday, September 02, 2016 2:58 PM
To: Burclette, Jennifer a; Goudreau, Chris J.; '[e-mail]';
I [e-mail]'
Subject: RE: Ward Mill DEA comments
Attachments: DWR comments re FERC P-9842-006 DEA 9-2-16.pdf
See attached... FT
Fred R Tarver III
Instrearn Flow Program Supervisor
Department of Environmental Quality
919-707-9029 office
[e-mail]
Division of Water Resources
1611 Mail Service Center
Raleigh NC 27699-1611
Email corresponclence to and fi`orn thio; address o; sut-Yect to t1he
P,Iodhl Carolina Public Records 'Law and may be disclosed to thloird padfes,

virc ninent ,l
liality
September 2, 2016
Ms. Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
Subject: COMMENTS
PAT MCCRORY
f ime,rnor
DONALD R. VAN DER VAART
`e,cretary
JAY ZIMMERMAN
1>WR Director
Notice of Availability of Draft Environmental Assessment
Ward Mill Hydroelectric Project, FERC# P-9842-006, Watauga River, Watauga Co., N.C.
Dear Secretary Bose:
The North Carolina Division of Water Resources (NCDWR) submits these comments in response
to the Federal Energy Regulatory Commission's (FERC) July 18, 2016 notice requesting comments
on the Draft Environmental Assessment (DEA) for the subject project.
The NCDWR agrees with most of the FERC staff's analysis and conclusions in the DEA. However,
we agree with the applicant's August 23, 2016 comments that a drawdown limit of 1 foot per
day is unnecessary. Natural fluctuations often occur at much higher rates. Also, the referenced
2012 demonstration study showed no significant impacts of a 3 -foot drawdown in just over 3
hours. We believe that since the reservoir is not very deep, the drawdown limit can be
eliminated or set at 6 feet per day. Also, initiating drawdowns when inflow exceeds 50 cubic feet
per second (cfs) while maintaining a flow release downstream of 50 cfs during refill is a
reasonable compromise between the staff's recommendation of 60 cfs and the licensee's
recommendation of 45 cfs in his comments regarding the DEA and will also hasten the refilling of
the reservoir. A flow of 50 cfs is 28.5% of MADF where 30% represents Excellent and Fair using
the Tennant Method (see Table 4 of the DEA).
Finally, Page 3, Section 1.2.2 of the DEA states that "[t]he Ward Mill Project provides power for
Mr. Ward's adjacent saw mill, with excess power being sold to the Blue Ridge Electric
Membership Cooperative...." It's questionable whether milling is still active at the adjacent mill
given the following quote from the applicant's 2011 pre -application document (PAD):
"The operation of the project has had a positive impact on the socioeconomic
development of the region through the production of sawed lumber and ground grain in
State of North Carolina I Environmental Quality
1611 Mail Service Center I Raleigh, North Carolina 27699-1611
919-707-9000

Ward &4iU DEA (FERC#P-9842-005NQ September 2, 2016
NC Division of Water Resources
the past, and the production ofpower and now Renewable Energy Certificates from the
power generation today."
Thank you for the opportunity to comment. If you have questions, | am available by phone at
919-707-9029, or by email at [e-mail].
Sincerely,
Fred RTarver,III
Basin Planning Section
cc: Jennifer 8urdet e NCOVVR'401
Chris Goudreau NCVVRC
Bryan Tompkins USFVVS
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