20080299 Ver 1_Public Comments_20080714

A American Rivers
Thriving By Nature
irs
July 11, 2008
Cindy Karoly
NC Department of Environment and Natural Resources
Division of Water Quality
2321 Crabtree Blvd; Suite 250
Raleigh, NC 27604
Dear Ms. Karoly:
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We urge you, in your consideration of the Linville Land Harbor dam reconstruction
permits, to use your regulatory power to assure that this once in a life time decision
weighs all the options and provides that community with the resources that they truly
desire.
The dams built on the Linville River during the 20th century served critical purposes but
are now at the end of their expected life spans, including the Linville Land Harbor dam.
The requirement from North Carolina Dam Safety that this dam be appropriately
mitigated left the community with two perceived choices: remove the dam and rebuild to
keep the lake resource that Linville Land Harbor is known for or remove the dam and
restore the river to the natural resource it once was.
The Linville River was one of the premier cold-water fisheries in western North Carolina,
including brook trout and brown and rainbow trout, before the dams were built along it.
These dams and other development throughout the watershed have negatively impacted
water quality and quantity to the detriment of the communities that value the fishery and
other wild life impacted. There are sections that are still pristine supporting towns and
people that flock to the river from all over the region and country to fish and enjoy the
cool waters.
American Rivers has been working with communities all over the country for the past
fifteen years wrestling with the question of what to do with dams that have become a
burden. Working through the process of what is the most valuable asset for each
community can be a painstaking process but, if proper consideration is given the
community can usually develop an outcome that meets their needs economically,
environmentally, recreationally, and provides adequate safety.
The community of Linville Land Harbor is faced with just such a dilemma. Originally,
the leadership had chosen to stick with the status quo that easily preserved the values that
had supported the community. However, as other members of the community became
aware of the dam replacement plan, interest in alternatives appeared. The leadership of
the community pledged to let this investigation go forward while still needing to meet
state requirements.
1101 14th Street, NW, Suite 1400 p 202.347.7550 www.americanrivers.org
Washington, DC 20005-5637 f 202.347.9240
The alternative developed to the original replacement plan presents an innovative plan
that meets the various values of the entire community (preserving the recreational lake
and restoring the main stem of the Linville River), seems to satisfy regulatory
requirements, and is more consistent with the goals of the Federal Water Pollution
Control Act and the North Carolina Water Quality Act. This proposal would build a levee
that maintains a significant portion of the current recreational lake, removal of the current
deteriorating dam, and restoration of a free flowing Linville River. This proposal requires
additional investigation, but initial surveys expect that with adequate engineering it
would be feasible and less costly than the replacement plan.
We urge you to use your full regulatory powers as you review the proposed dam
reconstruction permits to make sure that the interests of the entire community are met and
that dam reconstruction will not proceed until the residents and property owners of
Linville Land Harbor have had a full opportunity to consider all alternatives.
Thank you for your consideration of these comments.
Sincerely,
Peter Raabe
Southeast Director of Government Relations
American Rivers
Durham, NC
Cc: Tracy Davis, Hubbert Hawkins