Appendix C_20170421

T� DUKE
ENERGY.
Paul Draovitch
senlor vice-Presloen,
EnAran,l4antal, Flvofth & 5a1aty
525 Soeth (3113M5 511rQwt
Mall cme RU3AP
CR..rlana, NC z8zOz
704-373-0408
February 23, 2017
Mr. Jay ,cimmerman
North Carolina D-Wpartment u-f Enviru, n i.ental Quality
Division of Water Resources
1611 Mail Service Center
Raleigh, North Carulina 27699-1611
S..b�e%t: RI-zzpunae to February 15, 2017 letter and February 21, 2017 phone call
Dear Mr. Zimmerman:
Duke Energy appreciates NC DEQ's responses to the questions Duke EI 1e1 gy pused or 1
January cu. &0 1 r and your willingness to Qi5Cu5s these items with me in further detail on
February 21, 2017. Tu cnacrz that Duke Energy ende otan& NC DEVu i, iterpretaltion of the
alternative water supply pruvisions of Huase Bill 630- we regaest clarification un a few
alltlitional items.
1. The proposed plana submitted in Decamber 2016 stated "wall uvvnEra will be making
decisions for their plans." Also, in an email from Ms. Debra Watts to a humeowner within the
Yz mile boundary on January 26, 2017, NC DEu stated -...the General Statute that we are
fulN.r.r'ng directs Duke tv nut;fy each ivell oriner to let the,,, know that they are p,opus;ng as
an alternative water supply. h also Braced that 'Nothing in [the stature] swan ve construes ra ri)
require an eligible household to connect h-, a public ..rater supply er recerva a frlt,atim,
system...' The Department has ititerprated this to say that the well owne, has a choice of
what they receive."
Duke Energy has received numerous questions from homeowners who receive their water
from a well not owned by them i.e., they re..elve th-Vir ..rater from a ne;ghbur;s well or from at
cummun;ty well system, Bach as the Aqua system in Belmont). The aforementioned email
frum Ms. Watts, which was in response to a concern raised from an Aqua customer, also
atatlzd "Since Aqua ;a the ..ell ov..,,vu a„d will make the final &wV;s;on, 1 would , eCD,,,,,,end that
you Co„ tact then„ to let them know of your desires."
Doke Energy requests confirmation of NC DEQ's interpretation that Haase Bill 630 vests Well
owners with the decision -making authority as to the permanent water supply uptivn sulluctud,
and that as a raselt the .,,-0II-uvvner's deu;siun applies to any household that utilizes Bach
well(b) as a drinking water source.
2. In NC DEQ's Pelsraary I a letter; it states: -... if a property is vacant rix. na cr►c ;a U.,n-ently
Irving them) but they have a ..all on the property when the act beca,r,a effeCtive, they at
eligible fur a,t alten,ate water supply."
tube 1 01 1

There are different types of "vacant" properties. "Vacant" can mean:
a) A pay col of land that has both a huu5Ehuld um it and a vvulI um it, but the huu5ehvld 15
currently unuccupiud;
b) A par�.al of la, id that has a vveH on ;t and no household present on the parcel itself,
but were the well serves households on an adjoining parcel of land (i.e.. the Aqua
:.ornieznity supply ay -.turn in BuIrnurit);
c) A parcel of land that has a well on it and no household present; and the well [foes nor
Service any househvld5.
Duke Energy aurcuz that acunaric (a) ;� covzr-.;d by Huna—W Bill 630. Arguably scenario (b) is
not covered by House Bill 630 because the legislation states a preference for "connection to
public water 5upplie5" anti Rou5eRol05 servetl ey Hqua are alreacy connected to a public
vvater supply aubjuact to State and faderl regulation. Huvvsver, Duke Energy has L zluded the
Aqua households served by groundwater we115 within the half -mile in its permanent water
supply plans in order to provide peace of mind to these plant neighbors. The reason we
posed the question in our January 20, 2017 letter vva5 to ask for clarification regarding
scenario (c). The definition of "household" is "those who dwell under the same roof and
cormpusu a family" ur -aa SvUial unit cumpused of these living tuguther in the sarmu
dwelling." Therefore, where it states ii i House Bill 630_ Section , 9: "Requirements for
e5tal71isRment of a permanent alternate water supply under GS 130A-309.L i i (c i), as enacteu
by Sactiun 1 of this act, shall apply only to huu5ahuld5 with dri, king water supply -voila in
existence on the date this act becomes effective." it is clear to Duke Energy that only
households are covered, , got vacant lute vvith vv,lls luuatUd un thum, buuanue the vacant lots
do i lot have a hou5ehold a,, them. We would like NC DEQ'5 confirmation Uf this
interpretation.
3. One of the rewuifUrnunta ;n Huusu Bill 630 15: "No later than April 15, 2017, an
impoundment owner shall notify all re5ident5 identified in the approved plan of their eligibility
for establishment of a permanent water supply." Dune Energy Ras notifieu all resiiaents
identified in the approved plans thruugh u�, December 2016 mailing, January 2017 mailing,
and through the February 2017 community information 5es5iun5. Duke Energy reque5t5
acknowledgement from NC DEQ that the company has met this requirement of the house bill.
Of cuurse, if additiunal households are identified a5 being covered by House Bill 630 in the
future, we will communicate eligibility with them at Mat time.
4. Although we understand NC DEu's positiun that nun-nuupunsivv- vvull owners are not opt;ng
out of the offered optic, 5, Doke Energy does want tv en5ure that it can move forward with
providing hou5ehala5 witR Mair permanent solution in a timely manner; and in such a way that
will meet the cumpletiun dates in Huose Bill 630. Nun-reapvnsivc homeowner may alsu
affect the cast -effectiveness evalQation fur new municipal lines. We have requested that
homeowners provide their sw-luctiun5 by March 15, 2017. After that date, Duke Energy will
provide NC DEQ an update on the 5electioi-i 5- including the f umbet of households that have
been non-re5pon5ive. vve icolt forward to having a discussion with you at that time on how
Bun-respunsive houaeholda Should be trcatud in light of the October 15, 2018 completion date
in the house bill.
rage z of 1

vve I0OR rarward is your respond ant] it you Dave comments and/or questions, please direct
thUm to mu at 704-373-0408.
Sincere
Pa I Drauvitch
Senior Vice -President
Environmental, Health & Safety
Michael Raga.. — Sucretary, NC DEQ
Sheila Holman — AssibLam SecrLary, NC DEQ
Jessica Bednarcik — Duke Energy, EHS
Y..sc ti el ,i