20070812 Ver 2_More Info Received_20090102

OFFICE OF THE COMMISSIONERS AND MANAGER
500 N. Main St., Room 921 • Monroe, NC 28112 . Phone [phone] • Fax [phone]
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December 29, 2008 DO
Mr. John Dorney
Division of Water Quality
Wetland/401 Unit
1621 Mail Service Center
Raleigh, NC 27604-2060
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Re: 401 Water Quality Certification
Yadkin Hydroelectric Project
Dear Mr. Dorney:
As an operator of a public water supply system in the Yadkin-Pee Dee Basin the following
comments are submitted for the record in the matter of the Division's consideration of an
application for a 401 Water Quality Certification for the Yadkin Hydroelectric Project. It is
understood that obtaining issuance of 401 Water Quality Certification is a prerequisite to
issuance of the FERC license to Yadkin, Inc., wholly owned subsidiary of Alcoa. The "Brief of
Stanly County" before the NC Environmental Review Commission in this matter and the "Review
of Data and Proposals Regarding Water Quality in Badin Lake, NC - Risks and Dam or
Hydropower Operations," by John H. Rodgers, Jr., PhD, dated April 29, 2008, served as
reference in the preparation of these comments.
As noted in the Yadkin-Pee Dee River Basin Plan 2008 by NCDWQ, the Yadkin-Pee Dee
Basin is the second largest basin in North Carolina covering approximately 7,213 square
miles. Approximately 33% of the lakes and reservoirs are reported to be impaired. There are
79 public water supply systems in the Basin with "Local Water Supply Plans." By 2050 the
projected water demand for the Basin is expected to exceed 400 million gallons per day. The
"Source Basin" for 33 of these systems is listed as either the Yadkin River or South Yadkin
River.
2. It is clear that the water suppliers in the future will depend heavily on the Yadkin River as a
water supply source and its protection, conservation, and equitable use will be essential for
the health and economic vitality of the Basin.
3. The experience of this region with recent drought conditions and passage of "An Act to
Improve Drought Preparedness and Response in North Carolina," as recommended by the
Environmental Review Commission HB2499, leads to new, intense action toward the
provision of adequate public water supplies and emphasizes the importance of thorough
review of the Alcoa 401 Application by NCDWQ and any modifications or management of
stream flows in the Yadkin by Alcoa.
4. The dependence on the Yadkin as a water supply source by communities downstream of the
Alcoa licensed facility requires a thorough, comprehensive review of potential, negative
downstream water quality impacts of the Yadkin Project's issuance of a 401 Water Quality
Certification especially in view of the extensive data, highlighted and reviewed by Dr.
Rodgers and his assessment of the water quality issues.
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5. As a participant in a new, informal regional working collaboration, the "Yadkin-Pee Dee
Water Resources Association," we endorse the mutual concern of water purveyors in the
Basin that no action be taken by NCDWQ that in any way reduces, encumbers, or prevents
the reasonable and legal use of the waters of the Yadkin as a regional source for potable
water supply.
6. The NCDWQ prior to the final consideration of the issuance of the 401 Water Quality
Certification request a specific study be conducted by the Division of Water Resources to
determine the "minimum safe yield" of the Yadkin Basin and that any action or
recommendations take into account the implications of the minimum safe yield determination
on the conditions imposed on the potential new Alcoa operating license.
Your consideration of these concerns is greatly appreciated.
cc: Scott Huneycutt, Interim Public Works Director