20091002 Ver 1_Other Agency Comments_20091006

North Carolina Wildlife Resources Commission 9
Gordon Myers, Executive Director
MEMORANDUM
TO:
FROM:
DATE:
SUBJECT:
Monte Matthews, USACOE
Raleigh Regulatory Field Office
Ron Linville Regional Coordinator ZOW
Habitat Conservation Program
October 2, 2009
OCT •6 2009
WETLANOS AND ST EORMW EIR @RANCN
Wilkesboro Hydropower, LLC - W. Kerr Scott Hydropower Project, NCDWQ
No. 2009-1002, Yadkin River, Wilkes County
Wilkesboro Hydropower, LLC proposes to use waters released from the W. Kerr Scott Lake dam
and impoundment to produce electrical power. Biologists with the North Carolina Wildlife
Resources Commission are familiar with habitat values in the area. These comments are
provided in accordance with the provisions of the Fish and Wildlife Coordination Act (48 Stat.
401, as amended; 16 U.S.C. 661-667d) and the North Carolina Environmental Policy Act (G.S.
113A-1 through 113A-10; NCAC 25).
The proposed project is indicated to include an intake structure with trash rack, a new power
house with two (2) power generating turbines, a bypass liner to be installed in the existing
discharge conduit, penstock, discharge channel, power substation and transmission line
modifications. The project is indicated to be a "run of the river" operation despite the fact that
the water used is impounded.
Based on a very preliminary review by this agency, it appears that a) the power house may not
affect a public fishing platform in the vicinity, b) the flow regimes are not confirmed or
established fully, c) the intake design/operation may meet North Carolina Wildlife Resources
Commission (NCWRC) intake standards, and d) the only new channel modifications may be a
concrete discharge apron to the existing tailrace.
Although the application provides a narrative description of the proposed power generation
improvements, no site maps, plan views, or engineering designs were included in the Clean
Water Act Section 404/401 application copy received by this office. We are concerned that this
Mailing Address: Division of Inland Fisheries • 1721 Mail Service Center • Raleigh, NC 27699-1721
Telephone: [phone] - Fax: [phone]
W. Kerr Scott Hydropower Project Page 2
October 2, 2009
application has been requested prior to Federal Energy Regulatory Commission (FERC) design
and operation approvals have been obtained. Based on the lack of FERC approvals and the lack
of specific design and operational information, we are not able to properly evaluate this
application request. Accordingly, we recommend that any Section 404 and Section 401
permits/certifications be withheld or held in abeyance until FERC approves the power generation
facility and additional detailed engineering and site information is provided.
Thank you for the opportunity to review and comment on this project during the early planning
stages. If you have any questions regarding these comments, please contact me at 336-769-9453.
E-copy: Sue Homewood, NCDWQ-WSRO
Becky Fox, USEPA
Chris Goudreau, NCWRC
Cc: Cyndi Karoly, NCDWQ 401 Certification Unit