Thoughts and Comments Of
The High Rock Lake Association Inc.

from Review of Alcoa’s
INITIAL CONSULTATION DOCUMMENT
For Current FERC Project # P-2197
Issued September 2002

According to our understanding of this document, FERC must give equal consideration in the License process to the following issues:

We have reviewed this document hoping to find a balanced presentation of all factors to be addressed during the Licensing Process.  We believe there are deficiencies in certain areas of the document.  The comments that follow address our concerns.  Since the stated purpose of the Initial Consultation Document (ICD) is to “provide a common base of information” for the license application process, we request that revisions be made to the ICD which incorporate data needed to answer the comments and remarks following:  

HYDRO POWER OPERATIONS

We understand this document is to serve as a “current snapshot” of the Project, therefore it is very disappointing that this document does not provide any real insight on Alcoa’s power production management practices, or provide insight on consideration of the above listed factors that guide Alcoa personnel in day by day decisions that determine power production levels and the resulting effect on each of the project lakes.

In the Introduction Section 1.0 the wording has apparently been carefully crafted to give a casual reader the impression that power produced at High Rock Lake and the other three Project dams is for the purpose of providing energy to Alcoa’s aluminum smelting facility at Badin NC.  Investigation of the uses of hydro power produced at this Project reveals Alcoa entered into a five (5) year agreement beginning October 1, 2000 to sell all power produced by the four hydro power facilities to Aquila Energy Marketing Company.  These details are found on page 123.3 of the 2001 Annual Report filed with FERC.  We are concerned as to why the ICD does not deal forthright with the conversion of FERC Project P-2197 from the role of supplying power to Alcoa owned factories which used to provide substantial employment locally, to that of a wholesale electrical power producer selling electricity for interstate consumption.

The ICD mysteriously omits any explanation of operation of the lake during the summer of 2002.  Alcoa has never provided any creditable explanation of the draining in May, June, July, and August 2002, and we believe full disclosure of management decisions leading to the draining must be disclosed during the Relicensing study. 

This document of over 200 pages only addressed Power Production on about 7 pages and about half of those were spent addressing the Rule Curve for High Rock (which was apparently ignored this past summer).  We feel much more attention must be focused on the OPERATION OF THE LAKES, for without much better regulation of resulting WATER LEVELS and WATER QUALITY; the other issues are purely academic and coincidental.

The ICD describes a process to resolve License Application issues before the Application is submitted to FERC, and the process involves issue/dispute resolution by Issue Advisory Groups (IAG).  We are troubled that documents and notices issued to date do not include LAKE OPERATIONS as an issue planned for IAG Group participation.  Please add an IAG group to address Lake and Powerplant Operations.

The following ICD article’s should be reviewed and edited for clarity and/or accuracy:

ENVIRONMENTAL QUALITY AND RECREATIONAL OPPORTUNITY.

We understand Alcoa’s primary obligation is to show a ROI to its stockholders, so Power Production is understood to be Alcoa’s primary consideration in obtaining a new license.   We also trust Alcoa management understands the public users of High Rock Lake are more concerned with the other issues; especially Environmental Quality and Recreational Opportunity.

After nearly a century of existence, the two major lakes in this Project, Badin and High Rock, have become quasi-public facilities.  In 1958 the Federal Power Commission granted a very long term license to allow Alcoa to completely amortize its investment. It’s now time to allow public interests be fairly considered, and FERC must issue a license which requires High Rock and Badin Lakes to be operated  in a manner that provides for all interests, not just the interests of Alcoa.

The categories currently identified as IAG Issues seem to be addressing only those issues presently covered in excruciating detail by Alcoa’s Shoreline Management Plan (SMP).  This indicates the present SMP will terminate with the present License, and be replaced by a new SMP.   Any new SMP must be responsive to the needs and desires of users and property owners around the lakes, and must certainly be more “user friendly” on the issues that were hotly debated in the Nineties when Alcoa decided to implement a SMP.  These issues include the current highly restrictive Alcoa regulations for:

Alcoa should adopt guidelines that are in keeping with other lakes in North Carolina, such as those owned and managed by Duke Power Company and CP&L.  Any shoreline management plan that is a part of the 2008 License should be no more restrictive than similar projects.  Any restrictions should be limited to issues that have a demonstrated direct impact on Alcoa’s hydro power production.   Policy on issues affecting privately owned land surrounding the Project Lakes should be left to the many local, state, and federal agencies charged with administering laws and regulations on land use, watershed protection, environmental and cultural issues; and Alcoa should not try to incorporate or assume responsibility for those issues under terms of its FERC License.

PROJECT DESCRIPTION and BOUNDRIES

The following are comments specifically directed at certain portions of the ICD that might misrepresent factual information to readers not intimately familiar with the Project lakes and surrounding lands:  

General Suggestions

We ask that Badin Lake be identified in future documents by its universally recognized name, not Narrows Reservoir.  Many people tend to confuse Narrows with that narrow stretch of river called Falls Reservoir.  Practically all published maps identify this lake as Badin Lake, as do road signs, real estate listings, etc..  Even the ICD makes many references to “Badin Lake….”.   This would help eliminate confusion and misrepresentation.

During the study period, Alcoa could enhance public understanding of Project operation by providing more data on the web site.  For example, the web site provides links to USGS river flow stations, but simply looking at river flow data at the few available flow monitoring stations does not provide a true picture of inflows to the Project lakes. We think Alcoa should post data showing total inflow and discharge rates for each lake on a real time basis; in addition to the currently posted lake levels.

We suggest an independent 3rd party selected by FERC be used to record actions and discussions for each of the IAG meetings.  Such an independent recording of proceedings would dispel feelings that still exist from SMP “user input sessions” in which many suggestions, concerns and objections were never recorded; but the final work product was represented as a “consensus from all stakeholders”.

We request the addition of an issue study and complete engineering/revenue analysis for operation of High Rock Lake as a Run-of-River facility, just like the other three (3) project lakes, and like the two CP&L lakes downstream of this Project.

This review and comment document was discussed and endorsed by the Board of Directors of The High Rock Lake Association during its regular Board meeting Wednesday, January 08, 2003.

Respectfully Submitted,

High Rock Lake Association Inc.

Larry O. Jones
President

e-mail: larry@foxhollowfarm.org

phone: 704-637-6264
fax:      704-630-1174