"DO THE RIGHT THING"

Do you believe the hype that Alcoa's proposal for the future operations of High Rock Lake is an improvement over the past.  If you do you have fallen directly into the complacency trap APGI was hoping for.  In reality it is nothing more than a new way of saying "Operate High Rock Lake almost EXACTLY as in the past" and the shortcomings of this scenario are many.  If you compare their proposal to the historical lake level averages of the past 20 years you can easily see that the only improvement is about a foot during October.  In exchange for that foot you could be giving up almost 2 feet in May, June and July. The 4 foot range offers no protection to the important wetlands and only guarantees 33% of the High Quality fish habitat will actually be under water.  The 10 foot winter drawdown makes all but three of the Public Access Areas and almost ALL of the 2722 privately permitted recreation facilities (piers) unusable during this time.  It makes thousands of Acres of the lake either completely dewatered or unsafe for boating as shown in this CONTOUR MAP.  APGI creatively contends this scenario does not KILL beneficial aquatic vegetation at High Rock, it has simply PREVENTED it from ever being established.  The historical operation has proven to produce excessively long water retention periods during many parts of the year.  This causes nutrient loading and dissolved oxygen problems as water temperatures rise and has resulted in High Rock Lake being officially declared "Impaired" by  the NC Dept. of Environment and Natural Resources.  The practice of capturing large quantities of sediment laden water allows the suspended sediments to settle out and has effectively reduced the depth of some portions of the lake by more than 10 feet. Nearly 40 of operating High Rock Lake using these guidelines has proven it to be a failure unless your goals are to:

  • PREVENT beneficial aquatic vegetation from growing

  • Offer little to no protection of the wetlands and High Quality fish habitat

  • Collect sediment

  • "Impair" one of the largest lakes in NC

  • Make recreation totally unsafe for up to one third of the year

  • Keep local boat and prop repair businesses busy

  • Maximize shareholder returns.



 

Based on several factors that our Agency Representatives were NOT willing to compromise on, you need to consider several things when you analyze their proposal.  First, due to the lessons learned from the drought of 2002, the new license will contain a very strict "Low Inflow Protocol" that will protect the entire river system during periods of severe drought.  Consequently, the operating guide will not be used to manage lake levels during the times that the LIP has been triggered, only during "normal" flow conditions.  Second, in an effort to create a more natural river flow regime below the impoundments, the discharge requirements for the project will change from "Weekly Averages" to "Daily Averages".  This means that downstream flows must be released on a daily basis, effectively ending the practice of closing the dams for 2 or more days each week and capturing all of the incoming water for use only during the more lucrative "On Peak" periods.  This new delivery scenario will not significantly decrease the amount of power generated.  It will simply shift some of that power generation to "Off Peak" times.  A side effect of this reduced "capture period" is it should result in a reduced need to maintain lower lake levels.  If you are only allowed to capture water for less than 24 hours, you only need to reserve enough room to hold 24 hours worth of inflow.  These facts combined with the recommendation of EVERY scientific study completed graphically demonstrate that higher more steady water levels are the RIGHT thing to do and unreasonably low limits are neither required nor beneficial to the watershed.

In comparison, we offer our counter proposal for the future operation of High Rock Lake.



 

As you can see it would truly be an improvement in many ways.  The slightly higher levels from April through October would necessitate shorter retention periods and encourage a more frequent flushing of contaminants from the lake.  Beneficial aquatic vegetation would be allowed to grow and flourish just as it does in every impoundment below High Rock. Both of these factors would contribute to improving water quality IN High Rock Lake.  The aquatic vegetation is identified in the Shoreline Management Plan as being the PREMIER fish habitat.  The 3 foot operational range would allow sufficient capture space (45,000 Acre Feet) for almost an entire additional week of average generation (with absolutely NO inflow) and some portion of extremely high flow events would be passed downstream to perform the beneficial scouring of the river basin.  At least 50% of the High Quality Fish habitat would remain under water at all times, additional habitat would be created as vegetation began to emerge and it would offer more protection of the important wetlands.

Limiting the winter drawdown to NO more than 6 feet would provide nearly 85,000 Acre Feet of capture space which would be only slightly less than the historical operations of the past 20 years has provided.  It would allow at least 5 of the Public Access Areas and most of the 2722 privately permitted recreation facilities to remain usable and continue to provide recreational access to the lake.  Operation at this level would also dramatically improve recreational boating safety during the winter months.

The downstream flow regime preferred by river advocates is to approximate a natural unblocked river flow as closely as possible and for high flow events to be passed through the reservoirs to allow for beneficial scouring of the river basin.  This allows suspended sediments to travel much further downstream before settling out into the river bed.   Higher lake levels at High Rock would dramatically reduce the retention period of the water being captured in the lake.  Common sense dictates and scientific studies confirm that moving water is less likely to experience low Dissolved Oxygen problems, nutrient loading or dangerously high temperatures.  All of the lakes downstream of High Rock are comprised almost entirely of water coming from an "Impaired" source but do not experience the same problems as High Rock since the retention period of the water is much shorter and it flows out before adverse conditions are allowed to develop.  This alone is a testament to improving water quality IN High Rock Lake by keeping the retention period to a minimum.

All of these improvements can be accomplished at a minimal expense.  Using the best publicly available information we could find, we estimate the cost differential between the AIP proposal and our proposal at a little more than $300,000 annually.  Again, this is mostly due to the shift of power sales from the "On Peak" periods to the "Off Peak" periods, NOT in lost generation capabilities.  IF you accept APGI's contention that they expect to operate the lakes at least one foot above the curve to allow them to "Chase Peaks" then you could reduce the 3/6 proposal to a 4/7 proposal.  We estimate this would result in a cost differential of less than $150,000 annually while still maintaining all of the benefits above.   This is a tiny amount to a company generating tens of millions of dollars of profits every year from the FREE use of our natural resources.  In reality it appears to be less than 1% of their annual profits.  To put everything into proper perspective, $300,000 is the equivalent of ONE APGI management person with benefits or approximately 20 CENTS per recreation day documented at High Rock Lake.

Finally, one only has to look at the communities surrounding Lake Norman to witness the economic boost a WELL MANAGED Hydroelectric impoundment can produce.  They are growing exponentially and property values are VERY high.  The electricity generated by Alcoa's facilities is NOT a part of the generating capacity used by the Public Utilities serving the citizens of NC directly impacted by the operation of the project.  In fact since the smelting plant at Badin has closed Project 2197 contributes almost nothing to the local economy.  The TRUE value of the project to the citizens of the surrounding communities is in the tourism and tourism related jobs created by the lakes.  Appropriate management of High Rock Lake to protect the environment would result in enhanced recreational opportunities, increased employment, increased sales tax revenues and increased property values.  These improvements all equate to significant economic gains for Davidson and Rowan Counties.

Now it's up to YOU to "Do the RIGHT Thing".  You owe it to yourself and your community to review our FACTS  and  REALITIES OF HYDROPOWER RELICENSING pages and then attend one of the upcoming SCOPING MEETINGS.  Encourage the Federal Energy Regulatory Commission to adequately consider the unique properties and problems of High Rock Lake and "Do the RIGHT Thing" by demanding IMPROVED protection of the environment in the ENTIRE Yadkin-Pee Dee watershed, not 50 more years of the same problems.  Encourage them to insure public safety and protect the recreational opportunities at one of the largest lakes in NC.  Remind them the Federal Power Act does not require them to guarantee ANY level of profit to the licensee.  They are however required to honor the terms in the Environmental Policy Act and the Electric Consumers Protection Act of 1986.  Simply ask them NOT to treat High Rock Lake "Special", just treat it "Equal" to the rest of the lakes in the project.
 

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Last modified: January 05, 2011