Alcoa was given the right to use the Natural Resources belonging to the citizens of North Carolina in exchange for the positive economic benefits to the surrounding communities as a result of the employment of hundreds of North Carolinians. The power generated by the project offset the huge demand of the aluminum smelting operation and kept the local public utilities from having to build new generating facilities at the publics expense.
In 1968 the High Rock Operating Guide Curve developed by Alcoa appropriately included staged cut backs in generation as lake levels fell and proclaimed this to be a huge benefit to the river system and recreation at High Rock Lake. Unfortunately only Alcoa knew the defined cut backs would be completely inadequate to protect the aquatic environment at High Rock Lake when they coupled it with the undisclosed changes they made to the Headwater Benefits Agreement with Carolina Power and Light.
Alcoa's practice of extreme winter drawdowns at High Rock Lake has prevented the establishment of beneficial aquatic vegetation such as water willow. This type of vegetation is prolific at the other project lakes and would be a significant factor in improving the water quality at High Rock. This practice also compounds the sediment problems at High Rock by capturing sediment laden water and allowing the suspended sediments to settle out of the water instead of flowing through the dam and carrying the nutrient rich water downstream.
APGI graphically demonstrated during the drought of 2002 that they will not voluntarily "Do the Right Thing" and that corporate profits are their first priority. While they cited the Headwater Benefits Agreement with Carolina Power and Light as the cause, section III (Page 3) and section VIII (Page 8) of the agreement actually includes clauses that allows them to modify the terms by simple agreement between the two companies and recognizes "Dry Weather" as a valid reason to suspend enforcement of the agreement.
Badin (Narrows) reservoir and High Rock Lake are both designated as "Store and Release" facilities but always kept Badin (Narrows) near full pond while routinely fluctuating High Rock as much as 15 feet. Alcoa has always claimed that it was necessary to maintain Badin (Narrows) reservoir near full pond due to the large drop in generation efficiency as lake levels decreased but stated that a similar drop in efficiency did not occur at High Rock Lake. Based on the head verses capacity curves submitted to FERC on 10/13/06 this is not true. The curves indicate a loss of capacity at Badin (Narrows) at a rate of .66 mw per foot versus a loss of .6 mw per foot at High Rock Lake. This amounts to a miniscule differential of only .06 mw per foot between the two reservoirs and would be effectively irrelevant. Since High Rock Lake is effectively three times larger than Badin (Narrows) it would be more productive to maintain the larger reserves at High Rock which would allow longer generation periods on a per foot basis while maintaining a significant water reserve to protect the remainder of the river system.
The Yadkin River is commonly known as the "Worst Managed" watershed in North Carolina.
Since APGI's current license was issued, the Congress of the United States has passed two significant pieces of legislation that Alcoa has been "Grandfathered" from and has not been required to honor. These Acts are the direct result of mismanagement of our natural resources by many companies for the sake of corporate profits. APGI is no longer exempt from the terms of the Environmental Policy Act and the Electric Consumers Protection Act of 1986 and it is the direct responsibility of FERC to see that any new license terms strictly conform to the INTENT of these Acts.
Alcoa has closed their aluminum smelting operations at Badin NC. APGI employs only a handful of people in NC now and contributes very little to the economies of the surrounding communities. The power generated by APGI's hydroelectric facilities is now simply excess capacity that the local public utility companies are required to purchase whether they really need it or not. These Public Utilities (Duke Energy and Progress Energy) operate large networks of fossil fuel, nuclear and hydroelectric power generating facilities as well as constructing and maintaining extensive high availability power distribution systems in the interest of the citizens of North Carolina. They provide direct high value employment to thousands of North Carolinians across the state as well as tens of thousands more indirectly through contract and supplier services. They provide these services economically to the public while operating under the terms and conditions of the NC Utilities Commission. One of the most significant restrictions placed on these companies is the 12.5% rate cap that limits their profits and protects the citizens of NC from opportunistic price gouging. This also encourages them to provide the necessary stable base load capabilities from their fossil fuel and nuclear facilities while using their hydroelectric facilities to provide load following (peaking) capacity. Since hydroelectric facilities can be brought online in just a few minutes and shut down just as quickly, this is the most prudent use of hydroelectric generation. This operating scenario is what allowed Progress Energy to keep Lake Tillery nearly full while High Rock Lake was being drained in 2002. It also allowed Duke Energy to manage the Catawba Chain of lakes in a manner that kept them reasonably full and resulted in FERC commending them on their management of the system during the worst drought ever experienced in North Carolina. Since APGI has no other source of electricity to sell and their profits (averaging well over 200% per year) are not regulated by the NC Utilities Commission they are seeking new license terms that will allow them to operate their hydroelectric facilities at their highest possible capacity for the longest periods possible instead of in the more suitable load following manner. This may be good for corporate profits (which are all sent to the parent company out of state) but is certainly not in the best interest of the of the river system or the citizens of North Carolina. With the closing of the Badin smelter the only real value of the APGI Yadkin project to the citizens of the communities surrounding it is in the recreation and tourism industries.
The High Rock Operating Guide proposed in the Agreement in Principal extends
the "Recreation Season" (as defined by APGI) and is being promoted by APGI as a
huge improvement over the past with significant improvements for fish, wildlife,
environment, water quality and recreation. The new guide does away with
all of the hocus pocus curves and generation restrictions as lake levels fall
and simply sets a lower limit on lake levels for each month. This is the same
story Alcoa told in 1968 when they developed the current Guide Curve with its
maze of lines and corresponding rules that virtually no one outside of the
Hydroelectric power industry could understand. Only THEY knew the restrictions
were basically "smoke and mirrors" and it would be almost impossible for them to
be found in violation of the rules. If you look at our
comparison of the NEW Operating
Guide to the Historical High Rock Lake levels, you will see that the new
proposal is little more than a request to continue operating High Rock Lake
almost exactly as they always have. The difference now is there are
absolutely NO restrictions on generation/discharges as lake levels fall to the
defined minimums and nothing to regulate the maximum allowable fluctuations
daily, weekly or even monthly as found at many hydroelectric developments.
There is an adage used in business management training that states:
If you always do what you have always done
You will always get what you have always gotten
For most businesses this is a bad thing and is used to emphasize that if your business doesn't change and adapt to the times, it will not grow. However in the hydropower generation business nothing is more desirable than to be able to continue operating in the same fashion as you have for more than half a century. If they are allowed to do what they have always done, we already know what we will get!! The new guide includes an allowable winter drawdown of approximately 62% of the average depth of High Rock Lake even though there was NOT A SINGLE STUDY that supported the need for a winter drawdown other than APGI's desire to continue the practice. We have not been able to identify any other Hydroelectric development that includes an operating guide recommending drawdowns anywhere near 50% of the average depth of the reservoir.
High Rock is unique in several ways that require
special consideration. Overall it is a very large but relatively shallow
impoundment. The unregulated water flowing into High Rock
is very nutrient rich and sediment laden. These four factors combined contribute
greatly to its impaired status. Dingy, shallow and slow moving water warms up
much more rapidly than clear or rapidly moving water so High Rock reaches
critically high temperatures earlier in the year than any other place in the
river system and maintains those higher temperatures for a longer period of
time. Warm nutrient rich water promotes higher levels of algal growth which
cause dissolved oxygen problems causing stress on the fish population and
ultimately resulting in fish kills. The need to continue the historical practice
of "Winter drawdowns" is NOT supported by any scientific study. It promotes
longer retention periods for the water captured and the fallout of suspended
sediment in an already sediment laden lakebed. This compounds the nutrient
loading problems. Interestingly enough, the most
beneficial operating scenario is NOT to treat High Rock Lake special, but to
manage it exactly the same as the other reservoirs in the watershed and
keep it reasonably close to full. This encourages sediments laden waters to pass
through more quickly with less fallout and pushes nutrient rich waters out of
the lake faster. Maintaining all lakes in the project within 3 foot of full pond
on a year round basis provides the closest mimic of natural river flow
throughout the watershed. Higher head elevations provide higher total power
output from the generators. It would allow beneficial aquatic vegetation
to be established in High Rock Lake while producing the shortest water retention
period. Both of which are beneficial to improving water quality directly
in the lake.
High Rock Lake is no longer a remote collection of weekend get-aways and fishing shacks as it was in the 1950s. It is less than an hour away from no less than four of North Carolinas largest cities and dozens of smaller cities such as Lexington, Salisbury, Asheboro and Thomasville. It is a highly valued tourism destination and has become the equivalent of a bedroom community for thousands living around High Rock and commuting to these cities on a daily basis. These waterfront homes and lakeside communities represent the most highly valued property in Davidson and Rowan counties contributing millions to the counties tax base. Annual recreational use of High Rock Lake was documented by the Recreational Use Study at approximately 1.48 million recreation days. Approximately 1.4 million of these Recreation Days were attributed to use via approximately 2800 privately permitted and commercially licensed facilities belonging to High Rock Residents, businesses, organizations and lakeside communities. The remaining 80,000 recreation days of usage were attributed to the 13 public access areas. At the proposed 10 foot winter drawdown only 4 of the public access areas remain usable and nearly all of the private and commercial facilities are unusable. This highlighted map of High Rock Lake gives you a graphic view of the adverse effects of a 10 foot drawdown. The RED portions of the lake are completely dry at 10 feet down and the YELLOW portions (from 10 to 15) feet are too shallow for safe boating. Even if you don't run aground or hit a rock or stump, the prop wash from most boats and the scouring effects of subsequent high flow events would disturb the bottom sediments and further contribute to water quality problems already present at High Rock Lake.
APGI likes to portray those who live in the communities around High Rock Lake or use it for recreational purposes as a single interest group interested only in water levels while purporting the regulatory agencies as the representatives of the "big picture". In reality, the opposite is actually the case. NC Dept. of Environment and Natural Resources has participants from the Water Resources, Water Quality and Wildlife Resources Departments. Each of these areas has a very specific interest they are there to represent. The US Fish and Wildlife, EPA and National Parks Service representatives also have a very specific interest they are there to protect. The NC Land Trust, SC Coastal Conservation League and American Rivers again have a specific interest they are representing. While each of these groups does consider other issues, when the time comes to stand up and be counted their primary goal is protecting their single interest. Most of these Agency representatives representing your rights live nowhere close to High Rock and some had never even been to High Rock Lake before this process started and most will rarely if ever be back. On the other hand, community residents and recreational users of High Rock Lake ARE more interested in the "big picture". We certainly don't want to live around or play in a dry, unsafe, ugly or polluted lake.
We ARE the stakeholders who: