Alabama Power files comments with FERCPublished 3:07pm Monday, September 2, 2013
Alabama Power Company last month filed a 57-page eComment with the Federal Energy Regulatory Commission (FERC) in support of its pending proposal for the relicensing of their Martin Dam operation.
More than 17 pages of the electronically filed document dealt directly with the proposed 3-foot increase in the winter pool level and conditional fall extension issues that dominated the hearing FERC staff held here in July. At that time, FERC staffers indicated they needed more information to support the proposed changes.
“Alabama Power believes these comments provide the additional information, clarification and analysis necessary to support acceptance of our winter pool increase and conditional fall extension proposals,” wrote the power company’s Hydro Services Manager, Jim Crew.
With the last 21 pages of the document dedicated to support materials for the drought response operations and Alabama Power’s suggested corrections to the draft Environmental Impact Statement (EIS) released by FERC staff in June, approximately half of the eComment document addressed the water level questions.
Crew said he hopes the information included would supply the additional information FERC staff needs to accept the winter pool increase and conditional fall extension proposals.
Crew suggested that the draft EIS conclusions seemed to discount and mischaracterize the results of two studies that demonstrated the recreational and economic benefits associated with a winter pool increase.
“When properly analyzed, the recreational and economic benefits are much greater than accounted for by staff,” he wrote.
In re-analyzing the data, shoreline landowners were separated into unique categories for seasonal and permanent residents. The separation of the categories resulted in a predicted increase of eight percent for seasonal residents in the case of an increased winter pool level.
“Viewing the predicted increases in average recreation use by month demonstrates that projected increased use is directly correlated to the proposed 3-foot increase in winter pool,” the document stated.
The power company also noted that the study indicates a 21 percent increase in the number of private docks that would be usable year round.
“Given that there are approximately 4,000 boat docks around Lake Martin, approximately 840 additional docks would have boat access to the water at the proposed higher winter elevation. This is not insignificant,” Crew wrote.
The predicted 8 percent increase in use from seasonal residents, along with a projected six percent increase from visitors, a 6 percent increase in use from permanent residents and a 5 percent increase in business activity in the region could also generate an estimated increase of $800,000 spent on trip-related expenses, generating additional economic impact for the Lake Martin region.
The eComment noted that FERC staff relied in part on a 2008 study of recreational use on Lake Martin.
“Because this 2008 study was conducted during a year of severe drought on the reservoir, it does not adequately reflect typical recreation and land use numbers,” the document stated. “The 2010 study better reflects typical reservoir conditions and therefore more reliable recreation and land use numbers.”
In addressing the rejection of Alabama Power Company’s proposal for a conditional fall extension of the summer full pool level, Crew noted that some data collected as part of the FERC-approved study were not referenced in the conclusion of the draft EIS.
Crew reported that when conditions are met to extend summer water levels into the fall, an estimated increase of more than $1 million could be spent on trip-related expenses, in addition to a 14.5 percent increase in area business activity.
The document also addressed the potential downstream impact of the proposed water level changes, noting that the changes could result in an increase of six additional days of spill over an entire 67-year period of record.
“That’s six days out of 24,445 days or an increase of 0.02 percent. It is important to note that spill at Martin does not necessarily equate to any additional flooding downstream because not all spill events result in the river getting out of its bank,” the document reads.
The document noted that in the highly improbable event of a conditional fall extension impacting the flooding of roads or structures downstream, the flood would be likely to stay within the Federal Emergency Management Agency (FEMA) 100-year flood elevation. The report also recognized that the downstream structures and roads that could be affected are located in a designated floodplain and fall under the protection of FEMA.
Still, because FERC staff’s draft EIS conclusions indicated a level of uncertainty regarding the recreational, economic, environmental and operational benefits and impacts of the proposed changes, the power company offered an alternative interim proposal.
“As an interim measure, Alabama Power would implement and evaluate its proposed higher winter pool elevation of 484 feet (mean seal level) and conditional fall extension for a period of 10 years following issuance of the new Martin license,” the document stated.
In addition to analyzing the recreational and economic impacts of the proposed changes, the interim period also would be used to study impacts on water quality and nuisance aquatic vegetation.
Such an interim period is not a new approach for FERC and Alabama Power, as the measure was used in the recent issuance of the FERC license for the Coosa River Project in the spring of this year.
In conclusion, Crew wrote of the public support for Alabama Power Company’s license proposal, as demonstrated by the turnout at the July 17 public meeting.
He asked that FERC staff take a closer look at the information provided in the original proposal, along with that included in the electronically filed document, and that those be analyzed and reflected in the final EIS and license, which will be released at an unspecified date.