we appreciate the opportunity to comment on duke … · throughout the catawba-wateree river basin....

A WATERKEEPER ALLIANCE® Member

715 N Church St, # 120 Charlotte NC 28202

Phone: 704-679-9494 Fax: 704-679-9559

www.catawbariverkeeper.org

August 18, 2017

Secretary Kimberly D. Bose

Federal Energy Regulatory Commission

888 First Street NE

Washington, DC 20426

COMMENTS Re: Project Docket P-2232-522 Duke Energy Carolinas, LLC; Notice of Application

for Amendment of Project License

To the Federal Energy Regulatory Commission:

We appreciate the opportunity to comment on Duke Energy’s application to amend its FERC

project license. The Catawba Riverkeeper Foundation (“CRF”) is a 501(c)3 nonprofit established in 1997

at the recommendation of the region’s county governments. Our mission is to advocate and educate

for the protection of the Catawba-Wateree River, which more than two million people in the Carolinas

enjoy and depend on. In pursuit of this mission, we also perform our own research, monitoring and

sampling with a network of hundreds of volunteers every year. Our five full-time staff are supported by

approximately 700 annually renewed memberships from individuals, families and businesses

throughout the Catawba-Wateree River basin.

The amendment application is based on Duke’s work in the Catawba-Wateree Water

Management Group (CWWMG) in the development of a Water Supply Master Plan (WSMP), which we

have followed closely. The CWWMG is itself a 501(c)3 consisting of Duke and 18 public water utilities.

Our comments here are to express concern with strategies and implications around and including the

proposal to hold Lake James, Lake Norman and Lake Wylie six inches higher between May 1 and

October 1. More than anything, we have questions that have never been answered in full or even in

part but should be in the critical long-term water planning the Catawba-Wateree River basin needs.

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Water Supply in the Catawba-Wateree River Basin

The proposal to raise target elevations of three of the largest reservoirs by six inches generates

a lot of questions and concerns on its own, but the proposal must be considered in the larger context

of the strategies (of which this proposal is one) and structure of the WSMP as well as the unique

situation of the relatively small, densely populated and constantly impounded Catawba-Wateree River

basin.

The Catawba River is mostly dammed inline into 11 slackwater reservoirs (Appendix A). As part

of Duke’s privilege to profit off of and to manage the river under its FERC license, the reservoirs are

recreation havens and have lakefront residential development that provides a major portion of

property tax base and revenue from only a few percent of a county’s acreage. A GIS analysis of

property record databases reveals that tens of billions of dollars of property tax base and ultimately

local economies are dependent upon high quality, desirable water for which people are willing to pay a

premium to live near.

These reservoirs, originally created for hydroelectric generation, also provide cooling water for

the two active coal-fired power plants and two active nuclear power plants in a 39-mile span of the

Catawba River around Charlotte. These four power plants – two on Lake Norman and two on Lake

Wylie – have 7.75 GW of generation capacity, and the power they generate does not stop at basin lines

but also feeds the larger region at the heart of the Carolinas.

Multiple inter-basin transfers (IBTs) in the middle of the basin send drinking water to the

Yadkin-Pee Dee River basin. This happens in three ways: public water utilities that withdraw from the

Catawba-Wateree River but have customers who use water (e.g., irrigation) in the Yadkin-Pee Dee

River basin; wastewater treatment plants that discharge into the Yadkin-Pee Dee River basin but

receive water from customers supplied by water from the Catawba-Wateree River; and wholesale to

municipalities in the Yadkin-Pee Dee River basin. These IBTs are significant as demand within the basin

alone is already high, and our already limited water supply is even less available for downstream users

within the Catawba-Wateree River basin. IBT allotments have been set aside but have not yet been

fully utilized. The current estimate (according to the WSMP) is that at least 32 MGD is currently lost via

IBTs, but an estimated 73 MGD will be lost via IBTs in 2065.

Water quantity has long been an issue in this region, which has some of the nation’s highest

rates of growth. Water demands are increasing, including on a per capita basis. This region had a

drought of record in 2002 that was surpassed by drought in 2007-2008 that also led to a U.S. Supreme

Court case when South Carolina (downstream) filed against North Carolina. There was an obvious need

to better plan and coordinate for the future water supply. In 2008, the water conservation nonprofit

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American Rivers named the Catawba-Wateree River the #1 Most Endangered River in America because

of the drought and ensuing crisis because of such densely situated demand in a basin with limited

supply.

At about this time, Duke started its relicensing process with FERC. In April 2006, Duke and HDR

Engineering released the Water Supply Study. It analyzed safe yields and potential failures of the water

supply and found that there could be failures as soon as 2038. Failure is defined as demand exceeding

supply and water elevation falling below the critical intake elevation in a reservoir. This study also

evaluated sources of water consumption (Figure ES.3 below) and identified thermoelectric power

generation’s need for cooling water as accounting for approximately half of all water consumed (net

use, as in available downstream). Oddly, less than 10 years later, the CWWMG’s WSMP pie chart

displaying water consumption instead displayed less water consumption on the part of power and

almost a double the consumption from the public water supply (Figure 5-4). Furthermore, power

generation’s share of water consumption is undoubtedly much greater than how portrayed in either

pie chart. To calculate power’s water consumption rates, the WSMP uses the difference between

withdrawal and return volumes. Induced evaporation via the discharge of hot water primed to

evaporate is a component contributing to water consumption that is not [but should] be considered.

Water consumption pie chart from Duke’s 2006 Water Supply Study.

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Water consumption pie chart from the 2014 WSMP.

The CWWMG’s WSMP was released in May 2014. During development, the CWWMG

considered multiple strategies for prolonging the limited water supply in the Catawba-Wateree River

basin. These strategies were assembled in different scenarios for runs of Duke’s CHEOPS

(Computerized Hydroelectric Operations and Planning Software) computer model. The strategies

considered everything from lowering existing critical intake elevations and raising target operating

elevations in the reservoirs (part of the application currently before FERC) to cloud seeding and

covering the lakes to reduce evaporation (Appendix B). Nowhere in their strategies was there

consideration of reducing thermoelectric power’s consumption of water, which could occur at the

customer level, through other power generation technologies (e.g., solar) that do not consume water

and/or by investigating and supporting research into alternative cooling technologies. The WSMP

should have granted at least some consideration to slowing consumption rates that lead to failure

during drought.

It is important to note that the Low Inflow Protocol (LIP) also fails to address thermoelectric

power generation as a major source of water consumption. Reducing electrical consumption – and

thereby water consumption via thermoelectric power generation and cooling – would seem to be a

logical component of any water conservation plan. Yet, the crux of the strategy appears to be creating

more accessible storage at the tops and bottoms of reservoirs while also asking citizens to reduce their

August 15, 2017 of 14

public water supply consumption but not their electrical consumption. Consequently, this will also

force public water supply utilities (not Duke) to increase their rates.

The WSMP has multiple other oddities, such as notes of Duke’s plans to install eight combined

cycle (natural gas) and two two-unit nuclear power plants in the Catawba-Wateree River basin

between 2026 and 2065 (the two coal power plants would come offline by 2040). This seems to be an

ambitious plan. These are just some of our concerns with the overall WSMP and suffice to lend some

context to our concerns and questions regarding the WSMP’s ultimate efficacy, including with this

specific proposed strategy of raising reservoir target elevations six inches.

Direct Concerns About Raising Reservoir Elevations

The proposal to raise three of the Catawba-Wateree River’s largest reservoirs by six inches does

raise multiple concerns and thus far unanswered questions, which should be addressed prior to any

approval from FERC.

The Catawba-Wateree River basin, increasingly populated and developed, has a history of

flooding problems, particularly at the reservoirs. Hurricanes and tropical storm remnants can inundate

the Catawba-Wateree River basin with significant rain, as has been seen with major flooding events in

1989, 2004, 2013, and the Great Flood of 1916, which even wiped out dams. Duke’s general practice

during high-flow events is to not allow reservoirs with flood gates to exceed full pond, but not all

reservoirs have gates that can be opened to pass water through the system. This means that some

reservoirs already experience major flooding events.

Mountain Island Lake is immediately downstream of the 12-time-larger Lake Norman, which is

one of the reservoirs Duke would like to hold six inches higher. But dropping Lake Norman one inch

adds one foot of water to Mountain Island Lake, which does not have flood gates (only a spillway). Not

only is Mountain Island Lake the drinking water reservoir for approximately one million people in

Mecklenburg and Gaston Counties, there are hundreds of homes on Mountain Island Lake. Flooding

over the spillway of Mountain Island Lake’s impounding dam also causes significant flooding for homes

downstream; emergency evacuations have been required. Duke does not – but should – operate a

notification system where residents can receive an alert when Lake Norman’s flood gates are going to

be opened and cause extreme flooding. In May 2013, residents complained after upstream

precipitation and Duke’s middle-of-the-night opening of Lake Norman’s floodgates caused extreme and

surprising flooding.

Another lake with frequent flooding issues is Lake Wateree, which is the last reservoir in the

chain. It has no flood gates. However, the proposed installation of a bladder dam could mitigate this

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issue. For Mountain Island Lake, Lake Wateree and others, the key question is, what is the increased

flooding impact to these reservoirs if three of the largest are held six inches higher?

In its application to FERC, Duke included CHEOPS model results with the number of spill events

baseline vs. with a summer target elevation six inches higher at Lake James, Lake Norman and Lake

Wylie. These model results have created multiple questions. First, the modeling described above the

table on application page 8 (figure below) says it analyzed the 82-year period of record (29,330 days,

though there is a discrepancy as the table immediately below says 29,950 days) and that the

“operational modification was modeled.”

Taken directly from Duke’s Application for Amendment of Water Quality Certification

Supposedly, Mountain Island Lake would see fewer spill events (134) with the six-inch summer

target elevation increase compared to the baseline scenario (140 events). Based on “Note 1 – Baseline

Scenario uses New License requirements, projected water withdrawals,” CHEOPS appears to have

taken data from the period of record and modeled the number of spill events that would have

occurred had the past river conditions had the new license requirements and the projected water

withdrawals.

We need to know exactly how the CHEOPS runs were conducted for generating the numbers in

the above table. Was the actual period of record of reservoir elevations simply modeled to assess

whether reservoirs would have spilled if Duke had to manage an extra 6” of water on three reservoirs

August 15, 2017 of 14

during the summer? Or was CHEOPS run off actual period of record inflow data (rather than reservoir

elevation data) with model results for both baseline number of spill events and elevated reservoir level

spill events? More simply put, are the baseline scenario numbers generated by actually looking at the

period of record and counting spill events, or are the baseline scenario numbers a product of CHEOPS

modeling what it calculates spill events to have been? If it is the latter, there needs to be an analysis of

how many spill events have actually occurred. This is because we have concerns about the accuracy of

CHEOPS’ results, especially given some modeling results for Lake Norman (one of the three reservoirs

Duke would like to raise the target summer elevation for) and history of flooding on immediately

downstream Mountain Island Lake.

During the development of the WSMP, we and others engaged in training for how to use

CHEOPS but were never able to recreate the results in the format presented in the WSMP. This is

something FERC and the general public should have the documentation and ability to do. We and

others wanted to see the results in a different format -- how CHEOPS’ modeling results looked in terms

of lake levels over time so we could compare them to FERC-regulated reservoir elevations. We

requested this format directly from the CWWMG (namely Duke and HDR Engineering). They generated

charts for Lake Norman, but these raised significant concerns about CHEOPS’ ability to model the

Catawba-Wateree River with accuracy. The following charts are from a presentation to the Lake

Norman Marine Commission on February 12, 2015. The first showed the median end of day elevation

for Lake Norman. Indeed, CHEOPS appears to reflect the six-inch increase.

August 15, 2017 of 14

The subsequent chart illustrates end of day elevation exceedance. What it reflects is that Lake

Norman will be held at full pond 25-30% of the time. Perhaps even more concerning is that its display

of Scenario 1 (No WSMP Actions), which should reflect current reservoir management practices

(including elevation management) with additional consumption in future years, indicates Lake Norman

would still be at full pond 25% of the time.

Lake Norman has never been managed at full pond 25% of the time. The median value chart

hides a long duration at the extreme of full pond, where even the smallest rains would mean

significant downstream water passage to Mountain Island Lake, for which one inch of water dropped

from Lake Norman equates to one foot of elevation on Mountain Island Lake because Mountain Island

Lake is one-twelfth the surface area and does not have flood gates. The same presentation contains

actual lake levels for Lake Norman (Appendix C), and these charts show that Lake Norman is rarely

(what appears to be less than 1% of the time) at full pond. So, why the discrepancy between what we

historically know to be true and what CHEOPS shows? How does this information fit with the

calculations for flooding implications?

In terms of long-term water quantity planning, this is concerning for trying to accurately predict

whether or not the strategies of the WSMP will prove helpful and safe. But these charts are especially

troubling for the much smaller, downstream, and flood-prone Mountain Island Lake. If CHEOPS is right

and Lake Norman is going to be held at full pond 25-30% of the time, this would seem to be possibly

August 15, 2017 of 14

conflict with the current target elevations defined in Duke’s recently issued FERC license. If CHEOPS is

wrong – which it would seem to be given that ‘business as usual’ would have Lake Norman held at full

pond 25% of the time – there is a long list of concerns with the model, the WSMP developed off of it

and any other project management decisions Duke makes with the model.

Most notably as it pertains to the application proposal to increase the summer target elevation

of Lake Norman by six inches, the modeled results of flooding implications for Mountain Island Lake

cannot be trusted as there are conflicting conclusions and a lack of clarity with regard to details on the

CHEOPS runs in the application. FERC needs more credible, accurate, and consistent information about

the implications from an extra six inches of storage immediately upstream on a reservoir (Lake

Norman) that is 12 times larger. This is also important for evaluating increased stress on Mountain

Island Lake’s impounding dam, which was built almost a century ago (early 1920s).

We do not know how CHEOPS models the percent of time elevations are met or exceeded on

other reservoirs. We have requested but never received those runs. There is particular concern about

water levels on Lake James, though not for the desired increase in summer target elevation.

Lake James is a beautiful mountain lake and the first reservoir in the Catawba-Wateree chain.

While other reservoirs have public water supply and power plant intakes, Lake James’ critical reservoir

elevation is simply that of the hydroelectric unit. This elevation is 50 feet below full pond and

significantly lower than the critical reservoir elevation for any other reservoir. The next lowest critical

reservoir elevation is 25.1 feet below full pond (Lookout Shoals Lake). The remaining nine critical

reservoir elevations are an average of 10 feet below full pond.

Our concern with Lake James is that it could become disproportionately drained at the expense

of other reservoirs. During low-inflow conditions, Lake James’ normal minimum elevation is dropped

significantly and more than other reservoirs throughout the stages. By Stage 3 of low-inflow

conditions, the licensee reduces Lake James’ minimum elevation by 10 feet while Lake Norman is only

five feet below normal minimum elevation and other reservoirs are dropped to only three feet below

their normal minimum elevations. In Stage 4, the licensee is allowed to use its discretion for setting

reservoir elevations. This has significant implications for aquatic life, recreation, property tax base and

water quality on Lake James, which is anticipated to soon be utilized for drinking water, though

discussions by the CWWMG have said the intake will have to be installed at least 50 feet below full

pond.

August 15, 2017 of 14

Summary

The Catawba-Wateree River basin is heavily utilized for power generation, drinking water,

recreation, property tax base and much more. We need good long-term planning to ensure water is as

clean, plentiful, inexpensive and unthreatened as possible for the more than two million people who

enjoy and depend on it. Perhaps nowhere else in the U.S. is water supply planning more critical than it

is in the densely populated Catawba-Wateree River basin and region outside its basin lines that still

depend on it for electrical generation and drinking water.

The proposal before FERC raises questions not just about the specific implications of increasing

the elevations of three reservoirs by six inches but also about the larger WSMP and the CHEOPS model.

At this stage, the WSMP appears not to be a “Master Plan” but rather a chapter in what would be a

more comprehensive, well-rounded and balanced master plan. This current WSMP focuses on creating

more accessible volume and deterring consumption through the public water supply. The Catawba-

Wateree needs a master plan with more strategies and chapters, including reliable, consistent

modeling and due diligence regarding efficacy and other impacts, such as increased flooding caused by

raising reservoir elevations as proposed in this application.

We still have too many questions about the flooding implications for those downstream of

potentially elevated reservoirs. The current application should not be approved without additional

information and conditions:

Demonstrated improvements to the accuracy CHEOPS, especially in its portrayal of lake levels in

compliance with reservoir elevations prescribed by Duke’s FERC license (i.e., not showing a

reservoir being held at full pond 25-30% of the time)

o New elevation duration charts need to be generated once CHEOPS can demonstrate an

ability to accurately model water throughout the basin

o Clear documentation for how FERC and the public can recreate CHEOPS’ results when

CHEOPS is applied for various calculations

New analysis and more details on the analysis for additional days of spillover that could be

caused by an additional six inches in Lakes James, Norman and Wylie from May 1 to October 1

o Clarification on how additional spillover days are being calculated/modeled

o Acceptance of CHEOPS modeling for additional spillover days only if CHEOPS is proven

accurate and consistent

In the CHEOPS model, thorough consideration of changes to hydrologic runoff response from

increasing impervious surface area (likely to exacerbate flooding and spillover)

August 15, 2017 of 14

Are the WSMP and its strategies balanced and likely to be effective? Is CHEOPS accurate

enough to model the basin? Raising target elevations might not exacerbate flooding issues, but based

on current issues with CHEOPS, we have concern that there is no way to reliably know for sure. FERC

needs reliable, accurate information – that it can also recreate and validate – on lake levels and

flooding impacts before it can truly assess the impacts and appropriateness of raising target elevations.

We hope FERC will pursue well-supported answers to the questions and concerns we have

discussed here, including the larger questions and issues regarding the composition of the WSMP. The

purported efficacy of the WSMP is based on the implementation of various strategies, including the

holding reservoir elevations higher – the very application now in front of FERC.

Thank you for the opportunity to comment on this matter. Please do not hesitate to contact me

by phone (704-679-9494) or email ([email protected]) if you have any questions or would

like to discuss this further.

Sincerely,

Sam Perkins, Catawba RIVERKEEPER® Catawba RIVERKEEPER® is a member of Waterkeeper Alliance, Inc. Riverkeeper is a registered trademark of Riverkeeper, Inc., and is licensed for use herein.

August 15, 2017 of 14

Appendix A: Catawba-Wateree River and reservoirs

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Appendix B: Table 6-1 Prioritized List of Potential Yeidl Enhancement Strategies from 2013 Safe Yield Study; taken from Water Supply Master Plan

August 15, 2017 of 14

Appendix C: Additional charts showing historical Lake Norman reservoir elevation and normal operating range

we appreciate the opportunity to comment on duke … · throughout the catawba-wateree river basin....

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