Please send to:ROS Project Manager David NyeTennessee Valley Authorityc/o WT 11A, 400 West Summit Hill Dr.Knoxville, TN 37902
or go to TVA.com to submit electronic comments
TVA Reservoir Operations Study Scoping Comments
Respectfully Submitted on ________, By ____________________
I am an avid whitewater enthusiast and therefore have a direct interest in the management of the Ocoee and Hiwassee rivers. I would ask that you consider the following comments on the ongoing Reservoir Operations Study (ROS). In addition to these comments I support the comments submitted by American Whitewater regarding the ROS.
I have an interest in being able to paddle the Hiwassee, and Upper and Middle Ocoee rivers, free of charge, on as many days as possible. I support the Hiwassee Scenic River Stakeholder’s and American Whitewater’s comments regarding TVA providing a reliable schedule of releases on the Hiwassee River and additional instream flows to benefit fisheries. I also support American Whitewater’s comments requesting that future management of the Upper Ocoee River closely follows the release schedule defined in the United States Forest Service’s 1997 Record of Decision on the Final Environmental Impact Statement titled “Upper Ocoee River Corridor Recreational Development.” Under this preferred alternative, TVA would annually provide 74 free recreational releases in the Upper Ocoee. This management should work in concert with the existing management of the Middle Ocoee to provide the maximum recreational benefits at the lowest cost. I feel that these provisions provide the best way of sharing these valuable resources in an equitable manner between all the stakeholders.
In order to best meet my interests the ROS should include the following studies and address the following topics in the manner suggested by American Whitewater in their comments:
Upper Ocoee River
1. Existing Information:
a. The USFS/TVA 1997 Environmental Impact Statement titled “Upper Ocoee River Corridor Recreational Development” should be referenced.
2. Hydrological Analysis:
a. Stream-flow records (hourly if possible) for the Ocoee River above and below the Ocoee Number 3 Dam for at least a 30-year period should be analyzed to determine historical water availability and recreation opportunities, and should be presented in the EIS.
b. The ROS should address the potential effects of various numbers of recreational releases on upstream lake levels.
c. Water availability and effects on lake levels should be integrated into a water budgeting model that addresses the seasonal hydrological limitations on providing recreational releases on the Upper Ocoee River.
3. Project Operations
a. A general description of the Ocoee River Projects should be provided including the dimensions of dams and reservoirs, lengths of diversion reaches and bypass tunnels and flumes, capacity and efficiency of turbines, hydraulic head, relationship with downstream projects, and electrical output.
b. Generation records for the Ocoee Projects since at least 1991 should be analyzed to determine water availability, impacts of project operations on recreation, seasonal power generation patterns, and the specific seasonal economic revenue produced by the generation.
c. An analysis of a given unit of water as it travels down the TVA system from Lake Blue Ridge should be included in the ROS.
4. Economics:
a. The potential and historical economic impacts of whitewater releases on the local and regional economy must be studied in detail. The impacts of non-commercial boating, commercial boating, and whitewater events on the Ocoee River should be studied.
b. Similarly, the potential and historical economic impacts of providing additional recreational releases in the Upper Ocoee on the TVA should be studied in detail.
c. The economics of the TVA’s cost recovery efforts regarding recreational releases on the Upper Ocoee should be addressed in the ROS.
d. The profit structure for the individual Ocoee River Projects should be included in the reports and analysis.
e. Lastly, a great deal of TVA, public, and private money has already been invested in the Upper Ocoee River Corridor. The ROS should describe these investments in detail.
5. Existing recreation data:
a. Information on use of both sections of river by various types of user groups and for various purposes should be collected and analyzed.
b. The recreational resources of the Ocoee River should be documented in the ROS.
c. Whitewater recreation opportunities, other than the Ocoee River, that are affected by TVA’s reservoir operations should be cataloged in the ROS.
6. Legal Issues:
a. The legality of TVA charging members of the public and other agencies to use water that is owned by the public under the Public Trust Doctrine must be addressed.
b. The issue of how TVA’s congressional mandate to provide for navigation relates to the whitewater use on the Ocoee River should be addressed.
c. The ROS should consider reclassifying the Ocoee River Projects as recreational projects.
d. The TVA has at least some mandate to support economic growth and sustainability for the Tennessee Valley but consistently holds the economy of Polk County back by keeping the Upper Ocoee River dry. The legality of this management decision should be questioned in the ROS.
7. Biological Considerations:
a. Any potential biological impacts of providing or eliminating flows from the Ocoee River should be considered in the ROS.
8. Agency and Stakeholder Cooperation:
a. The ROS should consider procedural changes that will help the TVA to act responsibly and address the needs of other federal, state, and local agencies and their stakeholders that have an interest in the Ocoee River.
The Middle Ocoee
In 1984 Congress authorized an interest-free Treasury loan to prepay TVA for 30 years of water releases on the middle Ocoee to sustain a growing commercial rafting industry. The agreement that currently requires the TVA to provide releases for commercial operations on the Middle Ocoee expires in 2014, and the management of Middle Ocoee will once again be in question. Unless another ROS will be done before the Middle Ocoee agreement runs out, all the previous questions regarding the Upper Ocoee should be applied to the Middle Ocoee as well. The goal of this is to have solid baseline data when it comes time to re-define the management of the Middle Ocoee.
In addition to the question regarding the Upper Ocoee, the economic details of how water is provided on the Middle Ocoee should be included in the ROS. This should include interest rates on and amounts of any loans, and a history of how the situation arose.
Hiwassee River
1. Hydrological analysis:
a. Streamflow records (hourly if possible) for the Hiwassee River for at least a 30-year period should be analyzed to determine water availability.
b. The ROS should provide the number, flow, and timing of historical flows in the bypass reach below Apalachia Dam.
c. The ROS should address the potential effect of various numbers of recreational releases and minimum instream flows on upstream lake levels.
d. Water availability and effects on lake levels should be integrated into a water budgeting model that addresses the seasonal hydrological limitations on providing sustained habitat and recreational releases.
2. Project Operations:
a. A general description of Apalachia, Hiwassee, Chatuge, and Nottely Dams should be included in the ROS and should include descriptions of the capacity and efficiency of turbines, hydraulic head, electrical output, and relationship with downstream projects.
b. Generation records of the Hiwassee River dams since at least 1980 should be analyzed .
3. Economics:
a. The potential and historic economic impacts of whitewater releases on the local and regional economy must be studied in detail, as well as the impacts on TVA’s profitability.
b. The ROS should consider the economic costs and benefits associated with installing constant flow generators capable of generating power while releasing some ecological minimum flow into both the bypass reach and the Hiwassee below the powerhouse.
c. Lastly, a great deal of TVA, TWRA, private, and public money has already been invested in the Hiwassee State Scenic River corridor. The ROS should describe these investments in detail.
4. Available Recreation Status:
a. The recreational resources of the Hiwassee Scenic River tailwater and bypass reach should be documented in the ROS.
b. The ROS should address multiple alternatives that provide varying numbers of guaranteed recreational releases, and various way of communicating flow information.
c. The ROS should address the recreational potential of the 12 mile stretch of river that is currently bypassed below Apalachia Dam and the impacts of current, historical and potential management on recreation.
d. The potential of providing releases in the bypass for whitewater recreation and fisheries enhancement should be studied in the ROS.
5. Conservation and Biological Considerations:
a. The current and potential minimum instream flows (both below the powerhouse and in the bypass reach) and their ecological (and economic) costs and benefits should be addressed in the ROS.
b. The ROS should address TVA’s land management in the Hiwassee River Corridor and Watershed to determine if there are negative impacts of that management on the river and seek opportunities for land protection through conservation easements.
I hope that these comments can act in concert with those of American Whitewater to ensure that the ROS wisely addresses a wide range of alternatives that address my interests. I believe that the TVA has a public obligation to provide free recreational releases in the rivers they manage. Through doing this on the Upper and Middle Ocoee, as well as the Hiwassee, TVA can prove that they can be public stewards as effectively as their private competitors.