I am writing in response to Appalachian Power Company’s request for a new license to operate the Claytor Hydroelectric Project (No. 739-018).  Before a new license is issued, I recommend that FERC require Appalachian to address the following issues:

Shoreline Erosion

A study of shoreline erosion was conducted and this study established that approximately 13 miles of the shoreline is highly erodible.  Shoreline erosion rates of up to 0.5 meters per year and bank recession since 1939 of more than 60 feet was found.  This rate of erosion is outrageous.  It is dumping thousands of tons of prime soil into the watershed each year.  Where this is occurring, my observation is that the high degree of sedimentation has created a sterile environment with very few to no mussels or other life forms present.  Stopping this erosion should be a high priority for FERC as part of its mission to protect all stakeholders impacted by Appalachian’s management of the Claytor Project.  

Appalachian Power is proposing in its licensing request to monitor shoreline erosion.  I personally find this rather laughable.  The Erosion Study documents what has occurred during the past 60+ years, which gives us a very accurate assessment of erosion rates.  With 60 years of information currently available, I believe we can reasonably project what will occur in the future.  Action needs to be taken now to help protect our prime soils, water quality, aquatic life, and human resources.  

Appalachian Power should be held responsible and required to work with landowners to stabilize the shoreline in the highly erodible areas.  If for some reason this is not possible, at least the continuation of the annual lake drawdown should be required which provides stakeholders a more affordable opportunity to protect their land from being taken through erosion by Appalachian.  

I understand that some concern exists relative to the impact of drawdown on the mussel population and, if this is a real issue (there are extremely few to no mussels in highly eroded areas), Appalachian should be required to mitigate for mussel mortality.

Relicensing Process

The relicensing process began with input from interested parties from the lake community.  Since the initial meetings, it seems that there has been very little involvement by anyone other than Appalachian, state and federal employees.  The distribution list for study results is essentially all state and federal staff.  The general public is not informed and has not been involved in the process.  Before issuing a new license, FERC needs to hold a public meeting and share Appalachian’s relicensing proposals with the general community.

Thank you for the opportunity to provide input into the relicensing process.

Alan W. Graybeal