CALL TO ACTION
The purpose of this page is to keep our members and the public informed of any activities that may affect our lake in a negative way and will allow you to take action as appropriate (contacting local, state, federal representatives, informing your neighbors, etc.)
In addition, we will be using this page to solicit volunteers for our various activities throughout the year.
Many of our members have requested that we re-post the information regarding the US Army Corps of Engineers proposal to reallocate water in Lake Allatoona (GA) and in Weiss and Logan Martin lakes (AL). The below contains our latest letter to the Federal Energy Regulatory Commission requesting their assistance in this matter as well background information supporting our concerns.
We will keep you updated on this issue.
Neely Henry Lake Association
90 Walnut Street
Gadsden, AL 35901
Date: June 8, 2021
Secretary, Office of the Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, D.C 20426
RE: US Army Corps of Engineers Lake Allatoona (GA) Water Supply Reallocation proposal
I am writing to you as a follow-up to my letter and documentation of November 23, 2020 (see attached). After not hearing from Mr. Larry Parkinson, I did some checking and found that he is no longer listed as a member of the FERC team. I guess this, coupled with mail delivery/processing issues related to Covid-19 (I was told it had been a challenge in Washington, D.C.), that it was very likely that my initial contact had not been reviewed by anyone at FERC.
Upon further investigating, I was told that perhaps I had sent my initial letter to the wrong individual and that I should have sent to you, as you are the one that makes things happen!
To that end, I would appreciate your help in getting the attached routed to the correct person/department at FERC. As you can see in attached letter, I am writing on behalf of the Neely Henry Lake Association Board and our nearly 200 members. Our main concern is the request by Alabama Power Company, within the US Army Corps of Engineers Lake Allatoona (GA) Water Supply Reallocation proposal, to modify flood operations at Weiss and Logan Martin Lakes (one is above and one below Neely Henry Lake) and the potential impact these changes could have on the environment of our lake.
In order to save you time, I won't repeat all that was written in attached letter, as none of the issues have changed and you can read at your leisure.
As stated, we would very much like FERC to review our documentation and concerns and provide us feedback on those concerns and other questions raised.
We are ready and willing to meet with you and discuss either by phone or in person at your office in Washington, D.C.
Thank you in advance for your assistance in this very important matter.
David C. Tumlin
President, Neely Henry Lake Association
cc: Sen. Richard Shelby
Sen. Tommy Tubberville
Rep. Robert Aderholt
Prepared by the Neely Henry Lake Association
January 22, 2020
Alabama Power Company is requesting that the US Army Corp of Engineers make changes to the Coosa River Water Control Manual to raise the winter draw-down elevation at Weiss Lake from 558 to 561 feet while reducing the maximum surcharge flood elevation from 574 feet to 572 feet (much less room to store water in Weiss during flood events.) The result is that more water must be released sooner from Weiss for flood control.
The Neely Henry Lake Association is concerned that the increased discharge of water from Weiss Lake during flood events (i.e. releasing more water sooner because of the higher lake elevation) will adversely impact Neely Henry Lake. Specifically, we are concerned about the possibility of increased flooding above a natural restriction in Neely Henry reservoir known as “Minnesota Bend,” which significantly impacts the city of Gadsden, and the evacuation of water below “Minnesota Bend.” The evacuation of water below “Minnesota Bend” leads to very low water conditions in the Rainbow City and Southside areas in Etowah County and various communities in St. Clair and Calhoun Counties. We are concerned that more drastic and frequent flooding and evacuation of water could occur and for longer periods of time if the proposed changes to the Water Control Manual are adopted. Should this be the case it could result in various environmental and safety-related issues. In addition, it could cause property damage and a decrease in property values in the impacted areas.
As a result of the proposed changes to the Water Control Manual, the full impact of increased frequent evacuation is unknown without a complete and comprehensive Environmental Impact Study regarding endangered species, fish spawning, marine vegetation, etc.
A recently-completed study revealed that the Neely Henry Reservoir has a $570 million annual positive economic impact to the local communities. Should the proposed changes be implemented, we would expect a significant reduction to the economies of the impacted communities.
WHAT YOU CAN DO TO HELP:
Please share this with as many people as possible. The form can also be downloaded at www.greatergadsden.com or picked up at 90 Walnut Street, Gadsden, AL 35901
The USACE Draft Feasibility Report and Integrated Supplemental Environmental Impact Statement involving the current Allatoona Lake Water Supply Reallocation Study and Updates to Weiss and Logan Martin Reservoir Project Water Control Manuals
In October, 2014 the USACE published the Final Environmental Impact Statement (EIS) addressing updates to the Master Water Control Manual (Master Manual) for the ACT Basin.
The 2014 published Final Feasibility Report (FR) and EIS included guidelines for the following:
The Master Water Control Manual regulations associated with the FR/EIS went into effect in May, 2015 when a Record of Decision (ROD) was signed by the USACE. After the ROD was signed the State of Alabama, Alabama Power and other entities filed a lawsuit involving the revised guide rule curve and operational zones at Allatoona Lake. The reason for the lawsuit was that Alabama believed the revised Allatoona rule curve and operational zones would reduce flow from Allatoona Lake to the Etowah and Coosa River consequently reducing the amount of water reaching Alabama from Georgia. This lawsuit has not yet been resolved and is now in district court. It is believed that the lawsuit will eventually be decided by a three judge panel in the US Circuit Court of Appeals in Washington, DC.
It is important to note that when the 2015 ROD was signed by the USACE the USACE deferred action on issues which are the subjects of a new (2019) USACE Draft Feasibility Report (FR) and SupplementalEnvironmental Impact Statement (SEIS). The USACE 2019 plan addresses a) Georgia’s water supply request from Allatoona Lake b) new water accounting guidelines associated with Hickory Log Creek reservoir and two waste water facilities and c) APC’s request to modify flood operations at Weiss and Logan Martin Lakes.
Although the USACE says that the newly developed plan would have no adverse impacts to federally authorized projects and only minor impacts on the natural and human environment (as is described in detail in the Draft FR/SEIS), they have identified various problems/opportunities associated with the newly proposed changes to the Water Treatment Manuals. These are as follows:
1) The impact of additional municipal and industrial (M&I) water that will be taken from Allatoona Lake to supply the Cobb County Marietta Water Authority (CCMWA) and the City of Cartersville, Georgia:
2) The impact of “new” water accounting requests by the State of Georgia: The State of Georgia has requested that USACE consider a revised operation of Hickory Log Creek Reservoir for water supply withdrawal at Allatoona Lake by the CCMWA. This revised operation would involve making releases from Hickory Log Creek Reservoir into the Etowah River and then withdrawing the water at its existing intake in the lake. Current USACE water storage accounting practices do not recognize this operation, (commonly known as “pass through conveyance”). Additionally, Georgia requested the USACE provide credit for “made inflows” (e.g. treated wastewater returns). As with “pass through conveyance” current USACE storage accounting practices do not recognize credit for “made inflows”.
3) Lack of flowage easements to accommodate flood operations at Weiss and Logan Martin dams. APC does not currently have the level of flowage easements that were described in the original Weiss and Logan Martin Lake manuals. The maximum surcharge (top of flood pool) at Weiss Lake is at an elevation of 574 feet. (Flowage easements are currently purchased to elevation 572 feet). The maximum surcharge elevation at Logan Martin Lake is at an elevation of 477 feet and flowage easements are currently purchased to elevation 473.5 ft. The absence of the necessary flowage easements at the projects has required APC to request temporary deviations, or variances, from the USACE to conduct flood operations differently during flood events that are prescribed in the currently approved WCM’s on multiple occasions since the projects were constructed.
The NHLA has concerns about the new USACE plan for the following reasons:
1) We are concerned with the amount of water the CCMWA has requested to be allocated from Lake Allatoona for municipal and industrial (M&I) purposes and the request for water accounting changes. Georgia has requested an average daily water supply of 94 million gallons per day through the year 2050 from Allatoona Lake. This would require the reallocation of an additional 33,872 acre-feet (ac-ft) of storage to meet the projected demand bringing the total storage allocation for M&I water at Allatoona Lake to 52,411 ac-ft. According to the USACE the reallocation of storage in Allatoona Lake would require a 1 ft. increase in the lake’s summer guide curve elevation (840 to 841 feet) and a 1.5ft increase in the winter guide curve elevation(from 823 ft to 824.5 ft). Obviously, we are concerned that this will result in a reduced amount of water reaching the Etowah River resulting in a reduction in the volume of water reaching the Coosa River and Neely Henry Lake. In addition, the additional water that will be stored in Allatoona during the winter could possibly increase flood issues downstream of the Allatoona Dam impacting Coosa River Lakes including Neely Henry.
2) We are concerned about Georgia’s requested changes to current water accounting practices. The accounting request changes involves a) the release of water from Hickory Log Creek reservoir into the Etowah River and the release of water from b)two waste water treatment facilities associated with the CCMWA. We are concerned that, if these water accounting procedures are implemented as requested by Georgia, it would result in less water reaching the Etowah River and would adversely impact the volume of water reaching the Coosa River and Neely Henry reservoir.
3) We are concerned that APC has requested the USACE consider and approve changes to the established maximum surcharge levels and winter drawdown levels at Weiss and Logan Martin Lakes. For Weiss Lake APC has proposed lowering the maximum surcharge flood elevation from 574 feet to 572 feet and raising the winter drawdown elevation from 558ft to 561 ft. At Logan Martin Lake APC has proposed lowering the maximum surcharge elevation from 477ft. to 473.5 feet and raising the winter drawdown elevation from 460 ft. to 462 ft. (According to the USACE Draft FR/SEIS document, APC does not currently own flowage easements up to the maximum surcharge elevations established in the current WCMs). Because of these changes, APC has proposed modifying flood operations at Weiss and Logan Martin Lakes by releasing more water sooner during flood events to keep reservoir pool levels within the newly proposed maximum surcharge elevations and has proposed acquiring downstream flowage easements to accommodate increased non-damaging releases from 50,000cfs to 70,000cfs. The USACE has said they will conduct additional analysis of impacts to private property both upstream and downstream of Weiss and Logan Martin dams. According to the USACE this analysis will provide a comprehensive impact assessment of the effects of APC’s current and proposed operations. (Prior to implementation, it may be incumbent on APC to purchase any identified “real” interests as part of this proposed plan). This analysis and findings will be available for review in the Final FR/SEIS.
The NHLA is concerned that the increased discharge of water from Weiss Lake during flood events (i.e. releasing more water sooner) will adversely impact Neely Henry Lake. Specifically, we are concerned about the possibility of increased flooding above a natural restriction in Neely Henry reservoir known as “Minnesota Bend” and the evacuation of water below “Minnesota Bend”. (The evacuation of water below “Minnesota Bend” leads to very low water conditions in the Rainbow City and Southside area in Etowah County and various communities in St. Clair and Calhoun Counties). We are concerned that flooding and evacuation of water could occur more frequently and for longer periods of time if the proposed changes to the Water Control Manual are adopted. Should this be the case it could result in various environmental and safety related issues. In addition, it could cause property damage and a decrease in property values in the impacted areas.
(The proposed raising of the winter drawdown elevation at each project by APC is in response to requests by recreational users to reduce the severe constraints to recreational use that occur during the current winter drawdown level. These requests by recreational users were reaffirmed during the scoping process of the USACE’s study. The study considered the flood risks and other impacts associated with APC’s proposed operational changes at Weiss and Logan Martin reservoirs).* Not covered in the new Draft FR/SEIS is the newly constructed Richland Creek Reservoir and water treatment facility (in Paulding County, Georgia) that is nearing completion and should be operational in 2020. This reservoir and water treatment facility is downstream of Allatoona Dam and is permitted to withdraw 40+ million gallons of water per day from the Etowah River. In addition, like Hickory Log Creek reservoir located upstream of Allatoona Dam on the Etowah River, Richland Creek reservoir will also be utilized as a recreational reservoir for adjacent communities.