FEDERAL ENERGY REGULATORY COMMISSION WASHINGTON, D.C. 20426 March 16, 2009 OFFICE OF ENERGY PROJECTS Project No. 739-018 – Virginia Claytor Project Appalachian Power Company Ms. Teresa Rogers Appalachian Power Company 40 Franklin Road Roanoke, Virginia 24011 Reference: Commission Staff Comments on Update Study Report and Meeting Summary Dear Ms. Rogers: Commission staff have reviewed the updated study meeting report for the Claytor Project No. 739, filed on February 16, 2009. We have no comments on the meeting summary. Our comments and requests for clarification on the final study reports are provided in appendix A. Any questions on these comments should be directed to John Smith at (202) 502-8972 or john.smith@ferc.gov. Sincerely, Vince Yearick, Chief Hydro East Branch 1 cc: Mailing List Public Files APPENDIX – A Comments on Final Study Reports Commission staff have reviewed the final study reports and meeting summary pursuant to 18 CFR § 5.15(c)(4), and have the following comments and clarifications: Aquatic Resources Assessment 1. In appendix D, the CE-QUAL-W2 study report indicates that the wind sheltering coefficient (WSC) was adjusted to 1.1 for 2002 and 2007 and 0.8 for 2004. Please explain what these adjustments were based on. 2. On pages 62 and 87 of the CE-QUAL-W2 study report, you state that many expert modelers consider the CE-QUAL-W2 model to be acceptable when the absolute mean error (AME) is less than 1.0 degree Celsius and less than 2.0 milligrams per liter dissolved oxygen. Please provide a reference for these statements. Erosion Study 1. In section 1.4 of the Erosion study report, the surface area of Claytor Lake is stated to be 4,472 acres which is consistent with the revised scoping document, but the Preliminary Licensing Proposal lists the area as 4,363 acres at full pool. Please clarify this discrepancy and explain if there is any difference in the original lake area versus the current lake area. 2. In Section 2.6.5, please clarify the DISFAC (downcutting) and BLERODE (bluff erosion) coefficients. Specifically, are these coefficients unique to the COSMOS model? Do they have physical significance or are they coefficients used to calibrate the model? Does figure 2.17 represent a specific location or is it an example of the DISFAC and BLERODE coefficients? If it is a physical location, please indicate where it is. What do the measured downcutting points represent? 3. In section 3.1.1, it is stated that 86.2 miles of shoreline were observed during field reconnaissance. However, in section 1.4, it is stated that Claytor Lake has about 100 miles of shoreline. Please explain the rationale for not observing the entire shoreline? 4. In table 3.2, Material and Geomorphic Characteristics do not sum to the same total. What material was not observed? Please clarify. 2 5. The total and unprotected lengths of shoreline in table 3.1 and table 3.5 differ. Please clarify. 6. You indicate that no other shoreline protection measures other than riprap are present on the Claytor Lake islands so the shoreline is either covered by riprap or it is not. Based on this, please explain why the percentages in table 3.7 do not add to 100 percent? 7. Objective 3 of the revised study plan required identification of the degrees of susceptibility of areas along the project reservoir and downstream to the VA/WV border for bank erosion. What figure(s) best illustrates the varying degrees that banks are susceptible to erosion for both the shoreline around the lake and downstream river channel? A plot of the degrees of susceptibility would be helpful, along with an index. 8. Objective 4 of the revised study plan required identification of areas subject to accelerated bank erosion. What figure(s) best illustrates the varying degrees that banks are subject to accelerated erosion for both the shoreline around the lake and downstream river channel? A plot of the degrees of erosion would be helpful, along with an index. 9. Objective 7 of the revised study plan required an assessment of erosion control measures in terms of effectiveness, costs, longevity and natural compatibility? This analysis appears to be missing. Instream Flow Needs Study 1. In addition to the analyses presented in the report, a summary table showing the percent of maximum weighted usable area for each species life stage evaluated at various selected flows would be helpful for our analysis. Navigational Aids Study 1. The primary map of proposed aids to navigation (in Appendix F) should include map insets that refer to the larger scale blow-up maps that follow for better clarification. The maps should also include the locations of bridges and other points of interest (hollows, creeks, etc.). Sedimentation Study 1. Some of the data tables would be easier to compare if similar units were used. For example, table 4 has units of tonnes while table 5 uses tons. 3 2. In the caption for figure 14, horizontal and vertical uncertainty bars are referenced but not included in the figure. 3. The extent of the riverbed or water surface elevation should be shown on the cross sections included on figures 51 through 64. 4. Please describe how particle size was determined for the distribution presented on figures 51 through 64? Were these particle sizes used in any sediment transport calculations (for example, WinXSPRO)? 5. A legend or more detailed caption would be useful on figure 65 to explain the bar, and “x” and “-” symbols. 6. Please describe how stability was determined in figure 66? 7. The Soil and Water Assessment Tool (SWAT) was used to estimate the sediment yield of 342 subwatersheds for a range of future conditions (table 5). What is the average sediment yield of these subwatersheds for these future conditions and how does average sediment yield of these subwatersheds compare to the measured yield from 1939 through 2007? Wetland, Riparian, Woody Debris, Littoral and Bald Eagle Habitat 1. It would helpful if figure 1-1 Vegetation Cover Types map could be provided in a scale similar to the one used for the Appendix B littoral habitat mapping for clarity.