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Evironmental Alerts Paradise Cove Marina under review by the FERC
The letter below, sent to SCE&G on Oct. 30, was not included in SCE&G's application to the FERC requesting approval for the Paradise Cove Marina. The letter including comments below will be forwarded to the FERC before the March 6 deadline.
October 30, 2007 Mr. Jim Landreth VP Fossil Fuel and Hydro Operations SCE&G Re: Application by Lighthouse Developments, Inc to construct an 84 slip private marina and boat ramp; US Army Corp of Engineers and S.C. Department of Health and Environmental Control Joint Public Notice #2005-1E-229-W(Revised). Dear Mr. Landreth: Lake Murray Watch is a citizens? watchdog organization committed to protecting and enhancing Large docking facilities can negatively impact fish and wildlife habitat, water quality, property values, and can contribute to congestion, over crowding, and boating safety concerns. And each additional docking facility on As licensee of the Saluda River Hydro Project 516, SCE&G must ultimately decide whether a docking facility is consistent with its license, federal regulations and the approved shoreline management plan (SMP). The SMP requires an applicant to obtain the necessary state and federal permits, and meet certain setback requirements. Additionally, Article 30 of SCE&G?s license requires that permitting activities protect and enhance the recreational, scenic and other environmental values of the project. Before applying for FERC approval for a change in land and water rights, SCE&G must review all information relevant to the proposed project to ensure consistency with the SMP, its license and other federal requirements. The licensee has the legal authority to deny the request in spite of the navigable waters permit and water quality certification issued by SC DHEC and the US Army Corp of Engineers. The SMP guidelines are very useful tools when there are no objections to a project and there is clearly no reason to deny a proposed project. But when objections are made based on legitimate concerns that clearly indicate significant potential impacts, SCE&G must consider those concerns in addition to the SMP set back requirements. Since the application was initially received and given ?tentative? approval, significant information which identifies problems has been brought forth in public meetings and written comments by the agencies, lake groups and individuals. And while SC DHEC and the Corp issued the permit based on their assessment and their regulations, we believe that overall, the information conclusively shows that the proposed project is not consistent with the more stringent FERC license requirements. A case in point is a review by Dr. Dan Tufford a USC Biologist, of DHEC?s staff assessment and the study used to make its decision to issue the 401 Certification for the Paradise Cove project. Dr. Tufford emphasized that the decision was based on a SC DHEC marina study in coastal waters e.g. estuaries. Dr. Tufford concluded that while there are similarities between reservoirs and coastal waters, there are also differences that strongly suggest reservoirs should be treated as a separate kind of water body for the purpose of permitting. Dr. Tufford indicated that ?a similar study is needed and the outcome cannot be known a priori, but until it is done, there is reasonable cause for concern that water quality protection is not assured.? Another case in point is the review of private marina permitting policies as part of the ongoing relicensing process. Members of the In reviewing the proposed project, we ask SCE&G to weigh the overall concerns of the lake community against the private interest of the developer. We have found only one individual other than the developer, who is in favor of this project. And as stated above, none of the agencies support docking facilities of this nature. To properly assess this request we ask your staff to answer the following questions: 1- Will the proposed project degrade the scenic values of this cove? 2- Will the addition of 84 slips in this cove, create boating congestion, public safety concerns and the possibility of loss of life? 3- Will this proposed project block and impair public use of a portion of the water in this cove? 4- Considering the size, is there a potential for gas spills, motor oil and gear oil leaks. Is the ?petro sorb? designed to contain all spills? 5- Considering the concentration of many boats, is there potential for fires including a catastrophic event? 5- Will increase boating traffic stir up sediments and impact the environmentally sensitive areas? 6- Will the increased boating traffic and the resulting wakes likely increase shoreline erosion and impact spawning areas? 7- Will the increased boating activity negatively impact the striper fishery in this area? 8- Will the increase in human presence negatively impact nesting water fowl? 9- Will the proposed project significantly change the existing character of 10- Does the project have the support of the lake community? 11- Does the DHEC study give reasonable assurance that the proposed project will not pollute the cove? 12- Will the proposed project contribute to concerns about cumulative impacts? 13- Will the proposed project protect and enhance the recreational, scenic and environmental values of the project as required by Article 30 of your license? Finally, as part of your assessment, we ask SCE&G to hold a public forum and provide a commenting period so the lake community will have an opportunity, as the developer has, to meet face to face with your staff to discuss our concerns. In conclusion, we oppose the facility as proposed and recommend that SCE&G use its discretionary authority and require the applicant to downsize the facility to no more than 40 slips. Attached is the letter from Dr. Tufford, and our detailed written comments. Sincerely, Bert Floyd- Lake Murray Homeowners Coalition Notice- Click here to review the LMHOC comments to the FERC
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