ML13114A105
| ML13114A105 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 03/25/2013 |
| From: | Barker D, Destefano T - No Known Affiliation |
| To: | Macfarlane A NRC/Chairman |
| Shared Package | |
| ML13114A106 | List: |
| References | |
| G20130318, LTR-13-0347 | |
| Download: ML13114A105 (5) | |
Text
ETS SU.S.NRC United $tatý Nuclear I.cgulator. Commission Prote'ting gople and the Environment Ticket No: G20130318 2485 information
`
Assigned Office: NRR Other Assignees:
OEDO Due Date: 05/22/2013 SECY Due Date: 05/22/2013 Date Response Requested by Originator:
Other Parties:
Subject:
Duke Energy Lake Keowee - Toxaway Relicensing Application
==
Description:==
CC Routing: Regionli ADAMS Accession Numbers - Incoming: ML13114A105 Response I Package: ML13114A106 r
Infrmaio Cross Reference No: LTR-1 3-0347 SRM\\Other: No s Inomain Action Type: Letter Signature Level: NRR Special Instructions:
OEDO Concurrence: No OCM Concurrence: No OCA Concurrence: No
- 3.
nen Inforatio Originator Name:
Originator Org:
Addressee:
Incoming Task:
Thomas M. Destefano, Jr.
Citizens Chairman Macfarlane Letter Date of Incoming: 03/25/2013 Document Received by OEDO Date: 04/24/2013 OEDO POC: Dan Merzke
Wed, Apr 24, 2013 09:05 1
Page No:
OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET LTR-13-0347 PAPER NUMBER:
04/23/2013 LOGGING DATE:
ACTION OFFICE:
EDO AUTHOR:
AFFILIATION:
ADDRESSEE:
Macfarlane A M
SUBJECT:
LTR-13-0347 - Thomas Destefano Ltr. re: Duke Energy Keowee - Toxaway Relicensing Application ACTION:
RF, SECY to Ack.
Direct Reply DISTRIBUTION:
ACKNOWLEDGED:
03/25/2013 Lead Office to Publicly Release 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after Secy's assignment.
No LETTER DATE:
SPECIAL HANDLING:
NOTES:
ADAMS FILE LOCATION:
DUE DATE:
05/22/2013 DATE SIGNED:
Destefano, T Sunset, SC
Thomas M. Destefano Jr 305 Cool Water Way Sunset,SC 29685 March 25,2013 Ms. Allison M. MacFarlane, Chairman U.S. Nuclear Regulatory Commission Washington, DC 20555-0001 Ms. MacFarlane, Attached is a copy ofa letter recently disseminated to 1322 residents and property mvners who have signed a petition opposed to Duke's proposal to lower the floor level of Lake Keowee another five (5) feet, to 790 feet above mean sea level.
The letter discusses the findings of a study recently conducted by Professor Dave Wyman of Clemson University regarding the potential impact on real estate values should Duke lower the Lake Keowee floor to 790 feet. The findings and study will be presented and published in April 2013 at American Real Estate Association conference. The potential consequences of Duke's proposal are significant and severe for Oconee and Pickens Counties and residents.
Please do not let Duke run rough-shod over the residents and citizens of Oconee and Pickens Counties in the interest increasing ofcorporate profits. Demand that Duke incorporate Professor Wyman's findings into its application and set forth for all reviewers to consider the potential economic consequences ofDuke proposed application plan.
Under Duke's current application proposal, 100% ofthe burden oflowering the floor ofLake Keowee falls on the residents and citizens ofOconee and Pickens Counties while 100% ofthe benefits accrue to Duke. Such a one-sided arrangement is patently unfair. Demand that Duke reconsider its plan and proposal to lower the floor level ofLake Keowee to 790 feet.
Thank you for your consideration of this matter.
Sincerely,
To: 1322 Interested petitioners and other interested parties March 21,2013 As part of Duke Power's Keowee-Toxaway hydropower relicensing application, Duke maintains that the findings oftwo studies done in 2010 are sufficient for Duke to draw the conclusion that there will be little to no property value impact on Lake Keowee real estate as a result of its proposal to lower Lake Keowee an additional 5ft., to 790 ft. during drought conditions..
The two studies on which Duke is relying in support of its application were conducted by Allen, et al., in 2010. The first study was conducted for the Corp. ofEngineers and focused only on Lake Hartwell and encompassed a six county area. The study concluded that the economic impact on the entire six counties would be minimal. Although the second Allen study did include Lake Keowee, it assumed the water level would not drop below the current minimum of795 ft. and it did not include the impact of property value reductions.
Duke is relying on the aforementioned studies to conclude that the lowering of Lake Keowee another 5 ft., as proposed in its application, will have neither an economic impact on Oconee and Pickens Coun!)' nor a significant impact on property values. The lack ofeconomic impact is, of course, the very conclusion Duke wants. Duke has steadfastly refused to conduct a focused study of the economic impact on the Lake Keowee area ofits proposal to lower the water level floor to 790 ft. despite the fact that multiple stakeholders and property owners have requested Duke to do so. The 1322 Petitioners that have signed a petition in opposition to Duke's proposal believe the use of the aforementioned studies is clearly wrongful and misleading, and, now, the facts set forth below unequivocally support our beliefs.
In a research paper to be presented at the American Real Estate Association conference in April, Professor David Wyman ofClemson University will present his findings from a 2013 study focused solely on the economic impact on the Lake Keowee area, and hence Oconee and Pickens Counties, of Duke's proposal to lower Lake Keowee to 790 ft.
during drought conditions. Dr. Wyman's academic area of expertise is in assessing the factors that impact real estate values.
As mentioned above, Professor Wyman's paper will be finalized and presented in April 2013. What follows is a very brief summary ofthe facts and conclusions ofthis study.
Professor Wyman reviewed real estate transactions on both Lake Hartwell and Lake Keowee in Oconee County between 2002 and 2012 in order to obtain an accurate and comparable assessment ofthe impact of lake levels on property values. Using topographic data obtained from Duke through the Freedom ofInformation Act, GIS information obtained from Oconee County and input from a local dock manufacture to determine at what level each property would be "dockable", Dr. Wyman concluded that 4 7.7% ofthe lots on Lake Keowee would be undockable at 790 ft. This finding compares
with Duke's conclusion that 46% would be undockable and confirms the accuracy ofDr.
Wyman's data base.
Dr. Wyman used actual sales data and lake levels from Lake Hartwell over a 10 year period to extrapolate the projected impact the lowering of Lake Keowee' s floor to 790 ft.
would have on Lake Keowee real estate values. In order to further confirm the accuracy ofhis data and conclusion, Dr. Wyman compared the Lake Keowee conclusions with similar studies conducted on Lake Lanier (Georgia) and Lake Comoe (Texas).
What Professor Wyman concluded from the Hartwell data, and that which was supported by both the Lanier and Comoe studies, is that a single short duration lowering ofthe Lake Keowee level would have a moderate impact on real estate values (-14%), but that any sustained lowering ofthe lake level would have a dramatic and permanent impact on real estate values (-32%). The aforementioned projected diminution in value estimates is, of course, an average for all properties. However, what is notable is that those properties in shallower water that will become undockable will be impacted significantly (>-50%)
while those in deeper water will be impacted less.
A pretext of Duke's application and proposal to lower Lake Keowee's floor to 790 ft. is its claim that the lake will be subject to drought conditions and therefore down below 795 ft. (current floor) only 4% ofthe time. What Professor Wyman's review ofthe Lake Hartwell data concluded was that by using a more relevant time frame, these drought conditions are in excess of4% and occur for extended periods oftime. Once Lake Hartwell was lowered the lake level remained down for extended periods oftime. For example, when Lake Hartwell was lowered below 654 ft. in August 2007, it was not refilled until April 2009 (21 months later). The result was an 85% drop in Hartwell real estate values for raw land (which suggests that Dr. Wyman's -32% number is likely conservative).
The facts are now in and they are irrefutable. There can be no doubt that Duke's proposed application to lower Lake Keowee's floor to 790 ft. will result in a significant and long term impact on Oconee and Pickens County property values, tax revenues and school funding.
The question that remains unanswered is why Duke desires to lower the Lake Keowee floor to 790 ft. Virtually everyone involved, including Duke, acknowledges, that the amount of water involved in lowering the lake 5 ft. is minimal compared to the volumes of the other downstream lakes and that lowering the lake is a one-time event (once the water is gone it is gone forever).
Now is the time to act. Write your representatives on the county councils and at the state and federal level and tell that them that you think a decrease in your property values, school tax revenues and County tax revenues based merely on Duke's desire to have more flexibility in its nuclear plant operation is unacceptable. Demand that your representatives not sign off on Duke's application until and unless Duke incorporates into its application Professor Wyman's conclusion regarding the potential significant financial
impact on Oconee and Pickens County property owners, tax revenues, school tax revenues and ultimately all Oconee and Pickens County residents.
Doug Barker Newton Brightwell Lake Keowee Homeowners Petition originators