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Restore Chattooga Gorge

Photo by: Miguel A Gomez

update: september 2022

The Restore Chattooga Gorge coalition has had a busy summer!  At the forefront was intervening in the Georgia Public Service Commission’s (PSC) hearing docket for GA Power’s 2022 Integrated Resource Plan (IRP).  Every three years, GA Power is required to update its IRP, which is a 20-year plan detailing what energy sources the power company intends to use to provide electricity to customers.  Our goal as an intervenor was to challenge GA Power’s plans to upgrade the turbines at Tugalo Dam, that would cost around $115 million. We hold that modernizing the turbines prior to the upcoming Federal Energy Regulatory Commission (FERC) hearings, for whether or not to relicense the 100-year-old dam, would unduly prejudice the FERC process.

Intervening in the PSC hearings followed Restore Chattooga Gorge coalition’s earlier intervention (in Nov. 2021) in a different FERC proceeding about GA Power’s request for a license amendment to permit modernizing Tugalo Dam’s turbines.  The coalition is being represented by the Southern Environmental Law Center in this FERC proceeding, and was represented by Taylor-English-Duma LLC in the PSC hearings  Our goal for intervening in both the FERC and PSC proceedings is to present the compelling case for consideration of decommissioning the Tugalo Dam.

The GA PSC’s quasi-judicial proceedings were ongoing from March to August.  Our team retained legal counsel to help navigate the PSC hearings, testimonies, witnesses and cross-examinations.  Our witness panel consisted of representatives from American Rivers and the Nantahala Outdoor Center, and their testimony laid out the huge ecological and economic benefits to be gained from decommissioning the old Tugalo Dam.

The argument presented by our respective counsels for both the PSC and FERC proceedings is similar:  If the power company receives blanket approval to replace Tugalo Dam’s turbines (using approximately $115 million of rate-payers monies) to function for another 40 years as stated by GA Power, this would be an irretrievable investment prejudicing FERC’s upcoming proceedings about whether or not to even relicense the aging Tugalo Dam, which are scheduled to start in 2031.

The outcome of the GA PSC hearings was that the PSC declined to engage in the issue.  FERC has not yet decided on GA Power’s license amendment request.  Meanwhile, our counsel identified an error of law in the PSC decision, and has filed a petition for declaratory and injunctive relief in the Fulton County Superior Court.  Additional funds for legal expenses are needed!  Please consider a dedicated contribution so that we may continue this work to Restore Chattooga Gorge.

Background

Built by Georgia Power in 1923, Tugalo Dam is responsible for the impoundment of over 4 miles of the Chattooga River and 2 miles of the Tallulah River. Typically, dams like Tugalo are up for relicensing every 40-50 years, with Georgia Power due to begin their relicensing process in 2031. However, Georgia Power has just filed for a licensing amendment that has the potential to seriously impact the outcome of their approaching relicensing procedure.
As an organization dedicated to the health and ecological integrity of the Chattooga River watershed, fully restoring the Chattooga to its most natural, free-flowing, and ecologically robust form is top priority. Our vision of an unencumbered river has always been diminished by the existence of the Tugalo Dam, and the sudden dispersion of the free-flowing Chattooga into the stagnation of Lake Tugalo.
1923 construction of Tugalo Dam buried over 4 miles of the Chattooga River.
Today, achieving this vision is gaining momentum! A group of organizations, including the Chattooga Conservancy, American Rivers, American Whitewater, Upstate Forever, Naturaland Trust, and the Georgia Canoeing Association is now allied in an effort to pursue Tugalo Dam removal. We believe the argument for dam removal is comprehensive and compelling.
The Chattooga Conservancy and our partners have corresponded with Georgia Power, proposing a collaborative partnership that would work towards examining alternatives to Tugalo hydroelectric production, and the feasibility of removing the dam in a safe & responsible manner. But, rather than entertain working together, Georgia Power has just filed an application with the Federal Energy Regulatory Commission (FERC) to amend its operating license, which expires in 2036, angling for permission to spend over $25 million updating the Tugalo Dam and rebuilding major components.
We believe approval of facility modernization circumvents the FERC licensing process where impacts and alternatives are reevaluated. It is both unnecessary and inappropriate, because approval would influence the outcome of the overall relicensing process (due to commence in 2031), thus ensuring continued dam operation and Chattooga River impoundment for at least another 50 years.
ACTION
You have the opportunity to join in efforts to Restore the Chattooga Gorge! Please submit your comments to FERC, making it known that you are categorically opposed to Georgia Power receiving a licensing amendment.
In addition to advocating for dam removal, we urge you to request that:
(1) FERC require Georgia Power to produce comprehensive studies that evaluate impacts created by continued dam existence, and
(2) Georgia Power provide objective information on a) the reasons modernization of the Tugalo facility should happen now, prior to the formal relicensing process, and b) why they are choosing to further invest ratepayer money into outdated hydroelectric infrastructure, rather than into a less impactful renewable such as solar power.

TAlking points

  • UNEssential Energy:

    The Tugalo Dam, built over 100 years ago, only produces 45 megawatts of power. This represents less than 1% of Georgia Power’s total energy portfolio, which will be made further redundant once the Vogtle Nuclear Facility becomes active next year.

  • Greener Alternatives:

    The energy loss caused by dam removal could sufficiently be replaced by more efficient & less impactful sources, such as increasing capacity at a different hydroelectric dam in Georgia Power’s North Georgia Project, or further investment into Georgia Power’s growing solar portfolio.

  • Rising Sediment:

    Growing sediment levels are reaching critical mass in the lake, negatively affecting dam efficiency, affecting lake water capacity and flood event storage, navigability and downstream aquatic health, and will potentially require costly mitigation measures – none of which Georgia Power has shown consideration.

  • Ecological Imperative:

    Dam removal & lake bed rewilding would restore ~600 acres of biologically rich forest land, thus increasing carbon storage & sequestration, as well as providing habitat and migratory corridors for many species of native plants and wildlife. These measures will improve ecological resilience in the watershed – a vitally important measure as the effects of climate change accelerate at alarming rates.

  • Economic Opportunity:

    The Chattooga River was granted wild & scenic river status in 1974. Yet, for over one century, the last few miles of this national treasure have been buried in an impoundment. Thousands of people come to recreate in the Chattooga River watershed each year, and the removal of the dam would restore over 4 miles of the Chattooga River, and 2 miles of the Tallulah River. Dam removal would facilitate an increase in tourism associated with recreational opportunities such as world class whitewater boating, fly fishing, and hiking.

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COMMENT
The deadline for comments was Friday, November 26th, 2021.
  • Follow this link https://ferconline.ferc.gov/QuickComment.aspx
  • Fill out your contact information. You will then receive an email directing you to a commenting page.
  • Enter Docket Number P-2354-152, select the docket, fill out your comment and submit!
We appreciate your help to Restore Chattooga Gorge, and will keep you updated as this project progresses.

You can read our correspondence with Georgia Power here.