Smith Lake Topics: Gorgas

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	Name:	lotowner -
	Subject:	Gorgas
	Date:	1/12/2009 9:26:58 AM

Keyman

I read your response and the paragraph below roused my interest.

Gorgas steam plant was not in the original license or in the relicense as a project purpose. Public recreation is in the original license and the relicense as a project purpose. FERC has already told APC that it was going to have to at least follow their current rule curve, and as stated earlier APC can not follow its current rule curve without cooling towers or reducing Gorgas generation. The following is take from APC's own record to FERC.
"Limiting the amount of water that may be released from storage at Smith during the important summer
and fall seasons will prevent Gorgas Steam Plant from being able to operate and meet its
NPDES temperature requirements."

By this, I assuming that Smith Lake was created and licensed initially for Hydro electrical production only. It was also interesting that you noted tthat the Rule Curve was followed for many years until APC elected to instaall additional capacity at Gorgas. During this time, APC engineering apparently decided that major capital expenditures could be avoided by using the cooler water from Smith lake for cooling. This may have been a good option for APC but it apparently has become a disaster for water level managent during the warm months.

Based on this, I would assume that the odds of FERCE permitting APC for the next 40 years without requiring APC to install some type of site cooling at Gorgas is remote and unlikely. If it does happen, would the next step be relief via the courts? I would project that APC does not want a court case over this.

There appearss to be too much compelling evidence that APC has deviated from following the rule curve. My understanding is that if this is done, APC cannot operate Gorgas at full capacity. Is it not true that FERC has stated that APC must follow the Rule Curve? Maybe the verdict would be for APC to follow the Rule Curve.

Whatever is required at Gorgas to allow this would be at the expense of APC. This would be corrective actions that are required because of bad decisions by APC when additional capacity was installed at Gorgas. I do not view this in any manner as a developer issue.