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2-18-07 Oconee Water Option at Snapping Shoals- General Electric- Thomas Bros. Hydro

Proponents claim that this project has had favorable comments from GA EPD and it is working toward being permitted. It does not need a reservoir or COE Section 404 Permit.

AVOC

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February 18, 2007

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Oconee Water Option at Snapping Shoals- General Electric- Thomas Bros. Hydro

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By Wendell Dawson, Editor, AVOC, Inc

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Jasper County has voted to pursue this project and wants to work with Oconee County and “Wheel the Water” through intervening, interlocking systems.

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Proponents claim that this project has had favorable comments from GA EPD and it is working toward being permitted.  It does not need a reservoir or COE Section 404 Permit.

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EXCERPTS From Hoke Thomas Letter of 2-11-07 (See full report below)

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…Due to the abundance of raw water no reservoir is needed at Snapping Shoals, resulting in no need to finance and construct a $ 500 million dollar reservoir requiring the costly procedure of pumping supplemental raw water from the nearest available,

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..The site has an operating hydroelectric plant and is located within 1000 yards of the underground potable water transmissions lines of both Newton and Henry Counties. Development of this site as a 30 to 60 MGD raw water filter plant has (3) outstanding potentials:

(1)     Via “wheeling” the potable water can be used by The City of Atlanta/Fulton County and returned to the Chattahoochee River, reducing the withdrawals from the Chattahoochee River by 60 MGD.

(2)     Via “wheeling” the potable water can be used by DeKalb and Gwinnett counties technically as “recycled water”, reducing the withdrawals from Lake Lanier by 60 MGD.

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(3)     The water can be used by the six surrounding counties; Newton, Rockdale,

Henry, Butts, Jasper and Walton and any other counties who require water without having any investment in the project and with partial ownership, free of charge, including partial ownership of the EPD permit.

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Withdrawal Yield          30 MGD, 24 hours a day, 365 days a year

Storage Capacity          90 million gallons at lake above the dam

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The following total available withdrawal water exists at the withdrawal site:

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NORMAL FLOWS

South River                              387.7 MGD

Snapping Shoals Creek           27.7 MGD

Inter basin transfer flow              58.0 MGD

                                                   473.4 MGD available to withdraw 30 MGD

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DROUGHT FLOWS

South River                               57 MGD

Snapping Shoals Creek               6 MGD

Inter basin transfer flow              58 MGD

                                                 121 MGD available to withdraw 30 MGD

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7Q 10 FLOWS

   South River                              18.2MGD (for 2 days in 1954)                        

   Snapping Shoals Creek          2.6 MGD this is the 7Q10 “creeks end”

   Inter basin transfer flow            58.0 MGD  

                                                     78.8 MGD available to withdraw 30 MGD

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Thomas Brothers Hydro, Inc SITE HISTORY

            Located at Snapping Shoals on the South river and upstream of the 1910 Lloyd Shoals installation owned by Georgia Power, is a dam and hydroelectric plant owned by Thomas Brothers Hydro, Inc. According to the Newton County Historical Society, the Snapping Shoals dam was constructed in 1823.

            Back in the early 1900’s a hydroelectric plant was constructed on the old Snapping Shoals site that previously mechanically (water) powered a sawmill and gristmill. Electrical lines were constructed to Covington where the power was used. At this same time a study was conducted and plans were completed to construct a very large dam that would back water all the way up to what is now the Atlanta Airport. This larger and taller dam and resulting impoundment would greatly increase the electrical power in an effort to keep up with the power demands of industrial and residential growth in the surrounding counties.

On May 11, 1935 President Roosevelt signed an Executive Order, which created the Rural Electrification Administration (REA).

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In 1936 Snapping Shoals Power and Light was formed and their office was located at Snapping Shoals at the present site of the hydroelectric station. A government loan of $0,000.00 was granted to install 90 miles of transmission lines and serve 270 customers in Newton and Henry counties. In 1938 Snapping Shoals Power and Light became Snapping Shoals EMC and moved their offices to Covington. The EMC has served the surrounding counties ever since.

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Sadly, our near-sighted forefathers could not envision the need to properly plan for the future electrical needs of the surrounding counties; it was easier to take no action at all. Therefore, the existing hydroelectric potential of the Snapping Shoals site was never fully developed. Today, the same hydroelectric plant exists as it did in the early 1900s; but using the existing dam and flows in the river, additional hydroelectric equipment can be added resulting in the annual production of 5,000,000 KWH at the current national rate $.0732 per KWH = $ 366,000.00 in annual revenues.

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            But all is not lost.Unknown at the time to our forefathers was the most valuable asset of the site, not the hydroelectric potential, but the withdrawal and usage of the raw water flow in the river. Now about 100 years after our forefathers cast their damning vote not to develop the electrical power potential of the site, the citizens of the surrounding counties have the opportunity of a lifetime to have the Snapping Shoals site developed as the largest, most economical source of potable water in the area, now and for the future.

Sound economics of developing the Snapping Shoals site are two fold; first being the production of the most economical source of energy, the aforementioned operational hydroelectric plant and second, the abundant supply of raw water.

DRAINAGE BASIN AND RIVER FLOW DATA

.         Due to the tremendously large drainage basin of the South River at Snapping Shoals, the current EPA/EPD rules and regulations require an area seven miles above the withdrawal point to be evaluated as the Source Water Assessment Plan (SWAP). The entire river basin (drainage basin) above the aforementioned withdrawal point covers an area of 468 square miles. The area we are evaluating covers the most downstream part of the drainage basin and covers an area of 80 square miles or 50,560 acres. Unregulated flow is the natural flow from rainfall, while regulated flow is man made such as the permanent “extra” flow in the South River resulting from the raw water withdrawn from Lake Sidney Lanier (Chattahoochee River) by DeKalb and Gwinnett Counties and returned to the Ocmulgee River Basin once discharged some 27.5 miles upstream of the proposed withdrawal point. The Snapping Shoals Dam and raceway site dates back to 1823 and has the oldest Riparian rights to the withdrawal of the Inter Basin transferred water. A meeting was conducted with DeKalb County Public Works director, Mr. Roy Barnes and his staff resulting in the conclusion that DeKalb County is glad to discharge the Inter Basin Transferred water into the South River and has no future uses for the water. At a public hearing relating to the CSO for the City of Atlanta, Mr. Bob Scott, EPD Program Manager (404-362-2680) stated that the inter basin transferred water from Lake Sidney Lanier to the South River is permanent and that the cost and operation of the equipment to construct a pipe line large enough to pump the water back to the Chattahoochee River is totally cost prohibited. Presently, this inter basin transferred water flows at the rate of 58 mgd and is expected to get larger. The Federal USGS gauges the stream flows and is the keeper of the records and the agency that sets the 7Q10, which is the lowest consecutive seven day stream flow for the past ten years. When evaluating a potential withdrawal site, the EPD looks at the 7Q10 flow and makes the decision as to how much raw water can be withdrawn from the site without having to construct a reservoir for dry weather storage. In the case of the Snapping Shoals site, there is always 58 mgd flowing in the river in excess of the 7Q10. Therefore, 30 mgd can be withdrawn without the need to construct a reservoir. In fact, since the beginning of record keepingby the USGS, there have only been two days back in 1954 when the inter basin transferred water would have been needed. In other words, with the exception of two days, there has always been enough flow in the river at Snapping Shoals to exceed the 7Q10 and allow 30 mgd to be withdrawn without any negative effect on downstream ecology.   

The South River at the withdrawal point has the following characteristics:

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Average Flow                            600 CFS or 387.7 MGD (un-regulated)

Drought Flow                            88 CFS or57MGD (un-regulated)

Inter Basin Transfer Flow         58 MGD (regulated) (continuous)

7Q10 Flow (USGS)                    28 CFS or 18.2 MGD (un-regulated) year 1954 for 2 days

Withdrawal Yield                      30 MGD, 24 hours a day, 365 days a year

Storage Capacity                      90 million gallons at lake above the dam

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The withdrawal point is to be located at the confluence of the South River and Snapping Shoals Creek. Snapping Shoals Creek has the following characteristics:

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Average Flow                            42.9 CFS or 27.7 MGD (un-regulated)

Drought Flow                            9.3 CFS or 6.0 MGD (un-regulated)

7Q10 Flow (USGS)                       4.0 CFS or 2.6 MGD (un-regulated)

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Note: there is no withdrawal restriction or damage to downstream ecology of Snapping Shoals Creek due to the fact the withdrawal point is at the confluence of Snapping Shoals Creek and the South River. In other words, at the “Creeks end” all of the available stream is useable, can be withdrawn.

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The following total available withdrawal water exists at the withdrawal site:

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NORMAL FLOWS

South River                             387.7 MGD

Snapping Shoals Creek           27.7 MGD

Inter basin transfer flow              58.0 MGD

                                                    473.4 MGD available to withdraw 30 MGD

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DROUGHT FLOWS

South River                             57 MGD

Snapping Shoals Creek               6 MGD

Inter basin transfer flow              58 MGD

                                                121 MGD available to withdraw 30 MGD

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7Q 10 FLOWS

   South River                              18.2MGD (for 2 days in 1954)                        

   Snapping Shoals Creek          2.6 MGD this is the 7Q10 “creeks end”

   Inter basin transfer flow            58.0 MGD  

                                                     78.8 MGD available to withdraw 30 MGD

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In essence, if ever needed, Lake Sidney Lanier is the reservoir, via inter basin transferred water, for the Snapping Shoals project. The planned ownership of the facility with partnering counties gives the project a strong regional supply of drinking water and the existing reservoirs of these counties will also act as reserve capacity if ever needed.

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The following are a few elevation reference points above MSL:

According to GIS the crest of the Snapping Shoals dam is 556 msl, the crest of the downstream Georgia Power dam at Lloyd Shoals is 524 msl and the surface of the river at the confluence of Snapping Shoals creek is 536 msl. Therefore, the elevation difference from the crest of the Snapping Shoals dam to the confluence of Snapping Shoals creek with the South river is 20 feet, then from Snapping Shoals creek to the back waters of Jackson Lake (Lloyd Shoals) exists a 12 feet difference.

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All the flow data for this project was obtained from the USGS office at Doraville, Georgia, Mr. Tim Stamey (770-903-9138). We are most grateful for his contribution.

ASSESSMENT AREA

           For the Source Water Assessment Plan, the entire watershed that drains to the water intake at Snapping Shoals is within the protection area; however, the EPA has given the states flexibility to identify and assess smaller areas or segments of the overall, larger watershed area for a cost and time-effective analysis. Georgia’s Plan is based on protection distances defined in the EPD Rules of Environmental Planning Criteria, as part of the Georgia Planning Act of l989. The plan identifies three assessment zones within the water supply watershed upstream from a given drinking water intake.

  • The inner management zone (IMZ) – within a 7-mile radius above the intake.
  • The outer management zone (OMZ) – radius between 7 and 20 miles of the intake, and
  • The non-management zone (NMZ) – remainder of watershed above the OMZ.

The IMZ (referred to as the Area of Responsibility, “AOR”), is the area that was required for this SWAP. The map reflects only the specified seven mile radius territory above the withdrawal point.

SUMMARY AND RECOMMENDATIONS

Georgia State Attorney General Thurbert Baker recently stated “The decisions we make today concerning Georgia’s water resources will determine not just the safety of drinking water but its future allocation, not to mention the ability to attract industries with jobs and the vitality of Georgia agribusiness. Overall, a lot is at stake.”

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With the stakes so high it is imperative that the State pursue a comprehensive water management plan – one that will bring all stakeholders to the table, including representatives of water users, water providers, business, industry, agriculture, environmentalists, elected and appointed government officials, the State of Georgia, counties and cities, as well as Georgia citizens.All must have a seat at the table.

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Throughout most of the state’s history, Georgia has been considered a riparian state.Black’s Law states that a riparian water rights system treats surface water as a common resource shared between and among users.

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Water use legislation in the Eastern United States, of which our state is representative, says that water is a common resource and not a commodity.O.C.G.A Statute 12-5-91 provides guidance.That statute finds that the general welfare and public interest require the state’s water resources be put to the best use possible, subject to reasonable regulation, to conserve the resources and maintain conditions conducive to development and use of water resources, including Inter Basin transferred water.

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With reference to water rights, the water flowing in our streams belongs to the people. It is the responsibility of our State EPD to regulate and maintain wise and prudent uses of this most precious natural resource. One of the recent major accomplishments has been the connecting of potable water distribution systems between counties and cities allowing water to be “wheeled” in a similar fashion as our Electrical Utility Companies “wheel” electricity from one grid to another. Now by simply opening a series of valves, potable water can be transferred (wheeled) from an area having a surplus to one in need.

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Lastly, the permitted use of Inter Basin transferred water during the very low flow 7Q10 conditions is a blessing. Recognizing the availability of this additional flow totally negates the requirement to construct a reservoir.

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Butts County just downstream from the Snapping Shoals site was recently granted a permit to withdraw 9 MGD from the confluence at Lloyd Shoals. Butts County has no reservoir. EPD has required that a withdrawal site construct a reservoir to store water on an emergency basis in order to “ride out” the low flow 7Q10 conditions, unless there is additional flow in the river above the 7Q10 reduced flow.

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The same Inter Basin transferred water that flows through Snapping Shoals also flows a short distance down river through the Butts County withdrawal site. Therefore, for Butts County to be issued a withdrawal permit and no requirement to construct a reservoir, the State EPD has recognized the value of the use of the Inter Basin transferred water. Butts County is currently doing the same thing that The Snapping Shoals facility is requesting to do. Also, 21 mgd of Inter Basin transferred water from the Yellow riverflows through the Butts County withdrawal site.

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            7Q10 is 7Q10, regardless of the geographical location of the withdrawal site within the river basin. Therefore, for a site to be issued a withdrawal permit without the requirement to construct a reservoir, additional water above the 7Q10 flows must be acknowledged. This is the case for Butts County, likewise The Snapping Shoals site is requesting the very same courtesy: that is to utilize (withdraw) the inter basin transferred water should a low flow 7Q10 stream flow condition ever occur again as was the case back in 1954 for a two day period.   

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Currently there are more than 30 Inter Basin transfers taking place within our state and 25 plus water systems transferring (wheeling) water. Due to the cost involved with returning the permitted Inter Basin transferred water back to its source of origin, the initial questions concerning this issue no longer exist. Our resources must be directed towards the best use scenarios.

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The major Inter Basin transfer of water within our State is created by the withdrawal of water from the Chattahoochee River (Lake Lanier) by the counties of DeKalb withdrawing(56 MGD) and discharging it into the South river and Gwinnett withdrawing (21.5 MGD) and discharging it into the Yellow River. Both discharges are into the Ocmulgee River from the Chattahoochee River. (Most of the water withdrawn by Fulton County from the Chattahoochee River is treated and returned to the source) Raw water withdrawn from Lake Lanier goes through a process and is filtered to potable (drinking) water standards, it is used and in its deteriorated state is once again treated back to standards at or above its raw water state at withdrawal and then discharged.

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Both the withdrawal and discharge processes are permitted and regulated by the EPD. A customer’s water bill is payment for the services rendered to the water; to take raw water and make potable from it, then take the water in its deteriorated used state, treat it back to or better than its original withdrawn state and discharge (dispose of) it.

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The customer buys the services performed, not the water. How could you purchase something that you already own? The water belongs to the people. If this statement were not so, then every county or municipality discharging treated effluent into the Ocmulgee River from its origin to the 12 mile limit off shore would all own a percentage of the river and respective ocean out to 12 miles, along with multiple other legal ramifications.

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With respect to our “Free Enterprise System”, royalties would be due these dischargers any time the rivers or ocean waters are used for pleasure or business. This type of arrangement is totally impossible. Ownership of the discharged Inter Basin transferred water as well as any other type water discharged is not the property of the entity performing the discharging. Again, the water belongs to the people or the next down stream user.

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Due to the topography of the land, raw water withdrawn from Lake Lanier is discharged into the South River some 27.5 miles upstream of Snapping Shoals. During this 27.5 mile trip to Snapping Shoals the water is aerated twice, once at Peachstone Shoals and then at Snapping Shoals, above the selected water filtration plant site, reducing the Fecal Coliform Bacteria count and greatly increasing the dissolved oxygen content.                

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      A potential raw water withdrawal site located 30 miles southeast of Atlanta, having riparian rights to use the water dating back to 1823, located on a large river, having a supplemental flow from an adjoining large creek and also having a large long term flow of additional water from Inter Basin transferred water, equates to possibly the most important drinking water source in the region. The Snapping Shoals site is located on the terminus of the South River, just before its confluences form the Ocmulgee River and possesses all of these attributes.

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      Furthermore, the site has an operating hydroelectric plant and is located within 1000        yards of the underground potable water transmissions lines of both Newton and Henry       Counties. Development of this site as a 30 to 60 MGD raw water filter plant has (3) outstanding potentials:

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(4)     Via “wheeling” the potable water can be used by The City of Atlanta/Fulton County and returned to the Chattahoochee River, reducing the withdrawals from the Chattahoochee River by 60 MGD.

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(5)     Via “wheeling” the potable water can be used by DeKalb and Gwinnett counties technically as “recycled water”, reducing the withdrawals from Lake Lanier by 60 MGD.

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(6)     The water can be used by the six surrounding counties; Newton, Rockdale,

Henry, Butts, Jasper and Walton and any other counties who require water without having any investment in the project and with partial ownership, free of charge, including partial ownership of the EPD permit.

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With respect to items number (1) and number (2) the returned or recycled water would directly reduce the withdrawals from the Chattahoochee river (Lake Lanier) by 60 MDG and help to ease the ongoing dispute between Georgia, Alabama and Florida over flows in the Chattahoochee river.

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The Upper Ocmulgee River basin is most unique, for it is the recipient of the inter basin transferred water. No other river or withdrawal site in the State of Georgia has these positive characteristics in such large quantity because of the site’s 1823 riparian rights to use the normal flow plus the additional Inter Basin transferred flow.

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Due to the many miles of river between the introductions of the Inter Basin transferred water down river to Snapping Shoals, the water experiences natural purification and its quality is greatly enhanced. This distance is of great importance.

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Recognition and immediate usage of this Inter Basin transferred water is in the best interest of the surrounding counties and their citizens if the aforementioned option (3) is utilized, also just as important to the States of Alabama and Florida as these options are utilized (1 and 2).All the Counties and municipalities located in the entire river basin from its point of origin just north of Snapping Shoals to its discharge into the Atlantic ocean at Darien, Georgia, withdraw, use, treat and discharge this same water back into the Ocmulgee River. The normal flow in the river is “recycled” many times.

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This situation is not unique; all river basins are managed in the same fashion. It is a common practice used in every country.It is the very lifeblood of our Nation and most especially our State, being one that has no rivers entering into it and the creation of all water in Georgia is from groundwater sources and rainwater. This use is monitored, regulated and enforced by each state’s EPD.       

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           The primary threat to the source water quality for the Snapping Shoals AOR is the threat that roadways present in terms of the potential for the release of spills from transport vehicles using the bridges within said area. The secondary threat to the Snapping Shoals System water source is limited to residential septic tanks and 8 gas stations having underground storage tanks permitted by the EPD.

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          This source water assessment plan can be used by the Snapping Shoals Raw Water Treatment Facility in times when emergency response is needed in reaction to a possible contamination of the drinking water supply. Depending on whether the potential contamination is coming down the South River or Snapping Shoals Creek, the pickup point for the raw water can be switched to either Snapping Shoals Creek or the South River, utilizing a weir to be put in place by the civil construction.

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          Under normal conditions water will be withdrawn from the confluence of Snapping Shoals Creek and the South River. The information contained herein can be used to communicate with authorities relative to the distances of road crossings and other features to the drinking water intake.By identifying various in stream lengths from potential contaminants to the drinking water intake, scientists and water managers involved in emergency response will be able to use these data to estimate contaminant travel time to the intake(s). This plan includes the names and phone numbers of federal, state and local government agencies to be notified in the event an emergency response is needed.The use of the emergency number 911 will be utilized.

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The Snapping Shoals facility has an abundant source of raw water coming from three different sources; The South River with an average flow of 387 MGD, Snapping Shoals Creek with an average flow of 27.7 MGD and the Inter Basin transferred water presently at 60 MGD coming from the Chattahoochee River/Lake Lanier. These combined flows are always above and beyond the 7Q10 requirements regardless of the season of the year and more importantly in extreme drought conditions.

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The site has an existing 90,000,000 reservoir, the raw water source is only 1100 feet from the proposed filter plant, and the recently tested quality of the raw water meets or exceeds all EPD and Federal Standards.

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The withdrawal point is most unique for it can be bifurcated in the event one of the two raw water sources becomes contaminated. The site is centrally located within the (6) county area and lastly is within 1000 feet of Henry and Newton counties potable water line.

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The General Electric Company using the most advanced “Ultra Filtration” equipment, which can filter raw water to potable water removing all unwanted items down to .03 microns, will construct the proposed filter plant.

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The proposed Snapping Shoals facility is located within one mile of Georgia Power’s main electrical transmission line and adjacent to Snapping Shoals EMC’s main transmission line. An operating hydroelectric station with the potential for increasing the output up to 1500 KW exists. The existing and future expansion of the hydroelectric station will decrease the utility bills for the facility and allow independent water filtration operations and pumping to continue for survival water supply to the local and Metro Areas even in the case of a National emergency.

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With respect to the present Thomas Brothers/General Electric proposal, any participating Counties can become partners in the project by simply “signing on” for a percentage of the finished water production. This process requires no money to be invested by the counties, no bond issues and no money to be paid down in advance of production.

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Both Thomas Brothers and The General Electric Companies will be reimbursed for their investments by the existing standard of billing which is per 1,000 gallons of finished water consumed by the respective counties customer. Lastly, no additional property needs to be purchased or condemned, no wetlands need to be destroyed and no wetland mitigation need be considered. The price of the finished water to be delivered is calculated to be in the range of $ 2.00 per 1,000 gallons based on a 20-year estimated return on the overall investment.

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The current calculations for finished water are based on the cost of the permit and the filter plant and its operational cost. (These calculations are available to any entity that would be interested in doing a third party analysis on the water costs to the users)

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Due to the abundance of raw water no reservoir is needed at Snapping Shoals, resulting in no need to finance and construct a $ 500 million dollar reservoir requiring the costly procedure of pumping supplemental raw water from the nearest available, free flowing, large stream. Reservoirs are normally financed and paid for by bond issues and are not “figured in” with the cost of the finished water production, but are handled with a separate financial agreement. Therefore the cost of the finished water production does not include the cost of the reservoir. For example, to pay back a $00 million dollar reservoir in 20 years, with 4.5% interest on the debt, at the filtration rate of 30 MGD, would require a payment of $05,438.00 daily or this would add $.51 per 1,000 gallons to the customer’s water bill making the cost of the delivered finished water $.51 (reservoir) plus $.00 (delivered, finished water) equaling $.51 per 1,000 gallons. A further devastating example of paying back the monies to construct the same $00 million dollar reservoir with daily production reduced to only 20 mgd from the aforementioned 30 mgd plant would raise the cost per 1,000 gallons from $.51 to $.27 making the cost of the delivered finished water total $.27 (reservoir) plus $.00 (delivered, finished water) equaling $.27 per 1,000 gallons. In conclusion, as the production (usage) goes down the cost of the finished water goes up, but the daily reservoir debt of $05,438.00 remains constant. Again, the cost of the finished water produced at Snapping Shoals will be in the range of $.00 per 1,000 gallons. The Thomas Brothers/GE scenario based on daily production, only requires payment by the user for the finished water. A reservoir requires the taxpayer/ratepayer to pay debt service for the multi-million dollar cost of the reservoir plus the cost of the finished water—whether it is one gallon or 30 MGD. The aforementioned cost figures do not include the margin that the distributor/water authority/county would add for their purposes. These margins could raise the cost of the reservoir water to near $.00 per 1,000 gallons to the consumer. A consumer currently paying $0.00 per month for water would then be paying $30.00 per month for water. This equates to an unreasonable amount and many on fixed incomes could not afford to pay their water bills. This is the reason that General Assembly got out of the reservoir business. You cannot pay back the investment necessary to build a reservoir with water revenues alone.

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In accordance with Georgia Environmental Protection Regulations, Thomas Brothers Hydro, Inc. SWAP clearly indicates the Snapping Shoals site has (1) The available raw water, (2) The required finances necessary to totally eliminate any county from having to invest monies in the project, (3) Is located adjacent to the necessary “in ground” infrastructure for distribution, (4) Requires no further procurement of real estate or wetland mitigation and offers all of these most positive aspects to the entire Region as positive proof of the development and optimization of our natural resources for the public good in (5) An environment of Public/Private Enterprise.

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EPD made the following comments at our November 7, 2006 meeting with them to discuss the status of our withdrawal permit:

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Allow the free enterprise system to work, no written agreement with DeKalb County concerning the status of the inter basin transferred water is required, only to inform our customers of our intent to use this water if ever needed due to a prolonged drought.

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Demonstrate the present and future needs for the water and potential customers.


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