Fairfield Glade Inc. has applied to construct an 81-acre impoundment on Cove

Creek, a tributary to Daddy's Creek and the Obed National Wild and Scenic

River.  The application was made to the US Corps of Engineers under Section

404 of the Clean Water Act.  Before a permit can be issued, a 401(a)(1)

certification must be provided by the Tennessee Division of Water Pollution

Control.

I am writing on behalf of Tennessee Paddle to express our concern about this proposed dam, which is in the watershed of the Obed River, a National Wild and Scenic River which only last year received the designation of ONRW (Outstanding National Resource Water) by the State of Tennessee. Tennessee Paddle is a non-profit organization dedicated to the protection of

the Obed River and its tributaries. The primary mission of our organization is the protection of the Obed area.

There are numerous possible ways in which the project could have an adverse

influence on the water quality (which includes quantity) of Cove Branch, Daddy's Creek, and the Obed River.

*         The potential exists for pollution, both during construction and thereafter, especially in view of coal seams and mineral-containing soil in this region of the Cumberlands.  For example, a similar impoundment on an nearby stream, which created Dartmoor Lake, resulted in anoxic discharges containing mobile forms of metals, such iron.  This led to a coating of "yellow boy" in the streambed and banks below Dartmoor Lake. Impoundments typically cannot meet water quality criteria for iron, suspended solids, and dissolved oxygen. Also, the sediment released through dam construction would have immediate and unacceptable impacts on the river system.

*         The impoundment would have an adverse effect on natural streamflow

fluctuations in Daddy's Creek.  Daddy's Creek watershed has numerous existing dams.  We are concerned about the restriction of the natural streamflow caused by the proposed dam.

*         The applicants wish to develop the area around the proposed reservoir. Such an influx and concentration of residential and other developments in this drainage provides additional potential for pollution and sediment runoff into Cove Branch.

*         A number of threatened and endangered species find refuge in the Obed River watershed. Plants such as the Cumberland Rosemary and Virginia Spiraea depend on periodic flooding to survive. Populations of several freshwater mussels (Alabama lampmussel, the finerayed pigtoe, the purple bean, and turgid blossom) and a fish (the spotfin chub) are already stressed by low stream flow conditions in summer. Further reductions in availability of water and increased pollution and siltation would cause additional stress to these sensitive species. So far there has been no assessment of the effects of the proposed dam on these protected species.

We hope very much that the US Army Corps of Engineers and Tennessee Division of Water Pollution Control will refuse to issue the permits for this project to proceed.  Should the Corps of Engineers and Tennessee Division of Water Pollution Control issue the necessary permits, we will expect to see overwhelming scientific evidence that no adverse influences will result downstream of the proposed impoundment.

We feel that we should not sanction the sacrifice of stream habitat and public access to waterways when the benefit is for strictly private development.  This consideration is particularly pertinent in view of the fact that a major portion of Cove Branch, in the project area and downstream, forms part of the Catoosa Wildlife Management Area boundary.

Sincerely yours,

Tennessee Paddle