FAQ
FAQ -
Tulloch Shoreline Management Plan Frequently Asked Questions
The Tri-Dam Project prepared these Frequently Asked Questions (FAQ) and answers to facilitate review of the draft updated Shoreline Management Plan for the Tulloch Hydroelectric Project, Federal Energy Regulatory Commission (FERC or Commission) Project Number 2067 (Project).
1. What is the Tulloch Reservoir Shoreline Management Plan?
Article 413 of the FERC license for the Project requires FERC approve any uses of lands or waters within the FERC Project Boundary, which at Tulloch Reservoir is all lands and water within an elevation of 515 feet, to ensure the uses do not conflict with Project purposes. Recognizing that some approvals can be facilitated at a local level, FERC allowed that Tri-Dam Project, the licensee, approve some minor activities (e.g., boat docks, wharfs) if they are identified in a Shoreline Management Plan (SMP). Activities not included in the SMP must be approved by FERC under Article 413 of the Project license.
2. Is there an existing SMP?
During Project relicensing, Tri-Dam Project developed and filed with FERC a Tulloch Reservoir SMP that FERC approved in 2002 and included in the Project license. As required by FERC, Tri-Dam Project updated the 2002 SMP and FERC approved the updated SMP in 2015.
3. Why is Tri-Dam Project updating the SMP now?
The 2015 SMP required that once every 10 years, Tri-Dam Project consider whether the existing SMP meets current needs and conditions and if any changes to the SMP are needed. To perform this adequacy assessment, Tri-Dam Project would consult with stakeholders, including federal, State, and local agencies, and representatives of commercial marinas and homeowners’ associations (HOA) that have lands directly abutting Tulloch Reservoir. However, the 2015 SMP states that, regardless of this consultation, if Tri-Dam Project on its own determines that the SMP needs to be substantively updated, Tri-Dam Project must file an updated SMP for FERC approval. To prepare for the 2026 adequacy assessment, in late 2025, Tri-Dam Project reviewed the 2015 SMP and determined the SMP needed substantive updates. To streamline preparation and filing with FERC of a proposed updated SMP, Tri-Dam Project prepared a draft updated SMP to correct the inadequacies Tr0Dam Project found in the 2015 SMP.
4. When will the updated SMP become effective?
The 2015 SMP will remain in place until FERC approves an updated SMP, as may be modified by FERC once it is filed, after which the updated SMP will replace the 2015 SMP. Tri-Dam Project
anticipates FERC will approve the updated SMP by early 2027, but timing of the approval is ultimately determined by FERC.
5. Who is Tri-Dam Project required to consult with to update the SMP?
Tri-Dam Project is required by the 2015 SMP to consult with federal, State, and local agencies, and representatives of commercial marinas and HOA that have lands directly abutting Tulloch Reservoir.
6. Is Tri-Dam Project required to hold a public meeting for the SMP update?
The 2015 SMP requires Tri-Dam Project consult with federal, State, and local agencies, and representatives of commercial marinas and HOAs that have lands directly abutting Tulloch Reservoir, but it does not specifically require a public meeting.
7. How is Tri-Dam Project consulting?
On May 17, 2026, Tri-Dam Project distributed to federal, State, and local agencies, representatives of commercial marinas and HOAs that have lands directly abutting Tulloch Reservoir, local landowners and potentially-interested Native Americans and NGOs a draft redline and clean version of Tri-Dam Project’s proposed updated SMP for 30-day review and comment. On June 17, 2026, Tri-Dam Project extended the comment period for an additional 30 days. The distributed redline version of the draft updated plan showed Tri-Dam Project’s proposed changes to the 2015 SMP, including rationale for each change and, for ease of review, the distributed clean version of the draft plan showed the plan with all Tri-Dam Project’s proposed changes accepted. Tri-Dam Project will attach and address all written comments on the draft updated SMP in the final updated SMP Tri-Dam Project files with FERC, and if any suggested changes are not adopted, provide the reason why Tri-Dam Project did not adopt the suggested change.
8. Does the 2015 or draft updated SMP change private property rights?
The 2015 SMP does not change property ownership or private property rights but establishes requirements for certain shoreline uses and occupancies within the FERC Project Boundary that are subject to Tri-Dam Project’s authority under the FERC license. The draft updated SMP does not change these property ownership or private property rights.
9. Will property owners be responsible for managing aquatic vegetation around their shoreline facilities?
Yes. Under the updated Shoreline Management Plan (SMP), property owners will be responsible for managing aquatic vegetation associated with their permitted shoreline facilities. The permitting guidelines address aquatic vegetation in a manner that supports shared responsibility for shoreline facilities. The intent of these provisions is to promote shared responsibility for maintaining shoreline facilities and adjacent use areas while ensuring that vegetation management activities are conducted in a consistent manner that protects reservoir resources.
10. I noticed some references and details in resource plans in the Project license that were included in the 2015 SMP are not in the draft updated SMP. Why were they removed and does that mean Tri-Dam Project will have no obligation to adhere to the plans if the updated SMP is approved by FERC?
The resource plans are stand-alone plans in the license that describe Tri-Dam Project’s obligations in certain areas (e.g., vegetation management). The summary of the plans in the 2015 SMP led to confusion because each plan includes detailed measures and nuances that, when taken out of context in a summary, are misleading. In addition, the resource plans may be amended, with
FERC’s approval independently of the SMP, so a summary in the SMP may become out of date. For these reasons, the draft updated SMP lists the resource plans but does not attempt to summarize each plan but directs the reader to where the plan may be accessed for full review. Whether or not a resource plan in the license is summarized in the SMP, Tri-Dam Project’s obligations to implement the measures in the plan remain part of the FERC license and Tri-Dam Project’s obligation.
11. I noticed the draft updated SMP includes requirements for annual permits and annual shoreline fees that were not required in the 2015 SMP. Why were these added?
The proposed annual permit and fee provisions are intended to support ongoing administration of shoreline facilities within the FERC Project Boundary. Annual permits help maintain current ownership records, facility information, compliance documentation, and communication with permit holders. Any fee structure would be established through a separate Board process and would be used to support shoreline management program administration and implementation.
12. I noticed the draft updated SMP treats “grandfathered” facilities differently than the 2015 SMP treated them. Why?
The 2015 SMP acknowledged that many unauthorized structures and facilities were constructed on Tulloch Reservoir before 2015 and many structures that did not comply with the standards in the 2015 SMP had been authorized by Tri-Dam Project before then. These facilities and structures were referred to as “Grandfathered Facilities”. The draft updated SMP also acknowledges them. When the 2015 SMP was approved, Tri-Dam Project assumed that many of the Grandfathered Facilities would reach the end of their useful life over the next 10 years and the owners of the facilities would wish to replace or upgrade the facilities, which would require the owner submit to Tri-Dam Project an application for the replacement structure or upgrade, in conformance with the 2015 SMP. However, Tri-Dam Project is not receiving commensurate levels of permit applications to replace or upgrade these Grandfathered Facilities and the owners may be assuming they can modify, including replace, the Grandfathered Facilities in any way they choose. This was not Tri-Dam Project’s intent nor does it ensure environmental protection. Therefore, the draft updated SMP moves toward a consistent permitting framework by requiring all facilities to obtain authorization and conform to current SMP requirements over time. The objective is to improve public safety, administrative efficiency, ensure equitable treatment of property owners, and to ensure all shoreline facilities are reviewed under a consistent framework and managed in accordance with Tri-Dam Project’s obligations under the FERC license.