CSPA, along with several other Conservation Groups[1], submitted extensive comments in early August to the Federal Energy Regulatory Commission (FERC) in the just-initiated relicensing of two PG&E dams on the mainstem Eel River. Cape Horn Dam (built 1908) and Scott Dam (1922) are part of PG&E’s Potter Valley Project. The Project’s main feature is the diversion of water through a tunnel from the Eel River to the Russian River watershed. The Project’s license expires in 2022. At present, PG&E proposes to relicense the Project with no change in operations.
The Conservation Groups commented on FERC’s Scoping Document 1 (SD1) that describes the scope of the topics FERC will analyze in an Environmental Impact Statement later in the process. The groups also commented on PG&E’s Pre-Application Document, or PAD, in which PG&E presents factual information about the Project that PG&E believes to be relevant. In addition to describing shortcomings in those two documents, the Conservation Groups submitted seven requests for studies to evaluate various issues related to the Project.
The Eel River is California’s third largest watershed and flows more than 200 miles from the headwaters above Lake Pillsbury in Lake County to the ocean. Scott Dam has no fish passage facilities and thus prevents migrating salmon and steelhead from reaching the upper watershed of the mainstem Eel River. One of the major themes in the comments is that FERC must evaluate dam removal and also decommissioning of the Project.
The Conservation Groups also argue that dam safety issues are relevant to FERC’s consideration of a new Project license. However, FERC has historically not considered dam safety in relicensing proceedings. Design and problems from initial construction are known to exist at Scott Dam. PG&E would have limited ability to release water if the dam’s low-level outlet failed. At the top of the dam, PG&E must operate all but one gate by hand to regulate high flow events. Following events in Oroville in February, 2017, FERC will need to re-evaluate whether to address these and other dam safety issues in the relicensing process.
The principal driver of the Potter Valley Project is not the small and irregular amount of electrical power it produces. Rather, it is the water diverted to the Russian River through the Project powerhouse for irrigation in Potter Valley and along the Russian River downstream of Lake Mendocino. Tens of thousands of acre-feet of water are unaccounted for every year in the Russian River watershed. Conservation groups question how much Eel River water is used to supply unauthorized water diversions along the Russian River.
FERC is scheduled to issue a Scoping Document 2 by September 18, 2017. PG&E is required to file a Proposed Study Plan on the same date. A Study Plan meeting is required in October, 2017. Therefore, stay tuned for further information about this important relicensing proceeding which provides an opportunity to improve fish populations on the Eel River.
Conservation Groups comments SD1 PAD Exhibits Study requests
[1] Other groups included American Whitewater, California Trout, Friends of the Eel River, Friends of the River, Native Fish Society, and Trout Unlimited and the Redwood Empire Chapter of Trout Unlimited