CSPA and seven other Conservation Groups filed comments on May 29, 2015 on the Draft Environmental Impact Statement for the relicensing of the Merced River Hydroelectric Project and the Merced Falls Hydroelectric Project. These relicensings began in 2009. The Federal Energy Regulatory Commission (FERC) issued the DEIS in March. Along with the State Water Board’s ongoing update of the Bay-Delta Water Quality Control Plan, these FERC relicensings will determine in part flows in the lower Merced River for the next 30-50 years.
The central theme of Conservation Groups’ comments is that the DEIS inequitably balances uses of the Merced River:
The Commission has an obligation to balance the beneficial uses of a waterway consistent with the public interest. Unfortunately, staff has adopted an overly restricted view of its authority to balance certain uses, leaving it with a self-inflicted inability to fix the institutional problem in the Merced River. That problem is unsustainable water demand, which systemically threatens the health of fish and wildlife resources that inhabit and utilize the Merced River, and which ultimately threatens the sustainability of the agricultural economy in eastern Merced County.
The comments conclude that, “… it appears that FERC is on course to leave the hard problems of this relicensing to others.”