CSPA and Foothills Water Network Comment on Draft License Application for Yuba-Bear and Drum-Spaulding Hydroelectric Projects

February 1, 2011. The Foothills Water Network, a coalition of NGO’s in which CSPA plays a leading role, filed 80 pages of comments on the Draft License Applications for the Yuba-Bear and Drum-Spaulding hydroelectric projects. The projects, licensed to  Nevada Irrigation District and PG&E respectively, coordinate their operations, and their licensees are engaged in a single coordinated relicensing.

The Network recommends that NID and PG&E:

  • Compare mitigation alternatives to existing operations and water deliveries
  • Develop flow measures with heavy emphasis on water temperature
  • Restore the snowmelt hydrograph in the South Yuba River and other streams
  • Include salmon and steelhead as target species in the South Yuba and Middle Yuba rivers
  • Provide a year-round minimum flow in Auburn Ravine to protect salmon, steelhead and trout

The Network recommends that the Federal Energy Regulatory Commission (FERC):

  • Analyze alternatives for reintroduction of salmon and steelhead to the upper Yuba watershed
  • Analyze water supply alternatives that both increase and decrease existing deliveries
  • Consider a joint operations alternative to achieve environmental benefits
  • Carefully and expansively analyze cumulative effects of current and future operations

In a related action, FERC issued letters on January 31 to PG&E and NID, citing numerous deficiencies in the respective Draft License Applications. Most notably, FERC found unacceptable NID and PG&E’s efforts to pad baseline analysis and modeling of water deliveries with future projected demand. FERC also demanded a more substantive cumulative effects analysis of both licensees.

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