By Chris Shutes, FERC Projects Director
In a comment letter filed in the dockets of the coordinated relicensing of the Yuba-Bear and Drum-Spaulding hydroelectric projects, the Foothills Water Network has taken the Federal Energy Regulatory Commission to task for failure to consider and order study of water supply in the hydropower relicensing process.
The Network’s comment letter was written in response to an earlier letter filed by the Placer County Water Agency. PCWA complained that a scenario proposed by the Network for analysis in a water balance model might, if implemented, reduce the amount of water available to PCWA customers. PCWA also expressed frustration with the inability of the model to separate impacts to its own water supply from that of Nevada Irrigation District, operator of the Yuba-Bear Project. PCWA purchases water from PG&E’s Drum-Spaulding Project under two contracts.
While Foothills Water Network was troubled by the manner in which PCWA raised the issues, the Network found merit in PCWA’s concerns. FERC routinely denies study of water supply deliveries in hydropower relicensing, and had previously denied study proposals, made by the Network and by others, relating to impacts of water supply. This was all the more troubling because during parts of the year, water supply is the key driver of how the combined projects are operated.
In the absence of study ordered by FERC, a member of the Foothills Water Network Coalition undertook a hydrologic analysis. This analysis showed that substantial amounts of water currently exported out of the Middle Yuba and South Yuba watersheds could be returned with little impact to water supply.
The Foothills Water Network represents a broad group of non-governmental organizations and water resource stakeholders in the Yuba, Bear, and American Watersheds. CSPA has been an active participant in the Network for several years.