Humboldt County Residents Input Not Actively Sought as Potter Valley Project Dam Study Opens for Comments
In April of this year, PG&E began the process of relicensing the Potter Valley Project. The Potter Valley Project (PVP) diverts water from the mainstem of the Eel River into the Russian River watershed. It produces up to 9mw of electricity at the hydro-power station in Potter Valley, California then it fills Lake Mendocino along the highway 20 near Ukiah. The water that is diverted would have flowed through Humboldt County if the Potter Valley Project didn’t exist. However, the agency in charge did not reach out actively to Humboldt County residents about the relicensing process. All meetings and even public notices were set in counties south of here.
To operate the diversion, PG&E maintains two dams in the upper reach of the Eel River, about a dozen miles directly east of Willits in Mendocino and Lake Counties. The upstream dam is the Scott Dam and it impounds Lake Pillsbury in Lake County. Lake Pillsbury holds water across the dry season releasing it for use throughout the year by both the diversion and the Eel River. Twelve river miles downstream is the Cape Horn Dam which impounds Van Arsdale reservoir in Mendocino County. Van Arsdale holds a small pool of water sufficient for supplying the diversion via a set of tunnels through two consecutive mountain ridges. After which, the Eel River water falls 450 feet in two 48 inch diameter “penstocks” to the hydro-power station in the back corner of Potter Valley and becomes the headwaters of the East Branch of the Russian River.
Every fifty years the utility must renew their license with the Federal Energy Regulatory Commission (FERC). The original license was issued in 1922 and expired in 1972. So, PG&E is beginning their renewal application process for the current license which expires in April of 2022
What Potter Valley Project Provides
The nine 9MW of power produced is barely mentioned in the process of renewing the license. In fact, most of the time, the power house is operating at less than half that output since 2007, according to PG&E’s Pre-Application Document to FERC.
The main issue on the Eel River side is the pristine, cold water spawning grounds above Lake Pillsbury that have been cut off from salmonid species for nearly 100years.
And on the Russian River side, the primary issue is the 70,000 acre feet of water transferred annually that fuels the agricultural economy for Potter Valley and Russian River farmers and provides the environmental offsets for the SCWA which withdraws water from the Russian River for municipal water supply for half a million people in Sonoma and Marin Counties. The unmentioned regulatory issue is that PG&E ratepayers are subsidizing the environmental analysis and mitigation of this water transfer. The utility is not paid for the majority of the water its transfer provides.
Humboldt County Input Not Actively Sought
The power project is in Mendocino County, the major reservoir is in Lake County and the Eel River runs extensively through Humboldt County. No scoping sessions or outreach to the public at large is being conducted in the Eel River watershed. When Congressman Jared Huffman wrote to FERC to inquire about having public meetings in Eel River communities, FERC responded in a letter dated August 29, 2017 that it wouldn’t be necessary because Eel River constituents have provided input either in writing or through the meetings in Ukiah, CA.
The letter signed by FERC Chairman Neil Chatterjee says, “We understand that there are stakeholders with concerns that reside several hours from the immediate project location. The scoping meetings were publicly noticed concurrently with SD1 on June 1, 2017, and published in the Lake County Record Bee, the Lake County News and the Mendocino Beacon. The notice and SD1 were also sent to over 100 entities on the Commission’s mailing list for the project and about 300 entities on PG&Es distribution list for the project. As a result of these efforts to afford public notice of the relicensing process and encourage participation, we have received hundreds of comments from individuals in both the Eel (including the lower Eel) and Russian River Basins, and beyond.”
Integrated Licensing Process
FERC’s renewal process is called an Integrated Licensing Process (ILP), meaning it now integrates the environmental analysis needed for NEPA (National Environmental Policy Act) into the licensing process.
The ILP process is as fast-paced as it is bureaucratic and challenging to understand.
PG&E filed a Notice of Intent (NOI) and a Pre-Application Document (PAD) in April of this year. The public had until August 14th to comment on the NOI and the PAD. In the meantime, FERC issued their first Scoping Document on June 5th. The Scoping Document (SD1) describes the environmental analysis that will be done for NEPA.
On June 27th FERC held the only two publicly noticed Scoping meetings, and those meetings were only noticed in the Congressional Federal Register. Both meetings were held on the same day in the same place, Ukiah’s Board of Supervisors’ Chambers. There was a morning session and an evening session.
From the comments on FERC’s Scoping Document One (SD1) and PG&E’s Pre-Application and Notice of Intent, PG&E developed a Proposed Study Plan which it sent out on the 18th of September.
The very next day, FERC released its revision of the scope of the environmental analysis in Scoping Document Two (SD2). SD2 was not open to public comment according to Vivian Helliwell of the Pacific Coast Federation of Fishermen’s Associations (PCFFA).
After submitting their proposed study plan on the 18th of September, PG&E began Technical Working Groups with regulatory agencies including NOAA’s National Marine Fisheries Service and California’s Department of Fish and Wildlife; local tribes including the Round Valley Indian Tribes and the Wiyot Tribe; environmental non-profit groups like Friends of the Eel and the Native Fish Society; economic sector advocates such as PCFFA and Mendocino County Farm Bureau, and other affected parties such as the Sonoma County Water Agency (SCWA) and the Potter Valley Irrigation District (PVID).
Technical Study Sessions were held by PG&E this fall, in Ukiah, from October 18th through November 30th. The Technical Study Sessions covered 11 areas: hydrology, water temperature, water quality, geomorphology, instream flow, Lake Pillsbury fish habitat, fish passage, entrainment, fish populations, special-status amphibians, and special-status mollusks. Both the Eel and the Russian Rivers will be studied from their headwaters to their mouths. Fish passage on the Van Arsdale dam will be studied for its efficacy and Scott Dam will be studied for the possibility of introducing fish passage in some fashion. And the potential impacts to both rivers if one or both dams were decommissioned has been introduced for study as well.
You can comment on the Potter Valley Project
PG&E began distributing the revised Proposed Study Plan for public comment last week. The public has until next week on the 17th of December to submit their comments to FERC via an filing. And that deadline closes at 2 p.m. Pacific Time because FERC is located in Washington DC. The web address for filing is www.ferc.gov/docs-filing/ecomment.asp for comments that are shorter than 6,000 characters. You must identify your comments as regarding the Potter Valley Project (P-77-285) For longer remarks call FERC at 1-866-208-3676 for instructions on how to register for e-filing. PG&E maintains information on the re-licensing process at www.pge.com/pottervalley