Comments to FERC re: Temporary Variance Request

Sunday, February 2, 2014

Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
Re: Potter Valley Project (FERC No. 77)
Temporary Urgent Request for Flow Variance Due to Limited Water Availability

Dear Secretary Bose:

Under the present extreme and extraordinary circumstances, Friends of the Eel River concurs that FERC should immediately grant the extension requested by PG&E on Jan 14 of this year to the variance that has been in effect for the Potter Valley Project since mid_ December of 2013. The effect of this approval would be to allow PG&E to continue to release flows of no less than 25 cfs to the upper mainstem Eel River below Cape Horn Dam.

If the extension is not granted, the project’s flow schedule would dictate that PGE increase flows to 100 cfs. While under better circumstances such flows would be highly desirable for listed salmon and steelhead in the Eel River, extremely low water levels in the Lake Pillsbury reservoir and the continuing severe drought make it very unlikely such flows could be sustained through even the spring of this year. Raising water levels and then dropping them sharply may risk greater additional harm to fish populations likely already to be severely affected by this year’s conditions than would maintaining some  flows through the spring.

As well, releases of such volume would risk further collapse of sediments accumulated in the bed of Lake Pillsbury. If released below Scott Dam, such sediments could cause serious harm to eggs in any redds that have been established in this very difficult fish breeding season. We also understand that PG&E is concerned by the potential for damage to the needle valve that controls releases from Scott Dam; such damage could impair further releases.

We do appreciate that under the current variance, PGE has been releasing to the Eel River flows well above the 25 cfs floor. We sincerely implore PG&E to maintain such higher flows to the extent possible, and would support a higher floor of 35 cfs; such flows in the Eel River could be maintained by curtailing current diversions to the Russian River.

Please note that FOER’s support for continued extension of the flow variance and limited releases to the Eel River is necessarily limited to the present circumstances, and is not intended as a withdrawal of any of the points made in our comment letter of Weds, Jan 15, 2014. Nor have we seen any reason to change our position that any continued diversions to the Russian River, now running at a steady 10 cfs actual, over a 5 cfs floor, are unjustified given the relative importance of flows for salmonids in the mainstem Eel River.

Please note as well that FOER respectfully requests that FERC schedule a hearing no later the end of February 2014 to clarify several serious questions raised in this matter. We would note at least that (1) the conditions under which this temporary variance would be lifted should be described with clarity; (2) how the PVP will allot any additional flows the upper Eel River basin and the Lake Pillsbury reservoir may receive during the spring of 2014 remains a matter of real concern that requires careful analysis; and (3) as noted above and in our letter of Jan 15, FOER has yet to be provided with any substantial  evidence or analysis showing that the economic, environmental and equitable benefits of continued diversions to the Russian River outweigh the imperative to maintain conditions in the Eel River as beneficial as possible to this year’s critically imperiled cohorts of salmon and steelhead.

Thank you very much for your timely consideration.


Sincerely yours,

Scotss sig WEB

Scott Greacen
Executive Director
Friends of the Eel River


Read our motion to intervene here.