Comments to FERC re: Temporary Variance and “Make up Flows”

PG&E requested a temporary variance to reduce flows into the East Branch Russian River as they performed work on the Potter Valley Project. Sonoma County Water Agency requested, among other things, compensatory flows to “make up” for lost flows during this variance. Friends of the Eel River submitted comments that we agree with the need for a temporary variance to conduct work on the project, but disagree that SCWA is entitled to “make up flows” & that those flows would have a benign effect on listed species in the Eel River. Read a snipped from our Motion to Intervene below, a link to the full text of our motion follows.

PG&E has requested a significant reduction in flows through the Potter Valley Project (FERC #77) (“PVP”) for the purpose of “planning to conduct repairs to project works, including: replacing the penstock shutoff valves, replacing the standpipe connection, and installing penstock protection . … The licensee states that during the repair period [between November 1, 2014 and March 15, 2015], it would release a minimum flow of 20 cfs from the conduit into the East Branch Russian River, which would include the release of up to 5 cfs for the Potter Valley Irrigation District.” (Notice, pg. 2)

This would likely result in a substantial reduction in flows to the East Branch Russian River, and downstream winter storage in Lake Mendocino. See, “PG&E plan may reduce water flowing into Lake Mendocino,” Press Democrat, Oct. 17, 2014 [“PD”]    , and, Motion to Intervene by the County of Sonoma and the Sonoma County Water Agency, and Protest and Comments by the County of Sonoma and the Sonoma County Water Agency to PG&E’ s Application for Temporary Variance of Minimum Flow Requirement, FERC Project No. 77-269, both dated October 23, 2014.

The Sonoma County Water Agency has responded to the proposed variance by requesting FERC require as a condition of the variance, among other things, that PG&E meet with Sonoma “within 15 days .. . to discuss possible alternatives to mitigate the impacts of the reduction in flows to Lake Mendocino .. .” and jointly propose to the NMFS and Cal DFW “make up” flows “which could be accomplished without adversely impacting salmonid species in the Eel River watershed.”

Evidence in the record demonstrates that any reductions in flows released to the mainstem Eel River may result in disruption of migration, spawning, and successful reproduction of salmon and steelhead listed under the federal Endangered Species Act (“ESA”), 16 U.S.C. §§ 1531 et seq., while additional releases to the Russian River reduce the water available to Eel River fisheries. Therefore, any proposals to add flows (such as the proposed “make up” flows) to the Russian River must be carefully considered in a thorough public process.

Read our full Motion to Intervene here.