Action Alert: Submit Comments on Scoping Document 3

Hi Friends,

Here’s another chance to make your voice heard and help us elevate critical issues related to Eel River dam removal. The Federal Energy Regulatory Commission (FERC) just issued Scoping Document 3, a first step toward preparation of an Environmental Impact Statement which will evaluate a potential license based on the Feasibility Study Report that the Two Basin Partnership submitted in May. Whew, that’s a mouthful. The simple version is that we have yet another opportunity to remind FERC how important it is to remove Scott Dam from the Eel River as soon as possible.

If you have submitted comments to FERC before, the process is the same. You need to register with FERC online and follow their instructions for submitting your comments.

There are three main issues that we feel are not adequately addressed in Scoping Document 3. Those are: Dam Safety, Adequate Project Alternatives Including Removal of Cape Horn Dam, and Eel River Restoration Plan.

Dam Safety

FERC’s approach to dam safety throughout the process thus far has been inadequate at best, allowing significant liabilities to be concealed from the public. Our concerns include, but are not limited to, concerns about the materials, techniques, and design used to construct the dam; the location of the dam immediately proximal to a major fault system; the presence of an active landslide above the dam’s southern abutment; and the potential for storms well in excess of those which the dam was designed to accommodate. You can learn more about FOER’s research on Dam Safety here.

Project Alternatives and Cape Horn Dam Removal

True volitional fish passage past the current project location cannot be realized without substantial modifications to the existing fish passage structure at Cape Horn Dam. Despite a series of reconstruction efforts over the last century, volitional fish passage still has not been achieved. If true volitional fish passage is not feasible, Cape Horn Dam must be removed.

Cape Horn Dam removal must be fully analyzed as a project alternative, not only to prepare for the potential full decommissioning of the project, but also to ensure that accurate information is available to all stakeholders as we seek an equitable resolution to the problems presented by PVP relicensing.

Eel River Restoration

The Eel River has been substantially impaired by the construction and operation of the PVP over the last century. Equity demands that PG&E, as the beneficiary of the harms suffered by the Eel, should provide for the restoration not only of the locations where PVP facilities now exist, but of the larger watershed. An analysis and prioritization of watershed restoration actions should be conducted as part of any relicensing process and NEPA analysis.

Please take a few moments to write your own comments based on the above information, or use our sample comments below.

INSTRUCTIONS

Click here to register with FERC online, follow the on screen instructions to submit comments to docket #P-77-285. If you wish you use our sample comments, copy and paste below or click here to download.

SAMPLE COMMENTS

Dear FERC Staff and Commissioners,

I am writing to comment on Scoping Document 3 for the Potter Valley Project (PVP), issued by FERC on July 28 2020.

I care about the Eel River, its fisheries, and pursuing an equitable solution to the long-standing problems this project has inflicted on the habitat.

It is important that FERC fully analyze this proposed project, including the serious liability issues associated with dam safety, as well as alternatives which were not part of the NOI parties’ Feasibility Study.

Just two of many dam safety concerns that need to be analyzed are the major fault system adjacent to Scott Dam and the presence of an active landslide above Scott Dam’s southern abutment. Scott Dam is rated as a high hazard facility, and thus likely presents a fatal liability in the result of dam failure.

Cape Horn Dam removal should be analyzed as a project alternative. Substantial modifications are necessary to achieve volitional fish passage, and in the event that modifications cannot achieve this requirement, dam removal may be necessary. Thus, full removal should be analyzed so that accurate information is available to all stakeholders and future license holders.

Finally, given the substantial impairment the project has wrought on the Eel River watershed, PG&E should provide for broad watershed restoration. Generations of people negatively impacted by this project deserve equity.

Sincerely,

[your name]