Friends of the Eel River’s comments to FERC on the Initial Study Report filed by the coalition of five entities known
variously as the Two Basin Partners, the Notice of Intent (NOI) group, or the Planning Agreement Group (PAG).
Dear Secretary Bose and FERC staff:
On behalf of our members, staff, and board, Friends of the Eel River (FOER) submits the
following comments on the Initial Study Report filed by the coalition of five entities known
variously as the Two Basin Partners, the Notice of Intent (NOI) group, or the Planning
Agreement Group (PAG) as part of their effort to complete the Federal Energy Regulatory
Commission’s (FERC) relicensing process for the Potter Valley Project (PVP) P-77, as well
as our disagreements with, and requests for amendments of the Study Plans proposed by
the PAG group.
FOER was founded in 1994 to secure the protection and recovery of the Wild and Scenic Eel
River, particularly the fisheries which are the keystone of the watershed’s ecosystems.
FOER and its supporters use and enjoy the Eel River in the areas surrounding the Project
and in Project-affected areas for recreational, aesthetic, and educational purposes,
including but not limited to fishing, viewing, and enjoyment of the outdoors. Operations of
the PVP under a new license could adversely affect those interests. FOER has actively
participated in the existing license proceedings, and also attended the Scoping Meetings for
Seeking to restore the Eel River’s ecological function and health, FOER has opposed the
interbasin transfer of Eel River water to the Russian River, and sought removal of both
Scott and Cape Horn Dams, the PVP’s dams on the upper mainstem Eel River. The declining
health of Eel River salmon and steelhead runs over the last several decades has only
increased the urgency of the need to restore access to the habitat above Scott Dam. We
supplied this information to FERC in our first comments on PG&E’s relicensing. We see no
evidence FERC has taken notice of the urgency demanded by the potential extinction of Eel
The fish ladder at Cape Horn Dam (generally known as the Van Arsdale Fish Station) is the
longest and highest ladder in the state of California. It has been modified many times over
its century of existence. As we write, contractors for PG&E continue to work to install new
metal doors on the Fish Hotel structure. Chinook will be attempting to move up the Van
Arsdale ladder as soon as rains permit. With significant atmospheric river storms projected
for the North Coast as soon as the date of this letter – Friday, November 13 – it is very likely
that construction activities will result in another obstruction to salmonid passage at the
Van Arsdale site. If PG&E has consulted with NMFS regarding the impacts of their of their
door installation on the chinook run, we are not aware of it.
FOER requests that each of the proposed study plans which includes analysis of Scott Dam
removal be amended to include a parallel analysis of Cape Horn Dam removal. Most
essentially, this would include SE 1, socioeconomics, and AQ 7, fish passage. Cape Horn
Dam removal analysis in both studies would closely parallel the analysis of Scott Dam
removal already described in detail in both study plans. The issues, methods, and relevant
questions for Cape Horn Dam closely track those already described for Scott Dam.
As detailed below, SE 1 should also be amended to require analysis of the potential public
health impacts of the extremely high mercury levels found in fish in the Lake Pillsbury
reservoir, as well as to clarify that its analysis of economic impacts will be based on the
fantasy that PG&E can somehow be compelled to keep Scott Dam standing and operating
even though it cannot relicense the dam.
Additionally, a separate study plan parallel to AQ 12, Scott Dam removal, should be
required to analyze all aspects of Cape Horn Dam removal. Again, the issues, methods, and
relevant questions for Cape Horn Dam removal are essentially identical to those already
described for Scott Dam in AQ 12.