Background
You may remember from the announcement last fall, or have read in the news, that PG&E has requested authorization from both the California Public Utilities Commission (CPUC) and the Federal Energy Regulatory Commission (FERC) to transfer all of their non-nuclear generation assets to a newly formed subsidiary called Pacific Generation.
Several of the hydropower assets that PG&E seeks to transfer are in the midst of license surrender and decommissioning processes, including the Potter Valley Project. This seems a blatant attempt to reduce the company’s liability on neglected aging infrastructure, and is not in the public’s best interest.
The Hydropower Reform Coalition has been hard at work advocating for several projects, including the PVP, to either be excluded from the transfer or have special conditions placed on them. We filed comments outlining why the PVP specifically should be excluded from PG&E’s proposed transfer, or PG&E should at least be required to remain on the license.
You too can file comments by August 12 urging FERC to require PG&E remain on the project as a co-licensee. This is aligned with FERC’s decision requiring PacifiCorp to remain as a co-licensee when approving transfer of the Klamath dams in 2020. See below for instructions and talking points, click here to download our sample letter.
INSTRUCTIONS:
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TALKING POINTS:
- Eel River Dams need to come out now to give threatened salmon and steelhead access to the upper basin habitat and a chance at recovery.
- The PG&E has not demonstrated that Pacific Generation has the financial or technical means to handle their liabilities for decommissioning, dam removal, and restoration.
- The Potter Valley Project no longer functions as a hydropower project, so it does not generate any income to offset operations and maintenance costs, let alone decommissioning costs.
- Allowing PG&E to transfer the Potter Valley Project license is not in the public’s best interest. At a minimum, PG&E should be required to remain a co-licensee on the project.
Dear Secretary Bose,
In order to protect and recover threatened runs of chinook salmon and steelhead in the upper Eel River, the two dams of the Potter Valley Project must be removed as soon as possible. This will restore access to hundreds of miles of high-quality habitat above Scott Dam, in addition to providing other ecological benefits.
Given PG&E’s acknowledgement that Scott Dam faces serious seismic risks from the Bartlett Spring fault, dam removal is also necessary to protect downstream communities.
The public’s best interest is served by providing PG&E a path to accelerated dam removal, thus furthering protection and restoration of Eel River native fish. Transferring the Potter Valley Project to Pacific Generation would do nothing to advance project decommissioning, and could instead slow the process.
In considering PG&E’s license transfer proposal, FERC must ensure that Pacific Generation has the financial and technical means to handle PG&E’s liabilities for decommissioning, dam removal, and restoration of the project area. If the Commission decides the transfer is still appropriate, it should require PG&E to remain a co-licensee pending full dam removal. This decision would mirror FERC’s 2020 decision requiring PacifiCorp to remain a co-licensee in approving transfer of the Klamath Dams.
Sincerely,
(your name)