The Potter Valley Project, which blocks access to pristine, cold water spawning habitat for Eel River salmonids, is no longer a functioning hydroelectric project. PG&E has announced plans to remove both Scott and Cape Horn dams as soon as possible. Until Scott Dam is removed, management of the Potter Valley Project must focus primarily on maintaining a cold pool in the Lake Pillsbury reservoir through the summer months. This cold water is crucial to prevent juvenile steelhead from being outcompeted by Sacramento pikeminnow, an invasive species that thrives in warmer waters.
Frequently over the years, PG&E has submitted flow variance requests to the Federal Energy Regulatory Commission (FERC), and this year is no different. Historically, PG&E has been unable to achieve its scheduled project flows that divert water from the Eel River to the Russian due to several reasons: climate change, built-up sediments reducing reservoir capacity, and seismic risks at Scott Dam further reducing that capacity.
The proposed variance for 2024, which would significantly reduce the amount of water diverted from the Eel River, is vital to protecting critically imperiled Eel River fisheries pending removal of the dams. Reducing the flows maintains deeper, colder waters. We strongly encourage FERC to expedite the approval of the variance, as delays in the approval process in 2023 led to high water temperatures detrimental to the survival of salmonid species listed under the Endangered Species Act.
Given that none of the conditions that make this variance necessary are likely to change, FERC needs to work promptly toward a longer-term resolution that will effectively protect Eel River fisheries throughout the decommissioning process. The inconsistent wait times between when variances are submitted and when they are approved is too risky for endangered Chinook salmon and steelhead trout. If FERC does not approve this year’s variance in time for PG&E to reduce the Potter Valley Project flows, that delay could become lethal.
PG&E and FERC have joint and several responsibilities to ensure the Potter Valley Project’s operations do not harm listed species. PG&E’s part here is to propose a timely and effective variance and prepare to implement it. FERC’s is to approve it without delay.
As for our part, you can view our comments advocating for the protection of the Eel River’s native fish here.