As many of you are likely now familiar, PG&E is unable to meet the flow schedule for the Potter Valley Project as outlined in their amended license from 2004. This flow schedule is unobtainable in most years due to a variety of factors including strategies employed to reduce dam safety risk, and changes in climate conditions. So, nearly every year, PG&E must ask the Federal Energy Regulatory Commission (FERC) for permission to deviate from these scheduled flows with a “variance request”. To their credit, in recent years PG&E’s variance requests have also focused on maintaining cool water temperatures below Scott Dam adequate to protect native fish trapped below the dam.
In 2022 PG&E’s variance request was approved in a timely manner by FERC and the utility was able to maintain temperatures at or below 19 degrees C, an important threshold for juvenile salmonids. However, in 2023 FERC delayed approving the variance for five months, resulting in dangerous conditions for salmonids where temperatures exceeded 21 degrees C for nearly a month. The below graph is a great illustration of the effectiveness of PG&E’s variance when implemented early in the season.
This year, in an effort to avoid the catastrophe that occurred last year, PG&E submitted a variance request to FERC in February. Unfortunately FERC has still not approved this request, despite the clear evidence of this management plan’s effectiveness in improving the degraded habitat below Scott Dam.
The 2024 variance request is similar to the past two years, except that it proposes that PG&E, in consultation with wildlife agencies, begin reducing diversions when temperatures below Scott Dam reach 15 degrees C. That temperature threshold was passed just two days ago on June 10. There is still time for FERC to do the right thing and approve PG&E’s request. Thus, members of our Free the Eel coalition submitted a letter on June 2 urging FERC to take immediate action to approve the variance and give the Eel’s native fish the best chance they have while the dams remain in place.