The recent commenting period on PG&E’s draft license surrender application is the latest step in the long process of evaluating the best options for decommissioning the Potter Valley Project. For over a century now, the Potter Valley Project has contributed to the decline of the Eel River and its fisheries. The Project has failed in every possible manner: power production, economic utility, and even as a means to divert substantial water for irrigators in the Russian River. Because of sediment accumulation and seismic instability, the reservoir cannot be completely filled or emptied. And of course, operation of the project blocks access to hundreds of miles of salmonid habitat and violates the Endangered Species Act by causing harm to listed species. For all these reasons and more, PG&E is highly motivated to rid themselves of this costly liability. The utility is working quickly to prepare plans to decommission and remove the project, as outlined in their draft License Surrender Application.
Cape Horn Dam, pictured above, is one of the two dams the draft license surrender application plans to decommission.
We appreciate PG&E’s draft plan and generally support their proposed actions, including:
- Decommissioning and removal of Scott Dam;
- Decommissioning and removal of Cape Horn Dam;
- Removal of the New Eel-Russian Facility from the FERC license; and
- Restoration of Project facility and sites.
PG&E proposes a “rapid removal” plan for removal of Scott Dam. Estimated to take place over two years, this proposed removal method will result in serious turbidity impacts downstream. While these impacts are likely to result in depleted dissolved oxygen levels, high nutrient levels, and other adverse impacts, the proposed rapid removal will limit the temporal scope of these impacts. We encourage PG&E to continue consulting with Tribes and resource agencies to develop plans to minimize the impacts of the sediment release.
We also support PG&E’s proposal for Non-Project Use of Project Lands, which will remove the New Eel-Russian Facility (NERF) from the FERC license. This will help ensure that any delays with that process will not cause delays to dam removal. The NERF recently made headlines with the Memorandum of Understanding between various stakeholders that would allow for continued diversions from the Eel to the Russian River.
Given that the Potter Valley Project is no longer part of the electric generation system, and the serious risks posed by this “high hazard facility,” we suggest in our comments that the time has come for transparency when it comes to dam safety. PG&E’s lack of transparency on seismic risks has contributed to some communities continuing to advocate for keeping the unsafe infrastructure in place.
Additionally, in our comments, we note areas of concern, needs for clarification, and various suggestions offered in the hope of improving the final license surrender application. These comments are consolidated from a variety of subject matter experts.