By Scott Greacen | Originally published in Issue No. 111 of The Osprey.
As 2025 drew to a close, the big news on California’s Eel River was U.S. Secretary of Agriculture Brooke Rollins’ unhinged and weird letter to the Federal Energy Regulatory Commission (FERC) opposing Pacific Gas and Electric’s (PG&E) License Surrender Application for the Potter Valley Project. Rollins demanded the commission reject PG&E’s application, contrary to FERC precedent and federal law, because PG&E proposes to remove Scott and Cape Horn dams from the Eel River.
What FERC will ultimately do is more uncertain now, but the license surrender process was always going to take years. PG&E’s plan to begin dam removal in 2028 is aspirational given the studies and plans that must be completed before FERC will issue a surrender order. If the Trump administration truly does mean to thwart Eel River dam removal, it can do things to further slow FERC’s never rapid processes.
But I should back up a step or two.
The Potter Valley Project
The Potter Valley Project is a federally licensed hydroelectric project PG&E owns and operates on the upper mainstem of northwestern California’s Eel River, where two dams and the diversion works are, as well as in Potter Valley on the upper East Branch Russian River, where the powerhouse is located. Cape Horn Dam was built in 1908 at a bend in the Eel River where it is separated from the Russian River by only a single ridge to the south. Because the Eel is hundreds of feet higher, builders used gravity to divert water to a powerhouse in Potter Valley below. The Potter Valley Irrigation District was formed around the bonanza of “abandoned” water below the powerhouse.
Though convenient for a diversion, the location quickly proved a poor place for a reservoir on the Eel, which moves as much sediment by volume as any river in the lower 48 states. Cape Horn Dam’s Van Arsdale reservoir filled in rapidly. Dam builders went looking for a better place for a bigger reservoir. About twelve miles upstream, they found a narrow canyon downstream from a wide valley.
Today, we know these valley-and-canyon formations happen where rivers cross faults. We know the Bartlett Springs Fault that produced this particular formation is an extension of the San Andreas Fault Complex, and we know that scientists think it can produce tremors up to magnitude 7.2. But dam builders in 1920 didn’t understand plate tectonics, so that is where they built Scott Dam.
While Cape Horn Dam got a fish ladder, Scott Dam was so tall no ladder was built. The Eel’s runs of steelhead, Chinook and probably coho salmon that spawned and reared above the new dam were cut off. Of particular note, the southernmost run of summer-run steelhead on Earth vanished. While those fish have not been seen since, their genetic legacy persists in their descendants — rainbow trout trapped above Scott Dam.
Fisheries Collapse in the Eel
The dams have not been the only culprit in the degradation of the Eel watershed and the decline of its fisheries. Overfishing has been a persistent threat, starting with the installation of canneries in the lower Eel River at the turn of the 20th century. In 1914, a railroad was completed through the Eel River Canyon, across dozens of ancient landslides, increasing the burden of sediment in the watershed. The postwar logging boom in the redwood and Douglas-fir forests left a vast network of sketchy logging roads across one of the most erosive landscapes on Earth.
The Eel River watershed experienced successive record flood events in 1958 and 1964. In those floods and wet winters since, clearcut slopes and badly built roads have repeatedly failed, dumping whole mountainsides into the Eel River. Increased sediment buried salmon and steelhead redds, blunting their ability to find food, a particular burden on coho salmon and steelhead that spend a year in freshwater. After 1964, populations of Chinook, coho, and steelhead that had averaged a million fish a year in returns to the Eel River before colonization plummeted to thousands of adults. Commercial and especially recreational fishing on the Eel fell off dramatically.
21st Century Operations – the Reasonable and Prudent Alternative
For most of the 20th century, PG&E ran the Eel River dams for maximum power production and the convenience of Russian River irrigators. It was not uncommon for flows on the Eel’s upper mainstem to be sharply reduced, as nearly all the river’s flow was sent south to the Russian River.
When the Potter Valley Project came up for FERC relicensing in 1977, CalTrout and others challenged it. But it was only after Eel River salmonids were listed as Threatened under the ESA in the 1990s that the National Marine Fisheries Service (NMFS) was able influence operation of the project. NMFS found that the license FERC had approved risked jeopardizing Eel River salmon and steelhead. This “jeopardy” finding became the basis for a revised flow schedule, which FERC incorporated into PG&E’s license in 2004.
The new flow schedule roughly approximated natural flows on the Eel River, reducing fisheries impacts. It did not address other harms caused by the project, including the fish ladder, high temperatures below Scott Dam, nor predation by pikeminnow introduced to the Eel system via the Lake Pillsbury reservoir.
From PG&E’s perspective, however, the new flow schedule left the utility holding the bag on meeting water allocations with a shrinking reservoir and an increasingly unprofitable dam. A series of very dry and warm years sharpened conflicting demands of irrigation diversions to the Russian River and protecting fisheries in the Eel River.
From Relicensing to a Dam Removal Deal
In 2017 PG&E began preparing to relicense the Potter Valley Project, with license expiration looming in 2022. The utility ended up putting the project up for auction, before declaring bankruptcy in 2018 and withdrawing its notice of intent to relicense. Abandoning its relicensing attempt means PG&E cannot apply for another license for the project. An additional attempt to offer the project to qualified operators found none. (Sonoma Water, the dominant water system on the Russian River, has held an option to purchase the project since the 1960s, but declined to exercise it.) Thus, when the project license expired in 2022, license surrender and dam removal appeared the only logical option.
Brought together by Rep. Jared Huffman (D-CA2), disparate stakeholders in both river basins developed a deal — what Huffman called a “two basin solution” — that would best serve everyone’s interests. Under the framework ultimately agreed to by Sonoma Water, the Mendocino Inland Water and Power Commission, Humboldt County, the Round Valley Indian Tribes, Trout Unlimited, and CalTrout, the Russian River interests agreed to support removal of the Eel River dams as soon as practicable, while the Eel River and fisheries side agreed to support a continued diversion from the Eel to the Russian.
Under the plan, diversions will only happen during higher flows, with a run of the river structure and a pump station into the existing tunnel. The Round Valley Indian Tribes will hold the water right on which PG&E’s diversion had been based. Russian River water users will pay for the costs of their new diversion and for the water, with annual payments to both the Tribes and to an Eel River restoration fund. By agreeing to a deal that could be presented to FERC with broad support, we all hoped to move as quickly as possible through FERC’s notoriously slow processes.
That is the project that PG&E outlined in its August 2025 License Surrender Application — a “Rapid Dam Removal” plan that would knock most of both Cape Horn and Scott Dams down in the first year of implementation, see the new diversion works built while the river was diverted for dam removal, and then plan for the sediment of both reservoirs to flush downriver as soon as high enough flows come. The informed reader will note that this plan broadly mirrors the dam removal project on the Klamath River, recently completed with greater than anticipated success for fisheries recovery.
Hitting the Wall
The thing is, some of the people who fought Klamath dam removal are still mad as hell, and are still circulating whole rivers of do-your-own-research conspiracy theories. They have now joined the upper Eel’s own minor flood of dam removal disinformation. For years, naysayers have been focused by summer cabin owners around the Lake Pillsbury Reservoir, and increasingly by Lake County, whose official position is that dam removal is a plot by PG&E against Lake County.
A new strain came into the picture over the last couple of years with the re-election of Donald Trump. A MAGA influencer and her father, a longtime veterinarian in Potter Valley, whipped up opposition to dam removal among the conservative towns and agricultural interests of the Russian River. Their Save Potter Valley effort is in some tension with the expressed support of the Potter Valley Irrigation District for the two basin deal, reflecting a larger tension between water users on the Russian. Because the two basin solution deal entails both dam removal and an upgrade to the existing diversion, it’s often not clear what opponents actually want, beyond a way to turn back the hands of time.
The Rollins Letter
So that’s the punchbowl in which the Secretary of Agriculture’s submission landed. Why the Secretary of Agriculture? Because the upper portion of the Lake Pillsbury reservoir lies on lands of the Mendocino National Forest. So it is the Forest Service that has been meeting with PG&E and stakeholders for years, planning for dam removal and river restoration which is very much consistent with the agency’s mission and the Mendocino forest plan.
Ironically, Forest Service founder Gifford Pinchot engineered his agency’s placement in the Department of Agriculture to insulate it from political interference with public lands endemic to the Teapot Dome-era Department of the Interior. But when MAGA complaints reached Mar-a-Lago, Secretary Rollins tossed all that woke nonsense. Rollins pulled Mendocino and other Forest Service staff from the Potter Valley Project process, replacing them with leaders of the Natural Resources Conservation Service with roots in California agribusiness. Rollins also reversed the Trump administration’s position on Klamath dam removals, which was to not interfere with private business decisions. The new posture is, alas, consistent with administration attempts to force coal plants to continue to operate.
Here, though, there are some other practical problems. First, the transformer in Potter Valley blew in 2021, and PG&E decided not to commission a new one, which is a multimillion dollar process that now takes years. So the dam makes no power at all. More importantly for water users, Scott Dam’s systems are increasingly failing. Continuing sedimentation threatens to irreparably block the only remaining low level outlet. That would end irrigation deliveries, as well as releases to maintain flows in the Eel River.
Finally, an investigation of Scott Dam’s seismic stability resulted in PG&E being ordered by state and federal dam safety regulators to permanently leave the radial gates atop the dam open. The reduced capacity resulting from both the open gates and the need to keep water in the reservoir to prevent sediment mobilization means that, in even the wettest years, PG&E has only a dry year’s supply to meet its flow schedule.
This leaves threatened juvenile steelhead in the upper Eel at the mercy of FERC each year. PG&E must seek permission to alter flows in an attempt to balance complying with required flows and maintaining a cold water pool for releases into the Eel. In 2025, FERC failed again to approve PG&E’s variance request in time, delaying approval until early August. The result was more than two months of deadly temperatures in the upper Eel below Scott Dam.
According to temperature data maintained by the California Department of Water Resources, 24-hour average temperatures in the Eel River below Lake Pillsbury were at or above 20°C for 80 straight days from July 10 to September 30, 2025, and were at or above 22°C for 30 days from August 11 to September 11. Water temperatures below 16°C are best to protect rearing of juvenile steelhead, and temperatures above 20°C may be directly lethal even to adult steelhead. Temperatures above 18°C also favor non-native pikeminnow and allow them to outcompete juvenile steelhead.
There is nothing the federal government can do to make the dams seismically safe, or to solve the physics of sedimentation and the inadequacy of Scott Dam’s failing structures. PG&E wants to remove the dams for really good reasons, and the key interests in the Eel and the Russian basins agree. Nonetheless, Eel River dam removal is far from a done deal. As long as federal power remains in the hands of vindictive ideologues, those of us who want our grandchildren to see wild Eel River salmon and steelhead are going to have our hands full.
Scott Greacen is Conservation Director for Friends of the Eel River.