Recent news about a Southern California water agency interested in taking over the Potter Valley Project has many of us distracted, but not the Federal Energy Regulatory Commission (FERC).
FERC is responsible for overseeing hydropower projects, and approving their decommissioning. As such, FERC has just announced the next step toward dam removal with the commencement of their National Environmental Protection Act (NEPA) process to analyze the impacts of Eel River dam removal.
Two meetings are scheduled for June 23rd at 6:30pm and June 24th at 10am at the Ukiah Valley Conference Center (200 S School Street, Ukiah) to receive comments on FERC’s Scoping Document.
What Is the Scoping Document?
The Scoping Document outlines what FERC will evaluate in their NEPA process, and clearly affirms that the only path forward for this project is dam removal.
FERC has rejected the possibility of retaining Scott Dam, citing seismic stability concerns and economic losses of the project. The option of a Federal Government takeover has also been rejected, as FERC says that no federal agency has expressed interest in operating the project. Finally, FERC has also removed analysis of dam removal without building the New Eel-Russian Facility (NERF), the proposed diversion infrastructure that will facilitate wet-season diversions following dam removal.
This last alternative removal has us concerned. If something goes wrong and the Eel-Russian Project Authority is unable to begin construction of the NERF facilities when PG&E is ready to begin removing the dams, FERC may need to issue a supplemental Environmental Impact Statement, which could delay dam removal. The endangered and threatened species of the Eel River cannot afford to wait.
Why Showing Up Matters
While several entities have already requested that FERC schedule additional meetings in Humboldt County, we don’t yet know whether FERC will fulfill those requests. So it is important that everyone who cares about supporting dam removal attend one of the in-person meetings in Ukiah.
Giving comments in person is important for two reasons. First, it’s an opportunity to speak directly to FERC staff about how dam removal is in the broad public interest. Second, it’s an opportunity to send a message to the larger public that dam removal is supported by a majority of North Coast residents. We know that dam removal opponents will show up in force to give the impression that dam removal is not broadly supported. It’s up to all of us to prove them wrong.
Talking Points
The most important message you can send to FERC is that you support their timely initiation of the NEPA process, and that you agree with their Scoping Document that keeping the dams is not an option.
While we support continued diversions following dam removal during the wet season, allowing the NERF to delay dam removal in any way is unacceptable. So we also recommend telling FERC that they should include a “no NERF alternative” in their NEPA analysis.
FERC also needs to understand that dam removal will benefit cultural revitalization and the economies of downstream communities. A single wild salmon is worth more than a barrel of oil, and has immeasurable value to Indigenous people. Returning wild salmon runs to abundance will have a ripple effect throughout North Coast communities.
Finally, any comments made on PG&E’s License Surrender Application at the end of 2025 will be included in FERC’s Scoping process. So you do not need to reiterate any detailed or technical comments made during that comment period. However, any additional information you have about the benefits or impacts of dam removal should be included in your comments. For example, emphasizing the need to study and avoid impacts on aquatic life during the release of sediment, evaluating options for preventing further spread of invasive pikeminnow, or incorporating particular native plants into revegetation plans following dam removal.
How to Comment Electronically or by Mail
If you cannot attend the meetings in Ukiah, you can still submit comments by July 24th.
Comments must be clearly labeled “Potter Valley Project (P-77-332)” and can be submitted electronically at ferconline.ferc.gov/FERCOnline.aspx by selecting “eComment”, or sent by mail to:
Debbie-Anne A. Reese, Secretary,
Federal Energy Regulatory Commission
888 First Street NE, Room 1A
Washington, DC 20426