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Thursday, July 25, 2024
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Why Is PG&E Requesting an Extension on Its Surrender Application of the Potter Valley Project?

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The Cape Horn Dam and Van Arsdale Reservoir on the Eel River an essential part of the infrastructure for the Potter Valley power plant [Photograph from CalTrout]

Those who have been following the progress of PG&E’s planned surrender of its Federal Energy Regulatory Commission hydroelectric license for the Potter Valley Project were expecting to see a draft Surrender Application from PG&E in June 2024. On May 31, PG&E released this statement:

PG&E will be submitting to FERC an Extension of Time (EOT) request for the Final Draft Surrender Agreement (Final Draft SA) as well as the Final Surrender Application and Decommissioning Plan (Final SA). PG&E will propose the Final Draft SA be available for comment in January 2025 instead of June 2024 as currently detailed in the Plan and Schedule approved by FERC on July 29, 2022. PG&E will also propose the Final SA being submitted to FERC in June 2025 (previously January 2025).

PG&E is committed to supporting the Proponent’s (Sonoma County Water Agency, Mendocino County Inland Water and Power Commission, Humboldt County, Round Valley Indian Tribes, California Trout, Trout Unlimited, and California Department of Fish and Wildlife) Proposal of a New Eel-Russian Facility. PG&E and the Eel-Russian Project Authority will enter into legal agreements addressing construction obligations, permitting, and facility transfers. PG&E, the Proponents, and others have formed a steering committee to develop a Surrender Application MOU to best bring shared interests into one agreement that aligns with PG&E’s Surrender Application and Decommissioning Plan. In addition, PG&E will attempt to enter into legal agreements with other agencies and parties where their interest related to the Potter Valley facility removal fall outside of the FERC Surrender proceeding. This approach demonstrates PG&E’s interest in efficiently completing the regulatory approval processes in consideration of mutual interests. PG&E believes the additional time to consult with agencies and other interested parties will result in a more robust Final SA and ultimately in a quicker path for the decommissioning of the Potter Valley Project.

The Eel-Russian Project Authority is working to take over the Potter Valley diversion facility from PG&E, in order to construct a new diversion after Scott and Cape Horn dams are removed. The ERPA has dual goals:  to continue sending some water from the Eel River into the Russian River, and to restore healthy fisheries to the Eel River. 

PG&E’s statement does not provide much information. Friends of the Eel River expressed concern about the delay, saying PG&E is “. . . giving ground on their previous position that arrangements for a potential continued diversion will not delay Eel River dam removal.” 

We spoke by phone to Janet Pauli of the Inland Water and Power Commission of Mendocino County, which has a board seat on the Eel-Russian Project Authority. Pauli said, “I don’t think anyone should be surprised by a 6-month delay from PG&E.” The utility wants to abandon the project, and the delay is most likely for reasons related to data gathering and computer modeling. The data analysis necessary for the Surrender Application is not easy. There is existing data on climate, rainfall, and river flow for the past 100 years, but trying to estimate what the next 100 years of climate and rainfall will bring is a challenge. It will take time to create models using estimates. “Sometimes you have to go slow to go fast,” said Pauli. 

When asked about future public meetings of the Eel-Russian Project Authority, Pauli said there are none currently scheduled because there are “no actions that need to be addressed yet.”

Grants are funding some of the work of ERPA. Sonoma Water obtained a grant from the Federal Bureau of Reclamation for work on the new diversion design. 

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Lake County, which is not a member of ERPA, but is working to be made whole for the planned loss of Lake Pillsbury, was awarded a $700,000 grant by the California Department of Water Resources Water Shortage Management Program funding to provide for analysis of the potential effects of PG&E’s proposed decommissioning of Scott Dam.

Note about the invasive species Sacramento Pike Minnow: While searching for information about PG&E’s request for a delay, we noticed that The Federal Energy Regulatory Commission (FERC) eLibrary contains a Pike Minnow Report posted on May 24, 2024. In 2004 FERC ordered PG&E to prepare an annual report on efforts to suppress the Sacramento Pike Minnow, an invasive species found in Lake Pillsbury and Van Arsdale Reservoir. At first, gillnetting was the method used to catch the pike minnow, but a 2007 review of the data showed that gillnetting was harmful to the steelhead. Pike minnow suppression was discontinued until 2019, when a program of electrofishing was initiated in Van Arsdale Reservoir. The method uses a flat-bottomed boat to scoop up fish into a live well. The pike minnow and other invasive species are separated and disposed of, while the local fish species are returned to the water. 3,063 pike minnow were removed from Van Arsdale Reservoir in 2023. The report contains many charts showing the number and type of fish caught during each of the 8 days of electrofishing in 2023. We could not find an estimate of the total number of pike minnow in the reservoir. Is 3,063 a significant number, or a drop in bucket? The 2023 suppression effort took place only at Van Arsdale Reservoir, not at Lake Pillsbury. A separate pike minnow suppression effort, not covered by the report, is ongoing in the Eel River below the dams.


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Monica Huettl
Monica Huettl
Mendocino County Resident, Annoying Horse Girl.

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