Take Action for Salmon and River Ecosystem Health! The 12-month period from January to December 2013 has been the driest year on record. Watersheds across the North Coast of California are feeling the stress from recent drought, the undeniable onset of local and planetary climate change, and an increasing intensity of human economic activities that rely on the exploitation of scarce water resources. The hydrological conditions in the Eel River are of particular concern to the Environmental Protection Information Center (EPIC), as well as many other stakeholders in the region.
In response to these clearly extreme and dry conditions in the Eel River basin, drastic reductions in flow releases from the Potter Valley Project (PVP) have been requested by the Pacific Gas and Electric Company (PG&E), operator of the PVP, of the Federal Energy Regulatory Commission (FERC), the agency with authority over permitting conditions for the PVP. Late last week, on Thursday, December 12, FERC ordered that the urgent PG&E request would be granted and that PG&E would be allowed to implement the “critical” water year flow releases for the Eel River below Scott Dam and into the East Fork of the Russian River through at least the end of January 2014.
What this means for the Eel River is that minimum flows out of the PVP dams, which would in a “normal” or “dry” year remain above a minimum of 100 cubic feet per second (cfs), are permitted by the federal government to drop as low as 25 cfs, flows which will clearly present serious challenges for recovering salmonid populations in the mainstem and lower sections of the Eel River.
EPIC is gravely concerned about the precedent being established by this management decision. Though there are several elements of the justification for this decision that could support a temporary reduction of releases below the agreed upon Reasonable and Prudent Alternative of 100 cfs for this time of year, we are very concerned about the manner in which this decision was made, as well as the ramifications of a severely reduced flow regime on the health of aquatic systems in the Eel River.
Foremost amongst EPIC concerns in regards to this decision is the manner in which public participation is being solicited AFTER the decision has been made. As FERC states in their order granting the flow variance (i.e. severe reductions in flows), “given the historical public interest in the Potter Valley Project and the associated fisheries resources, the general public should be afforded the opportunity to review and comment on a proposal of this nature.” FERC goes on to explain that though the “urgency” of the matter required them to approve the action even as they open a 30-day comment period regarding the flow variance, they would be prepared to integrate public comment into future decisions about any flow deviations deemed necessary beyond January 31, 2014.
Our team at EPIC is sounding the alarm at the precedent that this process is setting as treasured North Coast rivers such the Eel River come under increasing stress from the onset of the local and planetary climate emergency. It is untenable that residents of the Eel River basin, of the North Coast, and of the State of California would not be consulted in a timely manner concerning such drastic changes in the management of flow regimes in the Eel River. Please take action today to request that FERC prioritize the health of the Eel River when authorizing changes in minimum flow standards, and that the public be given the opportunity to participate in a meaningful and well informed manner.
The threats that the dams of the Potter Valley Project present to the health of the Eel River are becoming increasingly evident, as these emergency situations expose the underlying weaknesses of the aging dam infrastructure, out of control sedimentation in the respective reservoirs, and archaic water management vision that is still predicated upon unsustainable water transfers from the Eel River to the Russian River. Tell FERC today that you want the public to have a meaningful voice in the management of our Eel River, and that the health of our river ecosystems must be the number one priority as our society grapples with the impacts of increasing drought and climate change.
To take action follow the steps outlined below:
1. go to the ferc online page and sign up to make an ecomment: https://ferconline.ferc.gov/QuickComment.aspx
2. wait for them to send an email back to you, and then click on the link in that email
3. fill out the form as necessary, and copy and paste your comment (or the sample comment text below)
4. don’t forget to search for and select docket P-77-266
5. once all of that is in order submit your comment
SAMPLE COMMENT:
Mr. T.J. LoVullo, I am gravely concerned about the recent order granting the Pacific Gas and Electric Company (PG&E) permission to greatly reduce flows out of the Potter Valley Project (PVP) into the mainstem of the Eel River. The flow variance that has been authorized is a drastic measure that presents clear dangers to returning chinook salmon and other salmonids in the Eel River system. Maintaining aquatic system health is an imperative as our landscapes and watersheds are increasingly stressed by reduced water resources, a changing climate, and the incessant pressures of human economic activity. To take measures that result in significantly reduced flows without having consulted appropriately with local communities is flirting dangerously with an authoritarian decision making style that will result in an erosion of the public trust in the ability of government agencies to manage water resources and energy infrastructure with the best interest of all citizens and our ecosystems in mind. When consulting with stakeholders regarding the authorization of the flow variance PG&E was informed that it is of particular concern that out-of-basin water transfers may be receiving a higher priority than the maintenance of ecosystem health in the Eel River. I thereby request that any future discussion of flow variance insure that priorities by placed on the maintenance and recovery of listed species in the Eel River, in the facilitation of meaningful public participation in decision making, and holistically planning for and pro-actively anticipating the implications of the rapid onset of local and global climate change on our North Coast river systems.
Thank you for considering this message, and I look forward to further engagement on this issue.
Sincerely,