PG&E seeks more flow reductions to Eel and Russian rivers; comment period ends Thursday

Tomorrow, Jan. 15, Pacific Gas and Electric Company will officially apply to the Federal Energy Regulatory Commission (FERC) for further reductions to required water releases from Lake Pillsbury and Van Arsdale Reservoir, as well as extensions to the timeframe of the variance.

The power company received its first variance of release requirements on Dec. 12, 2013 because of extremely low water conditions in Lake Pillsbury in the upper Eel River, but only to the end of January, with provision for review and application for an extension, including a public comment period.

The 30-day comment period began in mid-December and ends this Thursday, Jan. 16.

Early in December, with historic low rainfall in Northern California and no relief in sight, the water level in Lake Pillsbury was dropping at the rate of 250 acre-feet a day (an acre-foot is equal to approximately 326,000 gallons) - until FERC approved the variance on Dec. 12, PG&E environmental scientist Paul Kubicek told the Redwood Times in a phone interview.

Up to that time PG&E was required to release water from Scott Dam at Lake Pillsbury into the Eel River at 100 cubic feet per second (cfs). Twelve miles downstream, at Cape Horn Dam below the smaller Van Arsdale Reservoir, PG&E was required to divert enough water to operate its hydroelectric plant in Potter Valley and release a flow of 35 cfs into the East Branch of the Russian River.

PG&E also was required to release at least 100 cfs into the Eel River below Cape Horn Dam.

According to the Reasonable and Prudent Alternative (RPA), a 2004 agreement among several key stakeholders to set protocols for water releases under varying conditions, 2013 was a "normal" water year, probably because of heavy rain and snowfall in December, 2012.

PG&E asked FERC for a variance to reduce minimum releases to those allowed in a "critically dry" year: 20 cfs from Scott Damn, 5 cfs to the East Branch Russian River, and 25 cfs to the Eel River below Cape Horn Dam.

But even with these greatly reduced releases, Lake Pillsbury has been dropping at the rate of 50 acre-feet a day, Kubicek said, so PG&E is hoping to further lower the minimum releases in the hope of stabilizing the water level in the lake.

A number of tributaries continue to feed water into Lake Pillsbury but they, too, are shrinking from lack of precipitation.

"Our intent is to conserve critical resources for beneficial use over the long term," said Kubicek.

"The licensee [PG&E] states that it can no longer sustain the minimum flow requirements and needs to reduce flow releases to conserve water in Lake Pillsbury, provide for the continued release of water for the long-term protection of chinook salmon and steelhead, and to eliminate the risk of vertical bed collapse in the Lake Pillsbury reservoir," states FERC's Order Granting Temporary Variance of Minimum Flow Requirements.

Asked about "vertical bed collapse," Kubicek explained that erosion in the upper Eel has deposited a heavy layer of sediment on the bed of Lake Pillsbury. The water level has now dropped so far that it is cutting into the sediment bed.

PG&E staff at Lake Pillsbury have observed "sloughing," sediment falling into the water as it flows toward the outlet. Sediment that passes through the dam into the Eel River can leave a fine silt deposit on the salmon nests, or redds, reducing the chances of hatching and survival of the fry.

Salmon have spawned and redds have been observed in the deepest parts of the river, called thalwegs, below both Scott and Van Arsdale dams. "Project biologists believe that the majority of early salmon redds would remain within the wetted channel..." at the reduced flow amounts, PG&E stated in its request for variance.

Power production at PG&E's hydroelectric plant in Potter Valley has been limited by reduction in the amount of water. "We're taking a small hit but we have no other choice," Kubicek said.

PG&E also has an agreement with the Potter Valley Irrigation District (PVID) that allows PVID to withdraw water from the East Branch of the Russian River below the hydroelectric plant, according to protocols also established by the RPA.

In a normal winter, PVID can use up to 5 cfs, but they have agreed to reduce that amount to 2 cfs, Kubicek said.

In addition to the allocation to PVID, PG&E is required to release enough water to the East Branch Russian River for fisheries as required by the National Marine Fisheries Services (NMFS), and a "buffer" amount to account for temporary fluctuations in daily flow due to natural conditions or problems with infrastructure at the hydroelectric plant.

Below Potter Valley, the East Branch flows into Lake Mendocino, a reservoir behind Coyote Dam that is owned and managed by the Army Corps of Engineers. From there water is released into the main stem Russian River.

PG&E consulted with several agencies, including NMFS, the California Department of Fish and Wildlife (CDFW), and the Round Valley Indian Tribes of Covelo, to determine acceptable minimum flows in their application.

The Round Valley Tribes, major participants in drafting the RPA, agreed to support PG&E's request in an email dated Dec. 6, 2013, stating, "We support the reduction now to preserve water in Pillsbury that will be released over coming weeks to ensure enough of a wet river channel that spawners and redds have a decent chance of survival.

"We take exception to the proposed flow variance to the extent that it authorizes any releases at all to the Russian River. Given the critically dry circumstances combined with active spawning in the Eel River by chinook salmon, diversions in any amount from the Eel River during this period will only increase the risks to the fisheries and cannot, therefore, be justified."

In the variance order, FERC responded, "the Tribes' petition for a cessation of flow releases to the East Branch Russian River altogether is not prudent, given the existing fishery and the consumptive water uses downstream."

"We're trying to balance all the issues," Kubicek said.

In the most extreme circumstances, if the level of Lake Pillsbury dropped so low none of the release protocol scenarios could be maintained, "We would have to go to a flow-through system," Kubicek said. "How much [water] goes where - I can't say."

FERC will accept comments on PG&E's current request for an extension of the variance and further reductions through Thursday, Jan. 16. The agency prefers emailed comments. The public notice, dated Dec. 16, 2013, advises the public to submit "brief comments up to 6,000 characters, without prior registration," using the eComment system at

To make longer statements, commenters must be registered at FERC's eFiling system at

For assistance, FERC suggests calling 866-208-3676 or emailing

Alternatively, go to, the Environmental Protection Information Center (EPIC) website, and click on the Action Alert dated Dec. 19, 2013. Instructions for making comments can be found at the end of the article, which also includes a summary of events.

The website states: "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."

Application documents are available from FERC at Documents and media articles are also available on Friends of the Eel River's website, Click on the News tab and then click on the article titled Reduced Flows Approved. Links to documents and other news articles can be found on that page.