I would like to have the email below, and the two attachments included with our meeting notes for distribution.


Thank you.



----- Original Message -----

From: Bill Dennison

Sent: Sunday, June 13, 2004 12:07 AM

Subject: Review and comments on Rock Creek/Cresta Water Temperature Agreement


To: Mike Willhoit, Tom Jereb and Plumas County BOS:


The Rock Creek/Cresta FERC Project # 1962 was not readily available in electronic form. Therefore, I have typed portions of the Settlement Agreement that are pertinent to our understanding of the origination of the Water Temperature requirements that are resulting in proposals to initiate a "Prattville Intake Modification control measure." In addition, I have emphasized certain portions of the written agreement and added personal comments in an attempt to not only generate a better understanding of the agreement, but to point out the documents deficiency to require a full review of potential negative impacts of the proposal to Lake Almanor and Butt Reservoir.


It is reasonable to expect negative impacts to both bodies of water, if 50%, or more of the Cold Water Pool is removed from Lake Almanor. It is unreasonable to put any more funding into the proposed project until a full EIS and cost/benefit analysis has been completed.


In addition, the negative impacts from the Prattville Intake Temperature Curtain should be reviewed as soon as PG&E has completed relevant data to discuss whether, or not there is any reason to move forward with the proposal.

Mike, I appreciate the data that you have collected which include the following pertinent information:


* The Draft Environmental Impact Assessment, November 1, 1966 to FERC, in the Rock Creek/Cresta Relicensing stated, "Based on the results of physical modeling studies and their projected temperature benefits, PG&E and California Department of Fish and Game have separately concluded that equal, or greater protection and enhancement of NFFR fishery resources would result if PG&E provides fund for fishery enhancement projects than if PG&E fulfills the Agreement.....Therefore, CDF&G and PG&E have agreed to amend the Agreement by deleting the requirement to modify the Prattville intake structure...."


* In the study done for PG&E by Resource Decisions, December 28, 1999 regarding improving habitat, several points regarding modifying the Prattville Intake to take cold water from Lake Almanor were made, including:


    a) "Because food and not temperature is probably the limiting factor, the additional temperature decrease of 1 degree Centigrade due to temperature modification would not have any further effect on use."

    b) "The temperature modification proposal does not come close to justifying its cost, as calculated by FERC methods. Whether it is considered as a self-standing option, or in combination with the 1991 Agreement, or the CDF&G proposal, the annual cost of $1.9 million is not a cost-effective way to spend ratepayers' money."


Ron DeCota, a long-time CDF&G fish biologist, who helped manage Lake Almanor fisheries wrote a June 14, 2003 letter to FERC that stated in part: "We are not willing to take a chance that our concerns will not upset the delicate ecological balance in these two prized trophy trout lakes. Therefore, we recommend the feasibility study be abandoned and deepwater releases at Prattville (and Canyon Dam) not be pursued."


A June 8, 2003 news release by University of Iowa described their modeling of the Prattville Intake Modification measure, quoted Professor A. Joe Odgaard as saying that "...a continuous withdrawal of only cold water would delete the lakes cold water supply, resulting in damage to the lake habitat."


A May 20, 2004 email from Lori Powers, CDF&G Fisheries Biologist stated in part: "As far as the thermal curtain is concerned, the Department is concerned about 3 issues in particular: 1) the effects on water temperature and fishery in Lake Almanor, 2) the effects on the water temperature and fishery in Butt Valley Reservoir, and 3) the effects of the pond smelt populations in both Lake Almanor and Butt Valley. The Department is recommending thorough study of the potential effects as a first step in the decision process.


There are still unanswered questions that were raised during our May 24, 2004 meeting in Chester, including verification of the historic, pre-dam temperatures that SWRCB is attempting to emulate downstream.


By copy of this, I am once again respectfully requesting that Tom Jereb prepare a written statement that answers those May 24th questions that can be answered and provide a critique on how the remainder of the questions will be addressed.


Since several documents and common sense shed a cloud on the legitimacy of PG&E's Prattville Intake Modification proposal under FERC

Project # 2105, it is incumbent upon Plumas County and others to demand that a full EIS and Cost/Benefit Analysis be initiated immediately. We can not rely on an experiment with the waters of Lake Almanor and Butt Reservoir to benefit a few fish and even fewer fisherman in the Rock Creek/Cresta Reach.


I will appreciate any comments on the attached paper.


The next Water Temperature meeting with PG&E is scheduled for Monday, June 21st at the Chico Holiday Inn. 


Bill Dennison