Pacific Gas and Electric Company

Upper North Fork Feather River Project, FERC No. 2105

REPLY COMMENTS

In response to AW, Chico Paddleheads, & Shasta Paddlers Dec. 1, 2003 comments

 

 

General Comment: – The Pacific Gas and Electric Company (Licensee) has been involved in collaborative discussions with numerous stakeholders in this Project, including the American Whitewater, Chico Paddleheads and Shasta Paddlers (collectively AW).  These discussions have resulted in the development of a Draft Settlement Agreement, on which the Parties are currently in the process of making final changes.  Licensee assumes that the proposed conditions and recommendations of the parties entering into the final Settlement Agreement will be modified to reflect the final version of the Settlement Agreement.  Accordingly, Licensee’s reply comments are limited to those proposed conditions that either conflict with or are not addressed in the Draft Settlement Agreement.  The Draft Settlement Agreement addresses concerns about the potential affects of whitewater boating releases during the summer months and includes a mechanism to address these concerns while providing the opportunity for whitewater flows from July through October.  The whitewater portion of the agreement has general support from most all interested parties on all elements, except AW, which disputes the boating use level needed to trigger additional boating releases on the Belden Reach.

 

 

AW Recommendation D – Triggers for Flow Adjustment. 

 

Licensee Response:

 

The current boater use trigger levels contained in the Draft Settlement Agreement are based on the principles of the Electric Consumers Protection Act (1986), which requires the FERC to give equal consideration to power and non-power values and principles developed by the U.S. Water Resources Council to “guide the formulation and evaluation studies of the major Federal water resources development agencies.”[1]

 

In developing the boater use triggers Licensee used the whitewater boating user-day values developed by Confluence Consulting (Licensee’s whitewater consultant), which developed an estimated boating user-day value for the Belden Reach based on the economic value of whitewater resources of comparable river reaches to the Belden Reach (see pages E5-1052 through E5-11054 of License Application).  Confluence estimated the whitewater boating user-day benefit value for the Belden Reach to be between $20 and $40.  In developing the boater use trigger, Licensee assumed a slightly higher user-day benefit value ($50) and divided this amount into the societal, lost generation economic value of providing one day of whitewater boating release to the Belden Reach.  The estimated amount of water necessary to make one day of whitewater boating release, including ramping up and ramping down water, is about 500 acre-feet and has an estimated value of $9,300 assuming a $0.03/Kwh cost of electricity.  This calculation resulted in approximately 186 boaters needed to create sufficient whitewater economic benefit to offset the societal cost of otherwise using the water for electric purposes.  This calculation does not factor in any potential lost societal economic benefit from anglers being displaced as a result of the whitewater release, which would result in an even high number of boaters for a trigger.   This 186 boater calculation is the basis for the range of 130 to 200 boater day triggers used in Table B of the Draft Settlement Agreement.

 

The whitewater boater day triggers contained in the Draft Settlement Agreement are based, more appropriately, on a sound, professionally accepted method for balancing economic benefit between water resource interests. This economic, equal consideration  method was also used to develop the whitewater boater day triggers contained in the new license for the nearby Rock Creek -Cresta Project (FERC 1962), which as the AW points out, has received up to 500 boaters per day on each reach during recent boating releases. 

 

In summary, the Draft Settlement Agreement does contain provisions to provide boating releases during the summer and fall months in the Belden Reach.  If the Belden Reach is as high a demand and as important a statewide whitewater recreation resource as AW suggests, then the Draft Settlement Agreement whitewater use triggers for additional flows should be easily reached, as they have on the adjacent Rock Creek and Cresta reaches.  If whitewater boating use levels do not reach the trigger levels, then the State’s water should be used for a higher-valued use within the State.