April 18, 2005
Randy Livingston
Sr. Director of Power Generation
Pacific Gas & Electric
245 Market Street, Mail Code N11E
San Francisco, CA 94105
Dear Randy:
This is to express Plumas County’s appreciation for PG&E’s willingness to work with the County and other participants in the relicensing of FERC Project No. 2105, but also to express our grave concern over what we perceive as schedule delays by PG&E. We truly appreciate working closely with you and PG&E staff to develop sound, mutually beneficial goals and license terms for the relicensing of Project 2105. Although the County participation has been primarily through their appointed 2105 Committee, which I chair, the County Board of Supervisors are completely informed and continue to guide the Committee actions.
The relicensing process has reached a point of great concern to the County and our citizens. This concern could possibly be described in more politically correct terms, but it is interpreted as “stalling tactics” by PG&E.
Let me be more specific, Randy. The County initiated a collaborative effort (2105 Licensing Group), because we believed that it would be beneficial to all parties and should result in timely resolution of issues. We invited PG&E and you accepted the invitation to not only be a part of the collaborative effort, but to fund the expenses of a facilitator. We thank you for participation and financial assistance.
We all agreed from the very first meeting that a) time is of essence b) in an attempt to reach “yes” on all issues, the question would not necessarily be what is best for each entity, but “can we live with it?”
That mission served us very well up to the signing of the April 23, 2004 Settlement Agreement. Little did Plumas County know of the struggle that would result in attempting to reach even an understanding of the problem, to say nothing of the solution on obtaining a reduced water temperature at the Rock Creek/Cresta reaches. Had we known that PG&E’s evaluations of water temperature management alternatives would require many months of additional analyses, it is likely that we would have held more steadfast on some of the recreation issues that we believed were PG&E responsibilities. However, we acted in good faith and that is behind us. Most important is the future and when those amenities will be implemented, if the 2105 license is not finalized soon.
We cannot second-guess how quickly your staff and consultants could have identified and evaluated alternative options to construction of the Thermal Curtain. But, that has been a major delay and we believe studies for alternatives should have been initiated at the same time the Thermal Curtain was contrived, particularly since there was such a public and political protest against the Prattville Thermal Curtain proposal.
There has been one other delay for which PG&E is responsible—the hiring of a consultant to complete the Environmental Impact Review (EIR). The 2105 LG, including SWRCB staff has been urging PG&E’s Relicensing Project Manager to locate and hire a consultant for the past 7-months, because we have been concerned about the delay in issuance of the 401 Water Quality Certification and new 2105 license. Even today, we are not certain that the final contracts have been signed that permits the EIR work to commence.
The November 2004 PG&E statement that it is not the company’s intent at this time to implement the construction of the Thermal Curtain may have provided security for some, but it left the possibility of constructing the Curtain in the future. We want to reiterate that construction of a Thermal Curtain in either Lake Almanor, or Butt Valley Reservoir will never be acceptable to Plumas County, whether financed by PG&E, or as intended, the Rate Payers. We are prepared to use all means possible to ensure that if the decreased water temperature objectives in the Rock Creek/Cresta settlement agreement are to be met, it will not be to the detriment of the upper water fisheries and/or degradation of the ecology of either Lake Almanor, or Butt Reservoir. This is a reasonable goal and we respectfully request that PG&E join us in that mission.
There is very strong political support to “Stop the Curtain”. However, it makes sense to have the support of PG&E, since your engineering and fisheries experts recognize that the Thermal Curtain is too expensive, will raise the ire of your ratepayers, would only reach the downstream temperature goals about 50% of the time and even then does not clearly establish a benefit to the fisheries downriver.
We must be candid in our concerns to you, Randy. As long as FERC continues to provide yearly extensions of the 2105 LG license, PG&E has no commitment to begin the construction of the recreation facilities, nor fulfill the lake level and water quality understandings that were signed under our April 23rd, 2004 Settlement Agreement. Delay provides a financial gain to PG&E and a continued loss of many amenities that FERC had recognized as PG&E responsibilities 25 years ago. Those do not provide the necessary relationship for a sound partnership in this venture.
Plumas County wishes to continue as a good working partner with PG&E. It is to that end that I write to express our frustrations and request that PG&E establish a reasonable time-schedule under which we can understand PG&E’s expectations for completing the EIR and supporting us in the elimination of the Thermal Curtain from any further consideration in the water temperature alternatives evaluation.
In summary, Randy, Plumas County is seeking your assistance and would like to meet with you on this entire subject on, or before April 27th. That is the date for a 2105LG meeting and our Lake Level Committee meeting (3 p.m.) in Chico, and we hope that you will be able to attend. We could also meet with you in Sacramento following, or prior to the 2105 LG sub-committee meeting (reviewing the last option to the Thermal Curtain). I believe that meeting is scheduled for April 21st from 10 a.m. to 3 p.m.
Please let me know your availability as soon as possible. You may contact me at (530) 258-2058 or e-mail dennison@digitalpath.net.
Thank you Randy.
Sincerely,
William N. Dennison, Chairman
Plumas County Board of Supervisors