Plumas County Resolution 04-7076

Opposing Further Consideration 


Construction of the Proposed

Prattville Intake Thermal Curtain


WHEREAS, the Plumas County 2105 Committee (2105 Committee), on behalf of the Plumas County Board of Supervisors (Plumas) has been working cooperatively with 2105 Licensing Group (LG) for the past two-years in an attempt to finalize a Settlement Agreement (SA) that can be presented to Federal Energy Regulatory Commission (FERC) in support of the re-licensing of Project #2105 (License), and


WHEREAS, 2105 Committee worked diligently to meet the FERC October 2004 schedule for agreements to assure that the License would be signed and all parties would benefit from a timely License, and


WHEREAS, the board has been kept advised of the meaningful progress that led to the signing of the April 23rd, 2004 Settlement, and


WHEREAS, since the signing of the SA, 2105 Committee and Plumas have become aware that not all of the study data had been completed for the Water Temperature agreements that were made under the FERC Project #1962 Rock Creek/Cresta (RC/C) agreement that requires a reasonable set of alternatives be developed by PG&E that may reduce the water temperature to 20 degrees Celsius, or lower at the RC/C reaches, and


WHEREAS, to date PG&E has only presented one alternative, known as the Prattville Intake Modification (Thermal Curtain), and the information from PG&E has been delayed more than 5-months, and 


WHEREAS, those data show that the proposal will not provide the water temperature results, or the cost estimates originally

                      anticipated in the RC/C agreement, to wit:

1)     The water temperature downstream can not be reduced by the installation of one curtain, but rather there would be a need for two more Thermal Curtains in Butt Reservoir increasing the total cost of at least $53 million, to be borne by the Rate Payers, not PG&E and in addition,

2)     Even that investment will only reduce the water temperature down stream by 1 degree Celsius in Normal and Wet Years and not even that amount during Dry and Critically Dry Water Years, which historically have been 50% of the time, and


WHEREAS, earlier studies and reports resulted in an agreement between PG&E, California Department of Fish and Game (DFG) and FERC in their 1996 Draft EIS that a minimal water temperature reduction was not prudent, based on the following statements:

1)     “Based on the results of physical modeling studies and their projected temperature benefits, PG&E and DFG have

 separately concluded that equal, or greater protection and enhancement of NFFR fishery resources would result if PG&E provides funds for fishery enhancement projects than if PG&E fulfills the Agreement…Therefore DFG and PG&E have agreed to amend the Agreement by deleting the requirement to modify the Prattville Intake structure….”

2)     “Because food, not temperature is probably the limiting factor, the additional temperature decrease of 1 degree 

Celsius due to temperature modification would not have any further effect on use.”

3)     “The temperature modification proposal does not come close to justifying its cost, as calculated by FERC.

Whether it is considered as a self-standing option, or in combination with the 1991 Agreement, or DFG proposal, the annual cost of $1.9 million is not a cost-effective way to spend ratepayer’s money.”


WHEREAS, the construction will require the excavation and removal of 42,000 Cu.Yds. of  rock and soil that according to Maidu Tribe representatives will disturb and/or destroy their ancient cultural and burial sites, and


WHEREAS, the plan to withdraw up to 50% of the Lake Almanor Cold Water Pool could result in the following degradation of the lake waters and fisheries, to wit:

1)     The Thomas Payne and Associates report, states that the Lake Almanor salmonid habitat could be reduced up to 40%, and

2)     A. Joe Odgaard (one of the researchers that presented the Thermal Curtain alternative) is quoted in a May 20, 2004 Iowa State news release, as saying that “…a continuous withdrawal of only cold water could deplete the lakes cold water supply, resulting in damage to the lake habitat.”, and

3)     Ron DeCota, a long-time California Department Fish and Game fish biologist, who helped manage Lake Almanor fisheries for 20 years, wrote in a June 14, 2003 letter to FERC regarding the Thermal Curtain, 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. (Butt Reservoir being the second lake). Therefore, we recommend the feasibility study be abandoned and deepwater releases at Prattville (and Canyon Dam) not be pursued.”

4)     The 2004 Payne and Associates report indicated that the Thermal Curtain would virtually eliminate the pond smelt that provide the major food source for the trophy trout in Butt Reservoir, and require mitigation measures to restore the appropriate level of Dissolved Oxygen (DO) and,


WHEREAS, PG&E has not revealed studies that indicate they have pursued any alternative solution to a reduction in water temperature reduction, and


WHEREAS, There are obvious alternatives, including re-operation of Caribou #1 and # 2 during the month of August and

release of cold water through the lower gates at Canyon Dam, rather than the current blending of the cold and warm water that could reportedly reduce the NFFR temperature by 1.5 degrees Celsius,  and


WHEREAS, There are other proposed alternatives to the Thermal Curtains that PG&E has not been willing to consider publicly, included a) Cooling towers, b) Cold Water Wells, c) Stream course rehabilitation to provide maximum shading, and


WHEREAS, even though there may be reasons for reducing the water temperature down stream, all studies show that the installation of a Thermal Curtain at the Prattville Intake will be detrimental beyond definition to both Lake Almanor and Butt Reservoir, and


WHEREAS, the RC/C agreement requires the Ecological Resource Committee (ERC) to “..evaluate the effectiveness of”…..the Prattville Intake Curtain…”after review of the study results.”, it does not provide a proper review of the environmental impacts of that structure on either Lake Almanor, or Butt Reservoir, and


WHEREAS, there is apparently no intention for PG&E to complete a feasibility study on any of the three proposed Thermal Curtains, and


WHEREAS, all studies thus far indicate that the construction of the Prattville Intake Modification (Thermal Curtain) will cause great environmental damage to the ecology and lake fisheries, and


WHEREAS, Plumas County Board of Supervisors recognizes Lake Almanor as one of our pristine assets that is the main socio-economic driver of northern Plumas County, and


WHEREAS, degradation of the waters and/or shoreline of Lake Almanor and Butt Reservoir would cause severe reduction in  home values in the Lake Almanor Basin and severely damage the tourism that is important to Plumas County businesses,


NOW, THEREFORE BE IT BE RESOLVED THAT, Plumas County Board of Supervisors this day declares their adamant opposition to the construction of the Prattville Intake Modification (Thermal Curtain), and


FURTHER BE IT RESOLVED, Plumas County will enlist the assistance from state and federal elected officials, SWRCB, the Governor, and the PG&E Rate Payers to cease and desist any consideration, or further study of the Thermal Curtains in Lake Almanor and Butt Reservoir.


The foregoing resolution was duly passed and adopted by the Board of Supervisors of the County of Plumas, State of California, at a regular meeting of said Board held on the 12th day of October, by the following vote:


Ayes: Supervisors Dennison, Pearson, Meacher, Olsen and Nelson

Noes: None

Absent: None




                                                                                                                    Signed;  Kenneth Nelson

                                                                                                        Chairma, Plumas County Board of Supervisors


Nancy L. DaForno

Clerk of the Board