Prepared for Senator Dianne Feinstein
By
Plumas County Supervisor Bill Dennison
Regarding
Proposed Prattville Intake Temperature Curtain
Under the FERC Project # 2105 (Lake Almanor) Re-licensing
Intent of White Paper- to provide basic background information that will be helpful to Senator Feinstein in answering constituent correspondence and in resolving this important issue in the weeks ahead.
Purpose of the proposed Temperature Curtain-- to lower the water temperature at the Rock Creek/Cresta River
Reaches located about 40 miles below Lake Almanor to a maximum of 20 degrees Celsius by removing up to 50% of the lakes cold water pool. The Basin Plan designates the North Fork of the Feather River (NFFR) in this area as a Cold Water Fishery, thus the 20 degree Celsius requirement.
Advocates of the decreased temperature—State Water Resource Control Board and some agency fish biologists. California Hydropower Reform Coalition has attended no meetings on the Temperature Curtains, but has erroneously announced (Sierra
County newspaper) that the proposal has been accepted by FERC.
Background—The November 1, 1996 Draft EIS for the re-licensing of FERC #1962 (PG&E Rock Creek/Cresta hydroelectric facilities) included an understanding that: “Based on the results of physical modeling studies and their projected temperature benefits, PG&E and California Department of Fish and Game (CDFG) 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, CDFG and PG&E have agreed to amend the Agreement by deleting the requirement to modify the Prattville intake structure……”
Another major study, (Resource Decisions—Dec. 28, 1999) concluded that; “Because food, not water temperature is probably the limiting factor, the additional decrease of 1 degree Centigrade due to temperature modification would not have any further effect on use.” In addition—“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 ratepayer’s money.”
Long-time CDFG fish biologist, Ron DeCota, who helped manage Lake Almanor for over 20 years, in a June 8, 2003 letter stated; “We are not willing to take a chance that our concerns will not upset the delicate ecological balance in these two prized trophy lakes. (Lake Almanor and Butt Lake). Therefore, we recommend that the feasibility study be abandoned and deepwater releases at Prattville (and Canyon Dam) not be pursued.”
However, contrary to the above, an understanding was developed in the Negotiated Settlement reached in 2001during the re-licensing of the Rock Creek/Cresta License (FERC # 1962) that “reasonable” attempts would be made to meet the proposed water temperature stated above.
The re-licensing meetings for FERC Project #2105 (Lake Almanor) began about 2 ½ years ago. On April 23, 2004, Plumas County, CDFG, PG&E, and others signed a negotiated settlement on some important issues, including Lake Almanor water levels, river flows, recreation development by PG&E, and lake access. That settlement was forwarded to FERC, but we had to wait for additional PG&E study data from Iowa State University on the feasibility of lowering the water temperature to meet the proposal noted above. Distribution of those data and subsequent studies by PG&E have been very slow, but we have preliminary results, including the following:
a) The water temperature downstream cannot be reduced by installation of just one curtain. It will require two more in Butt Reservoir (just below Lake Almanor) for an estimated cost of $51 million; an increase from the original $12 million.
b) The salmonid habitat in Lake Almanor could be reduced by 40%. The remaining habitat will be 39,000 acre feet, or less (approximately 4 %) of the total body of water that is 1,300,000 acre feet at maximum level and about 800,000 acre feet during the season that PG&E plans to draw from the cold water pool. The scientific study to determine habitat damage stated that habitat could be completely eliminated during some periods.
c) The pond smelt that ordinarily go through the Prattville Intake to Butt Reservoir will be virtually eliminated and have a serious impact on the trophy fish feeding at Butt Reservoir.
d) Excavation will be required at the Prattville Intake that is being protested by the Maidu Tribe, because it reportedly will be within their ancient burial grounds. A resolution is being prepared by the Mountain Maidu Tribal Council..
e) The temperature downstream will be reduced only by about 1 degree Celsius in Normal and Wet Water Years, for the critical month of August.
f) During the Dry and Critically Dry Years (about 50% of historic records) the temperature curtain will have no impact on the water temperature.
g) PG&E reports that withdrawal of up to 50% of the Lake Almanor Cold Water Pool may not significantly reduce the lake temperature, but this is being disputed by others.
h) No studies have been produced that show the historical water temperatures in the Rock Creek/Cresta River Reaches were within the current definition of “Cold Water.”
General Issues/Comments—
1. There are grave concerns that an installation of the proposed Temperature Curtains will cause detrimental damage to the Lake Almanor water temperature and fisheries.
2. Such events will have severe, negative socio-economic impacts on Plumas County tourism, businesses and home values.
3. The “temperature solution” is being focused on the Temperature Curtains, when in fact: a) it will not provide the stated goals and b) other alternatives, such as re-operation of the PG&E Caribou hydro-electric facilities and stream course enhancements have not been reviewed.
4. Delay of a solution is favorable to PG&E, since until FERC has granted the #2105 License, the utility company is not obligated to make the investment commitments made under the April 23, 2004 Negotiated Settlement. This could delay the final license for two, or more years. Some of the improvements have been pending since the 1980’s and others were deferred by FERC in the early 1990’s with the understanding that PG&E would remedy them in the final 2004 re-license.
5. The final decision will be made by the SWRCB under there 401 designation that may not be based on a reasonable consideration of the Cost/Benefit, or environmental trade-off of the fisheries at Lake Almanor vs those downstream.
6. Thus, far there are no positive indicators that favor the installation and thus, there is need for serious consideration of the issues noted above, as to when “enough is enough” and the Temperature Curtain proposal is to be discarded.
7. A very effective and knowledgeable environmental grass roots group (Save Lake Almanor) has been developed that will pursue a just scientific, legal and/or political resolution to the Water Temperature issue.
8. The Water Temperature project is scheduled for the Plumas County Board of Supervisors September 21 meeting agenda.
9. The next 2105 Licensing Group meeting is scheduled for October 14th in Chester.
For more information, please contact:
Bill Dennison, Supervisor
Plumas County; District 3
530/258-2058 (telephone)
530/258-1896 (Fax)