REDWOOD NEEDLES
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Sierra Club comments on Eel River
Draft Environmental Impact Statement
Water diversions are a major threat to Eel River salmon,
and the Redwood Chapter is making Eel River recovery a
priority. The altered flow patterns due to the diversion of
the Eel to the Russian River are damaging salmon populations
in both rivers. For example, the dam and diversion system
artificially raises the water temperature of the
below-project Upper Eel and impairs the Russian through the
importation of massive quantities of sediment from the
geologically unstable Eel River system. Additionally the
availability of the diverted Eel River water fuels urban
growth in Sonoma and Marin Counties at the expense of both
the Russian and Eel Rivers health. PG&E diverts more
that 160,000 acre feet of water annually from the Eel into
the Russian to run the Potter Valley (hydroelectric) Project
(PVP). Currently the Federal Energy Commission (FERC) is
examining the Potter Valley Projects flow regime for
the fishery. The Sierra Club has filed as an intervener to
be involved formally in the process and has submitted
comments on the Draft Environmental Impact Statement DEIS.
Activists have been advocating for increased flows to the
Eel. PG&E announced that as of April 1st it will voluntarily
boost flows to the Eel and reduce water exports to the
Russian by 15 percent. This decision follows recommendations
from U.S. Depart-ment of Interior, National Marine Fisheries
Service and the California Department of Forestry. Many
activists believe that this minimal change will not be
sufficient to save listed salmonids. The FERC decision will
determine whether this reduction will be sufficient and/or
permanent.
Sierra Club Comments on the DEIS were researched and
compiled by Redwood Chapter Water Committee Chair, Krista
Rector, with assistance from Sierra Club staff member
Jennifer Witherspoon and Michael Bowan (formerly with Cal
Trout).
The comments
Sierra Club believes that the continued diversion
of Eel River water into the Russian River will contribute to
the extirpation of wild Pacific salmonids and to
environ-mentally destructive development and growth.
Previous oversight and regulation by FERC, US Fish
and Wildlife Service, and California Department of Fish and
Game have been inadequate and have resulted in continued
decline of the Upper Eels fishery resources.
Sierra Club views the resources of the Upper Eel as
being held in Public Trust, therefore, it is expected that
FERC under the Federal Power Act not simply maintain the
fishery resources in their present degraded condition, but
protect and enhance those resources.
Sierra Club views the current proceeding as a
historic moment which FERC and the resource agencies should
seize to stem the decline of Pacific salmonids. Clearly the
building and management of the PVP is a key cause of the
decline of the Eel Rivers fishery and water quality.
FERCs objective should be to consider an
option that will recover the fishery. This is
supported in federal and state laws such as the Public Trust
Doctrine, the federal and state Endangered Species Act,
NEPA, the Federal Pow-er Act, and the Clean Water Act.
Sierra Club believes that decom-missioning the
project should be considered for full recovery of the salmon
species. That option has been ignored to date.
Of the alternatives offered in the DEIS, Sierra
Club prefers the Tribes proposal&emdash;particularly the
efforts to protect important summer flows and the inclusion
of monitoring. However, we share the concern that this
alternative may not be sufficient to protect or recover the
Eel Rivers fisheries and therefore we are supportive
of the efforts being made by Friends of the Eel River.
Shortcomings of the DEIS and preferred alternative
compliance language.
The licensee is given carte blanche to increase diversion
levels based on professional judgment of the operating
personnel. Given the licensees (bad) track
record in this regard, it would be prudent to provide as
little wiggle-room as possible for the licensees
operation of the facility. Summer-Rearing Flows.
The preferred alternative fails to protect summer rearing
habitat for steelhead below the project area. The DEIS
focuses on quantity of water but ignores water quality.
Water temperature (raised by the PVP) and turbidity and
toxicity (raised during very low flow levels) are not given
adequate consideration as required by the Clean Water Act.
Monitoring.
Only the Tribes proposal calls for monitoring in
order to gauge success or failure of a flow regime.
Monitoring accompanied by adaptive management that would
allow for revision of the flow regime in order to protect
the fishery is essential. Water Supply Alternatives.
The DEIS pays attention to concerns about water delivery
raised by groups such as Sonoma County Water Agency and
Potter Valley Irrigation District, but fails to address
either alternative water supplies (i.e. development of
ground water, Lake Sonoma) or conservation practices which
could alleviate much of the alleged harm reductions in the
diversion might create. Economic Bias.
The economic evaluation is biased towards presentations
made by PG&E and Sonoma County Water Agency. The economic
value of the Eel River sport fishing industry is completely
omitted. PG&E claims that the cost of monitoring and
additional studies would make the hydroelectric project
uneconomical. The overriding concern before the Commission
should be to effectively evaluate and mitigate the fishery
impacts. The economic viability of the PVP (which provides
under 1% of PG&Es total power generation) is secondary
and questionable, at best.
Concluding comments
The steelhead population of the Eel River has crashed
from ten thousand in the 1940s to just hundreds today
and there has been a 99% drop in chinook. The decimation of
the fish population has lead to a decline in the economic
viability of the regional fishing industry. The river is
being managed with two outcomes: electrical economics and
proliferation of squawfish (non-native salmonid predators).
This cannot continue. FERC must address the Endangered
Species Act and Clean Water Act issues. This would include a
consider-ation of decommissioning the PVP.
Sierra Clubs Redwood Chapter, San Francisco Bay
Chapter and CA/Nevada Regional Conservation Council have
signed on to the Friends of the Eel River resolution that
calls on state and federal agencies to:
take
whatever action deemed necessary, including decommis-sioning
of the Potter Valley Project (PVP), to bring about the
restoration of the Eel River and allow the Eel to be
returned to its original designation as one of the
world-class sport river fishing systems on the West
Coast. The Redwood Chapter and Sonoma Group have
together contributed $5000 to the Friends of the Eel River
lawsuit against the Sonoma County Water Agency over the
agencys bid to increase the amount of water it takes
from the Russian River each year.
For more information about Eel River issues and salmon
recovery, including how you can get involved and help,
please contact: Margaret Pennington, 707-829-2294,
penningt@sonic.net or Jennifer Witherspoon, Sierra Club
Rules for Re-covery project organizer, 415-977-5730,
jennifer.witherspoon @sierraclub.org
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Last updated on 3/02/99
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