CSPA and American Whitewater (AW) have defended proposed measures to keep summer water temperatures in the North Fork Feather River cold enough for trout.  The defense came in comments to the Federal Energy Regulatory Commission (FERC) in opposition to a petition by PG&E to waive water quality certification for PG&E’s Upper North Fork Feather Project (Project 2105).

Relicensing of Project 2105 wrapped up fifteen years ago with a partial settlement agreement.  The Project 2105 Settlement left water temperature unresolved.  FERC left any water temperature improvements to the State Water Board and its water quality certification for the relicensing (certification under the Clean Water Act that the new license would comply with water quality law).  On April 24, 2020, as the State Water Board was on the cusp of issuing a draft certification and a revised draft environmental impact report (EIR), PG&E petitioned FERC to “waive” the certification for procedural reasons.  The State Water Board issued its Draft Certification and Revised Draft EIR on May 15, 2020.  Unless FERC were to reverse its position from fifteen years ago, waiver would mean that water temperatures in most of the North Fork would remain too warm in the summer for trout for the next forty to fifty years.

CSPA and AW’s comments state: “It is fair to say that Project 2105 and associated PG&E projects in the North Fork Feather River watershed could not have been designed to heat up water more efficiently than they do under their present-day configuration.”  The comments document how existing conditions in the North Fork Feather violate the Central Valley Region Basin Plan.  Project 2105 heats water in excess of standards and leaves water too warm to support cold freshwater habitat.

The State Water Board’s Draft Certification would require that PG&E improve water temperatures in the North Fork Feather by releasing more water in summer into the river, instead of bypassing the river through PG&E’s upper power system. The Draft Certification abandons the idea of a “thermal curtain” at Lake Almanor.  The thermal curtain was a proposed engineering addition to PG&E’s power intake that local residents and anglers universally reviled because of impacts to the trout fishery in Lake Almanor.

CSPA and AW, consistent with previous comments from Plumas County, also call on FERC and the State Water Board to require a new facility that would add oxygen to the cold water in Lake Almanor.  Much of the cold water in Lake Almanor has too little dissolved oxygen to support trout.  In the summer, this leaves trout the Hobson’s choice of water that’s too warm but has enough oxygen or water that’s cold but without enough oxygen.  An oxygenation facility called a “Speece Cone” is successfully used by East Bay MUD at Camanche Dam.  A similar facility could be installed and operated at Lake Almanor with funds already allocated for improving coldwater habitat.

PG&E and FERC need to protect coldwater habitat for the trout in the North Fork Feather River and Lake Almanor.  The best way to do that is to let the water quality certification for Project 2105 stand and to implement an oxygenation facility at Lake Almanor.