WHAT AGENCIES/COMMUNITIES ASK FERC TO STUDY BEFORE deciding the Potter Valley Project’s future

FERC is preparing an environmental review of PG&E’s proposal to surrender the Potter Valley Project license, remove Scott and Cape Horn dams, and allow use of project lands for construction of a New Eel-Russian Facility to continue water diversions from the Eel River to the East Branch of the Russian River.

Agencies and communities have identified critical questions that this environmental review must address. Below, we highlight their key requests for studies and analyses, with links to the full filings so you can read them for yourself.

Lake Pillsbury Alliance: What happens to the people and places around the lake?

LPA asks FERC to examine the loss of Lake Pillsbury as a wildfire suppression resource, the effects on groundwater and local water systems, the loss of recreation, and consequences for the surrounding community. LPA also calls for a full Environmental Impact Statement and a serious comparison of alternatives that would retain the lake and its benefits.

Read LPA’s July 23, 2026 Scoping Comments

County of Lake: How will local impacts be measured and addressed?

The County has called attention to Lake Pillsbury’s role in recreation, water supply, and wildfire protection, as well as the need to assess effects on Lake County residents and services. Its filing provides a local government perspective on impacts and alternatives that FERC’s regional analysis must account for.

Read the County of Lake’s July 24, 2026 Comments

U.S. Department of Agriculture: Which alternatives deserve a full comparison?

USDA asks FERC to examine continued operation, transfer to a qualified successor, and options that retain some or all project works. It also requests study of effects on Forest Service grazing allotments, agricultural communities, water supply, and wildfire response. USDA calls for an Environmental Impact Statement.

Read USDA’s September 18, 2026 Scoping Comments

U.S. Department of the Interior: Will replacement water be ready when it is needed?

DOI asks FERC to test whether the proposed New Eel-Russian Facility can provide water in the volumes and seasons needed, whether Lake Mendocino can store that water under its operating rules, and what happens if replacement infrastructure is delayed. DOI requests an Environmental Impact Statement and a detailed analysis of water supply continuity. DOI filed these comments with a request that FERC accept them after the scoping deadline.

Read DOI’s September 18, 2026 Scoping Comments

State Water Resources Control Board: Are the studies and management plans complete?

The State Water Board identifies ongoing work on slope stability, sediment, toxicity, wetlands, and other subjects. It asks FERC to consider the surrender application incomplete and hold its environmental analysis until PG&E develops the management plans informed by those studies.

Read the State Water Board’s July 23 Comments

Mendocino County Inland Water & Power Commission: Where will the water be stored after Scott Dam is gone?

IWPC asks FERC to analyze what happens when Scott Dam’s seasonal storage is eliminated and the proposed NERF can divert water only when Eel River flows allow it. It specifically raises the risk that water available during winter and wet spring months may not be available when it is needed for summer irrigation, environmental flows, and domestic uses unless additional Russian River storage is developed.

Read IWPC’s July 2026 Scoping Comments

Potter Valley Irrigation District: How will Potter Valley have water when it needs it?

PVID asks FERC to examine the consequences of replacing the existing system of stored water with a seasonal, run-of-river diversion. Potter Valley sits upstream of Lake Mendocino and cannot rely on releases from the reservoir, making the timing, quantity, storage, and reliability of future NERF deliveries especially important to farms, homes, and other local water users. IWPC specifically directed FERC to PVID’s filing for more detailed analysis of this issue.

Read PVID’s July 2026 Scoping Comments

Sonoma County Farm Bureau: What are the economic consequences of reduced water supply?

The Sonoma County Farm Bureau asks FERC to examine the economic effects of reduced Potter Valley Project water on agriculture and the broader Sonoma County economy. It also calls for replacement water infrastructure to be funded, permitted, designed, and operational before existing diversion or storage infrastructure is dismantled, and asks FERC to examine whether the proposed NERF can provide reliable replacement water.

Read Sonoma County Farm Bureau’s July 15, 2026 Scoping Comments

Humboldt County: What happens downstream when the dams are removed?

Humboldt County asks FERC to examine how sediment released by dam removal could affect water quality, channel migration, and municipal water infrastructure serving downstream Eel River communities, including Scotia and Rio Dell. It also asks FERC to evaluate socioeconomic effects on sport and commercial fishing, recreation, and the benefits and costs associated with fisheries restoration.

Read Humboldt County’s July 17, 2026 Scoping Comments

The shared question is whether FERC will examine the complete consequences of the proposal before making an irreversible decision. The filings do not all make the same arguments. Together, they show why the public needs a thorough, transparent review of the evidence and reasonable alternatives.

Follow the Potter Valley Project Proceeding

THEIR DOCUMENTS. THEIR WORDS.

How Much NERF Water Can Lake Mendocino Actually Store?

The Eel-Russian Project Authority (ERPA) says future Eel River diversions depend on rainfall and Lake Mendocino’s storage capacity. What does that mean for water available during the dry season?

ERPA proposes a new facility to divert Eel River water into the Russian River watershed after PG&E decommissions the Potter Valley Project. On its own FAQ page, ERPA says anticipated diversion volumes depend on rainfall levels and Lake Mendocino storage capacity. It describes up to 30,000 acre-feet per year as anticipated and says the facility could reliably divert up to 50,000 acre-feet under typical wet-season conditions.

Those figures deserve a closer look. Water that can be diverted during a wet period is not necessarily water that can be stored for summer use. The amount retained depends on when the water arrives, how much room Lake Mendocino has at that time, reservoir operating rules, and the water already flowing into the lake.

ERPA’s Water Diversion Agreement rules change by season: they set minimum Eel River flows before diversion can begin and limit the share of flow that can be diverted. The rules also set a 300-cubic-foot-per-second facility limit. They describe potential diversions under specified conditions; they do not, by themselves, show how much water Lake Mendocino would retain through a sequence of dry years.

LPA believes the public should be able to see that full calculation. For each water year, how much water is eligible for diversion, how much reaches Lake Mendocino, how much can be retained, and how much remains available when Russian River communities need it most?

These are questions about the performance of a proposed water system. They deserve answers grounded in daily data, reservoir operating rules, and clearly stated assumptions.

Read the documents yourself: ERPA Fact Sheet-Summer 2025, ERPA FAQ and the Water Diversion Agreement, Appendix 3.

How a California tribe is confronting the Trump administration to claim historic rights to a river

Press Democrat - January 31, 2026 - by Amie Windsor

“Just as dam removal opponents, including Lake County itself, are lobbying the administration to intervene and block federal sign-off on PG&E’s plans, the tribes and their allies are asking Washington, D.C., to allow a locally brokered water pact to proceed.”

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BREAKING: Feds Intervene to Halt Potter Valley Dam Removal

December 19, 2025 - KEELY COVELLO

Agriculture Secretary Rollins has asked FERC to reject removal of Scott and Cape Horn Dams.

“It is abundantly clear that PG&E’s application fails to consider appropriately the elimination of water supply to local communities without viable alternatives; the negative impact that removal will have on downstream communities and agricultural producers; and the diminished capacity for wildland firefighting in one of the most fire-prone regions of the country,” said USDA senior advisor Tucker Stewart in written comments submitted to FERC.”

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