Potter Valley Irrigation District Protests Pacific Gas and Electric's Minimum Instream Flow Amendment Request

The Potter Valley Irrigation District (PVID) has submitted a motion to intervene, protest, and provide comments to the Federal Energy Regulatory Commission (FERC) regarding Pacific Gas and Electric Company's (PG&E) Minimum Instream Temporary Flow Amendment Request for the Potter Valley Hydroelectric Project. PVID strongly opposes PG&E's proposal to reduce the East Branch Russian River (EBRR) flow requirements from 75 cubic feet per second (cfs) to 25 cfs, citing concerns over water supply reliability, financial burdens on appropriative water rights holders, and the potential harm to the Russian River watershed.

Key Takeaways:

• PVID requests FERC reject PG&E's proposal to preemptively reduce EBRR flows to 25 cfs, and instead approve reductions in EBRR flows slowly over time based on updated storage forecasting and temperature monitoring.
• PG&E proposes reducing EBRR flows to 25 cfs, which could later be reduced to as low as 5 cfs, citing the need to preserve Lake Pillsbury storage and maintain cooler release temperatures at E-2.
• PVID strongly opposes this assertion, citing current Lake Pillsbury storage levels (56,116 acre-feet as of May 13, 2025) and the need to maintain minimum pool levels in the lake.
• PVID supports convening the Drought Working Group for regular discussions on whether reductions in EBRR minimum flows are warranted, based on observed changes in conditions.
• PG&E has very limited discretion to restrict PVID's contracted deliveries, and any assertion that they can disallow deliveries to attain "temperature, storage and facility safety objectives" is false.
• Changes to the minimum instream flow requirement at E-16 would negatively impact water supply reliability within the Russian River watershed, affecting hundreds of diverters, including PVID, with granted Water Rights.
• PVID's appropriative water right allows them to provide water to customers at less cost than purchasing water from PG&E under their contract.

Statistics:

• Current Lake Pillsbury storage levels: 56,116 acre-feet as of May 13, 2025.
• Cumulative inflow to Lake Pillsbury by April 1, 2025: 519,813 AF.
• Cumulative inflow to Lake Pillsbury in April alone: 65,510 AF.
• Appropriate water rights granted by the California State Water Resources Control Board (SWRCB): hundreds of diverters, including PVID.

Sources:

• May 15, 2025 letter from anet K.F. Pauli, President of PVID, to Secretary Debbie-Ann A. Reese, Federal Energy Regulatory Commission.
• Pacific Gas and Electric Company's February 14, 2025 filing with FERC titled Potter Valley Hydroelectric Project, FERC No. 77-CA 2025 Minimum Instream Temporary Flow Amendment Request.
• California State Water Resources Control Board (SWRCB) regulations and documents regarding appropriative water rights.