COUNTY OF LAKE HELEN OWEN – District 1 Supervisor

Board of Supervisors BRUNO SABATIER – District 2 Supervisor

Courthouse - 255 North Forbes Street EDDIE CRANDELL – District 3 Supervisor
Lakeport, California 95453 BRAD RASMUSSEN – District 4 Supervisor
Telephone (707) 263-2368 JESSICA PYSKA – District 5 Supervisor
Fax (707) 263-2207

February 25, 2025

To Governor Newsom:

On January 31, 2025, you signed Executive Order N-16-25, directing the Department of Water
Resources, the State Water Resources Control Board, the Natural Resources Agency, and the
Environmental Protection Agency to maximize storage of excess flows due to winter storms.
The Lake County Board of Supervisors echoes your concern that we store water desperately
needed for fire mitigation, agriculture, wildlife, and vital household drinking water.

In consistency with your Executive Order, we have a need to reinforce the potential loss of Scott
Dam, the headwaters of the Eel River, would be detrimental to public safety and water supply
security in a fire-prone region of our state. Two of the three largest wildfires in California
occurred in the Lake Pillsbury area; the water stored behind Scott Dam was pivotal to keeping
the fire from moving towards more developed areas. You will recall, 2018’s Mendocino
Complex was a staggering 459,123 acres and 2020’s August Complex, which was lightning-vs.
human-caused, consumed 1,032,648 acres.

We are highly concerned that the State of California has shown support for decommissioning
Scott Dam, rather than serving in a neutral role and weighing the network of risks. The release
of the aforementioned Executive Order presents a contradiction; loss of Scott Dam would
markedly reduce storage of water from future winter storms, whereas your Order directs State
Agencies to maximize storage of excess flows.

Lake County appreciates the need to protect California’s fisheries and the salmon, a federally
recognized endangered species. However, effects of the dam on salmon populations can be
reduced without placing communities surrounding Lake Pillsbury (and more populated areas in
the region, should a small lightning-caused fire grow due to lack of fire suppression water
supply) in harm’s way.

In 2014, Prop 1 was passed dedicating $2.7 billion to invest in water storage projects. This
money is allocated for meritorious projects; many still in development. However, providing
money for more storage and expressing the need for more storage in the Executive Order all
while supporting removal of 80,000 acre feet impounded by Lake Pillsbury is contradictory.

The Lake County Board of Supervisors requests time to meet with your office to more fully
express our concerns surrounding the effects of the proposed Scott Dam decommissioning.
This includes concerns regarding fire resilience, wildlife, water availability, economic impact
from the loss of property, sales, and Transient Occupancy Taxes, and much more. Lake County
has not been heard, and costs to keep Lake County whole in the face of potential future loss of
Scott Dam have been minimized and misrepresented by other parties.

In the midst of unprecedented climate change and concern not to duplicate devastation brought
to Lake County by the August and Mendocino Complex events (with the catastrophic losses and
long-term recovery needs associated with the Palisades and Eaton fires fresh in mind), we are
advocating for the needs of Lake County.

Supporting the decommissioning of Scott Dam without far greater investment in mitigating
related concerns puts Lake County residents and others in our region at risk. We have full-time
residents who live in the Lake Pillsbury area, and we care greatly to protect them, their homes,
their businesses, and the value of their property.

California can do better, and we hope you will agree our water needs are just as important as
other Counties’ water needs. We request to meet with your office to discuss this very important
topic at greater length in hopes of finding better options; the current direction is untenable and
dangerous.

Promoting water storage and protecting endangered species cannot be a binary choice; there
are solutions to save both. PG&E is pitching a plan that offers no real restoration in Lake
County or assurance of resources for necessary mitigations. The State of California, through
Department of Fish and Wildlife, is a party to an MOU that includes all parties except Lake
County, since we are upstream of the proposed Diversion.

If Scott Dam is to be removed, please consider the needs of Lake County, and ensure
necessary funds and resources are allocated to provide for public safety and essential water
storage, in consistency with broader State priorities and Executive Order N-16-25.

Sincerely,

_______________________________________
Eddie “EJ” Crandell, Chair
Lake County Board of Supervisors
 COUNTY OF LAKE HELEN OWEN – District 1 Supervisor
Board of Supervisors BRUNO SABATIER – District 2 Supervisor
Courthouse - 255 North Forbes Street EDDIE CRANDELL – District 3 Supervisor
Lakeport, California 95453 BRAD RASMUSSEN – District 4 Supervisor
Telephone (707) 263-2368 JESSICA PYSKA – District 5 Supervisor
Fax (707) 263-2207

February 25, 2025

Secretary of Energy – Chris Wright

Secretary of the Interior – Doug Burgum
Secretary of Agriculture – Brooke Rollins
Secretary of Defense – Pete Hegseth
United States Attorney General – Pamela Bondi
Secretary of Homeland Security – Kristi Noem
Secretary of Commerce – Howard Lutnik

Re: FERC Proceeding P-77 Proposed Scott Dam Decommissioning in the State of
California

Honorable Secretaries, Attorney General Bondi, and Agency Staff,

The Board of Supervisors representing Lake County in the state of California has grave
concern destroying and draining Lake Pillsbury, an 80,000 acre-foot lake in Northern
California, would constitute an expensive and irresponsible gamble with regional water
supply in an area that has repeatedly been threatened by catastrophic wildfire events. We
ask your collective support in ensuring the Federal Energy Regulatory Commission and your
Federal Agencies take seriously the potential for profound human consequences.

Pacific Gas & Electric (PG&E), a California Public Utility, expects to file a plan to
Decommission Scott Dam, a part of the Potter Valley Project, in July 2025 (two Draft
Applications have already been circulated). Scott Dam has been operated for over 100
years; located on the Eel River, whose headwaters are in Lake County, the dam forms Lake
Pillsbury. The Eel River eventually flows into the Pacific Ocean. Estimated costs of
removing this dam, including early figures for mitigation and restoration, could exceed $500
million.

Lake Pillsbury is a destination for hunting, fishing, camping, hiking, and more. It also holds
water storage that helps to keep the Eel River from running dry every year, especially during
drought years. The Potter Valley Project allows for water diversion further down the Eel
River and into the Russian River basin to provide water for agricultural use and drinking
water for about 600,000 people in Northern California. The water storage has also been
utilized to fight fires in the wilderness surrounding it, Mendocino National Forest. Two of the
three largest wildfires in the state of California occurred in the areas surrounding Lake
Pillsbury, each within the past decade: the August Complex (1,032,648 acres, 2020) and the
Mendocino Complex (459,123 acres, 2018). The August Complex was lightning-caused.

Decommissioning of the dam would put regional agriculture, fire protection, water
availability, and our tourism economy at great risk. Concepts in Executive Orders signed by
President Donald J Trump argue for prioritizing such human needs; we believe FERC would
be going against those Orders if they approved Decommissioning of Scott Dam without a
degree of investment in mitigation measures PG&E is unlikely to engage in unless
compelled to by FERC and other regulatory entities.
On January 24, 2025, President Trump signed Executive Order 14181: “Emergency
Measures To Provide Water Resources in California and Improve Disaster Response in
Certain Areas.” In this Executive Order, President Trump requests that the Secretary of the
Interior and the Secretary of Commerce, “immediately take actions to override existing
activities that unduly burden efforts to maximize water deliveries.” By approving
Decommissioning of Scott Dam, FERC would “unduly burden” many communities that rely
on Lake Pillsbury, minimizing water deliveries to our farmers and other end users, including
water flows in fire hydrants.

The Executive Order continues by highlighting the need to, “deliver more water and produce
additional hydropower, including by increasing storage and conveyance….to high-need
communities.” While this statement is specific to a Central Valley Project, we see the
parallels in the current needs of Southern California to the constant needs of Lake County
and Northern California where large and devastating wildfires have affected our
communities for the past 10 years. Lake County, alone, has endured more than 10
devastating wildfires in that timeframe, with many receiving State and Federal Emergency
Declarations. Reducing our water storage is not what California needs, and it is not what
Lake County needs at all, especially in the surrounding areas of Lake Pillsbury.

Furthermore, on January 20, 2025, President Trump signed Executive Order 14156:
“Declaring a National Energy Emergency.” In this Executive Order, President Trump
requests increases to our supply of energy, stating our “generation capacity of the United
States are all far too inadequate to meet our Nation’s needs.” While the Executive Order is
specific to developing and creating new facilities to provide the nation’s energy, FERC will
be reviewing PG&E’s plan for Decommissioning of the Potter Valley Project’s Scott Dam,
which has the potential to generate at least 9.4 megawatts of energy. The Executive Order,
in Section 7, speaks to “the Department of Defense’s ability to acquire and transport the
energy needed to protect the homeland….with a focus on such vulnerabilities within the
Northeast and West Coast regions of the United States.”

PG&E does not want to continue operating Scott Dam. However, if FERC approves the plan
to decommission the dam under Project 77, it would appear FERC would be acting against
the President’s Executive Orders. If FERC cannot convince or compel PG&E to continue
operation of the dam, there will be devasting impacts to our infrastructure, economy, and
public safety. There are other alternatives previously not given due consideration at the
Federal level that could still be explored.

We are keenly aware of the effects this upcoming FERC decision will have on Lake County,
and hope you will see the importance of ensuring Scott Dam does not recklessly come
down, as is the political hope and desire of many in the State of California.

Secure water supply and protection of people and private property from catastrophic
wildfires are matters of great national consequence and priority. Thank you for joining Lake
County, and fulfilling the intent of President Trump’s Executive Orders, in opposing hurried
and irresponsible Decommissioning of Scott Dam.

Sincerely,

_______________________________________
Eddie “EJ” Crandell, Chair
Lake County Board of Supervisors
From: Lee Boatright
To: Lake County Clerk of the Board
Subject: [EXTERNAL] Pro comment for item 6.7 at the 2/25/2025 meeting
Date: Monday, February 24, 2025 3:18:59 PM

February 24,2025
County of Lake Board of Supervisors
Re: Item 6.7 on the calendar for 2/25/2025

Is it the role of FERC to align exclusively with the interests of PG&E?

There are several outcomes to PG&E’s proposed Scott Dam Decommissioning.

One is that FERC recognizes that the destruction of this project is not in the public’s interest
and directs PG&E to continue with the project AS IS. At 50 cents per KW for the power
generated, PG&E should be able to maintain this project. 9.4 Megawatts of power – enough
to power almost 2,000 homes.

Another outcome could be that FERC directs PG&E to give the facilities to interested parties.
This would of course take power generation off the table, which is the only reason FERC is
involved. It would also be done at NO COST to rate payers or PG&E and have no adverse
impact on the environment.

Who would take over and maintain Scott Dam? Lake County, Army Corp of Engineers,
National Forest Service, the Russian River / Sonoma County group, or perhaps another Joint
Powers Resolution?

Cape Horn Dam. No matter what happens to Scott Dam, it makes no sense, that Cape Horn
Dam be removed, as PG&E has already agreed that the water diversion to the Russian River in
Potter Valley should continue. Cape Horn Dam has a perfectly good Fish Ladder, which
allows fish to go over the dam and on up the Eel River. When comparing the fish counts on
Tomki Creek, a few miles below the dam, to the fish going up the fish ladder, they have
corresponded proportionally for many decades, demonstrating that the Dam is not an
impediment to fish going upriver.

The politics of it all. Seems our congressman, state representatives, and Governor have, in
this case, forgotten who their constituents are, and what another bad drought would look like.

And, yes, I have lived on the Eel River for 35 years.

Lee Boatright

21500 Ridgeway Highway

Potter Valley, CA 95469

707-367-9885 – [email protected]

--
Lee at Boats on the Eel, Potter Valley, CA [email protected]
707-367-9885
 COUNTY OF LAKE Helen Owen – District 1
BOARD OF SUPERVISORS Bruno Sabatier – District 2
Courthouse - 255 North Forbes Street
Lakeport, California 95453 Eddie Crandell – District 3
TELEPHONE (707) 263-2368
FAX (707) 263-2207 Brad Rasmussen – District 4

Jessica Pyska – District 5

March 3, 2025

Tony Gigliotti
Senior Licensing Project Manager
Power Generation
12840 Bill Clark Way
Auburn, CA 95602

RE: County of Lake Comments on Pacific Gas & Electric Company’s (PG&E’s) Draft
Application for Surrender of License and Application for Non-Project Use of Project Lands

Dear Mr. Gigliotti and PG&E Staff:

The County of Lake hereby submits the following comments to PG&E’s Draft Application for
Surrender of License and Application for Non-Project Use of Project Lands (hereinafter, “Draft
Application”). Despite submitting its initial comments on or about December 5, 2023 and several
requests to engage in good-faith substantive discussions with your representatives, the County of
Lake continues to have significant concerns over the lack of demonstrated Lake County-focused
consideration in this Draft Application.

We note the County of Lake received this Draft Application the afternoon of January 31, 2025, with a
deadline to submit comments by March 3, 2025. This provided the parties less than twenty-one (21)
business days to submit substantive comments on a 2,086 page document. We also note that
despite being unwilling to accommodate extension requests from other parties, PG&E unilaterally
extended its own deadline to submit this Draft Application by six (6) days. PG&E is willing to permit
such extensions for its own submittals, but has not allowed reasonable time for other parties to
respond.

Absent such an extension to submit comments, the County of Lake is left to deal with broad
categories addressed in this Draft Application. Section 6.3 of the Draft Application references
“unavoidable adverse effects” of the proposed construction and deconstruction of project facilities
and post-facility removal. First, these effects result from PG&E-determined action, and many are
avoidable only to the extent PG&E does not wish to make the investments needed to cover these
costs, or explore alternatives.

Under Section 6.3, unavoidable adverse effects to the water, fish, soil, wildlife, and other categories
are left without any proposed mitigation measures. PG&E appears content to rely on alleged long-
term beneficial effects of this decommissioning plan for a few of these categories. Furthermore,
PG&E fails to provide estimated short-term or long-term timelines for these unavoidable adverse
effects for any of these categories.

The lack of proposed measures to resolve these unavoidable adverse effects is of significant
concern for the County of Lake and its residents. An example of this is the failure to address the
debris and sediment issues largely ignored under Sections 6.2.1.1 and 6.3.1.2 of the Draft
Application. These sections fail to propose any measure to resolve the anticipated large portion of
the 115,000 cubic yards of total dam materials and 21-35 million cubic yards of sediment may be
effectively dumped in Lake County for an undetermined period.
Further, PG&E’s recent Draft Application continues to very narrowly construe the area that will be
affected by Decommissioning of the dam; as a result, impacts are dramatically underestimated. The
rushed nature of this process and lack of due consideration for very serious concerns expressed
thus far underscore a need for regulatory authorities, including FERC and the State Water
Resources Control Board, to assert their oversight responsibilities, and ensure the network of
potential effects to California residents and all federal taxpayers are duly considered. PG&E
underestimating impacts and leaving others to pick up the pieces, potentially in the face of
environmental disaster, is unacceptable.
As stated in our December 5, 2023 comments, proceeding with decommissioning presents serious
risks that cannot be adequately addressed on the rapid timeline PG&E has proposed, including the
following:
 The precedent of allowing a private/shareholder-owned Public Utility to fundamentally alter
the character of a community without robustly consulting its residents and ensuring any plan
at a minimum keeps affected property owners whole should be deeply troubling to California
residents, and particularly those in rural communities – submitting a plan to FERC without
such considerations would essentially be asking the regulatory body to prioritize the Utility’s
bottom line over the well-being and economic resiliency of these private property owners
(many of whom are PG&E ratepayers) – the implications of this could be far-reaching;
 600,000 Californians are reliant on water managed by the Potter Valley Project,
spanning Lake, Mendocino, Sonoma and Marin counties, and existing climate modeling
suggests there may not be water to divert in up to 8 of 10 years if decommissioning
proceeds – this is a serious gamble with California’s water supply;
 Less than 10 years ago (2014), 67% of California voters voiced their support for $2.7
billion in new spending on water storage, in the interest of increasing California’s drought
resiliency, and Governor Newsom’s Executive Order N-16-25 recently reinforced the need to
store stormwater – yet, refurbishing Scott Dam as a statewide water supply security matter
has been given shockingly minimal consideration;
 Costs related to dam removal have consistently been minimized in FERC and other
proceedings, generating momentum and multi-faceted planning for an uncertain future – if
removal of Scott Dam necessitates construction of new storage assets, how do we count
those costs, and what responsibilities do PG&E and regulatory agencies bear?;
 Two of the largest wildfire events in Lake County’s history were in the Lake Pillsbury
area, and the physical barrier and immediate access to water the lake provided were crucial
to suppression efforts. What if Lake Pillsbury was not there in 2018 and 2020? The
probability of small, lightning-caused fires resulting in large-scale wildfire events is among
many facets under considered in PG&E’s application; and
 The mischaracterizations and inaccuracies pertaining to the economic impacts of
PG&E’s proposal are demonstrative of PG&E’s failure to engage on these matters.
3.4.1.14-26 provides baseless claims that the potential loss of property tax revenue
associated with the Lake Pillsbury area is at $85,000. This does not even account for
the property taxes paid by PG&E in the project area, let alone private landowners. In
fact, the total loss of revenue in the area could conservatively approach or exceed 10
times this amount.

As you will appreciate, the continued lack of substantive attention to Lake County’s concerns in
PG&E’s Draft Surrender Application, despite our attempts to engage in good faith, does little to
inspire confidence the County’s interests, and those of residents and property owners in the area,
will receive appropriate attention. In addition to the substantive concerns described here, please find
further comments and technical review in the attached document, prepared by SLR International
Corporation.

Sincerely,

________________________________
Chair
Lake County Board of Supervisors
COUNTY OF LAKE
SLR International Corporation
2175 N California Blvd, Suite 205, Walnut Creek, California, 94596

February 21, 2025

County of Lake
255 N. Forbes Street
Lakeport, CA 95453

SLR Project No.: 102.021249.00001

RE: SLR Comments on PG&E’s Draft Application for Surrender of License and
Application for Non-Project Use of Project Lands dated January 2025

1.0 Introduction
SLR International Corporation (SLR) has been contracted by the County of Lake to analyze the
effects of the proposed Scott Dam decommissioning, including providing comments on the Draft
Application for Surrender of License prepared by Pacific Gas & Electric Company (PG&E).
PG&E has prepared a Draft Application for Surrender of License and Application for Non-Project
Use of Project Lands dated January 31, 2025 (Draft Application for Surrender of License; PG&E,
2025) for the Potter Valley Hydroelectric Project (Federal Energy Regulatory Commission [FERC]
Proceeding No. 77). The Draft Application for Surrender of License includes information on the
decommissioning process for the Potter Valley Hydroelectric Project, and for the construction of
a New Eel Russian Facility, which is identified as non-project use of project lands by the Eel-
Russian Project Authority (ERPA).
This letter report summarizes SLR’s comments on PG&E’s 2025 Draft Application for Surrender
of License. The comments provided only refer to the Application for Surrender of License aspects,
and not the Non-Project Use of Project Lands by the ERPA.
Although FERC has primary regulatory authority in the Decommissioning Proceeding filed under
FERC Docket P-77, the County would like SLR to provide recommendations on environmental
mitigation and economic impacts to be considered by both PG&E and FERC in connection to the
Environmental Impact Statement (EIS) process required by the National Environmental Policy Act
(NEPA) and the Environmental Impact Report (EIR) process required by the California
Environmental Quality Act (CEQA). PG&E will submit a Final Application for Surrender of License
to FERC in July 2025.
The focus of SLR’s comments is on the existing known or documented conditions and effects
within the County of Lake; impacts outside of the County may likewise be noted, where relevant
to the County of Lake’s concerns.
The position of the County of Lake Board of Supervisors is that PG&E has not demonstrated the
full effects of dam removal, proposed environmental mitigation measures or addressed potential
economic impacts to the County12.
Organization of the Comment Letter:
This letter is organized as follows:

1
County of Lake, 2023.Motion to Intervene and Comments of the County of Lake. July 31.
2
County of Lake, 2023b. PG&E's Proposed Decommissioning of Potter Valley Project and Scott Dam. July 11.

1
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

1.0 – Introduction: Provides an overview of the Draft Application for Surrender of License and
Application for Non-Project Use of Project Lands dated January 31, 2025; background information
on work conducted by PG&E and others for the Potter Valley Hydroelectric Project, and
Interventions by the County of Lake.
2.0 – General Comments by SLR: This section lists general comments on the Draft Application
for Surrender of License, and the general decommissioning process.
3.0 – Comments on PG&E Surrender Application: This section is subdivided into 19
subsections that correlate with the Affected Environment resource areas identified by PG&E. In
particular, the resource areas directly match those listed in Volume II, Section 3.3 Affected
Environment of the Draft Surrender Application. A summary correlation table is included for the
reader.

1.1 Background Information

In 1922, Lake Pillsbury was created by the construction of Scott Dam, one of two dams included
in PG&E’s Potter Valley Hydroelectric Project. Scott Dam is located on the Eel River in the County
of Lake, within the Mendocino National Forest.
PG&E is proposing to decommission the Potter Valley Hydroelectric Project, which includes Potter
Valley Powerhouse, Cape Horn Dam and Scott Dam. The Draft Application for Surrender of
License considers removal of Scott Dam and draining Lake Pillsbury. The proposed
decommissioning of Scott Dam is also considered by some interested parties as part of a broader
initiative to restore the Eel River’s ecosystem and improve fish passage3.
Scott Dam is a concrete, gravity-type, ogee-shaped structure. It is 130 feet high and 805 feet long.
The spillway crest elevation is 1,900 feet4. There are five radial gates and 26 steel slide gates
surmounting the spill crest that allow storage of water 10 feet above the spill elevation.
At its maximum capacity, Lake Pillsbury has a surface area of approximately 2,275 acres with an
elevation of 1,910 feet. The initial design capacity of the lake is 76,876-acre feet at the elevation
of 1,910 feet. PG&E reduced this capacity in 2023 due to concerns of dam instability, to a
maximum elevation at the spillway crest of 1,900 feet. Therefore, the reservoir is currently
operated for a storage capacity of 66,876 acre-feet (ac-ft).
1) On January 25, 2019, PG&E filed a notice of withdrawal with FERC, discontinuing its
efforts to relicense or sell/transfer the Potter Valley Hydroelectric Project. FERC issued a
notice soliciting applications, which did not result in a viable new applicant5.
2) Since July 2021, the Potter Valley Powerhouse has been offline. PG&E determined a
transformer did not meet operating standards (PG&E, 2025). No plans were made to
return the Potter Valley Powerhouse to service.
3) The Project License expired April 14, 2022. The default license term for most hydroelectric
projects under FERC jurisdiction is 40 years. Currently PG&E operates the project under
annual licenses (PG&E, 2025).
4) FERC issued a Notice of Authorization for Continued Project Operation, on April 21, 2022.

3
Friends of the Eel River, n.d. https://eelriver.org/about-us/
4
Scott Dam Area elevations are based on PG&E’s datum, which equals National Geodetic Vertical Datum of 1929
(NGVD29) + 81.7 feet. Elevations for Potter Valley Project (PVP) facilities in the Cape Horn Dam area are in
relationship to the North American Vertical Datum of 1988 (NAVD88) datum.
5
FERC Accession No. 20190125-5100 and FERC Accession No. 20190301-3038.

2
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

5) On July 8, 2022, PG&E proposed to file a Surrender application by January 2025, which
was acknowledged by Commission staff on July 29, 2022.
6) In 2023, the Scott Dam spillways were permanently opened due to seismic risk with the
approval of the Division of Safety of Dams (DSOD, a Division of the California Department
of Water Resources). Lake Pillsbury reservoir had 20,000 AF of reduced capacity. PG&E
submitted a long-term flow variance request to FERC. A Water Quality Certification for the
lower flow is pending with the State Water Resources Control Board6.
7) On December 12, 2023, a Joint Exercise of Powers Agreement was executed by
Mendocino County Inland Water and Power Commission, County of Sonoma and Sonoma
County Water Agency to create the Eel-Russian Project Authority (ERPA)7.
8) On June 6, 2024, PG&E documented progress in developing a Decommissioning plan
among the consulting parties. Prior to filing their final application with FERC, PG&E
provided a revised Surrender application to interested parties and agencies in January
2025, for a 30-day comment period. The anticipated filing of a Final Surrender application
by July 29, 2025.
Several non-governmental organizations (NGOs), governmental agencies, and working groups
have an interest in the Decommissioning process.
Further, all project lands are covered by a Conservation Easement, which transfers the lands for
conservation of the property for beneficial public values and significantly limits opportunity for
future development. The Easement includes: protection of the natural habitat of fish, wildlife and
plants; preservation of open space; limited outdoor recreation by the general public; sustainable
forestry; agricultural uses; and historic values (Deed of Conservation Easement and Agreement
[Eel River Planning Unit]; PG&E, 2022).

1.2 Interventions and Comments by the County of Lake

On July 31, 2023, the County of Lake filed a motion to intervene on the Potter Valley Hydroelectric
Project Decommissioning with FERC using FERC Rule 214 subdivision (b). The County’s
interests in the proceedings include:
1) The Potter Valley Project (PVP) doesn’t just generate power but also provides water
supply for agriculture, recreation, and wildfire suppression.
2) The County has an interest in this matter as this project creates Lake Pillsbury on the Eel
River. This lake has 31 miles of shoreline, used for recreational activities such as fishing,
boating, sailing, and waterskiing.
3) The County opposes Decommissioning of Scott Dam, in part, because PG&E has not
outlined mitigation measures that would be put in place to address environmental and
safety concerns raised by the County.
4) If FERC provides approval for Decommissioning of Scott Dam, the County of Lake
requests the following mitigation measures:

6
State Water Resources Control Board (SWRCB), 2017. Study Requests and Comments on the Pre-Application
Document and Scoping Document 1 for Potter Valley Hydroelectric Project, FERC Project No. 77, Mendocino and
Lake Counties. August.
7
The Agreement is available here:
https://www.sonomawater.org/media/PDF/Water%20Resources/Potter%20Valley%20-
%20ERPA/for%20signature_%20JEPA%20FINAL%20-%20Eel%20Russian%20Project%20Auth%20-%20signed.pdf

3
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

a. Establishing fire protection measures that directly address wildfire risks resulting from
removal of Scott Dam;
b. Establishing water rights for the County of Lake and its residents on Scott Dam, and
implementing water storage measures for the County of Lake;
c. Financial consideration of lost County of Lake property tax collections, and any and all
revenue losses to result from removal of Scott Dam;
d. Additional monetary consideration for loss of economic development opportunity in the
County of Lake;
e. Full restoration and revegetation of the area, restoring flora and fauna in areas due to
the loss of Scott Dam and Lake Pillsbury;
f. Constructing road and other infrastructure improvements necessary to safely complete
the decommissioning plan.
 The County asserts that any financial burden of these mitigation measures should be the
responsibility of PG&E, as PG&E should remain responsible for the PVP and all
consequences throughout the project lifecycle including Decommissioning.
 Additionally, FERC should maintain PG&E’s Licensee status until these mitigation efforts
are addressed. For example, FERC required PacifiCorp (the project owner) to stay Co-
Licensee surrounding Decommissioning of the Klamath Dams.
On December 23, 2023, the County of Lake issued a comment letter to PG&E regarding the PVP
Initial Draft Surrender Application. This letter expressed concern regarding the lack of sufficient
consideration for the effects of decommissioning on the County of Lake. These effects include
loss of property, environmental concerns, regional loss of recreation, loss of water supply for
wildfire suppression, and more. Additionally, the rapid timeline proposed by PG&E and lack of
risk mitigation measures with respect to the County of Lake was an issue. The County is
concerned about the need to manage large amounts of sediment and the lack of communication
between PG&E and the County. Lake Pillsbury is an important source of economic activity as well
as local government tax revenues.
PG&E documents several meetings with the County of Lake in their Draft Application for
Surrender of License; nevertheless, no substantive formal response to comments has been
provided by PG&E to address the County of Lake’s concerns.

1.3 FERC / NEPA / CEQA Process

PG&E has summarized the process to be followed by FERC and the State Water Resources
Control Board as required by NEPA and CEQA. The process described is similar to what has
been followed in other decommissioning processes.
A final approval of the Surrender Application would be documented in a FERC Order with
conditions as specified in the EIS (led by the FERC) and EIR (led by the State Water Resources
Control Board), Management Plans (prepared by PG&E and others), and any other conditions.

2.0 General Comments by SLR

In accordance with 18 Code of Federal Regulations Ch. I § 6.1, an application for the Surrender
of a license for a dam must include a detailed plan outlining the disposition of project works and
any required restoration measures. The plan should address environmental, public safety, and
operational concerns associated with cessation of the project's use. The Surrender application

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

must be filed with FERC, accompanied by necessary environmental documentation and

stakeholder consultations to ensure compliance with federal regulations. Based on SLR’s
independent review:
1) PG&E has not fully addressed or requested an evaluation of Federal and California
Environmental review processes. The County of Lake intends to participate in both
processes.
2) Specific studies are not included in the Draft Application for Surrender of License even
though PG&E acknowledged in the Surrender Application additional studies will be
conducted as part of the final Decommissioning per the future FERC order to be issued.
3) In the Draft Application for Surrender of License, there are references to facilities and
features that will be left in place (including piezometers and block building) and there is no
detailed discussion with respect to the plan to leave in place/restore.
4) The County of Lake has not been included in meaningful stakeholder consultation, and
therefore the stakeholder consultation has not been adequate from the County’s
perspective.
5) PG&E has stated in the Draft Application for Surrender of License that various impacts
resulting from the Scott Dam Decommissioning are unavoidable adverse impacts.
However, the SLR review indicates these impacts are not sufficiently evaluated to be
considered unavoidable.
6) PG&E should more thoroughly evaluate these impacts to establish that they are
unavoidable and identify and evaluate options for minimizing unavoidable impacts. The
County proposes PG&E include additional restoration scenarios that will likely minimize
the unavoidable impacts to the County and enhance recreation, ecosystem, and fire
suppression benefits. We recommend PG&E discusses with the County of Lake these
likely options before the final Application for Surrender of License is submitted on July 29,
2025.
Unavoidable adverse impacts are defined in both NEPA and CEQA. The definitions include:
 NEPA states “Effects that can not be avoided due to constraints in alternatives. These
effects do not have to be avoided by the planning agency, but they must be disclosed,
discussed, and mitigated, if possible [40 CFR 1500.2(e)]” 8.
 CEQA states “A project impact is considered significant and unavoidable if it would result
in a substantial adverse change in the environment that cannot be feasibly avoided or
mitigated to a less-than-significant level if the project is implemented. If a lead agency
proposes to approve a project with significant unavoidable impacts, it must adopt a
statement of overriding considerations to explain its actions (CEQA Guidelines, Section
15093(b))”
PG&E has indicated in the application that several impacts are unavoidable; nevertheless, PG&E
has failed to identify mitigation strategies and offsets. PG&E would need to comply with NEPA
and CEQA with respect to defining the unavoidable impacts.
Clear understanding of the impacts expected to result from the proposed decommissioning is
important to the County, as following the decommissioning process, the County of Lake will need
to revise its General Plan and the Local Area Plan.

8
US Forest Service, nd. NEPA Glossary. https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5298903.pdf

5
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

During a public online meeting on February 6, 2025, PG&E described how the dewatering of Scott
Dam (to occur during the low-flow season) would not necessarily be followed by sediment being
flushed down the river during the subsequent high-flow season. The Draft Application for
Surrender of License does not describe dam removal activities during different years. Rather,
there are mentions of complete rapid removal being completed in approximately two years. The
Conceptual Decommissioning Plan does not specify how Scott Dam and the Eel River flows will
be managed if the first high-flow season does not occur the November following the initial low-
flow season (i.e. if it is a low-flow winter that does not produce much precipitation).
It is unclear how PG&E will determine when a wet season with enough precipitation is anticipated
to conduct the sediment flushing needed during the first high-flow season described in the
Conceptual Decommissioning Plan. PG&E should consider using the definition of the historic
precipitation data in forecasting expected wet and dry seasons. In the absence of a high
precipitation season, a long slow bleed of sediments may occur for many years, and PG&E would
need to address these scenarios in the Sediment Management Plan.
Several plans to manage and mitigate environmental effects are briefly described in the
application. PG&E needs to provide more detailed information on how proposed mitigation
measures will be implemented. Additional comments are anticipated to be provided when these
details become available.

3.0 Comments on PG&E Surrender Application

SLR comments are presented in the following subsections, organized by the resource areas in
the draft PG&E application. For the reader’s reference, this table outlines the corresponding
sections in the PG&E application and this comment letter. Any comments that were not related to
a specific resource areas in the PG&E Draft Application for Surrender of License are presented
in Section 3.19.

Topic PG&E Vol I PG&E Vol II SLR Comments

6.3.1.1 3.3.1 3.1
Water Use and Hydrology
3.4.1.2
6.3.1.2 3.3.2 3.2
Water Quality
3.4.1.3

Fish and Aquatic 6.3.1.3 3.3.3 3.3

Resources 3.4.1.4
6.3.1.4 3.3.4 3.4
Botanical Resources
3.4.1.5
6.3.1.5 3.3.5 3.5
Wildlife Resources
3.4.1.6
6.3.1.6 3.3.6 3.6
Geology and Soils
3.4.1.7
6.3.1.7 3.3.7 3.7
Geomorphology
3.4.1.8

6
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

Topic PG&E Vol I PG&E Vol II SLR Comments

6.3.1.8 3.3.8 3.8
Land Use
3.4.1.9
6.3.1.9 3.3.9 3.9
Recreation Resources
3.4.1.10
-- 3.3.10 3.10
Aesthetic Resources
3.4.1.11
6.3.1.10 3.3.11 3.11
Cultural Resources
3.4.1.12
6.3.1.11 3.3.12 3.12
Tribal Resources
3.4.1.13
6.3.1.12 3.3.13 3.13
Socioeconomic Resources
3.4.1.14
-- 3.3.14 3.14
Environmental Justice
3.4.1.15
-- 3.3.15 3.15
Air Quality
3.4.1.16
6.3.1.13 3.3.16 3.16
Noise and Vibration
3.4.1.17
-- 3.3.17 3.17
Traffic
3.4.1.18
6.3.1.14 3.3.18 3.18
Marine Resources
3.4.1.19

Others -- -- 3.19

3.1 Water Use and Hydrology

 PG&E needs to discuss the local beneficial uses of Lake Pillsbury water, including
drinking, recreational, and others, and how loss of this water supply for the various
beneficial uses will be mitigated. PG&E notes in the application there are no expected
effects on water reliability or cost in the Scott Dam Area because there are no known
surface or authorized water diversions, but PG&E did not acknowledge the potential
recharge to groundwater from Lake Pillsbury, which will result in reduced water reliability
and increased cost for well owners. Additional related comments are provided as part of
Geology and Soils and Socioeconomic Resources sections herein.

7
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

 Water from Lake Pillsbury is currently used for fire suppression, and removing the lake will
affect this resource and water use. Additional related comments are provided as part of
the Land Use section.
 PG&E should evaluate the water supply and the effects on groundwater recharge as part
of the final surrender application. Water supply insecurity has been a concern during
drought conditions in recent years even with Scott Dam in place. As part of the NEPA
Process, PG&E may be required to prepare a Water Supply Management Plan and Public
Drinking Water Management Plan. The Draft Application for Surrender of License does
not include any details on these plans. It is currently unknown what the anticipated
groundwater levels will be in the vicinity of Lake Pillsbury. Drinking water should be made
available to well owners that will be affected by the reduced groundwater recharge
resulting from draining the lake. Long-term effects are not expected to be known until
several years have passed.
 PG&E notes “removal of the dam would restore flows in the Eel River to unimpaired natural
conditions. High flows are similar under existing conditions (i.e. No-Action) and the
Proposed Action (refer to Section 3.3.1, Figure 3.3.1-18), but low flows would vary
substantially. […] Because there are no water users in the Eel River between Scott Dam
and the Van Arsdale Diversion, the Proposed Action would have no effect on water users
in the river reach.” PG&E needs to evaluate the current beneficial uses of Lake Pillsbury
to include recreational, ecosystem, and fire suppression.
 The mass balance approach PG&E used to determine unimpaired flows and flood
frequency is unconventional per standard industry practice. PG&E needs to develop a
flood flow frequency analysis based on the USGS Guidelines for Determining Flood Flow
Frequency – Bulletin 17C9 and perform an uncertainty analysis to account for the raw
hydrology data and unimpaired natural flow assumptions. Active USGS gages along the
Eel River and within the County of Lake are limited and restricted in the information
provided. Streamflow gages near Scott Dam only record periods where flow is controlled
or impaired by dam operations and there are no known or active precipitation gages within
the entire Eel River watershed. The streamflow gages used in the hydrologic analyses are
likely to incur levels of uncertainty based on the unimpaired data available. PG&E should
further analyze the raw hydrology data and assumptions to perform an uncertainty
analysis.
 The January 2025 Draft Application for Surrender of License does not provide any insight
on validating or calibrating the hydrology assumptions for unimpaired flows. PG&E needs
to add additional streamflow gages upstream of the Scott Dam to understand inflows to
the impoundment, validate and calibrate unimpaired natural flows, and predict future
climate change flows. Note that, the California State Water Resources Control Board, as
part of the 2022 California Stream Gaging Prioritization Plan, have highlighted the
Smokehouse Creek-Lake Pillsbury, Lake Pillsbury-Eel River, and Rice Creek-Rice Fork
watersheds that supply Lake Pillsbury as high-priority watersheds with significant gaps in
their stream gaging network.10 The Plan also highlights that the Eel River reach between
Scott Dam and Cape Horn Dam are not defined as well-gaged but as almost well-gaged
or un-gaged.

9
https://pubs.usgs.gov/tm/04/b05/tm4b5.pdf
10
SB 19 Stream Gaging Plan | California State Water Resources Control Board

8
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

 PG&E should conduct further analysis into the operations, storage, and streamflow gage
relationship to better understand the flow relationship to operations and assumptions for
unimpaired flows and water supply. Further analysis over the entire period of record will
also provide a level of confidence in the data and assumptions made for the hydrology
and hydraulics. Operations of Scott Dam have changed due to varying regulations and
restrictions over the life of the dam. Storage capacity has likewise changed, due to the
accumulation of sediment within Pillsbury Reservoir and permanently opening the spillway
gates due to seismic concerns. SLR recommends verifying the assumption of no sediment
management or removal of sediment within the Lake Pillsbury Reservoir. Changes in
operations and storage can affect the stage discharge relationship.
 To the benefit of stakeholders including the County, PG&E should make all relevant data
available to stakeholders and firms providing contracted technical support. Scott Dam has
been in place since 1921, and there is limited publicly available data. A majority of relevant
data is managed by PG&E. The various reports and studies completed reference a variety
of PG&E supplied data not made available for this review.
 PG&E needs to further develop the hydrology, building on past analyses to evaluate future
climate change scenarios as part of the environmental analysis for dam removal.
 PG&E should develop a hydraulic model to better define the proposed action during
varying seasons and recurrence intervals. This would also support quantifying the
sediment yield.
 PG&E needs to analyze sediment grain size distribution and determine the grain size and
flow correlation for mobility (i.e., At what flows will sediment move?) to support changes
in the longitudinal profile as well as core sampling the entire depth of sediment within Lake
Pillsbury. Tributaries upstream and downstream of Scott Dam are likely sediment sources
that account for and will continue to transport sediment into the Eel River system under all
conditions.
 PG&E needs to develop a risk and uncertainty analysis for the proposed Scott Dam
removal to better understand potential consequences and articulate the level of
uncertainty or confidence in the data assumptions. The hydrology informs the hydraulics
and the function of the existing and proposed infrastructure and the assumptions under
proposed conditions. If hydrologic information is limited or inconclusive, there is a lower
level of confidence in the models and assumptions made to fill in gaps within the data.
 PG&E notes "The Flood Monitoring Plan would establish protocols for monitoring water
levels and flood risks, enabling proactive measures to protect infrastructure and
surrounding areas." The details of the proposed plan will need to accommodate the
findings of the additional hydraulic modelling for defining the monitoring requirements.

3.2 Water Quality

 PG&E notes they expect a short-term adverse effect due to the suspended sediment and
turbidity following removal of the dams. Based on the level of uncertainty of the models,
and lack of grain size analysis data, it appears that the anticipated period of several days
up to several months, and additional effects with remobilization for 1 to 3 years may be
optimistic. PG&E should conduct further studies to improve the sediment grain-size
distribution dataset and update the sediment transport models with improved data.

9
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

 PG&E should consider the above suggested additional data collection in development of
short term and long-term sediment mitigation measures, including engineering controls
and maintenance activities.
 PG&E acknowledges there will be impacts to water temperatures during and following the
removal of Scott Dam. Given the uncertainty of the existing models, these may be
underestimated, and additional evaluation with improved data should be conducted by
PG&E in order to facilitate the methodologies for temperature monitoring.

3.3 Fish and Aquatic Resources

 The Application does not include the estimated current fish population of Lake Pillsbury.
The Draft Application for Surrender of License provides an overview of fish and aquatic
resources in the Project Study Area, which includes the Eel River from upstream of Lake
Pillsbury downstream to the ocean, including the East Branch of the Russian River to Lake
Mendocino. PG&E needs to include the lake-related fish population for estimating the
ecological impacts due to the decommissioning of the Lake.

3.4 Botanical Resources

 PG&E needs to document the botanical resources within the footprint of Lake Pillsbury to
better address the maintenance and improvements necessary to sustain these resources
as part of the decommissioning process.
 PG&E needs to document riparian and wetland resources within the footprint of Lake
Pillsbury to better address the maintenance and improvements necessary to sustain these
resources as part of the decommissioning process.

3.5 Wildlife Resources

 PG&E needs to document the wildlife resources within the vicinity of Lake Pillsbury to
better address the maintenance and improvements necessary to sustain these resources
as part of the decommissioning process.

3.6 Geology and Soils

 PG&E needs to evaluate impacts on surface and groundwater interactions following dam
removal and its effects on groundwater wells as part of the Surrender Process. It is
anticipated stored groundwater will be used, and without surface water replenishment from
the reservoir, groundwater levels will be lower and affect existing wells. As a mitigation,
PG&E should establish a well monitoring program pre- and post-dam removal, and funding
to support well owners to repair or deepen existing wells to allow access to groundwater.
 The Draft Application for Surrender of License says there was no readily available
information on the specific groundwater wells that may be affected. PG&E should conduct
additional evaluation of the publicly available well completion reports and identify
potentially affectedwells.
 PG&E should conduct additional hydrogeological assessments and evaluate the radius of
impact of the groundwater level drawdown. Once the system is better understood, PG&E
should contact residents and landowners in the impacted radius to notify of these potential
impacts, and request information on existing wells in the affected area. A detailed
groundwater monitoring plan should be developed prior to decommissioning of Scott Dam.

10
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

 Suggested mitigation strategies similar to those established for the Lower Klamath
Projects should be considered by PG&E. For example, in that instance, the Water Board
required the following conditions to be met by the Renewal Corporation. Note that the
distances or number of locations listed below are for information only, and site-specific
criteria applicable here needs to be developed based on further studies:
a) Monitor groundwater levels within a 2.5-mile range of the high-water marks, before,
during and after reservoir drawdown;
b) Contact all residents and landowners within 1,000 feet of the reservoirs;
c) Identify potentially affected groundwater wells;
d) Monitor groundwater levels at a minimum of 10 locations within the 1,000 feet
radius for at least two months before drawdown activities, and continue monthly
monitoring for at least two years;
e) If necessary, mitigate groundwater impacts.
 The geotechnical engineering concerns indicated by PG&E (i.e. landslide at the left
abutment) being presented as a reason for dam removal have not been subjected to
adequate technical scrutiny. The original designers and constructors were apparently
aware of the landslide-prone areas and have re-aligned the dam with a kink in it in an
effort to avoid the higher risk area.
 The removal of the abutment structure will require more detailed evaluations including
abutment removal sequence and phasing plan, temporary excavation support systems for
worker safety, slope stability analysis for each stage of the proposed removal, permanent
slope support systems, and ground movement monitoring and alarm systems. During
removals, there is a high risk of triggering landslides. Proper restoration and re-vegetation
of these slopes to their original condition may involve complete removal of the abutment.
 Upon removal, the existing slopes all around the basin will be subject to higher risk of
landslides. This risk may be heightened during or soon after water release due to rapid
drawdown conditions. The slope conditions of currently submerged areas need to
analyzed and remedial grading should be developed accordingly.
 Alternative options should be further evaluated, as they can provide a well-balanced
remedy to many of the geotechnical and geologic concerns.
 PG&E needs to conduct targeted and dam-specific subsurface investigations as a crucial
part of this process in the absence of existing documentation to support the current
conditions.
 Debris management needs to be considered as part of the removal process, including any
disposal or reuse of the demolished concrete of the dam, other structures, material found
at recreational facilities, and any material (including solid waste) discovered during
sediment removal. PG&E proposes the bulk of the dam material would be stored and
capped on PG&E lands. Land disposal of waste in California is regulated under California
Code of Regulations Title 27, CEQA and County ordinances. PG&E should detail their
planned permitting process for disposal of non-hazardous waste on PG&E lands.
 PG&E needs to evaluate risks associated with triggering slides when removing the dam
and when cleaning out sediments. The Application to Surrender License does not provide
details on evaluating these risks, it notes the exposed reservoir bed would be susceptible

11
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

to erosion and proposes to define specific mitigation measures in management plans that
will be prepared in the future.
 Additional investigations and planning are needed to protect against a potential release of
Naturally Occurring Asbestos (NOA) which is known to occur within the Lake Pillsbury
watershed. A NOA management and mitigation plan would need to be developed to
mitigate the potential impacts during the dam decommissioning process. The Draft
Application for Surrender of License mentions there is serpentinite rock in the area of Scott
Dam but does not consider the potential impacts of disturbing asbestos containing rocks
or the potential risks of releasing asbestos into the air during construction.

3.7 Geomorphology
 Better understanding of current conditions of the dam and the lake will be crucial to support
any proposed dam removal process. PG&E’s proposed conceptual approach lacks
sufficient baseline studies on the amount and quality of sediments impounded in Lake
Pillsbury.
 PG&E needs to complete a comprehensive sediment risk analysis for the proposed action.
The United States Bureau of Reclamation recommends an iterative, risk-based approach
for evaluating and managing sediment impacts from dam removal projects in its Dam
Removal Analysis Guidelines for Sediment (Bureau of Reclamation, 2017).
 The application notes “PG&E would develop a Scott Dam Slope Stability Monitoring Plan
that would include the following measures to address and reduce the potential for
reactivating the landslide and to protect worker safety.” The details should be provided by
PG&E to better understand the proposed plan.
 The application notes “Water surface elevations would continue to decline after the dam
is removed. Without the impoundment, the denuded slopes surrounding Lake Pillsbury
and the exposed reservoir bed would be susceptible to water and wind erosion, especially
as the soils dry.” The details should be provided by PG&E to better understand the
proposed plan.

 The PG&E Draft Application for Surrender of License would need to address sediment
impacts to water quality, erosion and transport following dam removal, and any mitigation
alternatives such as sediment stabilization or removal.
 To analyze the effects of sediment transport, PG&E relies on the 2-year event scenario
modeled by Stillwater Sciences (2021c)11, which it acknowledges differs from the
Proposed Action. Because the method of dam removal heavily affects sediment erosion
and transport modelling, PG&E should model the final removal approach and determine
sediment-related impacts.
 PG&E will need to evaluate sediment grain size distribution. Additional field studies would
be needed to properly evaluate the relative proportions of coarse and fine sediment
impounded behind Scott Dam, which will affect transport of sediments. If the lake is
drained, there would be increased landslide hazards of the currently submerged slopes.
These risks would be increased in a similar fashion to lowered safety factors for any slope
under drawdown conditions. This may involve long-term maintenance efforts in the wet

11
Stillwater Sciences. 2021c. Hydraulic model development and potential flood implications following the proposed
Scott Dam removal, Eel River, California. Technical memorandum. August 2021. As referred to in PG&E, 2025.

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

seasons. Such slope failures or slumps would increase the volume of materials that have
to be managed, in addition to the already inordinate amounts of sediments that must be
mitigated. Other geotechnical issues to be looked at include the stability of submerged
slopes when the lake is drained.
 Potential scour at or near the toes of future slopes needs to be addressed as it can be a
triggering factor for landslides.

3.8 Land Use

 PG&E noted that “The Proposed Action may result in unavoidable adverse effects to local
fire suppression to properties near Lake Pillsbury due to the replacement of Lake Pillsbury
with the Eel River or other sources as a water source, resulting in potentially longer fire
response times.” The loss of Lake Pillsbury water availability would have significant
wildfire suppression adverse impacts on infrastructure, property, and human life. Below
is an analysis of the key impacts that PG&E need to include in their analysis:
o Keeping small wildfires small is vital in the County of Lake due to the history of
wildfires in the area. Federal, state and local fire resources have all worked
together in the past to combat the many large campaign fires that have brought
stress to the communities that have been affected.
o Dry lightning around the Lake Pillsbury area poses the greatest risk for large scale
wildfires in the area due to their unpredictability. Lightning fires can spark a large-
scale wildfire in very remote areas of the Mendocino National Forest and have the
potential to grow rapidly with fuel and topography alignment. Dry Lightning is a
natural occurring event in California and is always a threat to the wildland every
year.
o The County is already prone to having water availability problems due to the
wildland rural community interface that affects the populace that call the area
home. Water availability directly correlates with fire department resources
efficiency to fight fire in a rural area. Large fires that develop near Lake Pillsbury
can grow (and historically have grown) exceptionally large due to the difficult
access and topography aspects that promote fire growth.
o Since its creation, Lake Pillsbury has always been utilized as a water resource
because it reduces flight or drive time to resupply water to combat fires in the
surrounding area. Extended fire attack operations that take place around Lake
Pillsbury benefit from and rely on the lake as a primary water source because of
reduced drive time for ground resources to refill their apparatus with water.
Additionally, not having a body of water available to fire resources will always
change fire strategies. Mitigating fire threats in rural locations always makes fire
attack operations difficult for firefighter safety.
o In the Lake Pillsbury area, the first suppression resource on scene of a fire will
most likely be a fire engine. There exists a direct mutual aid agreement allowing
both US Forest Service and CAL FIRE to respond regardless of jurisdiction. The
first responder could be one of the helicopters from CAL FIRE. Because of the
limited resources in the more rural areas, the helicopter resource becomes a
critical initial attack resource. The closest fire station to Lake Pillsbury is a USFS
station 2.6 miles/9 min drive to Lake Pillsbury. The closest CAL FIRE helicopter air
support is in Willits, Ca. The estimated flight time for a Sikorsky S-70 Firehawk
helicopter from Willits to Lake Pillsbury is approximately 8 to 10 minutes,

13
SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

depending on specific conditions and flight paths. CAL FIRE's helicopter attack
(Helitac) philosophy incorporates specific goals for air resources, enhancing their
effectiveness in wildfire management. Their number one goal is a rapid response.
Specifically, it is used to achieve a quick initial attack on wildfires, keeping most
fires at 10 acres or less. Helicopters can reach remote fires in approximately 20
minutes, allowing for timely intervention.
o The distance from Clear Lake to Lake Pillsbury is approximately 20 miles. Given
that the Sikorsky S-70 Firehawk has a cruise speed of around 150 to 160 knots
(approximately 173 to 184 mph), the estimated flight time for a Sikorsky S-70
Firehawk from Clear Lake to Lake Pillsbury is approximately 6 to 7 minutes,
depending on specific conditions and flight paths. Given the spacing between fire
stations, and the windy roads, the next fire engine to respond to a fire in the
surrounding areas adjacent to Lake Pillsbury will be 20+ minutes away. Rotary
wing and fixed wing aircraft play a pivotal roll in helping control the spread of a fire.
Helicopters can get water from many sources, sources as small as a swimming
pool. However, smaller water sources may only allow for one or two dips.
o Another issue with water sources for the fire service is cross-contamination. In
California, aircraft used for firefighting must adhere to strict guidelines to prevent
cross-contamination of water from different sources, such as lakes or reservoirs.
Firefighting aircraft are required to identify and use designated water sources that
have been approved for firefighting purposes. To prevent contamination, aircraft
must avoid collecting water from multiple sources in a single mission. This means
they should not dip from different lakes or reservoirs in one operation. For CAL
FIRE’s fixed wing resources, the CL-415 Super Scooper is utilized, and these
aircraft are able to scoop water from a larger water source. The scoopers response
time is a little slower than the Helicopters, but they can dump more water on a fire
than a helicopter. It would take about 20-25 minutes to fly from a nearby airbase
to wildfires adjacent to Lake Pillsbury. For fires north of Lake Pillsbury there are
fewer larger lakes and greater distances between fire stations.
o Removing Scott Dam, eventually leading to Lake Pillsbury ceasing to exist, would
increase fire behavior in the area due to the exposed lakebed. Invasive plant
species already are well established in the area that can contribute to erratic fire
behavior. Previous fires like the August Complex and the Mendocino Complex
have already burned an exceptionally sizable portion of the Mendocino National
Forest. Additionally, invasive brush and grass species will grow in these burn scars
and create a bigger problem for wildfire, and in return make wildfire difficult to
mitigate with ground and aerial resources. Ecosystems will be affected when taking
a water source from the area, which means drier fuel moisture content that can
increase fire behavior with certain types of fuel models. The largest fire in the State
of California was the Mendocino Complex Fire. Without the Lake Pillsbury water,
the potential exists for a similar situation. This makes Lake Pillsbury an important
resource for the fire service and its loss will have long-term adverse wildfire
suppression impacts.
 There are additional Wildfire Suppression-related adverse Impacts on infrastructure,
property, and human life, as noted below (these should be addressed by PG&E):
o Increased Wear on Aviation Equipment: Helicopters would need to fly an additional
40 miles to access water, leading to increased operational wear and tear on rotors,

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

engines, and other critical components. This could shorten equipment lifespan and
increase maintenance costs, reducing overall readiness.
o Strain on Fuel Infrastructure: The additional flight distance increases fuel
consumption, which could strain local aviation fuel supplies and necessitate more
frequent refueling, delaying firefighting operations.
o Delay in Other Emergency Responses: With helicopters occupied for longer
periods, there would be reduced availability for other critical missions, such as
evacuations or medical response.
o Delays in Fire Containment: The additional round-trip distance to collect water
translates to slower response times for suppressing fires, increasing the likelihood
of wildfires spreading. This could result in greater destruction of homes,
businesses, agricultural lands, and critical infrastructure (e.g., power lines, roads).
o Increased Costs of Fire Damage: Larger, uncontrolled wildfires typically lead to
greater property losses and more extensive rebuilding efforts, which can strain
local and state resources.
o Increased Risk to Residents: Delayed fire suppression increases the danger to
residents, especially in rural areas where evacuation routes are limited. Lives could
be lost or disrupted due to a lack of timely intervention.
o Helitac Crew Safety: Longer flight distances increase fatigue for Helitac crews,
raising the risk of accidents during firefighting operations. The additional flight time
also increases exposure to hazardous conditions, such as smoke, turbulence, and
heat.
o Health Impacts from Smoke: Slower containment of wildfires leads to prolonged
exposure to wildfire smoke for residents, exacerbating respiratory and
cardiovascular issues, particularly among vulnerable populations.
o Loss of Natural Resources: Delayed fire suppression can lead to the loss of
forests, watersheds, and wildlife habitats, which are critical for local ecosystems
and the area's economy.
o Economic Hardship: The destruction of property and infrastructure could result in
significant economic hardship for affected communities, including loss of jobs,
reduced tourism, and increased insurance premiums.
 The decommissioning project will require several road improvements to ensure safe
execution during the project and to maintain accessibility for emergency wildfire response,
recreation, and other purposes afterward. Below is a breakdown of the necessary road
improvements that PG&E will need to incorporate in future road improvements:
o Fire Access Road accessibility around Lake Pillsbury is a concern for emergency
response and must be upgraded to allow rapid emergency response. Roads
always pose concern for emergency vehicles due to the difficulty in turning fire
engines, if needed. Constructing or upgrading fire access roads with all-weather
surfaces will ensure year-round usability. Adding turnouts and passing lanes on
long, narrow roads will improve emergency vehicles safe passage.
o Encroaching vegetation will also need to be cleared from high priority areas to
reduce fire risk and improve visibility for emergency responders.

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

o Recreational access roadways post-decommissioning, to include trailhead and

parking access may be changed or require modifications to parking lots and
trailheads. Improvements may need to be made, including creating or improving
parking facilities and access points for hiking, fishing, and other activities, and
installing clear signage to direct visitors to new recreation areas.
o If the decommissioning affects current road alignments (e.g., roads become
submerged or rerouted due to reservoir changes), new road sections may need to
be built. Any unpaved or poorly maintained roads in the area must be upgraded to
meet CAL FIRE standards for emergency access. The decommissioning project
will require significant upgrades to roads and related infrastructure to ensure safety
during construction and maintain accessibility afterward. Improvements such as
road widening, weight-bearing capacity increases, emergency access
enhancements, erosion control, and vegetation management will be essential.
These upgrades will not only support the decommissioning project but also ensure
the long-term usability of the area for wildfire response, recreation, and other
community needs.
 The removal of Lake Pillsbury as part of the PG&E Scott Dam Decommissioning Project
raises valid concerns about wildfire spread, particularly the loss of the Lake’s role as a
barrier to prevent small fires from becoming larger events, according to United States
Forest Service and Lake Pillsbury Fire Protection District personnel. The lake has
frequently acted as a natural firebreak, slowing or stopping the spread of wildfires. Without
the lake, vegetation would replace the reservoir basin, potentially increasing fuel loads
and creating a continuous pathway for fire spread. Below is an analysis of the technical
considerations to address wildfire concerns and the feasibility of retaining or reconfiguring
the lake to meet both wildfire mitigation and seismic safety goals that must be considered
by PG&E:
o Vegetation Management: Implementing rigorous fuel reduction measures (e.g.,
controlled burns, mechanical thinning) in the lake basin and surrounding areas to
reduce fire risk.
o Establishing permanent firebreaks where the lake currently acts as a barrier.
o Strategic Water Storage: Constructing smaller reservoirs, ponds, or water tanks
within the region to provide accessible water for firefighting.
o Installing dry hydrants and ensuring sufficient water storage for aerial and ground
crews.
o Infrastructure Upgrades: Setting up permanent firefighting staging areas with water
access near the former lakebed.
o Enhanced Detection Systems: Installing advanced fire detection systems, such as
remote cameras, infrared sensors, and drones, to monitor for lightning-related
ignitions.

3.9 Recreation Resources

 PG&E is planning to remove the existing camping facilities. This would result in a
significant recreation impact. PG&E should reconsider the removal of existing recreation
facilities. To reduce recreation impacts, PG&E should include recreational elements in the
Restoration Plan they intend to develop. The plan should be developed to offset the loss
of recreational facilities, such as swimming opportunities, hiking, picnicking, off-road

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

vehicle paths, camping and fishing. This plan needs to be developed in coordination with
both USFS/Mendocino National Forest (MNF) staff and the County of Lake.
 PG&E is preparing a Restoration Plan – within this plan, PG&E should add elements that
offset the loss of recreational facilities, such as swimming opportunities, hiking, picnicking.
 The PG&E draft application and environmental reports need to address loss of revenue
generated by visitor usage and similar losses that will be experienced in the area.
 Recreation needs to be quantified as value revenue loss. PG&E should provide
compensation to the County of Lake for the loss of recreation. Other locations offering
similar lake-based recreational opportunities are a 45-minute to 2-hour drive from Lake
Pillsbury, and include Clear Lake, Lake Sonoma, and Lake Mendocino. PG&E has
provided no information regarding recreational activities, facilities, visitor usage, etc.
regarding these other facilities. PG&E should discuss the potential for overcrowding at
these other facilities due to closure of recreational facilities at Scott Dam.
 The Scott Dam Area includes Scott Dam, Lake Pillsbury, and the surrounding recreation
facilities.
 Recreation opportunities in the Project vicinity are concentrated around Lake Pillsbury,
which inundates land primarily owned by PG&E but is surrounded by public land managed
by the US Forest Service.
 Lake Pillsbury is the largest waterbody in the MNF and provides a variety of reservoir-
based recreation opportunities such as, boating, wind surfing, fishing, and swimming.
There are a variety of developed recreation facilities in the immediate area of Lake
Pillsbury, including family campgrounds, group campgrounds, and day-use opportunities.
 All Project recreation facilities (including campgrounds and day-use areas), ancillary
facilities, and associated access roads in the Scott Dam area would be removed and the
sites would be restored.
 Construction activities associated with removal of the recreation facilities and ancillary
features are anticipated to last for approximately 2 years in duration and would occur at
the same time as the dam removal construction activities.
 A Construction Recreation Plan should be developed and implemented that will include
public notification measures, such as announcements and postings of the Project
construction schedule and closure areas, and educational signage that informs
recreationists about Project activities.
 PG&E will also develop a Public Safety Plan that will include measures to address and
reduce potential safety risks to the public during construction.
 PG&E could reduce temporary recreation impacts by leaving recreational facilities within
the Project Area and developing a Recreation Plan to minimize recreational impacts.

3.10 Aesthetic Resources

 PG&E needs to incorporate the various proposed restoration activities to improve the
aesthetic aspects of the decommissioning project. This consideration needs to be
addressed within the NEPA and CEQA process.
 SLR recommends that PG&E include photo modelling/artist renderings of visual impacts
following dam removal. A photo rendering was included for the Non-Project Use of Project

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

Lands subsection of the application. Similar renderings should be provided for the Scott
Dam location.
 PG&E will need to prepare an ecosystem restoration plan that considers management of
invasive species, and reintroduction of native and endangered species, along with
management and stabilization of the lake sediments. Monitoring should be considered to
evaluate the progress of revegetation, and any needed adaptation until vegetation is
established in the areas affected by the Project.
 PG&E would need to properly address the restoration of all areas and items referenced in
their preliminary restoration plan to the landowners’ and the County’s agreement.
 PG&E does not describe in this section how the Scott Dam area recreation facilities would
be restored such as the campground, day-use areas, and associated roads and trails.
 Removing water bodies has a significant visual impact. Anything that is restored should
be visually appealing. Small ponds and hiking trails could be help offset these visual
impacts and should be included in a restoration plan.
 PG&E argues that no adverse effects to visual resources have been identified for Phase
2 of the Proposed Action. During Phase 2, visual resources will be impacted until final
restoration is implemented. PG&E should note this impact and propose offsets. PG&E
argues the overall impact would be temporary adverse effects during construction and
long-term benefits as the rivers return to natural conditions and vegetation recovers.
PG&E needs to provide a better justification for the offsets indicated with respect to the
aesthetic aspects of the decommissioning project over a sufficient timeframe to allow for
seed collection and responsible revegetation, as well as mitigation of invasive species.

3.11 Cultural Resources

 PG&E’s proposed Historic Properties Management Plan will need to be reviewed for
compliance and consistency with Federal and State environmental review requirements.

3.12 Tribal Resources

 PG&E’s proposed Tribal coordination will need to be reviewed for compliance and
meeting Federal and State environmental review requirements.

3.13 Socioeconomic Resources

 PG&E has not quantified Operation and Maintenance costs associated with areas that
will be restored, where sediments will be disposed of, and where dam debris will be
contained.
 PG&E states that the community way of life for residents surrounding Lake Pillsbury will
likely be adversely affected both during and post construction. PG&E should identify
proper compensation for current residents that may be impacted.
 PG&E states that river-based recreation, in the long term, may provide similar economic
opportunity to reservoir-based recreation. PG&E also provided a study that “estimated that
decommissioning of the Project would extend the rafting and kayak season on the Eel
River by approximately 6 weeks…”, which appears to be for a portion of the Eel River
below Cape Horn Dam, and not for the Scott Dam area. With the absence of road
infrastructure to access the river, any potential rafting and kayaking activity near Scott

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

Dam will be further reduced. Given that the loss of Lake Pillsbury will cause lost revenue
from reservoir-based recreation for the County of Lake, and that the potential increase in
river-based recreation may happen outside of County limits, PG&E will need to work with
the County to identify the potential revenue loss for the County caused by the change in
recreational activities from reservoir-based to river-based and conduct additional studies
to identify mitigation measures associated with recreational activities for the water shed.
 PG&E states that “for recreationists who prefer lake-based activities”, Lake Mendocino or
Clear Lake “can provide substitute recreation opportunities.” As many lake-based
recreationalists from higher population centers currently travel to Lake Pillsbury from the
west, most will likely go to Lake Mendocino instead. This would result in a loss of tourism
and revenue to the County of Lake. Furthermore, Lake Pillsbury appeals to recreationists
due to its remoteness, which these alternative lakes may not provide. PG&E has not
accounted for this revenue loss.
 PG&E also states that “potential adverse affects can be offset with restoration of
vegetation and site aesthetics (see the Restoration Plan) and with investment in river-
based recreation infrastructure by local businesses.” PG&E has not yet provided a
Restoration Plan and appears to assume that restoration will involve investment by local
communities. River based recreation infrastructure as part of the Restoration Plan should
be prepared and set up funded by PG&E.
 PG&E ties the hypothetical fish abundance to an increase in recreational activities by
stating that if “fish abundance in the Eel River were to improve in response to the Proposed
Action and return to natural conditions, then economic opportunity associated with
commercial and recreational fishing could also increase.” This statement should be
supported by additional studies to be performed to identify whether restoring the river is
going to lead to additional fishing and if this would overcome the loss of lake fishing at
Lake Pillsbury.
 The study identifies approximately 300 recreational homes and cabins surrounding Lake
Pillsbury. PG&E has not defined how the impact area was identified. It is not clear how
many other homes are in the surrounding hills that enjoy the aesthetics of the lake and
are used recreationally by driving to the lake from a few miles away to enjoy boating,
fishing, etc. A more detailed survey of the properties and of the people using the Lake
should be conducted, with impacts documented on a map.
 In Section 3.3.13.6 of the application - Local Government Finance, PG&E have identified
current revenue from property tax, lodging tax, sales tax and licenses, but have not
evaluated how the lodging tax, sales tax, and licenses will be affected long-term. PG&E
should consult with the County to obtain the correct tax information and incorporate it into
the analysis.
 In Section 3.3.13.5, Table 3.13.3 of the application, PG&E shows that the County of Lake
has a higher unemployment rate, poverty rate, and lower median income than the state
average. PG&E has failed to quantify the effect of dam removal on these key economic
indicators. These impacts need to be quantified, with mitigation measures identified and
implemented by PG&E.

3.14 Environmental Justice

 PG&E has concluded that this is not an Environmental Justice community by comparing
Lake County, Tract 1, Block Group 2 to the county average. PG&E should revise the

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

analysis to compare the census tract to a larger-scale reference community. At a

minimum, this should include the region impacted by the project or the State of California,
rather than county averages. This approach ensures a more comprehensive evaluation of
potential disproportionate impacts on this community.

3.15 Air Quality

 The construction plans proposed by PG&E should address emissions from construction
vehicles and other greenhouse gas aspects.
 Monitoring for airborne NOA and other asbestos will be required due to the presence of
serpentinite rock in project construction areas and potential building demolition.

3.16 Noise and Vibration

 The construction plans proposed by PG&E should address noise and vibration from
construction equipment and vehicles.

3.17 Traffic
 PG&E documented existing road infrastructure, transit and aviation facilities in the vicinity
of Scott Dam and Lake Pillsbury area. However, the impact on access road infrastructure
was limited to three access roads. PG&E should include all access roads and other
infrastructure to facilitate the future restoration and use of the facilities.
 Regarding impacts of dam removal, PG&E will need to prepare inundation maps with
respect to releases during dam drainage and removal, and evaluate the potential effects
on road infrastructure, including road easements, culverts, bridges and other utilities.
 Once these effects are sufficiently evaluated, road and other infrastructure improvements
deemed necessary to provide for consistent opportunity for ingress/egress by emergency
services (including United States Forest Service personnel) and residents of/visitors to the
area would need to be conducted prior to removal of Potter Valley Project Dams and
Equipment. The application notes “[sediment] deposition can reduce the capacity of the
river and floodways to transport water during periods of high rainfall, which can potentially
cause localized flooding in areas that were previously unaffected. These changes can
heighten the risk of flooding at downstream structures, such as bridges and road
crossings". A Sediment/Channel Monitoring and Response Plan is proposed to monitor
problematic levels and interventions.
 Roadwork improvements and modifications will be needed to accommodate the
anticipated increased construction traffic and heavy equipment movement on local roads
during the dam decommissioning. The general construction measures will include speed
limits and dust control. PG&E proposes to prepare a Construction Transportation
Management Plan and follow the General Construction Measures to mitigate
transportation network effects. The construction transportation plan needs to include non-
construction related traffic that is expected to be present in the vicinity of the Lake
Pillsbury.

3.18 Marine Resources

 Impacts to Marine Resources are outside of the scope of this review.

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SLR Comments on PG&E’s Draft Application for Surrender of License and February 21, 2025
Application for Non-Project Use of Project Lands dated January 2025 SLR Project No.: 102.021249.00001

3.19 Others
 PG&E will need to discuss the existing power grid in the area and provide mitigation
measures for any impacts on the power grid due to dam and lake removal. PG&E notes
that the project powerhouse has not generated power since May 2021, and the
decommissioning would permanently eliminate generation capabilities. The Draft
Application for Surrender of License does not explicitly state whether the vicinity of Lake
Pillsbury is connected to the electrical grid.

4.0 Closure
SLR appreciates the opportunity to support the County of Lake on this important project. Please
contact the undersigned if you have questions.
Regards,
SLR International Corporation

DRAFT DRAFT

Dharme Rathnayake, PE Maria E. Lorca, PG

Senior Principal Senior Geologist
[email protected] [email protected]

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