FRIENDS OF THE RIVER

915 20TH Street, Sacramento, CA 95691

916-442-3155 FAX: 916-442-3396 www.friendsoftheriver.org

January 27, 2005

Ms. Magalie Roman Salas

Secretary

Federal Energy Regulatory Commission

888 First Street, NE

Washington, D.C. 20426

RE: Comments on Scoping Document 1 and Pacific Gas and Electric's Pre-
Application Document for the DeSabla-Centerville Hydroelectric Project (FERC Project 803)

Dear Ms. Salas,

Friends of the River appreciates the opportunity to provide comments on Scoping Document 1 and Pacific Gas and Electric's (PG&E) Pre-Application Document for the DeSabla-Centerville Hydroelectric Project (FERC Project 803). Our comments will first address Scoping Document 1 before addressing the Pre-Application Document and Pacific Gas and Electric's proposed study plans.

Comments on Scoping Document 1

Process- In general, Friends of the River (FOR) is pleased that FERC has decided to perform scoping earlier in the ILP than in other relicensing processes. We think the PAD, as prepared by PG&E, is a wonderful tool for pulling together existing information for use in scoping. However, FOR is concerned that scoping has been done too early and that the PAD does not provide adequate information to determine which alternatives should be evaluated in FERC's NEPA analysis.

Ordinarily, in the ALP and TLP processes, FERC has waited to do its scoping until some of the studies have been completed and data gaps have been filled. This has allowed both FERC and stakeholders to make informed decisions, based on science, about which alternatives need to be evaluated in the NEPA analysis. The PAD, though providing a significant amount of information, does not provide enough information to make an informed decision about which alternatives should be evaluated in the NEPA analysis. Despite the information pulled together by PG&E in the PAD, data gaps still exist. To fill those data gaps, PG&E has proposed studies that will provide additional information to inform decision making about the project.

FOR feels that this additional data will be helpful in making an informed decision about which alternatives need to be evaluated in the NEPA analysis. We hope that FERC will consider the data from PG&E's proposed studies and stakeholder comments when they become available and be open to amending their NEPA alternatives as necessary based on the new information to be provided by the studies.

Participation of FERC staff- FOR is pleased that FERC staff has been so involved in the ILP thus far. We recognize that in the new ILP process, FERC staff walks a fine line between being decision makers and participants. FOR feels that FERC staff have conducted themselves with a high degree of professionalism and we find their participation to be an asset.

Production of an EA vs. an EIS- FERC's regulations provide that an EIS must be completed for major federal actions that significantly affect the quality of the human environment. 18 CFR 380.6(b) The DeSabla-Centerville project continues to impact those who live on and around Butte Creek. The project has temperature and water quality impacts that affect the creek's aesthetics and may have contributed to large fish kills on Butte Creek. The fisheries of Butte Creek have been severely impacted in recent years. An EIS would provide a more in-depth analysis of the impacts of the project on the fisheries of Butte Creek and would allow stakeholders and FERC to make a well-
informed decision about how the project should be managed to reduce its impacts on the Butte Creek ecosystem.

Butte Creek supports one of the largest runs of threatened spring run Chinook salmon in California's Central Valley. It also supports threatened steelhead. NEPA guidelines require an EIS for a project that may result in significant impacts to ESA listed species and their habitat.

Additionally, the project attracts recreationists, who can create conflicts with private land owners, increase management problems (litter clean-up, trash disposal), and potentially stress threatened salmon that hold in deep pools in the creek during the peak summer recreation season. For these reasons, FOR feels that the DeSabla-Centerville project has significant effects on the human environment of Butte Creek and we ask FERC to consider performing an EIS.

In addition to impacts to the human environment, the Bureau of Land Management (Redding Field Office) has determined a 14.2 mile segment of Butte Creek affected by the DeSabla-Centerville project to be eligible for National Wild & Scenic River status, in recognition of its outstandingly remarkable scenic, recreational, historical/cultural, and geological values. Federal guidelines require federal agencies to protect and enhance the free flowing character and outstanding values of eligible streams until a final decision is made concerning the suitability of designation by Congress. Thus, the alternatives evaluated in FERC's NEPA document should consider ways to protect and enhance the outstandingly remarkable qualities of Butte Creek as part of the relicensing process.

Comments on the Pre-Application Document

In general, Friends of the River thinks that PG&E did a good job of putting together a comprehensive PAD. We feel the extensive information and proposed studies provided in the PAD have contributed greatly to stakeholder knowledge and the efficiency of the DeSabla-Centerville ILP. We sincerely hope that FERC will use PG&E's PAD as the standard to be achieved in other ILPs.

The remainder of our comments on the PAD will focus on study plans and specific studies proposed by PG&E.

Monitoring and Development of a Water Temperature Model- Study plan 6.3.2-4 states the goal of this study is to: 1) provide monitoring sufficient to assess project related water temperature relicensing issues; and 2) develop a stream temperature model that can be used to evaluate the range of operational alternatives for managing stream temperatures in lower Butte Creek during summer months (June through September)… for the benefit of spring run Chinook salmon. Friends of the River concurs with these goals and asserts that they would be better achieved if PG&E considered adding an evaluation of water temperature in the West Branch Feather River (WBFR) in addition to the modeling proposed in Butte Creek. We are supportive of requests from the State Water Resources Control Board (SWRCB) and the Forest Service (USFS) to model the WBFR below Hendricks Diversion Dam. Specifically, we request that such modeling effort examine summer lethal temperatures for aquatic species. In light of recent extremely hot water temperatures and fish kills in Butte Creek, FOR considers it imperative that studies done in this relicensing provide an adequate understanding of water temperatures in both Butte Creek and the WBFR and how the transfer of water from WBFR to Butte Creek effects water temperatures in Butte Creek.

Likewise, FOR is supportive of the request from Friends of Butte Creek (FBC) that PG&E consider including the two CDFG temperature monitors below Centerville Powerhouse in its study. FOR agrees with FBC that this data may be useful in determining the affect of the DeSabla-Centerville project on water temperatures in Butte Creek when there are no diversions from the WBFR. Again, FOR considers it imperative that the studies yield an understanding of temperatures in each component part of the project (i.e. WBFR and Butte Creek) and how those parts and the project itself interact and impact the temperatures in Butte Creek.

Instream Flow Study- FOR would like PG&E to consider incorporating some different methodology into its instream flow study. We are not certain of the feasibility of performing an instream flow study similar to what PG&E performed on the Pit 3,4,5 relicensing on Butte Creek and WBFR, but FOR found the methods used there to yield lots of good data on how different flows affect stream and riparian habitat for fish and amphibians. Specifically, in addition to the IFIM and PHABSIM methods proposed, FOR would like PG&E to consider using the habitat mapping method used on the Pit 3,4,5 relicensing or other appropriate mapping method. It is our understanding that in addition to IFIM and PHABSIM, fly-overs of the Pit River were done and photos were taken showing the river at different flows. These photos provided a valuable "reality check" on the models and the data provided could be used to evaluate habitat for different aquatic and amphibian species. Again, FOR is not certain of the feasibility of this approach on Butte Creek, but we found this valuable on the Pit 3,4,5 relicensing and would like PG&E to consider if a similar approach would be valuable for the DeSabla-Centerville relicensing.

Additionally, FOR is supportive of the USFS's request that a technical subcommittee be formed to discuss the details of this study plan. Likewise, we commend PG&E for agreeing to do so and moving quickly to establish the subgroup set-up a meeting. FOR feels it is important that the study plan methodology and other details be developed collaboratively and that subcommittee discussions focus on selecting the methodology that will yield the most relevant information for decisionmaking.

Benthic Macroinvertebrates Survey- In the December 28, 2004 version of the study plan, PG&E proposes to conduct BMI sampling in fall 2005 to establish baseline data for project-affected stream reaches. However, in the PAD section 6.3.3, under its description of the proposed BMI study, PG&E proposes sampling for up to 2 years. Friends of the River feels strongly that the BMI study should collect data for at least two field seasons to establish baseline data. Macroinvertebrate populations are highly variable from year to year and we assert that one year of data is simply not enough to develop an adequate understanding of baseline conditions.

Further, FOR would like to request that PG&E distribute to stakeholders results from the fall 2005 sampling (when available) to allow stakeholders and PG&E to evaluate if changes need to be made to sampling method or location.

Again, thank you for the opportunity to comment on the Scoping Document 1 and the Pre-Application Document. If you have any questions, please feel free to contact me at (916) 442-3155 ext. 223.

Sincerely,

/s/

Kelly L. Catlett

Policy Advocate

Friends of the River