PG&E Project 2105 is a large “project” owned and operated by PG&E that includes several electrical power plants on the North Fork of the Feather River, including Lake Almanor in Plumas County. The project of putting power plants on this portion of the Feather River began in 1910, resulting in the entire stretch of the river and lakes in this region making up a large, highly managed, power generation system. The Upper North Fork Feather River Hydroelectric Project (UNFFR Project) is located on the North Fork Feather River in Plumas County. It consists of three reservoirs with dams: Lake Almanor, Butt Valley reservoir and Belden forebay; five powerhouses; tunnels and penstocks connecting the reservoirs to the powerhouses; and transmission, operation and maintenance, and access facilities. The five powerhouses include eight hydroelectric generating units with a total nameplate capacity of 362.3 megawatts (MW).

This project came up for re-licensing in 2004, but has been stalled since that time because of a new requirement imposed by the State Water Resource Control Board (SWRCB) to draw cold water from Lake Almanor in the hopes of cooling a stretch of the Feather River located about 20 miles downstream that has been deemed to be too warm to support the native rainbow trout population. The average temperature of the river in some locations gets to approximately 23°C during the months of July and August. EPA regulations state that water temperatures above 20°C are dangerous for cold water fish, including rainbow trout.

There are many problems with those regulations, not the least of which is that they don’t actually conform with science. It turns out that for rainbow trout to achieve maximum growth rates they require a varying thermal environment shifting between about 16° C to 24°C on a daily basis. 20°C is NOT an absolute limit as it is treated in the regulations. The conditions in the UNFFR are quite varied, with deep cold pools provided by underground springs, and many small tributaries feeding the river that provide spawning and brood waters at the “nursery” for rainbow trout. The 20°C limit was set decades ago before enough studies were performed to have a good idea of the conditions necessary for a healthy fish population. It was just a guess, that was never intended to be the final answer, it was more or less just a place-holder until better information became available. Better information has become available, but the regulations have not been changed.

It is clear that if there is a problem with the rainbow trout in the river, it is almost certainly not because the average river temperature exceeds 20°C for a couple of months out of the year. The native trout are well suited to the environment in the river and congregate around the cold pools when necessary. The fish spawn and remain in the tributaries, not in the main body of the river. Decreasing the river temperature by dumping more cold water into it from Lake Almanor will have no impact on the critical spawning habitat in the tributaries. In fact, there is no evidence that increasing the water temperature will have any beneficial impact on the cold fish populations, with the available science pointing strongly to the conclusion that water temperatures are not a danger to the fish.

However, drawing cold water from Lake Almanor is a known high risk option. In fact, the SWRCB acknowledges that their plan will result in large scale fish kills to the large and robust native rainbow trout population in the lake. Their solution to these fish kills is to annually plants tens of thousands of hatchery raised trout to maintain a large enough population to satisfy the sport fishermen. They intend to plant “catchable” sized fish since they know that the environment will be unable to support the fish once they draw out the pools of cold water at the bottom of the lake.

In addition to the problem of killing the rainbow trout that current live in the cold pools at the bottom of the lake, they expect the overall water temperature of the lake to increase due to the removal of the cold water. However, they don’t know how much warmer the lake will become because they have not studied that outcome – they are focused on river temperatures, not lake temperatures. There appears to be a real, but unquantified, risk of the lake warming sufficiently to induce algae blooms that could result in a feedback loop of more algae resulting in darker water, resulting in more solar induced warming, creating more algae – etc. That would be a terrible thing to happen to the beautiful, clear waters of the lake.

An additional problem with their proposed cold water withdrawl plan is that it is in addition to the water that is currently needed for hydroelectric production and irrigation. Currently the lake is operated in a way that provides adequate flow for a massive amount of sustainable hydroelectric power production, irrigation needs in the Sacramento Valley, and maintaining a healthy ecosystem in the river – while keeping lake levels relative constant in support of other needs such as recreation and maintaining beach front for the thousands of homes and cottages surrounding the lake. Removing large amounts of additional cold water will probably result in a significant disruption to the lake levels, threatening the human uses, and also the wildlife (such as nesting grebes) that have come to depend upon the current lake levels.

I think this entire thing is a travesty with some people whose job it is to regulate things doing so without stepping back and including the entire system under study. They are focused on a single outdated target number rather than the health of the ecosystem that the number is supposed to represent. I am totally in favor of regulations, and understand that they are necessary in order to make sure that projects “do the right thing.” However, the regulations need to be implemented with a large dollop of sound science. The law being enforced specifies that reasonable measures be taken. To me, that means that the solutions to the problem do not cause more problems. It is not appropriate to move the problem from one place to another, nor is it appropriate to mandate actions just because of the existence of an unsupported number. I think the fact that the risk has been flagged as “at risk” because of water temperatures is a clue that perhaps there might be a problem. That means that it is probably worthwhile to study the problem to see if the fish are actually at risk, or actually being harmed. That study should include the other possible sources of harm that were identified along with water temperatures, include lack of proper gravel in stream beds, lack of adequate access to tributaries, the presence of introduced predatory fish, and others.

In addition to all of these problems, the studies projecting the amount of cooling that could result from these actions were performed in 2000, using engineering models that were based upon past historical data using what are now out-of-date computer models. The newer models, using current projections of water cooling with global warming indicate that the impact of the cold water releases with be on the order of 0.2°C, or less. That means that the water will be drawn from the lake but will have essentially zero impact on the temperatures of the river water. There will be a lot of costs, a lot of risks to the lake, and no resulting positive outcomes. The problem is that once a regulatory “machine” gets started, and regulators have made their pronouncements, it is extremely difficult to stop the train before the train wreck happens. The machine has a lot of momentum and just keeps rolling along.