The South Yuba River Citizens League (SYRCL) and a coalition of local and national conservation organizations once again filed formal comments with the Federal Energy Regulatory Commission (FERC) regarding Archon Energy’s proposal to build a 3-megawatt facility at Daguerre Point Dam on the lower Yuba River. These comments, filed on January 3 by the Foothills Water Network, are a critical response to a draft study plan that Archon filed with FERC in November.
A variety of studies will be necessary for Archon to complete their application to FERC. SYRCL, the Foothills Water Network and four state and federal resource agencies provided comments to FERC in early 2013 describing study needs. Archon’s draft study plan represents an attempt to address study needs, including effects of the project on salmon, steelhead and sturgeon. Specific studies would focus on upstream migrating fish, downstream migrating fish, direct mortality from the turbines and predation on juvenile salmonids near the dam.
“Archon’s draft study plan is inadequate in detail, scope and process,” said SYRCL Science Director Gary Reedy. “Necessary studies would require years for permitting and data collection, yet the draft study plan suggests that it can all be accomplished within a year despite the proponent not sufficiently coordinating with existing research and regulatory process on the lower Yuba River.” Furthermore, says Reedy, “the design details of the proposed project are still lacking, limiting the ability to design studies as well as assess potential impacts.” Additionally, the FWN comments point out the absence of studies on how the project may impact water quality and recreation.
FERC also received comments on Archon’s draft study plan from the State Water Resources Control Board which would have final certification authority for any project licensed by FERC. The State Water Board comments were similar to those by FWN and cited portions of the Federal Power Act in making the point that the project proponent should complete all necessary studies before submission of a draft license application, the next formal step for Archon in their process with FERC. For more background on this proposed project, see the Daguerre Dam Hydropower Project page.
In addition to SYRCL, the Foothills Water Network’s comment letter was signed by American Rivers, American Whitewater, California Sportfishing Protection Alliance, Gold Country Fly Fishers, Northern California Federation of Fly Fishers, the Sierra Club – Mother Lode Chapter, and Trout Unlimited.