The U.S. Department of the Interior is asking federal regulators to stop PG&E from tearing out Scott Dam and Cape Horn Dam—at least until a replacement water supply is up and running.
In a nine-page filing, Interior told the Federal Energy Regulatory Commission (FERC) that the proposed replacement, the New Eel-Russian Facility (NERF), “is not in place, is not funded for construction, is not sized or timed to meet irrigation-season demand, and has no demonstrated place to store the winter water it would divert.”
“It should not issue a surrender order that allows Scott Dam and Cape Horn Dam to come down on a promise,” the department wrote.
Interior says NERF an inadequate replacement
Interior says NERF is an inadequate solution because it is not timed to supply water when needed, its construction is not funded, and even if it is built, the water deliveries will be insufficient and mistimed.
“The Department does contest any environmental review that treats the dismantling of working water infrastructure as the main event and the replacement of that water as a later, local problem,” the department writes.
Timing: Interior points out that “NERF will not be online before the dams come out.” Estimates from PG&E, Sonoma Water, and the Eel-Russian Project Authority (ERPA) put completion at roughly 2035. NERF’s construction is to happen “simultaneously” with removal of Cape Horn Dam, but Interior says this “is not a continuity plan.” NERF still needs a host of permits and reviews. “‘Simultaneous’ is a hope,” the department writes.
Cost: NERF’s construction is not funded. Capital cost estimates were $50 million as of March 2025. Russian River users will pay an additional $7 million to $12 million every year in operations and maintenance, $1 million a year to the Round Valley Indian Tribes, and $750,000 to $1 million a year into an Eel River restoration fund.
“The proposed action shifts cost and risk onto the people who can least absorb a supply interruption,” Interior writes. “Construction of NERF is unfunded. Operations, maintenance, tribal payments, and restoration assessments will be billed to Russian River users. Potter Valley growers are being told, in Sonoma Water’s 2025 reliability study, that closing a 9,000 acre-foot summer gap would require new in-valley ponds, new groundwater development, and demand reductions of 20 to 30 percent. Those projects are not built and not permitted. Farmers would pay for them while also paying for NERF. Landowners around Lake Pillsbury face the separate loss of a reservoir, recreation economy, and groundwater support.”
The department takes issue with PG&E. leaving communities with this burden.
“None of that is a free byproduct of ‘decommissioning an uneconomic power project.’ It is a transfer of stranded-asset costs from a utility that has chosen to walk away onto farms, cities, and rural landowners.”
Volume and Season: Interior says the water NERF would produce is “not adequate in volume or in season.” According to diversion rules, water deliveries will be concentrated in winter and spring and diminished in summer, when needed most. In June, July, and August 2025, transfers were 7,135, 7,603, and 3,017 acre-feet. Using Sonoma Water’s own modeling, NERF transfers for the same period would have been 1,070, 243, and zero.
Storage: The department also claims “there is not adequate storage to make NERF water useful—about 123,695 acre-feet diverted, but storage for only 57,522 acre-feet. Proponents are pushing plans to raise Coyote Valley Dam, expanding storage opportunities in Lake Mendocino—the principle source of water for Sonoma County, serving about 600,000 people. But Interior says the Army Corps of Engineers, which owns and operates Lake Mendocino, has not been consulted. And according to Inland Water and Power Commission analyses, without deliveries from the Potter Valley Project, Lake Mendocino will fail to meet demands in eight years out of 10 and go dry in two of those eight. Raising the dam is pointless without water.
What Interior is asking FERC to do
Interior is asking regulators to consider alternatives, including keeping Scott Dam in place “if a capable operator is identified.” It’s also asking that FERC bring the Fish and Wildlife Service and the Corps into the review process as cooperating agencies.
And they want a full environmental impact statement.
“Given the intensity of public controversy, the scale of the proposed demolition, the irreversible loss of Lake Pillsbury storage, and the unproven character of the proposed replacement supply, the Department requests that the Commission prepare an environmental impact statement, not an environmental assessment,” the department writes.
The department lists several conditions it expects in any surrender order, including a full stop on any dam removal until NERF is operating and a FERC finding, backed by a written Corps assessment, that water storage is adequate.
FERC’s deadline expired about five hours before Interior submitted its comments. The department filed a separate motion asking FERC to accept its late entry, citing “unforeseen and unavoidable impediments” to coordinating “amongst multiple agencies with direct jurisdiction.” FERC had not ruled on Interior’s request as of publication.
The letter is signed by Laura Fleming, deputy director of Interior’s Office of Environmental Policy and Compliance.
Interior aligns with Department of Agriculture
It’s a welcome signal of federal support for a community on the verge of losing critical water infrastructure, that has struggled to receive an audience with most local lawmakers.
Congressman Jared Huffman told FERC in a 2022 letter that dam removals were an opportunity for “environmental justice” and should be executed “expeditiously.”
He mocked Agriculture Secretary Brooke Rollins—the leading cabinet-level champion for the 750,000 largely rural water users who stand to lose their water, including hundreds of farms and ranches. Huffman told The Mendocino Voice in June 2026 Rollins is “politically freelancing” and “apparently without very much to back her up.”
Interior says its view is “consistent with the position the Secretary of Agriculture has already placed on this docket,” namely that “the United States should not accept surrender” of Potter Valley Project dams unless “water-supply deficiencies” are remedied.
“Water supply for farms and communities is not a secondary amenity of this proceeding,” Interior writes. “It is a direct effect on the human environment under the National Environmental Policy Act. The Commission should treat it as such.”
The letter notes that both Rollins and Interior Secretary Doug Burgum met with PG&E and potential dam buyers in June 2026.
This writer would say not to count on FERC to do the “right” thing which is a complete review of the surrender demand by PG&E and stop the current dam removal process. When Congressman Huffman say this will be “environmental justice” one wonders if he is mentally ill. Or simply a pathological liar. What no one seems to understand is that once the dams are gone the environmental impacts are “unknown.” Consulting engineers and maybe the FERC ERO out of San Francisco have done some studies on the dam and reservoir structurally, but they have no idea what will happen when the dams are gone and Mother Nature takes over. If a sitting Congressman thinks harming 750,000 American citizens is “environmental justice” then he needs to hauled off to a rubber room for a good long while. What he is really saying is the big money on Nob Hill is all over this, fly fishing for me, drought for thee. Or, the Native American nation which stands to gain financially, supposedly are all in line behind Huffman. Let this writer tell you what happens when Native American Nations get windfall money. The tribal councils, (at best a very dysfunctional extended family having a bad thanksgiving dinner party) will take the money and then take to fight’n. Huffman is unconcerned with the little people, the little people must pay for their original sin, and wash him clear and clean of any sin, since he is doing Stalin’s work. Show me the man, I will show you the crime. American’s need to wake up and realize this has nothing to do with environmental science, rather a plan to destroy a way of life and run people out of the two counties. The people like Huffman or Newsom never count on the notion that people will simply get a moving van and leave the state. At some point the Ritchy Rich will find themselves in a 90% tax bracket and wonder why their fois gras and Napa Valley wines are so expensive. Then they will home. Hey if Florida and a $35 million dollar home on the ocean is good enough for Nancy Pelosi, then it will be good enough for the Ritchy Rich. Both Agriculture and Interior need to move to sue and litigate PG&E from now until the cows come home, or Donald Trump’s 2nd term ends, which ever comes first. The People need to stand up to this bunch. If the Canadian First Nation Haida Gawaii could strap themselves to the SItka Spruce in the Queen Charlotte Islands in British Columbia and stop logging operations for generations, then the locals can camp out on the dams and stop the five fly fishermen from Nob Hill from fishing for a couple of generations, and preserve their rural way of life.
Keely,
This is quite frustrating. We are not interested in the impacts AFTER the dam is down. We want FERC to stop the dam from coming down. Once it is down the damage is down and our community is destroyed. Water will not be replaced, that is what the dam is there for in the first place. Our family and thousands of others will lose our lakeside homes and farms and businesses will be destroyed. FERC needs to STOP the decommission, not figure out how to manufacture a report that says there will be enough water. Without the dam, there will be no water. Tell anyone to look at the Eel above the dam in the summer. It is a desert not a river. Fires will come, that is a fact (look at he Lucas fir last month), and property and lives will be lost without that water. Water is life and without the dam there is no water and no life. There were less than 300 salmon counted at Van Arsdale last year and there were a lot more than 300 letters from selfish fly fisherman pretty much saying that is all they care about is catching and eating a salmon. Even if it costs peoples lives and livelihoods to be destroyed in the process. You really want to protect the fish. Leave the dam and restrict the fly fishing and all forms of salmon fishing in the Eel and let it recover. Then the people in Arcata and Eureka can work on restoration of the existing 200 miles of river and there will still be water in it. There are hundreds and hundreds of hours of work that can help restore that beautiful river and the damage time and people have done to it over the years. But, if that Dam comes down there sure isn't going to be any water in there in the summer. We don't need studys showing how much water there will be AFTER the dam is down. We need someone in authority to realize the region of 95469 and beyond needs this water! Desperately! Lives and property are at risk!