Letter from Russian and Eel River communities asks federal agencies to review "devastating" environmental impact of Potter Valley dam removals
Over 700 farmers, ranchers, tribal leaders, community leaders, and residents signed a letter opposing proposed dam removals in Potter Valley.
More than 700 community leaders, farmers, ranchers, firefighters, and residents of the Russian and Eel River communities have signed a letter to federal agency heads, expressing deep concern over the proposed removal of two dams in Potter Valley, California.
The letter outlines a host of alleged legal and regulatory failures with Pacific Gas & Electric’s (PG&E) decommissioning plan, and urges federal officials to reject dam removal in favor of a “transparent, science-driven process” that includes “robust stakeholder consultation.”
The full text of the letter, dated September 29, 2025, is published below:
Secretaries Rollins, Hegseth, Lutnick, Burgum, Wright, Administrator Zeldin, and Chairs Rosner and Scarlett—
As tribal leaders, farmers, ranchers, and residents of the Russian and Eel River communities, we write today to express grave concerns regarding Pacific Gas & Electric Company’s (PG&E) proposed surrender and decommissioning plan for the Potter Valley Project (FERC Project No. 77), submitted on July 25, 2025.
For over a century, the Potter Valley Project has provided reliable electricity and water to over 750,000 residents across four counties from Potter Valley to Marin County, and its Lake Pillsbury even helped extinguish two of the three largest fires in California history. Specifically, the proposed dam removals of the Potter Valley Projects’ Cape Horn and Scott Dams threaten our region’s water supply, economic stability, and even our environment. While we support reasonable environmental permitting, preserving critical water infrastructure is existential. We therefore urge a full and thorough review of the decommissioning’s impacts, especially with respect to dam removal in California.
PG&E’s plan identifies “unavoidable adverse effects” from decommissioning. However, the process lacks transparency, meaningful stakeholder engagement, and adequate mitigation plans. Despite PG&E’s claims of consulting resource agencies and tribes, several tribes including the Potter Valley Tribe were removed from discussions or not consulted, and it appears other agencies tasked with protecting Russian and Eel River resources were similarly excluded.
Hydrological and Environmental Impacts
Decommissioning will halt summertime diversions to the East Branch Russian River, devastating the Russian River watershed’s water supply, destabilizing flow regimes, and raising water temperatures during critical spring and summer months. Dam removal will release turbidity, sediment, and nutrients, degrading water quality, reducing dissolved oxygen, and fostering algal blooms. These impacts will extend downstream through the Eel River, its estuary, and the near-shore ocean, with effects lasting years.
Aquatic species, including Endangered Species Act (ESA)-listed Chinook salmon, steelhead, Pacific Lamprey, Foothill Yellow-Legged Frog, Pond Turtle, Western Pearl Shell Mussels, and Green Sturgeon, face immediate risks from sediment-driven habitat loss, non-native fish releases, and direct mortality. The Russian River will lose habitat for special-status amphibians and mussels, undermining ecological protections. These species hold cultural significance to several area tribes, amplifying the need for careful consideration.
Botanical resources, including eelgrass, riparian, and wetland habitats, will be disrupted. Wildlife such as Bald Eagles, Ospreys, Northern Spotted Owls, Waterfowl, Tricolored Blackbirds, and Tule Elk will face habitat loss, noise disturbance, and displacement. Groundwater wells, downstream infrastructure, and water intakes are also at risk.
Wildfire Fighting Concerns
The reservoirs of the Potter Valley Project are critical for wildfire suppression in the region, providing accessible water for firefighting efforts. Their removal would severely hamper the ability to combat wildfires, increasing risks to lives, property, and ecosystems. We request immediate consultation with the United States Forest Service (FS) to assess the reservoirs’ role in wildfire management and to ensure that decommissioning does not compromise regional fire suppression capabilities.
Human and Cultural Impacts
Decommissioning will eliminate recreational opportunities at Lake Pillsbury, reduce agricultural productivity, and alter the character and economy of the Eel and Russian River watershed communities. Tribal cultural resources face significant impacts without proper consultation, violating legal requirements. The rushed process disregards stakeholders who will bear the consequences, trading one set of environmental harms for another while imposing severe costs on people, wildlife, and ecosystems.
Legal and Regulatory Failures
Clean Water Act (Sections 401 and 404): PG&E has not demonstrated how communities will be compensated for unavoidable impacts or ensured water quality, particularly for Lake Mendocino, affected by upstream dam removal. A U.S. Army Corps of Engineers (USACE) permit and state water quality certification are required.
Endangered Species Act: FERC must conduct a biological assessment and consult with the Services to mitigate harm to listed species. PG&E’s admission of “direct loss” of aquatic species, including 168.5 miles of the Eel River below Scott Dam, necessitates significant modifications.
Magnuson-Stevens Act: Impacts on essential fish habitat require a FERC and National Marine Fisheries Service (NMFS) consultation.
National Environmental Policy Act (NEPA): The project’s significant environmental impacts require an Environmental Impact Statement (EIS) to evaluate water quality, fisheries, wetlands, wildlife, sediment transport, and community impacts. A “no-action” alternative must be considered as the least damaging option.
National Historic Preservation Act (Section 106): PG&E has not assessed impacts on historic sites. The Area of Potential Effects (APE) remains undefined, risking damage to California Coast Ranges’ cultural resources.
Coastal Zone Management Act: The plan violates California’s Coastal Management Program by harming marine resources, water quality, and sensitive habitats.
Federal Dam Safety Guidelines: PG&E lacks a comprehensive risk assessment and Emergency Action Plan (EAP) for decommissioning, ignoring risks like uncontrolled water flow, sediment release, and slope instability.
Department of Energy and Clean Hydropower Concerns: The decommissioning eliminates a reliable source of clean hydropower, undermining national energy security goals. The Potter Valley Project’s renewable energy contribution supports grid stability. We urge consultation with the Department of Energy to evaluate the loss of this critical energy resource.
Resource Conservation and Recovery Act (RCRA): PG&E has not assessed accumulated sediment for toxic contaminants. If hazardous, strict RCRA regulations and potential CERCLA cleanup apply.
PG&E’s decommissioning plan is inadequate, non-compliant with federal law, and dismissive of community and environmental consequences. We urge the Commission and cooperating agencies to reject the plan in its current form and facilitate a transparent, science-driven process that includes robust stakeholder consultation. Numerous tribes, along with communities of both the Eel and Russian River watershed, have relied on this project for generations; we should not bear the costs of a flawed plan. We call on you to halt this reckless action until a lawful, transparent, and alternate path is established.
Thank you for your attention to this critical matter.
“David vs. Goliath” battle for region’s water
Constructed more than 100 years ago, the Potter Valley Project was originally designed to generate hydropower, but has become even more essential for its water storage. It includes two dams and a diversion tunnel that channels water from the Eel River during the high-flow winter months to Lake Pillsbury for storage. From there, the water is released back into both the Eel and Russian Rivers during the dry summer season. Over time, this water allowed the region to grow into a thriving agricultural community.
After several lawsuits from environmental groups claiming the dams harm fish populations, and subsequent water cuts from the federal government, PG&E announced plans in 2023 to decommission the project and remove the dams, cutting a vital water source for over 600,000 citizens. The effort has been supported by various state politicians including Governor Gavin Newsom, who told the Associated Press in 2024 that Potter Valley dam removals are central to his strategy for restoring salmon populations.
The Sept. 29 letter marks the latest effort by local communities to protect their water source in what is taking shape as a David-versus-Goliath battle between rural, agricultural stakeholders and powerful political and corporate forces.
Thank you for your leadership on this Keeley!
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