CSPA
San Gorgonio Creek
San Gorgonio Nos. 1 & 2 FERC Project No. 344
Subject: San Gorgonio Creek - FERC
Date: Fri, 24 Jul 1998 10:39:35 +0000
From: BOB BAIOCCHI <cspa@psln.com>
Organization: CSPA
To: CSPA email distribution
United States of America
Before the Federal Energy Regulatory Commission
San Gorgonio Nos. 1 & 2
FERC Project No. 344
Southern California Edison Company, Licensee
San Gorgonio Creek Watershed
San Bernardino County, Within the San Bernardino National Forest, State
of California
In the Matter of Notice of Intent to File Application for New License
Notice of Intent to File Motion to Intervene by the
California Sportfishing Protection Alliance
1. In accordance with the Commission's rules of procedures the
California Sportfishing Protection Alliance (hereinafter known as
"CSPA") propose to file a motion to intervene when the application for
new license for the above mentioned project is noticed by the
Commission.
2. Place the CSPA on the FERC mailing list for all notices and
submittals in this matter. Also, all FERC notices should include a
service list.
3. The expiration date for the original license is April 26, 2003. The
licensee for FERC Project No. 344 is the Southern California Edison
Company. The agent and the mailing address is shown below in the service
list.
4. The project consist of two (2) diversion dams, concrete-lined canals,
two (2) water tanks, two (2) forebays, two (2) penstocks, two (2)
powerhouses with a total installed capacity of 2,440 kilowatts, two (2)
switchyards, and a transmission line.
5. We request the Commission to require the licensee to provide the CSPA
with a copy of the application for new license, including the
environmental studies.
6. We request the Commission to require the licensee to conduct the
following studies:
(a) San Gorgonio Creek - fishery studies and surveys (all fish species
and their habitat - life history - environmental requirements -
pre-project and post- project condition of the fish and other aquatic
species);
(b) San Gorgonio Creek - environmental instreamflow studies which
pertain to the fish and invertebrate species and their habitat,
riparian habitat, and water quality;
(c) Forebays - fish and invertebrate species studies (all species -
minimum pool requirements);
(d) San Gorgonio Creek - invertebrate studies (all species and their
habitat);
(e) San Gorgonio Creek - water quality studies (sediment loads - water
temperature [cold water species];
(f) San Gorgonio Creek and Forebays - sediment removal studies
(sluicing should be prohibited to protect water quality);
(g) All Diversions - screening studies (entrainment - all species -
diversions must be screened);
(h) Wildlife Studies - all species and their habitat - project caused
impacts and alterations - loss of habitat;
(i) Hydrology Studies - pre-project and post project periods -
condition of existing gauging devices;
(j) Water Rights - Disclosure of SEC's water rights, i.e. amount of
water diverted (af-cfs) - season of use, purposes of use - places of
use, validity of rights;
(k) Compliance Record - FERC mandatory minimum daily flow requirements
and other terms and conditions of FERC license;
(l) Rare, Threatened and Endangered Species and their Habitat Studies
(consult with state and federal agencies pursuant to federal Endangered
Species Act);
(m) San Gorgonio Creek Watershed - Cumulative Environmental Impact
Studies (this project, other existing projects, and future projects
[water diversions]);
(n) Water Quality Certification from the California State Water
Resources Control Board;
(o) Section 4(e) Conditions from the U.S. Forest Service;
(p) Public Recreation Studies (existing and proposed recreation
facilities and activities throughout the project area;
(q) San Gorgonio Creek - Forebays - public reservoir and river boating
and recreational studies;
(r) Compliance of state and federal statutes - Pre-project and post
project conditions, which includes the Common Law Public Trust
Doctrine, Section 5937 of the California Fish and Game Code, California
Water Code, California Constitution, federal Clean Water Act, federal
Endangered Species Act, and all other applicable state and federal law;
(s) As an alternative under NEPA, the Commission should disclose and
evaluate in detail, the decommissioning of the project.
That concludes the comments and notice of intent to file a motion to
intervene by the California Sportfishing Protection Alliance.
Respectfully Submitted
_________________________________________________
Robert J. Baiocchi, Consultant
For: California Sportfishing Protection Alliance
P.O. Box 357
Quincy, CA 95971
Bus Tel: 530-836-1115; Fax: 530-836-2062;
E-Mail Address - cspa@psln.com
Date: July 23, 1998
Certificate of Service
The Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
(Original and 15 Copies)
Carol Simpson, Director
Office of Hydropower Licensing - Room 62-15
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
Bryant C. Danner
Southern California Edison Company, Licensee
2244 Walnut Grove Avenue
P.O. Box 800
Rosemead, CA 91770
Gary Taylor, Water and Power
U.S. Fish and Wildlife Service
3310 El Camino Avenue, Suite 130
Sacramento, CA 95821-6340
Jim Canaday, Environmental Unit
Section 401 CWA Coordinator
Division of Water Rights - SWRCB
P.O. Box 2000
Sacramento, CA 95812-2000
Jacqueline Schafer, Director
California Department of Fish and Game
1416 Ninth Street
Sacramento, CA 95814
Jim Crenshaw, President
California Sportfishing Protection Alliance
1248 East Oak Avenue, Suite D
Woodland, CA 95695
Mike Fitzwater
California Sportfishing Protection Alliance
2739 Third Avenue
Sacramento, CA 95818
Maureen Rose
Friends of the River, Inc.
California Hydro Reform Coalition
128 J Street, 2nd Floor
Sacramento, CA 95814-2207
Interested Parties (numerous by e-mail)
For further information contact Bob Baiocchi at either 530-836-1115 or
at e-mail address: cspa@psln.com