The Kilarc Project


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Kilarc Cow History

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Key Davis Hydro Documents
A Brief Annotated Bibliography

 This is a chronological listing of a small subset of the documents filed on this project.  Be advised a more complete listing is here . The reader is advised that for a really complete record, he should consult the FERC Library here under Project P-606.  This is especially true on many documents that are aimed at the South Cow and Steve Tetrick's project there.

This subset focus on the evolution of the Alternatives put forth by Davis Hydro.  Also included are key agency comments and related documents.  The following documents are in order.  There are more earlier ones, but these will give a snapshot of our involvement.  It is important that anyone reading this understands that Davis Hydro walked late into this project late and is continuing to learn how to restore these fish populations. The changing and evolving nature of the proposals reflects an increasing understanding of the genetic, epigenetic, and environmental factors controlling the fish.  The full magnitude of the genetic collapse in the area was not clear when this project started.  We are learning and apologize for the repetition in documents below as we gain understanding on how to be most responsible caretakers of this resource.

We start with some of the the oldest filings.  The youngest are at the bottom.  Be aware there are often two dates, one for the cover date on the document, and one for the date it was filed with the FERC.


In the Spring of 2007 , people were just learning of a private agreement among various agencies and environmental parties to demolish the Kilarc-Cow Creek P-606 facilities.   We attended a meeting of the Cow Creek Watershed Management Committee (for unrelated reasons) , and we learned of it from people attending the meeting.  Our involvement in the project started there. 

 (7/30/2007) A Scoping Paper on the Kilarc and South Cow License Surrender Study Plans – First Draft  This contained several alternatives and early discussion of needed studies.  The paper focused on Alternatives addressing projects of mitigation and fish habitat enhancement on the South Cow basically in exchange for the ability to continuing operation of Kilarc.   The details of this Alternative have been superseded. but is included here to demonstrate the history and depth of the project.  

 9/10/07  Draft V3.2 of two Alternatives was proposed on with others similar distributed changing Web sites and letters.  The filing discusses methodology and defines a suite of ways forward.  The filing discusses some research possibilities.  This filing has been superseded by the creation of the Kilarc foundation, but is included here to demonstrate the history and depth of the project, the ideas, and the breadth of early thinking.  This filing introduces at length, acid rain and the scope of needed studies.  This paper introduced a trial period and the problems of measuring project efficacy.

 9/17/07 Requests for FERC Guidance and Action Regarding P-606 License Surrender.

1. Clarification of Acceptable License Surrender Plan

2. Order to Commence Environmental Impact Studies before March 2009

Submission of PG&E License Surrender Application

(9/25/07) NMFS Dismisses the four DH Alternatives then on the table.  NMFS calls them unsubstantiated, but does offer evidence to the contrary nor call for any studies.  NMFS implicitly asks for financial evidence that revenues could support off-site projects.  This is the only significant NMFS review to date. 

10/12/07 Comments of Davis Hydro On the PG&E Preliminary Proposed Decommissioning Plan 11/8/2008.  The filing contains early identification of Impacts.  This filing questions objectives, discusses the genetics and geographic scope.  Indirect effects were not brought in at this point.  

(1/17/2008 ) The Davis Hydro Alternative I  Ver. 1.1 DH files Alternative 1 focusing on Work on South Cow.  This introduced the fish bypass ideas.  It also discussed work on various diversions and on the South Cow.  See also later version updated March 2008. This version focuses on habitat improvements and new spawning areas. The fish bypass idea is introduced.  This described the efforts at a geo-specific conservation genetics oriented spawning channels.  These are now obsolete and this paper is included here to demonstrate the evolution and history and depth of the project.  This paper is now been updated.  See Filings below. 

(6/20/08) Introduction of the Reconstruction Alternative, also called the Fish Restoration Project.  This represents a continuing evolution of the project.  At this point, it was still believed that there was little suitable spawning habitat in the bypass channel.   It is now recognized that there is significant acceptable gravel in the bypass that would be used by steelhead.  Given the huge fines and clay load, its ability to allow successful hatching of fry is to be examined.  Discussion was made herein of a lease from PG&E to try some of these new ideas.  PG&E would continue to hold an annual License. 

(6/19/09) The Kilarc Steelhead Project, an Alternative to the Demolition of the Kilarc Hydropower Project.  This version focuses on the details of the various spawning grounds.  It has the first detailed maps of the on-site project works.  

(6/25/08) Performance Measures for Recovery of Endangered Species Act-Protected Anadromous Fish.  Part of every project is to know how well your are doing.  The demolition alternative by PG&E is blissfully free of this responsibility.  It is simply assumed that doing away with the diversions will be magically perfect.  This is very hard to contest since there is no measurements built in and as Ms. Sackheim pointed out in the DEIS review public meeting once you tear down all the green hydro facilities, there is no going back even if there are no fish. 

(August 1, 2008)  NMFS response to 6/20/08 Reconstruction Proposal.  Regrettably non-substantive.  The brief letter refers to their filing, dated October 1, 2007 (letter dated 9/25/07), which is available here. 

(July 12, 2009) Proposed Studies Scope and Studies  Early Discussion of needed Scope and Studies  Very specific project scope and Studies are enumerated and justified.  (Filed 7/13/09) 

(11/8/2008) Detailed Comments of Davis Hydro on the PG&E Draft License Surrender Application.  Discusses full range of deficiencies, ignored impacts, and implicitly the needed studies.  Continues to clarify parts of our Alternatives. 

(August, 24,  2009) Our comprehensive response to earlier NOAA FWS & CDFG comments.  This contains the whole discussion.  It discusses geographic, temporal scope, genetic, community, and probable cumulative direct and indirect effects of the project.

(October 2009 )Typical NMFS response to proposal.
It is always disappointing to be arguing with an agency we so much want to work with.

(October 25, 2009) Requested EIS Scope  This filing was dated 9/16/2009, but filed 10/25/09. It is in response to Scoping Document circulated by the FERC on September 16th, 2009.  It details the critical questions needed examination in a comparative analysis of Alternatives.   Page 19 of this Filing addresses FERC’s question whether documentation could be provided  that would support the conclusion that the proposed surrender of project license does or does not contribute to cumulative adverse or beneficial effects on resources (natural and social) and, therefore, should be excluded from further study or included for further consideration of cumulative effects. 

This question was answered for PG&E’s demolition Alternative.  Then we supplied a more comprehensive answer to ask the same question of all the 4 Alternatives being discussed at that time.

(December 2009) CDFG's response to our proposal. "Very Experimental" CDFG opened a partial dialog by indicating that they had read what we had written.  CDFG requested a financial analysis to support the off-site habitat conservation work.  (this has not yet been supplied). Further dialog is respectfully requested with CDFG.

(1/2010) Our response to CDFG. - We agree with CDFG! This is a response with a more complete description of our project as of January 2010.  This paper focuses on common goals and identified the genetic problems faced by population reconstructive efforts.  Also mentioned is the issue of geographic and temporal scope ( for example, the runoff from the future fires will destroy habitat indefinitely into the future).
  The paper does not address the genetic and extensive epigenetic issues, but focuses on responding to the issues raised by the agencies to date.

(2/22/2010) Davis Hydro clearly lays out five Alternatives and discusses pros and cons of two new variations in detail in the shadow of the CDFG letter.  Filing includes in the last attachment, a discussion of needed Research to guide Davis Hydro in the difficult job of genetic conservation efforts needed to recover target fish species diversity.

(2/5/10) An informal comprehensive Response to the various filings by and on behalf of Steve Tetrick, Evergreen Shasta Power.  This filing discusses why the local BIG Timber company opposes our proposal.  The filing also puts forth for discussion (if anyone is actually interested in the fish) a suggested solution to the Abbott Ditch problem on the South Cow.  There is only a brief discussion of the Tetrick “Settlement” proposal.

(June, 2010) Davis Hydro examined the different options for forming a non-profit.  We have been talking about a Kilarc Trust to handle the fish projects.  In the end it was concluded that a Foundation was more flexible, so The Kilarc Foundation was formed in Vermont (economical and big fish state). The Articles of incorporation are here.  The Initial byLaws are here.  We are open on ideas on how to best fabricate theis Foundation in long term interests of the fish.

(July, 2010) FERC released a Draft Environmental Impact Statement.  The public en mass and in toto was in complete anguish in that they did not know how to tear the heads of the FERC representatives and be polite at the same time.  Most succeeded in restraint, although Mrs. Bonnie Tetrick and Mr. Russ Mull clearly spoke for all, judging from the applause. 

(November 2010)  Steve Tetrick released an excellent discussion of how the Removal of the facilities - especially on the South Cow would have no effect of fish.  This was supplemented with extensive supporting information from Agencies obtained under a Freedom of Information Request.

(December, 2010) Davis Hydro releases a December 2010 Kilarc Project Summary and review of their project Alternative. This review shows how it will restore the anadromous steelhead.  It is designed to work within the FERC's laws and procedures.   The Recovery plan included in this summary continues to evolve as we learn more.  Current design is to have a mix of habitat improvements, genetic and epigenetic conservation in concert with State and Federal programs and a research program to address the large areas of biological uncertainty.  This summary also clarifies the role of the Kilarc Foundation as taking the lead on off-site enhancements and activities.

(March 2011) NMFS had released a very poor Biological Opinion on FERC's Preferred Alternative i.e. demolishing the Project.  It was incomplete, inaccurate, and did not include any data or reports submitted by the public.   It was also not in compliance with numerous Federal laws.   Davis Hydro commented on it here.