Mulho:ṭam Free the Eel; FERC Decommissioning of the Potter Valley Project
The Issue
Debbie-Anne A. Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
Re: In Support of Decommissioning; Potter Valley Hydroelectric Project, Docket No. P-77-332
Respected Secretary Reese,
Thank you to the agency for extending the opportunity to provide public comments supporting Eel River communities and the return of a free flowing river. The undersigned community members are in support of decommissioning of the Potter Valley Hydroelectric Project, Docket No. P-77-332. We are eager and proud to unite in restoring and conserving our longest free flowing river in California.
Our unique river and natural ecosystem is one of the most diverse in the world. In a healthy climate year we can travel at day break from the North Coast Ridges exploring snow capped mountains feeding tributaries reaching abundant forests where ancestral territories flourish with Native species producing resilient food staples, basketry materials and ceremonial plants and medicine gathered by ancient civilizations still present today. On the same day following the patterns of our anadromous aquatic relatives traveling down stream, one can touch the sand at sunset where our river meets the ocean.
Regenerative cultures of the region historically cared for the Eel River watershed maintaining healthy water ways. Habitat management and seasonal place based systems applied traditional practices where spring and fall ceremonies were reliant upon cultural burning. Genocide against ancient cultures were intentional in overtaking abundant resources in the area claiming property title and rights to not only the lands but the aboriginal peoples who carry the knowledge to care for them. With the intention to destroy cultural life ways came the exploitation of natural water resources and fisheries. Instead of working with the natural watershed and water cycles, supporting healthy returns of Native Species, colonial life ways divulged in control, manipulating mother nature. Climate crisis today is the result of these acts of destruction and we as humans do not benefit from working against our environment. Reservoirs and hydroelectric power plants advance climate change, exposing environmental degradation and public safety risks beyond regional perviews. Global climate risks associated with methane gas emissions and toxic algae bloom production are significant in contributing to global warming. To be cognizant of these dangers facing our planet and future generations we must act now. Decommissioning of this project restores the rights of nature protecting generations who will live to see a healthy return of our resilient and diverse ecosystem.
Intentional genocidal acts took place at the Potter Valley Project, under the reservoir are ancient Yuki village sites, adjacent remnants exist where rangers stationed to hunt Tribes for profit. Aside from the blood on the hands of the State and Federal Government, all natural life ways of economic value to settlers, Indigenous cultures and heritage, were stolen to degrade ancestral lands. Today the undersigned Stand In Solidarity with The Round Valley Indian Tribes, senior water rights holders, to Free the Eel and return the inundated territory to the aboriginal peoples of the region.
Architects of Abundance
In an attempt to interrupt the Federal Energy Regulatory Commission (FERC) process Secretary Brook Rollins and the United States Department of Agriculture (USDA) have intervened demanding agricultural farmers be prioritized claiming they are the “nation’s original conservationist?” Secretary Rollins fails to recognize existing laws where the State of California and our agencies, acknowledge Tribes as regenerative humans supporting healthy ecosystems since time immemorial. California Tribes, Traditional Ecological Knowledge (TEK) is Best Science.
In Architectures of Abundance: Indigenous Regenerative Food and Land Management Systems and the Excavation of Hidden History, Dr. Lyla June Johnston explains evolutional regenerative human concepts worldwide related to the elements. She analyses Indigenous soil management, Indigenous aquaculture, Indigenous pyrogenic land management and Indigenous oral history, all subjects that may be defined as Indigenous Knowledge (IK), TEK and or Best Science Practices.
In the Indigenous aquaculture section she explains (6) ancient Indigenous fish cultures from around the world presenting their underlying goals and principles. Standing out in her discussions, distinct cultural similarities related to Indigenous aquaculture techniques are represented in relation to the Eel River. Documented by the United States Forest Service (U.S.F.S) explains abundant food sovereignty in the watershed existed for generations. Dr. Lyla June’s writing expresses, pre-Columbian Indigenous Nations were not technologically deprived, victims of circumstance nor struggling to survive.
The Heart of Yuki Territory
The Round Valley Reservation is the aboriginal territories of the Valley Yuki, the heart of Yuki territory, is surrounded by the Eel River and the entire water basin is ancestral territories of The Round Valley Indian Tribes (RVIT) tribes. Flowing 300+ miles across multiple political boundaries and linguistic territories, each fork of the Eel is a diverse ecosystem holding historic sites, cultural resources and Tribal Beneficial Uses. The Yuki language place name for the Eel River is Mulho:ṭam which translates to “(the) big river” but may also be referred to as the “main” river. The term Eel River was given by colonizers during the Gold Rush who were grateful for their survival on the river after being introduced to lamprey, mistaken for eel. Eel River in the Yuki language may be translated as č̓a:k̓om mąl. This is a direct translation of the words eel and river in the ʔukomnoʔm dialect spoken in “Round Valley” and recorded from Arthur Anderson and Minnie Fulwider.
Regional basin plans continue to overlook the Senior Water Rights held by RVIT, a sovereign nation exercising self-governance since time immemorial whose rights predate the establishment of the Federal Government and the U.S. Constitution. Tribes are not stakeholders, members of the public, or an ethnic group, but sovereign governments requiring government-to-government consultation. No consultation took place during the creation of the Potter Valley Project, for over 100 years the Tribe has not been compensated for water exports.
According to Michael Dugas, et al., in a report titled "Yuki Settlement on the Black Butte River Revisited,” Yuki Indians occupied Mendocino, Humboldt, Lake, and Glenn Counties in Northern California. Kroeber (1925) suggests based on physical appearance and language, of all California Tribes, the Yuki are nearest to being autochthonous (native, original). Pre-Proto-Yukian is correlated with the Post pattern of the Paleo Indian period (12,000 to 8000 B.P.) and prior to 3000 B.P., ancestral Yuki territory extended over a large geographic area from Humboldt Bay to the lower Russian River valley. Fredrickson (1973) hypothesized Yukian speakers and their ancestors occupied the ethnographic territory of the Yuki, Coast Yuki, and Huchnom continuously throughout the entire period represented by the known archaeological record for the area.
George Foster’s 1944 “A Summary of Yuki Culture” outlined six Yuki subgroups: Ukomno’m (Valley People); Huititno’m (Middle Ridge People); Suksaltatamno’m (Nicely Shaped Pine Tree People); Witukomno’m (Eden Valley People); Onkolukomno’m (Ground in Another Valley People); and Ta’no’m (Slope People). Edwards noted (1966:9) an early settler, Judge Potter, estimated 3,000 Indians in Round Valley and 10,000 in the surrounding foothills in 1860. The judge stated “almost every spring in the mountains and every flat on the river had its Indian camp remains.” He stated Round Valley and the surrounding valleys and mountains were extremely productive of fish, game, berries, and acorns, tales of famine were rare. Trade for beads, shells, obsidian, and other items were in exchange for the Yuki’s surplus food.
Land Subsidence, Dam Safety and Water Quality
The United States Geological Survey (USGS) reports the main causes of land subsidence in California, the gradual sinking of the Earth's surface due to subsurface movement of earth materials, is groundwater pumping. Dried streams and rivers signify over pumped water systems creating erosion, flooding and fire fuels. Damaged soils incapable of recharging ground water deliver toxic agricultural runoff to the reaches of ditches or culvert drains polluting habitats, and water sources. Agricultural gas emissions and oil drilling pollute the water and air, where particle pollution emits on food crops mixing with pesticides and synthetic chemicals for consumption. Rollins, theoretical lead conservationist, are truly responsible for earning fortunes manipulating water ways to accommodate surplus crops filled with toxins. The Eel River is not the band aid fix for the degradation of industrial agriculture production who dismiss the evidence of environmental impacts from agencies whose work is to monitor and regulate lands subsidence, dam safety and water quality.
The Environmental Needs
To restore the diverse ecological integrity of the Eel River the first step is a quick and timely action to remove the project. This removal process must occur now and not be contingent upon another project facility. There are far too many variables posing threats to our environment and climate conditions globally to realistically uphold decommissioning to sustain agricultural exports where ground pumping and profits for over farming uses of water are prioritized.
The Eel River has been listed as an impaired water body in all (7) forks or tributaries. This impairment is theoretically applied to the natural function of the river system. Erosion and movements in the river's system are made to clean or filter the water naturally, native species are genetically adapted to survive in these conditions. Dam safety is in jeopardy because the structure is built on a natural moving surface. The river, similar to most current designs engineered on California waterways to withstand tectonic change, is built to move naturally and bend with forgiveness rather than be stable and forever standing. The impairment listings while assessed and provided by the United States Environmental Protection Agency (USEPA) are based not on true protections of the natural environment but on the threats to human structures in areas visually unsafe to maintain. This can be seen on the Highway 162 corridor that travels adjacent to the Eel River in and out of the Round Valley Indian Tribes Reservation. The cost to maintain road safety and structure can be determined by the California Department of Transportation or Caltrans who are maintaining the road ways, where the same erosion types exist. The work to restore and conserve the Eel River watershed must be carried out with caution and inclusion of Tribes and all agencies responsible for their particular scope of work.
At this time in preparing your environmental assessment and mitigation for impacts we ask that you take in the knowledge of the Eel River communities who have been impacted by the barriers created in this project. Be realistic in the assessment of what future and ongoing structural designs will face and their true purposes. When envisioning beneficial uses of water be reminded that for over 100 years an entire sovereign government, their members and sister Tribes throughout the watershed face excessive health and safety risks directly related to this structure. While the State of California has made significant progress in protecting Tribal Beneficial Uses, regional water plans to date do not include these uses which are distinct for each Tribe and ecotype in the watershed. Where documentation exists from Federal Government Agencies, there is yet a need to ensure these rights and responsibilities are upheld. The construction of the Potter Valley Project, FERC and PG&E failed to consult with the Tribes and is now being held responsibly for those actions.
Thank you for your time. Free The Eel!
Nikcole Whipple, Water Justice Coordinator
Communities United for Water Protection
107
The Issue
Debbie-Anne A. Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, DC 20426
Re: In Support of Decommissioning; Potter Valley Hydroelectric Project, Docket No. P-77-332
Respected Secretary Reese,
Thank you to the agency for extending the opportunity to provide public comments supporting Eel River communities and the return of a free flowing river. The undersigned community members are in support of decommissioning of the Potter Valley Hydroelectric Project, Docket No. P-77-332. We are eager and proud to unite in restoring and conserving our longest free flowing river in California.
Our unique river and natural ecosystem is one of the most diverse in the world. In a healthy climate year we can travel at day break from the North Coast Ridges exploring snow capped mountains feeding tributaries reaching abundant forests where ancestral territories flourish with Native species producing resilient food staples, basketry materials and ceremonial plants and medicine gathered by ancient civilizations still present today. On the same day following the patterns of our anadromous aquatic relatives traveling down stream, one can touch the sand at sunset where our river meets the ocean.
Regenerative cultures of the region historically cared for the Eel River watershed maintaining healthy water ways. Habitat management and seasonal place based systems applied traditional practices where spring and fall ceremonies were reliant upon cultural burning. Genocide against ancient cultures were intentional in overtaking abundant resources in the area claiming property title and rights to not only the lands but the aboriginal peoples who carry the knowledge to care for them. With the intention to destroy cultural life ways came the exploitation of natural water resources and fisheries. Instead of working with the natural watershed and water cycles, supporting healthy returns of Native Species, colonial life ways divulged in control, manipulating mother nature. Climate crisis today is the result of these acts of destruction and we as humans do not benefit from working against our environment. Reservoirs and hydroelectric power plants advance climate change, exposing environmental degradation and public safety risks beyond regional perviews. Global climate risks associated with methane gas emissions and toxic algae bloom production are significant in contributing to global warming. To be cognizant of these dangers facing our planet and future generations we must act now. Decommissioning of this project restores the rights of nature protecting generations who will live to see a healthy return of our resilient and diverse ecosystem.
Intentional genocidal acts took place at the Potter Valley Project, under the reservoir are ancient Yuki village sites, adjacent remnants exist where rangers stationed to hunt Tribes for profit. Aside from the blood on the hands of the State and Federal Government, all natural life ways of economic value to settlers, Indigenous cultures and heritage, were stolen to degrade ancestral lands. Today the undersigned Stand In Solidarity with The Round Valley Indian Tribes, senior water rights holders, to Free the Eel and return the inundated territory to the aboriginal peoples of the region.
Architects of Abundance
In an attempt to interrupt the Federal Energy Regulatory Commission (FERC) process Secretary Brook Rollins and the United States Department of Agriculture (USDA) have intervened demanding agricultural farmers be prioritized claiming they are the “nation’s original conservationist?” Secretary Rollins fails to recognize existing laws where the State of California and our agencies, acknowledge Tribes as regenerative humans supporting healthy ecosystems since time immemorial. California Tribes, Traditional Ecological Knowledge (TEK) is Best Science.
In Architectures of Abundance: Indigenous Regenerative Food and Land Management Systems and the Excavation of Hidden History, Dr. Lyla June Johnston explains evolutional regenerative human concepts worldwide related to the elements. She analyses Indigenous soil management, Indigenous aquaculture, Indigenous pyrogenic land management and Indigenous oral history, all subjects that may be defined as Indigenous Knowledge (IK), TEK and or Best Science Practices.
In the Indigenous aquaculture section she explains (6) ancient Indigenous fish cultures from around the world presenting their underlying goals and principles. Standing out in her discussions, distinct cultural similarities related to Indigenous aquaculture techniques are represented in relation to the Eel River. Documented by the United States Forest Service (U.S.F.S) explains abundant food sovereignty in the watershed existed for generations. Dr. Lyla June’s writing expresses, pre-Columbian Indigenous Nations were not technologically deprived, victims of circumstance nor struggling to survive.
The Heart of Yuki Territory
The Round Valley Reservation is the aboriginal territories of the Valley Yuki, the heart of Yuki territory, is surrounded by the Eel River and the entire water basin is ancestral territories of The Round Valley Indian Tribes (RVIT) tribes. Flowing 300+ miles across multiple political boundaries and linguistic territories, each fork of the Eel is a diverse ecosystem holding historic sites, cultural resources and Tribal Beneficial Uses. The Yuki language place name for the Eel River is Mulho:ṭam which translates to “(the) big river” but may also be referred to as the “main” river. The term Eel River was given by colonizers during the Gold Rush who were grateful for their survival on the river after being introduced to lamprey, mistaken for eel. Eel River in the Yuki language may be translated as č̓a:k̓om mąl. This is a direct translation of the words eel and river in the ʔukomnoʔm dialect spoken in “Round Valley” and recorded from Arthur Anderson and Minnie Fulwider.
Regional basin plans continue to overlook the Senior Water Rights held by RVIT, a sovereign nation exercising self-governance since time immemorial whose rights predate the establishment of the Federal Government and the U.S. Constitution. Tribes are not stakeholders, members of the public, or an ethnic group, but sovereign governments requiring government-to-government consultation. No consultation took place during the creation of the Potter Valley Project, for over 100 years the Tribe has not been compensated for water exports.
According to Michael Dugas, et al., in a report titled "Yuki Settlement on the Black Butte River Revisited,” Yuki Indians occupied Mendocino, Humboldt, Lake, and Glenn Counties in Northern California. Kroeber (1925) suggests based on physical appearance and language, of all California Tribes, the Yuki are nearest to being autochthonous (native, original). Pre-Proto-Yukian is correlated with the Post pattern of the Paleo Indian period (12,000 to 8000 B.P.) and prior to 3000 B.P., ancestral Yuki territory extended over a large geographic area from Humboldt Bay to the lower Russian River valley. Fredrickson (1973) hypothesized Yukian speakers and their ancestors occupied the ethnographic territory of the Yuki, Coast Yuki, and Huchnom continuously throughout the entire period represented by the known archaeological record for the area.
George Foster’s 1944 “A Summary of Yuki Culture” outlined six Yuki subgroups: Ukomno’m (Valley People); Huititno’m (Middle Ridge People); Suksaltatamno’m (Nicely Shaped Pine Tree People); Witukomno’m (Eden Valley People); Onkolukomno’m (Ground in Another Valley People); and Ta’no’m (Slope People). Edwards noted (1966:9) an early settler, Judge Potter, estimated 3,000 Indians in Round Valley and 10,000 in the surrounding foothills in 1860. The judge stated “almost every spring in the mountains and every flat on the river had its Indian camp remains.” He stated Round Valley and the surrounding valleys and mountains were extremely productive of fish, game, berries, and acorns, tales of famine were rare. Trade for beads, shells, obsidian, and other items were in exchange for the Yuki’s surplus food.
Land Subsidence, Dam Safety and Water Quality
The United States Geological Survey (USGS) reports the main causes of land subsidence in California, the gradual sinking of the Earth's surface due to subsurface movement of earth materials, is groundwater pumping. Dried streams and rivers signify over pumped water systems creating erosion, flooding and fire fuels. Damaged soils incapable of recharging ground water deliver toxic agricultural runoff to the reaches of ditches or culvert drains polluting habitats, and water sources. Agricultural gas emissions and oil drilling pollute the water and air, where particle pollution emits on food crops mixing with pesticides and synthetic chemicals for consumption. Rollins, theoretical lead conservationist, are truly responsible for earning fortunes manipulating water ways to accommodate surplus crops filled with toxins. The Eel River is not the band aid fix for the degradation of industrial agriculture production who dismiss the evidence of environmental impacts from agencies whose work is to monitor and regulate lands subsidence, dam safety and water quality.
The Environmental Needs
To restore the diverse ecological integrity of the Eel River the first step is a quick and timely action to remove the project. This removal process must occur now and not be contingent upon another project facility. There are far too many variables posing threats to our environment and climate conditions globally to realistically uphold decommissioning to sustain agricultural exports where ground pumping and profits for over farming uses of water are prioritized.
The Eel River has been listed as an impaired water body in all (7) forks or tributaries. This impairment is theoretically applied to the natural function of the river system. Erosion and movements in the river's system are made to clean or filter the water naturally, native species are genetically adapted to survive in these conditions. Dam safety is in jeopardy because the structure is built on a natural moving surface. The river, similar to most current designs engineered on California waterways to withstand tectonic change, is built to move naturally and bend with forgiveness rather than be stable and forever standing. The impairment listings while assessed and provided by the United States Environmental Protection Agency (USEPA) are based not on true protections of the natural environment but on the threats to human structures in areas visually unsafe to maintain. This can be seen on the Highway 162 corridor that travels adjacent to the Eel River in and out of the Round Valley Indian Tribes Reservation. The cost to maintain road safety and structure can be determined by the California Department of Transportation or Caltrans who are maintaining the road ways, where the same erosion types exist. The work to restore and conserve the Eel River watershed must be carried out with caution and inclusion of Tribes and all agencies responsible for their particular scope of work.
At this time in preparing your environmental assessment and mitigation for impacts we ask that you take in the knowledge of the Eel River communities who have been impacted by the barriers created in this project. Be realistic in the assessment of what future and ongoing structural designs will face and their true purposes. When envisioning beneficial uses of water be reminded that for over 100 years an entire sovereign government, their members and sister Tribes throughout the watershed face excessive health and safety risks directly related to this structure. While the State of California has made significant progress in protecting Tribal Beneficial Uses, regional water plans to date do not include these uses which are distinct for each Tribe and ecotype in the watershed. Where documentation exists from Federal Government Agencies, there is yet a need to ensure these rights and responsibilities are upheld. The construction of the Potter Valley Project, FERC and PG&E failed to consult with the Tribes and is now being held responsibly for those actions.
Thank you for your time. Free The Eel!
Nikcole Whipple, Water Justice Coordinator
Communities United for Water Protection
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Petition created on September 18, 2026