About — Friends of Silver Lake

Protecting the environs, habitats, and water quality around Silver Lake since 2023.

Photo Credit: Casey Horner

Our Purpose

Friends of Silver Lake (FOSL) is concerned that the Southern California Edison (SCE) Rush Creek Hydroelectric Powerplant and its activities, in particular it's proposed Modified Rush Creek Hydroelectric Project under FERC relicensing and review, will negatively impact water quality and will directly accelerate accretion below the powerplant at the Rush Creek and Silver Lake delta. FOSL believes the Modified Rush Creek Hydroelectric Project will detrimentally affect endangered or protected species habitats, salmonid spawning areas, fishing, tourism, and Silver Lake water quality as well as potentially impact downstream waterways. Possible downstream impacts could also affect the interests of several CA tribes and the Los Angeles Department of Water and Power diversion project at Grant Lake. Any Grant Lake impact could negatively affect Mono Lake.

Provide Education

The purpose of FOSL is to provide education and information to the general public about the environs, habitats, potential flooding issues and water quality around and on Silver Lake located in June Lake, CA with a special focus on the study and reporting of the impacts the Southern California Edison Rush Creek Hydroelectric Project has on the lake and Rush Creek.

Conduct Studies

The organization will gather information, conduct studies, take measurements and hire necessary environmental, legal, geologic, hydrologic and engineering, among other experts, to study any activities that may negatively impact Rush Creek and Silver Lake, its environs, tributary waterways, habitats, recreational activities, tourism or water quality.

Build Awareness

The Friends of Silver Lake will raise awareness regarding the impact various activities have on Silver Lake’s water quality, environs and habitats and provide such information to the public to preserve the quality of Rush Creek and Silver Lake and its environs for future generations.

Preserve and Protect

Friends of Silver Lake will make recommendations to federal and state regulatory agencies, to relevant Utility districts, to Southern California Edison and other stakeholders for hydroelectric power plant modifications, precautions, or necessary actions or steps needed to preserve the quality of the Silver Lake environs, habitat and water quality with a special focus between the Rush Creek Hydroelectric Powerplant and Silver Lake and Rush Creek delta.

Our History

Our founding purpose is to monitor and measure Silver Lake and its environs, habitats, water quality, and sediment accretion due to local hydroelectric power plant activities past, present, and future.

Friends of Silver Lake (“FOSL”) was incorporated in 2023. FOSL is a federally recognized public charity and is a designated tax exempt organization under the Internal Revenue Code ("IRC") Section 501(c)(3). FOSL is a CA nonprofit public benefit corporation. Our purpose is to monitor and measure the Silver Lake and its environs and habitats, water quality and sediment accretion due to local hydroelectric activities; to inform and educate the public about such findings and results; and, to make recommendations to relevant regulatory authorities and governmental agencies. Our purpose will be achieved by funding scientific research and testing to measure such impacts on Silver Lake water quality and accelerated sediment accretion in Silver Lake.

FOSL was formed as a direct result of Southern California Edison’s (SCE) launch of its multi-year Federal Energy Resource Commission’s (“FERC”) unprecedented 50 year relicensing request. The SCE Project under relicensing review is called the Rush Creek Hydroelectric Project, Project No. 1389. SCE intends to either partially or fully remove Rush Meadows and Agnew dams no longer impounding water in either dam and discontinuing their operation. SCE would modify the remaining Gem Dam to meet current seismic requirements. SCE is also studying a full project decommission and its possible impacts at FERC's request.

Why was FOSL formed?

As a result of various community concerns not being addressed in the Proposed Study Plan and Study Plan Determination, FOSL was formed. FOSL board members firmly believe each citizen has a duty to protect and preserve our natural resources for future generations. Silver Lake is an Eastern Sierra Nevada gem that deserves special focus and protection.

Because the FERC Study Determination Plan had not included certain scientific testing parameters, we believe it is important to protect critical environmentally-sensitive areas adjacent to and directly impacted by the Rush Creek Project, for this reason, FOSL was formed.

FOSL will collect data and replicate the only recent historic environmental analysis (See Our Friends' Reports - ESSLIA - David P. Groeneveld, Ph.D and Julia J. Thompson, Ph. D. "Sedimentation in Silver Lake Delta Analysis and Remediation," August 19, 1997 Prepared for East Shore Silver Lake Improvement Association") of the accelerated sediment accretion in Rush Creek and Silver Lake with a special focus on the Silver Lake and Rush Creek delta.

In addition, FOSL will conduct the necessary environmental tests and studies looking at Rush Creek and Silver Lake water quality with a special focus on the accelerated sediment accretion at the Rush Creek and Silver Lake delta on the eastern side of the lake and potential flooding of areas downstream of the powerplant.

FOSL’s goal is to have such study information available for the next steps in the SCE Rush Creek FERC process namely the following:

Ongoing public comment opportunities;
Influence the process during which FERC considers possible protection, mitigation, and enhancement ("PM&E") measures for the new license term as a condition of relicensing;
FERC’s environmental review of the license application;
Other state and federal proceedings, and all state and federal public comment periods during the licensing process allowing for public input; and finally;
FERC’s issuance of a license order for a new term of 30-50 years.

In addition, once FERC issues a Ready for Environmental Analysis Notice, it may also solicit filing of mandatory conditions, motions to intervene and comments and recommendations on the relicensing process. FOSL’s goal is to provide formal comments in National Environmental Policy Act (NEPA) environmental review process and the Comments, Interventions, and Preliminary Terms & Conditions period.

FOSL is concerned that the past and present ongoing SCE hydroelectric activities, in particular, sediment management, past seismic modifications to meet federal earthquake standards, have contributed to accelerated sediment accretion at the Rush Creek and Silver Lake inlet. Simply put, FOSL is concerned about all the potential and real negative impacts the local hydroelectric powerplant has on Rush Creek below the Powerplant and the Silver Lake and Rush Creek Delta.

Finally, and most importantly, FOSL is concerned that the SCE hydroelectric activities, particularly the proposed modified activities under FERC relicensing and review, will negatively impact water quality and will directly accelerate accretion at the Rush Creek and Silver Lake delta. As a result, FOSL believes the modified project will detrimentally affect endangered species habitats, salmonid spawning areas, fishing, tourism, and Silver Lake water quality as well as potentially impact downstream. Possible downstream impacts could also affect the interests of several CA tribes and the Los Angeles Department of Water and Power diversion project at Grant Lake. Any Grant Lake impact could negatively affect Mono Lake.

The FERC Process

What is the SCE Rush Creek FERC Project?

SCE is requesting a 50 year re-license from FERC for the currently operating SCE Rush Creek Hydroelectric Project located within the Eastern Sierra Nevada mountains with turbine operations located in June Lake, CA off CA Interstate 395 and State Highway 158 located in Mono County, CA. For more complete information regarding the Rush Creek Hydroelectric Project, Project No. 1389, please reference www.sce.com/rushcreek.

SCE is proposing in its FERC application to modify its current Rush Creek Hydroelectric Project to address seismic concerns:

Decommission and remove Agnew and Rush Meadows Dams;
Lower Gem Dam to current FERC restriction Level; and,
Total system impoundment capacity will be reduced from ~24,000 AF to ~10,600 AF of water.

Most of the modified project work would be accomplished by thousands of helicopter flights. FERC Process to Date has included the following:

SCE submitted its Pre-Application Document.
Technical Working Groups were established to examine key topic areas of concern.
Stakeholder and Public comments were accepted by FERC through e-filing.
SCE finalized Proposed Study Plan (“PSP”) and FERC issued a Study Plan Determination.
Technical Studies will be conducted over the next two years studying issues raised in the PSP.
FERC did not require SCE to incorporate into its PSP nor did it require certain community sedimentation water quality studies at the delta of Silver Lake and Rush Creek, an area impacted by the Project activities but outside the Project boundary, be included in the PSP because of insufficient study detail.

For more complete information on the FERC and their relicensing process please go to: https://FERC.gov

Please see the attached FERC Appendix A ‘Process Plan And Schedule Rush Creek Hydroelectric Project No. 1389’ for specific application process milestones and dates.

FOSL has also included FERC Guidance on Environmental Measures in License and Relicensing Applications commonly known as PM&E measures.

Researching Beyond

Although the deltaic accelerated accretion and water quality of Rush Creek and Silver Lake are not technically within the Rush Creek Project boundaries, the Project has significant impacts on the Lake and Creek that must be considered. SCE has acknowledged that they are studying areas below the Rush Creek Power Plant turbine substation outside the Project boundaries due to possible Project adverse impacts. In addition, SCE has added additional monitoring stations along Rush Creek and Silver Lake and has taken sediment samples at the Silver Lake delta, all outside the Project boundaries, due to concerns related to possible Project impact. We agree with their expanded sampling and testing approach.

Aerial Photos depict confluence of Rush Creek and Silver Lake and the delta at the confluence ("the Delta") showing sediment accretion/build up.

December 31, 2004: The photo shows level of sediment and size of the Delta immediately after the approved East Shore Silver Lake Improvement Association, a CA public benefit corporation, two month dredging project occurred.
June 2016: The photo shows the sediment and Delta build up prior to federal seismic retrofitting of the Rush Creek Project.
July 12, 2019: The photo shows sediment and Delta’s growth after the Rush Creek Project seismic retrofitting occurred.
May 22, 2022: The photo demonstrates the sediment accretion and Delta growth during the last normal snowfall year and its attendant run off.
July 1, 2024: This photo shows a rapidly accelerated growth of the sediment accretion and Delta growth over a two- year period.

Why is FOSL looking beyond the Rush Creek Project boundaries to conduct scientific and environmental studies and measurements?

View Our Reports