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Docket No.: F-619
BUMCOUNTY
BUTTE, COUNTY OF NISTRATIcN'
BOARD OF SUPERVISORS OCT 2 8 20116
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APPENDIX A
COMMENTS ON THE DRAFT LICENSE APPLICATION
FOR THE BUCKS CREEK PROJECT,FERC NO.619-158
Commission staff has identified that your draft license application(DLA)did not
contain some of the information that will be required by our regulations for a final license
application(FLA)(§5.18). In our comments,we note the areas of the DLA where more
specific information will be needed for a complete license application.
Exhibits B,D,and F
(1) The Exhibit B should also include monthly flow duration curves.
(2) Add a Short Run Avoided Cost reference to Table D.8.1-1.
(3) You do not include a Supporting Design Report in section F-3 because you believe
the recent Part 12 Independent Dam Safety Inspection Reports(October 29,2015)fulfills
.the requirements of the regulations. You should ask for a waiver of this requirement for
the reasons you give.
Exhibit E
Genera!
(1) Many sections within the DLA state that existing,relevant,and reasonable available
information for the resource is described in the pre-application document(PAD)of the
DLA. Note that the Commission's regulations,§5.18(b)(5)(C)(ii)(A-13),require a
detailed description of the affected environment or area(s)to be affected by the proposed
project by each resource,including the affected environment information filed in the
PAD,developed under the applicant's approved study pian,and otherwise developed or
obtained by the applicant. While much of this information is provided in the PAD and
summarized in the DLA,the FLA should include a more detailed description of the
resources.
(2) The preliminary proposed protection,mitigation,and enhancement(PM&E)
measures for the Bucks Creek Project are listed in a table that starts on page E-371 of the
DLA. Per the Commission's regulations,§5.18(0),this section also should detail how
each proposed measure would protect or enhance the existing environment and,when
possible,describe any anticipated benefits in non-monetary terms.
(3) Several of the PM&E measures listed in the table on page E-371 involve the
development of plans;however,the details of these proposed plans are not included in
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the DLA. It is the Commission's goal to have resource-specific protection plans Filed
prior to license issuance. We expect,therefore,that detailed plans be filed with the FLA
application. At a minimum,these plans(including the vegetation management plan;
recreation management plan;transportation management plan;and fire prevention plan)
should include the following details:
• The objectives of the plan
• The mitigation/monitoring/management techniques to be employed in the plan
• A description of how the mitigation/monitoringlmanagement techniques for the
plan will incorporate conservation/avoidance measures
• An implementation schedule
Aquatic Resources
(1) On page E-30,you state that a flow release of approximately 0.25 cubic feet per
second would be made from a fixed diameter pipe at Milk Ranch conduit diversion no.3
on South Fork Grouse Creek. In the FLA,please provide a detailed plan,implementation
schedule,and conceptual design drawings of the fixed diameter pipe.
(2) On page E-30,you state that a number of diversions along Milk Ranch Conduit
would be rendered inoperable and no longer divert flows but would continue to be
managed for safety. In the FLA,please provide a detailed plan describing how each of
these diversions would be rendered inoperable and managed for safety,and an
implementation schedule.
(3) On pages E-55 and 56,you propose to release channel maintenance flows in Bucks
Creek and Grizzly Creek as required in the existing license and you state that project
operation would have no significant adverse effects on channel condition and large
woody debris. In the FLA,please provide evidence or scientific reasoning to substantiate
the assertion that project operation would have insignificant effects on channel conditions
and large woody debris in Bucks Creek and Grizzly Creek. Please provide a detailed
technical discussion with any relevant data,figures,or tables to support your assertions.
(4) On page E-98,you state that water temperatures in the North Fork Feather River are
not substantially altered by inflow of project-affected stream reaches,and you refer to
Figure E.7.2.2-4 as evidence. In the FLA,please provide evidence or scientific reasoning
to substantiate the assertion that project operation would have insignificant effects on
water temperature in the North Fork Feather River. Please provide a detailed technical
discussion with any relevant data,figures,or tables to support your assertions.
(5) On page E-100,you state that water temperatures in the project-affected stream
reaches are generally suitable For cold water fish,even though water temperatures in
Grizzly Creek exceed 20 degrees Celsius in July and August. In the FLA,please provide
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the results of the temperature model being developed for Grizzly Creek as evidence to
substantiate the assertion that water temperatures in Grizzly Creek affected by project
operation are suitable for cold water fish and habitat. Please provide a detailed technical
discussion with any relevant data,figures,or tables to support your assertions.
(6) On page E-142,you propose to release minimum instream flows at Lower Bucks
Lake dam and Grizzly€orebay dam as required in the existing license. You refer to
graphs of weighted usable area(WUA)for various life-stages of brown and rainbow trout
from a 1991 instream flow study and you state that project operation with these minimum
instream flows would result in no significant adverse effects on aquatic and fish habitat.
In the FLA,please provide a detailed technical discussion using the WUA results from
the 1991 study to substantiate the assertion that the proposed minimum instream flows in
the project-affected reaches below Lower Bucks Lake dam and Grizzly Forebay dam
would have insignificant adverse effects on brown and rainbow trout habitat. Please
provide any relevant data,figures,or tables to support your assertions.
(7) On page E-142,you state that the proposed instream flows in Milk Ranch Creek
below Three Lakes and at Milk Ranch conduit diversions nos. I and 3 would result in no
significant adverse effect on aquatic habitat. In the FLA,please provide evidence or
scientific reasoning to substantiate the assertion that these instream flows would result in
insignificant effects on aquatic habitat in Milk Ranch Creek. Please provide a detailed
technical discussion with any relevant data,figures,or tables to support your assertions.
(8) On page E-195,you state that the proposed instream flows in Milk Ranch Creek
below Three Lakes and at Milk Ranch conduit diversions nos. I and 3 would have less
than significant effect to populations of back juga snail. In the FLA,please provide
evidence or scientific reasoning to substantiate the assertion these instream flows would
result in insignificant effects on the black juga snail in Milk Ranch Creek_ Please provide
a detailed technical discussion with any relevant data,figures,or tables to support your
assertions.
(9) In Section E.7.3.3.1,you should describe the location of the designated critical
habitat for the California red-legged frog and Sierra Nevada yellow-legged frog in
relationship to the project and any potential effects on that habitat.
Terrestrial Resources
(1) References to Table E.5.2-1 (Current Operation and Maintenance Practices within
the Project Area)(e.g.,page E-243,248,and 25 1)should be corrected to Table E.5.2-2
(Current Maintenance Practices within the Project Area)throughout Exhibit E.
(2) On page E-215,you indicate that no avian electrocution or collisions have been
observed in association with the transmission line. In the FLA,please include the time
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period,if known,covered by these observations.
(3) On page E-375,you propose to develop measures to protect ripariantwetland/littoral
habitats and botanical resources. More information is needed on the specifics of your
measures to protect riparian and wetland habitats,rare natural communities,and special-
status plant species and control invasive plant species,including the use of herbicides.
Ideally,you should include a draft vegetation management plan and transportation
management plan in the FLA.
(4) On page E-376,you propose to continue to implement the Bald Eagle Management
Plan that was filed in 2006. In the FLA,please discuss the specific measures to protect
and monitor bald eagle bald eagles that are outlined in the plan.
(5) On page E-376,define the breeding season for bald eagle and osprey.
(6) On page E-376,you propose to evaluate consistency of the existing transmission line
facilities with APLIC design criteria and upgrade hazardous facilities within 10 years of
the new license but provide no information on potential effects of the line on avian
electrocution or collision. In the FLA,please include existing information on the general
design of the power poles,number of power poles,presence or absence of a static or
shield wire,suitability of avian habitat surrounding the line,flight paths,and other factors
that can contribute to or lessen potential effects. In addition,describe aspects of the
PG&E's Avian Protection Program(page E-215)that are relevant to the Bucks Creek
Project and explain what is meant by"hazardous"and how would it be determined.
(7) The link to Nesting Birds: Species-specific Suffers for PG&E Activities on page E-
423 is incorrect. Please either file that document with the Commission or include as
appendix to the FLA.