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HomeMy WebLinkAbout03.02.20 Email from FERC - Comment of CA State Historic Perservation Office under P-619 `State of California Natural Resources Agency Gavin Newsom, Governor DEPARTMENT OF PARKS AND RECREATION Lisa Ann L. Mangat, Director OFFICE OF HISTORIC PRESERVATION Julianne Polanco, State Historic Preservation Officer 1725 23rd Street, Suite 100, Sacramento, CA 95816-7100 Telephone: (916) 445-7000 FAX: (916) 445-7053 calshpo.ohp@parks.ca.gov www.ohp.parks.ca.gov March 2, 2020 In reply refer to: FERC_2014_0806_001 Mr. Timothy Konnert, Chief West Branch Division of Hydropower Licensing Federal Energy Regulatory Commission Washington, D.C. 20426 VIA FERC E-FILING/EMAIL RE: Draft Programmatic Agreement Bucks Creek Hydroelectric Project FERC Licensing (FERC No. 619-164), Plumas County, CA Dear Mr. Konnert, The California State Historic Preservation Officer (SHPO) received a submittal from the Federal Energy Regulatory Commission (FERC) for the above-named undertaking pursuant to 36 CFR Part 800 (as amended 8-05-04), the regulations implementing Section 106 of the National Historic Preservation Act (NHPA). Included with the submittal was: Draft Programmatic Agreement Between the Federal Energy Regulatory Commission and the California State Historic Preservation Officer for Managing Historic Properties That May Be Affected By Issuing a License to the Pacific Gas and Electric Company for the continued operation of the Bucks Creek Hydroelectric Project in Plumas County, California (FERC No. 619-164) I have reviewed the Draft Programmatic Agreement and offer the following comments: Include a stipulation that addresses the consultation process for amending the Area of Potential Effects (APE), including which consulting parties are included and a timeframe for consultation. Include a process and timeline for parties to review and comment and for FERC to consider, incorporate, or otherwise respond to comments on determinations and/or assessments of effects. Include a process for consultation regarding the annual reporting, including a comment period, how comments will be addressed, and the Mr. Timothy Konnert FERC_2014_0806_001 March 2, 2020 Page 2 of 2 report finalized. It should also include an annual meeting or phone call with the consulting parties to discuss any comments. The draft PA should also include a stipulation that states that the HPMP can be amended without amending the PA, and a process for doing so. The draft PA should include a stipulation addressing emergency situations, consistent with 36 CFR § 800.12. Please provide the SHPO with copies of the written delegation from federal agencies to the FERC for the administrative record and describe in what capacity each is involved. Include a Discovery clause, per 800.6(c)(6), that references the discovery plan outlined in the HPMP, or the process at 800.13. In the Dispute Resolution stipulation, clarify the meaning of the statement: The Commission will consult with the objecting party, and with other parties as appropriate, to resolve the objection. The Commission may initiate on its own such consultation to remove any of its objections If you have any questions or concerns, please contact Brendon Greenaway at (916) 445-7036 or Brendon.Greenaway@parks.ca.gov. Sincerely, Julianne Polanco State Historic Preservation Officer