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HomeMy WebLinkAbout03.27.20 Email from FERC - FW_ Project Safety Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al. From:Schuman, Amy To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;Lambert, Steve;Lucero, Debra;McCracken, Shari;Ring, Brian;Ritter, Tami;Rodas, Amalia;Sweeney, Kathleen;Teeter, Doug Subject:FW: Project Safety Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al. Date:Friday, March 27, 2020 8:13:32 AM Good morning, Please see the email below from FERC. Amy Schuman Associate Clerk of the Board Butte County Administration 25 County Center Drive, Suite 200, Oroville, CA 95965 T: 530.552.3308 | F: 530.538.7120 Twitter | Facebook | YouTube | Pinterest -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Thursday, March 26, 2020 5:04 PM Subject: Project Safety Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al. .ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying.. On 3/26/2020, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Pacific Gas and Electric Company PGE (as Agent) Docket(s): P-2107-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Project Safety Compliance Report Description: Pacific Gas and Electric Company submits the Prevention, Response, Investigation Plan- Request for Approval submits the Poe Project under P-2107. To view the document for this Filing, click here https://urldefense.com/v3/__http://elibrary.FERC.gov/idmws/file_list.asp?accession_num=20200326- 5228__;!!KNMwiTCp4spf!XkYcBj8VF5CUW9vEqjcViTbIc_1j_2ahiNRdJk095QIYcctXouc8qoahuqmMe6XSduweS8e-Xp4$ To modify your subscriptions, click here: https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!XkYcBj8VF5CUW9vEqjcViTbIc_1j_2ahiNRdJk095QIYcctXouc8qoahuqmMe6XSduwewOevwGk$ ------------------------------------------------------------------------ Please do not respond to this email. Online help is available here: https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!XkYcBj8VF5CUW9vEqjcViTbIc_1j_2ahiNRdJk095QIYcctXouc8qoahuqmMe6XSduweDZ7zBQ8$ or for phone support, call 866-208-3676. 245 Market Street Power Generation San Francisco, CA 94105 Mailing Address Mail Code N11D P.O. Box 770000 San Francisco, CA 94177 March 25, 2020 Via Electronic Submittal Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Subject: Poe Hydroelectric Project, FERC Project No. 2107-CA Fire Prevention, Response, and Investigation Plan –Request for Approval ENCLOSURES CONTAIN CUI//CEII – DO NOT RELEASE Dear SecretaryBose: Attached for your review and approval is the Poe Fire Prevention, Response, and InvestigationPlan (Plan) (Enclosure A) for Pacific Gas and Electric Company’s(PG&E) Poe Hydroelectric Project (FERC P-2107) (Project). The Federal Energy Regulatory Commission (FERC) issued a new license for the Project on December 17, 2018 (License). Subsection (a) of Article 401 of the License requires PG&E to submit the Plan for FERC approval within one year from License issuance, after the final Plan has been approved by the Forest Supervisor of the Plumas National Forest (Forest Service). As background, the Plan is also required under Condition No.7(Condition No. 7) of the U.S. Department of Agriculture, Forest Service Final 4(e)’s, which are included in the License as Appendix B. An initial draft Plan was submitted to the Forest Service on September 9, 2019 and comments were returned on November 4, 2019. In a letter dated December 6, 2019, the Forest Service approved PG&E’s request for a 3-Month extension of time to address comments and complete the Plan. PG&E also submitted a request for an extension of time with FERC on December 12, 2019. FERC approved the request on January 8, 2020, extending the deadline to submit the final Plan to March 31, 2020. PG&E filed a revised Plan for review to the Forest Service and to CAL FIRE Butte County (CAL FIRE) on January 30 and 31, 2020, respectively. CAL FIRE had no additional comments or changes to the Plan. The Forest Service provided additional comments that were incorporated. PG&E requested approval from the Forest Service in a letter dated March 11, 2020. The Forest Service approved the final Plan by letter dated March 19, 2020. Ms. Kimberly D. Bose, Secretary March 25, 2020 Page 2 Enclosure A to this letter is the final Plan for your approval.The final Plan includes three Attachments.Attachment 1 is a copy of FERC Article 401 and Attachment 2 is a copy of FERC Appendix B - Forest Service 4(e) Condition No. 7. Attachments 1 and 2 are included with Enclosure A. Enclosure B is Attachment 3 to the Plan and includes PG&E’s Fire Prevention and Control Procedures and are filed as CUI//CEII – DO NOT RELEASE. If requested, PG&E will make copies of these procedures available to the Forest Service and/or CAL FIRE. Enclosure C includes PG&E’s letter dated March 11, 2020 and a copy of the Forest Service letter dated March 19, 2020 approving the final Plan. If you have any questions concerning this matter, please contact PG&E’s Sr. License Coordinator, Mr. Matthew Joseph, at 530-889-3276 or at Matthew.Joseph@pge.com. Sincerely, Neil J. Wong Supervisor, Hydro Licensing Enclosures: A – Fire Prevention, Response, and Investigation Plan Attachment 1 – FERC Article 401 Attachment 2 – FERC Appendix B - Forest Service 4(e) Condition No. 7 B – Attachment 3 – PG&E Fire Prevention and Control Procedures Filed with FERC as CUI/CEII – DO NOT RELEASE Copies available to Forest Service and/or CAL FIRE upon request C – Forest Service approval letter dated March 19, 2020 Enclosure A Poe Fire Prevention, Response, and Investigation Plan Poe Hydroelectric Project FERC Project No. 2107 Fire Prevention,Response and Investigation Plan March 2020 ©2020, Pacific Gas and Electric Company PACIFIC GAS AND ELECTRIC COMPANY Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan Table of Contents SECTION 1.0Introduction ......................................................................................................4 1.1.Background and Overview...............................................................................4 1.2.Goals and Objectives ........................................................................................5 1.3.Project Area ......................................................................................................5 SECTION 2.0Methods .............................................................................................................9 2.1.Information/Data Collection and Research .......................................................9 2.1.1.Federal Agency Land Use and Resource Management Plans ..........................9 2.1.2.Fire Management, Fire Prevention, Fire Response, and Fuel Management Plans 9 2.1.3.Cooperative Agreements, Regulations, and Codes .........................................10 2.1.4.Emergency Communication Plans ..................................................................10 SECTION 3.0Fire Prevention and Protection Actions .......................................................11 3.1.General Fire Prevention and Protection Action Summary .............................11 3.2.Specific Fire Prevention and Protection Requirements Applicable to the Project-Related Operations and Maintenance on Federal Lands ....................12 3.3.Project Operations Requiring the Use of Fire/Burning................................... 13 3.4.Protection, Applicable Codes, and Code Compliance Actions.......................14 3.4.1.Applicable Codes ............................................................................................14 3.4.2.Utility Corridor Firebreak and Vegetation Clearance Requirements .............14 3.4.3.Project Area Code Compliance and Inspections .............................................15 3.5.Fire Prevention Requirements for Project Area Tool & Equipment Use.......15 3.6.Fuels Treatment and Vegetation Management ...............................................15 SECTION 4.0Fire Safety at Recreation Facilities ..............................................................16 SECTION 5.0Reporting Fires...............................................................................................17 SECTION 6.0Fire Control/Extinguishment and Emergency Response Preparedness ...18 6.1.Project Roads, Helipads and Drafting Locations ............................................18 6.2.Fire Suppression Equipment and Personnel ....................................................19 March 2020 Page i Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 7.0Investigation of Project Related Fires ..........................................................20 7.1.Fires on NFS Lands ........................................................................................20 7.2.Fires on PG&E, Private, or Other Government-Owned Lands and Spread to NFS Lands ......................................................................................................20 SECTION 8.0Key Contacts...................................................................................................22 8.1.Forest Service Contacts –Plumas National Forest.........................................22 8.2.Licensee Contacts – Poe Hydroelectric Project ..............................................22 SECTION 9.0Plan Revisions.................................................................................................23 SECTION 10.0References .......................................................................................................24 LIST OF FIGURES Figure 1-1. Land Ownership and Project Features of the Poe Hydroelectric Project .....................6 Figure 1-2. Fire Hazard Severity Zones and Project Features of the Poe Hydroelectric Project ...7 ATTACHMENTS Attachment 1 FERC Article 401 Attachment 2 FERC Appendix B - Forest Service 4(e) Condition No. 7 Attachment 3 Filed with FERC as CUI//CEII – DO NOT RELEASE Copies available to Forest Service and/or CAL FIRE Upon Request PG&E Fire Prevention and Control Procedures (This Fire Response Plan references the following procedures that are periodically updated. The most current procedure is always available to employees, but may not be reflected in this Plan) Attachment 3-1: Utility Standard: RISK-7510S - Fire and Risk Engineering Design for PG&E Facilities Attachment 3-2: Utility Standard: PG-1041S - Fire Protection Requirements and Design Criteria - Hydro Attachment 3-3: Utility Procedure: PG-1041P-01 - Fire Protection Risk Evaluation – Hydro March 2020 Page ii Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan Attachment 3-4: Utility Standard: TD-1464S – Preventing and Mitigating Fires While Performing PG&E Work Attachment 3-5: Utility Bulletin: TD-3322B-065. Wildlife Fire Defensible Space for Substations. March 2020 Page iii Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 1.0 Introduction On December 17, 2018, the Federal Energy Regulatory Commission (FERC) issued a new license for Pacific Gas and Electric Company’s (PG&E or Licensee) Poe Project, FERC Number (No.) 2107 (Project). The new license incorporates State of California State Water Resources Control Board (SWRCB) 401 Water Quality Certification (WQC) Conditions into the license articles (SWRCB 2017; Appendix A) and United States Department of Agriculture Forest Service (Forest Service) 4(e) Conditions (Forest Service 2018; Appendix B). This document, Poe Fire Prevention and Response Plan (Plan), presents the plan to comply with fire prevention and response requirements in Forest Service 4(e) Condition No. 7 which was incorporated into FERC License Article 401 (FERC 2018). The relevant FERC Article 401 requirements applicable to this plan are summarized in Attachment 1. Similarly, Forest Service 4(e) Condition 7 is summarized in Attachment 2. The Plan was developed in consultation with the Forest Service. Any future modifications to the final plan approved by FERC shall be approved by the Plumas National Forest, Forest Supervisor, and FERC before implementation. 1.1. Background and Overview The Poe Project is located in the North Fork Feather River Basin, which contains extensive forested lands and is sparsely populated. The “Poe Reach” or “Poe Bypass Reach” is the section of the North Fork Feather River (NFFR) from Poe Dam downstream to Poe Powerhouse (Figure 1-1). Waters of the Poe Project include the Poe Reservoir, a 7.62-mile-long bypassed reach, and the Big Bend Reservoir, which serves as the after bay for the project. The Poe Powerhouse and Big Bend Reservoir are located just upstream of Lake Oroville, the primary storage reservoir for the Feather River Project No. 2100. The FERC boundary covers roughly 300 acres. Public lands within the project boundary include approximately 150 acres of National Forest System (NFS) lands managed by the Plumas National Forest. PG&E owns approximately 140 acres; other lands are owned by the state of California (2 acres) and private individuals (9 acres) (Figure 1-1). All Project features are included in this plan. This includes the Poe Powerhouse and switchyard on PG&E lands and the Poe Dam and associated facilities on NFS lands. The Project includes the following designated recreation sites (land ownership in parenthesis; see Recreation Management Plan): Bardees Bar River Access (PG&E) Poe Beach (NFS) Poe Powerhouse River Access(PG&E) March 2020 Page 4 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan Sandy Beach (NFS) Poe Reservoir Access Trail (PG&E) 1.2. Goals and Objectives The goalof this Plan is to provide guidance for fire prevention procedures, safe fire practices, and reporting for the Licensee’s personnel and contractors who are responsible for operating and maintaining the Project. A separate Integrated Vegetation Management Plan includes a fuel treatment plan to reduce the presence of ladder fuels, removal herbaceous vegetation along the shoulder of access roads, and thinning of existing trees and shrubs in the Project Boundary. 1.3. Project Area Figure 1-1 shows land ownership and the Project Boundary and features of the Poe Project. Figure 1-2 shows fire hazard severity zones as designated by the California Department of Forestry and Fire Protection (CAL FIRE) and the Project Boundary and features. March 2020 Page 5 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan Figure 1-1. Land Ownership and Project Features of the Poe Hydroelectric Project March 2020 Page 6 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan Figure 1-2. Fire Hazard Severity Zones and Project Features of the Poe Hydroelectric Project March 2020 Page 7 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 2.0 Methods Methods and research utilized in the development of this Plan are summarized in the sub-sections that follow. 2.1. Information/Data Collection and Research The information sources and data listed below relating to fire prevention, suppression, and fuel management on lands within the Project Area were reviewed to provide appropriate background and technical reference for the development of this Plan. 2.1.1.Federal Agency Land Use and Resource Management Plans The PNF Land and Resource Management Plan (LRMP) (USDA Forest Service 1988, as amended) 2.1.2. Fire Management, Fire Prevention, Fire Response, and Fuel Management Plans The PNF Fire Restrictions (USDA Forest Service 2020a) Forest Service Fire Management Programs and Policies, Pacific Southwest Region (USDA Forest Service n.d.) Forest Service Wildland Fire Management, 2020b (USDA Forest Service 2020b) Forest Service Wildland Fire Prevention Handbook – FSH 5109.18 (USDA Forest Service 1999) California Department of Forestry and Fire Protection, 2018 Strategic Fire Plan for California (CAL FIRE 2018) California Department of Forestry and Fire Protection, 2008 Power Line Fire Prevention Field Guide (CAL FIRE 2008) Wildland Fire Leadership Council Interagency Strategy for the Implementation of Federal Wildland Fire Management Policy, 2003 (Wildland Fire Leadership Council 2003) March 2020 Page 9 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan 2.1.3.Cooperative Agreements, Regulations, and Codes Applicable federal, state, and local agencies’ cooperative agreements, regulations, and codes related to fire protection, prevention, and suppression activities within the Project Area were compiled, reviewed, utilized, and referenced as appropriate. These references included: California Public Resource Codes (CPRC) Sections 4291-4293, 4421-4423, 4425, 4427-4428, 4430-4431, 4433, 4442, 4442.5, 4443, and 4446; California Health and Safety Codes Sections 12101, 13000, 13001, and 13005; the Forest Service Fire Management Manual Section 5130; Plumas County Code Section 6-7.10.3; and the CAL FIRE Power Line Fire Prevention Field Guide. 2.1.4. Emergency Communication Plans Federal, state, and local fire agency emergency management, fire dispatch, and mobilization plans and documents were compiled, reviewed, utilized, and referenced as appropriate. California Interagency Mobilization Guide, 2019 (USDA Forest Service 2019) Butte County Emergency Operations Plan (Butte County Office of Emergency Services 2011) March 2020 Page 10 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 3.0 Fire Prevention and Protection Actions 3.1.GeneralFire Prevention and ProtectionAction Summary The Project’s fire prevention action items identified in this section aresummarized below. In addition to the preventative actions provided in this Plan, the Licensee will comply with the following standards and procedures, which are included as Attachment 3: Utility Standard: RISK-7510S- Fire and Risk Engineering Design for PG&E Facilities Utility Standard: PG-1041S -Fire Protection Requirements and Design Criteria -Hydro Utility Procedure: PG-1041P-01 -Fire Protection Risk Evaluation – Hydro Utility Standard: TD-1464S –Preventing and Mitigating Fires While Performing PG&E Work PG&E. 2019. Wildlife Fire Defensible Space for Substations. Utility Bulletin: TD-3322B- 065. Publication date: 05/08/2019. During the Project’s general fire precautionary period(s), the Licensee will comply with the following codes, regulations, requirements, measures, and activities: All applicable laws of the CPRCs are listed in this document in Section 2.1.3, Cooperative Agreements, Regulations, and Codes. The general fire prevention requirements applicable to Project-related operations, maintenance, equipment, tool use, and fire use activities the Licensee will comply with: All applicable laws of the State of California, CPRCs,and California Health and Safety Codes. PNF’s fire restrictions as they relate to specific construction projects March 2020 Page 11 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan 3.2. Specific Fire Prevention and Protection Requirements Applicable to the Project-Related Operations and Maintenance on Federal Lands For the purposes of this Plan, the Licensee will comply with the following: “Fire Index Area” boundaries are designated by CALFIRE andthe Forest Service for the purpose ofestablishing a fire dangerrating based on local fire conditions. Through arrangements with CAL FIRE and the Forest Service, the Licensees are notified daily during the period from May15 throughNovember 1 when the next-dayfireadjective rating of either “VeryHigh” or “Extreme”are calculatedfor any fire index areas within the Licensees’ territory. These ratings are noted on the Project’s Switching Center logs and communicatedto all Operation and Maintenance (O&M) personnel. This informationisposted by 2100 hours each dayand becomes effective at 0800 hours the following day until 2 hours afterlocalsunsettime. Duringtheperiodswhenthefire adjective ratings are either “Very High” or “Extreme,” the following restrictions will apply: No open burning is permitted–all fires must be extinguished. Discontinue all welding, except in an enclosed building or within an area cleared of all flammable material for a radius of 35 feet. Discontinue all blasting. Smoking is prohibited in grasslands and forested areas. Restrict vehicular travel to cleared roadsexcept in the case of an emergency. Allwelding, cutting, andotherhot worksuchas brazing and grinding will be performed utilizing a Hot WorkPermit issued bythePermit Authorizing Individual for the responsible field crews within the Licensees’ employ. Portable fire extinguishers will be kept within 10 feet of welding and cutting operations and where flammable or combustible liquids are stored. All personnel working in hazardous fire areas must be equipped with firefighting equipment such as, but not limited to shovels, axes, back pumps, etc. The Licensees’ personnel will not replace blown tap fuses on transmission/distribution lines until the line has either been patrolled or the trouble has been cleared. Before replacing blown open-link fuses, all flammable material within a 15-foot radius ofthe test location willbe watered down. The Licensees’ personnel and contractors will perform the work in a manner that minimizes the risk of fire hazard. Personnel and contractors will remove or minimize fire hazards at or adjacent to work areas due to dry brush, grass, debris, and other conditions. Personnel March 2020 Page 12 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan and contractors will have equipment available to extinguish any fires that start at or adjacent to the Project. The Licensees will provide a communication system connecting each operation with the designated Forest Service and/or CAL FIRE dispatch center. The communications system will be capable of notifying the agency’s dispatch center upon the discovery of a fire in the Project Area. This communications system will be operable for the Licensees’ Project operations during the fire precautionary period. The Licensees will ensure that each vehicle has thefollowing firefighting equipment: A round pointshovel with an overall length of not less than46inches(for clearing away flammable materials). Arakeor standard wildland fire hoe (Adze type or McLeod tool) may also beused, but maynot besubstituted for the shovel on the vehicle. Onebackpack water pump readyfor use. 1 One5-pound orgreater ABC fire extinguisher. All firefighting equipment must be accessible at the job site in the event of an emergency. PG&E shall ensure that fire prevention measures conform to water quality protection practices as defined by the Forest Service (2000, 2012). The Licensees will continue to maintain records for all permanent sites that contain hazardous material (i.e., Powerhouses). These records contain information about the facility layout, quantity and type of materials stored, emergency response plans, and employee training. These plans will conform to other applicable federal, state, and local requirements including the California Health and Safety Code Chapter 6.67; Articles 79 and 80 of the California Uniform Fire Code adopted by the State of California; and the California Occupational Safety and Health regulations. Any equipment utilized in the field for a specific construction job must be clearly labeled if it contains a hazardous material such as fuel. In addition, if utilized for a specific field construction job, spill containment is also provided. 3.3. Project Operations Requiring the Use of Fire/Burning Prior to burning on NFS lands, with the Forest Service approval, the Licensee and their subcontractors will obtain the necessary burn permit from the Northern Sierra Air Quality Management District and any other permits required by California and local laws/ordinances. If 1 Used ®­ ¢« ²² ! Ȩ³± ²§-wood-¯ ¯¤±ȩǾ ¢« ²² " Ȩ«¨°´¨£²ȩǾ  ­£ ¢« ²² # Ȩ¤«¤¢³±¨¢ « ¤°´¨¯¬¤­³ȩ ¥¨±¤²ȁ March 2020 Page 13 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan the Forest Service does not approve of the Licensee or their subcontractors burning on NFSlands and the Licensee still wish to burn the material, the Licensee will appeal the Forest Service decision in writing. Should the Forest Service deny the Licensee’s appeal, the material will be disposed of using alternative methods. Prior to burning on non-NFS lands, permits from the appropriate CAL FIRE unit(s), the Northern Sierra Air Quality Management District, and any other permits required by California and local laws/ordinances will be obtained. 3.4.Protection, Applicable Codes, and Code Compliance Actions The Licenseeisresponsible for complying with all applicable laws of the State of California, CPRCs, California Health and Safety Codes, and Forest Service codes. The Licensee will continue to practice ongoing fire protection measures to comply with applicable codes and safeguard Project assets. For example, the Licensee willcreate a defensible space around all Project structures, including powerhouses, penstock facilities, and transmission infrastructure, around rock- and earth-filled dams by routinely clearing vegetation in their immediate vicinity, and around Project recreation facilities (see Integrated Vegetation Management Plan). Additionally, the Licensee will engage in ongoing transmission line/pole fire protection measures on the transmission lines within the Project. This will include periodic inspections to determine the need for vegetation removal, hazard tree trimming/removal, and compliance with CPRC clearance requirements. These efforts are expected to provide an effective level of fire protection and prevention within the Project. 3.4.1. Applicable Codes The Licensee will ensure that the Project is managed for compliance with CPRC Section 4292 – Utility Pole Firebreaks; CPRC Section 4293 - Line Clearance Guidelines; California General Order 95 - Rule 35 Tree Trimming Code (including Exceptions – Rule 35 and Rule 35 – Appendix E), CPRC Section 4291 – Building Clearance Guidelines, and other applicable codes and orders, unless otherwise exempt. The Licensee are also responsible for complying with all Forest Service rules and California public laws that are applicable to Project operations. Any fire code or operating violation will be corrected by the Licensee to the satisfaction of the appropriate Forest Service and/or CAL FIRE representative. 3.4.2. Utility Corridor Firebreak and Vegetation Clearance Requirements The Licensee will ensure that the transmission line corridors are managed for compliance with CPRC Section 4292 - Utility Pole Firebreaks; CPRC Section 4293 - Line Clearance Guidelines; California General Order 95 - Rule 35 Tree Trimming Code (including Exceptions – Rule 35 and Rule 35 - Appendix E), and other applicable codes and orders, unless otherwise exempt. Specifically, CPRC Section 4293 requires specific clearances be maintained between conductors and vegetation and also requires that hazard trees adjacent to the transmission line be removed. March 2020 Page 14 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan The firebreak and vegetation clearances required by CPRC Sections 4292-4293 are applicable, unless such pole or tower is exempt from minimum clearance requirements by provisions of 14 California Code of Regulations (CCR) Section 1255 or CPRC Section 4296. Identification of hazard trees required for removal will be completed prior to removal. When the removal of the hazard trees is required on non-PG&E land, the Licensee will notify the landowner prior to required work, except in emergency situations. If any investigations are needed (e.g., special- status plant and cultural surveys), the Licensees’ qualified professionals will perform them prior to tree removal. 3.4.3.Project Area Code Compliance and Inspections Inspections of equipment utilized in maintaining the Project facilities and surrounding vegetation are the responsibility of the Licensees. Project compliance inspections are completed at periodic intervals to comply with appropriate State of California Codes and Forest Service regulations. The purpose of these inspections is to look for missing or damaged equipment that may be an ignition source and to identify vegetation that does not comply with applicable codes. 3.5. Fire Prevention Requirements for Project Area Tool & Equipment Use The Licensee’s operations that involve any type of equipment/tool use within the Project Area on federal lands will be required to follow specific fire prevention actions and measures during the fire precautionary periods. Tools and equipment may be inspected by CAL FIRE or Forest Service to ensure compliance with fire safety rules. An approved spark arrester is required for any internal combustion engine. 3.6. Fuels Treatment and Vegetation Management Site-specific fuel management treatments have been identified to mitigate and prevent ignition and escape of Project-related or induced wildfires at the recreation sites, Poe Dam, and Poe powerhouse. The Licensee will prepare an Integrated Vegetation Management Plan to reduce the presence of ladder fuels, remove herbaceous vegetation along the shoulder of access roads, and thin existing trees and shrubs to increase spacing and decrease density. March 2020 Page 15 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 4.0 Fire Safety at Recreation Facilities The following language summarizes the Project’s fire prevention action items for recreation facilities: The Licenseewill adhere to Forest Service’s fire restrictions for all recreation facilities on federal and the Licensees’ lands within the FERC Project Boundary The Licensee will post appropriate fire safety signage at all recreation bulletin boards on federal lands within the FERC Project Boundary The Licensee will pursue and request enforcement of Butte County ordinance that prohibits unauthorized camping on the Licensees’ lands within the FERC Project Boundary (Butte County Code Article 15, Section 24-75) March 2020 Page 16 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 5.0 Reporting Fires PG&E personnel shall immediately report all Project related fires to 911. PG&E will also contact the PNF emergency dispatch \[(530)-283-0193\], Cal Fire and/or the local fire authority within as soon as possible. When reporting a fire, personnel shall provide the following information: Reporting party’s name Call back telephone number Project name Fire location; legal description (township, range, section); and descriptive location (reference point) Fire information; acres; rate of spread; and wind conditions If a Project-related wildland fire is suppressed by PG&E personnel, it shall be reported to Cal Fire and the appropriate Plumas National Forest office within 24 hours. March 2020 Page 17 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 6.0 Fire Control/Extinguishment and Emergency Response Preparedness Cal Fire, Forest Service, and the local fire authorities are responsible for wildland fire protection and fire suppression on Project lands. All fires occurring in the Project area will be responded to, attacked and extinguished by the appropriate agency, unless otherwise extinguished by PG&E personnel. PG&E will take reasonable actions to extinguish any fires that are caused, directly or indirectly as a result of Project-related operations and as training, equipment, authority, and safety allows. Project facilities contain several types of fire extinguishers, and emergency dry-standpipe fire hoses. Emergency fire extinguishers and fire protection equipment is inspected annually to ensure that firefighting equipment is ready to use in the event of a fire. In addition, PG&E personnel have access to shovels, other hand tools, and portable fire extinguishers located in Project vehicles. For fires that occur on lands located outside of Project facilities but adjacent to or in the vicinity of the Project area, PG&E personnel will notify appropriate agency and fire department responders and take reasonable fire suppression actions as training, equipment, authority, and safety allow. As required by CPRC 4436, PG&E employees will aid county, state, and federal fire personnel in combating a fire when requested and as their ability and safety allows. PG&E will also make personnel available to provide Project area technical information/support to Cal Fire, Forest Service, and the local fire authorities for fire operations in and adjacent to the Project area. 6.1. Project Roads, Helipads and Drafting Locations Highway 70 is the primary access route to and from the Project area, which provides direct access to the Poe Dam, the Sandy Beach and Poe Reservoir Access Trail recreation sites. Bardees Bar Road, a secondary road off Highway 70 is used to access the Bardees Bar Recreation Site. The Poe Powerhouse and Poe Beach are accessed from Bardees Bar Road and the Poe Powerhouse Road (Figure 1-1). These roads will all act as escape routes for employees, contractors, agency personnel, and private citizens who live, work, or recreate within the Project vicinity and watershed. Big Bend Dam, located downstream of the Poe Powerhouse is not easily accessible; PG&E primarily uses a helicopter to monitor and access this facility. There are three approved helicopter landing zones located at Adit 1, Adit 2, and the Poe Powerhouse. There are also occasional and temporary landing zones throughout the Project Area that will be evaluated and used as appropriate. The Project reservoirs (Poe Reservoir and Big Bend Reservoir) and North Fork Feather River providepotential water drafting sites. Agency personnel will evaluate these sites to determine their suitability for drafting water for fire protection and suppression March 2020 Page 18 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan 6.2. Fire Suppression Equipment and Personnel The Licensee’s personnel involved in routine O&M duties for the Project will have the equipment listed in Section 3.2, Specific Fire Prevention and Protection Requirements. Forspecific construction projects that are permitted through the Forest Service, in addition to the equipment listed in Section 3.2, additional fire suppression equipment may be available as needed, such as water tanks, pumps, and hoses. Project reservoirs are available to agencies responding to wildland fires in the Project vicinity for water supply with appropriate notification to the Licensee as listed below in Section 7.2, Licensee’s Contacts – Poe Hydroelectric Project. While the Licensee does not retain qualified personnel available for fire suppression duties, the Licensee does have personnel available to provide technical information/support for Cal Fire and Forest Service fire operations in and adjacent to the Project Boundary. March 2020 Page 19 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 7.0 Investigation of Project Related Fires 7.1.Fires on NFS Lands The Licensee agrees to fully cooperate with the Forest Service on all fire investigations. The Licensee shall produce upon request all materials and witnesses not subject to the attorney-client or attorney work product privileges, over which the Licensee has control, related to the fire and its investigation including: All investigation reports All witness statements All photographs All drawings All analysis of cause and origin All other, similar materials and documents regardless of how collected or maintained The Licensee shall preserve all physical evidence, and give custody to the Forest Service of all physical evidence requested. The Forest Service shall provide the Licensee with reasonable access to the physical evidence and documents the Licensee requires in order to defend any and all claims, which may arise from a fire resulting from project operations, to the extent such access is not precluded by ongoing criminal or civil litigation. 7.2. Fires on PG&E, Private, or Other Government-Owned Lands and Spread to NFS Lands The Licensee agreesto fully cooperate with the proper authorities on all fire investigations. The Licensee will produce, upon request, all materials and witnesses not subject to the attorney-client or attorney-work product privileges, over which the Licensee has control, related to the fire and its investigation including: investigation reports witness statements photographs drawings March 2020 Page 20 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan analysis of cause and origin other, similar materials, and documents The Licensee will preserve all physical evidence regarding fires and give custody to the proper authority of all physical evidence requested by that authority. The Licensee will have reasonable access consistent with the Freedom of Information Act (FOIA) to the physical evidence and documents, including, as needed, to defend any and all claims that may arise from a fire resulting from Project operations or in the Project Area, to the extent such access is not precluded by ongoing criminal or civil litigation. March 2020 Page 21 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 8.0 Key Contacts 8.1.Forest Service Contacts –Plumas National Forest PNF fire management contacts for non-emergency Project vegetation or fire-related issues: PNF Supervisor's Office: (530) 283-2050 Dispatch (non-emergency): (530)283-7838 Feather River Ranger District: (530) 534-6500 8.2.Licensee Contacts –Poe Hydroelectric Project Licensee supervisory personnel: Generation Supervisor:(530) 892-4510 Rock Creek Switching Center (24 hours a day/7 days a week): (530) 892-4502 March 2020 Page 22 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 9.0 Plan Revisions The Licensee, in consultation with the Forest Service will review, update, and/or revise the Plan, as needed, when significant changes in the existing conditions occur. Sixty days will be allowed for the Forest Service to provide written comments and recommendations. After consultation and agreement with Forest Service, the Licensee will work with the Forest Service to file the updated Plan with FERC. The Licensee will include all relevant documentation of coordination and consultation with the updated Plan filed with FERC. If the Licensee does not adopt a recommendation by Forest Service, the filing will include the reasons for not doing so. The Licensee will implement the Plan as approved by FERC. For administrative Plan updates, such as contact names and phone numbers, current information will be filed with FERC and provided to the Forest Service. March 2020 Page 23 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan SECTION 10.0 References Butte County Office of Emergency Services. 2011. Butte County Emergency Operations Plan. Available online: http://www.buttecounty.net/cob/Agendas/2011/Agenda_031511/3.10.pdf. Accessed: January 2020. California Building Standards Commission. 2016. 2016 California Fire Code. California Code of Regulations, Title 24, Part 9. Based on the 2015 International Fire Code. Effective January 1, 2017. California Building Standards Commission. Sacramento, California. CAL FIRE (California Department of Forestry and Fire Protection). 2018. 2018 Strategic Fire Plan for California. State Board of Forestry and Fire Protection. Available online: https://osfm.fire.ca.gov/media/5590/2018-strategic-fire-plan-approved- 08_22_18.pdf. Accessed: January 2020. CAL FIRE (California Department ofForestry and Fire Protection). 2012. Unit Strategic Fire Plan Lassen-Modoc-Plumas. Available online: https://www.landcan.org/article/Unit- Strategic-Fire-Plan-2012--LassenModocPlumas/2902. Accessed: January 2020. CAL FIRE (CaliforniaDepartment ofForestry and Fire Protection). 2007. Fire Hazard Severity Zones in SRA; adopted by Cal Fire on November 7. 2007. Available at: http://frap.fire.ca.gov/webdata/maps/butte/fhszs_map.4.pdf. Accessed: January 2020. CAL FIRE (California Department of Forestry and Fire Protection). 2008. Power Line Fire Prevention Field Guide. Forest Service (USDA Forest Service). 1999. Wildland Fire Prevention Handbook. FSH 5109.18. Amendment No. 5109.18-99-1. Available online https://www.fs.fed.us/ im/directives/dughtml/fsh5000.html Forest Service (USDA Forest Service). (n.d.) Fire Management Programs and Policies. Husari, Susan J. Pacific Southwest Region. Available online http://www.fs.fed.us/ psw/publications/4251/husari.pdf Forest Service (USDA Forest Service). 2020a. Fire Restrictions and Regulations. Plumas National Forest. Available online: https://www.fs.usda.gov/detail/plumas/home/?cid=stelprdb5374320. Accessed: January 2020. Forest Service (USDA Forest Service). 2020b. Wildland Fire Management. Available online: https://www.fs.usda.gov/managing-land/fire. Accessed: January 2020. March 2020 Page 24 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project, FERC Project No. 2107 Fire Prevention and Response Plan Forest Service (USDAForest Service). 1988. Plumas National ForestLand and Resource Management Plan, as amended in 2004 (USDA Forest Service 2004) and 2007 (USDA Forest Service 2007). Pacific Southwest Region, CA. USDA Forest Service. 2000. Water quality management for forest system lands in California – Best Management Practices. U.S. Department of Agriculture, Forest Service, Pacific Southwest Region. September 2000. USDA Forest Service 2019. California Interagency Mobilization Guide, 2019. US Forest Service, California Department of Forestry and Fire Protection, Bureau of Land Management, National Park Service, Bureau of Indian Affairs. Available online: https://gacc.nifc.gov/oncc/mob_guide/2019/2019CA_Mob_Guide.pdf. Accessesd: January 2020. ———. 2012. National Best Management Practices for Water Quality Management on National Forest System Lands. Vol. 1: National Core BMP Technical Guide. (FS -990a.) April. U.S. Department of Agriculture, Forest Service. Wildland Fire Leadership Council. 2003. Interagency Strategy for the Implementation of Federal Wildland Fire Management Policy. Available online: https://www.sierraforestlegacy.org/Resources/Community/SmokeManagement/AirQ ualityPolicy/FedWldFireMgmtPolicy.pdf. Accessed: January 2020. March 2020 Page 25 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company A TTACHMENT 1 A: FERC ARTICLE 401 – APPENDIX COMMISSION APPROVAL, REPORTING, NOTIFICATION,AND FILING OF AMENDMENTS(FERC2018) March 2020 Page 1 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company APPENDIX A: FERC ARTICLE 401 – COMMISSION APPROVAL, REPORTING, NOTIFICATION, AND FILING OF AMENDMENTS (FERC 2018) (a) Requirement to File Plans for Commission Approval The State Water Resources Control Board’s (Water Board) section 401 water quality certification (WQC) (Appendix A) and the U. S. Department of Agriculture – Forest Service’s (Forest Service) section 4(e) conditions (Appendix B) require the licensee to prepare plans in consultation with other entities for approval by the Water Board or Forest Service or for submittal to the Commission, and implement specific measures without prior Commission approval. The following plans must also be submitted to the Commission for approval by the deadlines specified below: Water Board WQC Forest Service 4(e) Plan Name Commission Due Date Condition No. Condition No. Within 1 year from license issuance Fire prevention, response, - 7 and investigation plan *excerpt from FERC 2018 Article 401 With each plan filed with the Commission, the licensee must include documentation that it developed the plan in consultation with the above-listed agencies and provide copies of any comments received, as well as its response to each comment. The Commission reserves the right to make changes to any plan filed. Upon Commission approval, the plan becomes a requirement of the license, and the licensee must implement the plan, including any changes required by the Commission. Any changes in the above schedule or plans require approval by the Commission before implementing the proposed change. March 2020 Page 2 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company A TTACHMENT 2 A PPENDIX B - USFS SECTION 4E FERC RESOURCECONDITIONS March 2020 Page 3 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company CUI//CEII – DO NOT RELEASE FERC Appendix B - USFS SECTION 4E RESOURCE CONDITIONS Condition No. 7: Fire Prevention, Response, and Investigation Plan Within one year of license issuance the Licensee shall file with the Commission a Fire Prevention and Response Plan that is approved by the Forest Service, and developed in consultation with appropriate State and local fire agencies. The plan shall set forth in detail the Licensee’s responsibility for the prevention (excluding vegetation treatment as described in Condition 29) reporting, control, and extinguishing of fires in the vicinity of the project resulting from project operations. At a minimum the plan shall address the following categories: 1. Fuels Treatment/Vegetation Management: Identification of fire hazard reduction measures to prevent the escape of project-induced fires. 2. Prevention: Availability of fire access roads, community road escape routes, helispots to allow aerial firefighting assistance in the steep canyon, water drafting sites and other fire suppression strategies. Address fire danger and public safety associated with project induced recreation, including fire danger associated with dispersed camping, existing and proposed developed recreation sites, trails, and vehicle access. 3. Emergency Response Preparedness: Analyze fire prevention needs including equipment and personnel availability. 4. Reporting: Licensee shall report any project related fires to the Forest Service within 24 hours. 5. Fire Control/Extinguishing: Provide the Forest Service a list of the locations of available fire suppression equipment and the location and availability of fire suppression personnel. Include appropriate measures from Condition 29 and assure fire prevention measures will conform to water quality protection practices as enumerated in USDA, Forest Service, Pacific Southwest Region, Water Quality Management for National Forest System Lands in California-Best Management Practices. Investigation of Project Related Fires The Licensee agrees to fully cooperate with the Forest Service on all fire Investigations. The Licensee shall produce upon request all materials and witnesses not subject to the attorney-client or attorney work product privileges, over which the Licensee has control, related to the fire and its investigation including: March 2020 Page 4 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company CUI//CEII – DO NOT RELEASE All investigation reports All witness statements All photographs All drawings All analysis of cause and origin All other, similar materials and documents regardless of how collected or maintained The Licensee shall preserve all physical evidence and give custody to the Forest Service of all physical evidence requested. The Forest Service shall provide the Licensee with reasonable access to the physical evidence and documents the Licensee requires in order to defend any and all claims, which may arise from a fire resulting from project operations, to the extent such access is not precluded by ongoing criminal or civil litigation. March 2020 Page 5 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company CUI//CEII – DO NOT RELEASE Filed with FERC as CUI//CEII – DO NOT RELEASE Copies available to Forest Service and/or CAL FIRE Upon Request Attachment 3 PG&E FIRE PREVENTION AND CONTROL PROCEDURES (This Fire Response Plan references the following procedures that are periodically updated. The most current procedure is always available to employees, but may not be reflected in this Plan) Attachment 3-1: Utility Standard: RISK-7510S - Fire and Risk Engineering Design for PG&E Facilities Attachment 3-2: Utility Standard: PG-1041S - Fire Protection Requirements and Design Criteria - Hydro Attachment 3-3: Utility Procedure: PG-1041P-01 - Fire Protection Risk Evaluation – Hydro Attachment 3-4: Utility Standard: TD-1464S – Preventing and Mitigating Fires While Performing PG&E Work Attachment 3-5: Utility Bulletin: TD-3322B-065 - Wildlife Fire Defensible Space for Substations March 2020 Page 6 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Enclosure C PG&E letter dated 3/11/2020 requesting approval Forest Service letter of approval dated 3/19/2020