HomeMy WebLinkAbout01.08.21 BOS Correspondence - FW_ Emergency Action Plan submitted in FERC P-2088-000 by Individual No Affiliation,et al.
From:Schuman, Amy
To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;Cook, Robin;Kimmelshue, Tod;Lambert, Steve;Lucero, Debra;McCracken, Shari;Paulsen, Shaina;Pickett, Andy;Ring,
Brian;Ritter, Tami;
Rodas, Amalia;Sweeney, Kathleen;Teeter, Doug
Subject:BOS Correspondence - FW: Emergency Action Plan submitted in FERC P-2088-000 by Individual No Affiliation,et al.
Date:Friday, January 8, 2021 8:06:23 AM
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
O: 530.552.3300 |D: 530.552.3308 | F: 530.538.7120
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-----Original Message-----
From: 'FERC eSubscription' <eSubscription@ferc.gov>
Sent: Friday, January 8, 2021 5:25 AM
Subject: Emergency Action Plan submitted in FERC P-2088-000 by Individual No Affiliation,et al.
.ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying..
On 1/8/2021, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.:
Filer: Individual No Affiliation
South Feather Water & Power Agency (as Agent)
Docket(s): P-2088-000
Lead Applicant: South Feather Water and Power Agency
Filing Type: Emergency Action Plan
Description: South Feather Water & Power Agency submits Plan and Schedule for formatting revisions to the 5-year Emergency Action Plan reprint. Under P-2088.
To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20210108-
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January 7, 2021 Electronically Filed
Frank L. Blackett, P.E., Regional Engineer
100 First Street, Suite 2300
San Francisco, CA 94105
RE:South Feather Power Project (FERC No. 2088)
Emergency Action Plan 5-year Reprint
Dear Mr. Blackett,
This letter serves as a response to your letter dated December 1, 2020 requesting a plan and schedule
for addressing your comments on the 5-year reprint of the Emergency Action Plan (EAP) for the high
hazard dams associated with South Feather Power Project, FERC No. 2088. As was noted in our 2020
EAP Status Report, efforts to carry out the reprint of the EAP began following the face to face binder
holder meeting in December 2019. Staff worked diligently to comply with the content requirements
set forth in Chapter 6 of the FERC Engineering Guidelines, while at the same time working to comply
with requirements defined in California Water Code, Title 23, Division 3, Part 1, Chapter 4, Article 6,
§6161 which delegates the California Office of Emergency Services as the entity to review and approve
an emergency action plan pursuant to California Government Code §8589.5. A significantly revised EAP
was submitted to FERC and Cal OES on October 13, 2020.
o By way of letter dated December 1, 2020, yourejected the format of the submitted EAP,
and requested that the EAP follow the format outlined in Chapter 6, Section 6-3.2.
o By way of letters dated November 4, 2020 and December 11, 2020, Cal OES provided
upward of 33 comments as to why they rejected the format of the submitted EAP, and
provided direction to follow FEMA Federal Guidelines for Sam Safety: Emergency Action
Planning for Dams.
It is an impossibility to compile an EAP that will satisfy the outline requirements of both FERC and Cal
OES. SFWPA believes it would be an extreme hardship to expect all 39 of our binder holders to maintain
two binders in order to satisfy the expectations of both regulatory agencies. This Agency would like to
request that FERC assert jurisdiction over the EAP formatting as outlined in Chapter 6 of the FERC
Engineering Guidelines, as well as California Water Code, Title 23, Division 3, Part 1, Chapter 4, Article
6, §6160(d), which states “An owner of a dam that is jointly regulated by the state and the Federal
Energy Regulatory Commission shall prepare an emergency action plan in accordance with the Federal
Energy Regulatory Commission guidelines.”
In the meantime, I am working to reconfigure the EAP so that the existing contents of the document
are laid out as required in the EAP Outline as defined in Section 6-3.2 of the guidelines. This revision
will be submitted to you no later than January 29, 2021.
If you have any questionsrelated to this transmittal, please feel free to contact me directly at
(530) 534-1221 x 265, or via email at kmckillop@southfeather.com.
Sincerely,
South Feather Water and Power Agency
Kristen McKillop
Compliance and Regulatory Manager
cc: Rath Moseley, General Manager
Dan Leon, Power Division Manager
Jaymie Perrin, Environmental Health & Safety Manager