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Home My WebLink About12.23.20 BOS Correspondence - FW_ Comment on Filing submitted in FERC P-2107-000 by Individual No Affiliation,et al. From:Schuman, Amy To:Alpert, Bruce;Bennett, Robin;Clerk of the Board;Connelly, Bill;Cook, Holly;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: Comment on Filing submitted in FERC P-2107-000 by Individual No Affiliation,et al. Date:Wednesday, December 23, 2020 1:22:41 PM 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 Twitter | Facebook | YouTube | Pinterest -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Wednesday, December 23, 2020 10:45 AM Subject: Comment on Filing submitted in FERC P-2107-000 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 12/22/2020, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Individual No Affiliation No Organization Found (as Agent) Docket(s): P-2107-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Comment on Filing Description: Comment of Mike F Taylor under P-2107. To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist? accession_num=20201222-5224__;!!KNMwiTCp4spf!VxzFALp3Apykl_0GJ- nRYehk3UNLTyPcqJY7Fkt4fjoAexDN4Z5Vj76BY-3KFAJhiMIu2z95uH4$ To modify your subscriptions, click here: https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!VxzFALp3Apykl_0GJ- nRYehk3UNLTyPcqJY7Fkt4fjoAexDN4Z5Vj76BY-3KFAJhiMIuNRI539E$ ------------------------------------------------------------------------ Please do not respond to this email. Online help is available here: https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!VxzFALp3Apykl_0GJ- nRYehk3UNLTyPcqJY7Fkt4fjoAexDN4Z5Vj76BY-3KFAJhiMIu9HyIRMs$ or for phone support, call 866-208-3676. Mike Taylor 1308 Mount Ida Road Oroville, CA 95966 530-589-0434 ljmftaylor68@gmail.com December 22, 2020 Via Electronic Submittal(E File) Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 Re:Comments regarding July 30, 2020 submittalto FERC by PG&E concerning Poe Hydroelectric Project, FERC No. 2107-CA, Article 407–Hiking Trail Feasibility Study. Dear Secretary Bose: The Pacific Gas and Electric Company (PG&E) stated in their July 30, 2020 submittal that neither the Bardees Bar Trial nor the Poe Hiking Trail isfeasible.I believe that the position taken by PG&E is incorrect and that the Poe Hiking Trail is feasible and can be constructed at reasonable cost. Background There is far more to the Poe trail than a mere conceptas stated in the PG&E comments of July 30, 2020. As Forest Service representative during Poe Project relicensing I became very familiar with the North Fork Feather River downstream from Bardees Bar.Each time I dropped down from the Bardees Bar Road to the riveror walked along the river I encountered trail fragments of various length and condition. It became clear that a historic and long abandoned trailusedfor mining access ran from the vicinity of the junction of the Bardees Bar Road and the Windy Gap Road downstream to a place known as Yankee Bar.Ditches were locateddownstream from Yankee Barthat extended trail access to a point below the Poe Powerhouse Road.In all,approximately three miles of historic trail and associated ditches were located. After retirement, another retiree and I brushed,logged out, removed slough and, in places reconnected trail fragmentseventually completing a nearly continuous trail of around three miles in length that ranged from one and one-half feetto three feet in width. The existing trail was even wider in some areas.Trail fragments were often found hidden beneath dense brush. Each fragment located helped fill the route and dimension of the trail. The trail exists. It is not conceptual as PG&E claims. There are nearly three miles of walkable trail. Granted the trail is not continuous, has some workable engineering challenges and will require several thousand feet of new construction to reach the proposed Poe Powerhouse Road trailhead but conceptual it is not.The shifting of the Poe Powerhouse Road trailhead as proposed would require additionalnew trail construction notoriginally anticipated.The trail follows a historic mining access trail and historic ditches. Nevertheless,PG&E asserts in the July 30, 2020 submittal that the “… proposed alignment of the trail does not correspond with any existing or historic trail.” The clearest justification for the Poe trail is found in the second paragraph on page 11 of the July 2020 Butte County Resource Conservation District (BCRCD)Poe Hiking Trail Feasibility Studyidentified as Attachment 1 of the July 30 PG&E submittal.The trailalsotraverses the last North Fork Feather River reach nearly entirelyfree of visual impairment byHighway 70 or the Union Pacific Railroad. The reachis in essence topographically as itwasbefore the arrival of Europeans. There are opportunitiesto interpret Native American use and historic mining that hastaken place along the river. Mining evidence consistsof streambank excavation, windrowing of stones and boulders moved in search of gold,a low dam used to capture storm runoff for sluicing of slopes, the trail itself,and ditches now used as trails.The trail traverses three rock outcrops where significant excavation was needed when constructed in the 1800s.There is also a large pile of boulders placed by a long-gone lifting devicelocated at the end of a short spur trail that is not part of this proposalbut could easily be includedto provide additional river access. Evidence of Native American use is lessobvious but nonetheless present. Comments PG&E has described the merely obvious challenges but has not evaluated each in detail. It is premature to state that the trail is not feasible without knowing cultural resource and foothill yellow-legged frog habitat locations along with any necessary mitigation. The same might be said regarding access across private land without first contacting the landowners to determine access requirements. Stating unilaterally that the trail is not feasible with only incomplete information does not make it so. Bardees Bar Trail: During project relicensing, I walked the road from BardeesBar to Highway 70. The road was constructed in 1907 or so by the Utah Construction Company to facilitate construction of the Western Pacific Railroad. The lower portion of the road provides rather spectacular views of the railroad that would be sought after by rail enthusiasts. During Highway 70 construction,side casting from the road created several debris slides that crossed the construction road rendering the road unusable and making conversion of the road to a trail problematic. The road now ends at Highway 70 at a place where there is no room for a trailhead. With Bardees Bar inaccessible by road and no feasible trailhead on Highway 70, conversion of the road to a trail would provide little public benefit. Poe Trail Design: The BCRCD Poe Hiking Trailfeasibility evaluation was conducted with the assumption that the trail would be constructed to USFS trail Class 3 specifications with a four-foot width and a maximum grade of 5 percent.Forest Service FSH 2353, Section 14.2, Exhibit 01 identifies the attributes of the five trail classes utilized by the Forest Service. The proposed trail class, Class 3, fits the terrain and expected use. Class 3 standards allowvariation in trail width and trail grade. Grades up to 12 percentand short pitches up to 25 percent fall within the Class 3 definition. Terrain often dictates adaptive measures. Engineering flexibility is needed at times to overcomelocal conditions. Existing stable trail is still stable and useable even if it is notfour feet in width. Hardening of short, steep pitches with rock or steps will maintain the existing trail corridor without the necessity of new construction with switchbacks in order to maintain the desired 5 percent grade. Portions of the trail have been in place in a nearly unaltered state since the 1800s. These segments might not be four feet in width but why would they now be deemed unsuitable for use? Why would these historic features be significantly altered in order to satisfy a standardized trailwidth? A trail of nominal width located on gentle side slopes need not be reconstructed to four feet in width to make it useable. Figure 8 of the BCRDC Poe Hiking Trail Feasibility Study shows a portion of trail traversing a rather stoney area with little vegetation. The trail is stable, well defined and has been in place for decades, yet it would be widened to four feet with little benefit to utility. It is difficult to evaluate the cost estimates provided by PG&E since no supporting documentation such as cost incurred on similar projects was provided. The BCRCD trail cost estimate is considerably less than the PG&E estimate and was provided by a professional recreation trail developer. Assuming a trail length of 3.6 miles, Poe Trail FERC No. 2107-CA Page 2 the PG&E cost per foot including trailhead construction would be $130.12 while the BCRCD estimated cost is $33.98 per foot. Discussion of the cost disparity with agencies, organizations and individuals who have worked with PG&E during the relicensing and license implementation process would be a logical next step. Private Property:While agreement to cross the private land is certainly needed,it would seem unnecessarily hasty to assume that agreement would not be forthcoming without first contacting the landowners regarding approval to cross and possible terms and conditions. The trail, actually a ditch in this case,located on private land in the SE ¼, SE ¼, Section 24 is substantially complete but will require a short reroute around a rather large Douglas-fir tree and stabilization of one steep pitch. The portion of ditch/trail in question is not four feet in width but has been in place without maintenance for quite a few decades andis perfectly suitable for hiking. Figure 1 of the BCRDC Poe Hiking Trail Feasibility Studyshows a portion of the trail on the private land in question. The trail at this location crosses a limestone outcrop. The private land in Section 13 is more challenging with a stream crossing, steep side slopes, minimal trail width in places and new construction needed in others. Environmental Resources:Agreed, the full impact of the trail on heritage resource sites, foothill yellow- legged frog habitat and botanical resources is unknown. To imply that resource constraints make the project infeasible without first knowing the location of sensitive areas and determining if mitigation is feasible seems a stretch. Surveys are needed to determine if mitigation of impacts such as rerouting or modification of the 5 percent grade/four-foot tread width construction template would satisfy concerns. For example, BCRDC Poe Hiking Trail Feasibility Study proposes the construction of 12 switchbacks traversing a historic mining site at the upstream portion of the trail in order to maintain the desired 5 percent grade. An existing trail covers the same ground and could be used with hardening of steep pitches thus avoiding soil disturbance in the historic site. There is also the possibility of reopening anearbyabandoned portion of the trail in order to avoid a steep pitch. The PG&E Poe Trail cost estimate shown in Attachment 2 of the July 30, 2020 submittal does not indicate the number of trail stream crossings. Figure 3a of the BCRDC Poe Hiking Trail Feasibility Study identifies 14 stream crossings. All but two of the crossings would be made with stone bridges. In bothinstancescrossings are not identified on maps making specific locations difficult to determine. It is agreed that stone bridges are preferable in fire prone areas. The BCRCD study lists rock cobbling at two crossings. Several stream crossings in addition to the two mentioned are intermittentin natureand quite adaptable to rock cobbling. There are two “one boot wet” perennial streamsthat are quite adaptable to cobbling.I have never seen water in five channels. Improving the trail for public use is feasible at a reasonable cost. A great deal of “concept” can currently be walked. I can be reached at 530-589-0434 if you have any questions concerning my comments. Sincerely, Mike Taylor cc: via email Steve Bauman (PG&E) Amy Lind (Forest Service) Dave Steindorf (American Whitewater Poe Trail FERC No. 2107-CA Page 3