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HomeMy WebLinkAbout12.28.20 BOS Correspondence - FW_ Procedural Motion 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;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: Procedural Motion submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al. Date:Monday, December 28, 2020 1:33:37 PM Good afternoon, Please see the email correspondence 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: Monday, December 28, 2020 1:25 PM Subject: Procedural Motion 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 12/28/2020, 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: Procedural Motion Description: Pacific Gas and Electric Company Request for Approval of the Integrated Vegetation Management Plan Regarding Condition Nos. 12, 29 and 34 for the Poe Hydro Project under P- 2107. To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20201228- 5318__;!!KNMwiTCp4spf!R2rN767li8eDFwrULjmfcRmOaD01xdDm17PiEmvoORbUsfZ0xgLSoahSRr4jEVz451P1GZ_pGOE$ To modify your subscriptions, click here: https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!R2rN767li8eDFwrULjmfcRmOaD01xdDm17PiEmvoORbUsfZ0xgLSoahSRr4jEVz451P1bFbIJyg$ ------------------------------------------------------------------------ Please do not respond to this email. Online help is available here: https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!R2rN767li8eDFwrULjmfcRmOaD01xdDm17PiEmvoORbUsfZ0xgLSoahSRr4jEVz451P1gFVPm1Q$ or for phone support, call 866-208-3676. 245 Market Street tƚǞĻƩ DĻƓĻƩğƷźƚƓ San Francisco, CA 94105 Mailing Address: Mail Code N11D P.O. Box 770000 San Francisco, CA 94177 December 28, 2020 Via Electronic Submittal (E-File) Ms. Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426 Subject: Poe Hydroelectric Project, FERC Project No. 2107 Condition Nos. 12, 29, and 34 Integrated Vegetation Management Plan Request for Approval Dear Secretary Bose: Pacific Gas and Electric Company (PG&E) is writing to seek your approval of the attached Integrated Vegetation Management Plan (Enclosure 1) Hydroelectric Project, Federal Energy Regulation Commission (FERC) Project No. 2107 (Project). On December 17, 2018, FERC issued a new license for the Project (License). Subsection (a) of Article 401 and 403 of the License requires PG&E to submit the final Plan that has been approved by the Forest Supervisor of the Plumas National Forest (Forest Service) in consultation with the California Department of Food and Agriculture (CDFA), and the Butte County Agricultural Commissione FERC approval by December 17, 2020. On December 12, 2019, PG&E proposed development of an Integrated Vegetation Management Plan to satisfy the Invasive Weed Management Plan requirements of Article 403 and Condition No. 34, as well as the Fuel Treatment Plan requirement of Article 401 and Condition No. 29. The FERC order amending Article 401 and approving development of an Integrated Vegetation Management Plan was issued on January 6, 2020, and extended the filing deadline to December 31, 2020. On December 15, 2020, PG&E submitted the Plan for formal approval from the Forest Service. The Forest Service approved the Plan, by letter dated December 16, 2020. The Plan was developed in consultation with CDFA, the Butte County Agricultural Ms. Kimberly D. Bose, Secretary December 28, 2020 Page 2 Coordinator, Mr. Matthew Joseph, at 530-889-3276 or at Matthew.Joseph@pge.com. Sincerely, Matthew Joseph (for) Elisabeth Rossi Supervisor, Hydro Licensing Enclosure: 1. Poe Integrated Vegetation Management Plan Enclosure 1 Poe Integrated Vegetation Management Plan PACIFIC GAS AND ELECTRIC COMPANY Poe Hydroelectric Project FERC Project No. 2107 POE INTEGRATED VEGETATION MANAGEMENT PLAN Prepared for: Pacific Gas & Electric Company 3401 Crow Canyon Road San Ramon, CA 94583 Prepared by: Garcia and Associates 435 Lincoln Way Auburn, CA 95603 December 2020 © 2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan POE HYDROELECTRIC PROJECT FERC PROJECT NO. 2107 POE INTEGRATED VEGETATION MANAGEMENT PLAN TABLE OF CONTENTS 1.0Introduction .......................................................................................................................1 2.0Goals of the Plan ...............................................................................................................2 3.0Project Location and Control Area.................................................................................5 4.0Invasive Weed Management ............................................................................................7 4.1Overview of Invasive Weed Management ..............................................................7 4.2Target Invasive Weed Species ................................................................................7 4.3Plan for Prevention and Control of Invasive Weeds ...............................................7 4.3.1Prevention Strategies ..................................................................................8 4.3.2Inventory, Mapping, Monitoring, and Reporting......................................14 4.3.3Control Measures and Schedule ................................................................19 5.0Wildfire Risk and Vegetation Management .................................................................21 5.1Wildfire Behavior and Modeling ..........................................................................21 5.1.1Current Risk Analysis/Resistance to Control...........................................22 5.1.2Fire Behavior Modeling Descriptions .......................................................26 5.2Vegetation Management for Fuels Treatment ......................................................29 5.2.1Fuels Treatment Objective ........................................................................30 5.2.2Fuel Treatment Methods ...........................................................................30 5.2.3Fuel Treatment Site Specifications ...........................................................31 5.3Vegetation Management Activities for Routine O&M .........................................34 5.3.1 Facility Vegetation Management ..............................................................34 5.3.2Transmission and Distribution Line Corridors .........................................34 5.3.3Roads.........................................................................................................35 5.3.4Recreation Facilities ..................................................................................36 5.3.5Hazard Tree Management.........................................................................37 6.0Vegetation and Invasive Weed Management Implementation ...................................39 6.1Annual Pre-Operations Consultation Meeting ......................................................39 6.2Control Treatment Decision Process ....................................................................40 6.3Forest Service Herbicide Use Consultation Process .............................................40 6.4Annual Employee Training ...................................................................................41 6.5Pre-Treatment Field Preparation ...........................................................................41 6.6Vegetation Management Methods ........................................................................42 December 2020 Page i Table of Contents Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6.6.1Manual Control.........................................................................................42 6.6.2Mechanical Control ...................................................................................43 6.6.3Cultural Control ........................................................................................44 6.6.4Chemical Control ......................................................................................44 6.7Special-status Plant Surveys .................................................................................48 6.7.1Special-status Plant Survey Objectives .....................................................49 6.7.2Special-status Plant Survey Schedule and Location .................................49 6.7.3Special-status Plant Survey Protocol and Reporting ................................50 6.7.4Monitoring Regular Invasive Weed Control and O&M Disturbance Activities ...................................................................................................50 6.7.5Monitoring Planned Disturbance Activities ..............................................51 6.8Environmental Protection .....................................................................................48 6.8.1Avoidance and Minimization Measures for Special-status Plants and Wildlife ..................................................................................................... 52 6.8.2Best Management Practices ......................................................................53 6.8.3Streamside Management Zones ................................................................54 7.0Revegetation ....................................................................................................................56 7.1Areas and Activities Subject to Revegetation .......................................................56 7.2Evaluation of Sites for Revegetation ....................................................................56 7.3Revegetation .........................................................................................................57 7.3.1Revegetation Planning ..............................................................................57 7.3.2Revegetation Methods ..............................................................................59 7.3.3Revegetation Monitoring ..........................................................................61 8.0Plan Revisions..................................................................................................................62 9.0References ........................................................................................................................63 December 2020 Page ii Table of Contents Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan LIST OF ATTACHMENTS Attachment A. FERC License Requirements Addressing Invasive Weed Management Attachment B. CDFA Noxious Weed Species Lists A, B, and Q Attachment C. Plumas National Forest Invasive Weed List Attachment D. Best Management Practices (BMPs) Attachment E. Plumas National Forest Invasive Weed Form Attachment F. Fire Behavior and Modeling Figures Attachment G. Fuel Treatment Prescription Maps Attachment H. Water Quality Sampling Protocol Attachment I. Plumas National Forest Revegetation Mix List Attachment J. Representative Photographs of the Poe Project LIST OF FIGURES Figure 3-1. Project Location PG&E Poe Project FERC No. 2107 .................................................6 Figure 5-1. Energy Release Component for the Plumas National Forest, West Zone ..................23 Figure 5-2. Flame Length and Flame Height Measurement .........................................................25 LIST OF TABLES Table 4-1. Invasive Weed Species Known to Occur within the Project FERC Boundary, (PG&E 2003) ....................................................................................................8 Table 4-2. Proposed Target Invasive Weed Management Schedule ............................................20 Table 5-1. Fire Behavior Indicators ..............................................................................................24 Table 5-2. Resistance to Control (RTC) Calculation Matrix ........................................................24 Table 5-3. Resistance to Control (RTC) Interpretation Matrix .....................................................26 Table 5-4. FireFamilyPlus Weather Data Used for FlamMap Analysis .......................................28 Table 5-4. Mean Fire Behavior Characteristics for Poe Project Facilities and Recreation Sites .................................................................................................................29 Table D-1. Buffer Strip Widths for Streams and Ditches ...........................................................D-9 December 2020 Page iii Table of Contents Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan LIST OF ACRONYMS o Cdegrees Celsius o F degrees Fahrenheit BAER burned area emergency response BMP Best Management Practice BTUBritish thermal unit CalEPACalifornia Environmental Protection Agency CalFire California Department of Forestry and Fire Protection CDFA California Department of Food and Agriculture CDFG California Department of Fish and Game CDFW California Department of Fish and Wildlife (formerly California Department of Fish and Game) CDPR California Department of Pesticide Regulation CESA California Endangered Species Act COC chain of custody Control Area 1,689 acres: all lands within the FERC boundary, including NFSL, and PG&E parcels adjacent to the FERC boundary CPRC California Public Resource Code EA Environmental Assessment ERC energy release component ESA federal Endangered Species Act FERCFederal Energy Regulatory Commission Forest Service United States Department of Agriculture Forest Service FSH Forest Service Handbook gpa gallons per acre GIS geographic information system GPS global positioning system IPM Integrated Pest Management HRD Heterobasdion root disease Landfire Landscape Fire and Resource Management Planning Tools program Licensee Pacific Gas and Electric Company December 2020 Page iv Table of Contents Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan MSO methylated seed oil NAD83 North American Datum of 1983 NEPA National Environmental Policy Act NERC North American Electric Reliability Corporation NFDRS National Fire Danger Rating System NFFRNorth Fork Feather River NFSL National Forest System Lands No. Number NRIS Natural Resource Information System O&M operations and maintenance PCA pest control advisor PCO pest control operator PG&E Pacific Gas and Electric Company Plan Poe Integrated Vegetation Management Plan Project Poe Hydroelectric Project, FERC Project No. 2107 psi pounds per square inch PUP pesticide use proposal, Forest Service 2100 Form QA/QC quality assurance/quality control RAWS Forest Service remote automated weather stations RTC Resistance to Control SERA Syracuse Environmental Research Associates SMZ Streamside Management Zone TECS threatened, endangered, candidate, or sensitive U.S.United States USDOI United States Department of the Interior USFWS United States Fish and Wildlife Service UTM Universal Transverse Mercator December 2020 Page v Table of Contents Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 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 Hydroelectric Project, Federal Energy Regulatory Commission (FERC)Project Number (No). 2107(Project), located in Butte County, California (FERC 2018). FERC Article 403 of the License, and Forest Service 4(e) Condition Nos. 34 and 12 (Forest Service 2018) require the development of an Invasive Weed Management Plan, and otherwise address use of pesticides on National Forest System Lands (NFSL) within the Project. This document, Poe Integrated Vegetation Management Plan (Plan), presents the program to comply with the FERC License invasive weedmanagement, operations and maintenance (O&M) vegetation management, and pesticide use requirements. The relevant FERC Article and Condition requirements applicable to this Plan aresummarized below andprovided inAttachment A. The Plan was developed in consultation with theCalifornia Department of Food and Agriculture (CDFA), the Butte County Agricultural Commissioner’s Office, and the Unites States Department of Agriculture Forest Service (Forest Service), Plumas National Forest. December 2020 Page 1 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 2.0 Goals of the Plan The Plan serves to comply with requirements of the FERC License. Article 403 of the License and Forest Service 4(e) Condition No. 34 require the development of an Invasive Weed Management Plan. Article 401 of the License and Forest Service 4(e) Condition No. 29 requires the development of a Fuel Treatment Plan and Forest Service 4(e) Condition No. 12 addresses the use of pesticides onNFSL within the Project. On December 12, 2019, the Licensee proposed development of an Integrated Vegetation Management Plan to satisfy the Invasive Weed Management Plan requirements of Article 403 and Condition No. 34 as well as the Fuel Treatment Plan requirement of Article 401 and Condition No. 29. The FERC order amending Article 401 and approving development of an Integrated Vegetation Management Plan was issued on January 6, 2020. This Plan has been developed to meet the requirements of License Articles 401 and 403, Forest Service Condition No. 12, and Forest Service Condition Nos. 29 and 34. The relevant FERC Article and Condition requirements applicable to this Plan are provided in Attachment A. This Plan presents the program to comply with the FERC License invasive weed and fuel treatment requirements. This Plan describes a program to prevent introduction and minimize spread of invasive weeds that are potentially associated with Project activities. To achieve this goal, this Plan includes measures to control invasive weeds and to monitor and track both the distribution of invasive weeds and the success of invasive weed control activities in the Project’s Control Area (defined inSection 3.0). The Plan also addresses general vegetation management as part of O&M activities and fuel treatment requirements. The License requires O&M vegetation management activities around Project facilities, including maintaining access to facilities and reducing fire risk by limiting the presence of ladder fuels, removing herbaceous vegetation along access roads, and thinning existing trees and shrubs in the Project boundary; an analysis of fire risk within 300 feet of facilities is included in this Plan. Because the methods and locations for both invasive weed control and O&M vegetation management are similar, this Plan includes a description of the O&M vegetation management program. Measures undertaken with respect to this Plan will be December 2020 Page 2 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan coordinated by the Licensee with other resource efforts and will, as necessary, consider all applicable requirements set forth in other Project-related management plans, as summarized below. Erosion Control Measures Plan Forest Service Condition No. 13 is an administrative measure that requires development of an Erosion Control Measures Plan prior to certain new construction or non-routine maintenance projects. If triggered, Condition No. 13 could include revegetation requirements upon completion of the applicable new construction or non-routine maintenance project. Recreation Management Plan Recreation Management Plan requirements are described in Article 401, Article 404, Water Quality Certification Condition 8, and Forest Service Condition No. 26 of the License. The Recreation Management Plan identifies a construction and maintenance program related to the new recreation facilities that are planned within the FERC Project Boundary. These planned recreation facilities are, from north to south, Poe Reservoir Access Trail, Sandy Beach, Bardee’s Bar River Access, Poe Beach Trail, and Poe Powerhouse River Access. As described in the Recreation Management Plan, O&M at recreation facilities could involve activities such as hazard tree removals, trail brushing, trimming, and limb removals. Since the Poe Reservoir Access Trail is in the FERC Boundary for the Rock Creek-Cresta License for FERC Project No. 1962, these O&M activities for this trail are managed under that License. Road Management Plan Road Management Plan requirements are described in Article 401, Water Quality Certification Condition 12, and Forest Service Condition No. 37 of the License. Approximately 3.4 miles of Project roads are contained within the Project FERC boundary and identified in the Road Management Plan. Road maintenance responsibilities, implementation schedules, and Forest Service standards (such as Forest Service Handbook \[FSH\] and/or Best Management Practice \[BMP\] references) are also identified in the Road Management Plan. December 2020 Page 3 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Fire Prevention and Response Plan Fire Prevention and Response Plan requirements are described in Article 401, and Forest Service Condition No. 7 of the License, and apply to all Project features in the FERC boundary (e.g., Poe Powerhouse, Switchyard, and Dam; all recreation sites; etc.). The Fire Prevention and Response Plan provides guidance for fire prevention procedures, safe fire practices, and reporting for Licensee’s personnel and contractors who are responsible for operating and maintaining the Project. December 2020 Page 4 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 3.0 Project Location and Control Area The Project is located along an approximately 7.62-mile bypassed reach (Poe Bypass Reach; Figure 3-1) of the North Fork Feather River (NFFR) in Butte County, California. The Project FERC boundary (shown in gray on Figure 3-1) encompasses approximately 313 acres, including 157 acres of PG&E fee-title property, 144 acres of NFSL managed by the Forest Service (Plumas National Forest), and 12 acres of private land. Within the FERC boundary, O&M vegetation management may occur anywhere. The Control Area for invasive weeds includes all lands within the FERC boundary, including PG&E fee-title property and NFSLwithin the FERC boundary(301 acres), and adjacent PG&E fee-title parcels (1,388 acres; total Control Area approximately 1,689 acres). The Project is located in forested lands that are sparsely populated. The Project FERC boundary includes Poe Powerhouse, Poe Dam, Poe Tunnel, and associated access roads and appurtenant facilities. Big Bend Reservoir serves as the afterbay for the Project. The Project is located just upstream of Lake Oroville, the primary storage reservoir for the California Department of Water Resources’ Feather River Project (FERC Project No. 2100); and just downstream of Cresta Powerhouse, at the western end of PG&E’s Rock Creek–Cresta Project (FERC Project No. 1962). December 2020 Page 5 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Figure 3-1. Project Location PG&E Poe Project FERC No. 2107 December 2020 Page 6 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 4.0 Invasive Weed Management 4.1 Overview of Invasive Weed Management Invasive weeds are non-native plants that when introduced into an environment in which they did not evolve, compete with native plants, dominating and often damaging native plant communities. Invasive weedcontrolaids in the protection and conservation of native plant species, as well as the improvement of wildlife habitat and recreational user experience (United States Fish and Wildlife Service \[USFWS\] 2020). In some cases, invasive weed control also reduces habitat vulnerability to wildfire. 4.2 Target Invasive Weed Species Under the License requirements, invasive weeds for the Project are those aquatic and terrestrial invasive weeds defined by the CDFA, and other species identified by the Forest Service.As such, target invasive weed species, including aquatic invasive weeds, for the Project include all weeds rated as A, B, or Q by CDFA (3 CCR §4500. Noxious Weed Species, CDFA 2016, and Meyer et al.2010;Attachment B) and any invasive weed species designated bythePlumas National Forest (Attachment C). The target invasive weed species list is likely to change over time and can be updated on an ongoing basis as needed. Based on plant species present during the most recent Project relicensing survey (PG&E 2003), Table 4-1lists the invasive weedsknown to occur within the FERC boundarythat may be targeted for control. Other invasive weed species may also be present. 4.3 Plan for Prevention and Control of Invasive Weeds The goal of the invasive weed element of this Plan is to prevent and control the introduction and spread of invasive weeds potentially associated with Project activities. Forest Service 4(e) Condition No. 34 directs PG&E to inventory, map, and monitor known and new populations of December 2020 Page 7 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table 4-1. Invasive Weed Species Known to Occur within the Project FERC Boundary, (PG&E 2003) Plumas 1 Species Common Name (Scientific name) CDFA-rating National Forest List 2 Barbed goatgrass (Aegilops triuncialis) BYes 3 French broom (Genista monspessulana) CYes Himalayan blackberry (Rubus armeniacus) NoneYes 2 Yellow star-thistle (Centaurea solstitialis)CYes 1 CDFA rating definitions provided at the end of Attachment B. 2 Current rating available from CDFA 2016. 3 Species under review, and rating from CDFA 2016 not available. Rating from Meyer et al. 2010 provided. invasive weeds, and control new infestations of CDFA A-and B-rated weeds within 12 months of detection or as soon as practical and feasible; since CDFA treats Q-rated weeds similarly to A- rated weeds, Q-rated weeds are also included. BMPs to prevent the introduction and spread of invasive weed species will be incorporated into Project operations. PG&E will implement a comprehensive invasive weed control strategy that can be updated over time as conditions change. The invasive weed element of this Plan therefore has three main components: 1.Prevention strategies, including an education program and measures for aquatic invasive weeds; 2.Inventory, mapping, monitoring, and reporting; and 3. Control measures. Control measures are presented in general in Section 4.3.3, and further detailed in Section 6.0, which describes vegetation control methods for both target invasive weeds and O&M vegetation management. 4.3.1 Prevention Strategies Some routine O&M activities have the potential to affect the introduction or spread of target invasive weeds from one location to another, such as facility inspection and repair, vegetation management, and road maintenance. Project-related recreation activities and other public access may also introduce and spread target invasive weeds. Project features requiring routine December 2020 Page 8 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan maintenance and other periodic work, or having recreation-related disturbance include the following: Poe Dam and Intake; Poe Tunnel, Tunnel Adit 1, and Tunnel Adit 2; Sandy Beach; Bardee’s Bar River Access; Poe Beach Trail; Poe Powerhouse, Penstock, and Surge Chamber; Poe Powerhouse River Access; Project roads; and Appurtenant Facilities (gaging stations, access trails, landing zones, etc.). The following prevention strategies will be implemented to prevent the introduction and/or spread of target invasive weeds, including aquatic invasive weeds, within the Control Area. These prevention strategies include implementing an education program for PG&E employees and contractors, and the public; and requirements for equipment cleaning, and ground-disturbing activities including road maintenance. Project prevention strategies also include an adaptive management program for aquatic invasive weeds. Prevention strategies are described in further detail in the following sections. All measures for invasive weed prevention are provided in greater detail in Attachment D. 4.3.1.1 Education Program PG&E employees and contract maintenance personnel on the Project will receive annual environmental training, regarding the importance of preventing target invasive weed introduction and spread. This training will review the identifying characteristics of the target invasive weeds most likely to occur in the Project and directions to comply with FERC and Forest Service requirements. Training will follow Attachment D, Measure 1 Education. December 2020 Page 9 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 4.3.1.2Equipment Cleaning In order to prevent invasive weed introduction and spread, PG&E and its contractorsimplementing O&M activities or construction activities will ensure that all off-road equipment brought into the Project from outside the watershed is free of target invasive weed seeds and other propagules. Cleaning will follow Attachment D, Measure 2: Equipment Cleaning. 4.3.1.3 Ground-disturbing and Road Maintenance Activities To ensure that new infestations of target invasive weeds are not introduced, and existing infestations are not spread, prevention measures will be incorporated into all ground-disturbing activities including ground-disturbing road maintenance activities (e.g., grading or roadside ditch clearing). These prevention measures may be applied to any associated erosion control and revegetation activities as-needed. Prevention measures include adhering to such BMPs as limiting number and area of disturbance, avoiding known target invasive weed infestations, and using weed-free straw and mulch. The purpose of these BMPs is to minimize suitable habitat for target invasive weeds (i.e., disturbed ground with open canopy), minimize weed seed sources, and maximize discovering new infestations. A complete list of BMPs, including those for invasive weed prevention, are presented in Attachment D, Measures 3 to 8: Avoid Infestations, Use Existing Roads, Limit Disturbance Areas, Monitoring After Disturbance, Weed-free Materials, and Weed-free Feed. 4.3.1.4 Adaptive Management for Aquatic Invasive Weeds In some settings, aquatic invasive weeds (definition inSection 4.2)can become established, disrupting the aquatic environment and posing economic threats by altering the natural ecosystem, competing with native plant species, and threatening habitat for native fish and wildlife. Aquatic invasive weeds have also been known to negatively impact power generation in hydroelectric systems by clogging intake structures or interfering with reservoir volumes. In addition, if aquatic invasive weeds are established in a water body, they may spread to adjacent water bodies. Generally, aquatic invasive weeds have been unintentionally introduced to waterbodies in large part by recreational activities such as boating, angling, and waterfowl hunting. Theycan be December 2020 Page 10 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan transported in many ways including watercraft, trailers, motors, mining gear, fishing gear, dumping live bait, fishing lines and downrigger cables, and waders. The Poe Project is relatively small, and most recreationists drive to informal parking areas, then walk on trails to access the NFFR.Although Condition No. 34 addresses cleaning stationsat boat ramps, the Project does not include any developed boat ramps and has limited opportunities for recreational boating. Therefore, watercraft and equipment cleaning stations are not practical for this Project and would likely not be useful to prevent introduction and spread of aquatic invasive weeds. Many aquatic weeds are spread by small propagules such as stem fragments (DiTomaso et al. 2013). Manual and mechanical control methods have a high risk of spreading existing infestations byreleasing small propagules that drift and spread to new areas. Since herbicide application within waterbodies is legally limited, controlling an aquatic weed infestation once it is establishedcan be challenging. Prevention is the optimal method for limiting aquatic invasive weeds from causing ecological and economic damage. Therefore, the objectives of aquatic invasive weed management are as follows: Increase employee education; Prevent introduction; Minimize spread; Early detection of new infestations; and Rapid response to new infestations. Per License Condition No. 34, the following measures will be implemented to prevent the introduction and establishment of aquatic invasive weeds on the Project (also included in Attachment D, Measures 9 to 11: Personnel Education, Measures to Avoid Introduction of Aquatic Invasive Weeds; and Measures to Avoid Spreading Known Aquatic Invasive Weeds: 1. Personnel Education: PG&E will educate their Project personnel and contractors about the importance of preventing introduction and spread of aquatic invasive weeds. Educational materials will be made available, including specific suggested measures for preventing introduction and spread. December 2020 Page 11 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 1 2.Measures to Avoid Introduction of Aquatic Invasive Weeds: PG&E will implement the following measures to prevent aquatic invasive weed infestations: a. Regularly inspect and thoroughly clean and dry equipment(e.g., boats, waders, felt footwear, etc.) before entering a waterbody, and when moving equipment between projects, waterbodies, or sites. b. Heavy equipment will not be used in wetted areas to the extent practical. c. If feasible, work will take place in dry conditions during the dry season. Accessing parts of the Project from a boat or wading is permitted. d. Never move live organisms from one waterbody into another. e. Use elliptical and bulb-shaped anchors to avoid snagging aquatic materials. 2 3. Measures to Avoid Spreading Known Aquatic Invasive Weeds: If occurrences of aquatic invasive weeds are identified in Project waterbodies, PG&E will implement the following measures: a.Prior to any construction or disturbance activities within the waterbody, inspections for aquatic invasive weeds will be performed. If aquatic invasive weeds are found in the work area, they will be treated or otherwise removed with a plan developed by a licensed pest control advisor (PCA). This plan will be implemented prior to or during construction, as feasible (e.g., work is not an emergency). b.Conduct work in less infested areas of thewaterbodyprior to infested areas, when possible. c. Minimize wading and running boats into sediment to avoid relocating the aquatic invasive weeds 1 Adapted from USFWS 2018 and California Department of Fish and Game (CDFG) 2008. 2 Adapted from USFWS 2018 and CDFG 2008. December 2020 Page 12 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan d.Minimize the amount of sediment, plants, and/or organisms that are incidentally removed from the water with equipment, boats, or sampling gear. If any of these materials are brought out of the water, leave them at the originating site to the extent feasible (e.g., pull or rinse off vegetation and sediment at the waterbody). 4. Comprehensive Invasive Weed Surveys including Aquatic Invasive Weeds: PG&E will complete comprehensive invasive weed surveys of the Project approximately every five years (see Section 4.3.2), during which PG&E will include aquatic invasive weed species; any present will be recorded, along with their population abundance and distribution. PG&E will report any findings and spatial data to the Forest Service as part of the associated comprehensive survey report. The management of these aquatic invasive weeds will be incorporated into the Management Strategy (Section 4.3.2) and may include chemical or mechanical treatment. 5.Preparation of Additional Aquatic Invasive Weed Measures: Additional aquatic invasive weed prevention or treatment measures will be developed on an as-needed based on the results of the periodic comprehensive invasive weed surveys and at the request of the Forest Service. The measures would be updated as necessary to address aquatic invasive weeds within the Project if any existing populations spread and/if new populations are detected. Additional measures may include, but would not be limited to, the following: a. Public Education: If aquatic invasive weeds appear to be introduced by recreation and similar public access, PG&E may produce informational outreach material (such as signage and pamphlets) to inform the public about the harmful ecological impacts of aquatic invasive weeds. Information will also include required measures to prevent introduction, including routine equipment washing. Signage may be posted at recreation December 2020 Page 13 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan areas (Sandy Beach, Bardee’s Bar River Access, Poe Beach Trail, and Poe Powerhouse River Access). 4.3.2Inventory, Mapping, Monitoring, and Reporting License Condition No. 34 directs PG&E to inventory, map, and monitor existing and new infestations of invasive weeds. PG&E proposes to carry out these activities within the Project Control Area. Surveys will include margins of water bodies associated with the Project to detect aquatic invasive weeds. Inventory, mapping, and monitoring will consist of systematic comprehensive surveys and annual monitoring, each further described below. Systematic comprehensive surveys will be conducted, whereby new occurrences of target invasive weed species are detected, inventoried, and mapped at five-year intervals. Data from these comprehensive surveys form the basis for the development of specific treatment prescriptions and schedule for control. Annual monitoring and mapping surveys will document changes in population parameters (e.g., population size, infested area) of previously mapped and treated target invasive weed occurrences in comparison to previous comprehensive survey results and may also incidentally detect new target invasive weed occurrences. 4.3.2.1Comprehensive Surveys, Mapping, and Reporting Comprehensive inventory and mapping surveys will be performed at five-year intervals, or longer if appropriate, for the term of the License. An initial comprehensive inventory will be conducted during the first year following approval of this Plan. Detailed target invasive weed mapping by qualified botanists and ecologists will occur during each comprehensive survey. The survey will cover all potential target invasive weed habitat within the Control Area, including areas with known disturbance tied to Project actions, such as road maintenance, at Project facilities, recreation areas, and new construction sites. These five-year comprehensive inventories will form the basis for the development of site- and species-specific methods and schedule for control (see Development of Management Strategy section below) and serve as a basis for comparison of annual treatment effectiveness in the December 2020 Page 14 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan intervening five-year period. Subsequent comprehensive surveys will detect any new populations of target invasive weeds that have established beyond the range of annual control treatments. Prior to each comprehensive survey, PG&E will consult with the Forest Service and the most- recent CDFA Action-Oriented Pest Rating System weed listfor any changes to the Project target invasive weed list. Field surveys will typically commence in late March or April and continue intermittently as-necessary through August to capture the blooming and/or identification periods for all occurring or potentially occurring target invasive weed species. Multiple visits to the Project may be necessary to detect and map all known and new invasive weed species occurrences. An electronic field data form with a data dictionary will be developed for use with a mobile geographic information system (GIS) platform to document target invasive weed occurrence attributes. The list of attributes to be collected during comprehensive surveys will be based on the current Plumas National Forest invasive weed forms, which are expected to follow current Natural Resource Information System (NRIS) protocols or its successor (see Attachment E). These attributes will include parameters such as the following: Data will be recorded in shapefile format (or approved successor); Projection used will be compatible with NRIS (e.g., North American Datum of 1983, \[NAD83\] Universal Transverse Mercator \[UTM\] Zone 10); Unique features will be recorded for each species occurrence (i.e., each feature will only include one target invasive weed species); Data will be provided to the Forest Service as polygons; small populations (0.1 acre or smaller) may be recorded as points with an estimated area, but will be converted to polygons in GIS; and For each target invasive weed occurrence, information on abundance, density, phenology, and other requirements of the current NRIS system. Following each comprehensive survey, a report will be prepared for submittal to the Forest Service. The report will include up to date occurrence data for all target invasive weed occurrences, including abundance, distribution, new infestations, and comparison to data presented in previous comprehensive survey reports. Maps will be included, and the associated GIS shapefiles will be December 2020 Page 15 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan submitted to theForest Service. The draft comprehensive survey report and data would be submitted by November 1 (see Section 4.3.3)in the years when these surveys are performed (i.e., five-year intervals). To ensure special-status plant populations are protected during vegetation management activities, including invasive weed control (Section 6.8.1), PG&E will include special-status plant surveys and mapping as part of the comprehensive surveys. The special-status plant surveys will be performed concurrently with the initial comprehensive invasive weed inventory during the first year following approval of this Plan, and every ten years thereafter (i.e., during every other comprehensive survey). These special-status plant surveys are detailed further in Section 6.7. Development of Management Strategy Based on the results of the first comprehensive survey, PG&E will develop an adaptive Management Strategy for the target invasive weeds found within the Control Area. The strategy will include specific control measures and schedule for control of the target invasive weeds present, and BMPs for the protection of sensitive resources. The Management Strategy would be a separate document, submitted on the same timeline as the initial comprehensive survey report for Forest Service approval (see Section 4.3.3). After subsequent comprehensive surveys, or at other periods as appropriate, PG&E, in consultation with the Forest Service, may revise the Management Strategy on an as-needed basis. Revisions may include changes to control methods in order to better control existing target invasive weed occurrences or newly observed target invasive weeds to improve treatment efficiency or effectiveness. The Management Strategy is considered a working document to be modified as needed following comprehensive surveys, and will be available from the Licensee, upon request. 4.3.2.2Annual Monitoring, Mapping, and Reporting Ongoing annual monitoring of known occurrences of target invasive weeds will be performed for the life of the License. The GIS data from each comprehensive survey will be transferred to a management grid system, which is then used to create annual treatment and monitoring maps, including a mobile GPS map system. Annual treatment and monitoring of target invasive weed December 2020 Page 16 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan occurrences will be directed by a grid-based map and data collection system. The intent of this grid-based approach is, first and foremost, to establish a repeatable, systematic approach to annual treatment, monitoring, and reporting, one that is both cost-effective and able to inform decision making for enhanced invasive weed control. A key component of the annual treatment and monitoring is a grid system map composed of 0.62- acre management cells (50 by 50 meters, or 0.25 hectare), which overlays the Control Area. In our experience, this grid cell size represents the largest area that can be visually assessed for invasive weed cover in the field. This approach ensures a systematic and complete survey of areas with known infestations in order to effectively treat and monitor target invasive weed populations (i.e., detect, treat and document change within a cell). The grid system provides a consistent set of permanent sample plots of fixed area, within which distribution and density of target invasive weeds over the landscape are tracked to direct and report treatments. Over time, this grid-based information is used to determine the efficacy of specific control treatments and may inform alternative approaches for greater effectiveness. In the mobile GIS platform, the grid layer containing population data translated from occurrences mapped during the comprehensive survey will appear along with property ownership attributedata. The resulting inventory map will show grid cells colored and patterned to identify locations of target invasive weeds. Grid cells that contain target invasive weeds will be treated and monitored annually. During treatment and monitoring activities, each grid cell containing any portion of a previously mapped invasive weed occurrence will be completely searched for target invasive weeds. The grid system is preferable to PG&E to a “point and polygon” tracking system for annual monitoring and reporting of invasive weed treatment activities. Individual invasive weed point and polygon occurrences can contract, expand, move, or combine and blend from year to year. This variability complicates reporting population densities and treatment application areas without remapping each point or polygon occurrence every year, which may be time consuming in the field. Each grid cell will be assigned with attribute fields for the collection of data relating to target invasive weeds (e.g., number of plants, acreage treated in cell, treatment date and method, etc.), eliminating the need for detailed mapping of individual weed occurrences. If new occurrences are December 2020 Page 17 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan incidentally observed during annual treatment or monitoring, they are incorporated into the grid maps for treatment and monitoring in the following years. Treatments are expected to take place in spring through summer, with monitoring taking place approximately four weeks after each treatment pass. Monitors will visit safely accessible management cells with known target invasive weed occurrences that have been treated in the most recent treatment pass. Monitors will walk meandering transects throughout all suitable habitat for target invasive weeds within each treated management cell, and will sight-check for living and/or fruiting target plants in the Control Area. Population sizes of live and/or seeding target invasive weeds within each management cell will be recorded. Annual monitoring reports will be submitted to the Forest Service that will document control treatments, a summary of all monitoring activities, changes in target invasive weed species as a result of treatments, new occurrences, any further control recommendations, and other information that may be judged useful to improve treatment efficacy and manage target invasive weed populations. Results will include comparisons between the most recent comprehensive survey conditions to current conditions. In addition, any disturbance area survey results for the year will be included in the annual report. Annual target invasive weed data collected in the management grid during monitoring surveys will be submitted to Forest Service in GIS format with attribute data as part of annual consultation. The annual report and data would be submitted by PG&E to the Forest Service annually by November 1 (see Section 4.3.3). Treatment locations may change over time as some infestations are eliminated and new infestations appear; these changes will be tracked and treatments directed with the management grid. New occurrences of CDFA A-, B-, and Q-rated species will also be incorporated into the management grid, and would be controlled within 12 months of detection or as soon as practical and feasible. The management grid of target invasive weeds will be updated based on new comprehensive field surveys completed every five years (Section 4.3.2.1). All annual treatment and monitoring may be supplemented by opportunistic incidental observations by PG&E employees and contractors in years between the comprehensive surveys. If Plumas National Forest or another entity locates an undocumented target invasive weed occurrence within the Control Area, PG&E will evaluate the occurrence during annual monitoring December 2020 Page 18 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan activities. Confirmed occurrences of target invasive weeds will be added into the management grid map system as appropriate. 4.3.3Control Measures and Schedule A general description of treatments to control new and existing occurrences of target invasive weeds are presented in Section 6.0. Hand treatments alone or in combination with mechanical treatments can be used to successfully control new or small-sized infestations or occurrences near sensitive resources (such as special-status species, wetlands, and waters). Older or larger populations of target invasive weeds may be controlled more effectively using chemical control methods. PG&E’s use of prescribed herbicides on NFSL will require completion of an authorization process with the Forest Service before start of treatments (see Section 6.3). The authorization may include completion and approval of Pesticide Use Proposals (PUPs) as form FS-2100’s (or current process) on a yearly or multi-year basis. PG&E will report all treatments on NFSL to the Forest Service by September 15 of each year. This report can be a spreadsheet and associated GIS data. This data report shall include type of treatment, chemical (if applicable), application rate, location, area treated, and other applicable information needed by the Forest Service to complete their annual treatment and herbicide reporting for the Forest Service Activity Tracking System database, or authorized successor (this reporting is additional to the treatment reporting in the annual report described in Section 4.3.2.2). A generalizedschedule for proposed target invasive weed management and reporting as described in this Plan is included below in Table 4-2. PG&E would begin control activities in the first year after FERC approval of this Plan; initiation of control would follow the initial comprehensive survey and development of the Management Strategy. Following the initial comprehensive survey, target invasive weed treatments and monitoring will occur annually at each location where target occurrences have been identified. December 2020 Page 19 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table 4-2. Proposed Target Invasive Weed Management Schedule ActivityTiming Every Ten Years Late March–August (starting the year following Plan Special-status Plant Survey approval) Every Five Years Late March–August (starting the year following Plan Comprehensive survey approval) Treatment proposals (e.g., FS-2100 forms) January–February submitted to Forest Service Draft comprehensive survey report, submitted to November 1 Forest Service GIS individual occurrence data submitted to November 1 Forest Service Draft Management Strategy, submitted to Forest November 1 Service Final Comprehensive Survey Report, addressing December 31 Forest Service comments Final Management Strategy, addressing Forest December 31 Service Comments Annually Annual consultation meeting Approximately January–March Approximately April through July, may require multiple Target invasive weed treatments visits Approximately May through August (approximately four Annual monitoring weeks following each treatment) Treatment reporting submitted to Forest Service September 15 Draft annual monitoring report submitted to November 1 Forest Service GIS grid data submitted to Forest Service November 1 Final Annual Monitoring Report, addressing December 31 Forest Service comments December 2020 Page 20 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 5.0 Wildfire Risk and Vegetation Management The Licensee conducts a variety of routine O&M vegetation management activities, often driven by regulatory requirements. These measures ensure safe and continued Project operations and include the continued implementation of ongoing fire protection measures to comply with applicable codes and safeguard Project assets. This section provides a detailed wildfire risk analysis of the Project and vicinity, including an evaluation of existing fuels. This analysis is followed by a description of vegetation management activities that are designed, in part, to mitigate that risk at Project recreation sites and other facilities. Lastly, a description of vegetation management associated with routine O&M activities is presented. 5.1 Wildfire Behavior and Modeling The wildland fire behavior analysis developed for the Poe Project was designed to examine the existing fire hazard in the event of a wildfire. Various models and applications were used to calculate and summarize expected fire behavior on the Project. The methods and results are described below and illustrated on maps in Attachment F. The assessment used fuels mapping data, made available from Landscape Fire and Resource Management Planning Tools (Landfire), a shared program between Forest Service and U.S. Department of the Interior (USDOI, Forest Service and USDOI 2019). The Landfire model Outputs (fire type, flame length, and rate of spread) are based on the following inputs: elevation, slope, aspect, fuel model, canopy cover, canopy height, crown base height, and crown bulk density. The Camp Fire, which occurred in November 2018 made short term changes to the fuel models provided by Landfire. These changes were taken into consideration and the models were verified with ground-truthing. Weather from the Forest Service Remote Automated Weather Stations (RAWS) at nearby Jarbo Gap in Butte County, was evaluated for weather trends and was determined to be the most representative of the Project. Trends in temperature and relative humidity affect the moisture content of both dead and living vegetation, determining their flammability. Another important factor in fire spread is wind speed and direction. During fire season, winds are predominately from December 2020 Page 21 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan northeast and are very dry, increasing the difficulty in controlling wildfires. Wind speed and direction is also influenced by vegetation type and terrain (slope and aspect). The local and diurnal winds can be greatly increased by topographic features; winds in the area are strongly influenced by the topography of Jarbo Gap. The fire behavior measurement used for this assessment was the Energy Release Component (ERC), a National Fire Danger Rating System (NFDRS) index. It is directly related to the 24-hour, potential worst case and total available energy (in British thermal units \[BTUs\]) per unit area (square feet) within the flaming front at the head of a fire. The ERC serves as a good characterization of fire hazard throughout the season, as it tracks seasonal fire danger trends well. The ERC is a function of the fuel model and the live and dead fuel moistures. Fuel loading, woody fuel moistures, and larger fuel moistures all have an influence on the ERC, while the lighter fuels have less influence and wind speed has none. ERC has low variability and is the best fire danger index for indicating the effects of intermediate to long-term drying on fire behavior (Southern California Geographic Coordination Center 2019). The ERC graph for the Jarbo Gap RAWS Station (Figure 5-1) indicates when fuel conditions in the Project can support fires that are likely to escape initial attack, generally when the ERC exceeds 80. Figure 5-1 shows the average ERC, the maximum historic ERC, and the minimum historic ERC, from 2001 through 2012. In an average year, the period that a wildfire is most likely to escape initial attack begins around June 15 and lasts into October. However, wildfires can also escape initial attack during drought years and outside the normal fire season. 5.1.1 Current Risk Analysis/Resistance to Control Resistance to Control (RTC) is used to help fire managers articulate several factors in order to determine the difficulty of controlling an ongoing wildfire. RTC was calculated using three important fire behavior outputs (Tables 5-1 and 5-2) from a fire behavior model (FlamMap \[Section 5.1.2 below\], Systems for Environmental Management 2019): 1) flame length (intensity), 2) rate of spread (speed), and 3) fire type (surface, torching, or actively crowning wildfire, Table 5-1). The formula used to calculate RTC is as follows: December 2020 Page 22 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Flame length + Rate of Spread + Fire Type = Analysis Score = RTC Formula example: 3.4 + 4.8 + 10 = 18.2 = 1 (Low) Figure 5-1. Energy Release Component for the Plumas National Forest, West Zone December 2020 Page 23 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table 5-1. Fire Behavior Indicators Flame Length (Measured in feet, see Figure 5-2) Flame Length: The distance measured from the average flame tip to the middle of the active flaming zone at the base of the fire. It is measured on a slant when the flames are tilted due to effects of wind and slope. Flame Height: The average height of flames as measured vertically, up and down. It is estimated by comparing the flame to a nearby object of known height. Flame height is needed to estimate spot distance from a burning pile. Rate of Spread(Measured in chains per hour) One chain equals 66 feet. Fire Type Fire Type 1:a surface fire; the fire is generally on the ground, high likelihood of initial attack success. Fire Type 2:passive crown fire, (torching and short-range spotting). Fire Type 3: active crown fire, (fire actively moving in the crowns of trees with mid to long range spotting). Table 5-2. Resistance to Control (RTC) Calculation Matrix Flame Length Rate of SpreadFire Type Resistance to a (feet) (chains/hour) X 10 Analysis ScoreControl 0 to 3.9 0 to 4.9 1x10=10 Less than 18.8 Low (1) 3.9 to 7.9 4.9 to 9.9 1x10=10 18.9 to 27.8 Moderate (2) 7.9 to 10.9 9.9 to 19.9 2x10=20 27.9 to 50.8 High (3) 10.9 to 19.9 19.9 to 39.9 2x10=20 50.9 to 79.8 Very High (4) 20 + 40 + 3x10=30 79.9 and greater Extreme (5) a One Chain equals 66 feet, 40 chains per hour equals ½ mile per hour rate of spread. December 2020 Page 24 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Figure 5-2. Flame Length and Flame Height Measurement A RTC rating above moderate means suppression efforts are unlikely to succeed unless extenuating circumstances occur, such as a break in the vegetation or a change in the weather. The RTC maps (Attachment F) show locations in the Projectwhere ignitions are likely to escape initial attack, asset loss could be the greatest, and investment in treatments might have the greatest impact on fire spread and suppression effectiveness. Table 5-3illustrates the range of flame lengths and the type of effective suppression efforts required for each RTC rating. Much of the Project fire modeling predicts flame lengths greater than 4 feet (Attachment F), which would require a combination of direct and indirect suppression tactics during much of the fire season. In these circumstances, dozers and aircraft are often part of the initial attack suppression, as they can generally be used for direct suppression on flame lengths up to 8 feet. December 2020 Page 25 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table 5-3. Resistance to Control (RTC) Interpretation Matrix Resistance to Control (RTC) Interpretation Fire can generally be attacked at the head or flanks by persons with Low hand tools and or engines. Handlines should hold the fire 1 Fire is too intense for direct attack on the head by persons using hand tools. Handlines cannot be relied on to hold the fire. Moderate 2 Equipment such as dozers, fire engines, and retardant aircraft can be effective Fire may present serious control problems --torching out, crowning, and spotting. Control efforts at the fire head will probably be High ineffective 3 Very HighCrowning spotting and major fire runs are probable. Control efforts at 4 the head of the fire are ineffective Extreme 5 5.1.2Fire Behavior Modeling Descriptions FlamMap (Systems for Environmental Management 2019) is a fire behavior mapping and analysis program that computes potential fire behavior characteristics (spread rate, flame length, fire line intensity, etc.) over an entire landscape for constant weather and fuel moisture conditions. With 3 the inclusion of a FARSITE (Forest Service 2020) two-dimensional landscape model, it can now compute wildfire growth and behavior for longer time periods under heterogeneous conditions of terrain, fuels, fuel moistures and weather. 3 FARSITE (Forest Service 2020) is a fire growth simulation modeling system that uses spatial information on topography and fuels along with weather and wind files. It incorporates existing models for surface fire, crown fire, spotting, post-frontal combustion, and fire acceleration into a two-dimensional fire growth model. FARSITE computes wildfire growth and behavior for long time periods under heterogeneous conditions of terrain, fuels, and weather. December 2020 Page 26 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 4 FlamMap software creates raster maps of potential fire behavior characteristics (spread rate, flame length, crown fire activity, etc.) and environmental conditions (dead fuel moistures, mid-flame wind speeds, and solar irradiance) over an entire FARSITE landscape. FlamMap is not a replacement for FARSITE or a complete fire growth simulation model. FlamMap has no temporal component; but instead uses spatial information on topography and fuels to calculate fire behavior characteristics at one instant. FlamMap is widely used by the National Park Service, Forest Service, and other federal and state land management agencies in support of fire management activities. It is designed for use by those 5 familiar with fuels, weather, topography, wildfire situations, and the associated terminology. FireFamilyPlus (Forest Service 2019) is a software system used to summarize and analyze historic 6 daily fire weather observations and to compute fire danger indices based on the NFDRS. Fire occurrence data can also be analyzed and cross-referenced with weather data to help determine critical levels for staffing and to establish fire danger for an area. This program was used to develop the weather parameters to run FlamMap those parameters are listed below (Table 5-4). The 90th percentile weather was used for this analysis. This is indicative of high fire danger days during the fire season when humidity is less than 15 percent, temperatures are greater than 80degrees Fahrenheit (°F), and wind speeds are greater than 6 miles per hour. 4 FlamMap incorporates the following fire behavior models: Rothermel’s 1972 surface fire model and 1991 crown fire spread model, Van Wagner’s 1977 crown fire initiation model, and Nelson’s 2000 dead fuel moisture model. 5 Because of its complexity, only users with the proper fire behavior training and experience should use FlamMap where the outputs are to be used for making fire and land management decisions. 6 The Canadian Fire Danger Rating System can also be used. December 2020 Page 27 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table 5-4. FireFamilyPlus Weather Data Used for FlamMap Analysis Based on the fire modeling and behavior analysis, surface fire (Type 1) is the mean fire type for the Project. However, Bardees Bar River Access, Poe Reservoir Access Trail, and Poe Beach recreation sites could also experience a torching fire (Type 2). Mean flame length will range from approximately 7-25 feet,and rate of spread is estimated to range from approximately 18 chains to 54 chains per hour (1,188 feet to 3,564 feet per hour; Table 5-5, Attachment F). TheRTC rating for the Project ranges from high to extreme, meaning control efforts will be difficult (Table 5-5). December 2020 Page 28 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table 5-4. Mean Fire Behavior Characteristics for Poe Project Facilities and Recreation Sites Mean Flame Mean Rate Length of Spread ab,c Facility Name (feet) (Chains/hr) Mean Fire Type Mean RTC Bardees Bar River 1.20 25.30 54.14 91.45 (extreme) Access(surface/torching fire) 1.33 Poe Beach 14.42 39.24 66.95 (very high) (surface/torching fire) Poe Powerhouse and 0.58 7.14 37.33 50.30 (high) River Access (surface fire) 0.73 Sandy Beach8.1422.8238.30 (high) (surface fire) Poe Reservoir Access 0.81 9.11 23.98 41.17 (high) Trail (surface/torching fire) 0.63 Poe Dam 7.01 17.93 31.29 (high) (surface fire) 0.70 Big Bend Dam 13.04 36.55 56.55 (very high) (surface fire) a One Chain equals 66 feet. b Mean RTC – See Table 5-2. RTC is based on flame length, rate of spread, and fire type. c See also Attachment F. 5.2 Vegetation Management for Fuels Treatment In addition to the results of the FlamMap modeling above, the Project is within a federal and California State responsibility area and in a “very-high fire hazard severity zone” (CalFire 2007). Per the requirements of California Fire Code (California Building Standards Commission 2016), fuels treatment and vegetation management will be conducted to “reduce the severity of potential exterior wildfire exposure to buildings and to reduce the risk of fire spreading to buildings as required by applicable laws and regulations.” Vegetation around Project facilities will be maintained in accordance with the following laws and regulations: Public Resources Code, Section 4291; California Code of Regulations, Title 14, Division 1.5, Chapter 7, Subchapter 3, Section 1299; California Government Code, Section 51182; California Code of Regulations, Title 19, Division 1, Chapter 7, Subchapter 1, Section 3.07. December 2020 Page 29 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Since the Project is within a “very-high fire hazard severity zone”, PG&E will maintain defensible space around Project facilities as required in Public Resources Code 4290 and “SRA Fire Safe Regulations” California Code of Regulations, Title 14, Division 1.5, Chapter 7, Subchapter 2, Section 1270. PG&E will also abide by Utility Bulletin TD-3322B-065(PG&E 2019)that requires defensible space be maintained around substations and switchyards.In spring of 2019, PG&E completed fuels reduction around the perimeter of Poe Switchyard, removing all vegetation within 30 feet of energized equipment and reducing fuels within another 70 feet of the facility. 5.2.1Fuels Treatment Objective The development of five Project recreation sites (Bardee’s Bar River Access, Poe Beach, Poe Powerhouse River Access, Sandy Beach, and Poe Reservoir Access Trail) and the anticipated increase in use increases the potential for human-caused ignitions. A wildfire originating in the Project would spread rapidly into adjacent dense stands of mixed conifer, foothill woodland, and mixed chaparral cover types and quickly result in a high intensity wildfire. Site-specific fuel management treatments have been identified to mitigate and prevent ignition and escape of Project-related or induced wildfires at the five recreation sites, Poe Dam, and Poe Powerhouse (Attachment G). The primary objective of the fuel treatments is 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. Fuels reduction will result in lower fire intensity, smaller flame length, improve control, and decrease the potential for a crown fire. 5.2.2 Fuel Treatment Methods Fuel treatment methods for the five recreation sites, Poe Dam, and Poe Powerhouse including manually removing vegetation with chainsaws and string trimmers. At Big Bend Dam and associated facilities, the main Project activity is general vegetation maintenance, and therefore no fuel treatment methods or specifications are proposed for this facility. Vegetation removal is designed to create a shaded fuel break. Accordingly, fuel treatment specification descriptions for each treatment area are general in nature and retain the flexibility to December 2020 Page 30 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan be modified prior to implementation. Prior to treatment prescriptions, PG&E will coordinate proposed modifications of fuel treatment prescriptions and specifications on NFSL with the Plumas National Forest. Selection criteria for “leave trees” will be as follows: Tree has no apparent damage to the main bole; Tree is not chlorotic; Tree visually demonstrates good vigor and is disease/bug free;and Tree has at least 40 percent crown ratio. Criteria for pruning, chipping, and felled trees: All trees will be pruned up to 10 feet in height, but no more than 50 percent of the crown will be removed. Residual slash material may be chipped in place and scattered so as not to exceed a depth of 6 inches. Tree boles that are not chipped will be limbed, the limbs lopped and scattered, and tree stems cut into 8-foot lengths. All vegetation will be removed manually with chainsaws and string trimmers. Where access allows and when cut vegetation is within a certain distance of the recreation site/Project facility then it will be chipped and broadcast back on site. 5.2.3 Fuel Treatment Site Specifications The following describes fuel treatment goals for specific Project facilities and recreation sites: Bardee’s Bar River Access – Within 25 feet of the parking/picnic area, all herbaceous vegetation will be removed. A shaded fuel break will be created for the remainder of the treatment area 7 (Attachment G). Trees or clumps of trees will be spaced a minimum of 18 feet apart. To reduce ladder fuels, all trees will be pruned a minimum of 10 feet from ground level. In areas with no trees, brush clumps will be spaced two times their height. Retained shrubs will also be pruned; limbs touching the ground will be removed. 7 A tree or brush clump is defined by multiple stems coming from the same bole or stem. December 2020 Page 31 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Vegetation that is removed on the slope between the picnic area and river will be either chipped or lopped and scattered. Cut vegetation within 100 feet of the picnic area will be hauled to the picnic area and chipped; all other cut vegetation along this slope will be lopped and scattered. Vegetation within the remainder of the treatment area will be chipped and broadcast on site. Poe Beach – Within 25 feet of the parking area, all herbaceous vegetation will be removed. With the use of string trimmers, vegetation will be removed to near ground level. Within the remainder of the treatment area a shaded fuel break will be created where trees and/or tree clumps are spaced a minimum of 18 feet apart (Attachment G). All retained trees will be pruned a minimum of 10 feet from ground level. In areas with no trees, shrub clumps will be spaced twice their height. All cut vegetation within 100 feet of the parking area and access road will be hauled to the road, chipped, and broadcast back on site. Vegetation greater than 100 feet from the parking area/road will be lopped and scattered. Poe Powerhouse and River Access Area – With the recent actions that PG&E took to reduce fuel loads within 100 feet of the powerhouse and switchyard, and because of the position of the recreation site between the river and outlet to the powerhouse, only shrubs and herbaceous vegetation encroaching on the beach access road will be removed and/or trimmed (Attachment G). Shrubs within 10 feet of the road shoulder will be manually removed, chipped, and broadcast back on site. Herbaceous vegetation within 10 feet of the shoulder of the access road will be removed annually with string trimmers. Sandy Beach – Within 25 feet of the parking area, all herbaceous vegetation will be removed manually with string trimmers. Within the remainder of the treatment area (Attachment G), trees and/or clumps of trees will be spaced a minimum of 18 feet apart. To reduce ladder fuels, all trees will be pruned a minimum of 10 feet from ground level. In areas with no trees, brush clumps will be spaced two times their height (i.e., a brush clump that is 6 feet tall will require 12 foot spacing). Retained shrubs will also be pruned; limbs touching the ground will be removed. All cut vegetation will be chipped and broadcast on site. December 2020 Page 32 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Poe Reservoir Access Trail – Within 25 feet of the parking area, all herbaceous vegetation will be removed. With the use of string trimmers, vegetation will be removed to near ground level. Within the remainder of the treatment area, a shaded fuel break will be created where trees and/or tree clumps are spaced a minimum of 18feet apart (Attachment G). Allretained trees will be pruned a minimum of 10 feet from ground level. In areas with no trees, shrub clumps will be spaced twice their height. PG&E recently completed (as of summer 2019) fuel reduction work around the perimeter of Cresta Powerhouse which is immediately adjacent to Poe Reservoir Access Trail. All cut vegetation within 100 feet of the parking area and road will be chipped and broadcast back on site. Vegetation greater than 100 feet from the parking area and road will be lopped and scattered. Poe Dam – All vegetation will be removed from within 25 feet of the dam (south abutment only) and around support facilities. A shaded fuel break will be created within the remaining portion of the treatment polygon (Attachment G). All understory shrubs will be removed and all trees and/or clumps of trees spaced a minimum of 18 feet apart. To reduce ladder fuels, all trees will be pruned a minimum of 10 feet from ground level. Retained shrubs will also be pruned; limbs touching the ground will be removed. All cut vegetation will be chipped and broadcast on site. 5.2.3.1 Implementation Schedule and Maintenance Fire hazards on the Poe Project will be evaluated annually by PG&E staff and their contractors. Areas assessed will include the developed recreation sites, Poe Powerhouse and Switchyard, dams, and Project roads in the FERC boundary. On an annual basis herbaceous vegetation within the parking and picnic areas of the five recreation sites will be trimmed and hazard trees identified and removed. As required by License Condition No. 29, fuels will be assessed at a 5-8 year interval, and if necessary, treatment prescriptions prepared and implemented. For fuels reduction work on NFSL, PG&E will coordinate with the Plumas National Forest. Prior to the removal of vegetation, PG&E will obtain all necessary approval and/or permits. December 2020 Page 33 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 5.3 Vegetation Management Activities for Routine O&M Routine vegetation management activities are enacted while protecting sensitive resources and preventing/minimizing the introduction, establishment, and/or spread of target invasive weeds. Routine vegetation management includes facility and transmission line management, road maintenance, hazard tree removal, and recreation site management. 5.3.1 Facility Vegetation Management The Licensee will routinelycontrolvegetation as required for safety and compliance in the immediate vicinityofProjectfacilitiesincludingpowerhouses,accessroads,support facilities, access trails, tunnels, conduits, diversions, gages, dam faces, and reservoirs. Activities typically include vegetation trimming or clearing, ditch cleaning, and spraying of herbicides. To maintain Project facilities and adjacent areas, vegetation control will be accomplished by mechanical or chemical methods (see Section 6.6). The Licensee will acquire the necessary permissions from the Forest Service prior to applying pesticides on NFSL (see Section 6.3). Any documented occurrences of special-status species will be protected during vegetation management activities (see Section 6.8.1 and Attachment D). 5.3.2 Transmission and Distribution Line Corridors North American Electric Reliability Corporation’s (NERC’s) reliability standard “Transmission Vegetation Management Program” (FAC-003) was implemented in 2007, and compliance with that standard is mandatory with potential penalties for allowing even a single tree to encroach within a specified distance of a conductor. California Public Resource Code (CPRC) 4292 (CPRC 4292) and 4293 (CPRC 4293) require specific clearance between conductors and power poles and vegetation. For distribution lines, CPRC 4293 requires maintaining 4 feet of clearance between the conductor and vegetation at all times in all conditions (e.g., sway, sag, snow loading, expected annual tree growth, etc.). Maintaining 4 feet of clearance may require obtaining up to a 20-foot clearance between the vegetation and conductor, depending on the tree species and annual growth rate. This code also requires the felling or trimming of hazard trees adjacent to the line that may fall into the line. CPRC December 2020 Page 34 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 4293 defines hazard trees as “dead trees, old decadent or rotten trees,trees weakened by decay or disease and trees or portions thereof that are leaning toward the line which may contact the line from the side or may fall on the line” and specifies that hazard trees “will be felled, cut, or trimmed so as to remove such hazard.” As noted above, the trim zone and the hazard tree zone are variable in width depending primarily on the height of trees adjacent to the distribution line, the topography, and the sway of the conductors at mid span as determined by the tension and length of the span. To identify areas requiring trimming or hazard tree removal, initially, Licensee inspectors will walk the entire transmission line corridor, noting locations where vegetation is either growing into the conductors or has the potential to fall into the conductors in violation of CPRC 4293. Following the ground inspection, non-compliant vegetation, including hazard trees, will be scheduled for trimming or cutting. Crews will then perform the required vegetation management using hand tools (e.g., chainsaws, pruning shears, and other hand-held tools). This work is generally scheduled to be completed each year prior to the start of fire season (typically in May). Transmission lines that overlap the FERC boundary must comply with FAC-003, CPRC 4293, and CPRC 4292. Therefore, the Licensee clears and maintains the transmission corridor and hazard tree zones of all non-compliant vegetation. The Licensee’s Vegetation Management Department implements this work for transmission and distribution lines that overlap the FERC boundary. If possible, documented occurrences of special-status species will be protected from disturbance arising from vegetation management along the transmission lines (see Section 6.8.1 and Attachment D). 5.3.3 Roads Project O&M activities conducted along roads typically include slide removal, road grading, vegetation trimming and clearing, and ditch cleaning. As practicable, the timing of these activities will be coordinated such that any scheduled surveys for target invasive weedswill be completed prior to vegetation clearing (which may obscure the presence of invasive weeds). Vegetation that occurs along roadsides frequently encroaches into those roads and requires trimming and/or mowing (see Sections 6.6.1 and 6.6.2). The Licensee will take reasonable measures to cut and/or December 2020 Page 35 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan mow roadsidevegetation that is free of target invasive weeds prior to cutting and/or mowing roadside vegetation that contains target invasive weeds. Equipment will be cleaned after cutting and/or mowing the target invasive weeds as soon as reasonably possible. When areas of dense shrubsaremanually or mechanically removed, theywillbechippedonsite. Nodocumented population of a target invasive weed will be chipped. Because many target invasive weeds grow best in full to partial sun, roadside shade will be retained as much as practicable as a preventative measure to reduce the vigor of existing target invasive weed infestations and/or reduce the risk of establishment of other invasive weeds. When mulch is needed for erosion control during road maintenance activities, mulch from on-site materials (e.g., chipped trees and slash) is preferred. If mulch from on-site materials is unavailable, then the mulch will be certified weed-free, if a weed-free product is commercially available. When mulch is needed to prevent target invasive weed establishment along roads, mulch with high void spaces (long-fiber mulch), and low water-holding capacity will be applied to a depth of approximately 2 to 4 inches. Material from right-of-way (ROW) clearing (e.g., roadside brushing) can be shredded to create long-fiber mulch, but woody target invasive weed species (e.g., broom species) will not be shredded and used as mulch. Any documented occurrences of special-status species will be protected from vegetation management during road maintenance activities (see Section 6.8.1 and Attachment D). 5.3.4 Recreation Facilities At Project recreation sites,vegetation management activities include the removal of vegetation, hazardous branches, and hazard trees, as identified by the Licensee’s land planners or foresters, to facilitate recreation activities. Any documented occurrences of special-status plants at Project recreation facilities will be protected from recreation site vegetation management activities (see Section 6.8.1 and Attachment D). In early spring (as well as in the fall, as time and project budget allows), foresters will survey facilities, parking lots, and immediate access routes to recreation areas for hazard trees and hazardous branches. Identified trees will be removed as soon as practicable thereafter. If a hazard December 2020 Page 36 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan tree is identified outside of the survey period, it will be removed as soon as reasonably possible. When a hazard tree is felled or branches removed, the slash will be chipped, and the trunk hauled away. Slash may be chipped and hauled away or piled at an agreed upon location for Forest Service to burn. For visual mitigation, stumps remaining within developed recreation facilities will be no greater than 6 inches in height and preferably cut to ground level. For situations where mechanical or manual removal is infeasible (i.e., remote sites approved by the Plumas National Forest), boles will remain intact on the ground to lessen potential adverse visual impacts. To prevent spread of Heterobasidion root disease (HRD), stumps will be treated as described in Section 5.3.5. 5.3.5Hazard Tree Management The Licensee is required under CPRC to remove trees that are dead or dying and have a potential to fall on Project facilities, including powerhouses, access roads, transmission and distribution lines, support facilities, recreation sites, access trails, tunnels, conduits, diversions, gages, dam faces, and reservoirs. In addition, Region 5 of the Forest Service has guidelines to identify and abate hazard from trees that may cause injury to people or property on ForestService system roads or at Forest Service facilities in California (Forest Service 2012b, 2020b, 2020c, 2020d). Hand tools and chainsaws are used to fell hazard trees. In areas with vehicle access, bucket trucks and chippers are also used. When hazard trees are located on private lands, the landowner will be notified prior to the hazard tree removal. When the removal of hazard trees is required on NFSL for an emergency, the Forest Service will be notified specifying a timeframe in which the hazard tree work will commence. If a response is not received from the Forest Service within the timeframe provided, PG&E will proceed with the necessary hazard tree removals. For planned hazard tree removal on NFSL, a project review package will be submitted to the Forest Service for review and will include a brief project description, an aerial map, a USGS topographic map of the work location, GIS shapefiles of the tree point locations, and a spreadsheet with the details of the trees to be removed. The work package will be reviewed by Forest Service specialists within 30 days, and if acceptable, a concurrence letter will be provided to PG&E as approval of the work. If any investigations are needed (e.g., special-status species and/or cultural resources surveys), the Licensee’s qualified professionals will perform them prior to hazard tree removal. If sensitive resources are discovered, the guidelines for sensitive area protections in Section 6.8 December 2020 Page 37 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan and Attachment D, will be followedwhether the treesto be felled are located within or immediately outside the FERC Project boundary. On NFSL, the Licensee will evaluate, and as appropriate, treat stumps to prevent the introduction and spread of Heterobasidion species(causal agent ofHRD) in hazard trees or other trees removed by the Licensee. In certain high value areas (e.g., recreation sites, progeny test sites and seed orchards) because the importance of minimizing the development of hazard trees in these areas, all conifer stumps greater than 3 inches across (outside bark diameter) will receive borate dressing as soon as practicable, but no longer than 24 hours after felling (Forest Service 2013). For all other areas on NFSL, including the general forest, stump treatments will be determined in consultation with the Forest Service on an individual stand basis. The Licensee will work with an appropriate Forest Service specialist (e.g., silviculturist, forester) to identify the objectives and management direction for the stand, assess the level of HRD currently in the stand or in nearby similar stands, estimate the cost-effectiveness of the treatment, and develop a recommended treatment approach. Alternatively, a site visit by a forest health protection specialist maybe conducted, and the findings and recommendations documented in an assessment report. The assessment and recommended approach will be submitted to the Forest Supervisor at the Plumas National Forest as part of the Licensee’s approval request for hazard or other tree removal, under this Plan. The Licensee will also request that the Forest Service approval letter to the Licensee provide guidance on whether the treatment for Heterobasidion is applicable. Any non-hazard trees that do not require being felled, but which contain hazardouslimbs that need removal, will have these limbs removed by pruning. Limbs removed from trees mustbe cut no shorterthan 1 inch fromthe bole to avoid tree damage, while avoiding projecting branch stubs. Small trees and brush that may reach the lineswill routinely be removed by chainsaw or other mechanical means. Any documented occurrences of special-status plants will be protected from hazard tree removal activities (see Section 6.8 and Attachment D). December 2020 Page 38 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6.0 Vegetation and Invasive Weed Management Implementation PG&E will use an integrated and comprehensive approach to vegetation management, including target invasive weed management, that includes the following: 1) prevention strategies for invasive weeds (Section 4.3.1 and BMPs in Attachment D); 2) an education and training program (Section 4.3.1.1 and Section 6.4); and 3) an array of control methods including manual, mechanical, and chemical methods (Section 6.6). Proposed treatments to control existing incompatible vegetation, including existing and new occurrences of target invasive weeds, will be site- and species-specific. The implemented vegetation management treatments will ultimately be derived from conditions on the ground, as well as recommendations in the five-year comprehensive reports and annual monitoring reports. In some cases, combinations of treatments may be most effective. This section describes the framework of the program. 6.1 Annual Pre-Operations Consultation Meeting An annual pre-operations consultation meeting will be held between PG&E and Plumas National Forest staff; PG&E contracted treatment personnel, monitoring personnel, and PCA may attend the meeting, as appropriate. The purpose of this meeting is to apprise Forest Service personnel on the status of vegetation management activities, including target invasive weed control, and possible impacts or hazards, and PG&E on any Forest Service activities that may be taking place in the Control Area. This meeting will allow PG&E and the Forest Service to better coordinate vegetation management activities with other activities taking place in the same area. If possible, this annual consultation meeting will be held prior to implementingvegetation management activities, including target invasive weed control, in the Control Area for the year. Given that vegetation management activities and locations on various hydroelectric projects may overlap, this meeting may address management for multiple PG&E projects on the Plumas National Forest. By the time of this meeting, it is expected that PG&E and the PCA will have completed and submitted pesticide use proposals (PUPs; i.e., form FS-2100-2 or current successor, Section 6.3) to be reviewed and approved by the Forest Service. December 2020 Page 39 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6.2 Control Treatment Decision Process PG&E’s selection of proposed site- and species-specific vegetation treatments will take place under the direction of a licensed PCA and will consider the following factors: Site access; Target invasive weed phenology and potential treatment timing; Size and physical characteristics of the area to be treated, including soil, terrain, and slope; Extent of special-status plants and other desirable vegetation to be avoided during treatment; Avoiding or minimizing adverse effects to special-status animals; Seasonal conditions including wind and precipitation; Proximity to waterbodies and potential for run-off; Proximity to cultural sites; Proximity to recreational use areas; and Desired post-treatment state of treated area. 6.3 Forest Service Herbicide Use Consultation Process The approval process for pesticide use on NFSL is described in Forest Service Region 5 supplement No. 2100-95-1 to 2150 (Forest Service 2000) and the Forest Service Handbook (Forest Service 2011).This process uses the FERC Final Environmental Assessment (EA; FERC 2007) as the National Environmental Policy Act (NEPA) document of record, and therefore applies to NFSL within the FERC boundary for the Project. Herbicide use for vegetation management, including target invasive weed control, requires a written pest control recommendation by a licensed PCA. This recommendation will include the proposed treatment sites, methods, and products with associated amounts. In addition to the written recommendation, a pesticide use proposal (PUP) on Forest Service Form FS-2100-2 (or approved successor) will be filled out and submitted for review and approval by the appropriate Forest Service officer (Forest Service 1994) prior to implementation of herbicide treatment on NFSL December 2020 Page 40 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan (Attachment D, Measure 12: Herbicide Use Planning Process).If appropriate, the recommendation and approval may be proposed for and extend over multiple years (e.g., five-year approvals, term of the License, etc.). This process provides of means for the Plumas National Forest to review treatment prescriptions, in order to protect sensitive resources and moderate the amount of herbicide utilized on a Forest-wide basis. PG&E will proceed with herbicide applications on NFSL only after receiving approval by the Forest Service. PG&E will provide treatment data and reports as specified in Section 4.3. If routine, Project-related vegetation management occurs on NFSL outside the FERC boundary, a separate NEPA analysis is required, as these lands are not covered in FERC’s analysis. Herbicide use on PG&E fee-title property within the Project’s FERC boundary shall not require the Forest Service approval process but will meet all other requirements as outlined below. 6.4 Annual Employee Training Prior to commencement of vegetation control work, a qualified person (e.g., PG&E’s invasive weed program manager and/or the Project PCA, etc.) will conduct an environmental briefing for treatment personnel and other Project vegetation management staff. The purpose of this briefing is to assure that treatment personnel follow appropriate treatment prescriptions and BMPs and avoid sensitive resources. Training will include instructions on complying with FERClicense, Forest Service, and other agency requirements. The environmental training will be performed as described in Attachment D, Measure 15: Environmental Training. 6.5 Pre-Treatment Field Preparation Prior to start of target invasive weed control treatments, GIS will be used to create the management grid for the Control Area showing which grid cells contain target invasive weeds (Section 4.3.2.2). A validation survey will be performed to assess current conditions in a representative sample of those cells, during which hard-to-identify target invasive weed species may be flagged to aid crew members with species identification and occurrence locations. December 2020 Page 41 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan In addition, prior to any vegetation management, including target invasive weed control, any known occurrences of special-status plants (e.g., threatened, endangered, candidate, and sensitive 8 \[TECS\] and/or watch list) in proximity to planned activities will be flagged to serve as herbicide exclusion buffers to protect these species during control treatments (Attachment D, Measure 14: Pre-treatment Flagging). The management grid will also include information regarding environmental constraints (e.g., streams or special-status plants) present in each cell. 6.6 Vegetation Management Methods An integrated pest management (IPM) approach will be employed to control vegetation, including target invasiveweed species, in that all appropriate methods (manual, mechanical, cultural, and chemical) will be considered and incorporated as appropriate for optimum result. Herbicides will be used to optimize control while reducing ground disturbance and the need for subsequent site restoration. Pre- and post-emergent herbicides will be used, but specific formulations will be determined upon completion of the first comprehensive invasive weed survey for invasive weed control and upon assessing O&M vegetation management needs for the Project. Manual and mechanical control will be used when necessary to provide added protection of nearby sensitive resources. Decisions on types of mechanical (e.g., string trimmers, mowers, and chainsaws) and manual (e.g., hand-pulling, shovels, pruners, loppers, handsaws, McLeod tools, and weed wrenches) treatments will be made based on site conditions. For target invasive weed treatment, the management grid system (see Section 4.3.2.2) will aid those implementing invasive weed controlactivitiesin locating work sites and planning daily work activities. 6.6.1Manual Control Manual treatments alone or in combination with mechanical treatments can be used successfully for treatment areas proximal to sensitive resources, or for small areas requiring vegetation 8 For invasive weed control, this will include special-status plant occurrences in the same grid cells as target invasive weeds. December 2020 Page 42 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan management, including some small-sized target invasive weed occurrences. Types of manual treatments that PG&E may implement include the following: Pulling – physically pulling plants from the soil by hand or using a tool such as a weed wrench; Cutting/lopping – using shears, clippers, or similar tools to cut above ground plant parts; Digging – using hoes, shovels, pulaskis, McLeod tools, or similar tools to remove entire plants including roots; and/or Solarizing – covering weed infestations with plastic or jute to superheat target plants and/or reduce access to sunlight. Each of these manual methods has advantages and disadvantages for vegetation control. In general, pulling, cutting, and digging have relatively limited use in controlling vegetation. These methods are labor-intensive and not applicable to large areas, nor do they reduce seeds in the soil. Seeds of some species can remain viable for several years. Cutting, and incomplete hand-pulling and digging, will not eliminate root systems, allowing some species to resprout. Therefore, other follow-up methods may be necessary to supplement manual methods. Removing vegetation manually can be selective and minimize effects to nearby sensitive resources and other desirable vegetation.Manual treatments may be appropriate for controlling sporadically occurring plants in small areas, in sensitive habitats, or near streams. However, trampling and/or soil disturbance caused by manual methods can stimulate further seed germination. Solarizing can be effective at controlling vegetation in small areas where aesthetic concerns are not an issue, or where retention of native plants or other ground cover is not necessary. 6.6.2Mechanical Control Mechanical treatments, alone or in combination with manual or chemical treatments, can also be an integral part of vegetation management, including target invasive weed management. Mechanical methods of vegetation control that PG&E may implement include the following: Cutting –using powered tools such as chainsaws and brush hogs to remove aboveground parts of undesirable woody vegetation; December 2020 Page 43 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Mowing – cutting vegetation with string trimmers or mowers, or with a rotary head attached to a rubber-tired vehicle; Cutting with chainsaws or brush hogs can be effective for removing undesirable shrubs and can be applied selectively so that damage to nearby desirable vegetation is minimized. Chainsaws can also be used near water, and result in minimal soil disturbance. Mowing can also be used to control undesirable herbaceous vegetation if timed appropriately, but is a non-selective process and cannot be used on steep slopes or rocky terrain; string trimming has more flexibility and can be used slightly more selectively. Mechanical control methods are generally less labor-intensive than manual treatments, but size of practical treatment area may be limited by slope and terrain. In addition, cutting and mowing treatments may need to be repeated for greater effectiveness, sometimes multiple times in a growing season to effectively reduce the soil seed bank over time. These treatments also have some similar disadvantages to hand-cutting, in that that they do not reduce seed already present in the soil or eliminate roots. Mowing and cutting may also spread seeds if timed improperly. 6.6.3 Cultural Control The main method of cultural control available for the Project is grazing. In recent years, the use of goats for vegetation management, including invasive weed control, has gained popularity. Goats eat a wide variety of herbaceous and woody species, including yellow star-thistle and Himalayan blackberry. They are not selective and are therefore often used to control dense infestations where little desirable vegetation is present. Goats do not compact the soil compared to cattle, but they do require containment (such as fencing or careful tending). While effective at removing aboveground biomass, grazing does not reduce seeds or roots in the soil and may stimulate some species to resprout. Multiple years of treatment may be required to control invasive weed infestations. 6.6.4 Chemical Control Herbicides will likely be necessary for effective Project vegetation management, including control of target invasive weeds. PG&E uses non-herbicide control techniques when appropriate. However, herbicides are an important tool for effective vegetation control and are an important December 2020 Page 44 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan component of PG&E’s routine vegetation management program. Herbicides are important for maintaining vegetation in early seral stages along linear ROWs (e.g., electric power ROWs, penstocks, and Project roads) and for maintaining bare ground around hydroelectric facilities such as dams, powerhouses, and switchyards. Herbicide effectiveness depends on the type of herbicide, application rate, target species, and environmental conditions (e.g., weather and soil type). Additional herbicides may be proposed for specific target invasive weed species, and herbicides will be proposed in the Management Strategy, based on the results of the first comprehensive inventory (see Section 4.3.2). Herbicides will not be used to treat target invasive weed species until the Management Strategy is approved. Prior to use, site-specific herbicides for vegetation management, including target invasive weeds, will be proposed on PUPs (i.e., FS-2100 forms) and approved by the Forest Service prior to use on NFSL (see Section 6.3). Vegetation management for O&M purposes expects to use herbicides with active ingredients including imazapyr, triclopyr, chlorsulfuron, aminopyralid, and aquatic and terrestrial formulations of glyphosate; clopyralid may also be used. These herbicides have been previously approved for use on PG&E hydroelectric projects on the Plumas National Forest. Fluazifop-p- butyl has also been proposed for use on the Plumas National Forest, but not yet approved. Additives, including application visualization dyes and surfactants such as formulations of modified vegetable and soybean oil are also used to increase effectiveness. Herbicides and additives are expected to change over the life of the License as safer and/or more effective herbicides are developed. There are two groups of herbicides: non-selective (e.g., glyphosate) and selective (e.g. clopyralid). Non-selective herbicides can be used to kill both broad-leaved plants and grasses. Selective herbicides target certain families or types of vegetation, such as grasses (e.g. fluazifop-p-butyl), sunflower family (e.g., aminopyralid), or woody vegetation (e.g., imazapyr). Some herbicide formulations have been approved for use in or near water, because they break down quickly and/or adhere to the soil tightly and have little chance of run-off (e.g., aquatic formulations of glyphosate), where other formulations cannot be used in or near water due to higher potential for off-site run- December 2020 Page 45 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan off (e.g., clopyralid). In addition, post-emergentherbicides are only effective on plants that have already germinated (e.g., glyphosate), while pre-emergent herbicides have residual soil activity that prevent germination and impact seedlings as they emerge (e.g., clopyralid). These factors will be considered when developing site-specific herbicide treatment recommendations. Any herbicides to be used on the Project shall be applied by licensed and certified pesticide applicators. Only herbicides registered with the Environmental Protection Agency, the California Department of Pesticide Regulations (CDPR), and Butte County Agricultural Commissioner will be used. Herbicides proposed will be those that are already approved for use on the Plumas National Forest, and for which environmental risk assessments (e.g., Syracuse Environmental Research Associates \[SERA\] 2014) have already been prepared. Herbicide application will typically consist of both foliar/contact and soil active application methods for O&M vegetation management and target invasive weed control. 6.6.4.1 Foliar and Contact Application Methods Foliar applications are low-volume, directed herbicide treatments that will be used to control herbaceous and resprouting woody vegetation. Applications will typically be made using a backpack or quad-mounted tank targeting individual plants, as opposed to general broadcast applications. These applications can be selective or non-selective, depending on the type of herbicide and the application method. For example, a selective herbicide can be used to control broad-leaved invasive weeds and brush when the target vegetation is actively growing, while not affecting desirable grasses. A non-selective herbicide can also be used selectively through the use of low- volume directed backpack applications, or by timing the application aimed at undesirable vegetation to occur after the desirable native species have already produced seed. Applications to target invasive weeds are typically timed prior to seed set. Basal stem treatment is a selective contact treatment using backpack sprayers that will be used to control woody vegetation. In this treatment, an oil-compatible formulation of herbicide is diluted December 2020 Page 46 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan in an oil carrier (e.g., imazapyr or triclopyr with methylated seed oil \[MSO\]). This mixture is then applied to the lower 18 inches of the target woody plant where it penetrates the bark providing the desired control. Basal stem applications have an extended application window from March through November. Applications are frequently made in the fall followingleaf drop, when woody stems are more accessible on deciduous plants. These late-season applications often have little visual impact because applications are made when deciduous plants have already lost their foliage. Cut-stump treatments will be used to prevent woody species from resprouting after cutting. After trees and brush are cut with a chainsaw or loppers, the stumps are treated with herbicide. This application may be done with backpack or by hand. Most cut-stump treatments can be made year- round. Frill, or hack and squirt, is another control method that will be used for woody species. In this application method, a frill or “hack” is made into the woody cambium. Small amounts of undiluted herbicide are then injected into the frill. The herbicide translocates to the roots and stems. This is a low-profile application, since the applicator carries only a hatchet and a hand-sized (e.g., 1-quart) spray bottle. 6.6.4.2 Soil Active Application Methods Soil active application methods are pre-emergent herbicide treatments. These methods involve applying herbicide to the soil. The herbicide permeates the upper 6 inches of the soil by rainfall and is taken up by the emerging roots and shoots of germinating seeds. The application methods and materials can result in selective or non-selective treatments, as described below. Non-selective soil active herbicides are generally used where bare ground conditions are required. These non-selective herbicides will be applied to the entire area requiring bare ground conditions and will be generally applied in fall or early winter, in advance of seasonal rainfall, to prevent seedling germination. A backpack sprayer is used for application. Non-selective soil active herbicides can also be used selectively with application devices such as a spot gun, which directs the herbicide to only the targeted species. December 2020 Page 47 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Selective soil active herbicides will be used to control undesirable broadleaf species while maintaining desirable grass species. Areas treated in this way will include dam slopes and along penstocks. A backpack sprayer is used for applications. 6.6.4.3Variations in Treatment on NFSL and PG&E Property Herbicide use on NFSL within the FERC Project boundary requires prior written approval from the Forest Service (see Section 6.3). However, herbicide use on PG&E fee-title property within the FERC boundary may occur at Project-related locations without Forest Service approval; in these locations, BMPs will be followed and site-specific measures will be implemented to protect non-target plants and animals, and other sensitive resources (see Section 6.8 and Attachment D). 6.7 Special-status Plant Surveys Protective measures will be implemented where vegetation management activities (including target invasive weed control) coincide with special-status plant species. (Section 6.8). PG&E will conduct comprehensive botanical surveys to also inform protection of known special-status plant occurrences within and near ground-disturbing activities throughout the Control Area. For the purposes of this Plan, “special-status plants” refers to vascular and non-vascular plant, lichen, and fungal taxa that have the following designations: 1) listed, candidates, or proposed for listing as threatened or endangered under the federal Endangered Species Act (ESA); 2) listed or candidates for listing by the State of California as threatened or endangered under the California Endangered Species Act (CESA); 3) listed as rare under the California Native Plant Protection Act; 4) designated by the Forest Service as sensitive, watchlist, or species of conservation concern in the Plumas National Forest; and/or 5) California Rare Plant Ranks of 1 or 2. December 2020 Page 48 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Special-status plants known from Project relicensing botanical survey (PG&E 2003) include Jepson’s onion (Allium jepsonii), Butte County calycadenia (Calycadenia oppositifolia), dissected-leaf toothwort (Cardamine pachystigma var. dissectifolia), white-stemmed clarkia (Clarkia gracilis subsp. albicaulis), Mosquin’s clarkia (Clarkia mosquinii subsp. mosquinii), northern Sierra daisy (Erigeron petrophilus var. sierrensis), Cantelow’s lewisia (Lewisia cantelovii), Humboldt lily (Lilium humboldtii subsp. humboldtii), shield-bracted monkeyflower (Erythranthe glaucescens), and cut-leaved ragwort (Packera eurycephala var. lewisrosei). 6.7.1 Special-status Plant Survey Objectives Survey objectives are to document known occurrences and locate new occurrences of special- status plants, including surveying for any plant taxa newly added to the list of special-status plant species with potentially suitable habitat. Surveys will also assess changes in any previously known occurrences of special-status plants. 6.7.2 Special-status Plant Survey Schedule and Location Special-status plant surveys will be performed concurrently with the first comprehensive invasive weed survey, within one year following Plan approval. Updated special-status plant surveys will be repeated concurrently with future comprehensive invasive weed surveys at Year 10 and every 10 years thereafter for the life of the License. The special-status plant surveys will provide information on known populations and determine if additional special-status plant occurrences have established. Surveys will be discontinued for any plant species no longer considered to have special-status. If a previously unknown special-status plant is observed during intervening years, it will be mapped and otherwise documented, and the Forest Service will be notified annually at the Annual Pre-operations Consultation meeting. The special-status plant surveys will take place within the Control Area for the Project (Section 3.0), with appropriate adjustments made for changes in Project roads, trails, and facilities associated with the FERC Project boundary or changes in ownership. Specifically excluded from December 2020 Page 49 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan surveys are areas where access is unsafe (e.g., very steep terrain, inaccessible areas, or high-water flows), or private property for which the Licensee does not have specific permission to access the property. 6.7.3Special-status Plant Survey Protocol and Reporting Special-status plant survey protocols will follow botanical survey guidelines detailed in Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed, and Candidate Plants (USFWS 2000 or current) and Protocols for Surveying and Evaluating Impacts to Special-Status Native Plant Populations and Natural Communities (California Department of Fish and Wildlife \[CDFW\] 2018). Surveys will include the collection of data required for completion of CDFW’s California Natural Diversity Database forms, including abundance, phenology, habitat description, and habitat condition. Special-status plants identified during the surveys will be documented using GPS technology. All special-status plant data collected will be included in a GIS database along with target invasive weed data, and the results included in the comprehensive survey report for that year. Both the GIS data and report will be provided to the Forest Service by the date stated on the comprehensive survey reporting schedule (see Section 4.3.2.1). 6.7.4 Monitoring Regular Invasive Weed Control and O&M Disturbance Activities Special-status plant species in the vicinity of invasive weed control and O&M vegetation management activities (e.g., within the same management grid cells) in the Control Area will be flagged for avoidance prior to the activity. To allow for an assessmentof potential impacts of these activities on special-status plants, concurrent with or within one year of initial special-status plant survey, PG&E will establish a limited number (e.g., 10 or fewer) of semi-permanent photo- monitoring plots within special-status plant occurrences that are located adjacent to roads or other facilities that experience regular Project disturbance. Photo-monitoring plots will primarily focus on Forest Service sensitive serpentine species (e.g., Jepson’s onion, Cantelow’s lewisia, white- stemmed clarkia) and other very rare sensitive species (e.g., Mosquin’s clarkia). December 2020 Page 50 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Special-status plant occurrences within photo-monitoring plots will be monitored annually for three years after Plan implementation, during the appropriate phenological period. Data collected will be summarized in a section of the annual monitoring report for target invasive weeds (Section 4.3.2.2) that will be provided to the Forest Service for treatment years 1, 2, and 3, and will include the following: Photographs from fixed photo point locations, from the same direction; General habitat and location description; Signs and nature of disturbance (e.g. herbivory, herbicides, physical destruction, etc.); A qualitative assessment of the site based on evident threats; Number of individuals of the special-status plant species; Vigor of the special-status plant species (e.g., noting percent of plants impacted by disturbance, percent of foliage impacted by disturbance, and type of disturbance); and Percent cover of native and non-native species by growth form (e.g., herbs, shrubs, vines, trees) and bare ground. The third-year monitoring report will provide a final condition assessment. Monitoring will be considered complete if the special-status plant occurrence size and vigor is not negatively affected by Project activities during the three-year monitoring period. If negative impacts are detected, PG&E will consult with the Forest Service to determine next steps. 6.7.5 Monitoring Planned Disturbance Activities For planned disturbance activities (i.e., non-emergency ground disturbing construction activities) that will be conducted near known special-status plant occurrences, a pre-construction evaluation will be conducted in the planned disturbance area to determine if any impacts will occur as a result of the disturbance. Based on the location and nature of the planned activity, PG&E will consult with the Forest Service to determine necessary avoidance and minimization measures during the activity planning. December 2020 Page 51 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan As general guidelines, avoidance and minimization measures will be applied at special-status plant occurrence locations identified in the most recent comprehensive surveys that are within or adjacent to (e.g., within 100 feet of) the planned disturbance activity. Minimization measures – including flagging the occurrence(s) for avoidance –will be applied prior to the planned disturbance. After the disturbance, post-activity monitoring will occur to determine if disturbance avoided the flagged area; if disturbance occurs in the flagged area, PG&E will document this and consult with the Forest Service to determine appropriate mitigation based on the disturbance level. Where practicable, monitoring will be conducted concurrently with comprehensive surveys and/or annual target invasive weed activities. 6.8 Environmental Protection Where vegetation management areas, including those for target invasive weed control, coincide with special-status plant or wildlife populations, wetlands, or other sensitive biological resources, suitable protective measures will be implemented to prevent or minimize adverse effects to sensitive resources. These are listed in Attachment D and described further below. 6.8.1Avoidance and Minimization Measures for Special-status Plants and Wildlife Avoidance and minimization measures will be incorporated into Project activities, including routine O&M vegetation management and target invasive weed treatment, which may have the potential to directly or indirectly affect special-status plants and wildlife. Protection measures will be implemented to avoid adverse effects, as described below (Sections 6.8.2 and 6.8.3, and Attachment D, Measure 14:Pretreatment Flagging, Measure 15 Environmental Training, Measure 19: Manual or Mechanical Control Near Sensitive Resources, and Measure 22: Streamside Wet Area Protection During Herbicide Spraying). Measures to avoid special-status plants and wildlife will include environmental training, flagging of avoidance areas, and limited operating periods. Environmental training for PG&E employees and contractors, including treatment crews, will emphasize to all operations personnel the importance of protecting special-status plant and wildlife species (see Section 6.4), known locations of these species, and current protection measures. Where locations are to be avoided, December 2020 Page 52 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan special-status plant species and special-status wildlife habitat located near treatment activities will be flagged. Any limited operating periods (e.g., for special-status wildlife breeding locations) will be explained and shown on project maps. For target invasive weed treatment, these environmental constraints will also be noted in the management grid maps used to direct annual treatment. In addition, the implementation of Streamside Management Zones (SMZs) will simultaneously provide protection for special-status plant and wildlife species that are primarily aquatic. 6.8.2 Best Management Practices This Plan describes how PG&E will implement general O&M vegetation management and target invasive weed control, while protecting valuable resources such as vegetation, soils, wildlife, range, and recreation into the future. All appropriate laws and regulations governing the use of pesticides, as required by governing agencies (CalEPA, CDPR, and Butte County Agricultural Commissioner) and Forest Service policy pertaining to pesticide use, will be followed. All required licenses and permits will be obtained prior to any pesticide application. In addition to existing laws and regulations, several additional practices will be employed to ensure environmental protection of sensitive resources. By agreement with the State Water Resources Control Board, the Forest Service is the water quality management agency for the lands it administers. A series of measures were developed that California and federal water quality agencies expect the Forest Service to implement in order to maintain and improve water quality (Forest Service 2000, 2011, 2012a). These measures are designed to prevent degradation of downstream water quality. Therefore, PG&E Project compliance with the Clean Water Act includes a monitoring plan approved by the Forest Service and following guidelines from the Central Valley Regional Water Quality Control Board to ensure standards are met. Based on these agency frameworks a series of BMPs that are pertinent to invasive weeds and vegetation management have been incorporated into this Plan and are described in detail in Attachment D, Measures 13 and 16 to 22: Pesticide Spill Contingency Planning; Follow Legal Requirements; Pesticide Application, Monitoring, and Evaluation; Applications Directed by a December 2020 Page 53 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Licensed PCA; Manual or Mechanical Control Near Sensitive Resources; Cleaning and Disposal of Pesticide Containers and Equipment; Controlling Pesticide Drift During Spray Applications; and Streamside Wet Area Protection During Herbicide Spraying. These BMPs describe actions to be followed during vegetation management, including target invasive weed treatment, for the protection of Project natural resources. All herbicide applicators will be qualified, trained, and licensed pesticide contractors and will be reviewed closely by PG&E personnel or their representatives to ensure adherence to regulations, Plan requirements, and reporting requirements (e.g., Butte County Agricultural Commissioner requires monthly reporting). Other BMPs to protect Project natural resources will also be followed; for instance, manual and mechanical control will be used when necessary to provide protection of nearby sensitive resources, cultural sites, or other situations where the use of herbicides may be determined by the Plumas National Forest to be potentially problematic. PG&E’s biologists or contractors will work closely with vegetation management contractors, ensuring that environmentally sensitive resources (e.g., streams, sensitive plant populations) are identified and protected prior to herbicide applications (see Section 6.5 and 6.8.3). 6.8.3 Streamside Management Zones PG&E will minimize the risk of herbicide inadvertently entering waters, or unintentionally altering riparian areas, streams, or wetlands (Forest Service 2000, 2011, 2012a), by establishing untreated stream buffer strips (i.e., SMZs) on all stream courses and roadside ditches that might be impacted by treatment (Attachment D, Measure 22 Streamside Wet Area Protection During Herbicide Spraying). Untreated SMZ widths will be based on the type of herbicide and its chemical properties, stream class, and the presence of water during treatment (Attachment D, Table D-1). These SMZs will provide adequate protection for downstream beneficial uses. These SMZs will also provide protection for special-status organisms utilizing mesic or aquatic habitat (e.g., special- status wildlife in streams). December 2020 Page 54 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6.8.3.1Water Quality Monitoring Based on proposed treatment prescription, a water quality monitoring protocol (following requirements from Forest Service 2000 and 2012a) is included as Attachment H. Water quality monitoring will verify that no herbicides prescribed for the Project’s Control Area enter the surface waters and will confirm efficacy of SMZs. Water quality monitoring consists of qualified laboratory testing of upstream and downstream surface water “control” samples for presence of herbicides prior to herbicide application, followed by repeat samples after treatment following run- off producing rainfall to detect any herbicide entering waterbodies. The intent of the water quality monitoring protocol will be to determine if the SMZs and other BMPs implemented are adequately protecting Project water bodies from herbicide run-off. As such, the protocol provides a means for halting testing after three years of negative detections if treatment methods and herbicides have not changed. December 2020 Page 55 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 7.0 Revegetation PG&E will be responsible for identifying sites where revegetation may be required due to Project- related activities that are expected to disturb, or have disturbed, a site. 7.1 Areas and Activities Subject to Revegetation PG&E will evaluate areas disturbed by Project activities on a site-by-site basis to determine if revegetation is necessary or appropriate. Disturbance may result from the following: Construction activities; Control treatments for target invasive weeds; Routine O&M vegetation treatment, where the cleared area does not need to be maintained as bare ground, paved, or covered; and Other ground-disturbing activities. Revegetation of disturbed soil will be designed in a manner that optimizes plant establishment for each disturbed site. Sites that are subject to constant disturbance or where bare ground needs to be maintained will not be revegetated. 7.2 Evaluation of Sites for Revegetation When construction activities are planned, PG&E includes revegetation planning as part of the preconstruction planning process. As part of this planning, a preconstruction site assessment will be performed, which would assess factors such as site size, percent vegetation cover, erosion potential, plant community, and land ownership. For emergency repairs, this preconstruction planning is not possible. If disturbance is caused by Project activities, a post-construction site assessment will be performed, which will assess (or reassess) the factors listed above. The post-construction assessment will take place within 30 days of the disturbance, or as soon as feasible thereafter. If the site is on NFSL, PG&E will consult with the Forest Service. Once the post-construction assessment is completed, the site will be revegetated if the following criteria are present: December 2020 Page 56 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Vegetative cover is less than or equal to 30 percent of the original vegetative cover (or a comparable reference site if pre-disturbance conditions are unknown); Erosion is evident, or the potential for erosion is moderate to high; Probability of invasive weed establishment is moderate to high; and/or Little to no possibility of natural regeneration (recruitment) is expected from the surrounding plant communities. Disturbed sites that do not meet the initial criteria for revegetation will be monitored for three years. After three years, if the site contains 70 percent or more of the original vegetative cover, then the site will be considered to not require revegetation and no further action will be taken. If the site contains 69 percent or less of the original vegetative cover after three years, then revegetation actions will be developed and implemented, and the site will be monitored an additional two years, for a total of five years of monitoring. After five years of monitoring (if needed), the sites will continue to be monitored for target invasive weeds as part of the comprehensive survey (five-year interval) and annual treatment and monitoring program. If success criteria are not met after five-years, an adaptive response will be implemented. 7.3 Revegetation Once the initial assessment is completed, and if revegetation is determined to be necessary, the following process will be implemented: Revegetation planning, including site documentation and assessment, Site preparation, Installing the revegetation (e.g., seeding, planting, etc.), and Revegetation monitoring. 7.3.1Revegetation Planning The site assessment will be used to develop the revegetation plan. This assessment will consist of the following: December 2020 Page 57 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 1.Documenting general site conditions, which may include, but is not limited toslope, terrain, micro-climate, soils, land use, access, and proximity to water; 2. Documenting vegetation community(ies), byevaluating native species composition, species richness,density or abundance, and site complexity (e.g., variety of landforms, soils, communities, etc.); 3. Determining native seed/plant sources and availability, with a preference for utilizing locally collected plant propagules (e.g., seed or cuttings) where feasible; and 4. Examining potential revegetation methods and optimum timing of seeding or planting. If practicable, the site conditions above will be documented prior to disturbance. If this is not practicable, these conditions will be evaluated at a similar undisturbed site nearby. If the site size is less than or equal to 0.25 acre, PG&E will develop a list of action items that includes the species to be planted, the method(s) for revegetation, and an implementation schedule. If the site size is greater than 0.25 acre, then PG&E will develop a site-specific revegetation plan consisting of the following: Site-specific end use or desired condition; Species to be planted (selected by a knowledgeable plant resource specialist – species and seed mixes pre-approved by the Plumas National Forestare listed in Attachment I); Methods for revegetation (e.g., hydromulch, rootstock, containerized) and optimum timing for seeding or planting; Measures for preventing plant diseases (e.g., Phytophthora fungus); Soil treatments (if necessary); Site planting design (i.e., what and where plant species will be placed); Irrigation design and timing; Success criteria; Monitoring plan; Management of invasive weeds; Remedial actions; and Schedule of activities. December 2020 Page 58 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan PG&E will be responsible for obtaining (i.e., collecting and/or ordering) necessary plant materials for revegetation activities. Planning well in advance for large work activities is critical; two or more years may be needed to obtain some native plant materials in sufficient quantities for revegetation. PG&E is also responsible for conducting all tasks associated with site revegetation and monitoring. Revegetation treatments will adhere to established BMPs for seed, mulch, and fertilizer used, as well as to site-specific plans designed to eliminate or greatly reduce the potential for colonization of invasive weeds. Measures for preventing and controlling invasive weeds are provided in Section 4.3.1 and Attachment D. 7.3.2 Revegetation Methods Site preparation may include surface soil scarification to reduce soil compaction. For small sites, this may be accomplished by hand raking; in larger sites, mechanical harrowing or raking may be needed. On a site-by-site basis, soil amendments, such as compost or fertilizer, may be applied if needed; however, amendments will not be applied where potential to enter waterways exists. After site preparation, based on site specifics, revegetation may include topsoil replacement, seeding, planting, or a combination of these methods. Small restoration projects on NFSL (less than or equal to 0.25 acre) will follow the guidelines provided here (Section 7.3.1 including subsections). Larger projects on NFSL (more than 0.25 acre) would require Forest Service approval of seed or planting mixes, rates, and methods, as well as any necessary irrigation or other maintenance (e.g., weeding, thinning, etc.) as part of the proposed planting plan (Section 7.3.1). 7.3.2.1 Topsoil replacement Topsoil replacement is a common, cost-effective method of reestablishing native herbaceous plants in small, disturbed areas that have had short-term ground disturbance. Where practical, the top 6 to 10 inches of invasive weed-free (or nearly invasive weed-free) topsoil may be stockpiled in a specified area at the beginning of ground-disturbing activities to serve as a native seed source December 2020 Page 59 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan for natural revegetation. At the end of work activities, the salvaged topsoil is redistributed and/or recontoured over the top of disturbed areas andmay be tamped in or mulched to stabilize. This method is most successful when topsoil is stockpiled for a short time (a few weeks to months) during dry weather, after the desirable herbaceous species have set seed for the season. 7.3.2.2Seeding Seeding may be most effective where the disturbed site is relatively small and located adjacent to native plant populations that will provide supplemental inputs of native plant propagules. Seed mixes will generally include native grasses and forbs approved by a qualified PG&E biologist. On NFSL, to the extent practicable, PG&E will use seed mixes that meet the current standards of the Plumas National Forest (Attachment I). If native seed is unavailable or in emergency situations that require ground cover (e.g. reduce erosion, invasive weed prevention), the site may be seeded with a quick growing sterile non-native species (e.g., non-persistent sterile cereal grains). When possible, sites will be seeded when temperature and moisture favor germination (e.g., during the fall rainy season). Seeding may be accomplished by broadcasting, hydroseeding, or drilling, depending on site-specific conditions. After seeding, sites may be mulched to protect the soil from erosion, conserve soil moisture, and deter seed predation. Only materials free of invasive weed seeds and other propagules (e.g., rhizomes, runners) will be used for mulch (e.g. certified invasive weed-free straw, clean rice straw, native grass hay, hydromulch, bonded fiber matrix, and/or erosion control mats). 7.3.2.3 Planting Larger disturbed areas may be replanted with native trees, shrubs, and perennials, in addition to native grasses and forbs. Plant materials may be purchased or grown from genetically appropriate native stock, at approved professional nurseries, if practicable. For some sites, salvaged plant materials from the disturbance area (or nearby sites) may be used, which are preferable. In some cases (e.g., willows) plants may be planted as cuttings rather than rootstock. Selected species and planting densities will depend on the location, terrain, soils, desired end state for vegetation management requirements, and any associated needs for habitat enhancement and aesthetics. December 2020 Page 60 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan These species would be described in the site-specific Revegetation Plan (or Revegetation Action Items) as appropriate to the location (Section 7.3.1). 7.3.3 Revegetation Monitoring PG&E will conduct revegetation monitoring to evaluate the establishment of plantings, assess the need to implement remedial measures, and evaluate the effectiveness of target invasive weed control measures. Success criteria for revegetation projects may include measures of percent vegetative cover,plant survival counts,species richness, plantdensity orabundance, invasive weed control, and erosion control. Revegetation sites will be monitored until success criteria are met. If, after three years of monitoring, success criteria are not met, remedial measures will be implemented and monitoring will occur for another two years, for a total of five years of monitoring. Sites where success criteria are not met within five years will be subject to adaptive response. Adaptive response will consist of refining the success criteria and/or revegetation goals and objectives based on site-specific conditions and constraints. The intent is to define a process where multiple attempts at revegetation (including remedial actions) can come to closure if site-specific problems prevent achieving the initial success criteria. For sites on NFSL, modified success criteria will be defined in consultation with and approved by the Forest Service. Small revegetation sites (less than or equal to 0.25 acre) may only require quick annual checks to determine if native vegetation is establishing and invasive weeds are controlled. Larger revegetation sites (greater than 0.25 acre) will be revisited at least once during the year following planting, with monitoring data collected as designated in the site-specific Revegetation Plan (Section 7.3.1). Where feasible, monitoring visits will be concurrent with annual invasive weed activities. All sites will be included in the comprehensive invasive weed surveys, with target invasive weed occurrences incorporated into the annual monitoring management grid. Revegetated sites will continue to be included in these target invasive weed mapping, treatment, and monitoring processes once revegetation monitoring concludes. December 2020 Page 61 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 8.0 Plan Revisions Changes in infestation or other vegetation conditions, treatment effectiveness, and resource conditions may result in the need to adapt this Plan. Accordingly, the tools available for efficient treatment, including treatment methods, may also change over time; utilizing best available technologies is a critical component of an integrated pest management approach. If new conditions are observed, and changes to the Plan are necessary or desirable, PG&E, in consultation with the Plumas National Forest will review, update, and revise this document (Poe Integrated Vegetation Management Plan). Coordination and Plumas National Forest review will ensure that the proposed changes fall within the scope of the License and 4(e) Conditions. Changes that may be considered include methodologies and monitoring frequencies based on current conditions and available treatment methods. PG&E would also present a summary memo or letter, notifying FERC and the Plumas National Forest of the proposed Plan changes. After consultation and agreement with the Plumas National Forest, the Licensee will work with the Plumas National Forest to file the updated Plan with FERC. The Licensee will include all relevant documentation December 2020 Page 62 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 9.0 References Belsher-Howe, J. 2014. List of Rare Plants and Weeds for the Plumas National Forest. Excel Spreadsheet. 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. California Department of Fish and Game (CDFG). 2008. California Aquatic Invasive Species Management Plan. State of California Resources Agency. Dated January. Sacramento, California. California Department of Fish and Wildlife (CDFW). 2018. Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities. Dated March 20, 2018. California Department of Food and Agriculture (CDFA). 2014. Section 3162 Pest Ratings and Mitigating Actions. Accessed online on September 28, 2020 at https://www.cdfa.ca.gov/plant/pestratings/docs/3162-ApprovedText-final.pdf.Dated August 18, 2014. California Department of Forestry and Fire Protection (CalFire). 2007. Fire Hazard Severity Zones in SRA; adopted by Cal Fire on November 7, 2007. Accessed May 22, 2019 at http://frap.fire.ca.gov/webdata/maps/butte/fhszs_map.4.pdf. California Department of Food and Agriculture (CDFA). 2016. Pest Rating Proposals and Final Ratings by Lisa Serrano. Accessed online on September 28, 2020 at blogs.cdfa.ca/Section3162/?p=1958. Dated May 13, 2016. California Department of Pesticide Regulation (CDPR). 2003. Pesticide Safety Information Series, documents N-1, N-2, N-3, N-4, N-5, N-7, N-8, N-10 regarding use of pesticides in non- agricultural settings. Accessed from http://www.cdpr.ca.gov/docs/whs/psisenglish.htm. California Department of Pesticide Regulation (CDPR). 2019. Laws and information page found at California Pesticide Information Portal accessed online at https://calpip.cdpr.ca.gov/main.cfm. DiTomaso, J.M., G.B. Kyser et al. 2013. Weed Control in Natural Areas in the Western United States. Weed Research and Information Center, University of California. 544 pp. December 2020 Page 63 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Federal Energy Regulatory Commission (FERC). 2007. Final Environmental Assessment Poe Hydroelectric Project, Project No. 2107-016, California. Office of Energy Projects, Division of Hydropower Licensing. Washington, DC. Federal Energy Regulatory Commission (FERC). 2018. Order Issuing New License. Project Nos. 2107-016. Prepared by Federal Energy Regulatory Commission, Office of Energy Projects, Division of Hydropower Licensing. Washington, DC. December 17. Meyer, Deborah, J. Lionakis, and Jim Effenberger. 2010. California Noxious Weed Disseminules Identification Manual. California Department of Food and Agriculture Plant Pest Diagnostics Center – Seed Laboratory. Sacramento, CA. Pacific Gas and Electric Company (PG&E). 2003. Poe Hydroelectric Project FERC No. 2107 Application for New License. Report E3 Fish Wildlife and Botanical Resources, Section E3.3 Botanical Resources. Final: December. Pacific Gas and Electric Company (PG&E). 2019. Wildlife Fire Defensible Space for Substations. Utility Bulletin: TD-3322B-065. Dated May 8, 2019. Southern California Geographic Coordination Center. 2019. Fuel Moisture Definitions. Accessed June 2019 at https://gacc.nifc.gov/oscc/fuelsFireDanger.definitions.php. Syracuse Environmental Research Associates (SERA). 2014. Preparation and Environmental Documentation and Risk Assessments for the USDA/Forest Service. Prepared by Patrick Durkin. Document MD-2014-02b.Accessed online June 17, 2020 at https://www.fs.fed.us/foresthealth/pesticide/pdfs/PrepEnvirmentalDoc_11-2014.pdf. Manlius, New York. Dated November 17, 2014. Systems for Environmental Management. 2019. FlamMap. Accessed online in June 2019 at http://www.fire.org. Thomson Reuters. 2020. Westlaw California Code of Regulations Website, describing 3CCR §4500 Noxious Weed Species. Accessed online on September 28, 2020 at https://govt.westlaw.com/calregs/Document/ID0CA0B50BE0A11E4A26BC7E8507C2F0 D?transitionType=Default&contextData=%28sc.Default%29. United States Department of Agriculture – Forest Service (Forest Service). 1994. Forest Service Handbook (FSH) 2109.14 – Pesticide-use Management and Coordination Handbook. Effective December 6, 1994. United States Department of Agriculture – Forest Service (Forest Service). 2000. Pacific Southwest Region Water Quality Management for Forest Service Lands in California. Best Management Practices. September 2000. Accessed online on September 28, 2020 at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5362512.pdf December 2020 Page 64 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan United States Department of Agriculture – Forest Service (Forest Service). 2011. Forest Service Handbook – Soil and Water Conservation Handbook, Chapter 10 (R5 FSH 2509.22), Section 12.2. Accessed online at https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/ stelprdb5399662.pdf. United States Department of Agriculture – Forest Service (Forest Service). 2012a. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. (FS-990a). April 2020. Accessed online on September 28, 2020 at https://www.fs.fed.us/naturalresources/watershed/pubs/ FS_National_Core_BMPs_April2012.pdf. United States Department of Agriculture – Forest Service (Forest Service). 2012b. Forest Health Protection Pacific Southwest Region (Report # RO-12-01) Hazard Tree Guidelines For Forest Service Facilities and Roads in the Pacific Southwest Region. P.A. Angwin, D.R. Cluck, P.J. Zambino, B.W. Oblinger, and W.C. Woodruff contributors. Dated April 2012. United States Department of Agriculture – Forest Service (Forest Service). 2013. Forest Service Handbook Pacific Southwest (R5), FSH 3409.11 - Forest Health Protection Handbook, Chapter 60 – Management of Specific Pests. Vallejo, CA (effective June 10, 2013) United States Department of Agriculture – Forest Service (Forest Service). 2018. Forest Service revised final license terms and conditions necessary for the protection and utilization of the Plumas National Forest in condition with the application for license Poe Hydroelectric Project, FERC No. 2107, Pacific Gas and Electric Company. Prepared by the United States Department of Agriculture, Forest Service. Pacific Southwest Region. July 6. United States Department of Agriculture – Forest Service (Forest Service). 2019. FireFamilyPlus. Fire, Fuel, Smoke Science Program, FireFamilyPlus website. Accessed online June 2019 at https://www.firelab.org/project/firefamilyplus. Rocky Mountain Research Station. United States Department of Agriculture – Forest Service (Forest Service). 2020a. Fire, Fuel, Smoke Science Program, FARSITE website. Accessed online on September 29, 2020 at http://firelab.org/project/farsite. Rocky Mountain Research Station. United States Department of Agriculture – Forest Service (Forest Service). 2020b. Hazard Trees Guidelines Addendum. File Code 3410, to Directors and Forest Supervisors, from Randy Moore, Regional Forester Pacific Southwest Region and signed by Steven M. Lohr. Pacific Southwest Region, Regional Office, Vallejo, California. Dated October 7, 2020. United States Department of Agriculture – Forest Service (Forest Service). 2020c. Defining the Hazard Tree Failure Zone (2020), Addendum to Hazard Tree Guidelines For Forest Service Facilities and Roads in the Pacific Southwest Region (2012). December 2020 Page 65 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan United States Department of Agriculture – Forest Service (Forest Service). 2020d. Streamlined Approach to Hazard Tree Abatement After Catastrophic Events (2020), Addendum to Hazard Tree Guidelines for Forest Service Facilities and Roads in the Pacific Southwest Region (2012). United States Department of Agriculture – Forest Service (Forest Service) and United States Department of Interior (USDOI). 2019. Landfire. Accessed June 2019 at https://www.landfire.gov/index.php. United States Fish and Wildlife Service (USFWS). 2000. Guidelines for Conducting and Reporting Botanical Inventories for Federally Listed, Proposed and Candidate Plants. Dated January 2000. United States Fish and Wildlife Service (USFWS). 2018. Guidelines for Preventing the Spread of Aquatic Invasive Species. Region 7, Anchorage, AK. 99503. August 2018. Accessed online at https://www.fws.gov/r7/fisheries/invasive/pdf/Region%207%20Aquatic%20 Invasive%20Species%20Prevention%20Guidelines_Final_083018.pdf. United States Fish and Wildlife Service (USFWS). 2020. Invasive Species webpage. Available at: http://www.fws.gov/invasives/faq.html#q2. December 2020 Page 66 Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT A FERC License Requirements Addressing Invasive Weed Management December 2020 Page A-1 Attachment A Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan The License requirements addressing invasive weed management are as follows (from FERC 2018): Article 403. Invasive Weed Management Plan. The Invasive Weed Management Plan required by Forest Service Condition 34 in AttachmentB of this license must apply to all lands within the project boundary. Article 401. Commission Approval, Reporting, Notification, and Filing of Amendments. (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** Fuel treatment plan - 29 *Excerpt from FERC 2018 Article 401 **Date modified to December 17, 2020 in FERC Order dated January 6, 2020, Modifying Article 401 and Granting Extension of Time 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. Forest Service 4(e) Condition No. 34: Invasive Weed Management Plan. Within two years of license issuance, the Licensee shall file with the Commission an Invasive Weed Management Plan developed in consultation with the Forest Service, the appropriate County Agricultural Commissioner and California Department of Food and Agriculture. Invasive weeds will be those weeds defined in the California Food and Agriculture code, and other species identified by the Forest Service. The plan will address both aquatic and terrestrial invasive weeds within the project December 2020 Page A-2 Attachment A Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan boundary and adjacent to project features directly affecting National Forest System lands including, roads, and distribution and transmission lines. The Invasive Weed Plan will include and address the following elements: Inventory and mapping of new populations of Invasive weeds using a Forest Service compatible database and GIS software. The Invasive weed GIS data layer will be updated periodically and shared with resource agencies. Action and/or strategies to prevent and control spread of known populations or introductions of new populations, such as vehicle/equipment wash stations. Development of a schedule for control of all known A, B, Q and selected other rated invasive weed species, designated by resource agencies. On-going annual monitoring of known populations of Invasive weeds for the life of the license in locations tied to project actions or effects, such as road maintenance, at project facilities, O&M activities, new construction sites, etc. to evaluate the effectiveness of re- vegetation and Invasive weed control measures. The plan will include an adaptive management element to implement methods for prevention of aquatic Invasive weeds, as necessary. These actions may include, but may not be limited to: 1.public education and signing of public boat access, 2.preparation of an Aquatic Plant Management Plan approved by the Forest Service, and in consultation with other agencies, and 3.boat cleaning stations at boat ramps for the removal of aquatic Invasive weeds. New infestations of A & B rated weeds shall be controlled within 12 months of detection or as soon as is practical and feasible (A, B, C, & Q ratings refer to the California Department of Food & Agriculture Action Oriented Pest Rating System). At specific sites where other objectives need to be met all classes of Invasive weeds may be required to be treated. Monitoring will be done in conjunction with other project maintenance and resource surveys, so as not to require separate travel and personnel. Monitoring information, in database and GIS formats, will be provided to the Forest Service as part of the annual consultation on affected National Forest resources (Condition No. 3). To assist with this monitoring requirement, training in invasive plant identification will be provided to project employees and contractors by the Forest Service. Licensee shall restore/revegetate areas where treatment has eliminated Invasive weeds in an effort to eliminate the reintroduction of Invasive weed species. Project-induced ground disturbing activities shall be monitored annually for the first 3 years after disturbance to detect and map new populations of Invasive weeds. Forest Service 4(e) Condition No. 12: Pesticide Use Restrictions on NFSL. Pesticides may not be used to control undesirable woody and herbaceous vegetation, aquatic plants, insects, and rodents, undesirable fish, or other pests on National Forest System lands without the prior written December 2020 Page A-3 Attachment A Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan approval of the Forest Service. The Licensee shall submit a request for approval of planned uses of pesticides. The request must cover annual planned use and be updated as required by the Forest Service. The Licensee shall provide information essential for review in the form specified. Exceptions to this schedule may be allowed only when unexpected outbreaks of pests require control measures that were not anticipated at the time the request was submitted. In such an instance, an emergency request and approval may be made. The Licensee shall use on National Forest System lands only those materials registered by the U.S. Environmental Protection Agency for the specific purpose planned. The Licensee must strictly follow label instructions in the preparation and application of pesticides and disposal of excess materials and containers. Forest Service 4(e) Condition No. 29: Fuel Treatment Plan. Within one year of License issuance, Licensee shall file with the Commission a Fuel Treatment Plan, approved by the Forest Service, for the purpose of identifying hazardous vegetative conditions surrounding project facilities that may accelerate the spread of a wildfire onto National Forest System lands as a result of Licensee activities or might place project facilities in jeopardy from an approaching fire. At a minimum the plan shall include provisions for: (1) analysis of live and dead fuel loading and potential fire behavior within 300 feet of project features; (2) treatments to be employed to reduce the hazard; (3) implementation schedule; and (4) provisions for the reassessment of hazard at 5 to 8 year intervals depending on regrowth of vegetation. Treatments extending onto adjacent National Forest System lands shall be approved by the Forest Service. When practicable coordinate implementation and accomplishment of hazard reduction activities with those of the Forest Service. December 2020 Page A-4 Attachment A Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT B CDFA Noxious Weed Species December 2020 Page B-1 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 1, 2 CDFA Section 4500 and List A, B, and Q Noxious Weed Species California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed List Rating System Acacia paradoxa kangaroo thorn yes none B Acaena anserinifolia bronze piri-piri-bur yes none A Acaena novae-zelandiae biddy-biddy yes none A Acaena pallida pale biddy-biddy yes none A Acroptilon repens Russian knapweedyes none B Aegilops cylindrica jointed goat grass yes none B Aegilops ovata ovate goat grass yes none B Aegilops triuncialis barbed goat grass yes none B Aeschynomene species joint-vetch yes A A Ailanthus altissima tree of heaven yes CC Alhagi maurorum camelthorn yes none A Allium paniculatum panicled onion yes none B Allium vineale wild garlic yes none B Alternanthera alligatorweed yes A A philoxeroides Alternanthera sessilis sessile joyweed yes none A Ambrosia trifida giant ragweedyes BB Araujia sericifera bladderflower yes none B Arctotheca calendula capeweed yes A A Arundo donax giant reed yes BB Asphodelus fistulosus onionweed yes none A Atriplex amnicola river saltbush yes none B Baccharis halimifolia sea myrtleno A none Berteroa incana hoary alyssum yes none B Brachypodium sylvaticum slender false-brome yes none A Butomus umbellatus flowering-rush no Bnone Cabomba caroliniana Carolina fanwort yes none B Carduus acanthoides plumeless thistle yes none A Carduus crispus welted thistle yes none A Carduus nutans musk thistle yes none A Carduus pycnocephalus slender-flowered thistle yes none C Carduus tenuiflorus Italian thistle yes none C Carrichtera annua Ward's weed no A none Carthamus baeticus smooth distaff thistle yes none B Carthamus lanatus woolly distaff thistle yes none B Carthamus leucocaulos whitestem distaff thistle yes none A December 2020 Page B-2 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Carthamnus oxyacantha jeweled distaff thistle no Bnone Cenchrus echinatus southern sandbur yes none C Cenchrus incertus coast sandbur yes none C Cenchrus longispinus mat sandbur yes none C Centaurea calcitrapa purple star-thistleyesnoneB Centaurea diffusa diffuse knapweedyes none A Centaurea iberica Iberian star-thistleyesnoneA Centaurea jacea meadow knapweed (includes C. pratensis, C. (black or brown yes none A nigra, C nigrescens) knapweed) Centaurea melitensis tocalote yes none C Centaurea solstitialis yellow star-thistle yes none C Centaurea squarrosa squarrose knapweed yes none A Centaurea stoebe (= spotted knapweed yes none A Centaurea maculosa) Centaurea sulphurea Sicilian star-thistle yes none B Ceratopteris thalictroides waterspriteyes D B Chondrilla juncea skeletonweedyes none A Chorispora tenella purple mustard yes none B Chrysanthemoides Bitou bush no A none monilifera Cirsium arvense Canada thistle yes none B Cirsium japonicum Japanese thistle yes D B Cirsium ochrocentrum yellowspine thistle yes CA Cirsium undulatum wavyleaf thistle yes D B Cirsium vulgare bull thistle yes none C Clematis vitalba old man's beardnoAnone Coincya monensis star-mustard yes none B Convolvulus arvensis field bindweed yes CC Cortaderia jubata jubata grass yes none B Crupina vulgaris bearded creeper yes A A Cucumis melo var. dudaim melon yes none A dudaim Cucumis myriocarpus paddy melon yes none B non-native dodder Cuscuta spp. (non-native) yes none A species Cynara cardunculus artichoke thistle yes none B Cyperus esculentus yellow nutsedge yes none B Cyperus rotundus purple nutsedge yes none B December 2020 Page B-3 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Cytisus scoparius Scotch broom yes none C Cytisus striatus Portuguese broom no Bnone Diodia virginiana buttonweed yes CB Dittrichia graveolens stinkweed yes none none Dittrichia viscosa false yellowheadnoAnone Drymaria cordata whitesnow yes CB Echium plantagineum Paterson's cursenoAnone Egeria najas narrow-leaf elodea yes none A Elymus repens (same as quack grass yes none B Elytrigia repens) Enchylaena tomentosa ruby saltbush no A none Erica lusitanca Spanish heath no Bnone Euphorbia dendroides tree spurge yes Bnone Euphorbia esula leafy spurge yes none A Euphorbia graminea grassleaf spurgeyes none B Euphorbia hypericifolia graceful spurge no A none Euphorbia myrsinites myrtle spurge no A none Euphorbia oblongata oblong spurgeyesnoneB Euphorbia serrata serrate spurge yes none A Geraldton carnation Euphorbia terracina yes none B spurge Fallopia japonica (same as Polygonum Japanese knotweed yes A B cuspidatum, Reynoutria japonica) Fallopia sachalinensis (same as Polygonum giant knotweed yes A B sachalinensis, Reynoutria sachalinensis) Fallopia xbohemica (same as Reynoutria Bohemian knotweed yes A none xbohemica, Polygonum xbohemica Fatoua villosa hairy crabweed yes none B Galega officianalis goatsrue yes A none Genista monspessulana French broomyes CC Geranium lucidum shining cranesbill no A none Gymnocoronis spilanthoides (same as Senegal tea plant no A none Alomia splanthoides) December 2020 Page B-4 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Gypsophila paniculata baby's breath no Bnone Halimodendron Russian salttree yes none A halodendron Halogeton glomeratus halogeton yes none A Helianthus ciliaris blueweedyes none A Heracleum giant hogweed no A none mantegazzianum kidneyleaf mud Heteranthera reniformis noA none plantain Heteropogon contortus tanglehead yes none B Hieracium aurantiacum orange hawkweed no Bnone Hydrilla verticillata hydrillayes none A Hydrocharis morsus- frogbit yes A A ranae Hygrophila polysperma swampweedyes A A Hyoscyamus niger black henbane yes none C Canary Island Saint Hypericum canariense yes none B John’s-wort Hypericum perforatum Klamathweedyes none C Iris pseudacorus yellow-flag iris no BQ Isatis tinctoria dyer's woad yes none B oxygen weed, African Lagarosiphon major yes none A elodea Lepidium appellianum hairy white-top, globe- (same as Cardaria yes none B podded hoarycress appellanum) Lepidium chalepensis lens-podded hoary (same as Cardaria yes none B cress chalepensis) Lepidium coronopus (same as Coronopus swinecress yes none B squamatus) Lepidium draba (same as heart-podded yes none B Cardaria draba) hoarycress Lepidium latifolium perennial peppercressyes none B Leptochloa chinensis (same as Dinebra Chinese sprangletop yes none none chinensis) South American Limnobium laevigatum yes A A spongeplant December 2020 Page B-5 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Limnobium spongia spongeplant yes none A Limnophila indica ambulia yes none A Limnophila sessiliflora dwarf ambulia yes none A Limonium durisculum European sea lavendar no Bnone Limonium ramosissmum Algerian sea lavendarnoB Linaria dalmatica Dalmatian toadflaxyes none A Ludwigia decurrens winged water-primroseyesAnone Ludwigia hexapetala water-primrose yes Cnone Peruvian primrose- Ludwigia peruviana yes none A willow Lythrum salicaria purple loosestrife yes none B Mantisalca salmantica (same as Centaurea dagger-flower no A none salmantica) Mercuraialis ambigua Spanish mercury yes Bnone Monochoria vaginalis false pickel weed no A none Muhlenbergia schreberi nimblewill yes none B Myosoton aquaticum giant chickweed yes CB Myriophyllum aquaticum parrotfeather no CB Nothoscordum gracile fragrant false garlicyesnoneB Nymphaea mexicana banana waterlily yes CB Nymphoides peltata yellow floating heart yes A none Oenothera sinuosus wavy-leaved gaura yes none B (same as Gaura sinuata) Oenothera xenogaura (same as Gaura Drummond’s gaura yes none B drummondii) Ononis alopecuroides foxtail restharrow yes none A Onopordum acanthium Scotch thistle yes none A and other congeners Onopordum illyricum Illyrian thistle yes none A Onopordum tauricum Taurian thistle yes none A Orobanche aeyptica Egyptian broomrape no A none Orobanche ramosa branched broomrape yes A A Oryza rufipogon perennial wild red riceyes none B Panicum antidotale blue panicgrass yes CB Parthenium Santa Maria feverfew yes A none hysterophorus Peganum harmala harmel yes none A December 2020 Page B-6 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Pennisetum clandestinum (same as Cenchrus Kikuyugrass yes C C clandestinus) Persicaria wallichii (same as Polygonum Himalayan knotweed yes none B polystachyum, Rubrivena polystachya) Physalis virginiana var smooth groundcherry yes none A sonorae Physalis viscosa grape groundcherry yes none B Phytolacca hetertepala Mexican pokeweednoAnone Potentilla recta sulfur cinquefoil yes none A Prosopis strombulifera creeping mesquite yes none A Retama monosperma bridal broom yes none B Rhagadiolus stellatus star endive yes none Q Rorippa austriaca Austrian field cress yes none B creeping yellow field Rorippa sylvestris yesnoneB cress Saccharum ravennae ravennagrass yes none none spineless Russian Salsola collina yes A A thistle Salsola damascena (same wormleaf salsola yes none A as Salsola vermiculata) barbwire Russian Salsola gobicola noB none thistle barbwire Russian Salsola paulsenii yes none C thistle Salsola tragus common Russian thistle yes C C Salvia aethiopis Mediterranean sage yes none B Salvia virgata southern meadow sageyes none A Salvinia auriculata giant salvinia yes none A Scolymus hispanicus golden thistle yes none A Senecio jacobaea tansy ragwort yes none B Senecio linearifolius narrowleaf ragwortyes none A Senecio squalidus Oxford ragwortyes none B scarlet wisteria, rattle Sesbania punicea yes none B box, red sesbania Setaria faberi giant foxtail yes none B December 2020 Page B-7 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Solanum cardiophyllum heartleaf nightshade yes CA Solanum carolinense Carolina horsenettleyes none B Solanum dimidiatum Torrey's nightshade yes none A Solanum elaeagnifolium white horsenettle yes none B Solanum lanceolatum lanceleaf nightshadeyesnoneB white-margined Solanum marginatum yes B B nightshade Sonchus arvensis perennial sowthistleyesnoneA Johnsongrass and Sorghum halapense similar perennial yes none C species Spartina alterniflora and smooth cordgrass and yes none B hybrids hybrids Spartina anglica common cordgrass yes none B dense-flowered Spartina densiflora yes none B cordgrass Spartina patens saltmeadow cordgrass yes none B Spartium junceum Spanish broom yes none C Sphaerophysa salsula Austrian peaweed yes none A Stipa brachyachaeta (same as Achnatherum brachychaeta, puna grass yes none A Ameliochloa brachychaeta) Striga asiatica witchweed yes A A Symphytum asperum rough comfreyyesnoneB Taeniatherum caput- medusahead grass yes none C medusae Tagetes minuta wild marigoldyes none A Tamarix chinensis Chinese tamarisk yes none B Tamarix gallica French tamariskyes none B Tamarix parviflora smallflower tamarisk yes none B Tamarix ramosissima saltcedar yes none B Tribolium obliterum Cape grass yes none none Tribulus terrestris puncturevine yes none C Ulex europaeus gorse yes none B Vachellia nilotica prickly acacia no A none Viscum album European mistletoe yes A B December 2020 Page B-8 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan California Action- 2 Scientific Name Common Name Noxious Pest Rating Oriented 13 Weed ListRating System Canary Island Volutaria canariensis yesnonenone knapweed Volutaria tubuliflora desert knapweed no A none Youngia japonica Japanese hawkweed no Bnone Zizania latifolia Manchurian wild rice no A none Zostera japonica Japanese eelgrassyesnoneA Zygophyllum fabago Syrian beancaperyesnoneA 1 – From 3 CCR §4500, as reported in Thomson Reuters 2020. 2 – Rating from CDFA Pest Rating (CDFA 2016). This rating system is in process, and not all noxious weed species listed in 3 CCR §4500 or those of interest to the Plumas National Forest have been rated. Some noxious weed species have been rated that are not listed in 3 CCR §4500. Ratings are as follows: A - Pests of the agricultural industry or environment which score high and are not known to occur or under official control in the State of California. Has authorized mitigating regulatory actions. B - Pests of the agricultural industry or environment which score medium to high and which are of limited distribution in the State of California. Has authorized mitigating regulatory actions. C - Pests of the agricultural industry or environment which score medium to low and are of common occurrence and generally distributed in California. Has no State-enforced authorized mitigating regulatory actions. D - An organism which scores low and is known to be of little or no economic importance to the agricultural industry or environmental detriment, has an extremely low likelihood of invasiveness, is known to be a parasite or predator or pathogen of a pest, or is an otherwise beneficial organism. No authorized mitigating regulatory actions. Q - Pests of the agricultural industry or environment which score high and which are not known to occur or where their California distribution is unknown and which are otherwise suspected of being economically harmful to the agricultural industry or the environment and which may not be completely identified or for which there is inadequate available scientific information. Has authorized mitigating regulatory actions. 3 – Rating from the older CDFA Action Oriented Rating System (Meyer et al. 2010) has also been provided, with definitions as follows: A – A pest of known economic or environmental detriment and is either not known to be established in California or it is present in a limited distribution that allows for the possibility of eradication or successful containment. A-rated pests are prohibited from entering the state because, by virtue of their rating, they have been placed on the of Plant Health and Pest Prevention Services Director’s list of organisms “detrimental to agriculture” in accordance with the FAC Sections 5261 and 6461. The only exception is for organisms accompanied by an approved CDFA or USDA live organism permit for contained exhibit or research purposes. If found entering or established in the state, A-rated pests are subject to state (or commissioner when acting as a state agent) enforced action involving eradication, quarantine regulation, containment, rejection, or other holding action. B – A pest of known economic or environmental detriment and, if present in California, it is of limited distribution. B-rated pests are eligible to enter the state if the receiving county has agreed to accept them. If found in the state, they are subject to state endorsed holding action and eradication only to provide for containment, as when found in a nursery. At the discretion of the individual county agricultural commissioner they are subject to eradication, containment, suppression, control, or other holding action. Q – An organism or disorder suspected to be of economic or environmental detriment, but whose status is uncertain because of incomplete identification or inadequate information. December 2020 Page B-9 Attachment B Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT C Plumas National Forest Invasive Weed List December 2020 Page C-1 Attachment C Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Scientific Name Common Name Acroptilon repens Russian knapweed Aegilops cylindrica jointed goat grass Aegilops triuncialis barbed goat grass Ailanthus altissima tree-of-heaven Arundo donax giant reed Cardaria chalepensis lens-podded white-top Carduus nutans musk thistle Carduus pycnocephalus ssp. pycnocephalus Italian thistle Centaurea diffusa diffuse knapweed Centaurea melitensis Malta star-thistle, tocalote Centaurea solstitialis yellow star-thistle Centaurea stoebe ssp. micranthos spotted knapweed Centaurea virgata ssp. squarrosa squarrose knapweed Chondrilla juncea rush skeletonweed Cirsium arvense Canada thistle Cirsium ochrocentrum yellowspine thistle Cynara cardunculus artichoke thistle Cytisus scoparius Scotch broom Dittrichia graveolens stinkwort Elymus caput-medusae medusahead grass Euphorbia esula leafy spurge Genista monspessulana French broom Isatis tinctoria dyer's woad Lepidium appelianum hairy white-top Lepidium chalepense lens-podded hoary cress Lepidium draba heart-podded hoary cress Lepidium latifolium perennial pepperweed Linaria dalmatica ssp. dalmatica Dalmatian toadflax Linaria vulgaris butter-and-eggs Lythrum salicaria purple loosestrife Onopordum acanthium Scotch thistle December 2020 Page C-2 Attachment C Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Scientific Name Common Name Potentilla recta sulfur cinquefoil Rubus armeniacus* Himalayan blackberry* Spartium junceum Spanish broom Source: Belsher-Howe 2014 *Due to the extensive distribution of Himalayan blackberry (Rubus armeniacus) in the Projectand NFFR, and the ability of this species to spread through both seed dispersal and vegetative means, only populations considered critical to control because of conflicts with other land use practices or routine O&M activities will be inventoried, mapped and targeted for application of control measures. December 2020 Page C-3 Attachment C Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT D Best Management Practices (BMPs) to Protect Environmental Resources During Vegetation Management December 2020 Page D-1 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan This section describes all invasive weed prevention BMPs and environmental protection measures that PG&E will perform to prevent introduction and spread of target invasive weeds and protect sensitive natural resources during vegetation management activities. The following BMPs shall be implemented on the Poe Hydroelectric Project: Measures to Prevent the Introduction and Spread of Target Invasive Weeds by PG&E Employees and Contractors 1.Education – Annual environmental training for all internal PG&E employees and contract maintenance personnel will be conducted that will emphasize the importance of preventing the further spread of target invasive weeds,including aquatic invasive weeds. This training will review the identifying characteristics of the target invasive weeds most likely to occur in the Project and review of Plan BMPs to prevent introduction and spread. Training materials may include brochures and field guides prepared by the Forest Service, Butte County Weed Management Area, or PG&E’s staff and contractors. 2.Equipment Cleaning – Heavy equipment brought into the Project from outside the watershed will be cleaned prior to its use on the Project. Equipment will be inspected to determine whether it is free of soil or other debris that could contain invasive weed seed. Equipment will be considered clean when a visual inspection does not disclose soil, seed, plant material, and other such debris. Off-road equipment used in the watershed shall be inspected and cleaned using air compressors, brooms, or similar tools, if necessary, when travelling off-road or through target invasive weed infestations. Vehicles not intended for off-road use (e.g., log trucks, chip vans, service vehicles, water trucks, pickup trucks) will not be subject to the equipment cleaning requirement. 3.AvoidInfestations – Travel through invasive weed infested areas shall be minimized. If travel through infested areas cannot be avoided, areas free of target invasive weeds will be worked on prior to areas with target invasive weed infestations to the extent practicable. December 2020 Page D-2 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 4.Use Existing Roads – Vehicles and equipment shall access work sites from existing roadways and shall be parked on pavement, existing roads, and previously disturbed areas to the extent practicable. 5.Limit Disturbance Areas – Ground disturbance, including road maintenance activities, shall not exceed the minimum necessary to safely complete operations. Precautions shall be taken to avoid damage to non-target vegetation. 6.Monitoring After Disturbance – Areas disturbed by PG&E maintenance activities and/or road maintenance will be monitored for three years after activity to ensure early detection of target invasive weeds. Any new target invasive weed occurrences will be incorporated into the management maps for the annual control program. 7.Weed-free Materials – All imported materials (e.g., straw, mulch, gravel, fill) used for work within NFSL shall be weed-free. 8.Weed-free Feed– If grazing is used as a target invasive weed control measure and supplemental feeding is necessary, only pelletized or commercially available certified weed- free feed will be used on NFSL. Measures to Prevent the Introduction and Spread of Target Aquatic Invasive Weeds The following actions will be implemented to prevent the introduction and establishment of aquatic invasive weeds on the Project. 9.Personnel Education – PG&E will educate their Project personnel and contractors about the importance of preventing introduction and spread of aquatic invasive weeds. Educational materials will be made available, including specific suggested measures for preventing introduction and spread. 10.Measures to Avoid Introduction of Aquatic Invasive Weeds – PG&E will implement the following measures to prevent aquatic invasive weed infestations: December 2020 Page D-3 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan a. Regularly inspect and thoroughly clean and dry equipment (e.g., boats, waders, felt footwear, etc.) before entering a waterbody, and when moving equipment between projects, waterbodies, or sites. b.Heavy equipment will not be used in wetted areas to the extent practical. c. If feasible, work will take place in dry conditions during the dry season. Accessing parts of the Project from a boat or wading is permitted. d. Never move live organisms from one waterbody into another. e. Use elliptical and bulb-shaped anchors to avoid snagging aquatic materials. 11. Measures to Avoid Spreading Known Aquatic Invasive Weeds – If occurrences of aquatic invasive weeds are identified in Project waterbodies, PG&E will implement the following measures: a. Prior to any construction or disturbance activities within the waterbody, inspections for aquatic invasive weeds will be performed. If aquatic invasive weeds are found in the work area, they will be treated or otherwise removed with a plan developed by a licensed PCA. This plan will be implemented prior to or during construction, as feasible (e.g., work is not an emergency). b.Conduct work in less infested areas of thewaterbody prior to infested areas, when possible. c. Minimize wading and running boats into sediment to avoid relocating the aquatic invasive weeds d. Minimize the amount of sediment, plants, and/or organisms that are incidentally removed from the water with equipment, boats, or sampling gear. If any of these materials are brought out of the water, leave them at the originating site to the extent feasible (e.g., pull or rinse off vegetation and sediment at the waterbody). December 2020 Page D-4 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Measures Implemented to Protect Sensitive Environmental Resources During Vegetation Management 12.Herbicide Use Planning Process – A licensed PCA will provide PUPs on Forest Service Form FS-2100-2(or current version) and written pest control recommendation to be reviewed and approved by the appropriate Plumas National Forest officer prior to implementation of herbicide treatment on NFSL. This recommendation will include the proposed treatment sites, methods, and products with associated amounts. 13.Pesticide Spill Contingency Planning–Prior to herbicide treatment, a spill plan willbe developed describing actions to be taken in the event of a pesticide spill. Plans should include parties responsible for spill notification, time requirements for notification, and spill containment and cleanup measures (Forest Service 2000, 2011, 2012a). Spill plans will be submitted with PUPs to the Plumas National Forest for review. Spill plans will identify and describe specific measures aimed at minimizing the chances and effects of herbicide spills. Measures include proper storage and handling of pesticides, designating routes of travel, and mixing sites. If a spill occurs, the spill plan will specify contact information and process for notification and containment. Spill kits will be required in contractor vehicles on site and where contractor-supplied herbicides are stored, along with safety data sheets (Forest Service 2000, 2011, 2012a). 14. Pre-Treatment Flagging – Prior to start of target invasive weed control treatments representative target invasive weed occurrences may be flagged in order to aid treatment contractors with identification and location of occurrences. In addition, prior to any vegetation management,known occurrences of rare (i.e., TECS and watch list) plant species will be flagged for avoidance during herbicide application. 15. Environmental Training – Prior control treatments, PG&E’s noxious weed program manager and the PCA will conduct an environmental briefing for the treatment contractor and other Project vegetation management, as appropriate, describing target invasive weeds to be treated, and BMPs to be implemented during vegetation management activities. At a minimum, the December 2020 Page D-5 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan following topics will be covered during the briefing: Allenvironmental constraints known in the Control Area (e.g., special-status plants and wildlife, SMZ buffers, etc.); Forest Service-approved materials; Safety and spill plan; Site restoration requirements; and Regulatory requirements that apply to herbicide use. Training materials may include existing identification brochures or field guides, or Project- specific materials prepared by PG&E’s staff or contractors. Training methods and materials may include both in-person and online components and may vary over the term of the License. 16. Follow Legal Requirements –Herbicide applications require the following: Licensed and trained personnel; Adherence to applicable state laws, California Department of Pesticide Regulation (CDPR) and CalEPA regulations, and label directions for application rates, methods, and mixing; Annual safety and product training for each herbicide used; Use of safety equipment as prescribed by state law and the pesticide label, including goggles, gloves, long pants, long-sleeved shirts, shoes and socks, as appropriate; Written Pest Control Recommendation by a licensed PCA; Monthly reporting of each use of herbicide by county; and Annual inspections by the County Agricultural Commissioner. Pesticide applicators will be licensed by the State of California, and as such must use pesticides according to CDPR regulations (found at CDPR 2019). Applicators will also observe guidelines provided in the Forest ServicePesticide Use Management and Coordination Handbook (Forest Service 1994). 17. Pesticide Application, Monitoring, and Evaluation – Prior to the start of application, all application equipment will be calibrated to ensure accuracy of delivered amounts of herbicide. December 2020 Page D-6 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Periodically during application, equipment will be rechecked for calibration. Colorants or dyes will be added to the herbicide mixture to determine placement. 18. Applications Directed by Licensed PCA – All herbicide treatments will be performed under the direction of a licensed PCA who will ensure that herbicide treatments are implemented properly and that BMPs are followed. The PCA will direct the work of a team of PCOs who will carry out all treatments. 19. Manual or Mechanical Control near Sensitive Resources – Manual and mechanical control will be used when necessary to protect nearby known special-status plants, cultural sites, or other sensitive situations where the use of herbicides may be potentially problematic. Any such sites will be identified annually during the pre-operations meeting and reviewed with the treatment contractor during the Environmental Training. 20. Cleaning and Disposal of Pesticide Containers and Equipment– All herbicide applications will adhere to applicable state laws, CalEPA regulations, CDPR regulations (CDPR 2003), and safety regulations for container disposal. All herbicide and adjuvant containers will be triple rinsed with clean water at an approved site. The rinsate will be disposed of by placing it in the batch tank for application. Used containers will be punctured on the top and bottom to render them unusable, unless said containers are part of a manufacturer's container recycling program, in which case the manufacturer's instructions will be followed. Disposal of non-recycled containers will be at legal dumpsites. Equipment will not be cleaned and personnel will not bathe in a manner that allows contaminated water to enter any body of water onNFSL. 21. Controlling Pesticide Drift during Spray Applications–Thefollowing measures will be followed to reduce risk of drift during application of herbicides onto non-target areas (Forest Service 2000, 2011, 2012a): Only ground-based equipment will be used; Application will cease when weather parameters exceed label requirements, or when precipitation occurs or is forecast with greater than a 70 percent probability in the next 24- hour period; December 2020 Page D-7 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Spray nozzles will produce a relatively large droplet size; Low nozzle pressures (15 pounds per square inch \[psi\]) will be observed; Spray nozzles will be kept within 24 inches of vegetation during spraying; A pressure gauge or pressure regulator will be required on each backpack sprayer; and All applications will be low volume (less than 15 gallons per acre \[gpa\]). 22. Streamside Wet Area Protection During Herbicide Spraying – Streamside management zones (SMZs, i.e., untreated buffer strips) will be established on all stream courses and roadside ditches that might be impacted.Widths are based on the type of herbicide, the class of stream or ditch, and the presence of water at time of treatment (Table D-1). Untreated buffer strips will be flagged or otherwise designated on the ground. The contractor staff will be informed of the location and extent of each of the strips prior to treatment. Applications will be monitored by the supervising PCA to determine accurate placement. December 2020 Page D-8 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Table D-1. Buffer Strip Widths for Streams and Ditches 1 Untreated Buffer Strips for SMZs Stream Class 2 Watercourse Class IV Including Rills Watercourse Watercourse and Gullies Class III Class II Water HerbicidePresent (Dry) (Dry) (Dry) Perennial Aminopyralid 50 feet 25 ft 25 ft 50 ft 75 ft (e.g., Milestone) (ft) Chlorsulfuron 50 ft 25 ft 25 ft 50 ft 75 ft (e.g., Telar) Clopyralid 50 ft 25 ft 25 ft 25 ft 75 ft (e.g., Transline) Glyphosate 50 ft 10 ft 25 ft 25 ft 50 ft (e.g., Roundup Pro) 3 Glyphosate 0 ft 0 ft 0 ft 0 ft 0 ft (e.g. Roundup Custom) Imazapyr 50 ft 10 ft 25 ft 25 ft 50 ft (e.g., Habitat) Triclopyr 50 ft 10 ft 25 ft 25 ft 50 ft (e.g., Garlon 3A) Untreated Buffers for Roadside Ditches Ditch Dry Ditches with Up to 300 Ft Down Ditch Beyond 25 Ft Above and 300 ft Down Water 4 Herbicide Presentfrom Wet Area or To Culvert Ditch from Wet Area Aminopyralid 25 ft 10 ft on either side of the ditch 0 ft (e.g., Milestone) Chlorsulfuron 25 ft 10 ft on either side of the ditch 0 ft (e.g., Telar) Clopyralid 25 ft 10 ft on either side of ditch 0 ft (e.g., Transline) Glyphosate 25 ft 10 ft on either side of ditch 0 ft (e.g., Roundup Pro) 3 Glyphosate 0 ft Water’s edge 0 ft (e.g., Roundup Custom) Imazapyr 25 ft Water’s edge 0 ft (e.g., Habitat) Triclopyr 25 ft Water’s edge 0 ft (e.g., Garlon 3A) 1 No mixing will take place within 300 ft of a stream. Buffer widths based on physical properties of herbicide and previous experience. 2 Watercourse class characteristics are defined in California Department of Forestry and Fire Protection (2018) as follows: December 2020 Page D-9 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Class I: Domestic supplies, including springs, on site and/or within 100 feet downstream of the operations area and/or fish always or seasonally present onsite, includes habitat to sustain fish migration and spawning. Class II: Fish always or seasonally present offsite within 1,000 feet downstream and/or aquatic habitat for aquatic species (excludes Class III waters that are tributary to Class I waters). Class III: No aquatic life present, watercourse showing evidence of being capable of sediment transport to Class I and II waters under normal high water flow conditions after completion of timber operations. Class IV: Man-made watercourses, usually downstream, established domestic, agricultural, hydroelectric supply or other beneficial use. 3 Aquatic formulations of glyphosate. 4 A ditch would be considered to have water present if the immediate ditch system contains water. December 2020 Page D-10 Attachment D Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT E Plumas National Forest Invasive Weed Form December 2020 Page E-1 Attachment E Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan PLUMAS NATIONAL FOREST INVASIVE PLANT REPORT Scientific Name: Common name: N-Site ID: ______________________ Date of assessment: __________Surveyor: _______ LOCATION INFORMATION: Landowner/Manager: __________ F.S. Ranger District: Mt. Hough Quadrangle: Legal Location: TRS: T R S UTM NAD 83: Easting: Northing: ___ DETAILED DIRECTIONS TO SITE (ATTACH MAP): HABITAT DESCRIPTION: INITIAL SITE ASSESSMENT: Area occupied by target species: __________ unit of measure: square feet or acres Percent cover of target species: 0–1 1.1–5 5.1–25 25.1–50 50.1–75 75.1–95 95.1–100 # Plants treated: Actual: Estimate: 100–500 500–1,000 1,000–5,000 5,000–10,000 >10,000 Phenology (percent): _____ vegetative _____ flowering ______ fruiting / seeding December 2020 Page E-2 Attachment E Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT F Fire Behavior and Modeling Figures December 2020 Page F-1 Attachment F Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Fuel Model Bardees Bar TL6SH7TL3TU2 GS2 GS1 TL3 TL3 TU5 SH7 GS2 GS2TL6 TL6 GS1 GS2 TL6 GS2TL6TL5 GR1 SH7 SH7 TL5 SH7 GR2TL6TL6 GR1 GR1SH5 TL6 SH7 GS1 GR2SH7 TL3TL6 GS2 GS2SH5TL6GR1 NB8 SH7 GS2 GS2SH5 SH7 GS2SH5NB8 GR2 SH5 TL6 SH7 GR2SH5TL6GS2GS2 GS2 SH7TL6SH5SH7TL6 GS2 NB8 GS2SH7GR2GS2SH5 NB9 SH7 SH7 TL6 SH7 NB9SH5SH7 TL3NB9NB9GR2SH5NB8NB9 NB8 NB9SH7NB9 TL6 SH5 TL3SH7GS2 SH7 NB9GS2TL6 TL6 NB9 SH5SH7SH5TL6 GS2 SH7NB8 TL3TL6 TL6NB8 TL3SH5SH7SH2 GS2 TL6SH7SH5 NB9 TU5 TL6 Recreation SiteGS1:Low load dry climate grass-shrubSH2:Mod. load dry climate shrubTL6:Moderate load broadleaf litter SH5 SH7 300ft BufferGS2:Moderate load dry climate grass-SH5:High load dry climate shrubTU2:Moderate load humid climate TL6 shrubtimber-shrub Fuel ModelSH7:Very high load dry climate shrub SH5GS2SH5 NB8:Non-burnableTU5:Very high load dry climate timber- GR1:Short, sparse dry climate grassTL3:Moderate load conifer litter TL3 shrub NB9:Non-burnable TL6 GR2:Low load dry climate grassTL5:High load conifer litter SH7 GS2SH5TL6GS2SH5TL6 Bardees Bar Rate of Spread Recreation Site 300ft Buffer Rate of Spread (Chains/Hr) 0 - 1 1 - 6 6 - 11 11 - 22 22 - 44 0100200300400500 44 - 88 Feet 121°27'30"W www.deercreekgis.com Bardees Bar Flame Length Recreation Site 300ft Buffer Flame Length (Ft) 0 - 4 4 - 8 8- 11 0100200300400500 11 - 20 Feet 121°27'30"W xxx/effsdsfflhjt/dpn Bardees Bar Fire Type Recreation Site 300ft Buffer Fire Type Surface Fire Torchicng Fire 0100200300400500 Crown Fire Feet 121°27'30"W xxx/effsdsfflhjt/dpn Bardees Bar Resistance to Control Recreation SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet 121°27'30"W xxx/effsdsfflhjt/dpn Fuel Model Poe Beach TL3NB9TL3TL6 TL3 SH7 NB8 TL6 SH7 GR2 TL6 NB9SH7 TL9 TL6 TL6 SH7TL9 TL3 SH7 SH7 GR2 TL6 TL3 NB9 SH7GR2 TL4 GS2 SH7 TL6 SH7 GS2 GR2 SH7SH7GS2NB9 GR2TL3 TL6 SH5 TL6SH7 GS2 SH7GR2 SH7 NB9 TL4 GR2SH7 Recreation SiteGS2:Moderate load dry climate grass-SH5:High load dry climate shrubTL6:Moderate load broadleaf litter shrub TL6 300ft BufferSH7:Very high load dry climate shrubTL9:Very high load broadleaf litter NB8:Non-burnable Fuel ModelTL3:Moderate load conifer litterTU5:Very high load dry climate timber- shrub NB9:Non-burnable GR2:Low load dry climate grassTL4:Small downed logs TU5 NB8TL6TL4 SH7 Poe Beach Rate of Spread Recreation Site 300ft Buffer Rate of Spread (Chains/Hr) 0 - 1 1 - 6 6 - 11 11 - 22 22 - 44 0100200300400500 44 - 88 Feet 121°28'0"W xxx/effsdsfflhjt/dpn Poe Beach Flame Length Recreation Site 300ft Buffer Flame Length (Ft) 0 - 4 4 - 8 8- 11 0100200300400500 11 - 20 Feet 121°28'0"W xxx/effsdsfflhjt/dpn Poe Beach Fire Type Recreation Site 300ft Buffer Fire Type Surface Fire Torchicng Fire 0100200300400500 Crown Fire Feet 121°28'0"W xxx/effsdsfflhjt/dpn Poe Beach Resistance to Control Recreation SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet 121°28'0"W xxx/effsdsfflhjt/dpn Fuel Model Poe Powerhouse SH7 NB8SH7TU5SH5 TL6 NB9 TL6 GS2 NB8SH5 TL6 TL3 NB9 GS2SH5 NB9SH7 SH7 SH5 SH7 TL3 NB9SH5SH7 TL6 SH7 TL4 TL6 NB9GS2GR1 GS2SH5 GR2 SH5SH7 NB9 TL3 GS2SH7SH5 TL6TL6 SH7GS2NB9SH7SH7 TL6 TU5 TL6TL4 NB8 TL6 NB9SH7 TL3TL3 TL6 TL3 TL4 TL6 TL3 Recreation SiteGR2:Low load dry climate grassNB9:Non-burnableTL4:Small downed logs 300ft BufferGS2:Moderate load dry climate grass-SH5:High load dry climate shrubTL6:Moderate load broadleaf litter shrub Fuel ModelSH7:Very high load dry climate shrubTU5:Very high load dry climate timber- NB9 shrub NB8:Non-burnable GR1:Short, sparse dry climate grassTL3:Moderate load conifer litter GR2TL3TL6 Poe Powerhouse Rate of Spread Recreation Site 300ft Buffer Rate of Spread (Chains/Hr) 0 - 1 1 - 6 6 - 11 11 - 22 22 - 44 0100200300400500 44 - 88 Feet xxx/effsdsfflhjt/dpn Poe Powerhouse Flame Length Recreation Site 300ft Buffer Flame Length (Ft) 0 - 4 4 - 8 8- 11 0100200300400500 11 - 20 Feet xxx/effsdsfflhjt/dpn Poe Powerhouse Fire Type Recreation Site 300ft Buffer Fire Type Surface Fire Torchicng Fire 0100200300400500 Crown Fire Feet xxx/effsdsfflhjt/dpn Poe Powerhouse Resistance to Control Recreation SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet xxx/effsdsfflhjt/dpn Fuel Model Sandy Beach SH7 GR1SH7 NB9GS2 SH7 TL6 GR2 SH7TL2NB9GS2 SH7GR2NB8 NB9 SH7 GS2 SH7GR2NB9NB8SH7 NB1 GS2 GR1TL6NB8TU5GR2TL3 SH7GR1GR2NB8SH2TL2 SH7TL3 TL2GR2NB8NB9 TL2TL6TL3NB9NB8NB9TL3GS1 SH7 TL3NB8GR1TL3GS1SH5 TL3 NB1 NB9 GR2 TL3NB8GR1TL3TL4 TL6TL3 TL3 NB9 NB8GR1TL3GS1 TL3 GR1SH2TL3GS1TL4 TL3 TL3 GS1GS1TL4 NB1 TL3 GS1TL4TL3TU2 TU5 TL3 GS1 TL4 TL4TU2 TL6 TU2 SH7TL6 Recreation SiteGS2:Moderate load dry climate grass-SH5:High load dry climate shrubTU2:Moderate load humid climate shrubtimber-shrub 300ft BufferSH7:Very high load dry climate shrub TL6 NB1:Non-burnableTU5:Very high load dry climate timber-TL6 Fuel ModelTL2:Low load broadleaf litter shrub NB8:Non-burnable GR1:Short, sparse dry climate grass GS2TL6 TL3:Moderate load conifer litter NB9:Non-burnable GR2:Low load dry climate grassTL4:Small downed logs SH2:Mod. load dry climate shrub GS1:Low load dry climate grass-shrub TL6:Moderate load broadleaf litter TL6 Sandy Beach Rate of Spread Recreation Site 300ft Buffer Rate of Spread (Chains/Hr) 0 - 1 1 - 6 6 - 11 11 - 22 22 - 44 0100200300400500 44 - 88 Feet 121°26'30"W xxx/effsdsfflhjt/dpn Sandy Beach Flame Length Recreation Site 300ft Buffer Flame Length (Ft) 0 - 4 4 - 8 8- 11 0100200300400500 11 - 20 Feet 121°26'30"W xxx/effsdsfflhjt/dpn Sandy Beach Fire Type Recreation Site 300ft Buffer Fire Type Surface Fire Torchicng Fire 0100200300400500 Crown Fire Feet 121°26'30"W xxx/effsdsfflhjt/dpn Sandy Beach Resistance to Control Recreation SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet 121°26'30"W xxx/effsdsfflhjt/dpn Fuel Model Poe Reservoir Access Trail TU5SH2GR2SH7GR2TL6SH2TU5SH7NB8 GS2TL3 TU5 GS2 TL6 TL6 SH7 TL6 SH7NB9SH2 GS2 GS2 GR2 SH7 TL3 GR2 GR2 SH2 SH7SH2SH7SH7 GR2 TL6 GS2 TL6 GR1 TU5GS2 TU5 SH7SH5 GR2GR2GS2 SH2 TL3 NB8NB9SH5 GR2 GR2 TL3 GR2 NB8 GR2 TL2 GR2 TL6 SH7 NB9 GR1 SH5 NB8 GS2 TL3 NB1 TL6 TL6NB1 GR2 GS2NB8 TL8 TL4 GR2 SH7NB9 GR1GR2 GS2 TL6 SH7 SH7 TL3 NB8SH5 GR2GS2GR2 NB9 TL9 GS2TL3 NB8SH5 GS2 SH5 TU5TL3 TU5 TL3TL3 SH5 GS1 TL3 TL3 SH5 GR1GS1GS2 GS1 GS2 TL3NB1TU5TL6 TL3 SH5 NB1 GS1 SH5 GS2 TL6 TL3 GS1 TL6 SH7 TU5 GS1 SH7 TL6 TL6 TU5TL6 GS2 TU5TU5 SH7 TL3 TU5 TU5 TL4TL6 Recreation SiteGS2:Moderate load dry climate grass-SH5:High load dry climate shrubTL8:Long-needle litter SH2 shrub 300ft BufferSH7:Very high load dry climate shrubTL9:Very high load broadleaf litter NB1:Non-burnable Fuel ModelTL2:Low load broadleaf litterTU5:Very high load dry climate timber- TL3 SH7 shrub NB8:Non-burnable GR1:Short, sparse dry climate grassTL3:Moderate load conifer litter TL6 NB9:Non-burnable GR2:Low load dry climate grass TL4:Small downed logs TU5 SH2:Mod. load dry climate shrub GS1:Low load dry climate grass-shrub TL6:Moderate load broadleaf litter GS2 Poe Reservoir Access Trail Fire Type Recreation Site 300ft Buffer Fire Type Surface Fire Torchicng Fire 0100200300400 Crown Fire Feet 121°24'30"W xxx/effsdsfflhjt/dpn Poe Reservoir Access Trail Flame Length Recreation Site 300ft Buffer Flame Length (Ft) 0 - 4 4-8 8-11 0100200300400 11-41 Feet 121°24'30"W xxx/effsdsfflhjt/dpn Poe Reservoir Access Trail Rate of Spread Recreation Site 300ft Buffer Rate of Spread (Chains/Min) 0 - 1 1-6 6-11 11-22 22-44 0100200300400 44-88 Feet 121°24'30"W xxx/effsdsfflhjt/dpn Poe Reservoir Access Trail Resistance to Control Recreation SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet 121°24'30"W xxx/effsdsfflhjt/dpn Fuel Model Poe Dam GR2 GS1TL3TL3GR2SH2GS1 TL6 GR1 NB1 GS2 TL4 GR2 TU5 TL3GR1 SH7 GS2 TL6 TU5 GR2TU5 TL4SH2 SH2 TU5 TU5TU5 GR2SH7SH2GR2 GS2SH2GR2GR2SH7 TL6 SH2TU5 TL6SH7TL6 TL6 TL6 TL3 SH2 TU5 TU5 TL3 SH2SH2SH7 TL6SH2SH2 TL3 TL3 TL6SH2 SH7 SH2 TL3 SH7 GR2GR2 NB8 NB1 NB9 TL3 TL3GS1 TL3 TL3GS1TL3GS1 NB9 TL3NB1 TL3 GS2TL3GS1GS1 TL6 NB1 TL3 GS1SH7 GS1 GS1TL6 GS2 TL3 TU5 SiteGS1:Low load dry climate grass-shrubNB9:Non-burnableTL6:Moderate load broadleaf litter 300ft BufferGS2:Moderate load dry climate grass-SH2:Mod. load dry climate shrubTU5:Very high load dry climate timber- shrubshrub Fuel ModelSH7:Very high load dry climate shrub NB1:Non-burnable GR1:Short, sparse dry climate grassTL3:Moderate load conifer litter NB8:Non-burnable GR2:Low load dry climate grassTL4:Small downed logs Poe Dam Rate of Spread Site 300ft Buffer Rate of Spread (Chains/Hr) 0 - 1 1 - 6 6 - 11 11 - 22 22 - 44 0100200300400500 44 - 88 Feet xxx/effsdsfflhjt/dpn Poe Dam Flame Length Site 300ft Buffer Flame Length (Ft) 0 - 4 4 - 8 8- 11 0100200300400500 11 - 20 Feet xxx/effsdsfflhjt/dpn Poe Dam Fire Type Site 300ft Buffer Fire Type Surface Fire Torchicng Fire 0100200300400500 Crown Fire Feet xxx/effsdsfflhjt/dpn Poe Dam Resistance to Control SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet xxx/effsdsfflhjt/dpn Fuel Model Big Bend Dam TL3 TL3TL6 TL6 SH7 SH7 TL6 GS2 SH5 TL6 TL3 SH7NB9 SH5 TL3 GS2 NB9 SH7 NB8 NB9 NB9 NB9GR2 NB9 TL3 SH7 TL6 SiteGR2:Low load dry climate grassNB8:Non-burnableSH7:Very high load dry climate shrub GR2 300ft BufferGS2:Moderate load dry climate grass-NB9:Non-burnableTL3:Moderate load conifer litter shrub Fuel ModelSH5:High load dry climate shrubTL6:Moderate load broadleaf litter GS2 SH7 Big Bend Dam Fire Type Site 300ft Buffer Fire Type Surface Fire 0100200300400 Torchicng Fire Feet 121°28'0"W xxx/effsdsfflhjt/dpn Big Bend Dam Flame Length Site 300ft Buffer Flame Length (Ft) 0 - 4 4-8 8-11 0100200300400 11-41 Feet 121°28'0"W xxx/effsdsfflhjt/dpn Big Bend Dam Rate of Spread Site 300ft Buffer Rate of Spread (Chains/Min) 0 - 1 1-6 6-11 11-22 0100200300400 44-88 Feet 121°28'0"W xxx/effsdsfflhjt/dpn Big Bend Dam Resistance to Control SiteModerate 300ft BufferHigh Resistance to Control Very High 0100200300 LowExtreme Feet 121°28'0"W xxx/effsdsfflhjt/dpn Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT G Fuel Treatment Prescription Maps December 2020 Page G-1 Attachment G Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Lassen National Forest Plumas Plumas County County Project Location 70 S T Butte Butte County County Plumas National Forest FERC Project Boundary Stream / Creek Shaded Fuel Break ´ Vegetation Maintenance Area 0100200 Feet A BardeeBarFuelTreatment Lassen National Forest Qmvnbt Qmvnbt Dpvouz Dpvouz Cvuuf Cvuuf Dpvouz Dpvouz 70 S T Plumas National Forest Project Location FERC Project Boundary Stream / Creek ´ Shaded Fuel Break 0100200 Feet PoeBeachFuelTreatment Lassen National Forest Qmvnbt Qmvnbt Dpvouz Dpvouz Cvuuf Cvuuf Dpvouz Dpvouz 70 S T Plumas National Forest Project Location FERC Project Boundary Stream / Creek ´ Vegetation Maintenance Area 0100200 Feet PoePowerhouseFuelTreatment Lassen National Forest Qmvnbt Qmvnbt Dpvouz Dpvouz Project Location 70 S T Cvuuf Cvuuf Dpvouz Dpvouz Plumas National Forest FERC Project Boundary Stream / Creek ´ Shaded Fuel Break 0100200 Feet SandyBeach Fuel Treatment Project Location Qmvnbt Qmvnbt Dpvouz Cresta Powerhouse Dpvouz Cvuuf Cvuuf Dpvouz Dpvouz 70 S T Stream / Creek FERC Project Boundary Fuel Treatment Area ´ 0100200 Feet PoeReservoirAccessTrailFuelTreatment Lassen National Forest Qmvnbt Qmvnbt Dpvouz Dpvouz Project Location 70 S T Cvuuf Cvuuf Dpvouz Dpvouz Plumas National Forest FERC Project Boundary Stream / Creek ´ Shaded Fuel Break 0100200 Feet PoeDamFuelTreatment Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT H Water Quality Sampling Protocol December 2020 Page H-1 Attachment H Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Water Quality Sampling Protocol PG&E shall be responsible for water quality monitoring to ensure that no pesticides prescribed for the Rock Creek–Cresta Vegetation Management Strategy enter the surface waters adjacent to the application areas. PG&E proposes to implement water quality monitoring adjacent to treated areas to document the effectiveness of proposed buffers. Water samples shall be taken at times and locations specified below. Samples shall be collected, stored and transported using EPA-approved procedures, including sampling chain of custody(COC). All water samples shall be tested at a California-certified laboratory (e.g., North Coast Laboratory in Arcata, California). The laboratory Environmental Accreditation Program number will be appended to each document. The water analysis will be carried out to determine if the prescribed herbicides and their associated breakdown products are present at detectable concentrations. All water samples shall be taken in new glass bottles that have been solvent-rinsed. All water samples will be taken in mid-channel (if possible, depending upon flow and any safety concerns) and as near to the mid-depth of the stream as possible. Sediment disturbance will be minimized. Samples will be collected in flowing water. The samples will be taken upstream from the sampler’s body to ensure no contact with the skin or clothing. A field blank will be provided from each sampling day to ensure that contamination of the sample bottles does not occur while in transit to o F, and from the sample site. The samples will be retained in coolers at 39 degrees Fahrenheit ( o equals 4 degrees Celsius \[C\]) until they are delivered to the laboratory. All samples will be delivered to the analytical laboratory within 24to 36 hours of sampling.Chain of custody documentation will follow the samples through the analytical process and a copy of the signed COC will be provided with the analytical report. To minimize any potential cross-contamination of samples, the sampler will not be involved in any other aspect of the treatment operation, including travel in vehicles. The laboratory detection limits and full quality assurance and quality control (QA/QC) documentation will be provided by the laboratory as a part of the results package. If the detection limits are not met or the results do not meet QA/QC requirements, the samples will be rerun. December 2020 Page H-2 Attachment H Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Monitoring Locations: Cresta Powerhouse, upstream of Control Area Poe Powerhouse, downstream of Control Area Monitoring Methods: One sample will be taken prior to initial application of herbicides each season. One sample will be taken during the first significant runoff-producing storm event that occurs within 90 days after herbicide application. Therefore, post-treatment water monitoring sampling will occur after the treatment area receives at least 0.5 inch of rain (within any 72-hour period) based on the precipitation recorded at the Bucks Creek Powerhouse (e.g., from the National Oceanographic and Atmospheric Administration’s California Nevada River Forecast Center website, cnrfc.noaa.gov or successor). If no runoff producing storm occurs within 90 days after herbicide applications, post-treatment samples will not be taken. If monitoring results in only negative samples for three years, then monitoring for those herbicides will be suspended, pending suitable changes in herbicide or application type that warrant additional sampling. Changes in herbicides and/or treatment methods will trigger an additional three years of water quality monitoring for herbicides according to the protocol described herein. December 2020 Page H-3 Attachment H Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT I Plumas National Forest Revegetation Mix List December 2020 Page I-1 Attachment I Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan Plumas National Forest – Feather River Ranger District Approved Erosion Control Seed Species – Poe Integrated Vegetation Management Plan The following approved native grass and forb species may be used on disturbed sites when allowing the site to regenerate from the native seedbank is not feasible and/or erosion potential is high. These species may be mixed and matched to accommodate availability and site specific conditions, and should be applied at a total combined rate of 40 pounds/acre. At least two bunchgrass species, one annual grass species, one clover, and one forb/lupine is ideal. To the extent practical, seeds and plants used in erosion control, fire rehabilitation, riparian restoration, forage enhancement, and other vegetation projects shall originate from genetically local sources of native plants. Acmispon americanus, Spanish Clover Bromus carinatus, California Brome (perennial grass) Deschampsia danthonioides, Annual hairgrass (annual grass) Elymus glaucus, Blue Wildrye (perennial grass) Festuca microstachys, Small Fescue (annual grass) Lupinus albifrons, Silver Lupine Lupinus nanus, Sky Lupine Poa secunda, Pine Bluegrass (perennial grass) Stipa pulchra, Purple needlegrass (perennial grass) Trifolium willdenovii, Tomcat Clover In addition, the following are recommended to include with the seeding mixture: Biosol Forte Slow Release Fertilizer 400 lbs per acre AM 120 Mycorrhizae Inoculant 20 lbs per acre December 2020 Page I-2 Attachment I Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan ATTACHMENT J Representative Photographs the Poe Project December 2020 Page J-1 Attachment J Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6/18/2019 Figure F-1. From Highway 70 Bridge, looking upstream from river left. 6/18/2019 Figure F-2. From Poe Powerhouse Access Bridge, looking upstream from channel center. December 2020 Page J-2 Attachment J Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6/18/2019 Figure F-3. Bardee’s Bar, looking upstream from river right. 6/18/2019 Figure F-4. From Bardee’s Bar Road, below Bardee’s Bar, looking upstream from river right. December 2020 Page J-3 Attachment J Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company Poe Hydroelectric Project FERC Project No. 2107 Poe Integrated Vegetation Management Plan 6/18/2019 Figure F-5. From Bardee’s Bar Road, below Bardee’s Bar, looking downstream from river right. December 2020 Page J-4 Attachment J Poe Hydroelectric Project, FERC Project No. 2107 ©2020, Pacific Gas and Electric Company