HomeMy WebLinkAbout12.29.20 BOS Correspondence - FW_ Request for Delay of Action_Extension of Time 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: Request for Delay of Action/Extension of Time submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al.
Date:Tuesday, December 29, 2020 8:25:01 AM
Good morning,
Please see the email below from FERC.
Amy Schuman
Associate Clerk of the Board
Butte County Administration
25 County Center Drive, Suite 200, Oroville, CA 95965
O: 530.552.3300 |D: 530.552.3308 | F: 530.538.7120
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-----Original Message-----
From: 'FERC eSubscription' <eSubscription@ferc.gov>
Sent: Tuesday, December 29, 2020 7:15 AM
Subject: Request for Delay of Action/Extension of Time 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 12/29/2020, 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: Request for Delay of Action/Extension of Time
Description: Pacific Gas and Electric Company submits the Second Request for Extension of Time to File Long-Term Ramping Rate Plan 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=20201229-
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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, N. E.
Washington, D.C. 20426
Re: Poe Hydroelectric Project, FERC No. 2107-CA
Second Request for Extension of Time to File Long-Term Ramping Rate
Plan, SWRCB Condition 5.2, Forest Service 4(e) Condition No. 23, Part 5
Dear Secretary Bose:
Pacific Gas and Electric Company (PG&E) is writing to seek your approval for a second
extension of time request for the development of the Long-Term Ramping Rate Plan
(Project), Federal Energy Regulation
Commission (FERC) No. 2107. FERC issued a new license for the Project on
December 17, 2018 (License). Subsection (a) of Article 401 of the License requires
PG&E to submit this plan for FERC approval within one year of License issuance.
PG&E requested an extension of time approval from FERC in a letter dated December
12, 2019 and it was approved by FERC Order dated December 31, 2019. This
extension provided additional time, until December 31, 2020, to develop the Plan. By
this letter, PG&E requests that FERC further extend the deadline, from December 31,
2020, to June 30, 2021.
The Plan is required by the State Water Resources Control Board (SWRCB) Water
Quality Certification Condition 5 and Forest Service 4(e) Condition No. 23, part 5 of the
License. PG&E submitted an extension of time request to both agencies on October 29,
2020 (Enclosure 1). The Forest Service approved the request by letter dated December
16, 2020 (Enclosure 2), and the SWRCB approval is pending. PG&E will file the
SWRCB approval letter to FERC upon receipt if the SWRCB does not concurrently e-file
their approval letter with FERC. Since March 2019, PG&E has been in consultation with
the Forest Service, SWRCB, California Department of Fish and Wildlife, and U.S. Fish
(e.g., American Whitewater and California Sportfishing Protection Alliance) on the
development of this Plan.
At a December 3, 2019 meeting, PG&E presented the proposed framework to the
agencies and stakeholders to continue discussions and to develop a schedule to
identify long-term ramping rates for the Project. Monthly meetings were held from
Ms. Kimberly D. Bose, Secretary
December 28, 2020
Page 2
January through November 2020and are continuing into December 2020 and beyond.
PG&E needs additional time to continue to develop our understanding of both the
biological resources and the operational constraints with the agencies and stakeholders.
Therefore, PG&E is requesting an additional 6 months to complete the Plan. In the
meantime, the interim ramping rates will remain in effect to protect aquatic species
downstream of Poe Dam.
senior license
coordinator, Matthew Joseph, at 415-264-5244.
Sincerely,
Elisabeth Rossi
Supervisor, Hydro Licensing
Enclosures:
1.
2.
Enclosure 1
PG&E letter to SWRCB and Forest Service dated
October 29, 2020 requesting extension
245 Market Street
tƚǞĻƩ DĻƓĻƩğƷźƚƓ
San Francisco, CA 94105
Mailing Address:
Mail Code N11D
P.O. Box 770000
San Francisco, CA 94177
October 29, 2020
Mr. Erik Ekdahl Mr. Christopher Carlton
Deputy Director, Division of Water Rights Forest Supervisor
CA State Water Resources Control Board United States Department of Agriculture,
th
1001 I Street, 14 Floor Forest Service
Sacramento, CA 95814 Plumas National Forest
159 Lawrence Street
Quincy, CA 95971-6025
RE: Poe Hydroelectric Project, FERC Project No. 2107-CA
Request for Extension of Time to File
Long-Term Ramping Rate Plan, SWRCB Condition 5.2,
Forest Service 4(e) Condition No. 23, Part 5
Dear Messrs. Ekdahl and Carlton:
Pacific Gas and Electric Company (PG&E) is writing to seek your approval for a second
extension of time request for the development of the Long-Term Ramping Rate Plan (Plan)
-2107) (Project). The Federal Energy
Regulation Commission (FERC) issued a new license for the Project on December 17,
2018 (License). Subsection (a) of Article 401 of the License requires PG&E to submit
these plans for FERC approval within one year of License issuance. PG&E filed the first
extension request in separate letters to the State Water Resources Control Board
(SWRCB) and the U. S. Department of Agriculture - Forest Service (Forest Service), dated
November 26, 2019, which were approved in letters dated February 5, 2020 and
December 6, 2019, respectively. In addition, PG&E requested FERC approval in a letter
dated December 13, 2019 and it was approved on December 31, 2019. These extensions
provided additional time until December 31, 2020 to develop the Plan.
Since March 2019, PG&E has been working with Forest Service, SWRCB, California
county representatives, and other stakeholders (e.g., American Whitewater and California
Sportfishing Protection Alliance) on the development of this Plan. At the time of our last
extension request, the stakeholders were provided a proposed framework to move forward
on long-term ramping rate discussions and to set up possible dates for a next meeting. At
the December 3, 2019 meeting, PG&E presented the proposed framework to the
stakeholders to continue discussions and to develop a schedule to identify long-term
ramping rates for the Project. Monthly meetings were created from January through
Mr. Erik Ekdahl
Mr. Christopher Carlton
October 29, 2020
Page 2
November 2020. Despite good engagement from stakeholders and moving forward in our
understanding of both the biological resources and the operational constraints, PG&E is
requesting an additional 6-months to complete the Plan, thus extending the deadline until
June 30, 2021. In the meantime, the interim ramping rates will remain in effect to protect
aquatic species downstream of Poe Dam.
If you have any questions regarding this request, please contact me at (415) 973-7410.
Sincerely,
Steven J. Bauman, P.E.
Sr. Relicensing Project Manager
cc: via email
Savannah Downey (SWRCB)
Amy Lind (Forest Service)
Emily Moghaddas (Forest Service)
Aondrea Bartoo (USFWS)
Sarah Lose (CDFW)
Chris Shutes (CSPA)
Dave Steindorf (AW)
Paul Gosselin (Butte County)
Tracey Ferguson (Plumas County)
Enclosure 2
Forest Service letter dated December 16, 2020 approving
extension request
Logo Department Name Agency Organization Organization Address Information
United States Forest Pacific Southwest Region 159 Lawrence Street
Department of Service Plumas National Forest Quincy, CA 95971
Agriculture 530-283-2050
TDD: 530-534-7984
Fax: 530-283-7746
File Code: 2770
Date:December 16, 2020
Steve Bauman
Senior Relicensing Manager
Pacific Gas and Electric Company
Mail Code N11D
P.O. Box 770000
San Francisco, CA 94177
SUBJECT:FOREST SERVICE APPROVAL OF RESOURCE MANAGEMENT PLANS AND
EXTENSIONREQUESTSFORPACIFICGASANDELECTRICCOMPANY’SPOE
HYDROELECRTRIC PROJECT, FERCNO. 2107
Dear Mr. Bauman:
This letter is regarding seven Resource Management Plans (“Plans”), required by the Federal
Energy Regulatory Commission (FERC) License for Pacific Gas and Electric Company’s
(PG&E) Poe Hydroelectric Project (P-2107). The Forest Service filed revised final Federal
Power Act (FPA) Section 4(e) Conditions in July of 2018, including a requirement to develop
these Plans, and these Conditions became part of the new FERC license for the Poe
Hydroelectric Project, issued on December 17, 2018.
The new license for the Poe Hydroelectric Project requires 15 Plans, establishment of a
Recreation River Flow Technical Group with two associated Memoranda of Understanding
(MOU) covering river recreation, and development of an operations water balance modelwithin
one year of license issuance; i.e., by December 17, 2019. Two additional Plans are required
within one-two years of license issuance; i.e., December 17, 2020. Attached is the Forest
Service’s understanding of the current status of all these Plans.
By letters to PG&E (dated December 6, 2019, and March 19, 2020), I previously approved six
Plans, and the operations water balance model. In addition, these letters provided concurrence
on Plans and an MOU required by the State Water Resources Control Board, and my approval
for PG&E’s extension requests for the remaining Plans. I signed the MOU (required within
Forest Service Condition No. 26) on August 12, 2020. On September 25, 2020, I approved the
Recreation Enhancement, Construction, and Implementation Plan (Forest Service Condition
No. 26).
Over the past two months, PG&E has submitted four additional completed Plans, one revised
Plan, and two extension requests. With this letter, I approve the following:
Bald Eagle Plan (Forest Service Condition No. 35) - PG&E final plan approval request
dated October 19, 2020.
Caring for the Land and Serving People Printed on Recycled Paper
2
Steve Bauman
Assessment and phased implementation plan for the Bardees Bar Tunnel Spoil
Revegetation Plan (Forest Service Condition No. 40) - PG&E approval request dated
October 22, 2020
Long-Term Ramping Rate Plan (Forest Service Condition No. 23, Part 5) – six-month
extension to complete Plan - PG&E request dated October 29, 2020
Sediment Management Plan (Forest Service Condition No. 23, Part 3A) - minor revision
to previously approved Plan - PG&E approval request dated November 19, 2020
Heritage Properties Management Plan (Forest Service Condition No. 31) – one-year
extension to complete Plan - PG&E request dated December 3, 2020
Road Management (Forest Service Condition No. 37) –PG&E final plan approval
request dated December 15, 2020
Integrated Vegetation Management Plan (Forest Service Condition Nos. 29 and 34) –
PG&E final plan approval request dated December 15, 2020
Thank you for working with the Forest Service on these resource plans for the new Poe
Hydroelectric Project license. If you have any questions about this letter, please contact Amy
Lind, Hydroelectric Coordinator, Regional Hydropower Assistance Team, at (530) 478-6298,
amy.lind@usda.gov, or Emily Moghaddas, Recreation, Engineering, Lands, and Minerals Staff
Officer, Plumas National Forest, at (530) 283-7772, emily.moghaddas@usda.gov.
Sincerely,
CHRISTOPHER CARLTON
Forest Supervisor
cc: Dawn Alvarez, Amy Lind, David Brillenz, Emily Moghaddas, Hilary Maxworthy
3
Steve Bauman
ATTACHMENT
Status of Management and Monitoring Plans and MOU's for Poe Hydroelectric Project (FERC No. 2107) new license implementation.
Plan or MOU (Forest Service Condition Original Due Date to the Amended Due Date to the
Status
No. or SWRCB Condition only) FERC FERC
Fish and Benthic Macroinvertebrate Plumas National Forest (PNF) staff have reviewed and PG&E
Dec. 17, 2019 Completed in 2019
Monitoring (Condition No. 25) addressed comments. Final Plan provided to PNF and FERC.
RO and PNF staff have reviewed and PG&E addressed
Hazardous Substances (Condition No. 5)Dec. 17, 2019 Completed in 2019
comments.Final Plan provided to PNF and FERC.
Final version provided to
Operations Water Balance Model This is a working model/tool. License condition due date met, Not required to have Forest Service on Dec. 9,
(Condition No. 23, Part 2) and model will be updated as needed. FERC approval 2019; Not required by the
FERC
PNF staff have reviewed and PG&E addressed comments.Final
Gaging (SWRCB) Dec. 17, 2019 Completed in 2019
Plan provided to PNF and FERC.
PNF staff have reviewed and PG&E addressed comments. Final
Water Temperature Monitoring (SWRCB) Dec. 17, 2019 Completed in 2019
Plan provided to PNF and FERC.
SWRCB and Forest Service approve, but do not sign. PNF staff
MOU1 (SWRCB) -Recreation Technical
have reviewed and PG&E addressed comments; other signatories Dec. 17, 2019 Completed in 2019
Review Group
are complete.
PNF staff have reviewed and PG&E addressed comments. Final
Amphibian Monitoring (Condition No. 25) Dec. 17, 2019 Completed in March 2020
Plan provided to PNF and FERC.
PNF staff have reviewed and PG&E addressed comments. Final
Tributary Access Observation (fish) Dec. 17, 2019 Completed in March 2020
Plan provided to PNF and FERC.
(Condition No. 23, Part 6)
Completed in March 2020;
Sediment Management (Condition No. 23, PNF staff have reviewed and PG&E addressed comments. Final
Dec. 17, 2019 Minor revisioninNovember
Part 3A) Plan provided to PNF and FERC.
2020
Fire Prevention and Response (Condition PNF staff have reviewed and PG&E addressed comments. Final
Dec. 17, 2019 Completed in March 2020
No. 7) Plan provided to PNF and FERC.
PNF staff have reviewed and PG&E addressed comments. Final
MOU2 -Poe Interagency Recreation River Prior to first full recreation Completed/fullysigned in
MOU provided, but PNF is waiting on signatures from other
Flow Management (Condition No. 26) season. August 2020
parties.
PNF staff have reviewed and PG&E addressed comments. Final
Riparian Monitoring (SWRCB) Dec. 17, 2019 Completed in March 2020
Plan provided to PNF and FERC.
4
Steve Bauman
Plan or MOU (Forest Service Condition Original Due Date to the Amended Due Date to the
Status
No. or SWRCB Condition only) FERC FERC
PNF staff have reviewed and PG&E addressed comments. River
Recreation Enhancement, Construction,
flow plan required under MOU2 is included as an attachment to Dec. 17, 2019 Completed in September 2020
and Implementation (Condition No. 26)
this Plan. Final Plan provided to PNF and FERC.
PNF staff have reviewed drafts, participated in field condition
Road Management (Condition No. 37) assessments, and PG&E has addressed comments. Final Plan Dec. 17, 2019 Dec. 31, 2020
provided to PNF.
Regularly meeting with PG&E and other stakeholders to discuss
Long Term Ramping Rates (Condition No. approach and content of this Plan; PG&E provided a draft Plan
Dec. 17, 2019 June 30, 2021
23, Part 5) provided to stakeholders in July 2020. Tied to upstream
hydroproject – further discussion needed to complete Plan.
PG&E provided aTechnical Assessment(TA)to PNF inMay
2020, which was reviewed by PNF staff. In October 2020, Plan is now phased Plan and
Bardees Bar Tunnel Spoil Revegetation
PG&E provided a revised TA along with a plan and schedule for Dec. 17, 2019 split into two Plans; expected
(Condition No. 30)
completing: the stability plan, a targeted revegetation plan, and completion 2021-2022
implementation of both plans.
PG&E provided an Archeology Report to PNF in late May 2020;
Heritage Properties Management
Traditional Cultural Properties study is ongoing with interviews Dec. 17, 2019 December 31, 2021
(Condition No. 31)
delayed due to Covid; pending draft of full Plan from PG&E.
PG&Eprovided draft Plan in July 30, 2020; PNF reviewedPlan
Bald Eagle Management (Condition No.
and discussed with PG&E in August. PG&E addressed Dec. 17, 2020 No change
35)
comments and provided a final plan provided to PNF.
Combines two Forest Service License Conditions; PG&E
Fuel Treatment and Invasive Weed
provideddraft Plan on Aug. 10, 2020. PNF staff have reviewed
Management (Integrated Plan) (ConditionDec. 17, 2019 and 2020Dec. 31, 2020
drafts, and PG&E has addressed comments. Final Plan provided
Nos. 29 and 34)
to PNF.