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HomeMy WebLinkAbout8.25.22 Board Correspondence - FW_ Environmental and Recreational Compliance Report submitted in FERC P-803-000 by PG&EFrom:Paulsen, Shaina To:Bennett, Robin; Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Hironimus, Patrizia; Kimmelshue, Tod; Lucero, Debra; Paulsen, Shaina; Pickett, Andy; Reaster, Kayla; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Valencia, Shyanne Subject:Board Correspondence - FW: Environmental and Recreational Compliance Report submitted in FERC P-803-000 by Pacific Gas and Electric Company,et al. Date:Thursday, August 25, 2022 11:14:48 AM Please see Board Correspondence below. Shaina Paulsen Associate Clerk of The Board Butte County Administration 25 County Center Drive, Suite 200, Oroville, CA 95965 T: 530.552.3304 | F: 530.538.7120 -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Thursday, August 25, 2022 11:05 AM Subject: Environmental and Recreational Compliance Report submitted in FERC P-803-000 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 8/25/2022, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Pacific Gas and Electric Company Pacific Gas & Electric Company (as Agent) Docket(s): P-803-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Environmental and Recreational Compliance Report Description: Pacific Gas and Electric Company submits 2022 Operations and Maintenance Plan for the DeSabla-Centerville Hydroelectric Project under P-803. 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Box 770000 San Francisco, CA 94177 August 25, 2022 Via Electronic Submittal (E-File) Kimberly D. Bose, Secretary Federal Energy Regulatory Commission Division of Hydropower Administration and Compliance 888 First Street, NE Washington, D.C. 20426 RE: DeSabla-Centerville Hydroelectric Project, FERC No. 803-CA 2022 Operations and Maintenance Plan Dear Secretary Bose: Under the Federal Energy Regulatory Commission's (FERC) "Order Amending Temperature Requirements" (Order) issued on August 20, 1998, Pacific Gas and Electric Company (PG&E) is submitting its 2022 Operations and Maintenance Plan (2022 O&M Plan) for the DeSabla – Centerville Hydroelectric Project, FERC No. 803. Consistent with FERC's Order, PG&E held a virtual meeting to discuss the 2022 O&M Plan on May 10, 2022, with the National Marine Fisheries Service (NMFS), California Department of Fish and Wildlife (CD FW), the U.S. Forest Service (USFS) and the U.S. Fish and Wildlife Service (USFWS), State Water Resources Control Board (Collectively, Resource Group). The enclosed 2022 O&M Plan (Enclosure 1) addresses the coordinated operation of the Project and continues to provide for water temperature monitoring and a forecasting approach to promptly detect changing summer weather conditions. The draft 2022 O&M Plan was provided to the Resource Group for comments via email on May 4, 2022. By June 12, 2022, PG&E had received final comments from CDFW, NMFS, and the USFWS. Should you have any questions or comments, please do not hesitate to contact PG&E’s License Coordinator, Jackie Pope, at 530-254-4007. Sincerely, Elisabeth Rossi Supervisor, Hydro License Compliance Enclosures: 1. DeSabla Centerville Operations and Maintenance Plan 2. PG&E and Agency Comment Matrix 3. Operations and Maintenance Plan Agency Comments, June 12, 2022 cc: List Attached Kimberly D. Bose, Secretary August 25, 2022 Page 2 cc: With Enclosures via Email Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, (530) 333-7746 Grantton Henley (CDFW)- Grantton.Henley@wildlife.ca.gov, (916) 272-4152 Anna Allison (CDFW) – Anna.allison@wildlife.ca.gov, (916) 272-4373 Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, (916) 358-2875 Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov, (916) 930-3722 Allison Bosworth (NOAA Fisheries) Allison.Bosworth@noaa.gov, (916) 930-5617 Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, (707) 575-6052 Tristan Leong (USFS)– tleong@fs.fed.us, (530) 226-2308 Jeff Wetzel (SWRCB) – Jeff.wetzel@waterboards.ca.gov, (916) 323-9390 Daniel Welsh (USFWS) – Daniel_weslsh@fws.gov, (916) 930-5639 Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov, (916) 930-2658 ENCLOSURE 1 Final DeSabla-Centerville Project (FERC No. 803) Final 2022 Operations and Maintenance Plan Pacific Gas and Electric Company The objective of the Operations and Maintenance Plan (O&M Plan) is to focus on how to best provide water temperatures that are as cold as possible to support holding, spawning, and rearing of Central Valley (CV) spring-run Chinook salmon in the reaches of Butte Creek below the DeSabla Powerhouse during 2022. It also documents Pacific Gas and Electric Company’s (PG&E) scheduled outages that allow for maintenance activities of the DeSabla-Centerville Project (Project). This O&M Plan outlines the procedures and practices PG&E will strive to follow in the operation of the Project to enhance and protect this habitat for CV spring-run Chinook salmon. This O&M Plan is also intended to provide the basis for modification of the reservoir temperature release criteria established in the Federal Energy Regulatory Commission (FERC) “Order Approving Water Temperature Study Report” issued August 21, 1997, as amended by FERC’s “Order Amending Temperature Requirements” issued August 20, 1998. A. Introduction 1) The DeSabla – Centerville Project includes the following features which are depicted in Exhibit A: Reservoirs and Forebays: Round Valley Reservoir (also called Snag Lake), Philbrook Reservoir, and DeSabla Forebay Canals and related features: Butte, Hendricks, Toadtown, Upper Centerville, and Lower Centerville canals and associated diversion dams, feeders, and spillway channels Powerhouses: Toadtown, DeSabla, and Centerville 2) Project Benefits to Butte Creek Habitat: a) Water diverted from the West Branch Feather River at the Hendricks Diversion Dam (including releases from Philbrook and Round Valley Reservoirs) increases the total flow available in Butte Creek below DeSabla Powerhouse by approximately 40% in July and August (depending on water availability in Butte Creek). b) Water imported from the West Branch Feather River provides additional water to cool water temperatures in reaches of Butte Creek used by CV spring-run Chinook salmon for over-summering by providing releases from Philbrook Reservoir when storage is available. The increased flow from the West Branch Feather River also helps minimize heating by reducing the residence time in the DeSabla forebay. The shorter travel time of water in canals also helps to minimize heating. 2 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final 3) Background: The Project storage reservoirs (Round Valley and Philbrook Reservoirs) are in the West Branch Feather River watershed. Project diversions are made from this drainage at the Hendricks Canal Diversion Dam. Due to the larger storage capacity and depth of Philbrook Reservoir (5,000 acre-feet) relative to Round Valley Reservoir (1,200 acre-feet), the water temperature tends to stay cooler for a longer period in Philbrook Reservoir. Accordingly, since 1998 PG&E has released water from Round Valley Reservoir first, to effectively manage the temperature of water released into Butte Creek. In more recent years, increases in flow at Round Valley (above minimum instream flow requirements) have been made later to reserve water in Philbrook Reservoir so that it is available during the hottest time of the holding period. Due to the input of very cool water from springs near Coon Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in the summer (June –August) have not increased water temperatures at Hendricks Diversion Dam. PG&E notifies the Resource Agencies when water releases commence from Round Valley Reservoir. a. Releases from Round Valley Reservoir begin between early May to mid-July when there is capacity in the Hendricks canal and, depending upon the amount released, continues for a period of approximately one to two months. Philbrook releases are typically delayed until releases from Round Valley begin to diminish or heat storm events occur. In 2016-2018 water from Round Valley Reservoir has been used to augment flow releases from Philbrook Reservoir. The release valves from these reservoirs must be operated manually and the travel time of the water released from these reservoirs to the Lower Centerville Diversion Dam (LCDD) is approximately 21 to 29 hours. Travel time of operator to the valve locations is approximately 1½ hours during workdays and may be up to 4 hours on weekends. b. On August 21, 1997, the FERC issued an Order placing temperature restrictions (17ºC at Round Valley and 18ºC at Philbrook) on the releases from these dams. On August 20, 1998, and 2020-2021, the FERC revised its Order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), the California Department of Fish and Wildlife (CDFW), and the United States Fish and Wildlife Service (USFWS); PG&E has also included the State Water Resource Control Board (SWRCB), and United States Forest Service (USFS) in this consultation process. These five agencies are referred to as the Resource Agencies in this Plan. Since 1999, this agreement has been accomplished by way of an annual O&M Plan. Reservoir operation has been based on expected water year conditions. Pursuant to FERC’s August 21, 1998 Order, this O&M Plan is annually updated and modified as appropriate in consultation with the Resources Agencies. This consultation group, composed of PG&E and the Resource Agencies, is called the Resource Group in the remainder of this Plan. Starting in 2016 a schedule of maintenance outages of the DeSabla-Centerville Canals was included in this O&M Plan. 3 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final c. The Resource Group has learned that there is a benefit from providing an increase in flow to Butte Creek during the hottest part of the holding period. Storage in Philbrook Reservoir is used to supplement flows in Butte Creek during the holding period. Monitoring data shows that cooler water released from the bottom of Philbrook Reservoir (i.e., the cold-water pool) increases in temperature while traveling through the system and reaches thermal equilibrium at Hendricks Diversion Dam. The Resource Group has agreed that it is a combination of total flow (decreased travel time, increased mass of water subject to heating) and cold-water releases that help reduce water temperatures in Butte Creek. Generally, the cool- water pool in Philbrook is depleted in late July to early August and release temperatures increase through August (e.g. maximum daily average release temperature of 20.3 ºC occurred on August 17, 2018); however, monitoring data show that after the beginning of August the thermal regime in the basin is such that releases with higher temperatures actually cool as the water travels to Hendricks Diversion Dam (sun declination is lower, canyon walls shade the stream, and cool evenings predominate). d. Initially, when management of Philbrook flows began in 1998, outflow from the reservoir was increased in response to forecasted heat events and then returned to pre- heat levels to save water. This resulted in a large amount of residual water storage at the end of the holding period, which was then released in September to make room in the reservoir for upcoming winter storms (Exhibit B). The Resource Group has moved away from short-term responses to heat events to releasing outflow from Philbrook in a stepwise fashion; this approach maximizes the use of storage during the holding period and minimizes the amount of residual storage at the end of the holding period. Although the Resource Group had been moving towards this approach in previous years, 2014 was the first year in which this pattern of management was fully employed (Exhibit B). Since 2014, an increase from minimum instream flow begins when room is available in the Hendricks canal and increases in a stepwise manner (i.e., by 5 to 10 cfs based on predicted heat events). If no heat event is predicted and flows remain steady in the canal, releases are held steady until the next heat event is forecasted. In this way, releases are increased so maximum flow is reached during the hottest period of the summer (mid-July to early August). Maximum release is held for a short period and is based on the amount of water available for the remainder of the holding period. It is then decreased in a stepwise fashion with timing and quantity of decrease dependent on a balance between heat events, remaining storage availability and the knowledge that as mid-August approaches we expect decreased average daily temperatures. The Resource Group has concluded that this release pattern is beneficial since it utilizes most of the stored Philbrook water during late June through late July when air and Butte Creek water temperatures are at their highest during the holding period. PG&E primarily uses meteorological forecast and amount of storage in Round Valley and Philbrook Reservoir to determine the amount and duration of increased flow. 4 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final This has been shown to result in a pro-active management of water supply. CDFW adds information about abundance, distribution and health of fish and temperatures at Quartz Bowl to help inform/support agency decisions. Collectively the Resource Group agree to a flow proposal based on the information provided. Management of flows in 2021 was different from how the project has been managed since 2014 because of all the challenges experienced. During the 2021 dry water year, both the Philbrook Reservoir and Round Valley Reservoir had not filled. This scenario had only been observed before during the 2015 water year. Limited water supply, plus above normal ambient air temperatures, coupled with potentially the largest population of SRCS observed since surveys have been performed, made 2021 a very challenging year for the run. Due to the limited water storage, the outflow from Philbrook Reservoir deviated from the stepwise method of releases. This deviation was driven by limited water resources, observed disease, and limited access to Philbrook Reservoir during local wildfires. e.During relicensing studies, water temperature modeling provided evidence that the use of the Lower Centerville Canal (LCC) benefited CV spring-run Chinook salmon holding downstream of the Centerville powerhouse (CVPH) by decreasing temperatures in these lower reaches (PG&E 2007). Modeling showed that the temperature benefit increases with the volume of flow provided through the canal, which is much higher when the CVPH is in operation. Due to its observed and modeled impact on water temperatures and distribution of CV spring-run Chinook salmon during the holding period, the operation of the LCC was included in previous O&M Plans but has been removed since it was taken out of service. f.The CVPH went offline in February 2011; from 2011-2013, the diversion of flow into the canal during the holding period continued at the request of the Resource Group. In 2013, diversions were decreased into the LCC after consultation with the Resource Agencies due to the unusually high numbers of CV spring-run Chinook salmon holding above CVPH. The water temperature data showed that the temperature benefit of using the LCC decreased as diverted flows into the LCC decreased. The decrease of flow diverted into the LCC was due to the limited availability of water that resulted from a dry water year. After the experience of 2013, in 2014 and 2015 the Resource Group made a consensus decision to not operate the LCC during the holding period because of the dry water year type. The Resource Group concluded that, likely, there would be insufficient water available to divert enough flow into the LCC to provide a cold-water benefit to any fish holding downstream of the Centerville Powerhouse. The Resource Group made a mutual decision not to run the LCC during the 2016 holding period of CV spring-run Chinook salmon, although it was a normal water year. On February 25, 2016, a conference call occurred between representatives of the Resource Group. PG&E sought Resource Agency guidance on whether to operate the LCC during the 2016 holding period. PG&E described the challenges of restoring the LCC to service after a 2.5-year period (2 summer holding periods) of non- 5 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final operation, including turbidity risk and the resulting potential for negative public perception. PG&E reminded the Resource Agencies that as the CVPH is inoperable, the LCC is only used to benefit the CV spring-run Chinook salmon. The Resource Agencies requested time before offering guidance to PG&E. On March 8, 2016, another conference call was held. PG&E provided additional information showing that because of the limited capacity of the CVPH’s Bypass/Spillway, the use of the LCC without the CVPH decreases the temperature benefit to fish holding in the downstream reaches. There was concurrence among the Resource Group on the call that PG&E would not be requested to put the LCC into service. The Resource Group agreed that availability of the LCC in future years requires more discussion and may depend on the outcome of the FERC License conditions. In 2017-2021 PG&E did not utilize the LCC to benefit water temperature for fish holding in the downstream reaches of CVPH. g. On February 16, 2017, PG&E submitted a notice of the withdrawal of its application for a new license for the project. On March 2, 2017, Commission staff issued an order disallowing the withdrawal and soliciting statements of interest regarding acquisition of the project license. In June 2018, PG&E selected a prospective buyer for the Project. Progress on the negotiations has been adversely affected by the Camp Fire, PG&E’s bankruptcy process, interconnections requirements, and settlement on various terms and conditions. PG&E submitted the Quarterly Status Report on the progress made in negotiating the sale and transfer of the project on August 16, 2022. This report detailed that PG&E plans to keep the Desabla Centerville Project; PG&E is requesting FERC move forward with any actions necessary to continue the FERC Licensing process for the project. B. Forecast for 2022 Water Year Type and Reservoir Operations The 2022 Water Year Type is currently forecasted to be “normal” per the definition of the license. The Department of Water Resources (DWR) forecast as of May 1, 2022, indicates that the Feather River Basin April-July runoff into Oroville is expected to be 51% of average. Exhibit C lists historical runoff forecasts and water year types since 1998. Reservoir Operations for 2022 Due to the water year type, the reservoirs will be operated under normal conditions. The Round Valley low level outlet (LLO) was fully closed on April 1, 2022. The Philbrook LLO is scheduled to provide MIF (3 cfs) until mitigations are started. PG&E successfully obtained an early gate closure from DSOD and the radial gate was closed on March 17, 2022. Installation of flashboards begins once the water elevation reaches the radial gate spillway which is 5ft below the bottom of the flashboards; flashboards were installed April 4th, 2022, flashboards are typically completely installed by June. The required normal water year minimum instream flows are being met. 6 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final Reservoir operation for the holding period is as follows: 1) Releases from Round Valley Reservoir begin when there is capacity in the Hendricks Canal. Capacity is dependent upon water year type. Because of the 2022 water type, Round Valley Reservoir is at full capacity 1168-acre foot as of April 27, 2022; the reservoir was emptied on July 25, 2022. It is expected that releases will begin in early summer from June to mid-July. Again, due to the input of very cool water from springs near Coon Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in early summer (June – early July) have been shown to not increase water temperatures at Hendricks Diversion Dam. PG&E will notify the Resource Agencies when water releases commence from Round Valley Reservoir. 2) As Round Valley Reservoir nears its minimum elevation, PG&E will consult with the Resource Agencies to determine when releases from Philbrook Reservoir should be increased to avoid a drop in canal flows when Round Valley Reservoir flow runs out. PG&E will closely monitor the drawdown of Round Valley Reservoir as the minimum elevation is approached. 3) The Resource Group will determine the initial release level from Philbrook Reservoir. Factors considered in establishing the actual rate of release include the date upon which releases commence the objective of reserving relatively cool water for a possible extreme heat event, the level of natural flows, and the objective of maintaining the highest possible flows through the DeSabla Forebay. 4) The “stepwise” release pattern from Philbrook Reservoir (as described above) was used during the 2014 – 2020 holding periods. This stepwise release pattern was modified in 2021 because of limited flows. In 2022 Philbrook reservoir filled, the Resource Group was able to use the stepwise pattern. The Resource Group determined the initial outflow from Philbrook Reservoir. The Resource Group holds weekly phone call meetings to determine these stepwise increases in outflow (approximately 5 to 10 cfs each) based on predicted heat events. Weekly phone calls also include discussion of weather forecast, reservoir levels, pre- spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. The Resource Group then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing meteorology predictions and storage availability); flows are expected to be returned to the minimum release about mid-September. A flow through the forebay of 60 cfs is targeted to reduce residence time and minimize heating of water as it moves through the forebay. The 60 cfs target flow through the DeSabla Forebay will be reviewed during the summer on the weekly calls described above to determine if this rate should be adjusted based on the available releases from Philbrook Reservoir. 5) Water temperature monitoring by PG&E will continue in 2022 at six stations (Exhibit E), five of which have been used prior to relicensing (since 1998). Installation of recorders 7 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final occurs in June or as soon thereafter when safe access to the stream channels is possible. Data will be reported out to the resource agency during the 2023 Annual Operations Meeting. 6) DWR gage BW12 (available on CDEC, provided on an hourly basis) will be used as the indicator of water temperatures in the Project waters that are diverted from the West Branch Feather River. C. Lower Centerville Canal Operations for 2022 As discussed previously (section A), due to turbidity concerns with returning the LCC to service, PG&E will not resume operation of the LCC in 2022. In addition, the project is currently up for sale and so PG&E is not considering returning the canal to service since the fate of the powerhouse is unknown. D. Contingency for Extreme Heat Event During the Holding Period In anticipation of a possible high ambient air temperature event, the following actions will be taken: 1. Ambient air temperature conditions are a major factor in determining actual water temperatures in Butte Creek. Starting on June 1 or at such time as the Resource Group determines, PG&E will prepare a weather forecast for the Project area by noon each Monday and Thursday. The weather forecast will be based on information from USFS weather stations at Cohasset and Chester. PG&E will provide an e-mail copy of the forecast to the Resource Agencies. If air temperatures in excess of 105ºF for two or more days during the next seven-day period are forecasted at Cohasset, with the potential for compression heating at higher elevations as confirmed by data from the Chester location, PG&E will send an e-mail to each Resource Agency representative identified in paragraph 5 below advising them that an extreme heat event is forecasted. If the next forecast confirms that an extreme heat event has started or is imminent within the next two days, and is expected to continue for over two days, PG&E will send a second e- mail, phone, or fax to one of the individuals at each Resource Agency identified in paragraph 5 to discuss actions to be taken. If personal contact cannot be made and PG&E still believes action needs to be taken, it will initiate efforts to modify Project operation as discussed in paragraphs 2 – 5, below. If action is taken, PG&E will send a third email or phone the Resource Agencies and explain the actions taken. 2. PG&E will coordinate weekly conference calls with the Resource Agencies during the CV spring-run Chinook salmon’s holding period. Increased call frequencies will be conducted as requested and agreed upon by the Resource Group. These conference calls are usually conducted from early June through mid-September (as needed). During these conference calls the Resource Group will discuss the results of pre-spawning mortality surveys (if provided by CDFW or NMFS), meteorological forecasts, water temperatures recorded by CDFW at Quartz Bowl Pool, flows and storage in Philbrook Reservoir. 3. The actual amount of water released from Philbrook Reservoir during a confirmed extreme heat event will depend on PG&E’s assessment of then-existing conditions and recommendations and comments received from the Resource Agencies in response to the 8 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final e- mails. The individuals to whom PG&E will send e-mails under this section are: • Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, (530) 333-7746 • Grantton Henley (CDFW)- Grantton.Henley@wildlife.ca.gov, (916) 272-4152 • Anna Allison (CDFW) – Anna.allison@wildlife.ca.gov, (916) 272-4373 • Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, (916) 358-2875 • Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov, (916) 930-3722 • Allison Bosworth (NOAA Fisheries) Allison.Bosworth@noaa.gov, (916) 930-5617 • Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, (707) 575-6052 • Tristan Leong (USFS)– tleong@fs.fed.us, (530) 226-2308 • Jeff Wetzel (SWRCB) – Jeff.wetzel@waterboards.ca.gov, (916) 323-9390 • Daniel Welsh (USFWS) – Daniel_weslsh@fws.gov, (916) 930-5639 • Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov, (916) 930-2658 E. Spawning Flows in Butte Creek As in previous years, it is best to reduce flow from the WBFR watershed so that redds are not at risk of being dewatered if an emergency outage occurs on the Hendricks or Butte canals. In the past, flows from the West Branch Feather River were decreased around mid-September when mean daily temperature decreases naturally and the use of the canals has less of an effect on keeping water temperatures cool. Essentially this sets flows at a level that can be sustained through February 28, 2023, or other appropriate date determined by the Resource Group. F. Scheduled and Emergency Maintenance and Operations 1) Maintenance Outage Scheduling – To minimize the disruption of flows in Butte Creek during times that are sensitive to CV spring-run Chinook salmon holding in Butte Creek, PG&E plans to take scheduled canal outages as early as possible in the year. Exhibit D is a schedule of planned maintenance and outages on the Project canals. 2) Unplanned Outages (2022-2023) - Winter storms, disruption in canal flows caused by slides or fallen trees, unexpected electric transmission system outages, Public Safety Power Shutoffs (PSPS) and other hazardous conditions can disrupt normal Project operation. PG&E shall use its best efforts to minimize impacts that may result from these conditions, including the actions outlined below: a) PSPS - As part of our Community Wildfire Safety Program, PG&E is implementing additional precautionary measures to help reduce the risk of wildfires. For public safety, it may be necessary for us to turn off electricity as a last resort when extreme fire danger 9 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final conditions are forecasted. This is called a "Public Safety Power Shutoff." See section below for more information on impacts and response. b) Unit Separation from Electric Grid - If the electric transmission grid, generating unit, a critical support system experiences a problem, or in the event of a PSPS, the generating units automatically separate from the grid and the flow of water to the units is directed away from the turbine. At the Toadtown and DeSabla powerhouses this is done by means of a bypass device that directs the flow through an energy dissipater bypass and allows the water to continue moving at approximately the same flow. PG&E will adjust the automatic bypass opening during the summer to reasonably correspond to the operational flow of the powerhouse. The shift from the generating unit to the bypass facility may result in a minor release of turbidity caused by sediment that may have built- up in the bypass system since its last use. During a unit separation or PSPS event, standby portable generators are deployed to supply power to station batteries that power bypass system controls. During a separation from electric grid, PG&E increases patrol of canals as some remote operation of equipment and some remote monitoring will not be available. In preparation for PSPS events, PG&E staffs additional personal to remediate any issues that arise during the duration of the event. c) Winter Operation and Canal Emergencies – Much of the Project’s canal system traverses steep forested lands. During times of high rainfall and/or high winds, slides, rock falls, and fallen trees can damage canals or block flows. To minimize the potential for damage in the event of a blockage or failure of a canal or flume, PG&E may reduce canal flows or dewater canals in advance of such weather events. In addition, emergency spill gates are located at several locations that are equipped with devices that can be operated remotely to spill water at various locations along the canals. PG&E has installed sensors that report canal flow levels to the operator at the Rock Creek Switching Center. This location is staffed 24 hours a day, 7 days a week, 365 days a year. If a sensor detects an unexpected change in the flow, an alarm is sent to alert the operator on duty. The operator will then dispatch personnel to the location to determine if immediate action can or should be taken to remove water from the canal by activating an emergency spill gate. The emergency spill gates are placed at locations where the channel through which the water will travel is generally protected by rocks and boulders. However, turbidity is possible from vegetative or other debris that may have accumulated in the channel since its last use. Spill channels are routinely inspected at the beginning of the winter season and are typically operated once during a winter high flow event to maintain the prescriptive right for the spill channel and keep the release gate clear of material. This operation results in an incremental increase in the turbidity of Butte Creek for a short period of time, which is typically already elevated during high flow events. Operation of the spill channels that may not be well protected and could likely result in turbidity increases, other than the annual winter operation discussed above, will be operated for emergency purposes only. To avoid releasing water into a damaged canal after a storm event, the canal is patrolled on foot prior to restoring flow. 10 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final G. Water Quality Monitoring 1) PG&E will monitor water temperature at six seasonal stations during 2022. These are in addition to the real-time, permanent CDEC station at BW-12. Temperature monitoring will generally be conducted between June and September. Results will be presented at the following Annual Operations and Management Meeting. Monitoring locations are identified in Exhibit E. 2) Prior to the start-up of a canal or powerhouse after an outage, which may result in the possible release of turbidity to Butte Creek, PG&E will monitor water quality using two existing continuous monitoring turbidity sensors located in Butte Creek; one sensor is located at the LCDD, the other sensor is on a wing wall of the CVPH tailrace. 3) In the event of a canal failure, spill gate operation or other release that results in a potential for turbidity to Butte Creek, PG&E will secure water quality samples to the extent practicable and taking into consideration personnel safety. The monitoring will be conducted using either grab samples collected by PG&E and tested for turbidity or use data from the two continuous monitoring turbidity meters (noted above), set to sample every 15 minutes. Sampling locations will generally be immediately upstream of the dam or point of diversion and approximately 300 feet downstream of the point of release or return to surface waters. If the point of release to surface waters is not reasonably accessible by vehicle, PG&E will sample at the nearest downstream location that can be safely and readily accessed. 4) Turbidity data collected during a canal start-up, etc., will be made available to one of the individuals at each of the Resource Agencies identified in Section D, paragraph 5, in a timely fashion. Water temperature data will be provided to Resource Agency representatives upon request. H. Ongoing Consultation 1) On August 21, 1997, the FERC issued an order placing temperature restrictions on releases from PG&E’s storage reservoirs in the upper West Branch Feather River watershed. On August 20, 1998 the FERC revised its order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), California Department of Fish and Wildlife (CDFW) and U.S. Fish and Wildlife Service (USFWS). Since 1999, this agreement has been accomplished by way of an annual operations plan for these reservoirs. The reservoir operation varies based on water year conditions. Pursuant to FERC’s August 21, 1998 order, this Operations Plan is annually updated and modified as appropriate in consultation with the Resource Agencies. The FERC Order requires licensee to notify FERC within 30 days after reaching agreement on the O&M Plan. 2) PG&E will meet at least annually with the interested Resource Agencies to discuss and review this O&M Plan. In addition, PG&E will continue to provide updates (generally by e- mail) on Project operations and events to at least one representative from each of the individual Resource Agencies identified in Section D, paragraph 5. A summary report will be prepared on annual operations and monitoring data, which will include water and air temperatures, reservoir and conveyance operations and actions taken to minimize effects on 11 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final the CV spring-run Chinook salmon. 3) Nothing in this O&M Plan will be construed as modifying any of the terms and conditions of the DeSabla-Centerville license, FERC No. 803, or in any manner limit the jurisdiction of the FERC. In the event of any conflict between any of the provisions of this O&M Plan and the license, the provisions of the license will control. 4) PG&E will work with the Resource Agencies, and others, as appropriate, to seek ways to promote prudent land management practices by others where such practices may directly or indirectly impact safe, reliable canal operations. Nothing in this O&M Plan will be construed as either PG&E or the Resource Agencies accepting responsibility for conditions or damage that may be the result of the actions, or inactions, of others. 5) PG&E management does not anticipate the sale and transfer of the Project in 2022 and plans on continued participation with the DeSabla Centerville Operations through the end of the year. I. References PG&E. 2007. DeSabla-Centerville Hydroelectric Project. FERC Project No. 803. License Application. Appendix E6.2.2.3-G Calibration and Scenarios Report. 14 pp. PG&E. 2015. Final Project Operations Plan – 2015. Pacific Gas and Electric Company DeSabla- Centerville Project (FERC No. 803). June 18, 2015 12 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final EXHIBIT A Map of Project area. 13 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final EXIBIT B Comparison of Philbrook Reservoir Storage Usage 14 August 2022 2022 Operations and Maintenance Plan Pacific Gas and Electric Company Final EXHIBIT C HISTORICAL RUNOFF FORECAST AND WATER YEAR TYPE SINCE 1998 Water Year Runoff Forecast Water Year Type 1998 149% Normal 1999 115% Normal 2000 99% Normal 2001 46% Dry 2002 70% Normal 2003 97% Normal 2004 70% Normal 2005 93% Normal 2006 180% Normal 2007 38% Dry 2008 66% Normal 2009 64% Normal 2010 106% Normal 2011 171% Normal 2012 80% Normal 2013 47% Dry 2014 31% Dry 2015 19% Dry 2016 84% Normal 2017 214% Normal 2018 77% Normal 2019 176% Normal 2020 55% Normal 2021 37% Dry 2022 51% Normal Runoff Forecasts are the published May 1 Bulletin 120 forecast of April – July unimpaired runoff into Oroville Reservoir as a percent of the 50-year average computed by the State of California at that time. Water Year Type is “Dry” if the runoff forecast is 50% or less. 15 August 2022 2022 Operations and Maintenance Plan 2022, Pacific Gas and Electric Company Final EXHIBIT D 2022 SCHEUDULED MAINTENANCE AND OUTAGES DESABLA-CENTERVILLE 2022 MAINTENANCE AND OUTAGE SCHEDULE JANUARY -DECEMBER OUTAGE SCHEDULE LOCATION DESCRIPTION OF WORK DURING OUTAGE DEWATERED STRUCTURE Start Date End Date BUTTE CANAL annual maintenance None. Limited flow (5-10cfs) will remain during work. 5/2/2022 5/31/2022 DE SABLA POWERHOUSE annual maintenance and inspections, vegetation management None 5/2/2022 5/31/2022 HENDRICKS CANAL annual maintenance, undermining repairs and liner repairs, erosion control, accessibility repairs. Fish rescue planned for 5/2/2022 to support dewatering Canal 5/2/2022 5/31/2022 LOWER CENTERVILLE CANAL vegetation management completed February 2022 OUT OF SERVICE OUT OF SERVICE OUT OF SERVICE UPPER CENTERVILLE CANAL canal annual and vegetation management None 5/2/2022 5/31/2022 CENTERVILLE POWERHOUSE TBD penstock canal OUT OF SERVICE OUT OF SERVICE TOADTOWN POWERHOUSE annual maintenance None 5/2/2022 5/31/2022 TOADTOWN CANAL minor repairs; annual maintenance various locations 5/2/2022 5/31/2022 16 August 2022 2022 Operations and Maintenance Plan 2022, Pacific Gas and Electric Company Final EXHIBIT E PG&E SEASONAL MONITORING LOCATIONS – 2022 1. Philbrook Creek at release * (Temperature and Flow) 2. WBFR at Hendricks Head Dam * (Temperature and Flow) 3. Total canal inflow to DeSabla Forebay * (Temperature and Flow) 4. DeSabla Powerhouse tailrace * (Temperature and Flow) 5. Butte Creek at LCDD * (Temperature, Turbidity, and Flow) 6. Butte Creek at Centerville Powerhouse (Temperature and Turbidity) * Original monitoring stations used since 1998 17 August 2022 2022 Operations and Maintenance Plan 2022, Pacific Gas and Electric Company Final Water Temperature Monitoring Network. ENCLOSURE 2 PG&E’s Response to Comments on the 2022 DeSabla-Centerville Operations and Maintenance Draft Plan Minor edits were accepted. The following comment table contains PG&E’s responses to substantial comments and suggested edits. Agency comments captured in italics. No Subject Commenter Comment/Suggested Edits Response 1 Background; section d; Page 3 CDFW- McReynolds Since 2014, an increase from minimum instream flow begins when room is available in the Hendricks canal and increases in a stepwise manner (i.e., by 5 to 10 cfs based on predicted heat events and fish health (provided by CDFW). If no heat event is predicted, flows remain steady in the canal, and fish appear in good health, releases are held steady until the next heat event is forecasted. Changes not accepted. See added language in O&M Plan on page 4. “PG&E primarily uses meteorological forecast and amount of storage in Round Valley and Philbrook Reservoir to determine the amount and duration of increased flow. This has been shown to result in a pro-active management of water supply. CDFW adds information about abundance, distribution and health of fish and temperatures at Quartz Bowl to help inform/support agency decisions. Collectively we agree to a flow proposal based on all these data. Management of flows in 2021 was different from how the project has been managed since 2014 because of all the challenges experienced. During the 2021 dry water year, both the Philbrook Reservoir and Round Valley Reservoir had not filled. This scenario had only been observed before during the 2015 water year. Limited water supply, plus above normal ambient air temperatures, coupled with potentially the largest population of SRCS observed since surveys have been performed, made 2021 a very challenging year for the run. Due to the limited water storage, the outflow from Philbrook Reservoir deviated from the stepwise method of releases. This deviation was driven by limited water resources, observed disease, and limited access to Philbrook Reservoir during local wildfires.” 2022 Operations and Maintenance Plan Comment Matrix 2 2 Background; section d; Page 3 CDFW- McReynolds The Resource Group has concluded that this release pattern is beneficial since it utilizes most of the stored Philbrook water during late June through late July when air and Butte Creek water temperatures are at their highest during the holding period. On a year-by-year basis, these actual operations are tuned by considering meteorological data, reservoir storage volumes, fish health data (provided by CDFW) and actual in-river temperatures in the pools where salmon are holding (provided by CDFW). Changes not accepted. Refer to response to comment 1. 3 Background; section g; Page 5 CDFW- McReynolds Progress on the negotiations has been adversely affected by the Camp Fire, PG&E’s bankruptcy process, interconnections requirements, and settlement on various terms and conditions. The expectation to execute a Purchase Agreement has been deferred to Quarter 2 2021. CDFW Comment: This needs to at least be updated to say where this stands in Q2 of 2022. O&M Plan will be updated to include the following statement: PG&E submitted the Quarterly Status Report on the progress made in negotiating the sale and transfer of the project on August 16, 2022. This report detailed that PG&Es plans to keep the Desabla Centerville project; PG&E is requesting FERC to move forward with any actions necessary to continue the FERC Licensing process for the Project. 4 Reservoir Operations for 2022; introduction; Page 5 CDFW- McReynolds Installation of flashboards begins once the water elevation reaches that of the radial gate spillway which is 5ft below the bottom of the flashboards and are planned for the week of April 25th, 2022. Flashboards are typically completely installed by June. The required normal water year minimum instream flows are being met. CDFW Comment: Can we update this? O&M Plan will be updated to include the following statement: Flashboards installed on April 4, 2022 2022 Operations and Maintenance Plan Comment Matrix 3 5 Reservoir Operations for 2022; section 1; Page 5 CDFW- McReynolds Capacity is dependent upon water year type. Because of the 2022 water type, Round Valley Reservoir is at full capacity 1168-acre foot on April 27, 2022. CDFW Comment: Can we update this? O&M Plan will be updated to include the following statement: Capacity is dependent upon water year type. Because of the 2022 water type, Round Valley Reservoir was at full capacity, of 1168-acre foot on April 27, 2022. Round Valley Reservoir Draft was completed on July 25th. 6 Reservoir Operations for 2022; section 4; Page 6 CDFW- McReynolds Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre-spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. Both of CDFW’s fish health observations and actual water temperatures measured in the holding pools are used to determine the relative importance of deciding when to release additional water from the upper reservoirs. The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing meteorology predictions and storage availability); flows are expected to be returned to the minimum release about mid-September. CDFW: Observed fish health and water temperatures measured in holding pools has been essential in determining when/if additional water releases were made in recent dry years. Comment noted. Refer to response to comment 1. 7 Reservoir Operations for 2022; section 7; Page 6 CDFW- McReynolds DWR gage BW12 (available on CDEC) will be used as the indicator of water temperatures in the Project waters that are diverted from the West Branch Feather River. CDFW: BW12 on cdec is flow only. It is not used as an indicator of water temperature from the West Branch. There is no real time monitoring of West Branch water temperatures. CDFW's Changes not accepted: BW12 provides temperature data on an hourly basis; the comment is inaccurate. 2022 Operations and Maintenance Plan Comment Matrix 4 Quartz Bowl Pool thermograph is used for real time water temperature information. 8 Scheduled and Emergency Maintenance and Operations; section 1; Page 8 CDFW- McReynolds Maintenance Outage Scheduling – To minimize the disruption of flows in Butte Creek during times that are sensitive to CV spring-run Chinook salmon holding in Butte Creek, PG&E plans to take scheduled canal outages as early as possible in the year. Exhibit D is a schedule of planned maintenance and outages on the Project canals. CDFW: CDFW is supportive of having a winter consult to discuss water levels and the timing of the current years migrating salmon population size and timing would be helpful to get the canal maintenance scheduled as early as possible. Comment noted: PG&E files a planned outage schedule for all PG&E managed projects 60 days prior to the first outage of the year with FERC, this report is made available publicly. 9 Exhibit D; 2022 Scheduled maintenance and outages; Hendricks Canal; Page 15 CDFW- Seapy Exhibit D; 2022 Scheduled Maintenance and Outages; CDFW: Can this be updated to when the canal flow will actually be restored? Comment Noted PG&E is required to provide FERC the annual outage schedule 60 days before the first outage. These dates reflect what PG&E provided to FERC. 10 Background; section A; Page 2 NMFS- Bosworth May to mid-July when there is capacity in the Hendricks canal and, depending upon the amount released, continues for a period of about 2 to 3 weeks. NMFS“I don’t think I’ve ever seen this water last more than 2 to 3 weeks, def not months…?.” Suggest changing one to two months to 2 to 3 weeks. Changes not accepted: PG&E has provided an estimated timeline based on historical information, changes not accepted. 11 Background; section B; Page NMFS- Bosworth Pursuant to FERC’s August 21, 1998 Order, this O&M Plan is annually updated and modified as Comment Noted: PG&E has provided a comment response 2022 Operations and Maintenance Plan Comment Matrix 5 2 appropriate in consultation with the Resources Agencies. Out of curiosity, the resource agencies have made numerous recommended changes to this plan previously, but I don’t usually see the comments incorporated… are they actually incorporated? See comments below regarding some previous things that have been recommended in the past 1-2 years just in the time I have been a part of the team, but I have not seen incorporated into the final plan or the new years plans. table and has included rationale for decision on whether to adopt recommendations and address comments. Refer to response to comment 1. 12 Background section D, Page 3 NMFS- Bosworths and McBride Maximum release is held for a short period and is based on the amount of water available for the remainder of the holding period. It is then decreased in a stepwise fashion with timing and quantity of decrease dependent on a balance between heat events, remaining storage availability and the knowledge that as mid-August approaches we expect decreased average daily temperatures. The Resource Group has concluded that this release pattern is beneficial since it utilizes most of the stored Philbrook water during late June through late July when air and Butte Creek water temperatures are at their highest during the holding period. “This has proven to be a more effective use of water, but there needs to be more emphasis here in regards to the importance of the monitoring data, both the snorkel surveys and instream temperature monitoring within the holding reaches, as both of those are heavily weighed in the decision to hold/increase flow levels. If fish health is looking to be declining or increased instream temps are noticed, often we will choose to increase flows regardless of predicted Comment noted: Refer to response to comment 1. 2022 Operations and Maintenance Plan Comment Matrix 6 heatstorms. It is a combination of all of these things that is used to manage operational decisions. This has been commented on several years now, but has yet to be added into the O&M Plan. Please incorporate this” Ellen Roots McBride – “Agreed. Both aspects of the monitoring data are critical elements here to keeping the fish alive and must continue to be shared weekly with the DeSabla-Centerville group.” 13 Reservoir Operations for 2022; introduction; page 5 Ally Bosworth, NMFS Installation of flashboards begins once the water elevation reaches that of the radial gate spillway which is 5ft below the bottom of the flashboards and are planned for the week of April 25th, 2022. NMFS- What date were these installed this year? I have in emails that the gates were closed on 3/17/22, but no updated date on the flashboard installation Adopted – update made. 14 Reservoir Operations for 2022; section 4 Ally Bosworth, NMFS The “stepwise” release pattern from Philbrook Reservoir used during the 2014 - 2020 holding periods will be used in 2021. The Resource Group will determine the initial outflow from Philbrook Reservoir. The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (often 5 to 10 cfs each) based on predicted heat events and other biologically relevant information provided during the weekly phone calls. Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre-spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. If no heat event is predicted flows will be held steady until the next heat event is forecasted or next increase in outflow is scheduled. In this way, outflow will increase until the end of July. The Resource Comment noted. Refer to response to comment 1. 2022 Operations and Maintenance Plan Comment Matrix 7 Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing weather forecasts and biological data); flows are expected to be returned to the minimum release about mid- September. USFWS & NMFS: Monitoring data continues to be used to inform ongoing Project operations. CDFW collects pre- spawn mortality data and water temperature data on a weekly basis and that data is shared weekly with the Resource Group. In 2018, 2019, and 2021 the Resource Group has used information collected by CDFW regarding observed fish condition, pre-spawn mortality, and water temperatures at Quartz Bowl to assist with stepping up and stepping down releases from Philbrook sooner or more steeply than the general plan of step-wise release pattern set forth at the beginning of the season or due solely to heat storm events. Therefore, this information is being used to inform proactive decisions regarding flow increases and decreases by the Resource Group. As a specific example: in August 2019, CDFW observations regarding fish stress, fish condition, and temperatures at Quartz Bowl, made earlier in the week, were used in conjunction with meteorology predictions during Resource Group discussions about whether or not to start implementing the step-wise reduction. Additionally, monitoring data being collected by CDFW is necessary to determine if the Reservoir Operations Plan was effective after the holding season has completed. 2022 Operations and Maintenance Plan Comment Matrix 8 This was a comment (and associated recommended changes to this paragraph) made by USFWS in 2021. I want to re-iterate the importance of how the real time biological data is also used in these decisions, and needs to be reflected in this plan. 15 Background; section d; page 3 Since 2014, an increase from minimum instream flow begins when room is available in the Hendricks canal and increases in a stepwise manner (i.e., by 5 to 10 cfs based on predicted heat events and observed fish health (currently provided by CDFW)). If no heat event is predicted, flows remain steady in the canal, and fish appear in good health, releases are held steady until the next heat event is forecasted. Changes not accepted. Please see response to comment 1. 16 Background; section d; page 3 USFWS- Milsap Monitoring data, currently being collected by CDFW, has also been used by the Resource Group to adjust these stepwise flow changes. USFWS agrees that heat events are the driving factor for how flows are stepped up and down during the holding season. However, salmonid monitoring data and temps at Quartz Bowl are used to make small adjustments to the pattern. This sentence is an attempt to incorporate that fact. Comment noted: Refer to response to comment 1. 17 Background; section g; page 5 USFWS- Milsap The expectation to execute a Purchase Agreement has been deferred to Quarter 2 2021. USFWS: PG&E filed a quarterly update on 6/1/22… recommend updating this sentence to be consistent with that update. O&M Plan will be updated to include the following statement: PG&E submitted the Quarterly Status Report on the progress made in negotiating the sale and transfer of the project on August 16, 2022. This report detailed that PG&Es plans to keep the Desabla Centerville project; PG&E is requesting FERC to move forward with any actions necessary to continue the FERC Licensing process for the Project. USFWS- Milsap 2022 Operations and Maintenance Plan Comment Matrix 9 18 Reservoir Operations for 2022; section 4; page 6 USFWS- Milsap The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (often 5 to 10 cfs each) based on predicted heat events and other biologically relevant information provided during the weekly phone calls. Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre-spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. If no heat event is predicted flows will be held steady until the next heat event is forecasted or next increase in outflow is scheduled. In this way, outflow will increase until the end of July. The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing weather forecasts and biological data); flows are expected to be returned to the minimum release about mid-September. USFWS: Monitoring data continues to be used to inform ongoing Project operations. CDFW collects pre-spawn mortality data and water temperature data on a weekly basis and that data is shared weekly with the Resource Group. In 2018, 2019, and 2021 the Resource Group has used information collected by CDFW regarding observed fish condition, pre-spawn mortality, and water temperatures at Quartz Bowl to assist with stepping up and stepping down releases from Philbrook sooner or more steeply than the general plan of step-wise release pattern set forth at the beginning of the season or due solely to heat storm events. Therefore, this information is being used to inform proactive decisions regarding flow Comment noted: See response to comment 1 2022 Operations and Maintenance Plan Comment Matrix 10 increases and decreases by the Resource Group. As a specific example: in August 2019, CDFW observations regarding fish stress, fish condition, and temperatures at Quartz Bowl, made earlier in the week, were used in conjunction with meteorology predictions during Resource Group discussions about whether or not to start implementing the step-wise reduction. Additionally, monitoring data being collected by CDFW is necessary to determine if the Reservoir Operations Plan was effective after the holding season has completed. USFWS Comment 2 This was a comment (and associated recommended changes to this paragraph) made by USFWS in 2021. I want to re-iterate the importance of how the real time biological data is also used in these decisions, and needs to be reflected in this plan. 19 Reservoir Operations for 2022; section 5; page 6 Water temperature monitoring by PG&E and CDFW will continue in 2022 at six stations (Exhibit E), five of which have been used prior to relicensing (since 1998). Installation of recorders occurs in June or as soon thereafter when safe access to the stream channels is possible. Data will be reported out to the resource agency during the 2023 Annual Operations Meeting. CDFW monitors temperature at 2 locations within the holding habitat for CV spring-run Chinook salmon. Edits not accepted. This plan documents the work that PG&E is committed to do, not CDFW. USFWS- Milsap 2022 Operations and Maintenance Plan Comment Matrix 11 20 Reservoir Operations for 2022; introduction; page 5 USFWS- Milsap Installation of flashboards begins once the water elevation reaches that of the radial gate spillway which is 5ft below the bottom of the flashboards and are planned for the week of April 25th, 2022. USFWS: Recommend updating O&M Plan will be updated to include the following statement: Flashboards installed on April 4, 2022 21 Reservoir Operations for 2022; Section 4; page 6 USFWS- Milsap The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (approximately 5 to 10 cfs each) based on predicted heat events and other information shared with the Resource Group. USFWS: As mentioned previously, while we rely predominantly on predicted heat events to determine flow increases, the Resource Group has also used monitoring data currently being conducted by CDFW to inform stepwise increases in outflow. Here are two specific examples from 2021: On 6/23 PG&E started releases from Philbrook, here’s the email from Catalina on 6/23: “I got an early morning email from Britt that Round Valley did not last as long as we thought and the flow in creeks is starting to drop. He recommends that we start drafting 10 cfs from Philbrook to make up for the flow we lost from Round Valley. This will also prepare the fish for the upcoming heat storm.” On 6/24 we met as a group and the outcome was to increase flows by another 5 cfs, such that total outflows from Philbrook were 15cfs. According to my notes, this increase wasn’t scheduled for another week. However, Resource Agency staff advocated for increasing flows earlier because temperatures at Quartz Bowl were already getting to threshold temperatures and fish were holding in Comment noted: Refer to response to comment 1. 2022 Operations and Maintenance Plan Comment Matrix 12 riffles (which is a sign of stress). An additional example from 2021 occurred on 7/29 when Resource Agency staff advocated for increasing flow to help flush out pathogens (information gathered during pre-spawn mortality surveys), but we ultimately waited to make that increase until 8/2 when the Dixie Fire was no longer an imminent threat to PG&E access. If not for uncertainties with the Dixie fire, we would have increased flows after the 7/29 meeting and that would’ve been solely based on field collected monitoring data. 22 Reservoir Operations for 2022; Section 4; page 6 USFWS- Milsap The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (utilizing all information shared during the weekly phone calls); flows are expected to be returned to the minimum release about mid-September. FWS continues to recommend that PG&E acknowledge that decisions regarding flow increases and decreases are also informed by data currently being collected by CDFW. The original parenthetical suggests that only meteorological data and reservoir storage are used to make decisions regarding how to shape the stepwise reduction. FWS deleted: again utilizing meteorology predictions and storage availability Comment noted: Refer to response to comment 1. 2022 Operations and Maintenance Plan Comment Matrix 13 23 Reservoir Operations for 2022; Section 5 (now deleted); page 7 USFWS- Milsap Comment: Planning on applying for 2022 variance, leave as placeholder FWS: Given that PG&E is considering a flow variance, but one hasn’t yet been provided for Agency review, I recommend using different placeholder language, such as: PG&E is in the process of identifying if a variance request for 2022 might be warranted and will coordinate with the Resource Group as the year progresses. Comment Noted: On July 9, 2022, the Resource Group Met and discussed the potential variance and determined that a variance was not needed due to the excess water impounded in Philbrook Reservoir by the early gate closure. PG&E will not be applying for a variance and will be removing this statement. 24 Reservoir Operations for 2022; section 6; page 7 USFWS- Milsap DWR gage BW12 (available on CDEC) will be used as the indicator of water temperatures in the Project waters that are diverted from the West Branch Feather River. FWS: Based on my experience, we don’t receive real-time water temperature data from this gage. Our discussions have been focused on water temperatures at the Quartz Bowl holding pool which is collected by CDFW and shared during Resource Group calls. Comment Noted: BW12 provides temperature data on an hourly basis, the comment is inaccurate. 25 Scheduled and Emergency Maintenance and Operations; Exhibit D; page 15 USFWS- Milsap Maintenance Outage Scheduling – To minimize the disruption of flows in Butte Creek during times that are sensitive to CV spring-run Chinook salmon holding in Butte Creek, PG&E plans to take scheduled canal outages as early as possible in the year. Exhibit D is a schedule of planned maintenance and outages on the Project canals. FWS: We had a great discussion during our meeting about some of the constraints are that drive when canal outages can be taken. I recommend including some of that information within this section. Comment Noted: The objective of this report is to discuss operations and the impacts during the holding period of the spring-run Chinook salmon in the reaches of Butte Creek below the DeSabla Powerhouse. Elaborating on outage constraints is outside the scope of this report. ENCLOSURE 3 DeSabla-Centerville Project (FERC No. 803) DRAFT 2022 Operations and Maintenance Plan Pacific Gas and Electric Company The objective of the Operations and Maintenance Plan (O&M Plan) is to focus on how to best provide water temperatures that are as cold as possible to support holding, spawning, and rearing of Central Valley (CV) spring-run Chinook salmon in the reaches of Butte Creek below the DeSabla Powerhouse during 2022. It also documents Pacific Gas and Electric Company’s (PG&E) scheduled outages that allow for maintenance activities of the DeSabla-Centerville Project (Project). This O&M Plan outlines the procedures and practices PG&E will strive to follow in the operation of the Project to enhance and protect this habita t for CV spring-run Chinook salmon. This O&M Plan is also intended to provide the basis for modification of the reservoir temperature release criteria established in the Federal Energy Regulatory Commission (FERC) “Order Approving Water Temperature Study Report” issued August 21, 1997, as amended by FERC’s “Order Amending Temperature Requirements” issued August 20, 1998. A. Introduction 1) The DeSabla – Centerville Project includes the following features which are depicted in Exhibit A: Reservoirs and Forebays: Round Valley Reservoir (also called Snag Lake), Philbrook Reservoir, and DeSabla Forebay Canals and related features: Butte, Hendricks, Toadtown, Upper Centerville, and Lower Centerville canals and associated diversion dams, feeders, and spillway channels Powerhouses: Toadtown, DeSabla, and Centerville 2) Project Benefits to Butte Creek Habitat: a) Water diverted from the West Branch Feather River at the Hendricks Diversion Dam (including releases from Philbrook and Round Valley Reservoirs) increases the total flow available in Butte Creek below DeSabla Powerhouse by approximately 40% in July and August (depending on water availability in Butte Creek). b) Water imported from the West Branch Feather River provides additional water to cool water temperatures in reaches of Butte Creek used by CV spring-run Chinook salmon for over-summering by providing releases from Philbrook Reservoir when storage is available. The increased flow from the West Branch Feather River also helps minimize heating by reducing the residence time in the DeSabla forebay. The shorter travel time of water in canals also helps to minimize heating. Formatted: Normal, Space After: 0 pt California Fish and Wildlife Service Comments 2 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company 3) Background: The Project storage reservoirs (Round Valley and Philbrook Reservoirs) are in the West Branch Feather River watershed. Project diversions are made from this drainage at the Hendricks Canal Diversion Dam. Due to the larger storage capacity and depth of Philbrook Reservoir (5,000 acre-feet) relative to Round Valley Reservoir (1,200 acre-feet), the water temperature tends to stay cooler for a longer period in Philbrook Reservoir. Accordingly, since 1998 PG&E has released water from Round Valley Reservoir first, to effectively manage the temperature of water released into Butte Creek. In more recent years, increases in flow at Round Valley (above minimum instream flow requirements) have been made later to reserve water in Philbrook Reservoir so that it is available during the hottest time of the holding period. Due to the input of very cool water from springs near Co on Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in the summer (June –August) have not increased water temperatures at Hendricks Diversion Dam. PG&E notifies the Resource Agencies when water releases commence from Round Valley Reservoir. a. Releases from Round Valley Reservoir begin between early May to mid-July when there is capacity in the Hendricks canal and, depending upon the amount released, continues for a period of about one to two months. Philbrook releases are typically delayed until releases from Round Valley begin to diminish or heat storm events occur. In 2016-2018 water from Round Valley Reservoir has been used to augment flow releases from Philbrook Reservoir. The release valves from these reservoirs must be operated manually and the travel time of the water released from these reservoirs to the Lower Centerville Diversion Dam (LCDD) is approximately 21 to 29 hours. Travel time of operator to the valve locations is approximately 1½ hours during workdays and may be up to 4 hours on weekends. b. On August 21, 1997, the FERC issued an Order placing temperature restrictions (17ºC at Round Valley and 18ºC at Philbrook) on the releases from these dams. On August 20, 1998, and 2020-2021, the FERC revised its Order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), the California Department of Fish and Wildlife (CDFW), and the United States Fish and Wildlife Service (USFWS); PG&E has also included the State Water Resource Control Board (SWRCB), and United States Forest Service (USFS) in this consultation process. These five agencies are referred to as the Resource Agencies in this Plan. Since 1999, this agreement has been accomplished by way of an annual O&M Plan. Reservoir operation has been based on expected water year conditions. Pursuant to FERC’s August 21, 1998 Order, this O&M Plan is annually updated and modified as appropriate in consultation with the Resources Agencies. This consultation group, composed of PG&E and the Resource Agencies, is called the Resource Group in the remainder of this Plan. Starting in 2016 a schedule of maintenance outages of the DeSabla-Centerville Canals was included in this O&M Plan. California Fish and Wildlife Service Comments 3 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company c. The Resource Group has learned that there is a benefit from providing an increase in flow to Butte Creek during the hottest part of the holding period. Storage in Philbrook Reservoir is used to supplement flows in Butte Creek during the holding period. Monitoring data shows that cooler water released from the bottom of Philbrook Reservoir (i.e., the cold-water pool) increases in temperature while traveling through the system and reaches thermal equilibrium at Hendricks Diversion Dam. The Resource Group has agreed that it is a combination of total flow (decreased travel time, increased mass of water subject to heating) and cold-water releases that help reduce water temperatures in Butte Creek. Generally, the cool- water pool in Philbrook is depleted in late July to early August and release temperatures increase through August (e.g. maximum daily average release temperature of 20.3 ºC occurred on August 17, 2018); however, monitoring data show that after the beginning of August the thermal regime in the basin is such that releases with higher temperatures actually cool as the water travels to Hendricks Diversion Dam (sun declination is lower, canyon walls shade the stream, and cool evenings predominate). d. Initially, when management of Philbrook flows began in 1998, outflow from the reservoir was increased in response to forecasted heat events and then returned to pre- heat levels to save water. This resulted in a large amount of residual water storage at the end of the holding period, which was then released in September to make room in the reservoir for upcoming winter storms (Exhibit B). The Resource Group has moved away from short-term responses to heat events to releasing outflow from Philbrook in a stepwise fashion; this approach maximizes the use of storage during the holding period and minimizes the amount of residual storage at the end of the holding period. Although the Resource Group had been moving towards this approach in previous years, 2014 was the first year in which this pattern of management was fully employed (Exhibit B). Since 2014, an increase from minimum instream flow begins when room is available in the Hendricks canal and increases in a stepwise manner (i.e., by 5 to 10 cfs based on predicted heat events and fish health (provided by CDFW) ). If no heat event is predicted,flows remain steady in the canal, and fish appear in good health, releases are held steady until the next heat event is forecasted. In this way, releases are increased so maximum flow is reached during the hottest period of the summer (mid-July to early August). Maximum release is held for a short period and is based on the amount of water available for the remainder of the holding period. It is then decreased in a stepwise fashion with timing and quantity of decrease dependent on a balance between heat events, remaining storage availability and the knowledge that as mid-August approaches we expect decreased average daily temperatures. The Resource Group has concluded that this release pattern is beneficial since it utilizes most of the stored Philbrook water during late June through late July when air and Butte Creek water temperatures are at their highest during the holding period. On a year-by-year basis, these actual operations are tuned by considering meteorological data, reservoir storage volumes, fish health data Deleted: and Deleted: now California Fish and Wildlife Service Comments 4 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company (provided by CDFW) and actual in-river temperatures in the pools where salmon are holding (provided by CDFW). e. During relicensing studies, water temperature modeling provided evidence that the use of the Lower Centerville Canal (LCC) benefited CV spring-run Chinook salmon holding downstream of the Centerville powerhouse (CVPH) by decreasing temperatures in these lower reaches (PG&E 2007). Modeling showed that the temperature benefit increases with the volume of flow provided through the canal, which is much higher when the CVPH is in operation. Due to its observed and modeled impact on water temperatures and distribution of CV spring-run Chinook salmon during the holding period, the operation of the LCC was included in previous O&M Plans but has been removed since it was taken out of service. f. The CVPH went offline in February 2011; from 2011-2013, the diversion of flow into the canal during the holding period continued at the request of the Resource Group. In 2013, diversions were decreased into the LCC after consultation with the Resource Agencies due to the unusually high numbers of CV spring-run Chinook salmon holding above CVPH. The water temperature data showed that the temperature benefit of using the LCC decreased as diverted flows into the LCC decreased. The decrease of flow diverted into the LCC was due to the limited availability of water that resulted from a dry water year. After the experience of 2013, in 2014 and 2015 the Resource Group made a consensus decision to not operate the LCC during the holding period because of the dry water year type. The Resource Group concluded that, likely, there would be insufficient water available to divert enough flow into the LCC to provide a cold-water benefit to any fish holding downstream of the Centerville Powerhouse. The Resource Group made a mutual decision not to run the LCC during the 2016 holding period of CV spring-run Chinook salmon, although it was a normal water year. On February 25, 2016, a conference call occurred between representatives of the Resource Group. PG&E sought Resource Agency guidance on whet her to operate the LCC during the 2016 holding period. PG&E described the challenges of restoring the LCC to service after a 2.5-year period (2 summer holding periods) of non- operation, including turbidity risk and the resulting potential for negative pub lic perception. PG&E reminded the Resource Agencies that as the CVPH is inoperable, the LCC is only used to benefit the CV spring-run Chinook salmon. The Resource Agencies requested time before offering guidance to PG&E. On March 8, 2016, another conference call was held. PG&E provided additional information showing that because of the limited capacity of the CVPH’s Bypass/Spillway, the use of the LCC without the CVPH decreases the temperature benefit to fish holding in the downstream reaches. There was concurrence among the Resource Group on the call that PG&E would not be requested to put the LCC into service. The Resource Group agreed that availability of the LCC in future years requires more discussion and may depend on the outcome of the FERC License conditions. California Fish and Wildlife Service Comments 5 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company In 2017-2021 PG&E did not utilize the LCC to benefit water temperature for fish holding in the downstream reaches of CVPH. g. On February 16, 2017, PG&E submitted a notice of the withdrawal of its application for a new license for the project. On March 2, 2017, Commission staff issued an order disallowing the withdrawal and soliciting statements of interest regarding acquisition of the project license. In June 2018, PG&E selected a prospective buyer for the Project. Progress on the negotiations has been adversely affected by the Camp Fire, PG&E’s bankruptcy process, interconnections requirements, and settlement on various terms and conditions. The expectation to execute a Purchase Agreement has been deferred to Quarter 2 2021. B. Forecast for 2022 Water Year Type and Reservoir Operations The 2022 Water Year Type is currently forecasted to be “normal” per the definition of the license. The Department of Water Resources (DWR) forecast as of May 1, 2022, indicates that the Feather River Basin April-July runoff into Oroville is expected to be 51% of average. Exhibit C lists historical runoff forecasts and water year types since 1998. Reservoir Operations for 2022 Due to the water year type, the reservoirs will be operated under normal conditions. The Round Valley low level outlet (LLO) was fully closed on April 1, 2022. The Philbrook LLO is scheduled to provide MIF (3 cfs) until mitigations are started.. PG&E successfully obtained an early gate closure from DSOD and the radial gate was closed on March 17, 2022. Installation of flashboards begins once the water elevation reaches that of the radial gate spillway which is 5ft below the bottom of the flashboards and are planned for the week of April 25th, 2022. Flashboards are typically completely installed by June. The required normal water year minimum instream flows are being met. Reservoir operation for the holding period is as follows: 1) Releases from Round Valley Reservoir begin when there is capacity in the Hendricks Canal. Capacity is dependent upon water year type. Because of the 2022 water type, Round Valley Reservoir is at full capacity 1168-acre foot as of April 27, 2022. It is expected that releases will begin in early summer from June to mid-July. Again, due to the input of very cool water from springs near Coon Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in early summer (June – early July) have been shown to not increase water temperatures at Hendricks Diversion Dam. PG&E will notify the Resource Agencies when water releases commence from Round Valley Reservoir. 2) As Round Valley Reservoir nears its minimum elevation, PG&E will consult with the Resource Agencies to determine when releases from Philbrook Reservoir should be increased to avoid a drop in canal flows when Round Valley Reservoir flow runs out. PG&E will closely monitor the drawdown of Round Valley Reservoi r as the minimum elevation is approached. Commented [PJ1]: Working on update, unknown at this time Commented [LB2R1]: This needs to at least be updated to say where this stands in Q2 of 2022. Commented [LB3]: Can we update this? Commented [MT4]: update California Fish and Wildlife Service Comments 6 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company 3) The Resource Group will determine the initial release level from Philbrook Reservoir. Factors considered in establishing the actual rate of release include the date upon which releases commence the objective of reserving relatively cool water for a possible extreme heat event, the level of natural flows, and the objective of maintaining the highest possible flows through the DeSabla Forebay. 4) The “stepwise” release pattern from Philbrook Reservoir (as described above) used during the 2014 - 2021 holding periods will be used in 2022. The Resource Group will determine the initial outflow from Philbrook Reservoir. The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (approximately 5 to 10 cfs each) based on predicted heat events. Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre-spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. Both of CDFW’s fish health observations and actual water temperatures measured in the holding pools are used to determine the relative importance of deciding when to release additional water from the upper reservoirs. The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing meteorology predictions and storage availability); flows are expected to be returned to the minimum release about mid- September. A flow through the forebay of 60 cfs is targeted to reduce residence time and minimize heating of water as it moves through the forebay. The 60 cfs target flow through the DeSabla Forebay will be reviewed during the summer on the weekly calls described above to determine if this rate should be adjusted based on the available releases from Philbrook Reservoir. 5) PG&E submitted a minimum instream flow variance on May 26, 2021, FERC provided temporary approval on June 25, 2021; final approval was granted on August 3, 2021, this variance expires on February 28, 2022. This variance allowed for the reduction of flows at Philbrook Creek from 2.0 cfs (with a 0.5 cfs flow buffer) from Philbrook Reservoir to 0.8 cfs (with a 0.2 cfs flow buffer) to ensure the availability of cold-water storage for CV spring-run Chinook salmon during the current drought conditions. The variance also allowed for an average MIF (over 48 hours) rather than an instantaneous MIF at both Butte Creek and Hendricks Head Dams. PG&E’s normal practice is to provide a buffer-flow of 4 – 5 cfs in addition to the MIF requirements; with the variance PG&E was able to release closer to the MIF. 6) Water temperature monitoring by PG&E will continue in 2022 at six stations (Exhibit E), five of which have been used prior to relicensing (since 1998). Installation of recorders occurs in June or as soon thereafter when safe access to the stream channels is possible. Data will be reported out to the resource agency during the 202 3 Annual Operations Meeting. 7) DWR gage BW12 (available on CDEC) will be used as the indicator of water temperatures in the Project waters that are diverted from the West Branch Feather River. C. Lower Centerville Canal Operations for 2022 Commented [LB5]: Observed fish health and water temperatures measured in holding pools has been essential in determining when/if additional water releases were made in recent dry years. Commented [RC6]: Planning on applying for 2022 variance, leave as placeholder Commented [MT7]: BW12 on cdec is flow only. It is not used as an indicator of water temperature from the West Branch. There is no real time monitoring of West Branch water temperatures. CDFW's Quartz Bowl Pool thermograph is used for real time water temperature information. Deleted: 2023 California Fish and Wildlife Service Comments 7 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company As discussed previously (section A), due to turbidity concerns with returning the LCC to service, PG&E will not resume operation of the LCC in 2022. In addition, the project is currently up for sale and so PG&E is not considering returning the canal to service since the fate of the powerhouse is unknown. D. Contingency for Extreme Heat Event During the Holding Period In anticipation of a possible high ambient air temperature event, the following actions will be taken: 1. Ambient air temperature conditions are a major factor in determining actual water temperatures in Butte Creek. Starting on June 1 or at such time as the Resource Group determines, PG&E will prepare a weather forecast for the Project area by noon each Monday and Thursday. The weather forecast will be based on information from USFS weather stations at Cohasset and Chester. PG&E will provide an e -mail copy of the forecast to the Resource Agencies. If air temperatures in excess of 105ºF for two or more days during the next seven-day period are forecasted at Cohasset, with the potential for compression heating at higher elevations as confirmed by data from the Chester location, PG&E will send an e-mail to each Resource Agency representative identified in paragraph 5 below advising them that an extreme heat event is forecasted. If the next forecast confirms that an extreme heat event has started or is imminent within the next two days, and is expected to continue for over two days, PG&E will send a second e - mail, phone, or fax to one of the individuals at each Resource Agency identified in paragraph 5 to discuss actions to be taken. If personal contact cannot be made and PG&E still believes action needs to be taken, it will initiate efforts to modify Project operation as discussed in paragraphs 2 – 5, below. If action is taken, PG&E will send a third email or phone the Resource Agencies and explain the actions taken. 2. PG&E will coordinate weekly conference calls with the Resource Agencies during the CV spring-run Chinook salmon’s holding period. Increased call frequencies will be conducted as requested and agreed upon by the Resource Group. These conference calls are usually conducted from early June through mid-September (as needed). During these conference calls the Resource Group will discuss the results of pre-spawning mortality surveys (if provided by CDFW or NMFS), meteorological forecasts, water temperatures recorded by CDFW at Quartz Bowl Pool, flows and storage in Philbrook Reservoir. 3. The actual amount of water released from Philbrook Reservoir during a confirmed extreme heat event will depend on PG&E’s assessment of then-existing conditions and recommendations and comments received from the Resource Agencies in response to the e- mails. The individuals to whom PG&E will send e-mails under this section are: • Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, (530) 333-7746 • Grantton Henley (CDFW)- Grantton.Henley@wildlife.ca.gov, (916) 272-4152 • Anna Allison (CDFW) – Anna.allison@wildlife.ca.gov, (916) 272-4373 Deleted: (530) 333-7748 California Fish and Wildlife Service Comments 8 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company • Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, (916) 358-2875 • Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov, (916) 930-3722 • Allison Lane (NOAA Fisheries) Allison.lane@noaa.gov, (916) 930-5617 • Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, (707) 575-6052 • Tristan Leong (USFS)– tleong@fs.fed.us, (530) 226-2308 • Jeff Wetzel (SWRCB) – Jeff.wetzel@waterboards.ca.gov, (916) 323-9390 • Daniel Welsh (USFWS) – Daniel_weslsh@fws.gov, (916) 930-5639 • Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov, (916) 930-2658 E. Spawning Flows in Butte Creek As in previous years, it is best to taper summer temperature-management flows from the WBFR watershed come fall so that redds are not at risk of being dewatered if an emergency outage occurs on the Hendricks or Butte canals. In the past, flows from the West Branch Feather River were decreased around mid-September when mean daily temperature decreases naturally and the use of the canals has less of an effect on keeping water temperatures cool. Essentially this sets flows at a level that can be sustained through February 28, 2023, or other appropriate date determined by the Resource Group. F. Scheduled and Emergency Maintenance and Operations 1) Maintenance Outage Scheduling – To minimize the disruption of flows in Butte Creek during times that are sensitive to CV spring-run Chinook salmon holding in Butte Creek, PG&E plans to take scheduled canal outages as early as possible in the year. Exhibit D is a schedule of planned maintenance and outages on the Project canals. 2) Unplanned Outages (2022-2023) - Winter storms, disruption in canal flows caused by slides or fallen trees, unexpected electric transmission system outages, Public Safety Power Shutoffs (PSPS) and other hazardous conditions can disrupt normal Project operation. PG&E shall use its best efforts to minimize impacts that may result from these conditions, including the actions outlined below: a) PSPS - As part of our Community Wildfire Safety Program, PG&E is implementing additional precautionary measures to help reduce the risk of wildfires. For public safety, it may be necessary for us to turn off electricity as a last resort when extreme fire danger conditions are forecasted. This is called a "Public Safety Power Shutoff." See section below for more information on impacts and response. b) Unit Separation from Electric Grid - If the electric transmission grid, generating unit, a critical support system experiences a problem, or in the event of a PSPS, the generating units automatically separate from the grid and the flow of water to the units is directed away from the turbine. At the Toadtown and DeSabla powerhouses this is done by means Commented [LB8]: This is no longer the correct SWRCB contact. Deleted: reduce Commented [LB9]: CDFW is supportive of having a winter consult to discuss water levels and the timing of the current years migrating salmon population size and timing would be helpful to get the canal maintenance scheduled as early as possible. California Fish and Wildlife Service Comments 9 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company of a bypass device that directs the flow through an energy dissipater bypass and allows the water to continue moving at approximately the same flow. PG&E will adjust the automatic bypass opening during the summer to reasonably correspond to the operational flow of the powerhouse. The shift from the generating unit to the bypass facility may result in a minor release of turbidity caused by sediment that may have built- up in the bypass system since its last use. During a unit separation or PSPS event, standby portable generators are deployed to supply power to station batteries that power bypass system controls. During a separation from electric grid, PG&E increases patrol of canals as some remote operation of equipment and some remote monitoring will not be available. In preparation for PSPS events, PG&E staffs additional personal to remediate any issues that arise during the duration of the event. c) Winter Operation and Canal Emergencies – Much of the Project’s canal system traverses steep forested lands. During times of high rainfall and/or high winds, slides, rock falls, and fallen trees can damage canals or block flows. To minimize the potential for damage in the event of a blockage or failure of a canal or flume, PG&E may reduce canal flows or dewater canals in advance of such weather events. In addition, emergency spill gates are located at several locations that are equipped with devices that can be operated remotely to spill water at various locations along the canals. PG&E has installed sensors that report canal flow levels to the operator at the Rock Creek Switching Center. This location is staffed 24 hours a day, 7 days a week, 365 days a year. If a sensor detects an unexpected change in the flow, an alarm is sent to alert the operator on duty. The operator will then dispatch personnel to the location to determine if immediate action can or should be taken to remove water from the canal by activating an emergency spill gate. The emergency spill gates are placed at locations where the channel through which the water will travel is generally protected by rocks and boulders. However, turbidity is possible from vegetative or other debris that may have accumulated in the channel since its last use. Spill channels are routinely inspected at the beginning of the winter season and are typically operated once during a winter high flow event to maintain the prescriptive right for the spill channel and keep the release gate clear of material. This operation results in an incremental increase in the turbidity of Butte Creek for a short period of time, which is typically already elevated during high flow events. Operation of the spill channels that may not be well protected and could likely result in turbidity increases, other than the annual winter operation discussed above, will be operated for emergency purposes only. To avoid releasing water into a damaged canal after a storm event, the canal is patrolled on foot prior to restoring flow. G. Water Quality Monitoring 1) PG&E will monitor water temperature at six seasonal stations during 2022. These are in addition to the real-time, permanent CDEC station at BW-12. Temperature monitoring will generally be conducted between June and September. Results will be presented at the following Annual Operations and Management Meeting. Monitoring locations are identified in Exhibit E. California Fish and Wildlife Service Comments 10 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company 2) Prior to the start-up of a canal or powerhouse after an outage, which may result in the possible release of turbidity to Butte Creek, PG&E will monitor water quality using two existing continuous monitoring turbidity sensors located in Butte Creek; one sensor is located at the LCDD, the other sensor is on a wing wall of the CVPH tailrace. 3) In the event of a canal failure, spill gate operation or other release that results in a potential for turbidity to Butte Creek, PG&E will secure water quality samples to the extent practicable and taking into consideration personnel safety. The monitoring will be conducted using either grab samples collected by PG&E and tested for turbidity or use data from the two continuous monitoring turbidity meters (noted above), set to sample every 15 minutes. Sampling locations will generally be immediately upstream of the dam or point of diversion and approximately 300 feet downstream of the point of release or return to surface waters. If the point of release to surface waters is not reasonably accessible by vehicle, PG&E will sample at the nearest downstream location that can be safely and readily accessed. 4) Turbidity data collected during a canal start-up, etc., will be made available to one of the individuals at each of the Resource Agencies identified in Section D, paragraph 5, in a timely fashion. Water temperature data will be provided to Resource Agency representatives upon request. H. Ongoing Consultation 1) On August 21, 1997, the FERC issued an order placing temperature restrictions on releases from PG&E’s storage reservoirs in the upper West Branch Feather River watershed. On August 20, 1998 the FERC revised its order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), California Department of Fish and Wildlife (CDFW) and U.S. Fish and Wildlife Service (USFWS). Since 1999, this agreement has been accomplished by way of an annual operations plan for these reservoirs. The reservoir operation varies based on water year conditions. Pursuant to FERC’s August 21, 1998 order, this Operations Plan is annually updated and modified as appropriate in consultation with the Resource Agencies. The FERC Order requires licensee to notify FERC within 30 days after reaching agreement on the O&M Plan. 2) PG&E will meet at least annually with the interested Resource Agencies to discuss and review this O&M Plan. In addition, PG&E will continue to provide updates (generally by e- mail) on Project operations and events to at least one representative from each of the individual Resource Agencies identified in Section D, paragraph 5. A summary report will be prepared on annual operations and monitoring data, which will include water and air temperatures, reservoir and conveyance operations and actions taken to minimize effects on the CV spring-run Chinook salmon. 3) Nothing in this O&M Plan will be construed as modifying any of the terms and conditions of the DeSabla-Centerville license, FERC No. 803, or in any manner limit the jurisdiction of the FERC. In the event of any conflict between any of the provisions of this O&M Plan and the license, the provisions of the license will control. 4) PG&E will work with the Resource Agencies, and others, as appropriate, to seek ways to California Fish and Wildlife Service Comments 11 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company promote prudent land management practices by others where such practices may directly or indirectly impact safe, reliable canal operations. Nothing in this O&M Plan will be construed as either PG&E or the Resource Agencies accepting responsibility for conditions or damage that may be the result of the actions, or inactions, of others. 5) PG&E management does not anticipate the sale and transfer of the Project in 2022 and plans on continued participation with the DeSabla Centerville Operations through the end of the year. I. References PG&E. 2007. DeSabla-Centerville Hydroelectric Project. FERC Project No. 803. License Application. Appendix E6.2.2.3-G Calibration and Scenarios Report. 14 pp. PG&E. 2015. Final Project Operations Plan – 2015. Pacific Gas and Electric Company DeSabla- Centerville Project (FERC No. 803). June 18, 2015 EXHIBIT A Commented [PJ10]: Unknown at this time California Fish and Wildlife Service Comments 12 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Map of Project area. California Fish and Wildlife Service Comments 13 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company EXIBIT B Comparison of Philbrook Reservoir Storage Usage California Fish and Wildlife Service Comments 14 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company EXHIBIT C HISTORICAL RUNOFF FORECAST AND WATER YEAR TYPE SINCE 1998 Water Year Runoff Forecast Water Year Type 1998 149% Normal 1999 115% Normal 2000 99% Normal 2001 46% Dry 2002 70% Normal 2003 97% Normal 2004 70% Normal 2005 93% Normal 2006 180% Normal 2007 38% Dry 2008 66% Normal 2009 64% Normal 2010 106% Normal 2011 171% Normal 2012 80% Normal 2013 47% Dry 2014 31% Dry 2015 19% Dry 2016 84% Normal 2017 214% Normal 2018 77% Normal 2019 176% Normal 2020 55% Normal 2021 37% Dry 2022 51% Normal Runoff Forecasts are the published May 1 Bulletin 120 forecast of April – July unimpaired runoff into Oroville Reservoir as a percent of the 50 -year average computed by the State of California at that time. Water Year Type is “Dry” if the runoff forecast is 50% or less. California Fish and Wildlife Service Comments 15 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company EXHIBIT D 2022 SCHEUDULED MAINTENANCE AND OUTAGES DESABLA-CENTERVILLE 2022 MAINTENANCE AND OUTAGE SCHEDULE JANUARY -DECEMBER OUTAGE SCHEDULE LOCATION DESCRIPTION OF WORK DURING OUTAGE DEWATERED STRUCTURE Start Date End Date BUTTE CANAL annual maintenance None. Limited flow (5-10cfs) will remain during work. 5/2/2022 5/31/2022 DE SABLA POWERHOUSE annual maintenance and inspections, vegetation management None 5/2/2022 5/31/2022 HENDRICKS CANAL annual maintenance, undermining repairs and liner repairs, erosion control, accessibility repairs. Fish rescue planned for 5/2/2022 to support dewatering Canal 5/2/2022 5/31/2022 LOWER CENTERVILLE CANAL vegetation management completed February 2022 OUT OF SERVICE OUT OF SERVICE OUT OF SERVICE UPPER CENTERVILLE CANAL canal annual and vegetation management None 5/2/2022 5/31/2022 CENTERVILLE POWERHOUSE TBD penstock canal OUT OF SERVICE OUT OF SERVICE TOADTOWN POWERHOUSE annual maintenance None 5/2/2022 5/31/2022 TOADTOWN CANAL minor repairs; annual maintenance various locations 5/2/2022 5/31/2022 Commented [SB11]: Can this be updated to when the canal flow was actually restored? California Fish and Wildlife Service Comments 16 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company EXHIBIT E PG&E SEASONAL MONITORING LOCATIONS – 2022 1. Philbrook Creek at release * (Temperature and Flow) 2. WBFR at Hendricks Head Dam * (Temperature and Flow) 3. Total canal inflow to DeSabla Forebay * (Temperature and Flow) 4. DeSabla Powerhouse tailrace * (Temperature and Flow) 5. Butte Creek at LCDD * (Temperature, Turbidity, and Flow) 6. Butte Creek at Centerville Powerhouse (Temperature and Turbidity) * Original monitoring stations used since 1998 California Fish and Wildlife Service Comments 17 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Proposed 2021 Water Temperature Monitoring Network. California Fish and Wildlife Service Comments Draft DeSabla-Centerville Project (FERC No. 803) DRAFT 2022 Operations and Maintenance Plan Pacific Gas and Electric Company The objective of the Operations and Maintenance Plan (O&M Plan) is to focus on how to best provide water temperatures that are as cold as possible to support holding, spawning, and rearing of Central Valley (CV) spring-run Chinook salmon in the reaches of Butte Creek below the DeSabla Powerhouse during 2022. It also documents Pacific Gas and Electric Company’s (PG&E) scheduled outages that allow for maintenance activities of the DeSabla-Centerville Project (Project). This O&M Plan outlines the procedures an d practices PG&E will strive to follow in the operation of the Project to enhance and protect this habitat for CV spring -run Chinook salmon. This O&M Plan is also intended to provide the basis for modification of the reservoir temperature release criteria established in the Federal Energy Regulatory Commission (FERC) “Order Approving Water Temperature Study Report” issued August 21, 1997, as amended by FERC’s “Order Amending Temperature Requirements” issued August 20, 1998. A. Introduction 1) The DeSabla – Centerville Project includes the following features which are depicted in Exhibit A: Reservoirs and Forebays: Round Valley Reservoir (also called Snag Lake), Philbrook Reservoir, and DeSabla Forebay Canals and related features: Butte, Hendricks, Toadtown, Upper Centerville, and Lower Centerville canals and associated diversion dams, feeders, and spillway channels Powerhouses: Toadtown, DeSabla, and Centerville 2) Project Benefits to Butte Creek Habitat: a) Water diverted from the West Branch Feather River at the Hendricks Diversion Dam (including releases from Philbrook and Round Valley Reservoirs) increases the total flow available in Butte Creek below DeSabla Powerhouse by approximately 40% in July and August (depending on water availability in Butte Creek). b) Water imported from the West Branch Feather River provides additional water to cool water temperatures in reaches of Butte Creek used by CV spring-run Chinook salmon for over-summering by providing releases from Philbrook Reservoir when storage is available. The increased flow from the West Branch Feather River also helps minimize heating by reducing the residence time in the DeSabla forebay. The shorter travel time of water in canals also helps to minimize heating. National Marinae Fisheries Service Comments 2 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft 3) Background: The Project storage reservoirs (Round Valley and Philbrook Reservoirs) are in the West Branch Feather River watershed. Project diversions are made from this drainage at the Hendricks Canal Diversion Dam. Due to the larger storage capacity and depth of Philbrook Reservoir (5,000 acre-feet) relative to Round Valley Reservoir (1,200 acre-feet), the water temperature tends to stay cooler for a longer period in Philbrook Reservoir. Accordingly, since 1998 PG&E has released water from Round Valley Reservoir first, to effectively manage the temperature of water released into Butte Creek. In more recent years, increases in flow at Round Valley (above minimum instream flow requirements) have been made later to reserve water in Philbrook Reservoir so that it is available during the hottest time of the holding period. Due to the input of very cool water from s prings near Coon Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in the summer (June –August) have not increased water temperatures at Hendricks Diversion Dam. PG&E notifies the Resource Agencies when water releases commence from Round Valley Reservoir. a. Releases from Round Valley Reservoir begin between early May to mid-July when there is capacity in the Hendricks canal and, depending upon the amount released, continues for a period of about 2 to 3 weeks. Philbrook releases are typically delayed until releases from Round Valley begin to diminish or heat storm events occur. In 2016-2018 water from Round Valley Reservoir has been used to augment flow releases from Philbrook Reservoir. The release valves from these reservoirs must be operated manually and the travel time of the water released from these reservoirs to the Lower Centerville Diversion Dam (LCDD) is approximately 21 to 29 hours. Travel time of operator to the valve locations is approximately 1½ hours during workdays and may be up to 4 hours on weekends. b. On August 21, 1997, the FERC issued an Order placing temperature restrictions (17ºC at Round Valley and 18ºC at Philbrook) on the releases from these dams. On August 20, 1998, and 2020-2021, the FERC revised its Order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), the California Department of Fish and Wildlife (CDFW), and the United States Fish and Wildlife Service (USFWS); PG&E has also included the State Water Resource Control Board (SWRCB), and United States Forest Service (USFS) in this consultation process. These five agencies are referred to as the Resource Agencies in this Plan. Since 1999, this agreement has been accomplished by way of an annual O&M Plan. Reservoir operation has been based on expected water year conditions. Pursuant to FERC’s August 21, 1998 Order, this O&M Plan is annually updated and modified as appropriate in consultation with the Resources Agencies. This consultation group, composed of PG&E and the Resource Agencies, is called the Resource Group in the remainder of this Plan. Starting in 2016 a schedule of maintenance outages of the DeSabla-Centerville Canals was included in this O&M Plan. Deleted: one to two months Commented [AB1]: I don’t think I’ve ever seen this water last more than 2 to 3 weeks, def not months…? Commented [AB2]: Out of curiosity, the resource agencies have made numerous recommended changes to this plan previously, but I don’t usually see the comments incorporated… are they actually incorporated? See comments below regarding some previous things that have been recommended in the past 1-2 years just in the time I have been a part of the team, but I have not seen incorporated into the final plan or the new years plans National Marinae Fisheries Service Comments 3 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft c.The Resource Group has learned that there is a benefit from providing an increase in flow to Butte Creek during the hottest part of the holding period. Storage in Philbrook Reservoir is used to supplement flows in Butte Creek during the holding period. Monitoring data shows that cooler water released from the bottom of Philbrook Reservoir (i.e., the cold-water pool) increases in temperature while traveling through the system and reaches thermal equilibrium at Hendricks Diversion Dam. The Resource Group has agreed that it is a combination of total flow (decreased travel time, increased mass of water subject to heating) and cold-water releases that help reduce water temperatures in Butte Creek. Generally, the cool- water pool in Philbrook is depleted in late July to early August and release temperatures increase through August (e.g. maximum daily average release temperature of 20.3 ºC occurred on August 17, 2018); however, monitoring data show that after the beginning of August the thermal regime in the basin is such that releases with higher temperatures actually cool as the water travels to Hendricks Diversion Dam (sun declination is lower, canyon walls shade the stream, and cool evenings predominate). d.Initially, when management of Philbrook flows began in 1998, outflow from the reservoir was increased in response to forecasted heat events and then returned to pre- heat levels to save water. This resulted in a large amount of residual water storage at the end of the holding period, which was then released in September to make room in the reservoir for upcoming winter storms (Exhibit B). The Resource Group has moved away from short-term responses to heat events to releasing outflow from Philbrook in a stepwise fashion; this approach maximizes the use of storage during the holding period and minimizes the amount of residual storage at the end of the holding period. Although the Resource Group had been moving towards this approach in previous years, 2014 was the first year in which this pattern of management was fully employed (Exhibit B). Since 2014, an increase from minimum instream flow begins when room is available in the Hendricks canal and increases in a stepwise manner (i.e., by 5 to 10 cfs based on predicted heat events). If no heat event is predicted and flows remain steady in the canal, releases are held steady until the next heat event is forecasted. In this way, releases are increased so maximum flow is reached during the hottest period of the summer (mid-July to early August). Maximum release is held for a short period and is based on the amount of water available for the remainder of the holding period. It is then decreased in a stepwise fashion with timing and quantity of decrease dependent on a balance between heat events, remaining storage availability and the knowledge that as mid-August approaches we expect decreased average daily temperatures. The Resource Group has concluded that this release pattern is beneficial since it utilizes most of the stored Philbrook water during late June through late July when air and Butte Creek water temperatures are at their highest during the holding period. e.During relicensing studies, water temperature modeling provided evidence that the use of the Lower Centerville Canal (LCC) benefited CV spring-run Chinook salmon Commented [AB3]: This has proven to be a more effective use of water, but there needs to be more emphasis here in regards to the importance of the monitoring data, both the snorkel surveys and instream temperature monitoring within the holding reaches, as both of those are heavily weighed in the decision to hold/increase flow levels. If fish health is looking to be declining or increased instream temps are noticed, often we will choose to increase flows regardless of predicted heatstorms. It is a combination of all of these things that is used to manage operational decisions. This has been commented on several years now, but has yet to be added into the O&M Plan. Please incorporate this Commented [ERM4R3]: Agreed. Both aspects of the monitoring data are critical elements here to keeping the fish alive and must continue to be shared weekly with the DeSabla-Centerville group. National Marinae Fisheries Service Comments 4 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft holding downstream of the Centerville powerhouse (CVPH) by decreasing temperatures in these lower reaches (PG&E 2007). Modeling showed that the temperature benefit increases with the volume of flow provided through the canal, which is much higher when the CVPH is in operation. Due to its observed and modeled impact on water temperatures and distribution of CV spring-run Chinook salmon during the holding period, the operation of th e LCC was included in previous O&M Plans but has been removed since it was taken out of service. f. The CVPH went offline in February 2011; from 2011-2013, the diversion of flow into the canal during the holding period continued at the request of the Resource Group. In 2013, diversions were decreased into the LCC after consultation with the Resource Agencies due to the unusually high numbers of CV spring-run Chinook salmon holding above CVPH. The water temperature data showed that the temperature benefit of using the LCC decreased as diverted flows into the LCC decreased. The decrease of flow diverted into the LCC was due to the limited availability of water that resulted from a dry water year. After the experience of 2013, in 2014 and 2015 the Resource Group made a consensus decision to not operate the LCC during the holding period because of the dry water year type. The Resource Group concluded that, likely, there would be insufficient water available to divert enough flow into the LCC to provide a cold-water benefit to any fish holding downstream of the Centerville Powerhouse. The Resource Group made a mutual decision not to run the LCC during the 2016 holding period of CV spring-run Chinook salmon, although it was a normal water year. On February 25, 2016, a conference call occurred between representatives of the Resource Group. PG&E sought Resource Agency guidance on whet her to operate the LCC during the 2016 holding period. PG&E described the challenges of restoring the LCC to service after a 2.5-year period (2 summer holding periods) of non- operation, including turbidity risk and the resulting potential for negative pub lic perception. PG&E reminded the Resource Agencies that as the CVPH is inoperable, the LCC is only used to benefit the CV spring-run Chinook salmon. The Resource Agencies requested time before offering guidance to PG&E. On March 8, 2016, another conference call was held. PG&E provided additional information showing that because of the limited capacity of the CVPH’s Bypass/Spillway, the use of the LCC without the CVPH decreases the temperature benefit to fish holding in the downstream reaches. There was concurrence among the Resource Group on the call that PG&E would not be requested to put the LCC into service. The Resource Group agreed that availability of the LCC in future years requires more discussion and may depend on the outcome of the FERC License conditions. In 2017-2021 PG&E did not utilize the LCC to benefit water temperature for fish holding in the downstream reaches of CVPH. g. On February 16, 2017, PG&E submitted a notice of the withdrawal of its application National Marinae Fisheries Service Comments 5 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft for a new license for the project. On March 2, 2017, Commission staff issued an order disallowing the withdrawal and soliciting statements of interest regarding acquisition of the project license. In June 2018, PG&E selected a prospective buyer for the Project. Progress on the negotiations has been adversely affected by the Camp Fire, PG&E’s bankruptcy process, interconnections requirements, and settlement on various terms and conditions. The expectation to execute a Purchase Agreement has been deferred to Quarter 2 2021. B. Forecast for 2022 Water Year Type and Reservoir Operations The 2022 Water Year Type is currently forecasted to be “normal” per the definition of the license. The Department of Water Resources (DWR) forecast as of May 1, 2022, indicates that the Feather River Basin April-July runoff into Oroville is expected to be 51% of average. Exhibit C lists historical runoff forecasts and water year types since 1998. Reservoir Operations for 2022 Due to the water year type, the reservoirs will be operated under normal conditions. The Round Valley low level outlet (LLO) was fully closed on April 1, 2022. The Philbrook LLO is scheduled to provide MIF (3 cfs) until mitigations are started.. PG&E successfully obtained an early gate closure from DSOD and the radial gate was closed on March 17, 2022. Installation of flashboards begins once the water elevation reaches that of the radial gate spillway which is 5ft below the bottom of the flashboards and are planned for the week of April 25th, 2022. Flashboards are typically completely installed by June. The required normal water year minimum instream flows are being met. Reservoir operation for the holding period is as follows: 1) Releases from Round Valley Reservoir begin when there is capacity in the Hendricks Canal. Capacity is dependent upon water year type. Because of the 2022 water type, Round Valley Reservoir is at full capacity 1168-acre foot as of April 27, 2022. It is expected that releases will begin in early summer from June to mid-July. Again, due to the input of very cool water from springs near Coon Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in early summer (June – early July) have been shown to not increase water temperatures at Hendricks Diversion Dam. PG&E will notify the Resource Agencies when water releases commence from Round Valley Reservoir. 2) As Round Valley Reservoir nears its minimum elevation, PG&E will consult with the Resource Agencies to determine when releases from Philbrook Reservoir should be increased to avoid a drop in canal flows when Round Valley Reservoir flow runs out. PG&E will closely monitor the drawdown of Round Valley Reservoi r as the minimum elevation is approached. 3) The Resource Group will determine the initial release level from Philbrook Reservoir. Factors considered in establishing the actual rate of release include the date upon which releases commence (the objective of reserving relatively cool water for a possible extreme Commented [PJ5]: Working on update, unknown at this time Commented [AB6]: What date were these installed this year? I have in emails that the gates were closed on 3/17/22, but no updated date on the flashboard installation National Marinae Fisheries Service Comments 6 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft heat event, the level of natural flows, and the objective of maintaining the highest possible flows through the DeSabla Forebay. 4) The “stepwise” release pattern from Philbrook Reservoir used during the 2014 - 2020 holding periods will be used in 2021. The Resource Group will determine the initial outflow from Philbrook Reservoir. The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (often 5 to 10 cfs each) based on predicted heat events and other biologically relevant information provided during the weekly phone calls. Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre-spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. If no heat event is predicted flows will be held steady until the next heat event is forecasted or next increase in outflow is scheduled. In this way, outflow will increase until the end of July. The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing weather forecasts and biological data); flows are expected to be returned to the minimum release about mid-September. A flow through the forebay of 60 cfs is targeted to reduce residence time and minimize heating of water as it moves through the forebay. The 60 cfs target flow through the DeSabla Forebay will be reviewed during the summer on the weekly calls described above to determine if this rate should be adjusted based on the available releases from Philbrook Reservoir. 5) PG&E submitted a minimum instream flow variance on May 26, 2021, FERC provided temporary approval on June 25, 2021; final approval was granted on August 3, 2021, this variance expires on February 28, 2022. This variance allowed for the reduction of flows at Philbrook Creek from 2.0 cfs (with a 0.5 cfs flow buffer) from Philbrook Reservoir to 0.8 cfs (with a 0.2 cfs flow buffer) to ensure the availability of cold-water storage for CV spring-run Chinook salmon during the current drought conditions. The variance also allowed for an average MIF (over 48 hours) rather than an instantaneous MIF at both Butte Creek and Hendricks Head Dams. PG&E’s normal practice is to provide a buffer-flow of 4 – 5 cfs in addition to the MIF requirements; with the variance PG&E was able to release closer to the MIF. 6) Water temperature monitoring by PG&E and CDFW will continue in 2022 at six stations (Exhibit E), five of which have been used prior to relicensing (since 1998). Installation of recorders occurs in June or as soon thereafter when safe access to the stream channels is possible. Data will be reported out to the resource agency during the 202 3 Annual Operations Meeting. CDFW monitors temperature at 2 locations within the holding habitat for CV spring-run Chinook salmon. 7) DWR gage BW12 (available on CDEC) will be used as the indicator of water temperatures in the Project waters that are diverted from the West Branch Feather River. C. Lower Centerville Canal Operations for 2022 As discussed previously (section A), due to turbidity concerns with returning the LCC to Commented [MSD7]: Monitoring data continues to be used to inform ongoing Project operations. CDFW collects pre-spawn mortality data and water temperature data on a weekly basis and that data is shared weekly with the Resource Group. In 2018, 2019, and 2021 the Resource Group has used information collected by CDFW regarding observed fish condition, pre-spawn mortality, and water temperatures at Quartz Bowl to assist with stepping up and stepping down releases from Philbrook sooner or more steeply than the general plan of step-wise release pattern set forth at the beginning of the season or due solely to heat storm events. Therefore, this information is being used to inform proactive decisions regarding flow increases and decreases by the Resource Group. As a specific example: in August 2019, CDFW observations regarding fish stress, fish condition, and temperatures at Quartz Bowl, made earlier in the week, were used in conjunction with meteorology predictions during Resource Group discussions about whether or not to start implementing the step-wise reduction. Additionally, monitoring data being collected by CDFW is necessary to determine if the Reservoir Operations Plan was effective after the holding season has completed. Commented [AB8R7]: This was a comment (and associated recommended changes to this paragraph) made by USFWS in 2021. I want to re-iterate the importance of how the real time biological data is also used in these decisions, and needs to be reflected in this plan. Deleted: <#>The “stepwise” release pattern from Philbrook Reservoir (as described above) used during the 2014 - 2021 holding periods will be used in 2022. The Resource Group will determine the initial outflow from Philbrook Reservoir. The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (approximately 5 to 10 cfs each) based on predicted heat events. Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre-spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (again utilizing meteorology predictions and storage availability); flows are expected to be returned to the minimum release about mid-September.¶ Commented [AB9]: Is this relevant to keep in this year? Deleted: 2023 National Marinae Fisheries Service Comments 7 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft service, PG&E will not resume operation of the LCC in 2022. In addition, the project is currently up for sale and so PG&E is not considering returning the canal to service since the fate of the powerhouse is unknown. D. Contingency for Extreme Heat Event During the Holding Period In anticipation of a possible high ambient air temperature event, the following actions will be taken: 1. Ambient air temperature conditions are a major factor in determining actual water temperatures in Butte Creek. Starting on June 1 or at such time as the Resource Group determines, PG&E will prepare a weather forecast for the Project area by noon each Monday and Thursday. The weather forecast will be based on information from USFS weather stations at Cohasset and Chester. PG&E will provide an e-mail copy of the forecast to the Resource Agencies. If air temperatures in excess of 105ºF for two or more days during the next seven-day period are forecasted at Cohasset, with the potential for compression heating at higher elevations as confirmed by data from the Chester location, PG&E will send an e-mail to each Resource Agency representative identified in paragraph 5 below advising them that an extreme heat event is forecasted. If the next forecast confirms that an extreme heat event has started or is imminent within the next two days, and is expected to continue for over two days, PG&E will send a second e - mail, phone, or fax to one of the individuals at each Resource Agency identified in paragraph 5 to discuss actions to be taken. If personal contact cannot be made and PG&E still believes action needs to be taken, it will initiate efforts to modify Project operation as discussed in paragraphs 2 – 5, below. If action is taken, PG&E will send a third email or phone the Resource Agencies and explain the actions taken. 2. PG&E will coordinate weekly conference calls with the Resource Agencies during the CV spring-run Chinook salmon’s holding period. Increased call frequencies will be conducted as requested and agreed upon by the Resource Group. These conference calls are usually conducted from early June through mid-September (as needed). During these conference calls the Resource Group will discuss the results of pre-spawning mortality surveys (if provided by CDFW or NMFS), meteorological forecasts, water temperatures recorded by CDFW at Quartz Bowl Pool, flows and storage in Philbrook Reservoir. 3. The actual amount of water released from Philbrook Reservoir during a confirmed extreme heat event will depend on PG&E’s assessment of then-existing conditions and recommendations and comments received from the Resource Agencies in response to the e- mails. The individuals to whom PG&E will send e-mails under this section are: • Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, (530) 333-7746 • Anna Allison (CDFW) – Anna.allison@wildlife.ca.gov, (916) 272-4373 • Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, (916) 358-2875 • Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov, (916) 930-3722 National Marinae Fisheries Service Comments 8 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft • Allison Bosworth (NOAA Fisheries) Allison.Bosworth@noaa.gov, (916) 930-5617 • Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, (707) 575-6052 • Tristan Leong (USFS)– tleong@fs.fed.us, (530) 226-2308 • Jeff Wetzel (SWRCB) – Jeff.wetzel@waterboards.ca.gov, (916) 323-9390 • Daniel Welsh (USFWS) – Daniel_weslsh@fws.gov, (916) 930-5639 • Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov, (916) 930-2658 E. Spawning Flows in Butte Creek As in previous years, it is best to reduce flow from the WBFR watershed so that redds are not at risk of being dewatered if an emergency outage occurs on the Hendricks or Butte canals. In the past, flows from the West Branch Feather River were decreased around mid-September when mean daily temperature decreases naturally and the use of the canals has less of an effect on keeping water temperatures cool. Essentially this sets flows at a level that can be sustained through February 28, 2023, or other appropriate date determined by the Resource Group. F. Scheduled and Emergency Maintenance and Operations 1) Maintenance Outage Scheduling – To minimize the disruption of flows in Butte Creek during times that are sensitive to CV spring-run Chinook salmon holding in Butte Creek, PG&E plans to take scheduled canal outages as early as possible in the year. Exhibit D is a schedule of planned maintenance and outages on the Project canals. 2) Unplanned Outages (2022-2023) - Winter storms, disruption in canal flows caused by slides or fallen trees, unexpected electric transmission system outages, Public Safety Power Shutoffs (PSPS) and other hazardous conditions can disrupt normal Project operation. PG&E shall use its best efforts to minimize impacts that may result from these conditions, including the actions outlined below: a) PSPS - As part of our Community Wildfire Safety Program, PG&E is implementing additional precautionary measures to help reduce the risk of wildfires. For public safety, it may be necessary for us to turn off electricity as a last resort when extreme fire danger conditions are forecasted. This is called a "Public Safety Power Shutoff." See section below for more information on impacts and response. b) Unit Separation from Electric Grid - If the electric transmission grid, generating unit, a critical support system experiences a problem, or in the event of a PSPS, the generating units automatically separate from the grid and the flow of water to the units is directed away from the turbine. At the Toadtown and DeSabla powerhouses this is done by means of a bypass device that directs the flow through an energy dissipater bypass and allows the water to continue moving at approximately the same flow. PG&E will adjust the automatic bypass opening during the summer to reasonably correspond to the operational flow of the powerhouse. The shift from the generating unit to the bypass facility may Deleted: Lane Field Code Changed Formatted: Font color: Hyperlink Deleted: lane National Marinae Fisheries Service Comments 9 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft result in a minor release of turbidity caused by sediment that may have built- up in the bypass system since its last use. During a unit separation or PSPS event, standby portable generators are deployed to supply power to station batteries that power bypass system controls. During a separation from electric grid, PG&E increases patrol of canals as some remote operation of equipment and some remote monitoring will not be available. In preparation for PSPS events, PG&E staffs additional personal to remediate any issues that arise during the duration of the event. c) Winter Operation and Canal Emergencies – Much of the Project’s canal system traverses steep forested lands. During times of high rainfall and/or high winds, slides, rock falls, and fallen trees can damage canals or block flows. To minimize the potential for damage in the event of a blockage or failure of a canal or flume, PG&E may reduce canal flows or dewater canals in advance of such weather events. In addition, emergency spill gates are located at several locations that are equipped with devices that can be operated remotely to spill water at various locations along the canals. PG&E has installed sensors that report canal flow levels to the operator at the Rock Creek Switching Center. This location is staffed 24 hours a day, 7 days a week, 365 days a year. If a sensor detects an unexpected change in the flow, an alarm is sent to alert the operator on duty. The operator will then dispatch personnel to the location to determine if immediate action can or should be taken to remove water from the canal by activating an emergency spill gate. The emergency spill gates are placed at locations where the channel through which the water will travel is generally protected by rocks and boulders. However, turbidity is possible from vegetative or other debris that may have accumulated in the channel since its last use. Spill channels are routinely inspected at the beginning of the winter season and are typically operated once during a winter high flow event to maintain the prescriptive right for the spill channel and keep the release gate clear of material. This operation results in an incremental increase in the turbidity of Butte Creek for a short period of time, which is typically already elevated during high flow events. Operation of the spill channels that may not be well protected and could likely result in turbi dity increases, other than the annual winter operation discussed above, will be operated for emergency purposes only. To avoid releasing water into a damaged canal after a storm event, the canal is patrolled on foot prior to restoring flow. G. Water Quality Monitoring 1) PG&E will monitor water temperature at six seasonal stations during 2022. These are in addition to the real-time, permanent CDEC station at BW-12. Temperature monitoring will generally be conducted between June and September. Results will be presented at the following Annual Operations and Management Meeting. Monitoring locations are identified in Exhibit E. 2) Prior to the start-up of a canal or powerhouse after an outage, which may result in the possible release of turbidity to Butte Creek, PG&E will monitor water quality using two existing continuous monitoring turbidity sensors located in Butte Creek; one sensor is located at the LCDD, the other sensor is on a wing wall of the CVPH tailrace. National Marinae Fisheries Service Comments 10 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft 3) In the event of a canal failure, spill gate operation or other release that results in a potential for turbidity to Butte Creek, PG&E will secure water quality samples to the extent practicable and taking into consideration personnel safety. The monitoring will be conducted using either grab samples collected by PG&E and tested for turbidity or use data from the two continuous monitoring turbidity meters (noted above), set to sample every 15 minutes. Sampling locations will generally be immediately upstream of the dam or point of diversion and approximately 300 feet downstream of the point of release or return to surface waters. If the point of release to surface waters is not reasonably accessible by vehicle, PG&E will sample at the nearest downstream location that can be safely and readily accessed. 4) Turbidity data collected during a canal start-up, etc., will be made available to one of the individuals at each of the Resource Agencies identified in Section D, paragraph 5, in a timely fashion. Water temperature data will be provided to Resource Agency representatives upon request. H. Ongoing Consultation 1) On August 21, 1997, the FERC issued an order placing temperature restrictions on releases from PG&E’s storage reservoirs in the upper West Branch Feather River watershed. On August 20, 1998 the FERC revised its order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), California Department of Fish and Wildlife (CDFW) and U.S. Fish and Wildlife Service (USFWS). Since 1999, this agreement has been accomplished by way of an annual operations plan for these reservoirs. The reservoir operation varies based on water year conditions. Pursuant to FERC’s August 21, 1998 order, this Operations Plan is annually updated and modified as appropriate in consultation with the Resource Agencies. The FE RC Order requires licensee to notify FERC within 30 days after reaching agreement on the O&M Plan. 2) PG&E will meet at least annually with the interested Resource Agencies to discuss and review this O&M Plan. In addition, PG&E will continue to provide update s (generally by e- mail) on Project operations and events to at least one representative from each of the individual Resource Agencies identified in Section D, paragraph 5. A summary report will be prepared on annual operations and monitoring data, which will include water and air temperatures, reservoir and conveyance operations and actions taken to minimize effects on the CV spring-run Chinook salmon. 3) Nothing in this O&M Plan will be construed as modifying any of the terms and conditions of the DeSabla-Centerville license, FERC No. 803, or in any manner limit the jurisdiction of the FERC. In the event of any conflict between any of the provisions of this O&M Plan and the license, the provisions of the license will control. 4) PG&E will work with the Resource Agencies, and others, as appropriate, to seek ways to promote prudent land management practices by others where such practices may directly or indirectly impact safe, reliable canal operations. Nothing in this O&M Plan will be construed as either PG&E or the Resource Agencies accepting responsibility for conditions or damage that may be the result of the actions, or inactions, of others. National Marinae Fisheries Service Comments 11 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft 5) PG&E management does not anticipate the sale and transfer of the Project in 2022 and plans on continued participation with the DeSabla Centerville Operations through the end of the year. I. References PG&E. 2007. DeSabla-Centerville Hydroelectric Project. FERC Project No. 803. License Application. Appendix E6.2.2.3-G Calibration and Scenarios Report. 14 pp. PG&E. 2015. Final Project Operations Plan – 2015. Pacific Gas and Electric Company DeSabla- Centerville Project (FERC No. 803). June 18, 2015 EXHIBIT A Map of Project area. Commented [PJ10]: Unknown at this time National Marinae Fisheries Service Comments 12 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXIBIT B Comparison of Philbrook Reservoir Storage Usage National Marinae Fisheries Service Comments 13 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXHIBIT C HISTORICAL RUNOFF FORECAST AND WATER YEAR TYPE SINCE 1998 Water Year Runoff Forecast Water Year Type 1998 149% Normal 1999 115% Normal 2000 99% Normal 2001 46% Dry 2002 70% Normal 2003 97% Normal 2004 70% Normal 2005 93% Normal 2006 180% Normal 2007 38% Dry 2008 66% Normal 2009 64% Normal 2010 106% Normal 2011 171% Normal 2012 80% Normal 2013 47% Dry 2014 31% Dry 2015 19% Dry 2016 84% Normal 2017 214% Normal 2018 77% Normal 2019 176% Normal 2020 55% Normal 2021 37% Dry 2022 51% Normal Runoff Forecasts are the published May 1 Bulletin 120 forecast of April – July unimpaired runoff into Oroville Reservoir as a percent of the 50 -year average computed by the State of California at that time. Water Year Type is “Dry” if the runoff forecast is 50% or less. National Marinae Fisheries Service Comments 14 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXHIBIT D 2022 SCHEUDULED MAINTENANCE AND OUTAGES DESABLA-CENTERVILLE 2022 MAINTENANCE AND OUTAGE SCHEDULE JANUARY -DECEMBER OUTAGE SCHEDULE LOCATION DESCRIPTION OF WORK DURING OUTAGE DEWATERED STRUCTURE Start Date End Date BUTTE CANAL annual maintenance None. Limited flow (5-10cfs) will remain during work. 5/2/2022 5/31/2022 DE SABLA POWERHOUSE annual maintenance and inspections, vegetation management None 5/2/2022 5/31/2022 HENDRICKS CANAL annual maintenance, undermining repairs and liner repairs, erosion control, accessibility repairs. Fish rescue planned for 5/2/2022 to support dewatering Canal 5/2/2022 5/31/2022 LOWER CENTERVILLE CANAL vegetation management completed February 2022 OUT OF SERVICE OUT OF SERVICE OUT OF SERVICE UPPER CENTERVILLE CANAL canal annual and vegetation management None 5/2/2022 5/31/2022 CENTERVILLE POWERHOUSE TBD penstock canal OUT OF SERVICE OUT OF SERVICE TOADTOWN POWERHOUSE annual maintenance None 5/2/2022 5/31/2022 TOADTOWN CANAL minor repairs; annual maintenance various locations 5/2/2022 5/31/2022 National Marinae Fisheries Service Comments 15 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXHIBIT E PG&E SEASONAL MONITORING LOCATIONS – 2022 1. Philbrook Creek at release * (Temperature and Flow) 2. WBFR at Hendricks Head Dam * (Temperature and Flow) 3. Total canal inflow to DeSabla Forebay * (Temperature and Flow) 4. DeSabla Powerhouse tailrace * (Temperature and Flow) 5. Butte Creek at LCDD * (Temperature, Turbidity, and Flow) 6. Butte Creek at Centerville Powerhouse (Temperature and Turbidity) * Original monitoring stations used since 1998 National Marinae Fisheries Service Comments 16 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft Proposed 2021 Water Temperature Monitoring Network. National Marinae Fisheries Service Comments Draft DeSabla-Centerville Project (FERC No. 803) DRAFT 2022 Operations and Maintenance Plan Pacific Gas and Electric Company The objective of the Operations and Maintenance Plan (O&M Plan) is to focus on how to best provide water temperatures that are as cold as possible to support holding, spawning, and rearing of Central Valley (CV) spring-run Chinook salmon in the reaches of Butte Creek below the DeSabla Powerhouse during 2022. It also documents Pacific Gas and Electric Company’s (PG&E) scheduled outages that allow for maintenance activities of the DeSabla-Centerville Project (Project). This O&M Plan outlines the procedures and practices PG&E will strive to follow in the operation of the Project to enhance and protect this habita t for CV spring-run Chinook salmon. This O&M Plan is also intended to provide the basis for modification of the reservoir temperature release criteria established in the Federal Energy Regulatory Commission (FERC) “Order Approving Water Temperature Study Report” issued August 21, 1997, as amended by FERC’s “Order Amending Temperature Requirements” issued August 20, 1998. A.Introduction 1) The DeSabla – Centerville Project includes the following features which are depicted in Exhibit A: Reservoirs and Forebays: Round Valley Reservoir (also called Snag Lake), Philbrook Reservoir, and DeSabla Forebay Canals and related features: Butte, Hendricks, Toadtown, Upper Centerville, and Lower Centerville canals and associated diversion dams, feeders, and spillway channels Powerhouses: Toadtown, DeSabla, and Centerville 2) Project Benefits to Butte Creek Habitat: a)Water diverted from the West Branch Feather River at the Hendricks Diversion Dam (including releases from Philbrook and Round Valley Reservoirs) increases the total fl ow available in Butte Creek below DeSabla Powerhouse by approximately 40% in July and August (depending on water availability in Butte Creek). b)Water imported from the West Branch Feather River provides additional water to cool water temperatures in reaches of Butte Creek used by CV spring-run Chinook salmon for over-summering by providing releases from Philbrook Reservoir when storage is available. The increased flow from the West Branch Feather River also helps minimize heating by reducing the residence time in the DeSabla forebay. The shorter travel time of water in canals also helps to minimize heating. US Fish and Wildlife Service Comments 2 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft 3) Background: The Project storage reservoirs (Round Valley and Philbrook Reservoirs) are in the West Branch Feather River watershed. Project diversions are made from this drainage at the Hendricks Canal Diversion Dam. Due to the larger storage capacity and depth of Philbrook Reservoir (5,000 acre-feet) relative to Round Valley Reservoir (1,200 acre-feet), the water temperature tends to stay cooler for a longer period in Philbrook Reservoir. Accordingly, since 1998 PG&E has released water from Round Valley Reservoir first, to effectively manage the temperature of water released into Butte Creek. In more recent years, increases in flow at Round Valley (above minimum instream flow requirements) have been made later to reserve water in Philbrook Reservoir so that it is available during the hottest time of the holding period. Due to the input of very cool water from springs near Co on Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in the summer (June –August) have not increased water temperatures at Hendricks Diversion Dam. PG&E notifies the Resource Agencies when water releases commence from Round Valley Reservoir. a. Releases from Round Valley Reservoir begin between early May to mid-July when there is capacity in the Hendricks canal and, depending upon the amount released, continues for a period of about one to two months. Philbrook releases are typically delayed until releases from Round Valley begin to diminish or heat storm events occur. In 2016-2018 water from Round Valley Reservoir has been used to augment flow releases from Philbrook Reservoir. The release valves from these reservoirs must be operated manually and the travel time of the water released from these reservoirs to the Lower Centerville Diversion Dam (LCDD) is approximately 21 to 29 hours. Travel time of operator to the valve locations is approximately 1½ hou rs during workdays and may be up to 4 hours on weekends. b. On August 21, 1997, the FERC issued an Order placing temperature restrictions (17ºC at Round Valley and 18ºC at Philbrook) on the releases from these dams. On August 20, 1998, and 2020-2021, the FERC revised its Order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), the California Department of Fish and Wildlife (CDFW), and the United States Fish and Wildlife Service (USFWS); PG&E has also included the State Water Resource Control Board (SWRCB), and United States Forest Service (USFS) in this consultation process. These five agencies are referred to as the Resource Agencies in this Plan. Since 1999, this agreement has been accomplished by way of an annual O&M Plan. Reservoir operation has been based on expected water year conditions. Pursuant to FERC’s August 21, 1998 Order, this O&M Plan is annually updated and modified as appropriate in consultation with the Resources Agencies. This consultation group, composed of PG&E and the Resource Agencies, is called the Resource Group in the remainder of this Plan. Starting in 2016 a schedule of maintenance outages of the DeSabla-Centerville Canals was included in this O&M Plan. Fish and Wildlife Service Comments 3 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft c. The Resource Group has learned that there is a benefit from providing an increase in flow to Butte Creek during the hottest part of the holding period. Storage in Philbrook Reservoir is used to supplement flows in Butte Creek during the holding period. Monitoring data shows that cooler water released from the bottom of Philbrook Reservoir (i.e., the cold-water pool) increases in temperature while traveling through the system and reaches thermal equilibrium at Hendricks Diversion Dam. The Resource Group has agreed that it is a combination of total flow (decreased travel time, increased mass of water subject to heating) and cold-water releases that help reduce water temperatures in Butte Creek. Generally, the cool- water pool in Philbrook is depleted in late July to early August and release temperatures increase through August (e.g. maximum daily average release temperature of 20.3 ºC occurred on August 17, 2018); however, monitoring data show that after the beginning of August the thermal regime in the basin is such that releases with higher temperatures actually cool as the water travels to Hendricks Diversion Dam (sun declination is lower, canyon walls shade the stream, and cool evenings predominate). d. Initially, when management of Philbrook flows began in 1998, outflow from the reservoir was increased in response to forecasted heat events and then returned to pre- heat levels to save water. This resulted in a large amount of residual water storage at the end of the holding period, which was then released in September to make room in the reservoir for upcoming winter storms (Exhibit B). The Resource Group has moved away from short-term responses to heat events to releasing outflow from Philbrook in a stepwise fashion; this approach maximizes the use of storage during the holding period and minimizes the amount of residual storage at the end of the holding period. Although the Resource Group had been moving towards this approach in previous years, 2014 was the first year in which this pattern of management was fully employed (Exhibit B). Since 2014, an increase from minimum instream flow begins when room is available in the Hendricks canal and increases in a stepwise manner (i.e., by 5 to 10 cfs based on predicted heat events and observed fish health (currently provided by CDFW)). If no heat event is predicted, flows remain steady in the canal, and fish appear in good health, releases are held steady until the next heat event is forecasted. In this way, releases are increased so maximum flow is reached during the hottest period of the summer (mid-July to early August). Maximum release is held for a short period and is based on the amount of water available for the remainder of the holding period. It is then decreased in a stepwise fashion with timing and quantity of decrease dependent on a balance between heat events, remaining storage availability and the knowledge that as mid-August approaches we expect decreased average daily temperatures. Monitoring data, currently being collected by CDFW, has also been used by the Resource Group to adjust these stepwise flow changes. The Resource Group has concluded that this release pattern is beneficial since it utilizes most of the stored Philbrook water during late June through late July when a ir and Butte Creek water temperatures are at their highest during the holding period. Deleted: and Commented [MSD1]: USFWS agrees that heat events are the driving factor for how flows are stepped up and down during the holding season. However, salmonid monitoring data and temps at Quartz Bowl are used to make small adjustments to the pattern. This sentence is an attempt to incorporate that fact. Fish and Wildlife Service Comments 4 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft e. During relicensing studies, water temperature modeling provided evidence that the use of the Lower Centerville Canal (LCC) benefited CV spring-run Chinook salmon holding downstream of the Centerville powerhouse (CVPH) by decreasing temperatures in these lower reaches (PG&E 2007). Modeling showed that the temperature benefit increases with the volume of flow provided through the canal, which is much higher when the CVPH is in operation. Due to its observed and modeled impact on water temperatures and distribution of CV spring-run Chinook salmon during the holding period, the operation of the LCC was included in previous O&M Plans but has been removed since it was taken out of service. f. The CVPH went offline in February 2011; from 2011-2013, the diversion of flow into the canal during the holding period continued at the request of the Resource Group. In 2013, diversions were decreased into the LCC after consultation with the Resource Agencies due to the unusually high numbers of CV spring -run Chinook salmon holding above CVPH. The water temperature data showed that the temperature benefit of using the LCC decreased as diverted flows into the LCC decreased. The decrease of flow diverted into the LCC was due to the limited availability of water that resulted from a dry water year. After the experience of 2013, in 2014 and 2015 the Resource Group made a consensus decision to not operate the LCC during the holding period because of the dry water year type. The Resource Group concluded that, likely, there would be insufficient water available to divert enough flow into the LCC to provide a cold-water benefit to any fish holding downstream of the Centerville Powerhouse. The Resource Group made a mutual decision not to run the LCC during the 2016 holding period of CV spring-run Chinook salmon, although it was a normal water year. On February 25, 2016, a conference call occurred between representatives of the Resource Group. PG&E sought Resource Agency guidance on whether to operate the LCC during the 2016 holding period. PG&E described the challenges of restoring the LCC to service after a 2.5-year period (2 summer holding periods) of non- operation, including turbidity risk and the resulting potential for negative public perception. PG&E reminded the Resource Agencies that as the CVPH is inoperable, the LCC is only used to benefit the CV spring-run Chinook salmon. The Resource Agencies requested time before offering guidance to PG&E. On March 8, 2016, another conference call was held. PG&E provided additional information showing that because of the limited capacity of the CVPH’s Bypass/Spillway, the use of the LCC without the CVPH decreases the temperature benefit to fish holding in the downstream reaches. There was concurrence among the Resource Group on the call that PG&E would not be requested to put the LCC into service. The Resource Group agreed that availability of the LCC in future years requires more discussion and may depend on the outcome of the FERC License conditions. In 2017-2021 PG&E did not utilize the LCC to benefit water temperature for fish holding in the downstream reaches of CVPH. Fish and Wildlife Service Comments 5 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft g. On February 16, 2017, PG&E submitted a notice of the withdrawal of its application for a new license for the project. On March 2, 2017, Commission staff issued an order disallowing the withdrawal and soliciting statements of interest regarding acquisition of the project license. In June 2018, PG&E selected a prospective buyer for the Project. Progress on the negotiations has been adversely affected by the Camp Fire, PG&E’s bankruptcy process, interconnections requirements, and settlement on various terms and conditions. The expectation to execute a Purchase Agreement has been deferred to Quarter 2 2021. B. Forecast for 2022 Water Year Type and Reservoir Operations The 2022 Water Year Type is currently forecasted to be “normal” per the definition of the license. The Department of Water Resources (DWR) forecast as of May 1, 2022, indicates that the Feather River Basin April-July runoff into Oroville is expected to be 51% of average. Exhibit C lists historical runoff forecasts and water year types since 1998. Reservoir Operations for 2022 Due to the water year type, the reservoirs will be operated under normal conditions. The Round Valley low level outlet (LLO) was fully closed on April 1, 2022. The Philbrook LLO is scheduled to provide MIF (3 cfs) until mitigations are started.. PG&E successfully obtained an early gate closure from DSOD and the radial gate was closed on March 17, 2022. Installation of flashboards begins once the water elevation reaches that of the radial gate spillway which is 5ft below the bottom of the flashboards and are planned for the week of April 25th, 2022. Flashboards are typically completely installed by June. The required normal water year minimum instream flows are being met. Reservoir operation for the holding period is as follows: 1) Releases from Round Valley Reservoir begin when there is capacity in the Hendricks Canal. Capacity is dependent upon water year type. Because of the 2022 water type, Round Valley Reservoir is at full capacity 1168-acre foot as of April 27, 2022. It is expected that releases will begin in early summer from June to mid-July. Again, due to the input of very cool water from springs near Coon Hollow and West Branch Feather River basin snow melt, releases from Round Valley Reservoir occurring in early summer (June – early July) have been shown to not increase water temperatures at Hendricks Diversion Dam. PG&E will notify the Resource Agencies when water releases commence from Round Valley Reservoir. 2) As Round Valley Reservoir nears its minimum elevation, PG&E will consult with the Resource Agencies to determine when releases from Philbrook Reservoir should be increased to avoid a drop in canal flows when Round Valley Reservoir flow runs out. PG&E will closely monitor the drawdown of Round Valley Reservoi r as the minimum elevation is approached. 3) The Resource Group will determine the initial release level from Philbrook Reservoir. Factors considered in establishing the actual rate of release include the date upon which releases commence the objective of reserving relatively cool water for a possible extreme Commented [PJ2]: Working on update, unknown at this time Commented [MSD3]: PG&E filed a quarterly update on 6/1/22… recommend updating this sentence to be consistent with that update. Deleted: dry Deleted: update Deleted: April 12 Deleted: 34 Deleted: dry Deleted: 2021 Deleted: The radial gate at Philbrook was closed on April 9, 2021 Commented [MSD4]: Recommend updating Fish and Wildlife Service Comments 6 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft heat event, the level of natural flows, and the objective of maintaining the highest possible flows through the DeSabla Forebay. 4) The “stepwise” release pattern from Philbrook Reservoir (as described above) used during the 2014 - 2021 holding periods will be used in 2022. The Resource Group will determine the initial outflow from Philbrook Reservoir. The Resource Group will hold weekly phone call meetings to determine these stepwise increases in outflow (approximately 5 to 10 cfs each) based on predicted heat events and other information shared with the Resource Group . Weekly phone calls will also include discussion of weather forecast, reservoir levels, pre - spawning mortality updates (if conducted by CDFW or NMFS), water temperatures, measured at the holding pool “Quartz Bowl” by CDFW, and proposed outflow from Philbrook Reservoir. The Resource Group will then determine, via weekly meetings, when Philbrook outflow will be decreased using a stepwise reduction (utilizing all information shared during the weekly phone calls); flows are expected to be returned to the minimum release about mid-September. A flow through the forebay of 60 cfs is targeted to reduce residence time and minimize heating of water as it moves through the forebay. The 60 cfs target flow through the DeSabla Forebay will be reviewed during the summer on the weekly calls described above to determine if this rate should be adjusted based on the available releases from Philbrook Reservoir. 5) PG&E submitted a minimum instream flow variance on May 26, 2021, FERC provided temporary approval on June 25, 2021; final approval was granted on August 3, 2021, this variance expires on February 28, 2022. This variance allowed for the reduction of flows at Philbrook Creek from 2.0 cfs (with a 0.5 cfs flow buffer) from Philbrook Reservoir to 0.8 cfs (with a 0.2 cfs flow buffer) to ensure the availability of cold-water storage for CV spring-run Chinook salmon during the current drought conditions. The variance also allowed for an average MIF (over 48 hours) rather than an instantaneous MIF at both Butte Creek and Hendricks Head Dams. PG&E’s normal practice is to provide a buffer-flow of 4 – 5 cfs in addition to the MIF requirements; with the variance PG&E was able to release closer to the MIF. 6) Water temperature monitoring by PG&E will continue in 2022 at six stations (Exhibit E), five of which have been used prior to relicensing (since 1998). Installation of recorders occurs in June or as soon thereafter when safe access to the stream channels is possible. Data will be reported out to the resource agency during the 2023 Annual Operations Meeting. 7) DWR gage BW12 (available on CDEC) will be used as the indicator of water temperatures in the Project waters that are diverted from the West Branch Feather River. C. Lower Centerville Canal Operations for 2022 As discussed previously (section A), due to turbidity concerns with returning the LCC to service, PG&E will not resume operation of the LCC in 2022. In addition, the project is currently up for sale and so PG&E is not considering returning the canal to service since the fate of the powerhouse is unknown. D. Contingency for Extreme Heat Event During the Holding Period Commented [MSD5]: As mentioned previously, while we rely predominantly on predicted heat events to determine flow increases, the Resource Group has also used monitoring data currently being conducted by CDFW to inform stepwise increases in outflow. Here are two specific examples from 2021: On 6/23 PG&E started releases from Philbrook, here’s the email from Catalina on 6/23: “I got an early morning email from Britt that Round Valley did not last as long as we thought and the flow in creeks is starting to drop. He recommends that we start drafting 10 cfs from Philbrook to make up for the flow we lost from Round Valley. This will also prepare the fish for the upcoming heat storm.” On 6/24 we met as a group and the outcome was to increase flows by another 5 cfs, such that total outflows from Philbrook were 15cfs. According to my notes, this increase wasn’t scheduled for another week. However, Resource Agency staff advocated for increasing flows earlier because temperatures at Quartz Bowl were already getting to threshold temperatures and fish were holding in riffles (which is a sign of stress). An additional example from 2021 occurred on 7/29 when Resource Agency staff advocated for increasing flow to help flush out pathogens (information gathered during pre-spawn mortality surveys), but we ultimately waited to make that increase until 8/2 when the Dixie Fire was no longer an ... Deleted: again utilizing meteorology predictions and storage availability Commented [MSD6]: FWS continues to recommend that PG&E acknowledge that decisions regarding flow increases and decreases are also informed by data currently being collected by CDFW. The original parenthetical suggests that only meteorological data and reservoir storage are used to make decisions regarding how to shape the stepwise reduction. Commented [RC7]: Planning on applying for 2022 variance, leave as placeholder Commented [MSD8R7]: Given that PG&E is considering a flow variance, but one hasn’t yet been provided for Agency review, I recommend using different placeholder language, such as: PG&E is in the process of identifying if a variance request for 2022 might be warranted and will coordinate with the ... Commented [MSD9]: Based on my experience, we don’t receive real-time water temperature data from this gage. Our discussions have been focused on water temperatures at the Quartz Bowl holding pool which is collected by CDFW and shared during Resource Group calls. Deleted: 2023 Fish and Wildlife Service Comments 7 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft In anticipation of a possible high ambient air temperature event, the following actions will be taken: 1. Ambient air temperature conditions are a major factor in determining actual water temperatures in Butte Creek. Starting on June 1 or at such time as the Resource Group determines, PG&E will prepare a weather forecast for the Project area by noon each Monday and Thursday. The weather forecast will be based on information from USFS weather stations at Cohasset and Chester. PG&E will provide an e -mail copy of the forecast to the Resource Agencies. If air temperatures in excess of 105ºF for two or more days during the next seven-day period are forecasted at Cohasset, with the potential for compression heating at higher elevations as confirmed by data from the Chester location, PG&E will send an e-mail to each Resource Agency representative identified in paragraph 5 below advising them that an extreme heat event is forecasted. If the next forecast confirms that an extreme heat event has started or is imminent within the next two days, and is expected to continue for over two days, PG&E will send a second e- mail, phone, or fax to one of the individuals at each Resource Agency identified in paragraph 5 to discuss actions to be taken. If personal contact cannot be made and PG&E still believes action needs to be taken, it will initiate efforts to modify Project operation as discussed in paragraphs 2 – 5, below. If action is taken, PG&E will send a third email or phone the Resource Agencies and explain the actions taken. 2. PG&E will coordinate weekly conference calls with the Resource Agencies during the CV spring-run Chinook salmon’s holding period. Increased call frequencies will be conducted as requested and agreed upon by the Resource Group. These conference calls are usually conducted from early June through mid-September (as needed). During these conference calls the Resource Group will discuss the results of pre-spawning mortality surveys (if provided by CDFW or NMFS), meteorological forecasts, water temperatures recorded by CDFW at Quartz Bowl Pool, flows and storage in Philbrook Reservoir. 3. The actual amount of water released from Philbrook Reservoir during a confirmed extreme heat event will depend on PG&E’s assessment of then-existing conditions and recommendations and comments received from the Resource Agencies in response to the e- mails. The individuals to whom PG&E will send e-mails under this section are: • Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, (530) 333-7746 • Anna Allison (CDFW) – Anna.allison@wildlife.ca.gov, (916) 272-4373 • Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, (916) 358-2875 • Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov, (916) 930-3722 • Allison Lane (NOAA Fisheries) Allison.lane@noaa.gov, (916) 930-5617 • Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, (707) 575-6052 • Tristan Leong (USFS)– tleong@fs.fed.us, (530) 226-2308 Fish and Wildlife Service Comments 8 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft • Jeff Wetzel (SWRCB) – Jeff.wetzel@waterboards.ca.gov, (916) 323-9390 • Daniel Welsh (USFWS) – Daniel_weslsh@fws.gov, (916) 930-5639 • Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov, (916) 930-2658 E. Spawning Flows in Butte Creek As in previous years, it is best to reduce flow from the WBFR watershed so that redds are not at risk of being dewatered if an emergency outage occurs on the Hendricks or Butte canals. In the past, flows from the West Branch Feather River were decreased around mid-September when mean daily temperature decreases naturally and the use of the canals has less of an effect on keeping water temperatures cool. Essentially this sets flows at a level that can be sustained through February 28, 2023, or other appropriate date determined by the Resource Group. F. Scheduled and Emergency Maintenance and Operations 1) Maintenance Outage Scheduling – To minimize the disruption of flows in Butte Creek during times that are sensitive to CV spring-run Chinook salmon holding in Butte Creek, PG&E plans to take scheduled canal outages as early as possible in the year. Exhibit D is a schedule of planned maintenance and outages on the Project canals. 2) Unplanned Outages (2022-2023) - Winter storms, disruption in canal flows caused by slides or fallen trees, unexpected electric transmission system outages, Public Safety Power Shutoffs (PSPS) and other hazardous conditions can disrupt normal Project operation. PG&E shall use its best efforts to minimize impacts that may result from these conditions, including the actions outlined below: a) PSPS - As part of our Community Wildfire Safety Program, PG&E is implementing additional precautionary measures to help reduce the risk of wildfires. For public safety, it may be necessary for us to turn off electricity as a last resort when extreme fire danger conditions are forecasted. This is called a "Public Safety Power Shutoff." See section below for more information on impacts and response. b) Unit Separation from Electric Grid - If the electric transmission grid, generating unit, a critical support system experiences a problem, or in the event of a PSPS, the generating units automatically separate from the grid and the flow of water to the units is directed away from the turbine. At the Toadtown and DeSabla powerhouses this is done by means of a bypass device that directs the flow through an energy dissipater bypass and allows the water to continue moving at approximately the same flow. PG&E will adj ust the automatic bypass opening during the summer to reasonably correspond to the operational flow of the powerhouse. The shift from the generating unit to the bypass facility may result in a minor release of turbidity caused by sediment that may have built- up in the bypass system since its last use. During a unit separation or PSPS event, standby portable generators are deployed to supply power to station batteries that power bypass system controls. During a separation from electric grid, PG&E increases patrol of canals as some remote operation of equipment and some remote monitoring will not be available. In Commented [MSD10]: We had a great discussion during our meeting about some of the constraints are that drive when canal outages can be taken. I recommend including some of that information within this section. Fish and Wildlife Service Comments 9 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft preparation for PSPS events, PG&E staffs additional personal to remediate any issues that arise during the duration of the event. c) Winter Operation and Canal Emergencies – Much of the Project’s canal system traverses steep forested lands. During times of high rainfall and/or high winds, slides, rock falls, and fallen trees can damage canals or block flows. To minimize the potential for damage in the event of a blockage or failure of a canal or flume, PG&E may reduce canal flows or dewater canals in advance of such weather events. In addition, emergency spill gates are located at several locations that are equipped with devices that can be operated remotely to spill water at various locations along the canals. PG&E has installed sensors that report canal flow levels to the operator at the Rock Creek Switching Center. This location is staffed 24 hours a day, 7 days a week, 365 days a year. If a sensor detects an unexpected change in the flow, an alarm is sent to alert the operator on duty. The operator will then dispatch personnel to the location to determine if immediate action can or should be taken to remove water from the canal by activating an emergenc y spill gate. The emergency spill gates are placed at locations where the channel through which the water will travel is generally protected by rocks and boulders. However, turbidity is possible from vegetative or other debris that may have accumulated in the channel since its last use. Spill channels are routinely inspected at the beginning of the winter season and are typically operated once during a winter high flow event to maintain the prescriptive right for the spill channel and keep the release gate clear of material. This operation results in an incremental increase in the turbidity of Butte Creek for a short period of time, which is typically already elevated during high flow events. Operation of the spill channels that may not be well protected and could likely result in turbidity increases, other than the annual winter operation discussed above, will be operated for emergency purposes only. To avoid releasing water into a damaged canal after a storm event, the canal is patrolled on foot prior to restoring flow. G. Water Quality Monitoring 1) PG&E will monitor water temperature at six seasonal stations during 2022. These are in addition to the real-time, permanent CDEC station at BW-12. Temperature monitoring will generally be conducted between June and September. Results will be presented at the following Annual Operations and Management Meeting. Monitoring locations are identified in Exhibit E. 2) Prior to the start-up of a canal or powerhouse after an outage, which may result in the possible release of turbidity to Butte Creek, PG&E will monitor water quality using two existing continuous monitoring turbidity sensors located in Butte Creek; one sensor is located at the LCDD, the other sensor is on a wing wall of the CVPH tailrace. 3) In the event of a canal failure, spill gate operation or other release that results in a potential for turbidity to Butte Creek, PG&E will secure water quality samples to the extent practicable and taking into consideration personnel safety. The monitoring will be conducted using either grab samples collected by PG&E and tested for turbidity or use data from the two continuous monitoring turbidity meters (noted above), set to sample every 15 minutes. Fish and Wildlife Service Comments 10 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft Sampling locations will generally be immediately upstream of the dam or point of diversion and approximately 300 feet downstream of the point of release or return to surface waters. If the point of release to surface waters is not reasonably accessible by vehicle, PG&E will sample at the nearest downstream location that can be safely and readily accessed. 4) Turbidity data collected during a canal start-up, etc., will be made available to one of the individuals at each of the Resource Agencies identified in Section D, paragraph 5, in a timely fashion. Water temperature data will be provided to Resource Agency representatives upon request. H. Ongoing Consultation 1) On August 21, 1997, the FERC issued an order placing temperature restrictions on releases from PG&E’s storage reservoirs in the upper West Branch Feather River watershed. On August 20, 1998 the FERC revised its order to allow for modification of the criteria upon mutual agreement of the National Marine Fisheries Service (NMFS), California Department of Fish and Wildlife (CDFW) and U.S. Fish and Wildlife Service (USFWS). Since 1999, this agreement has been accomplished by way of an annual operations plan for these reservoirs. The reservoir operation varies based on water year conditions. Pursuant to FERC’s August 21, 1998 order, this Operations Plan is annually updated and modified as appropriate in consultation with the Resource Agencies. The FERC Order requ ires licensee to notify FERC within 30 days after reaching agreement on the O&M Plan. 2) PG&E will meet at least annually with the interested Resource Agencies to discuss and review this O&M Plan. In addition, PG&E will continue to provide updates (generally by e- mail) on Project operations and events to at least one representative from each of the individual Resource Agencies identified in Section D, paragraph 5. A summary report will be prepared on annual operations and monitoring data, which will include water and air temperatures, reservoir and conveyance operations and actions taken to minimize effects on the CV spring-run Chinook salmon. 3) Nothing in this O&M Plan will be construed as modifying any of the terms and conditions of the DeSabla-Centerville license, FERC No. 803, or in any manner limit the jurisdiction of the FERC. In the event of any conflict between any of the provisions of this O&M Plan and the license, the provisions of the license will control. 4) PG&E will work with the Resource Agencies, and others, as appropriate, to seek ways to promote prudent land management practices by others where such practices may directly or indirectly impact safe, reliable canal operations. Nothing in this O&M Plan will be construed as either PG&E or the Resource Agencies accepting responsibility for conditions or damage that may be the result of the actions, or inactions, of others. 5) PG&E management does not anticipate the sale and transfer of the Project in 2022 and plans on continued participation with the DeSabla Centerville Operations through the end of the year. I. References Commented [PJ11]: Unknown at this time Fish and Wildlife Service Comments 11 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft PG&E. 2007. DeSabla-Centerville Hydroelectric Project. FERC Project No. 803. License Application. Appendix E6.2.2.3-G Calibration and Scenarios Report. 14 pp. PG&E. 2015. Final Project Operations Plan – 2015. Pacific Gas and Electric Company DeSabla- Centerville Project (FERC No. 803). June 18, 2015 EXHIBIT A Map of Project area. Fish and Wildlife Service Comments 12 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXIBIT B Comparison of Philbrook Reservoir Storage Usage Fish and Wildlife Service Comments 13 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXHIBIT C HISTORICAL RUNOFF FORECAST AND WATER YEAR TYPE SINCE 1998 Water Year Runoff Forecast Water Year Type 1998 149% Normal 1999 115% Normal 2000 99% Normal 2001 46% Dry 2002 70% Normal 2003 97% Normal 2004 70% Normal 2005 93% Normal 2006 180% Normal 2007 38% Dry 2008 66% Normal 2009 64% Normal 2010 106% Normal 2011 171% Normal 2012 80% Normal 2013 47% Dry 2014 31% Dry 2015 19% Dry 2016 84% Normal 2017 214% Normal 2018 77% Normal 2019 176% Normal 2020 55% Normal 2021 37% Dry 2022 51% Normal Runoff Forecasts are the published May 1 Bulletin 120 forecast of April – July unimpaired runoff into Oroville Reservoir as a percent of the 50 -year average computed by the State of California at that time. Water Year Type is “Dry” if the runoff forecast is 50% or less. Fish and Wildlife Service Comments 14 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXHIBIT D 2022 SCHEUDULED MAINTENANCE AND OUTAGES DESABLA-CENTERVILLE 2022 MAINTENANCE AND OUTAGE SCHEDULE JANUARY -DECEMBER OUTAGE SCHEDULE LOCATION DESCRIPTION OF WORK DURING OUTAGE DEWATERED STRUCTURE Start Date End Date BUTTE CANAL annual maintenance None. Limited flow (5-10cfs) will remain during work. 5/2/2022 5/31/2022 DE SABLA POWERHOUSE annual maintenance and inspections, vegetation management None 5/2/2022 5/31/2022 HENDRICKS CANAL annual maintenance, undermining repairs and liner repairs, erosion control, accessibility repairs. Fish rescue planned for 5/2/2022 to support dewatering Canal 5/2/2022 5/31/2022 LOWER CENTERVILLE CANAL vegetation management completed February 2022 OUT OF SERVICE OUT OF SERVICE OUT OF SERVICE UPPER CENTERVILLE CANAL canal annual and vegetation management None 5/2/2022 5/31/2022 CENTERVILLE POWERHOUSE TBD penstock canal OUT OF SERVICE OUT OF SERVICE TOADTOWN POWERHOUSE annual maintenance None 5/2/2022 5/31/2022 TOADTOWN CANAL minor repairs; annual maintenance various locations 5/2/2022 5/31/2022 Fish and Wildlife Service Comments 15 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft EXHIBIT E PG&E SEASONAL MONITORING LOCATIONS – 2022 1. Philbrook Creek at release * (Temperature and Flow) 2. WBFR at Hendricks Head Dam * (Temperature and Flow) 3. Total canal inflow to DeSabla Forebay * (Temperature and Flow) 4. DeSabla Powerhouse tailrace * (Temperature and Flow) 5. Butte Creek at LCDD * (Temperature, Turbidity, and Flow) 6. Butte Creek at Centerville Powerhouse (Temperature and Turbidity) * Original monitoring stations used since 1998 Fish and Wildlife Service Comments 16 May 2022 2022 Operations and Maintenance Plan ©2022, Pacific Gas and Electric Company Draft Proposed 2021 Water Temperature Monitoring Network. Fish and Wildlife Service Comments