HomeMy WebLinkAbout09.01.22 Board Correspondence - FW_ DOCKET CHANGE- Environmental and Recreational Compliance Report submitted in FERC P-2107-050 by Pacific Gas and Electric Company,et al.From: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: DOCKET CHANGE- Environmental and Recreational Compliance Report submitted in
FERC P-2107-050 by Pacific Gas and Electric Company,et al.
Date:Thursday, September 1, 2022 2:42:54 PM
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
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Subject: DOCKET CHANGE- Environmental and Recreational Compliance Report submitted in FERC P-2107-050
by Pacific Gas and Electric Company,et al.
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On 8/24/2022, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC),
Washington D.C.:
Filer: Pacific Gas and Electric Company
PG&E Corporation (as Agent)
Docket(s): P-2107-050
Lead Applicant: Pacific Gas and Electric Company
Filing Type: Environmental and Recreational Compliance Report
Description: Pacific Gas and Electric Company submits 2022 Fish and Benthic Macroinvertebrate Monitoring
Variances to allow a safe working environment for the field team for Poe Hydroelectric Project
under P-2107.
To view the document for this Filing, click here
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Power Generation
245 Market Street
San Francisco, CA 94105
Mailing Address:
Mail Code N11D
P.O. Box 770000
San Francisco, CA 94177
August 24, 2022
Via Electronic Submittal (E-File)
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
RE: Poe Hydroelectric Project, FERC No. 2107-CA
2022 Fish and BMI Monitoring Variances
Dear Secretary Bose:
Pacific Gas and Electric Company (PG&E) respectfully requests that the Federal
Energy Regulatory Commission (FERC) approve a temporary flow, sample site, and
sample methodology variance for the 2022 Poe fish and benthic macroinvertebrate
(BMI) monitoring, required under the Poe Bypass Reach Project Fish and BMI
Monitoring Plan (Plan), which was created pursuant to the license for PG&E’s Poe
Hydroelectric Project FERC No. 2107. These variances are necessary to allow a safe
working environment for the field team and are consistent with variances previously
approved for the Poe fish and BMI monitoring. This variance proposal received
concurrence (Enclosure 1) from the United States Department of Agriculture (Forest
Service), State Water Resources Control Board (SWRCB), United States Fish and
Wildlife Service (USFWS), and California Fish and Wildlife Service (CFWS) (hereinafter
referred to as Agencies). Please respond with approval authorization by September 17,
2022 so that the monitoring can be implemented on schedule .
License Requirements
License article 401(c) states that PG&E must notify the Commission of any planned
deviation from minimum flow release requirements:
(c) Requirement to Notify Commission of Planned and Unplanned Deviations
from License Requirements
Three Water Board conditions in Appendix A and three Forest Service conditions
in Appendix B would allow the licensee to temporarily modify project operations
under certain conditions. The Commission must be notified prior to implementing
such modifications, if possible, or in the event of an emergency, as soon as
possible, but no later than 10 days after each such incident. The California
Department of Fish and Wildlife and the U.S. Fish and Wildlife Service must also
Kimberly D. Bose, Secretary
August 24, 2022
Page 2
be notified prior to implementing any modifications to minimum flows required by
Certification Condition No. 1 and Forest Service Condition No. 23 (Part 1).
Table 1: License Conditions Allowing Temporary Modifications to Project
Operations
WQC
Condition
No.
Forest
Service
Condition
No. License requirement
1 23 (Part 1) Minimum flow releases
2 -
Notify California Fish and Wildlife, Forest Service,
FWS, and Water Board prior to release of pulse
flows.
- 23 (Part 1) Minimum Streamflows
3 23 (Part 1) Flow requirement modification due to multiple dry
water years
4(e) Condition No. 23 and 401 Condition 1 list the following MIF for dry years:
Table 2: Minimum River Flow –Dry Years
Date Min. Flow
September 300 cfs
October 180 cfs
The Plan states the following requirements for modifying streamflows:
PG&E may reduce streamflows defined in, and in accordance with any other
requirements of, SWRCB WQC Condition 1, Forest Service 4(e) Condition No.
23, and FERC License Article 401(c) to implement this [Fish and BMI] monitoring
Plan under the following conditions:
1. Monitoring streamflows will be no less than 55 cfs;
2. Reduced streamflow shall not exceed 10 consecutive days;
3. Up and down ramping rates during this period will be limited to n o more than
100 cfs per hour;
4. Reduced streamflow may only be commenced if no whitewater boating flow
releases have occurred for seven consecutive days;
Each year that monitoring occurs, PG&E shall provide the Agencies with the
specific proposed schedule at least 45 days prior to monitoring. Agencies will
have 15 days to comment on the schedule, and if any agency proposes an
Kimberly D. Bose, Secretary
August 24, 2022
Page 3
alternative schedule, PG&E will convene a conference call with the Agencies to
develop a revised schedule.
The Plan outlines the following survey method:
Fish population monitoring will be conducted using methods similar to those
currently used in the Rock Creek-Cresta Project (PG&E 2018). Where
appropriate, modifications to the methodology are based on efficiencies gained
from sampling in the Rock Creek-Cresta Project and limited safe access to the
Poe Bypass Reach. Specifically, fish population surveys will employ
electrofishing and direct observation methodologies.
Table 1 below provides the locations of all fish and BMI monitoring sites included in the
Plan.
Table 3: Locations of Poe Fish and BMI Monitoring Sites
Site ID Site Description Reach Type Monitoring
Conducted
Approximate
Upstream
Location
(UTM NAD 83)
PD-B Below
Poe Dam Regulated Fish/BMI 10S 064030
4407661
BB-B Bardee’s
Bar Regulated Fish/BMI 10S 0632281
4403580
PB-B Poe
Beach Regulated Fish/BMI 10S 0631333
4399175
EB-B
East Branch of North
Fork
Feather River
Unregulated BMI 10 S 0664699
4431124
MB-B Millsap Bar on Middle
Fork Feather River Unregulated BMI 10 S 0648328
4396628
SC-B
Stag Creek on the
Middle
Fork Feather River
Unregulated BMI 10 S 0664463
4406400
Background
In 2020 and 2021, PG&E requested and received approval concurrence from the
agencies, and approval from FERC, to reduce minimum streamflows under the
conditions stated in the Plan to allow a safe working environment for the field team .
During the March 31, 2022, Condition No. 3 meeting with the Forest Service, PG&E
proposed lowering flows to 55 cfs from the afternoon of September 18, 2022, to the
afternoon of September 28, 2022 (Table 4). The flows will be decreased for 10 days in
Kimberly D. Bose, Secretary
August 24, 2022
Page 4
total but will be returned to baseflow sooner if work is completed earlier. Ramping rates
of no more than 100 cfs per hour in both reaches will be implemented to avoid
stranding. PG&E proposed this same schedule to the Agencies on July 19, 2022.
Agencies concurred with this variance via email (Enclosure 1). This proposal is
consistent with the proposal for 2021, which was approved by FERC order on
September 1, 2021.
Table 4: Proposed Reduced River Flow for 2021 Monitoring
Date Flow
Sept. 18 – Sept. 28 55 cfs
On February 9, 2022, PG&E and the Agencies met to discuss the challenges that PG&E
has faced while implementing the Sediment Management Plan, Poe Tributary Access
Monitoring Plan, and Plan. Part of that discussion concerned the BMI reference site at
Stag Creek, which has been deemed unsafe by PG&E because of recent wildfire
activities. The Agencies agreed to use a new reference site at Yellow Creek; however,
monitoring at Yellow Creek is contingent upon the Forest Service making that site
accessible before the 2022 BMI monitoring commences. Yellow Creek is still not
accessible. For this reason, PG&E proposed replacing the Yellow Creek BMI monitoring
for 2022 with monitoring at Stag Creek. PG&E formally made this proposal to the
Agencies on July 19, 2022, and they concurred with the variance via email (Enclosure
1).
On February 9, 2022, PG&E and the Agencies also discussed the risks associated with
the backpack electrofishing methodology at the Bardees Bar site. During the 2021 fish
sampling event, electrofishing at the Bardees Bar site was ineffective and unsafe due to
the depth of the reach. The Agencies agreed to grant a variance that would replace
electrofishing with snorkeling. PG&E formally proposed replacing the 2022 backpack
electrofishing methodology with snorkeling at the Bardees Bar Site to the Agencies via
email on July 19, 2022. Agencies concurred with the variance via email (Enclosure 1).
Milsap Bar was closed in a USDA Forest Service, Plumas National Forest, Fire
Emergency Road and Trail Closure Order No. 05-11-03-21-04 on February 19, 2021.
Following that closure, PG&E consulted with the Forest Service on safe access to the
monitoring site. The Forest Service stated that the campground is safely accessible;
however, reaching the location of the monitoring site would require chainsaws and/or
side-by-side clearing. Since Milsap Bar is located outside of the FERC boundary on
Forest Service lands, PG&E does not have the ability to clear a path to create safe
access for monitoring. In a July 19, 2022, email to the Agencies, PG&E proposed to not
monitor at Milsap Bar in 2022. The Agencies concurred with this variance via email
(enclosure 1).
Kimberly D. Bose, Secretary
August 24, 2022
Page 5
Temporary Variance Request
PG&E is respectfully requesting a variance to:
1. Temporarily lower flows to 55 cfs, from September 18, 2022, through September
28, 2022
2. Replace the BMI monitoring site of Stag Creek with Yellow Creek
3. Replace the backpack electrofishing methodology with snorkeling at the Bardees
Bar site.
4. Not monitor Milsap Bar
Since sampling begins September 18, 2022, PG&E respectfully requests FERC
approval by September 17, 2022. If you have questions or comments regarding this
matter, please contact Sky Ramirez-Doble, license coordinator for PG&E, at (530) 250-
7002.
Sincerely,
Elisabeth Rossi,
Supervisor, Hydro License Compliance
Enclosures:
1. Agency Concurrence
From:McCready, Chadwick
To:McCready, Chadwick
Subject:Variance Request Poe 2022 Fish and BMI Monitoring- Record of Consultation
Date:Tuesday, August 23, 2022 9:24:18 AM
Attachments:image001.png
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Thanks for the reminder and apologies for missing these Sky. State Water Board staff also concur with:
Temporarily lowering flows to 55 cfs for fish and BMI monitoring
Sampling BMI at Yellow Creek instead of Stag Creek
Replacing backpack electrofishing with snorkeling at Bardees Bar
Savannah Downey (she/her)
State Water Resources Control Board
Water Quality Certification Program
From: Moghaddas, Emily - FS <emily.moghaddas@usda.gov>
Sent: Tuesday, August 23, 2022 8:41 AM
To: Ramirez-Doble, Sky <S9RV@pge.com>; Downey, Savannah@Waterboards
<Savannah.Downey@Waterboards.ca.gov>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>; Bartoo,
Aondrea <aondrea_bartoo@fws.gov>; Lind, Amy -FS <amy.lind@usda.gov>; Lawson, Beth@Wildlife
<Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
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Hello Sky,
The Forest Service approves PG&E’s request for a variance of instream flow requirements, under the Poe
Hydrologic Project License (FERC No. 2107), as described in the trailing emails below. For the monitoring work, we
understand that flows in the Poe reach of the North Fork Feather River will be temporarily reduced to 55 cfs from
September 18, 2022 through September 28, 2022.
Forest Service agrees to replacing the BMI monitoring site of Stag Creek with Yellow Creek, and replacing the
methodology with snorkeling at Bardees Bar.
Due to current safety and access concerns, we agree to the variance at Milsap Bar.
Thank you,
Emily Moghaddas
Acting Deputy Forest Supervisor
Forest Service
Plumas National Forest, Supervisor's Office
p: 530-283-7772
c: 530-927-7439
emily.moghaddas@usda.gov
159 Lawrence St.
Quincy, CA 95971
www.fs.fed.us
Caring for the land and serving people
From: Ramirez-Doble, Sky [mailto:S9RV@pge.com]
Sent: Monday, August 22, 2022 7:07 PM
To: Downey, Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>; Maher, Michael@Wildlife
<Michael.Maher@wildlife.ca.gov>; Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Lind, Amy -FS
<amy.lind@usda.gov>; Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife
<Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
Thank you Savannah and Michael!
@Savannah does the SWRCB approve of the other three variances too? If you’ve already sent a response for those,
please forgive me. I couldn’t find an approval email from the SWRCB. For reference, the other three variances are:
1. Temporarily lower flows to 55 cfs, from September 18, 2022 through September 28, 2022
2. Replace the BMI monitoring site of Stag Creek with Yellow Creek
3. Replace the backpack electrofishing methodology with snorkeling at the Bardees Bar site.
Please see the first email in this chain for more information.
With gratitude,
Sky Ramirez-Doble
He/Him/His
Hydro License Coordinator | Power Generation
Pacific Gas & Electric Company
c: (530) 250-7002 e: s9rv@pge.com
From: Downey, Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>
Sent: Friday, August 19, 2022 9:23 AM
To: Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>; Ramirez-Doble, Sky <S9RV@pge.com>; Bartoo,
Aondrea <aondrea_bartoo@fws.gov>; Lind, Amy -FS <amy.lind@usda.gov>; Moghaddas, Emily - FS
<emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
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Hello Sky – State Water Board staff concur with a temporary variance to riparian and BMI monitoring at Millsap Bar
due to safety concerns.
Savannah Downey (she/her)
State Water Resources Control Board
Water Quality Certification Program
From: Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>
Sent: Friday, August 19, 2022 8:44 AM
To: Ramirez-Doble, Sky <S9RV@pge.com>; Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Downey,
Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>; Lind, Amy -FS <amy.lind@usda.gov>;
Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
EXTERNAL:
Hello Sky,
CDFW concurs with the PG&E request for a temporary riparian and BMI monitoring sample site variance at Millsap
Bar due to the current lack of safe access for monitoring.
Michael Maher
Region 2 FERC Coordinator | ( Cell: 916-597-5505
California Department of Fish & Wildlife | North Central Region
1701 Nimbus Road, Rancho Cordova | michael.maher@wildlife.ca.gov
From: Ramirez-Doble, Sky <S9RV@pge.com>
Sent: Wednesday, August 17, 2022 8:59 AM
To: Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>;
Downey, Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>; Lind, Amy -FS <amy.lind@usda.gov>;
Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
Importance: High
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Hi all,
Following up on this as PG&E has received only one response since adding Milsap Bar to the variance request. As
this must to go to FERC prior to altering flows, please respond with concurrence or comments as soon as possible.
With gratitude,
Sky Ramirez-Doble
He/Him/His
Hydro License Coordinator | Power Generation
Pacific Gas & Electric Company
c: (530) 250-7002 e: s9rv@pge.com
From: Bartoo, Aondrea <aondrea_bartoo@fws.gov>
Sent: Friday, August 5, 2022 8:12 AM
To: Ramirez-Doble, Sky <S9RV@pge.com>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>; Downey,
Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>; Lind, Amy -FS <amy.lind@usda.gov>;
Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife <beth.lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: Re: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
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USFWS agrees to the temporary site variance for Millsap Bar due to the unsafe access conditions.
A. Leigh Bartoo
US Fish and Wildlife Service
Bay-Delta Fish and Wildlife Office
650 Capitol Mall, Suite 8-300
Sacramento, California 95814
916-930-5621
*packages can no longer be mailed to the above address. Please contact me through email if you have an
item to mail to me.
Pronouns: she/her/hers
Please contact me by email while staff are working from home.
From: Ramirez-Doble, Sky <S9RV@pge.com>
Sent: Thursday, August 4, 2022 4:31 PM
To: Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>; Bartoo, Aondrea <aondrea_bartoo@fws.gov>;
Downey, Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>; Lind, Amy -FS <amy.lind@usda.gov>;
Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife <beth.lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
Hi all,
In addition to the three temporary variances listed in the email correspondence below, PG&E respectfully requests
a temporary sample site variance for monitoring at Milsap Bar for the 2022 riparian and BMI monitoring, which is
required under the Poe Hydroelectric Project, Federal Energy Regulatory Commission (FERC) No. 2107 license. This
variance is needed for the safety of PG&E personnel and contractors.
License Requirement
The Poe Bypass Reach Project Fish and BMI Monitoring Plan and Poe Riparian Monitoring Plan require surveys at
Milsap Bar. Table 1 below provides the approximate upstream location of the Milsap Bar BMI and riparian
monitoring site.
Site ID Site Description Reach Type Monitoring
Conducted
approximate
Upstream Location
(UTM naD 83)
MB-B Millsap Bar on
Middle Fork
Feather River
Unregulated BMI and Riparian 10 S 0664463
4406400
Background
Milsap Bar was closed in a USDA Forest Service, Plumas National Forest, Fire Emergency Road and Trail Closure
Order No. 05-11-03-21-04 on February 19, 2021. Following that closure, PG&E consulted with the Forest Service on
safe access to the monitoring site. The Forest Service stated that the campground is safely accessible; however,
reaching the location of the monitoring site would require chainsaws and/or side-by-side clearing (attached). Since
Milsap Bar is located outside of the FERC boundary on Forest Service lands, PG&E does not have the ability to clear
a path to create safe access for monitoring.
variance Request
To ensure the safety of the field crew personnel, PG&E respectfully requests a temporary sampling site variance for
the 2022 riparian and BMI monitoring. Please respond with comments or approval as soon as possible, but no later
than September 4, 2022.
If you have any questions regarding this monitoring or variance request, please let me know.
Sky Ramirez-Doble
He/Him/His
Hydro License Coordinator | Power Generation
Pacific Gas & Electric Company
c: (530) 250-7002 e: s9rv@pge.com
From: Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>
Sent: Tuesday, July 26, 2022 11:00 AM
To: Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Ramirez-Doble, Sky <S9RV@pge.com>; Downey,
Savannah@Waterboards <Savannah.Downey@Waterboards.ca.gov>; Lind, Amy -FS <amy.lind@usda.gov>;
Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: RE: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
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Hello Sky,
As discussed at previous meetings and following requests from PG&E in previous years, CDFW concurs with:
1. The temporary flow variance request to accommodate fish and BMI sampling under the conditions described
in the monitoring plan,
2. changing the BMI sampling site from Stag Creek to Yellow Creek, and
3. performing snorkel surveys at the Bardees Bar site in lieu of backpack electrofishing.
CDFW would also like to know the process and schedule PG&E proposes for updating the monitoring plan with
items two and three of the variance request.
Thank you Sky,
Michael Maher
Region 2 FERC Coordinator | ( Cell: 916-597-5505California Department of Fish & Wildlife | North Central Region
1701 Nimbus Road, Rancho Cordova | michael.maher@wildlife.ca.gov
From: Bartoo, Aondrea <aondrea_bartoo@fws.gov>
Sent: Tuesday, July 26, 2022 7:52 AM
To: Ramirez-Doble, Sky <S9RV@pge.com>; Downey, Savannah@Waterboards
<Savannah.Downey@Waterboards.ca.gov>; Lind, Amy -FS <amy.lind@usda.gov>; Moghaddas, Emily - FS
<emily.moghaddas@usda.gov>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>; Lawson,
Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: Re: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
WARNING: This message is from an external source. Verify the sender and exercise caution when clicking links or opening
attachments.
The USFWS agrees with the requested variance to reduce flow in the NFFR from Sept 18-28 to 55cfs,
perform BMI sampling at Yellow Creek instead of Stag Creek, and to use snorkeling instead of backpack
electrofishing at the Bardees Bar site.
A. Leigh Bartoo
US Fish and Wildlife Service
Bay-Delta Fish and Wildlife Office
650 Capitol Mall, Suite 8-300
Sacramento, California 95814
916-930-5621
*packages can no longer be mailed to the above address. Please contact me through email if you have an
item to mail to me.
Pronouns: she/her/hers
Please contact me by email while staff are working from home.
From: Ramirez-Doble, Sky <S9RV@pge.com>
Sent: Tuesday, July 19, 2022 2:16 PM
To: Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Savannah Downey <Savannah.Downey@Waterboards.ca.gov>;
Lind, Amy -FS <amy.lind@usda.gov>; Moghaddas, Emily - FS <emily.moghaddas@usda.gov>; Maher,
Michael@Wildlife <Michael.Maher@wildlife.ca.gov>; Lawson, Beth@Wildlife <beth.lawson@wildlife.ca.gov>
Cc: McCready, Chadwick <COMM@pge.com>; Joseph, Matthew <MWJA@pge.com>; Reyes, Catalina
<CERh@pge.com>
Subject: [EXTERNAL] Variance Request Poe 2022 Fish and BMI Monitoring
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Dear Resource Agencies,
Pacific Gas and Electric Company (PG&E) respectfully requests a temporary flow, sample site, and sample
methodology variance for the 2022 Poe fish and benthic macroinvertebrate (BMI) monitoring, required under the
Poe Bypass Reach Project Fish and BMI Monitoring Plan (Plan), which was created pursuant to the Federal Energy
Regulatory Commission (FERC) No. 2107 license. These variances are necessary to allow a safe working environment
for the field team and are consistent with variances previously approved for the Poe fish and BMI monitoring.
License Requirements
The Plan states the following requirements for modifying streamflows:
PG&E may reduce streamflows defined in, and in accordance with any other requirements of, SWRCB WQC
Condition 1, Forest Service 4(e) Condition No. 23, and FERC License Article 401(c) to implement this [Fish
and BMI] monitoring Plan under the following conditions:
1. Monitoring will occur between September 15 to October 15, with a goal to complete monitoring by
the end of September, whenever possible;
1. Monitoring streamflows will be no less than 55 cfs;
2. Reduced streamflow shall not exceed 10 consecutive days;
3. Up and down ramping rates during this period will be limited to no more than 100 cfs per hour;
4. Reduced streamflow may only be commenced if no whitewater boating flow releases have
occurred for seven consecutive days;
Each year that monitoring occurs, PG&E shall provide the agencies with the specific proposed schedule at
least 45 days prior to monitoring. Agencies will have 15 days to comment on the schedule, and if any agency
proposes an alternative schedule, PG&E will convene a conference call with all agencies to develop a revised
schedule.
The Plan outlines the following survey method:
Fish population monitoring will be conducted using methods similar to those currently used in the Rock
Creek-Cresta Project (PG&E 2018). Where appropriate, modifications to the methodology are based on
efficiencies gained from sampling in the Rock Creek-Cresta Project and limited safe access to the Poe Bypass
Reach. Specifically, fish population surveys will employ electrofishing and direct observation methodologies.
Table 1 below provides the locations of all fish and BMI monitoring sites included in the Plan.
Table 1: Locations of Poe Fish and BMI Monitoring Sites
Site ID
Site Description
Reach Type Monitoring
Conducted
approximate Upstream
Location
(UTM naD 83)
PD-B Below Poe Dam Regulated Fish/BMI 10S 064030 4407661
BB-B Bardee’s Bar Regulated Fish/BMI 10S 0632281 4403580
PB-B Poe Beach Regulated Fish/BMI 10S 0631333 4399175
EB-B East Branch of North Fork
Feather River
Unregulated BMI 10 S 0664699 4431124
MB-B Millsap Bar on Middle Fork
Feather River
Unregulated BMI 10 S 0648328 4396628
SC-B Stag Creek on the Middle Fork
Feather River
Unregulated BMI 10 S 0664463 4406400
Background
PG&E has requested and received approval from the agencies, and FERC, to reduce minimum streamflows, under
the conditions stated in the Plan, in 2020 and 2021. During the 2022 Condition No. 3 meeting with the Forest
Service, PG&E proposed lowering flows to 55 cfs from the afternoon of September 18, 2022, to the afternoon of
September 28, 2022. Following that meeting, no comments were received on this proposal. PG&E is proposing the
same schedule to all agencies. The flows would be decreased for 10 days in total but will be returned to baseflow
sooner, if work is completed earlier. Ramping rates of no more than 100 cfs per hour in both reaches will be
implemented to avoid stranding. This proposal is consistent with that of the proposal for 2021, which was
unanimously approved by all agencies and FERC.
On February 9, 2022, PG&E and the agencies met to discuss the challenges that PG&E has been facing while
implementing the Sediment Management Plan, Poe Tributary Access Monitoring Plan, and Plan. Part of that
discussion concerned the BMI reference site at Stag Creek, which has been deemed unsafe by PG&E because of
recent wildfire activities. All agencies adopted the resolution to use a new reference site at Yellow Creek; however,
monitoring at Yellow Creek is contingent upon the Forest Service making that site accessible before the 2022 BMI
monitoring commences. A summary of this conversation can be found in the March 2, 2022 email titled Follow Up-
FERC No.2107 Poe Biological Plan (attached; highlighted in yellow).
On February 9, 2022, PG&E and the agencies also discussed the risks associated with the backpack electrofishing
methodology at the Bardees Bar site. During the 2021 fish sampling event, electrofishing at the Bardees Bar site was
ineffective and unsafe due to the depth of the reach. All agencies agreed to grant a variance that would replace
electrofishing with snorkeling. A summary of this conversation can be found in the March 2, 2022 email titled Follow
Up- FERC No.2107 Poe Biological Plan (attached; highlighted in blue).
variance Request
Pursuant to the meeting on February 9, 2022, and the requirements of the Plan, PG&E is respectfully requesting a
variance to:
1. Temporarily lower flows to 55 cfs, from September 18, 2022 through September 28, 2022
2. Replace the BMI monitoring site of Stag Creek with Yellow Creek
3. Replace the backpack electrofishing methodology with snorkeling at the Bardees Bar site.
Per the Plan, “agencies will have 15 days to comment on the schedule, and if any agency proposes an alternative
schedule, PG&E will convene a conference call with all agencies to develop a revised schedule.” PG&E respectfully
requests comment or approval of these variances 15 days from the date of this email, August 3, 2022. If you have
any questions regarding this monitoring or variance request, please let me know.
With gratitude,
Sky Ramirez-Doble
He/Him/His
Hydro License Coordinator | Power Generation
Pacific Gas & Electric Company
c: (530) 250-7002 e: s9rv@pge.com
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