HomeMy WebLinkAbout04.30.2024 Board Correspondence - FW_ Government Agency Submittal submitted in FERC P-803-121 by California Department of Fish and Wildlife,et al.From:Clerk of the Board
To:Bennett, Robin; Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Hancock, LeAnne; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Lee, Lewis; McDonnell, Susan; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney,
Kathleen; Teeter, Doug; Zepeda, Elizabeth; Loeser, Kamie
Cc:Nevers, Dawn
Subject:Board Correspondence - FW: Government Agency Submittal submitted in FERC P-803-121 by California Department of Fish and Wildlife,et al.
Date:Tuesday, April 30, 2024 4:45:27 PM
Please see Board correspondence -
-----Original Message-----
From: 'FERC eSubscription' <eSubscription@ferc.gov>
Sent: Tuesday, April 30, 2024 12:55 PM
Subject: Government Agency Submittal submitted in FERC P-803-121 by California Department of Fish and Wildlife,et al.
.ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying..
On 4/30/2024, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.:
Filer: California Department of Fish and Wildlife
California Department of Fish and Wildlife (as Agent)
Docket(s): P-803-121
Lead Applicant: Pacific Gas and Electric Company
Filing Type: Government Agency Submittal
Description: California Department of Fish and Wildlife submits comments on recommendations for additional mitigation and monitoring following the Butte Canal failure at the Desabla-Centerville Hydroelectric Project under P-
803.
To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20240430-
5317__;!!KNMwiTCp4spf!GDaLdu_NjkwDZveDGbNcaY8uGFZjbYsMClEk1DdoEnq5ioJEoFFU797NKQJ46oNto_t0MM5rT2p1UXDLTEZSepOE2eJt7HgvIIfJ$
To modify your subscriptions, click here:
https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!GDaLdu_NjkwDZveDGbNcaY8uGFZjbYsMClEk1DdoEnq5ioJEoFFU797NKQJ46oNto_t0MM5rT2p1UXDLTEZSepOE2eJt7FjuM_pa$
------------------------------------------------------------------------
Please do not respond to this email.
Online help is available here:
https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!GDaLdu_NjkwDZveDGbNcaY8uGFZjbYsMClEk1DdoEnq5ioJEoFFU797NKQJ46oNto_t0MM5rT2p1UXDLTEZSepOE2eJt7A90DkAZ$
or for phone support, call 866-208-3676.
State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, Director North Central Region 1701 Nimbus Road Rancho Cordova, CA 95670 www.wildlife.ca.gov April 30 , 2024 Debbie-Anne Reese, Acting Secretary Federal Energy Regulatory Commission 888 First Street, NE, Room 1A Washington, D.C. 20426 SUBJECT: CALIFORNIA DEPARTMENT OF FISH & WILDLIFE ADDITIONAL
COMMENTS ON THE BUTTE CANAL FAILURE INCIDENT : DESABLA-CENTERVILLE HYDROELECTRIC PROJECT - FERC PROJECT NO. 803-121 Dear Debbie-Anne Reese: The California Department of Fish and Wildlife (CDFW ) is providing comments regarding
recommendations for additional mitigation and monitoring following the Butte Canal failure
and subsequent sediment deposition and turbidity events in Butte Creek. As described in CDFW’s January 25 and March 26 , 2024 letters, the erosion event from
the Butte Canal failure and subsequent sediment deposition and high turbidity in Butte
Creek impacted multiple life history stages of Central Valley spring-run Chinook salmon (SRCS; Oncorhynchus tshaw ytscha ) and foothill yellow-legged frog (FYLF; Rana boylii), both of which are State and federally threatened, Central Valley steelhead (O. mykiss ), a
State fish species of special concern and federally threatened species, as well as other
native aquatic species. Temperature Mitigation During the Summer of 2024 During a meeting on April 3 , 2024 Pacific Gas and Electric Company (PG&E) confirmed
that they will be unable to return the Butte Canal to service during 2024 . Additionally, at this meeting, PG&E stated that Round Valley Reservoir will be operated at a lower-than-normal maximum elevation (and storage) during the summer period due to safety
concern s. Specifically, storage in Round Valley Reservoir will be reduced by 400 acre-feet,
lowering the normal combined capacity of Round Valley Reservoir and Philbrook
Reservoirs from 6200 acre-feet (1200 and 5000 ac re-feet, respectively) to 5,800, thereby
reducing the amount of water available for temperature management over summer in the
SRCS holding reaches of Butte Creek. The combined storage of the two reservoirs is
managed by PG&E each summer to both generate hydropower and provide additional
inter-basin water to Butte Creek during summer months . Those normal operations are described each year in the DeSabla Centerville Project Operations an d Maintenance Plan .
The combination of a reduction in available water storage , and additional heating that can
be expected with taking Butte Canal offline (described in CDFW’s March 26, 2024 letter)
have the potential to increase temperatures in Butte Creek and impact holding adult
SRCS. Warmer water temperatures have compounding effects on fish stress and increase
disease susceptibility and transmission. SRCS production in the Central Valley has
declined drastically over the last few years due to extended drought conditions , and CDFW
is concerned about a potential collapse of the Butte Creek population , one of only three remaining genetically independent and self-sustaining Central Valley SRCS populations . In our March 26, 2024 filing, CDFW request ed that FERC require PG&E to repair and return
the Butte Canal to service prior to summer 2024 or provide an alternative Project operation
to deliver cool water to the SRCS holding reaches June through September 2024 . In this
letter, we recommend short and long-term solutions to help mitigate the project-affected
temperature impacts during the planned operational deviations . As a part of an investigation of methods to cool water through the Butte Creek system,
DeSabla Forebay has been identified as a source of additional heating in the system (see
PG&E 1994). Both CDFW’s 2008 10(j) requirements and the State Water Resources
Control Board ’s (SWRCB) 2016 Water Quality Certification for the DeSabla Centerville
Hydroelectric Project (Project) FERC license require PG&E to file a DeSabla Forebay
Water Temperature Improvement Plan (Temperature Improvement Plan) that will describe
Document Accession #: 20240430-5317 Filed Date: 04/30/2024
Debbie-Anne Reese April 30 , 2024 Page 2 how the DeSabla Water Temperature Reduction Device will reduce the thermal loading
within the DeSabla Forebay by an average of 80 pe rcent or greater. A documented phone
conversation between FERC and PG&E staff and follow-up filing (FERC filing accession
number 20090619-5080) demonstrates that PG&E has already developed and costed
plans for a “baffle wall and pipeline option ”. CDFW staf f have been advocating for this
temperature improvement measure since filing our final 10j conditions in 2008 . These
important temperature management plans have never moved forward as the final licensing
of this project was stalled when PG&E attempted to s ell th e Project . At this time, due to the inability of PG&E to return Bu tte Canal to service following
the failure event, CDFW requests for FERC to require PG&E to move forward with
the following actions without further delay: Short Term : Design and construct a temporary “baffle wall” or temperature curtain along the shore of
DeSabla Forebay to “short-circuit” water from the entrance to the penstock intake to
reduce residence time and heating through the forebay. CDFW has additionally learn ed that PG&E does not plan to conduct FYLF monitoring
during 2024. As noted in our March 26, 2024 letter, multiple life stages of FYLF were
present during the time of the canal failure and impacted by the subsequent sedimentation
and high turbidity event i n Butte Creek. CDFW requests that FERC require PG&E to
conduct comprehensive surveys for FYLF in coordination with CDFW and U.S. Fish and
Wildlife Service at up to seven locations in Butte Creek during the spring and summer of
2024 to monitor the status of FYLF in the creek. Long Term : As contemplated in CDFW’s 2008 10(j) requirement s and SWRCB’s 2016 Water Quality
Certification for the Project, PG&E should immediately move forward with the d evelop ment
of a Temperature Improvement Plan for DeSabla Forebay , with a goal of completing a
draft with provision for review within six months . The draft Temperature Improvement Plan
shall include preliminary designs, a schedule for final design, permitting, and construction
of a proposed Water Temperature Reduction F acility within the DeSabla Forebay that
would reduce the thermal loading within the DeSabla Forebay by ≥ 80%, which is
equivalent ≤ 0.2°C, during the summer period. The heat gain shall be measured as the
change in temperature between stations BTC3 (Toadtow n Canal above DeSabla Forebay)
and DSPH (DeSabla Powerhouse). PG&E shall provide the draft Temperature
Improvement Plan to CDFW, SWRCB, U.S. Fish and Wildlife Service , NOAA Fisheries,
and the U.S. Forest Service for a 60-day review period and incorporate the Resource
Agencies comments into a Final DeSabla Forebay Water Temperature Improvement Plan
within an additional 60-day completion period. PG&E shall file the final Temperature
Improvement Plan, including evidence of Resource Agency cons ultation and rationale for
the exclu sion of any Resource Agency recommendations , with FERC at the end of the 60-day period. PG&E shall implement the final Temperature Improvement Plan upon approval
by FERC. If you have any questions regarding this letter , please contact Lt. Kaitlin Kraft at (559) 646-4053 or Kaitlin.Kraft @wildlife.ca.gov. Sincerely, Erica Manes – Assistant Chief Law Enforcement Division References PG&E. 1994. DeSabla-Centerville Project, FERC No. 803. Water Temperature Monitoring
Study, License Article 402. Document Accession #: 20240430-5317 Filed Date: 04/30/2024
Document Content(s)
CDFW Signed Temperature Mitigation Request.pdf ...........................1Document Accession #: 20240430-5317 Filed Date: 04/30/2024