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HomeMy WebLinkAbout07.30.25 Board Correspondence_ FW_ DOCKET CHANGE- Environmental and Recreational Compliance Report submitted in FERC P-803-124 by Pacific Gas and Electric Company,et al.From:Clerk of the Board To:Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Krater, Sharleen; Little, Melissa; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug Cc:Loeser, Kamie; Nuzum, Danielle Subject:Board Correspondence: FW: DOCKET CHANGE- Environmental and Recreational Compliance Report submitted in FERC P-803-124 by Pacific Gas and Electric Company,et al. Date:Wednesday, July 30, 2025 1:27:58 PM Please see Board Correspondence -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Wednesday, July 30, 2025 12:35 PM Subject: DOCKET CHANGE- Environmental and Recreational Compliance Report submitted in FERC P-803-124 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 5/19/2025, 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-803-124 Lead Applicant: Pacific Gas and Electric Company Filing Type: Environmental and Recreational Compliance Report Description: Pacific Gas and Electric Company submits Foothill Yellow-Legged Frog Monitoring Plan with Contingent Mitigation re the DeSabla-Centerville Hydroelectric Project under P-803. 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Box 28209 Oakland, CA 94604 May 19, 2025 Via Electronic Submittal (E-File) Debbie-Anne Reese, Acting 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 Foothill Yellow-Legged Frog Monitoring Plan with Contingent Mitigation Dear Secretary Reese: This letter presents the Foothill Yellow-legged Frog Study Plan: Butte Creek 2025-2028 (Plan) with Contingent Mitigation to the Federal Energy Regulatory Commission’s (FERC) for Pacific Gas and Electric Company’s (PG&E) DeSabla-Centerville Hydroelectric Project, FERC No. 803. On November 19, 2024, FERC issued a Notice of Violation (NOV) for the 2023 Incidents. This NOV requires PG&E to develop a monitoring plan, with contingency mitigation, for foothill yellow-legged frog (FYLF) in consultation with the California Department of Fish and Wildlife (CDFW) and the United States Fish and Wildlife Service (USFWS). The following sections provide a summary of the NOV requirements and the consultation history. NOV Requirements Concerning FYLF monitoring, the NOV states: To better assess the degree of adverse effect to FYLF in Butte Creek, we are requiring that you coordinate with the FWS and California DFW to conduct an ongoing FYLF population assessment to compare with the 2006 monitoring effort. Within 90 days, you must file a plan for additional FYLF monitoring in Butte Creek. The plan should also contain a contingency for mitigation to the Butte Creek FYLF population if monitoring confirms a significant loss of FYLF from the 2023 canal failure and sediment event. The plan must also contain documentation of consultation with the FWS and California DFW. FYLF Monitoring PG&E met with USFWS and CDFW to consult on a plan for additional FYLF monitoring in Butte Creek on January 13, 2025, March 27, 2025, and April 10, 2025. Prior to and following these meetings PG&E updated and shared the Foothill Yellow-legged Frog Study Plan: Butte Creek 2025-2028 in response to USFWS and CDFW’s comments. All written comments, PG&E organized into a comment matrix. This lists USFWS’s and CDFW’s Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Debbie-Anne Reese, Acting Secretary May 19, 2025 Page 2 comments, PG&E’s responses, and the date received. The consultation record prior to February 18, 2025, the date PG&E submitted a 90-day update on progress, can be found in that letter. Conclusion FERC’s NOV requires PG&E to develop an FYLF monitoring plan, with contingency mitigation. These efforts were to be completed in consultation with the agencies. PG&E has worked closely with the agencies on this FYLF monitoring and continency mitigation. PG&E respectfully requests FERC’s approval of the Plan by July 18, 2025, so that the Plan is final, and PG&E can begin monitoring. The Plan is provided as (Enclosure 1). A comment matrix is provided as (Enclosure 2). Documentation of agency consultation is provided as (Enclosure 3). If you have questions or comments regarding this matter, please contact Sky Ramirez- Doble, license coordinator for PG&E, at (530) 250-7002. Sincerely, Janet Walther Director, Hydro Licensing Management Enclosures: 1. Foothill Yellow-legged Frog Study Plan: Butte Creek 2025-2028 2. Comment Matrix 3. Documentation of agency consultation cc: via email w/enclosures Brittany Reaves, USFWS Brittany_reaves@fws.gov Anna Allison, CDFW Anna.allison@wildlife.ca.gov Leslie Alber, CDFW Leslie.Alber@wildlife.ca.gov Aondrea Bartoo, USFWS aondrea_bartoo@fws.gov Stephanie Millsap, USFWS stephanie_millsap@fws.gov Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Public ENCLOSURE 1 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 May 15, 2025 May 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Citation: Pacific Gas and Electric Company. 2025. Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028. May 2025. Prepared by Pacific Gas and Electric Company, Oakland, CA, and Stillwater Sciences, Berkeley, CA. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents i May 2025 ©2025, Pacific Gas and Electric Company TABLE OF CONTENTS 1.0 Introduction ....................................................................................................... 1-1 2.0 Study Site Selection .......................................................................................... 2-1 3.0 Methods............................................................................................................. 3-1 3.1 Habitat Assessments and Transects ..................................................................... 3-1 3.2 Visual Encounter Surveys .................................................................................... 3-1 3.3 Vegetation Encroachment Assessments .............................................................. 3-2 3.4 Decontamination Protocols .................................................................................. 3-2 4.0 Reporting, Analysis, and Adaptive Management ............................................. 4-1 5.0 Analysis for Contingency Mitigation ................................................................ 5-1 5.1 Data Analysis ....................................................................................................... 5-1 5.1.1 Estimating Population Size ...................................................................... 5-1 5.1.2 Population Predictor Variable .................................................................. 5-2 5.1.3 Population Trends .................................................................................... 5-2 5.2 Significant Loss Evaluation ................................................................................. 5-2 6.0 References ......................................................................................................... 6-1 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents ii May 2025 ©2025, Pacific Gas and Electric Company LIST OF TABLES Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. .... 2-2 LIST OF FIGURES Figure 2-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. ........................................................................................................................... 2-3 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 1.0 Introduction 1-1 May 2025 ©2025, Pacific Gas and Electric Company 1.0 Introduction Foothill yellow-legged frog (Rana boylii; FYLF) in Butte Creek is listed as threatened as part of the North Feather Distinct Population Segment (USFWS 2023). The California Fish and Game Commission listed the Feather River clade of FYLF as threatened in 2020 (CFGC 2020). Butte Creek is also part of proposed critical habitat for North Fork Feather River Unit NF-1 (USFWS 2025). Historically, Butte Creek has supported a robust population of FYLF that may be significant for species recovery efforts, as well as a likely candidate for future reintroduction efforts (B. Reaves, USFWS, pers. comm., February 5, 2025). On August 10, 2023, the Butte Canal, part of the Pacific Gas and Electric Company’s (PG&E) DeSabla-Centerville Hydroelectric Project (FERC No. 803), breached. This 2025–2028 study is a continuation of the FYLF study on Butte Creek initiated in fall 2023 to evaluate the current population status of FYLF downstream of the sediment deposition area. The 2023 study consisted of surveys in late September and early October, at three study sites (BC-4, BC-6, and BC-12); one adult and 12 young-of-year (YOY) were documented at BC-4, and three adults and one tadpole were documented at BC-12 (PG&E and Stillwater Sciences 2023), indicating successful metamorphosis in Butte Creek. In 2024 the study expanded to include seven study sites (BC-3, BC-4, BC-6, BC-7, BC-8, BC-9, and BC-12) with three to four surveys occurring at each site, except BC-9, from June through September. BC-9 was removed after one visit due to safety concerns. Transect habitat assessments were conducted at each site across suitable breeding habitat, typically located in an area with higher concentrations of observed tadpoles and/or young-of-year. No egg masses were observed at any of the sites likely due to survey timing; however, approximately 1,809 tadpoles and approximately 131 YOY were observed at all six sites indicating successful breeding and recruitment occurred throughout Butte Creek in 2024. Seventeen adult and two juvenile frogs were observed at all sites except BC-12 (PG&E and Stillwater Sciences 2025). In order to compare breeding and recruitment in Butte Creek, which was potentially impacted by the canal breach and sediment deposition, with sites not impacted by the canal breach, two additional monitoring sites on West Branch Feather River (WBFR) will be added to the monitoring program beginning in 2025. The two sites, WBFR-1 and WBFR-2, were also surveyed as part of relicensing studies performed in 2006 and will act as non-impact control sites. WBFR sites have similar habitat conditions to Butte Creek sites and all FYLF life stages were observed in 2006. This 2025–2028 continuation study was developed in response to the Federal Energy Regulatory Commission Notice of Violation letter, dated November 19, 2024 (FERC 2024). The study will include visual encounter surveys and habitat assessments. These surveys were designed to: (1) determine if reproduction is occurring throughout Butte Creek after the breach; (2) determine if recruitment is successful in the system; and (3) to compare current occupation and numbers to historical (i.e., 2006) baseline data. In addition, statistical data analyses will be incorporated to evaluate if the Butte Canal breach caused a significant loss of the FYLF population in Butte Creek (Section 5). Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-1 May 2025 ©2025, Pacific Gas and Electric Company 2.0 Study Site Selection Studies will continue at six sites surveyed in 2024 (BC-3, BC-4, BC-6, BC-7, BC-8, and BC-12) and two sites surveyed in 2006 (BC-1 and BC-2), and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). Eight study sites located downstream of the sediment deposition area, in three different reaches, were selected for surveys (Table 2-1, Figure 2-1). These sites, which are located on PG&E, U.S. Bureau of Land Management (BLM), California Department of Fish and Wildlife, Mechoopda Indian Tribe of Chico Rancheria, and private lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and nearly all life stages of frogs were identified at each location 1. BC-9 was attempted in 2024 but determined to be unsafe to survey. Monitoring will begin in 2025 at two sites in WBFR (WBFR-1 and WBFR-2) and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). These sites, which are located on Lassen National Forest and BLM lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and all life stages of frogs were identified at each location. 1 No egg masses or tadpoles were observed at BC-1 and BC-2 during relicensing surveys in 2006. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-2 May 2025 ©2025, Pacific Gas and Electric Company Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. Reach Site Code Site Length (miles)a Description (2006a) Butte Creek Forks of Butte Diversion Dam Area BC-12 1.2 This long, low gradient site was composed of long low gradient riffles as well as short high gradient riffles and shallow runs. occurrences of bedrock. DeSabla Powerhouse BC-8 1.0 High gradient site with step-run, cascade and mid- channel pool habitats. bedrock, cobble, and boulder. BC-7 0.6 Site contained mid- riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-6 0.3 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. Centerville Powerhouse BC-4 0.5 Low gradient riffles and lateral scour pools were the patches. BC-3 0.3 This site was very low gradient, characterized by a shallow fast run with riffle habitat at the upstream end. Substrate was cobble and boulder. Banks were heavily vegetated. BC-2 1.1 The majority of gradient riffles, slow-moving runs, and deep pools. Substrate was cobble and boulder throughout with some large woody debris. BC-1 1.2 gradient riffles and runs, with few deep pools and slow-moving runs. boulder throughout. West Branch Feather River Upstream of Miocene Diversion WBFR-1 0.2 Slow lateral pools and mid- cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. At Jordan Hill Bridge WBFR-2 0.3 Slow lateral pools and mid- cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. a From PG&E 2008. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-3 May 2025 ©2025, Pacific Gas and Electric Company Figure 2-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-1 May 2025 ©2025, Pacific Gas and Electric Company 3.0 Methods Habitat assessments and population monitoring will be conducted based on procedures described in PG&E’s monitoring protocol A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii) (Seltenrich and Pool 2002, as previously revised). In addition to FYLF, all American bullfrogs (Lithobates catesbeianus) observed will be counted and their life stages recorded. Surveyors will record all other amphibian and reptile species and any potential predators (e.g., fish, crayfish) observed. 3.1 Habitat Assessments and Transects At the end of each survey, general habitat for the entire survey site will be characterized and the following additional information will be recorded: air and mid-channel water temperatures; associated tributaries; fish, predators, or other aquatic herpetofauna observed; and observable anthropogenic disturbance (i.e., mining, recreation). Photographs will be taken of the survey start and end points at the downstream and upstream ends of the site and of representative habitat throughout the site. To compare potential observable changes in habitat suitability across years, surveyors established one transect per survey site across suitable breeding habitat in 2023 and/or 2024, typically located in an area with higher concentrations of observed tadpoles and/or YOY FYLF. Similar transects will be established at BC-1, BC-2, WBFR-1, and WBFR-2 in 2025. The following physical characteristics will be measured or estimated across each transect: geomorphic unit type; aquatic substrate and substrate embeddedness; wetted width and bankfull width (measured with a rangefinder); turbidity (visual assessment); river and bank gradient; upland habitat type; percent aquatic cover; percent canopy; and percent margin, emergent, and submerged vegetation by type. Photos will be taken of each transect from one or both banks looking toward the channel, and mid- channel photos will be taken looking both upstream and downstream. 3.2 Visual Encounter Surveys Remote monitoring of flows at PG&E gages BW-97 and BW-98, and Department of Water Resources gage WFR (West Branch Feather River near Magalia) will begin April 15 of each year. Up to four breeding season surveys will target egg masses and begin as flows allow safe access to sites (i.e., below 200 cfs). Surveys at lower elevation sites may begin earlier than higher elevation sites if safely accessible earlier. Once breeding is confirmed, as egg masses or tadpoles are observed, each survey round will occur in intervals of 10–14 days, in order to capture new egg mass or tadpole groups. If egg masses are not observed at a site, an additional survey will be conducted during the tadpole rearing season. Two later-season surveys will be performed, one in August and one in September, to target YOY. Surveys will be conducted by teams of two-to-four surveyors working in tandem and moving upstream to maximize access to all shoreline habitats and minimize double counting. During egg mass surveys, one surveyor will snorkel in suitable habitat, as safe and feasible. Data collection will include location, life stage, Gosner stage (for egg Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-2 May 2025 ©2025, Pacific Gas and Electric Company masses), total length (for tadpoles), depth at observation (for egg masses and tadpoles), perch or attachment substrate, snout-urostyle length, sex (if known), body condition (e.g., emaciated, injured), dominant riparian type at observation, geomorphic unit at observation, nearest bank, plus Universal Transverse Mercator (UTM) coordinates (measured using handheld global positioning system [GPS] units) for all observations (groupings of multiple YOY are recorded as an approximate range in meters from an initial GPS waypoint). Photos, including chin photos for individual identification, will be taken. 3.3 Vegetation Encroachment Assessments Vegetation at each survey site will be assessed. If it is determined that vegetation encroachment may be impacting the suitability of a site for breeding and that localized removal of vegetation (e.g., willow, alder, blackberry) could enhance site suitability, small-scale removal efforts will be considered each fall. Consideration will be given to private property access and permitting needs, which may make it infeasible to complete vegetation removal at sites. 3.4 Decontamination Protocols Decontamination protocols will be employed as specified in handling permits, or using currently accepted protocols, to minimize the potential to spread invasive species (e.g., chytrid fungus). Decontamination of boots, waders, and equipment will be practiced for all surveys. In addition, some field gear (e.g., waders, boots) may be dedicated for use only in the Butte Creek and/or WBFR watersheds. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 4.0 Reporting, Analysis, and Adaptive Management 4-1 May 2025 ©2025, Pacific Gas and Electric Company 4.0 Reporting, Analysis, and Adaptive Management A technical report will be prepared by January 31 of each year following surveys, detailing survey methods and results, including a discussion of habitat assessments as well as any meaningful comparisons of survey results with 2006 results that would inform potential impacts of 2023 sediment inputs into Butte Creek. The technical report will also include a summary of prior information collected about FYLF on Butte Creek in previous years, including any incidental observations. Where data are available, the following information regarding FYLF sightings will be included: location where FYLF were observed, day/time of observation, number of each life stage present, survey methodology utilized (e.g., walking vs. snorkeling), mean streamflow (in cubic feet per second) at the time of the survey, water temperature from both thalweg and nearshore environments (where available), weather on the day of the survey, and turbidity observations. Bullfrog observations will be summarized and reported. After each monitoring season, preliminary data analyses will be conducted to look for trends that may inform early evaluation of significant loss (see Section 5). PG&E will inform and involve agencies in review of preliminary data modeling results to assess whether data trends are showing significant loss, or otherwise. Results may be incorporated into relevant early adaptive management (e.g., mitigation) strategies prior to completing the full monitoring term. If a significant loss inference is not made during the monitoring term, PG&E will meet with USFWS and CDFW after completion of the study and subsequent final reporting in 2029, to discuss the analysis of significant loss of FYLF with respect to the canal breach sediment deposition and to determine if mitigation is required. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Analysis for Contingency Mitigation 5-1 May 2025 ©2025, Pacific Gas and Electric Company 5.0 Analysis for Contingency Mitigation 5.1 Data Analysis To determine potential effects of the Butte Canal breach on the FYLF population in Butte Creek, VES data from eight study sites located downstream of the canal breach (BC-1 through BC-12; affected sites) as well as two sites on the WBFR (WBFR-1 and WBFR-2; control sites) will be analyzed to answer the following questions: 1. Population Predictor Variables: How do the predictor variables, including exposure to sediment deposition from the canal breach, influence differences in population size across the control and affected sites? 2. Population Trends: How are FYLF population trends and demographics influenced in the control versus affected sites post canal breach? 5.1.1 Estimating Population Size Depending on analysis needs, life stages detected throughout the monitoring period, as well as historical data available, population size will be estimated using one of the following methods or a comparable alternative: Egg mass density: FYLFs typically lay one discrete egg mass per year, and the number of egg masses has been used as an index of population size (Loman and Andersson 2007, as cited by Kupferberg et al. 2012). Egg masses may be readily visible on rocks (Kupferberg et al. 2012). Biologists will survey each monitoring reach during the FYLF breeding season to detect egg masses. Egg masses are a categorical response and can be analyzed using Bayesian ordinal models. We can estimate the probability of the number of egg masses per site and evaluate the influence of predictor variables on the number of egg masses. These models can estimate probabilities of numbers of egg masses even if sample size is low. If egg masses are regularly detected at both the control and affected reaches, and throughout the monitoring period, the density of egg masses (egg masses per kilometer) can also be used as an estimate for population size. Capture-recapture analysis: Chin pattern identification is an effective tool for identifying individual FYLFs (Marlow et al. 2016). The chin mottling patterns will be photographed for each adult and juvenile frog captured throughout the duration of the monitoring period. Capture- recapture analysis will be used to determine population estimates. The analysis will incorporate imperfect detection by including an estimated parameter for the probability of detection as well as covariates that may influence detection probability (e.g., sex, life stage, survey timing) based on the literature. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Analysis for Contingency Mitigation 5-2 May 2025 ©2025, Pacific Gas and Electric Company Repeated counts of all life stages: Hierarchical models for metapopulations will be used to determine population size estimates based on repeat surveys and counts of all life stages that may not be uniquely recognized (see Fiske and Chandler 2011 for example analysis). Similar to capture- recapture analysis, population estimate analysis will account for imperfect detection by estimating detection probability as well as covariates that may influence detection probability as appropriate. 5.1.2 Population Predictor Variable To estimate differences in population size and evaluate the influence of predictor variables on population size changes across the control and affected sites, Bayesian models (e.g., generalized additive or ordinal) will be used. Predictor variables derived from the literature, based on the objectives of the study and the data generating process, will be used to estimate their influence on FYLF population size (e.g., water year, habitat characteristics, presence of non-native predators, and exposure to sediment deposition from the canal breach). Similar methods have been used to assess impacts on amphibian occupancy and abundance (Knapp et al. 2003, Lind 2005, Davidson and Knapp 2007, and Kupferberg et al. 2012). 5.1.3 Population Trends Population trends will be analyzed using either a time series model 2, an ordinal model with year as a monotonic categorical predictor, or other comparable model. The model will be used to evaluate the relationship between trends in population size and potential impacts from the canal breach. Population trends (i.e., the changes in population size over the monitoring period) are implicative of a stable or unstable population and will be compared across the control and affected sites. Similarly, changes in population demographics (i.e., changes in the number of adults or other life stages observed over the monitoring period) will also be compared across the control and affected sites. The changes in demographics may be implicative of a lagged response from sediment exposure to FYLF tadpoles at the affected sites. During model analysis, if no significant differences in the population trends between the control and affected sites are observed, then nominal effects of the canal breach on FYLF populations on Butte Creek may be inferred. We will focus on the trend within the estimated uncertainty. If there are significant differences in population estimate trends observed between the control and affected sites, possible impacts of the canal breach on the FYLF populations cannot be dismissed. 5.2 Significant Loss Evaluation Significant loss will be inferred if parameter estimate of population size is greater than –0.1 in the model assessing the influence of sediment deposition. Also, if the posterior contrast in population size between the affected and control reaches overlap zero, then there is no difference. If they do 2 A time series model was used in Kupferberg et al. 2012 analysis where trends in FYLF densities were modeled over time to determine hydrologic drivers to population densities. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Analysis for Contingency Mitigation 5-3 May 2025 ©2025, Pacific Gas and Electric Company not overlap zero, then the differences will be evaluated. If significant loss is inferred and contingency mitigation is required, population predictor variables will be used to define mitigation efforts. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 6.0 References 6-1 May 2025 ©2025, Pacific Gas and Electric Company 6.0 References CFGC (California Fish and Game Commission). 2020. Notice of findings for Foothill yellow- legged frog (Rana boylii). CFGC March 10, 2020. Davidson, C., and R.A. Knapp. 2007. Multiple stressors and amphibian declines: Dual impacts of pesticides and fish on yellow‐legged frogs. Ecological Applications, 17(2), 587–597. FERC (Federal Energy Regulatory Commission). 2024. 2023 Project Canal Failure, Overtopping, and Erosion Incidents. Letter from Federal Energy Regulatory Commission, Office of Energy Projects, to Pacific Gas & Electric Company, dated November 19, 2024. Fiske, I., and R. Chandler. 2011. unmarked: An R Package for Fitting Hierarchical Models of Wildlife Occurrence and Abundance. Journal of Statistical Software, 43(10), 1–23. https://doi.org/10.18637/jss.v043.i10. Knapp, R.A., K.R. Matthews, H.K. Preisler, and R. Jellison. 2003. Developing probabilistic models to predict amphibian site occupancy in a patchy landscape. Ecological Applications, 13(4), 1,069–1,082. Kupferberg, S.J., W.J. Palen, A.J. Lind, S. Bobzien, A. Catenazzi, J.E. Drennan, and M.E. Power. 2012. Effects of flow regimes altered by dams on survival, population declines, and range‐ wide losses of California river‐breeding frogs. Conservation Biology, 26(3), 513–524. Lind, A.J. 2005. Reintroduction of a declining amphibian: determining an ecologically feasible approach for the foothill yellow-legged frog (Rana boylii) through analysis of decline factors, genetic structure, and habitat associations. University of California, Davis. Loman, J., and G. Andersson. 2007. Monitoring brown frogs Rana arvalis and Rana temporaria in 120 south Swedish ponds 1989–2005. Mixed trends in different habitats. Biological Conservation 135:46–56. Marlow, K.R., K.D. Wiseman, C.A. Wheeler, J.E. Drennan, and R.E. Jackman. 2016. Identification of individual foothill yellow-legged frogs (Rana boylii) using chin pattern photographs: a non-invasive and effective method for small population studies. Herpetological Review, 47, 193-198. PG&E. 2008. DeSabla-Centerville Project (FERC Project No. 803-068), updated study results and license application sections—Updated Section 6.3.2.1: Assessment of RT&E amphibian and aquatic reptile species habitat near project reservoirs and project-affected stream reaches (Study 6.3.3-3), and Updated Section 7.3.2, Pacific Gas and Electric Company, San Francisco, CA. March 2008. PG&E and Stillwater Sciences. 2023. Butte Creek Canal Breach—Foothill Yellow-legged Frog Study Results, 2023. Technical Memorandum to Lynn Coster, Senior Environmental Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 6.0 References 6-2 May 2025 ©2025, Pacific Gas and Electric Company Scientist, Central Valley Regional Quality Control Board; and Tanya Sheya, Environmental Program Manager, California Department of Fish and Wildlife. PG&E and Stillwater Sciences. 2025. Butte Creek Foothill Yellow-legged Frog Monitoring 2024. January 2025. Oakland, CA. Prepared by PG&E and Stillwater Sciences, Berkeley, CA. Seltenrich, C.P., and A.C. Pool. 2002. A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii). May 2002. Pacific Gas and Electric Company, Technical and Ecological Services, unpublished report. USFWS (U.S. Fish and Wildlife Service). 2023. Endangered and threatened wildlife and plants; Foothill yellow-legged frog; Threatened status with Section 4(d) Rule for two distinct population segments and endangered status for two distinct population segments. Federal Register 88:166 Pages 59698-59727. August 29, 2023. USFWS. 2025. Endangered and threatened wildlife and plants; Designation of critical habitat for four distinct population segments of the foothill yellow-legged frog. Federal Register 90:8 Pages 3412-3470. January 14, 2025. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Public ENCLOSURE 2 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Subject Commenter Comment/Suggested Edits Response Plan updated? FYLF Study Plan CDFW Please include if this was do to timing or other factors or if there were not any egg masses detected during the breeding season.egg laying. We learned a lot last year (2024) and will get in to sites earlier this Monitoring will begin in 2025 at two sites in WBFR (WBFR1 and WBFR-2) and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla- Centerville Project relicensing studies (PG&E 2008). These sites, which are located on relicensing studies in 2006 and all life stages of frogs were identified at each location. observations via CDFW’s ESRI Quick Capture app? This would assist with statewide accessible. involve in-person checks of conditions at survey sites? What will be the CFS cutoff used to determine survey safety and timing? Will water temperature also be trigger. are deemed safe (based on CFS cutoff) surveys will be conducted every 10-14 days thereafter until eggs have hatched or until no new egg masses are found for two consecutive survey rounds at sites identified during habitat assessment surveys. strictly the contingency planning part of it. I have some concerns with the method for evaluating impacts from the canal failure. I went through the hydrographs for Butte station 11390000, which is farther downstream). Generally, the spring/summer hydrograph more or less mimics an unimpaired system, with exceptions (some years more than others). There are exceptions in 2017, 2019-2024. Almost all of those the conclusion of snowmelt) seem to correspond with rainfall events (as measured at Chico). 2021 is the only year with exceptions that I could not explain with rainfall. I am not familiar with the PG&E operations (diversions) on this system, but from looking at the hydrograph, it doesn't appear to me to be a highly impacted system, at least as far as flow. How is the historical hydrograph for Butte Creek taken into account with the evaluation of impacts from the canal failure? How does this system compare as far as WBFR yet, so if anyone is aware, please let me know. water on Butte or WBFR and therefore change trends observed for both Butte and WBFR are likely not related to hydrograph. However, we can model hydrograph as a predictor variable to better understand effects. There are no accessible control sites above the breach sites, and other watersheds in the area are too hydrologically different. The WBFR sites are the best control sites available and have similar habitats, stressors, and hydrologic influences compared to Butte Creek. There is also historical data available from WBFR, collected during the reliceisning studies in 2006. We use Department of Water Resources gage WFR (West Branch Feather River near Magalia) to monitor flow in WBFR. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 FYLF Contingency Plan USFWS Secondly, there is a reference to items the model will use (known predictor variables) and water year type is listed as one. I don't think water year type is a predictor variable with water year is that detectability varies more or less by water year type (detectability is not the same as population variation). In thinking of what would be a predictor variable, I do agree with habitat parameters (how flow changes over time and the corresponding depth and velocities within microhabitats, substrate types (boulders/coarse cobble), food source (algae), presence of predators (not all predators are equal--rainbow trout might be more compatible than bullfrogs, for instance), water quality (including suspended solids), cover (riparian shade/vegetation), and temperature. Temperature maybe is not a predictor as far as population size, but more some other predictor variables. I'm also interested in finding out if any of these predictor variables have changed since 2006 or if they have remained consistent since that time (and if they were present pre-2006 as well). may have considerable impacts on foothill yellow-legged frog populations. Summer runoff affects foraging, habitat availability, and water temperature (see Hayes et al. 2016 for summary). Similarly, the timing of spring runoff affects breeding chronology, likely influencing breeding success and recruitment. Changes in temperature also likely have large impacts on population sizes. Water temperature may affect parasite prevalence and pathogen virulence (Kupferberg et al. 2009; Jennings and Hayes 1994), invertebrate density and biomass (Hogg and Williams 1996), and changes in behavior responses (e.g., delayed onset of breeding). While the predictor variables are not set, we will choose them based on the best available science and documented risk factors for the species. recent (since 2006) addition? What other predators are present and does the WBFR have any of the same? What other parameters are different with the WBFR? At this point, I know nothing about WBFR, so cannot say if it is a good reference site. How will we deal with the variability of detection that occurs between water year types? We cannot assume the low detections of a wet water year means there are fewer breeding females nor the greater detections of a dry water year means more breeding females. This is a human problem and honestly, am not sure how to deal with that within this effort. Does PG&E have frog survey data for WBFR? Can it be shared please? BC1, BC2, and WBFR were not surveyed in 2024. We do not have information as a predictor variable. Imperfect detection will be accounted for in our population estimates. See updated language in monitoring plan. how will the effort take into account that males spend more time within breeding habitat (and therefore are more detectable) than females, given that breeding females are the detection probability. See updated language in the monitoring plan. but am unclear how to edit. It seems that the way it is worded now will be more likely to conclude "no impact" from the canal failure than I think may be appropriate. As I said on the call, I do not anticipate the result of all of this effort being a clearly defined answer...it is going to be a muddy mess (pun intended) and it will be very hard to tease the different parts out. We have a species that has seen significant declines in many parts of its range (but certainly not all), and many of those impacts may be present were present well before 2006. probability population trends. counts are not available for each year or location, what metric will be used? If tadpoles, how is that going to be adjusted based on survey time/area and density estimates? Document Accession #: 20250519-5175 Filed Date: 05/19/2025 FYLF Contingency Plan CDFW Given the wide swings of natural population variation (due to drought, flow, local events, etc.) and limited data set (2006 vs 4 years post breach data) this metric may effects be accounted for? The error/uncertainty associated with surveys from year to year (and even in the same year) can play a big role here, given detection probabilities can vary widely. If detection probabilities can be added to this variation estimate, it may make more sense. estimates incorporating detection probability. they can occur. There are other approaches that may be better, but particularly given the limited number of years in the dataset, and the imperfect detection of life stage the model). We included language describing potential models to be used with the flexibility of using a comparable approach depending on survey results. to the high amount of variability in frog populations and uncertainty of the dataset that and procedures describing habitat assessments and population monitoring methods Variables used to draw causal inferences. Confounding variables could cause misinterpretation of results if sediment deposition correlates with an unmeasured variable. directed acyclic graphs, or similar, to determine confounders and to develop our estimands. Variables very similar AIC values so that there is no strong evidence to support a conclusion.have a delta AIC <2 and there is no one model that would support a single Variables not correlate with lower population sizes for sampled reaches” using a pre-specified based on scientifically based questions and study objectives. 2006 is representative of all years before the breach but given the yearly variation in population is the same between control and breach-impact sites, while no evidence of that there are better approaches, such as a Generalized Additive Model (GAM).potential predictor variables. with models for population trends that show high variability and uncertainty in population trends. This could be interpreted as “no significant differences in the hiding impacts. addition to the inherent variation in the data. In a Bayesian framework, we can define the range of probabilties for a parameter coefficient instead of a statistical test that doesn't make sense biologically; we can examine the influence of the predictor variable while simultaneously evaluating the inherent variation in the data. If we look at the coefficient of the parameter and assess a positive, negative or no relation that would allow us to make a recommendation instead of "statistical significance" that has no basis in the biology of the system. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Significant Loss Threshold Arthur Barros This threshold is inflexible and impractical, especially given my above comments. Its easy to foresee a situation in which drastic decreases in population size at affected sites are observed and much lower in comparison to control sites, but AIC fails to identify the best model as including sediment disposition, resulting in the conclusion that the breach had no impact. we are interested in, we can more appropriately evaluate the effect of the predictor variable (in your example, sediment deposition). Document Accession #: 20250519-5175 Filed Date: 05/19/2025 ENCLOSURE 3 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 From:Weinmann, Sophia@Wildlife To:Reaves, Brittany L; Herman, Andie; Allison, Anna@Wildlife; Alber, Leslie@Wildlife; Bartoo, Aondrea; Millsap, Stephanie D Cc:Ramirez-Doble, Sky; Young, Megan; Cheslak, Edward Subject:RE: [EXTERNAL] Butte Creek FYLF Study Plan 2025 to 2028 V3 Redline Date:Friday, May 2, 2025 9:20:42 AM Attachments:FYLF Comments AB.docx CAUTION: EXTERNAL SENDER! This email was sent from an EXTERNAL source. Do you know this person? Are you expecting this email? Are you expecting any links or attachments? If suspicious, do not click links, open attachments, or provide credentials. Don't delete it. Report it by using the "Report Phish" button. Good morning— Attached are additional CDFW comments on the proposed data analysis methods. Best- Sophia Sophia Weinmann (she/her/hers) Environmental Scientist Foothill Yellow-legged Frogs From: Reaves, Brittany L <brittany_reaves@fws.gov> Sent: Wednesday, April 23, 2025 1:34 PM To: Herman, Andie <AEHb@pge.com>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov>; Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov>; Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov> Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com> Subject: Re: [EXTERNAL] Butte Creek FYLF Study Plan 2025 to 2028 V3 Redline WARNING: This message is from an external source. Verify the sender and exercise caution when clicking links or opening attachments. Andie, We'd like to propose the following language to replace the last paragraph in Section 4.0: After completion of the study and subsequent final reporting in 2029, PG&E will meet with the resource agencies (USFWS and CDFW) to discuss the analysis of significant loss of FYLF with Document Accession #: 20250519-5175 Filed Date: 05/19/2025 respect to the canal breach sediment deposition and to determine if mitigation will be required. In other areas of California, efforts to provide conservation benefits to FYLF have included: habitat restoration via removal of encroaching vegetation, bullfrog and crayfish abatement, and and captive (in situ or ex situ) breeding programs. If mitigation is found to be warranted, appropriate mitigation will be determined in collaboration with the resource agencies and implemented as soon as feasible. Thank you, Brittany Reaves Fish and Wildlife Biologist U.S. Fish and Wildlife Service (530) 365-7150 *********************** I am currently working part-time: Monday – Wednesday From: Herman, Andie Sent: Friday, April 18, 2025 5:43 PM To: Allison, Anna@Wildlife; Weinmann, Sophia@Wildlife; Alber, Leslie@Wildlife; Reaves, Brittany L; Bartoo, Aondrea; Millsap, Stephanie D Cc: Ramirez-Doble, Sky; Young, Megan; Cheslak, Edward Subject: [EXTERNAL] Butte Creek FYLF Study Plan 2025 to 2028 V3 Redline This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding. Hello, Thank you all for your continued participation in consultation meetings regarding foothill yellow- Document Accession #: 20250519-5175 Filed Date: 05/19/2025 legged frog on Butte Creek. I am providing the Butte Creek Foothill Yellow-legged Frog Study Plan 2025-2028, revised based on your comments and our discussion from the last two meetings. I have attached a version with redline of the contingency mitigation analysis section for your review, which has been revised based on the verbal and written comments we received. As discussed during the April 10 meeting, we are working to meet a May 17, 2025, filing deadline. Please provide any additional comments or review with this in mind. Please feel free to reach out with any questions or comments. Thank you, Andie Andie Herman | ( 530-680-9037| * andie.herman@pge.com Senior Aquatic Biologist - Herpetologist| Pacific Gas and Electric Company You can read about PG&E’s data privacy practices at PGE.com/privacy. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Arthur Barros Arthur.Barros@wildlife.ca.gov 4/21/2025 The following is a list of comments and concerns regarding the data analysis methods proposed in the “Foothill Yellow-legged Frog Study Plan: Butte Creek 2025-2028” draft provided by Pacific Gas and Electric Company. Population Monitoring • I was unable to find a copy of “Seltenrich and Pool 2002” which is cited as the methods and procedures describing habitat assessments and population monitoring methods (all google links came back broken). This study plan needs to describe how population size and uncertainty will be estimated for each site. Population Predictor Variables • Akaike information criterion is a method used for model selection and should not be used to draw causal inferences. Confounding variables could cause misinterpretation of results if sediment deposition correlates with an unmeasured variable. • The approach implies a binary conclusion (yes or no) but multiple models may have very similar AIC values so that there is no strong evidence to support a conclusion. • A better approach is to test a specific null hypothesis, i.e. “sediment deposition does not correlate with lower population sizes for sampled reaches” using a pre- specified significance level. Population Size Variation • Use of a single pre-breach year (2006) to compare population variation assumes that 2006 is representative of all years before the breach but given the yearly variation in important habitat variables like flow and temperature this is doubtful. • There is an assumption that habitat conditions and corresponding impacts to population is the same between control and breach-impact sites, while no evidence of this has been provided. • No statistical test is provided to determine if population estimates are “proportionally outside the range observed at control sites”. Population Trends • Linear regression will likely miss complex trends. I agree with Ryan Peeks comment that there are better approaches, such as a Generalized Additive Model (GAM). • Given the limited data set and high natural variability in conditions, we could end up with models for population trends that show high variability and uncertainty in Document Accession #: 20250519-5175 Filed Date: 05/19/2025 population trends. This could be interpreted as “no significant differences in the population trends between control and affected sites”, however the uncertainty could be hiding impacts. Significant Loss Threshold • This threshold is inflexible and impractical, especially given my above comments. Its easy to foresee a situation in which drastic decreases in population size at affected sites are observed and much lower in comparison to control sites, but AIC fails to identify the best model as including sediment disposition, resulting in the conclusion that the breach had no impact. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 From:Herman, Andie To:Bartoo, Aondrea; Ramirez-Doble, Sky; Alber, Leslie@Wildlife; Weinmann, Sophia@Wildlife; Reaves, Brittany L; Millsap, Stephanie D; Allison, Anna@Wildlife Cc:Young, Megan; Cheslak, Edward; Walther, Janet; Joseph, Matthew Subject:RE: FW: [EXTERNAL] FERC No. 803: Consultation on Additional FYLF Monitoring Part 4 Date:Monday, April 14, 2025 10:36:39 PM Attachments:Butte Creek_FYLF Annual Report_2024.pdf DeSabla C RL_FYLF Tech Memo_Updated Mar2008.pdf DSC FYLF Maps.pdf Classification: Public Hi Leigh, I am in the field and can’t respond to the entirety of your email as thoughtfully as needed, so more to come. I can provide you with the documents the rest of the agency team already has at their disposal and talk a little bit about Butte Creek and WBFR. Portions of these two streams make up the DeSabla-Centerville Project. During the relicensing effort we performed surveys at sites on both streams on all accessible public lands and some small private properties that allowed us to cross their property to get to the creek. We could not get permission to survey for frogs on SPI lands, so when looking at maps of the site locations take into consideration the ownership to understand why sites were located where they were. These surveys were performed in 2006 and are what we are using as the “before” data, as no surveys have occurred between 2006 and the canal breach. I have attached the relicensing tech memo and maps and the 2024 report. As to bullfrogs, I’ll need to look at the WBFR 2006 data. On Butte Creek bullfrogs were observed in 2006 as well as 2023 and 2024, but they have moved upstream quite a bit. Thanks, Andie From: Bartoo, Aondrea <aondrea_bartoo@fws.gov> Sent: Monday, April 14, 2025 2:10 PM To: Ramirez-Doble, Sky <S9RV@pge.com>; Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov>; Reaves, Brittany L <brittany_reaves@fws.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov> Cc: Herman, Andie <AEHb@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com>; Walther, Janet <JMW3@pge.com>; Joseph, Matthew <MWJA@pge.com> Subject: Re: FW: [EXTERNAL] FERC No. 803: Consultation on Additional FYLF Monitoring Part 4 CAUTION: EXTERNAL SENDER! This email was sent from an EXTERNAL source. Do you know this person? Are you expecting this email? Are you expecting any links or attachments? If suspicious, do not click links, open attachments, or provide credentials. Don't delete it. Report it by using the "Report Phish" button. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 I promised comments ASAP, so here you go: As I only have limited time to go over this plan, I'm keeping my comments today to strictly the contingency planning part of it. I have some concerns with the method for evaluating impacts from the canal failure. I went through the hydrographs for Butte Creek from 2015-2024 from start of snowmelt through Oct 1 for each year (using USGS station 11390000, which is farther downstream). Generally, the spring/summer hydrograph more or less mimics an unimpaired system, with exceptions (some years more than others). There are exceptions in 2017, 2019- 2024. Almost all of those exceptions (by which I mean the hydrograph increases/decreases to some degree after the conclusion of snowmelt) seem to correspond with rainfall events (as measured at Chico). 2021 is the only year with exceptions that I could not explain with rainfall. I am not familiar with the PG&E operations (diversions) on this system, but from looking at the hydrograph, it doesn't appear to me to be a highly impacted system, at least as far as flow. How is the historical hydrograph for Butte Creek taken into account with the evaluation of impacts from the canal failure? How does this system compare as far as flow to the control site, West Branch Feather R (right?)? I haven't found a station on the WBFR yet, so if anyone is aware, please let me know. Secondly, there is a reference to items the model will use (known predictor variables) and water year type is listed as one. I don't think water year type is a predictor variable and would encourage this to NOT be included. I think the only thing we can say for sure with water year is that detectability varies more or less by water year type (detectability is not the same as population variation). In thinking of what would be a predictor variable, I do agree with habitat parameters (how flow changes over time and the corresponding depth and velocities within microhabitats, substrate types (boulders/coarse cobble), food source (algae), presence of predators (not all predators are equal--rainbow trout might be more compatible than bullfrogs, for instance), water quality (including suspended solids), cover (riparian shade/vegetation), and temperature. Temperature maybe is not a predictor as far as population size, but more of a predictor of how long the egg and tadpole development will need. I may be missing some other predictor variables. I'm also interested in finding out if any of these predictor variables have changed since 2006 or if they have remained consistent since that time (and if they were present pre-2006 as well). How long have bullfrogs been detected within Butte Creek watershed? Are they a more recent (since 2006) addition? What other predators are present and does the WBFR have any of the same? What other parameters are different with the WBFR? At this point, I know nothing about WBFR, so cannot say if it is a good reference site. How will we deal with the variability of detection that occurs between water year types? We cannot assume the low detections of a wet water year means there are fewer breeding females nor the greater detections of a dry Document Accession #: 20250519-5175 Filed Date: 05/19/2025 water year means more breeding females. This is a human problem and honestly, am not sure how to deal with that within this effort. Does PG&E have frog survey data for WBFR? Can it be shared please? If frog crews are unable to detect egg masses and we need to shift our focus to adults, how will the effort take into account that males spend more time within breeding habitat (and therefore are more detectable) than females, given that breeding females are the metric that determines population numbers? I have discomfort in the method for which "significant loss threshold" has been defined but am unclear how to edit. It seems that the way it is worded now will be more likely to conclude "no impact" from the canal failure than I think may be appropriate. As I said on the call, I do not anticipate the result of all of this effort being a clearly defined answer...it is going to be a muddy mess (pun intended) and it will be very hard to tease the different parts out. We have a species that has seen significant declines in many parts of its range (but certainly not all), and many of those impacts may be present within Butte Creek, although I am very interested to hear if those impacts to the species were present well before 2006. I hope my jumble of comments, questions, and suggestions make sense. If I've stated something that does not jive with your understand, let's discuss. Leigh Bartoo From: Ramirez-Doble, Sky Sent: Thursday, April 10, 2025 7:42 AM To: Ramirez-Doble, Sky <S9RV@pge.com>; Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov>; Reaves, Brittany L <brittany_reaves@fws.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov> Cc: Herman, Andie <AEHb@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com>; Walther, Janet <JMW3@pge.com>; Joseph, Matthew <MWJA@pge.com> Subject: FW: [EXTERNAL] FERC No. 803: Consultation on Additional FYLF Monitoring Part 4 When: Thursday, April 10, 2025 2:00 PM-3:00 PM. Where: Microsoft Teams Meeting From: Ramirez-Doble, Sky <S9RV@pge.com> Sent: Monday, April 7, 2025 7:03:22 AM (UTC-08:00) Pacific Time (US & Canada) To: Ramirez-Doble, Sky <S9RV@pge.com>; Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov>; Reaves, Brittany L <brittany_reaves@fws.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; Allison, Anna@Wildlife Document Accession #: 20250519-5175 Filed Date: 05/19/2025 <Anna.Allison@wildlife.ca.gov> Cc: Herman, Andie <AEHb@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com>; Walther, Janet <JMW3@pge.com>; Joseph, Matthew <MWJA@pge.com> Subject: [EXTERNAL] FERC No. 803: Consultation on Additional FYLF Monitoring Part 4 When: Thursday, April 10, 2025 2:00 PM-3:00 PM. Where: Microsoft Teams Meeting This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding. Hi everyone, Thank you for providing your availability. This is the fourth meeting to consult with the USFWS and CDFW on “a plan for additional FYLF monitoring in Butte Creek” and “a contingency for mitigation to the Butte Creek FYLF population if monitoring confirms a significant loss of FYLF.” Specifically, this meeting is to discuss the Contingency Mitigation analysis proposal. If you have specific questions you’d like answered during the meeting, please provide them before the meeting and I’ll send them over to the Stillwater team so they can arrive prepared. Please feel free to reach out to me with any comments or questions. Kindly, Sky Ramirez-Doble He/Him/His Hydro License Coordinator | Power Generation Pacific Gas & Electric Company c: (530) 250-7002 e: s9rv@pge.com ________________________________________________________________________________ Microsoft Teams Need help? Join the meeting now Meeting ID: 254 831 721 781 Passcode: kQ7g7Ga7 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Dial in by phone +1 415-906-0873,,164484398# United States, San Francisco Find a local number Phone conference ID: 164 484 398# For organizers: Meeting options | Reset dial-in PIN Need Help with Teams? Click on the Org Help option in this invite to connect you directly to our Teamsat PG&E Training site! "Please reply to this meeting invite if you need an ADA ReasonableAccommodation to attend" Org help ________________________________________________________________________________ You can read about PG&E’s data privacy practices at PGE.com/privacy. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Sophia Weinmann (she/her/hers) Sierra Fisheries Environmental Scientist, Foothill Yellow-legged Frogs Sophia.Weinmann@wildlife.ca.gov 916.767.3380 1701 Nimbus Rd, Rancho Cordova, CA 95670 www.wildlife.ca.gov From:Weinmann, Sophia@Wildlife To:Ramirez-Doble, Sky; Alber, Leslie@Wildlife; brittany_reaves@fws.gov; stephanie_millsap@fws.gov; Allison, Anna@Wildlife; Herman, Andie; Young, Megan; Cheslak, Edward; Walther, Janet; Bartoo, Aondrea Subject:Butte Creek Mitigation Plan- CDFW Initial Comments Date:Friday, April 11, 2025 4:45:42 PM Attachments:image001.png image002.png Butte Creek FYLF Study Plan_2025 to 2028_V2 w Contingency Mitigation Plan_CDFW.docx CAUTION: EXTERNAL SENDER! This email was sent from an EXTERNAL source. Do you know this person? Are you expecting this email? Are you expecting any links or attachments? If suspicious, do not click links, open attachments, or provide credentials. Don't delete it. Report it by using the "Report Phish" button. Hello— Attached are CDFW’s initial comments on the Data Analysis portion of the Contingency Mitigation Plan Placeholder based on our review ahead of yesterday’s meeting. As a follow-up to these initial comments and our conversation yesterday, we are coordinating with a CDFW statistician for review of the proposed plan. We will submit their additional comments as soon as they are available, but wanted to make sure you received this set of comments in the meantime. Best- Sophia Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 February 25, 2025 February 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 February 25, 2025 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Citation: Pacific Gas and Electric Company. 2025. Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028. February 2025. Oakland, CA. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents i May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company TABLE OF CONTENTS 1.0 Introduction ....................................................................................................... 1-1 2.0 Study Site Selection .......................................................................................... 2-1 3.0 Methods............................................................................................................. 3-1 3.1 Habitat Assessments and Transects ..................................................................... 3-1 3.2 Visual Encounter Surveys .................................................................................... 3-1 3.3 Vegetation Encroachment Assessments .............................................................. 3-2 3.4 Decontamination Protocols .................................................................................. 3-2 4.0 Reporting........................................................................................................... 4-1 5.0 Contingency Mitigation Plan Placeholder ........................................................ 5-1 6.0 References ......................................................................................................... 6-1 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents ii May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company LIST OF TABLES Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. .... 2-1 LIST OF FIGURES Figure 2-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. ........................................................................................................................... 2-3 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 1.0 Introduction 1-1 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company 1.0 Introduction Foothill yellow-legged frog (Rana boylii; FYLF) in Butte Creek is listed as threatened as part of the North Feather Distinct Population Segment (USFWS 2023). The California Fish and Game Commission listed the Feather River clade of FYLF as threatened in 2020 (CFGC 2020). Butte Creek is also part of proposed critical habitat for North Fork Feather River Unit NF-1 (USFWS 2025). Historically, Butte Creek has supported a robust population of FYLF that may be significant for species recovery efforts, as well as a likely candidate for future reintroduction efforts (B. Reaves, USFWS personal communication, February 5, 2025). On August 10, 2023, the Butte Canal, part of the Pacific Gas and Electric Company’s (PG&E) DeSabla-Centerville Hydroelectric Project (FERC No. 803), breached. This 2025–2028 study is a continuation of the foothill yellow-legged frogFYLF (Rana boylii; FYLF) study on Butte Creek initiated in fall 2023 to evaluate the current population status of FYLF downstream of the sediment deposition area. The 2023 study consisted of surveys in late September and early October, at three study sites (BC-4, BC-6, and BC-12); one adults and 12 successful metamorphosis (i.e., young-of- year (YOY)) were documented at BC-4, and three adults and one tadpole were documented at BC- 12 (PG&E and Stillwater Sciences 2023), .indicating successful metamorphosis in Butte Creek. In 2024 the study expanded to include seven study sites (BC-3, BC-4, BC-6, BC-7, BC-8, BC-9, and BC-12) with three to four surveys occurring at each site, except BC-9, from June through September. BC-9 was removed after one visit due to safety concerns. Transect habitat assessments were conducted at each site across suitable breeding habitat, typically located in an area with higher concentrations of observed tadpoles and/or young-of-year (YOY). No egg masses were observed at any of the sites likely due to survey timing; however, approximately 1,809 tadpoles and approximately 131 young-of-yearYOY were observed at all six sites indicating successful breeding and recruitment occurred throughout Butte Creek in 2024. Seventeen aAdult and two juvenile frogs were observed at all sites except BC-12 (PG&E and Stillwater Sciences 2025). BC- 9 was removed due to safety concerns. In order to compare breeding and recruitment in Butte Creek, which was potentially impacted by the canal breach and sediment deposition, with sites not impacted by the canal breach, two additional monitoring sites on West Branch Feather River (WBFR) will be added to the monitoring program beginning in 2025. The two sites, WBFR-1 and WBFR-2, were also surveyed as part of relicensing studies performed in 2006 and will act as non-impact control sites. WBFR sites have similar habitat conditions to Butte Creek sites and all FYLF life stages were observed in 2006. This 2025–2028 continuation study was developed in response to the Federal Energy Regulatory Commission Notice of Violation letter, dated November 19, 2024 (FERC 2024). The study will include visual encounter surveys and habitat assessments. These surveys are designed to determine: (1) if reproduction is occurring throughout Butte Creek after the breach; (2) if recruitment is successful in the system; and (3) to compare current occupation and numbers to historical (i.e., 2006) baseline data. Commented [LA1]: Please include if this was do to timing or other factors or if there were not any egg masses detected during the reedin season. Commented [AH2R1]: Added language. Commented [SW3]: Please include additional information about why these are suitable comparison sites as well as why no sites above the canal breach are included. Commented [AH4R3]: Added next sentence. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-1 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company 2.0 Study Site Selection Studies will continue at six sites surveyed in 2024 (BC-3, BC-4, BC-6, BC-7, BC-8, and BC-12) and two sites surveyed in 2006 (BC-1 and BC-2), and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). Six Eight study sites located downstream of the sediment deposition area, in three different reaches, were selected for surveys (Table 2-1, Figure 2-1). These sites, which are located on PG&E, U.S. Bureau of Land Management (BLM), California Department of Fish and Wildlife, and private lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and nearly all life stages of frogs were identified at each location. BC-1 and BC-2 (from 2006 relicensing studies) were not selected as these sites were located furthest downstream from the sediment deposition area, are adjacent to BC-3, had no evidence of egg masses or tadpoles documented in 2006, and had documented occurrences of American bullfrogs (Lithobates catesbeianus). BC-9 was attempted in 2024 but determined to be unsafe to survey. Monitoring will begin in 2025 at two sites in WBFR (WBFR1 and WBFR-2) and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). These sites, which are located on Lassen National Forest and BLM lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and all life stages of frogs were identified at each location. Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. Reach Site Code Site Length (miles)a Description (2006a) BUTTE CREEK Forks of Butte Diversion Dam Area BC-12 1.2 This long, low gradient site was composed of long low gradient riffles as well as short high gradient riffles and shallow runs. The predominant substrates were boulder and cobble, with some occurrences of bedrock. DeSabla Powerhouse BC-8 1.0 High gradient site with step-run, cascade and mid-channel pool habitats. Substrate was mainly bedrock, cobble, and boulder. BC-7 0.6 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-6 0.3 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-4 0.5 Low gradient riffles and lateral scour ools were the prominent habitat type Commented [SW5]: Please note the land of Butte Creek Ecological Preserve was transferred to the Mechoopda of Chico Rancheria in Se tember 2023. Commented [AH6R5]: Need clarification. Does this apply to oth 1 and 2, or only 2? Commented [LA7]: This seems redundant to the paragraph above Commented [AH8R7]: One is addressing Butte and the other is WBFR, though language is similar. Commented [SW9]: If it has been decided to not include the tributaries at BC-6, please include the rational. Commented [AH10R9]: Haven’t decided yet, but we will update you once we know. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-2 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company Reach Site Code Site Length (miles)a Description (2006a) BUTTE CREEK Centerville Powerhouse in this site. Substrate consisted of cobble, boulder, and large gravel patches. BC-3 0.3 This site was very low gradient, characterized by a shallow fast run with riffle habitat at the upstream end. Substrate was cobble and boulder. Banks were heavily vegetated. BC-2 1.1 The majority of this site was composed of low gradient riffles, slow-moving runs, and deep pools. Substrate was cobble and boulder throughout with some large woody debris. BC-1 1.2 The majority of this site was composed of low gradient riffles and runs, with few deep pools and slow-moving runs. Substrate was cobble and boulder throughout. WEST BRANCH FEATHER RIVER Upstream of Miocene Diversion WBFR-1 0.2 Slow lateral pools and mid-channel pools with cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. At Jordan Hill Bridge WBFR-2 0.3 Slow lateral pools and mid-channel pools with cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. a From PG&E 2008. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-3 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company Figure 3-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. Commented [SW11]: Please add Hendricks Diversion Dam to the map Commented [AH12R11]: In progress. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-1 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company 3.0 Methods Habitat assessments and population monitoring will be conducted based on procedures described in PG&E’s monitoring protocol A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii) (Seltenrich and Pool 2002, as previously revised). In addition to FYLF, all American bullfrogs (Lithobates catesbeianus) observed will be counted and their life stages recorded. sSurveyors will record all other amphibian and reptile species and any potential predators (e.g., fish, crayfish, and bullfrogs) observed. 3.1 Habitat Assessments and Transects At the end of each survey, general habitat for the entire survey site will be characterized and the following additional information will be recorded: air and mid-channel water temperatures; associated tributaries; fish, predators, or other aquatic herpetofauna observed; and observable anthropogenic disturbance (i.e., mining, recreation). Photographs will be taken of the survey start and end points at the downstream and upstream ends of the site and of representative habitat throughout the site. To compare potential observable changes in habitat suitability across years, surveyors established one transect per survey site across suitable breeding habitat in 2023 and/or 2024, typically located in an area with higher concentrations of observed tadpoles and/or YOY FYLF. Similar transects will be established at BC-1, BC-2, WBFR-1, and WBFR-2 in 2025. The following physical characteristics will be measured or estimated across each transect: geomorphic unit type; aquatic substrate and substrate embeddedness; wetted width and bankfull width (measured with a rangefinder); turbidity (visual assessment); river and bank gradient; upland habitat type; percent aquatic cover; percent canopy; and percent margin, emergent, and submerged vegetation by type. Photos will be taken of each transect from one or both banks looking toward the channel, and mid- channel photos will be taken looking both upstream and downstream. 3.2 Visual Encounter Surveys Remote monitoring of flows at PG&E gages BW-97 and , BW-98, and Department of Water Resources gage WFR (West Branch Feather River near Magalia) will begin April 15 of each year. Two to three early season surveys will target egg masses and begin as flows allow safe access to sites. Surveys at lower elevation sites may begin earlier than higher elevation sites if safely accessible earlier. Once egg masses or tadpoles are observed, each survey round will occur in intervals of 10–-14 days, in order to capture new egg mass or tadpole groups. If signs of breedingegg masses are not observed at a thatsites, an additional survey will be conducted during the tadpole rearing season. Two later-season surveys will be performed, one in August and one in September, to target YOY.Three to four visual encounter surveys (VESs) will be conducted each year, if feasible based on flows and site access. These surveys will focus on different FYLF life stages. The first survey will target egg masses. If a relatively substantial number of egg masses are found during the first VES (e.g., as compared with 2006 surveys), or high flows delay egg mass surveys, follow-up egg mass surveys may be cancelled at the discretion of PG&E. The second Commented [SW13]: When the platform becomes accessible to the public, can you also record all bullfrog observations via CDFW’s ESRI Quick Capture app? This would assist with statewide efforts to gather bullfrog data. Commented [AH14R13]: Yes. Commented [SW15]: Please clarify. Will this occur remotely by assessing flow rates and images or will it involve in-person checks of conditions at survey sites? What will be the CFS cutoff used to determine survey safety and timing? Will water temperature also be monitored? Commented [AH16R15]: Last year we were told by Ops and CDFW/PG&E fish crews that it wasn’t safe to be in the water above 100 cfs. We now think that we can access the lower sites, especially the edgewaters, at flows over 100 cfs, but will confirm during site visits this year. We will remotely monitor flows. We don’t plan to monitor temps as a trigger, as flows are the safety issues and limiting factor. Commented [AH17R15]: Use 200 CFS Cutoff, caveat with safety. Commented [SW18]: Please clarify the survey approach for egg masses. Our preference is that once sites are deemed safe (based on CFS cutoff) surveys will be conducted every 10-14 days thereafter until eggs have hatched or until no new egg masses are found for two consecutive survey rounds at sites identified during habitat assessment surveys. Commented [AH19R18]: Let’s discuss. Commented [AH20R18]: Need to revise based on conversation. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-2 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company to last survey will target tadpoles. And the final survey will target young-of-year. Surveys will be conducted by teams of two-to-four surveyors working in tandem and moving upstream to maximize access to all shoreline habitats and minimize double counting. During egg mass surveys, one surveyor will snorkel in suitable habitat, as safe and feasible. Data collection will include location, life stage, Gosner stage (for egg masses), total length (for tadpoles), depth at observation (for egg masses and tadpoles), perch or attachment substrate, snout-urostyle length, sex (if known), body condition (e.g., emaciated, injured), dominant riparian type at observation, geomorphic unit at observation, nearest bank, plus Universal Transverse Mercator (UTM) coordinates (measured using handheld global positioning system [GPS] units) for all observations (groupings of multiple YOY are recorded as an approximate range in meters from an initial GPS waypoint). Photos, including chin photos for individual identification, will be taken. 3.3 Vegetation Encroachment Assessments Vegetation at each survey site will be assessed. If it is determined that vegetation encroachment may be impacting the suitability of a site for breeding and that localized removal of vegetation (e.g., willow, alder, blackberry) could enhance site suitability, small- scale removal efforts will be considered each fall. Consideration will be given to private property access and permitting needs, which may make it infeasible to complete vegetation removal at sites. 3.4 Decontamination Protocols Decontamination protocols will be employed as specified in handling permits, or using currently accepted protocols, to minimize the potential to spread invasive species (e.g., chytrid fungus). Decontamination of boots, waders, and equipment will be practiced for all surveys. In addition, some field gear (waders, boots, etc.) may be dedicated for use only in the Butte Creek and/or WBFR watersheds. Commented [SW21]: Is it possible to take chin spot photos as well? Commented [AH22R21]: Added. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 4.0 Reporting 4-1 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company 4.0 Reporting A technical report will be prepared by January 31 of each year following surveys, detailing survey methods and results, including a discussion of habitat assessments as well as any meaningful comparisons of survey results with 2006 results that would inform potential impacts of 2023 sediment inputs into Butte Creek. The technical report will also include a summary of prior information collected about FYLF on Butte Creek in previous years, including any incidental observations. Where data are available, the following information regarding FYLF sightings will be included: location where FYLF were observed, day/time of observation, number of each life stage present, survey methodology utilized (e.g., walking vs. snorkeling), mean streamflow (in cubic feet per second) at the time of the survey, water temperature from both thalweg and nearshore environments (where available), weather on the day of the survey, and turbidity observations. Bullfrog observations will be summarized and reported. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Contingency Mitigation Plan Placeholder 5-1 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company 5.0 Contingency Mitigation Plan Placeholder 5.1 Data Analysis To determine potential effects of the Butte Canal breach on the FYLF population in Butte Creek, VES data from eight study sites located downstream of the canal breach (BC-1 through BC-12; affected sites) as well as two sites on the WBFR (WBFR-1 and WBFR-2; control sites) will be analyzed to answer the following questions: 1. Population Predictor Variables: What predictor variables, including exposure to sediment deposition from the canal breach, best explain population size across the control and affected sites? 2. Population Variation: Is there a difference in variation of FYLF populations in the control verses affected sites pre and post canal breach? 3. Population Trends: Is there a difference in FYLF population trends in the control versus affected sites post canal breach? Population Predictor Variable To explain population size across the control and affected sites, general linear or mixed effects models will be compared using Akaike information criterion (AIC), a model selection criterion that balances the goodness of fit of the model (how well the model explains the data) with its complexity. Statisticians will model known predictor variables for FYLF population size (e.g., water year, habitat characteristics, presence of non-native predators) as well as exposure sediment deposition from the canal breach. The “best” predictor variable(s) for the population sizes observed across the control and impacted sites throughout the 2024–2028 monitoring period will be determined using AIC values. If the model with the lowest AIC value, considered the “best” predictive model, does not include exposure to sediment deposition from the canal breach as a predictor variable, then nominal effects of the canal breach on FYLF populations on Butte Creek may be inferred. If the model with the lowest AIC value includes exposure to sediment deposition from the canal breach as a predictor variable, then possible impacts of the canal breach on the FYLF populations cannot be dismissed. Population Size Variation The variation between population size estimates from pre canal breach (2006) and post canal breach (2024–2028) VES will be evaluated for the control and affected sites. The range in variation (i.e., differences between the 2006 and 2024–2028 population estimates) of the affected sites will be compared to the range in variation of the control sites and/or other stable FYLF population estimates from long-term monitoring programs (e.g., Kupferberg et al. 2012). If population estimates on the affected sites are proportionally within the range observed at the control sites and/or other stable FYLF populations, then nominal effects of the canal breach on FYLF Commented [SW23]: Please include a brief literature review showing previous uses of a similar approach. Commented [SW25]: Please include details about how population size will be determined? If egg mass counts are not available for each year or location, what metric will be used? If tadpoles, how is that going to be adjusted based on survey time/area and densit estimates? Commented [SW24]: Additional metrics we recommend including: life stage and year, the lagged impact on different life stages (based on delayed impacts due to age at sexual maturity), detection robabilit Commented [SW26]: Given the wide swings of natural population variation (due to drought, flow, local events, etc.) and limited data set (2006 vs 4 years post breach data) this metric may not be the best suited to determining impact. Commented [SW27]: How will variability be calculated? Using egg mass data? Adults only? Will survey effects be accounted for? The error/uncertainty associated with surveys from year to year (and even in the same year) can play a big role here, given detection probabilities can vary widely. If detection probabilities can be added to this variation estimate, it may make more sense. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Contingency Mitigation Plan Placeholder 5-2 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company populations on Butte Creek may be inferred. If population estimates on the affected sites are proportionally outside the range observed at the control sites and/or other stable FYLF populations, possible impacts of the canal breach on the FYLF populations cannot be dismissed. Population Trends Population estimates from the 2024–2028 VES will be analyzed using generalized linear or linear regression models. The models will be used to evaluate the relationship between trends in population size and potential impacts from the canal breach. Population trends (i.e., the changes in population size over the monitoring period) are implicative of a stable or unstable population and will be compared across the control and affected sites. During model analysis, if no significant differences in the population trends between the control and affected sites are observed, then nominal effects of the canal breach on FYLF populations on Butte Creek may be inferred. If there are significant differences in population estimate trends observed between the control and affected sites, possible impacts of the canal breach on the FYLF populations cannot be dismissed. Significant Loss Threshold Significant loss will be assumed if sediment deposition is a predictor variable included in the “best” predictive model and impacts of the canal breach on the FYLF populations cannot be dismissed for population variation and population trends. If significant loss is assumed and contingency mitigation is required, population predictor variables will be used to define mitigation efforts. Commented [RP28]: Would strongly advocate not using a linear relationship for trends given how variable they can occur. There are other approaches that may be better, but particularly given the limited number of years in the dataset, and the imperfect detection of life stage data, seems a gam approach may be more suitable here. Commented [SW29]: Some flexibility is needed here to establish significant loss without all three metrics due to the high amount of variability in frog populations and uncertainty of the dataset that will be collected. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 6.0 References 6-1 May 2025April 2025April 2025March 2025 ©2025, Pacific Gas and Electric Company 6.0 References CFGC (California Fish and Game Commission). 2020. Notice of findings for Foothill yellow- legged frog (Rana boylii). CFGC March 10, 2020. FERC (Federal Energy Regulatory Commission). 2024. 2023 Project Canal Failure, Overtopping, and Erosion Incidents. Letter from Federal Energy Regulatory Commission, Office of Energy Projects, to Pacific Gas & Electric Company, dated November 19, 2024. PG&E (Pacific Gas & Electric Company) and Stillwater Sciences. 2023. Butte Creek Canal Breach—Foothill Yellow-legged Frog Study Results, 2023. Technical Memorandum to Lynn Coster, Senior Environmental Scientist, Central Valley Regional Quality Control Board; and Tanya Sheya, Environmental Program Manager, California Department of Fish and Wildlife. PG&E. 2025. Butte Creek Foothill Yellow-legged Frog Monitoring 2024. January 2025. Oakland, CA. Prepared by PG&E and Stillwater Sciences, Berkeley, CA. PG&E. 2008. DeSabla-Centerville Project (FERC Project No. 803-068), updated study results and license application sections—Updated Section 6.3.2.1: Assessment of RT&E amphibian and aquatic reptile species habitat near project reservoirs and project-affected stream reaches (Study 6.3.3-3), and Updated Section 7.3.2, Pacific Gas and Electric Company, San Francisco, CA. March 2008. Seltenrich, C. P. and A. C. Pool. 2002. A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii). May 2002. Pacific Gas and Electric Company, Technical and Ecological Services, unpublished report. USFWS (U.S. Fish and Wildlife Service). 2023. Endangered and threatened wildlife and plants; Foothill yellow-legged frog; Threatened status with Section 4(d) Rule for two distinct population segments and endangered status for two distinct population segments. Federal Register 88:166 Pages 59698-59727. August 29, 2023. USFWS. 2025. Endangered and threatened wildlife and plants; Designation of critical habitat for four distinct population segments of the foothill yellow-legged frog. Federal Register 90:8 Pages 3412-3470. January 14, 2025. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 From:Herman, Andie To:Allison, Anna@Wildlife; Reaves, Brittany L; Alber, Leslie@Wildlife; Weinmann, Sophia@Wildlife; "Millsap, Stephanie (stephanie_millsap@fws.gov)" Cc:Ramirez-Doble, Sky; Young, Megan; Cheslak, Edward Subject:Butte Creek FYLF Plan 2025-2028 Version 2 plus Date:Thursday, March 27, 2025 2:15:57 PM Attachments:Butte Creek FYLF Study Plan_2025 to 2028_V2 Redline_CDFW Comments_aeh response.docx Hello, Thank you all for participating in the third consultation meeting regarding foothill yellow-legged frog on Butte Creek. I am providing the Butte Creek Foothill Yellow-legged Frog Study Plan 2025-2028, with the Contingency Mitigation analysis proposal included. I have attached a redline with the CDFW comments and response, but please remember that I have not finished addressing some of the comments based on our conversation today. I will send an update next week with those comments addressed. For now, the intention is to get you the analysis language for review. I have requested availability from the Stillwater team and we will send out some scheduling options for our meeting the week of April 7 (but not April 7) as soon as possible.. Please feel free to reach out before that meeting with any questions or comments. Thank you, Andie Andie Herman | ( 530-680-9037| * andie.herman@pge.com Senior Aquatic Biologist - Herpetologist| Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 From:Reaves, Brittany L To:Herman, Andie Cc:Weinmann, Sophia@Wildlife; Alber, Leslie@Wildlife; Allison, Anna@Wildlife; Ramirez-Doble, Sky; Young, Megan; Cheslak, Edward; Millsap, Stephanie D; Bartoo, Aondrea Subject:RE: [EXTERNAL] Butte Creek Study Plan Comments Date:Monday, March 24, 2025 2:13:18 PM Attachments:image001.png image002.png Butte Creek FYLF Study Plan_2025 to 2028_V2 Redline_USFWS comments.docx CAUTION: EXTERNAL SENDER! This email was sent from an EXTERNAL source. Do you know this person? Are you expecting this email? Are you expecting any links or attachments? If suspicious, do not click links, open attachments, or provide credentials. Don't delete it. Report it by using the "Report Phish" button. I’ve attached the Service’s comments on the Butte Creek FYLF Plan. Additionally, we support CDFW’s comments. Thank you, Brittany Reaves Fish and Wildlife Biologist U.S. Fish and Wildlife Service (916) 930-5643 *********************** I am currently working part-time: Monday – Wednesday From: Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov> Sent: Friday, March 21, 2025 3:22 PM To: Herman, Andie <AEHb@pge.com> Cc: Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov>; Ramirez-Doble, Sky <S9RV@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com>; Reaves, Brittany L <brittany_reaves@fws.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; Bartoo, Aondrea <aondrea_bartoo@fws.gov> Subject: [EXTERNAL] Butte Creek Study Plan Comments This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Sophia Weinmann (she/her/hers) Sierra Fisheries Environmental Scientist, Foothill Yellow-legged Frogs Sophia.Weinmann@wildlife.ca.gov 916.767.3380 1701 Nimbus Rd, Rancho Cordova, CA 95670 www.wildlife.ca.gov Hello— Attached are CDFW’s comments on the Butte Creek FYLF Plan. Best- Sophia Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 February 25, 2025 February 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 February 25, 2025 May 2025March 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Citation: Pacific Gas and Electric Company. 2025. Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028. February 2025. Oakland, CA. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents i May 2025March 2025 ©2025, Pacific Gas and Electric Company TABLE OF CONTENTS 1.0 Introduction ....................................................................................................... 1-1 2.0 Study Site Selection .......................................................................................... 2-1 3.0 Methods............................................................................................................. 3-1 3.1 Habitat Assessments and Transects ..................................................................... 3-1 3.2 Visual Encounter Surveys .................................................................................... 3-1 3.3 Vegetation Encroachment Assessments .............................................................. 3-2 3.4 Decontamination Protocols .................................................................................. 3-2 4.0 Reporting........................................................................................................... 4-1 5.0 Contingency Mitigation Plan Placeholder ........................................................ 5-1 6.0 References ......................................................................................................... 6-1 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents ii May 2025March 2025 ©2025, Pacific Gas and Electric Company LIST OF TABLES Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. .... 2-1 LIST OF FIGURES Figure 2-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. ........................................................................................................................... 2-3 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 1.0 Introduction 1-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 1.0 Introduction Foothill yellow-legged frog (Rana boylii; FYLF) in Butte Creek is federally listed as threatened as part of the North Feather Distinct Population Segment (USFWS 2023). The California Fish and Game Commission listed the Feather River clade of FYLF as State threatened in 2020 (CFGC 2020). Butte Creek is also part of proposed critical habitat for North Fork Feather River Unit NF- 1 (USFWS 2025). Historically, Butte Creek has supported a robust population of FYLF that may be significant for species recovery efforts, as well as a likely candidate for future reintroduction efforts (B. Reaves, USFWS personal communication, February 5, 2025). On August 10, 2023, the Butte Canal, part of the Pacific Gas and Electric Company’s (PG&E) DeSabla-Centerville Hydroelectric Project (FERC No. 803), breached. This 2025–2028 study is a continuation of the foothill yellow-legged frogFYLF (Rana boylii; FYLF) study on Butte Creek initiated in fall 2023 to evaluate the current population status of FYLF downstream of the sediment deposition area. The 2023 study consisted of surveys in late September and early October, at three study sites (BC-4, BC-6, and BC-12); one adults and 12 successful metamorphosis (i.e., young-of- year (YOY)) were documented at BC-4, and three adults and one tadpole were documented at BC- 12 (PG&E and Stillwater Sciences 2023), .indicating successful metamorphosis in Butte Creek. In 2024 the study expanded to include seven study sites (BC-3, BC-4, BC-6, BC-7, BC-8, BC-9, and BC-12) with three to four surveys occurring at each site, except BC-9, from June through September. BC-9 was removed after one visit due to safety concerns. Transect habitat assessments were conducted at each site across suitable breeding habitat, typically located in an area with higher concentrations of observed tadpoles and/or young-of-year (YOY). No egg masses were observed at any of the sites; however, approximately 1,809 tadpoles and approximately 131 young-of- yearYOY were observed at all six sites indicating successful breeding and recruitment occurred throughout Butte Creek in 2024. Seventeen aAdult and two juvenile frogs were observed at all sites except BC-12 (PG&E and Stillwater Sciences 2025). BC-9 was removed due to safety concerns. In order to compare breeding and recruitment in Butte Creek, which was potentially impacted by the canal breach and sediment deposition, with sites not impacted by the canal breach, two additional monitoring sites on West Branch Feather River (WBFR) will be added to the monitoring program beginning in 2025. The two sites, WBFR-1 and WBFR-2, were also surveyed as part of relicensing studies performed in 2006 and will act as non-impact control sites. This 2025–2028 continuation study was developed in response to the Federal Energy Regulatory Commission (FERC) Notice of Violation letter, dated November 19, 2024 (FERC 2024). The study will include visual encounter surveys and habitat assessments. These surveys are designed to determine: (1) if reproduction is occurring throughout Butte Creek after the breach; (2) if recruitment is successful in the system; and (3) to compare current occupation and numbers to historical (i.e., 2006) baseline data. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 2.0 Study Site Selection Studies will continue at six sites surveyed in 2024 (BC-3, BC-4, BC-6, BC-7, BC-8, and BC-12) and two sites surveyed in 2006 (BC-1 and BC-2), and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). Six Eight study sites located downstream of the sediment deposition area, in three different reaches, were selected for surveys (Table 2-1, Figure 2-1). These sites, which are located on PG&E, U.S. Bureau of Land Management (BLM), California Department of Fish and Wildlife (CDFW), and private lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and nearly all life stages of frogs were identified at each location. BC-1 and BC-2 (from 2006 relicensing studies) were not selected as these sites were located furthest downstream from the sediment deposition area, are adjacent to BC-3, had no evidence of egg masses or tadpoles documented in 2006, and had documented occurrences of American bullfrogs (Lithobates catesbeianus). BC-9 was attempted in 2024 but determined to be unsafe to survey. Monitoring will begin in 2025 at two sites in WBFR (WBFR1 and WBFR-2) and, to the extent safe and feasible, will include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). These sites, which are located on Lassen National Forest and BLM lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and all life stages of frogs were identified at each location. Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. Reach Site Code Site Length (miles)a Description (2006a) BUTTE CREEK Forks of Butte Diversion Dam Area BC-12 1.2 This long, low gradient site was composed of long low gradient riffles as well as short high gradient riffles and shallow runs. The predominant substrates were boulder and cobble, with some occurrences of bedrock. DeSabla Powerhouse BC-8 1.0 High gradient site with step-run, cascade and mid-channel pool habitats. Substrate was mainly bedrock, cobble, and boulder. BC-7 0.6 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-6 0.3 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-4 0.5 Low gradient riffles and lateral scour ools were the prominent habitat t pe Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-2 May 2025March 2025 ©2025, Pacific Gas and Electric Company Reach Site Code Site Length (miles)a Description (2006a) BUTTE CREEK Centerville Powerhouse in this site. Substrate consisted of cobble, boulder, and large gravel patches. BC-3 0.3 This site was very low gradient, characterized by a shallow fast run with riffle habitat at the upstream end. Substrate was cobble and boulder. Banks were heavily vegetated. BC-2 1.1 The majority of this site was composed of low gradient riffles, slow-moving runs, and deep pools. Substrate was cobble and boulder throughout with some large woody debris. BC-1 1.2 The majority of this site was composed of low gradient riffles and runs, with few deep pools and slow-moving runs. Substrate was cobble and boulder throughout. WEST BRANCH FEATHER RIVER Upstream of Miocene Diversion WBFR-1 0.2 Slow lateral pools and mid-channel pools with cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. At Jordan Hill Bridge WBFR-2 0.3 Slow lateral pools and mid-channel pools with cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. a From PG&E 2008. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-3 May 2025March 2025 ©2025, Pacific Gas and Electric Company Figure 3-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 3.0 Methods Habitat assessments and population monitoring will be conducted based on procedures described in PG&E’s monitoring protocol A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii) (Seltenrich and Pool 2002, as previously revised). In addition to FYLF, all American bullfrogs (Lithobates catesbeianus) observed will be counted and their life stages recorded. sSurveyors will record all other amphibian and reptile species and any potential predators (e.g., fish, crayfish, and bullfrogs) observed. 3.1 Habitat Assessments and Transects At the end of each survey, general habitat for the entire survey site will be characterized and the following additional information will be recorded: air and mid-channel water temperatures; associated tributaries; fish, predators, or other aquatic herpetofauna observed; and observable anthropogenic disturbance (i.e., mining, recreation). Photographs will be taken of the survey start and end points at the downstream and upstream ends of the site and of representative habitat throughout the site. To compare potential observable changes in habitat suitability across years, surveyors established one transect per survey site across suitable breeding habitat in 2023 and/or 2024, typically located in an area with higher concentrations of observed tadpoles and/or YOY FYLF. Similar transects will be established at BC-1, BC-2, WBFR-1, and WBFR-2 in 2025. The following physical characteristics will be measured or estimated across each transect: geomorphic unit type; aquatic substrate and substrate embeddedness; wetted width and bankfull width (measured with a rangefinder); turbidity (visual assessment); river and bank gradient; upland habitat type; percent aquatic cover; percent canopy; and percent margin, emergent, and submerged vegetation by type. Photos will be taken of each transect from one or both banks looking toward the channel, and mid- channel photos will be taken looking both upstream and downstream. 3.2 Visual Encounter Surveys Monitoring of flows at PG&E gages BW-97 and , BW-98, and Department of Water Resources gage WFR (West Branch Feather River near Magalia) will begin April 15 of each year. Two to three early season surveys will target egg masses and begin as flows allow safe access to sites. Surveys at lower elevation sites may begin earlier than higher elevation sites if safely accessible earlier. Surveys will be conducted every 10-14 days thereafter until eggs have hatched or until no new egg masses are found for two consecutive survey rounds. Once egg masses or tadpoles are observed, each survey round will occur in intervals of 10–-14 days, in order to capture new egg mass or tadpole groups. If signs of breeding are not observed at any sites, an additional survey will be conducted during the tadpole rearing season. Two later-season surveys will be performed, one in August and one in September, to target YOY.Three to four visual encounter surveys (VESs) will be conducted each year, if feasible based on flows and site access. These surveys will focus on different FYLF life stages. The first survey will target egg masses. If a relatively substantial number of egg masses are found during the first VES (e.g., as compared with 2006 surveys), or Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-2 May 2025March 2025 ©2025, Pacific Gas and Electric Company high flows delay egg mass surveys, follow-up egg mass surveys may be cancelled at the discretion of PG&E. The second to last survey will target tadpoles. And the final survey will target young- of-year. Surveys will be conducted by teams of two-to-four surveyors working in tandem to maximize access to all shoreline habitats. During egg mass surveys, one surveyor will snorkel in suitable habitat, as safe and feasible. Data collection will include location, life stage, Gosner stage (for egg masses), total length (for tadpoles), depth at observation (for egg masses and tadpoles), perch or attachment substrate, snout-urostyle length, sex (if known), body condition (e.g., emaciated, injured), dominant riparian type at observation, geomorphic unit at observation, nearest bank, plus Universal Transverse Mercator (UTM) coordinates (measured using handheld global positioning system [GPS] units) for all observations (groupings of multiple YOY are recorded as an approximate range in meters from an initial GPS waypoint). 3.3 Vegetation Encroachment Assessments Vegetation at each survey site will be assessed. If it is determined that vegetation encroachment may be impacting the suitability of a site for breeding and that localized removal of vegetation (e.g., willow, alder, blackberry) could enhance site suitability, small- scale removal efforts will be considered each fall. Consideration will be given to private property access and permitting needs, which may make it infeasible to complete vegetation removal at sites. 3.4 Decontamination Protocols Decontamination protocols will be employed as specified in handling permits, or using currently accepted protocols, to minimize the potential to spread invasive species (e.g., chytrid fungus). Decontamination of boots, waders, and equipment will be practiced for all surveys. In addition, some field gear (waders, boots, etc.) may be dedicated for use only in the Butte Creek and/or WBFR watersheds. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 4.0 Reporting 4-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 4.0 Reporting A technical report will be prepared by January 31 of each year following surveys, detailing survey methods and results, including a discussion of habitat assessments as well as any meaningful comparisons of survey results with 2006 results that would inform potential impacts of 2023 sediment inputs into Butte Creek. The technical report will also include a summary of prior information collected about FYLF on Butte Creek in previous years, including any incidental observations. Where data are available, the following information regarding FYLF sightings will be included: location where FYLF were observed, day/time of observation, number of each life stage present, survey methodology utilized (e.g., walking vs. snorkeling), mean streamflow (in cubic feet per second) at the time of the survey, water temperature from both thalweg and nearshore environments (where available), weather on the day of the survey, and turbidity observations. Bullfrog observations will be summarized and reported. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Contingency Mitigation Plan Placeholder 5-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 5.0 Contingency Mitigation Plan Placeholder Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 6.0 References 6-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 6.0 References CFGC (California Fish and Game Commission). 2020. Notice of findings for Foothill yellow- legged frog (Rana boylii). CFGC March 10, 2020. FERC (Federal Energy Regulatory Commission). 2024. 2023 Project Canal Failure, Overtopping, and Erosion Incidents. Letter from Federal Energy Regulatory Commission, Office of Energy Projects, to Pacific Gas & Electric Company, dated November 19, 2024. PG&E (Pacific Gas & Electric Company) and Stillwater Sciences. 2023. Butte Creek Canal Breach—Foothill Yellow-legged Frog Study Results, 2023. Technical Memorandum to Lynn Coster, Senior Environmental Scientist, Central Valley Regional Quality Control Board; and Tanya Sheya, Environmental Program Manager, California Department of Fish and Wildlife. PG&E. 2025. Butte Creek Foothill Yellow-legged Frog Monitoring 2024. January 2025. Oakland, CA. Prepared by PG&E and Stillwater Sciences, Berkeley, CA. PG&E. 2008. DeSabla-Centerville Project (FERC Project No. 803-068), updated study results and license application sections—Updated Section 6.3.2.1: Assessment of RT&E amphibian and aquatic reptile species habitat near project reservoirs and project-affected stream reaches (Study 6.3.3-3), and Updated Section 7.3.2, Pacific Gas and Electric Company, San Francisco, CA. March 2008. Seltenrich, C. P. and A. C. Pool. 2002. A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii). May 2002. Pacific Gas and Electric Company, Technical and Ecological Services, unpublished report. USFWS (U.S. Fish and Wildlife Service). 2023. Endangered and threatened wildlife and plants; Foothill yellow-legged frog; Threatened status with Section 4(d) Rule for two distinct population segments and endangered status for two distinct population segments. Federal Register 88:166 Pages 59698-59727. August 29, 2023. USFWS. 2025. Endangered and threatened wildlife and plants; Designation of critical habitat for four distinct population segments of the foothill yellow-legged frog. Federal Register 90:8 Pages 3412-3470. January 14, 2025. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Sophia Weinmann (she/her/hers) Sierra Fisheries Environmental Scientist, Foothill Yellow-legged Frogs From:Herman, Andie To:Weinmann, Sophia@Wildlife Cc:Alber, Leslie@Wildlife; Allison, Anna@Wildlife; Ramirez-Doble, Sky; Young, Megan; Cheslak, Edward; brittany_reaves@fws.gov; stephanie_millsap@fws.gov; Bartoo, Aondrea Subject:RE: Butte Creek Study Plan Comments Date:Friday, March 21, 2025 3:41:03 PM Attachments:image001.png image002.png Hi Sophia, Thank you for submitting comments. I look forward to reviewing and discussing them next week. Thanks again, Andie Andie Herman | ( 530-680-9037| * andie.herman@pge.com Senior Aquatic Biologist - Herpetologist| Pacific Gas and Electric Company From: Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov> Sent: Friday, March 21, 2025 3:22 PM To: Herman, Andie <AEHb@pge.com> Cc: Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov>; Ramirez-Doble, Sky <S9RV@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com>; brittany_reaves@fws.gov; stephanie_millsap@fws.gov; Bartoo, Aondrea <aondrea_bartoo@fws.gov> Subject: Butte Creek Study Plan Comments CAUTION: EXTERNAL SENDER! This email was sent from an EXTERNAL source. Do you know this person? Are you expecting this email? Are you expecting any links or attachments? If suspicious, do not click links, open attachments, or provide credentials. Don't delete it. Report it by using the "Report Phish" button. Hello— Attached are CDFW’s comments on the Butte Creek FYLF Plan. Best- Sophia Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Sophia.Weinmann@wildlife.ca.gov 916.767.3380 1701 Nimbus Rd, Rancho Cordova, CA 95670 www.wildlife.ca.gov Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 February 25, 2025 February 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 PACIFIC GAS AND ELECTRIC COMPANY Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 February 25, 2025 May 2025March 2025 ©2025, Pacific Gas and Electric Company Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Citation: Pacific Gas and Electric Company. 2025. Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028. February 2025. Oakland, CA. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents i May 2025March 2025 ©2025, Pacific Gas and Electric Company TABLE OF CONTENTS 1.0 Introduction ....................................................................................................... 1-1 2.0 Study Site Selection .......................................................................................... 2-1 3.0 Methods............................................................................................................. 3-1 3.1 Habitat Assessments and Transects ..................................................................... 3-1 3.2 Visual Encounter Surveys .................................................................................... 3-1 3.3 Vegetation Encroachment Assessments .............................................................. 3-2 3.4 Decontamination Protocols .................................................................................. 3-2 4.0 Reporting........................................................................................................... 4-1 5.0 Contingency Mitigation Plan Placeholder ........................................................ 5-1 6.0 References ......................................................................................................... 6-1 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 Table of Contents ii May 2025March 2025 ©2025, Pacific Gas and Electric Company LIST OF TABLES Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. .... 2-1 LIST OF FIGURES Figure 2-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. ........................................................................................................................... 2-3 Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 1.0 Introduction 1-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 1.0 Introduction Foothill yellow-legged frog (Rana boylii; FYLF) in Butte Creek is listed as threatened as part of the North Feather Distinct Population Segment (USFWS 2023). The California Fish and Game Commission listed the Feather River clade of FYLF as threatened in 2020 (CFGC 2020). Butte Creek is also part of proposed critical habitat for North Fork Feather River Unit NF-1 (USFWS 2025). Historically, Butte Creek has supported a robust population of FYLF that may be significant for species recovery efforts, as well as a likely candidate for future reintroduction efforts (B. Reaves, USFWS personal communication, February 5, 2025). On August 10, 2023, the Butte Canal, part of the Pacific Gas and Electric Company’s (PG&E) DeSabla-Centerville Hydroelectric Project (FERC No. 803), breached. This 2025–2028 study is a continuation of the foothill yellow-legged frogFYLF (Rana boylii; FYLF) study on Butte Creek initiated in fall 2023 to evaluate the current population status of FYLF downstream of the sediment deposition area. The 2023 study consisted of surveys in late September and early October, at three study sites (BC-4, BC-6, and BC-12); one adults and 12 successful metamorphosis (i.e., young-of- year (YOY)) were documented at BC-4, and three adults and one tadpole were documented at BC- 12 (PG&E and Stillwater Sciences 2023), .indicating successful metamorphosis in Butte Creek. In 2024 the study expanded to include seven study sites (BC-3, BC-4, BC-6, BC-7, BC-8, BC-9, and BC-12) with three to four surveys occurring at each site, except BC-9, from June through September. BC-9 was removed after one visit due to safety concerns. Transect habitat assessments were conducted at each site across suitable breeding habitat, typically located in an area with higher concentrations of observed tadpoles and/or young-of-year (YOY). No egg masses were observed at any of the sites; however, approximately 1,809 tadpoles and approximately 131 young-of- yearYOY were observed at all six sites indicating successful breeding and recruitment occurred throughout Butte Creek in 2024. Seventeen aAdult and two juvenile frogs were observed at all sites except BC-12 (PG&E and Stillwater Sciences 2025). BC-9 was removed due to safety concerns. In order to compare breeding and recruitment in Butte Creek, which was potentially impacted by the canal breach and sediment deposition, with sites not impacted by the canal breach, two additional monitoring sites on West Branch Feather River (WBFR) will be added to the monitoring program beginning in 2025. The two sites, WBFR-1 and WBFR-2, were also surveyed as part of relicensing studies performed in 2006 and will act as non-impact control sites. This 2025–2028 continuation study was developed in response to the Federal Energy Regulatory Commission Notice of Violation letter, dated November 19, 2024 (FERC 2024). The study will include visual encounter surveys and habitat assessments. These surveys are designed to determine: (1) if reproduction is occurring throughout Butte Creek after the breach; (2) if recruitment is successful in the system; and (3) to compare current occupation and numbers to historical (i.e., 2006) baseline data. Commented [LA1]: Please include if this was do to timing or other factors or if there were not any egg masses detected during the reedin season. Commented [SW2]: Please include additional information about why these are suitable comparison sites as well as why no sites above the canal breach are included. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 2.0 Study Site Selection Studies will continue at six sites surveyed in 2024 (BC-3, BC-4, BC-6, BC-7, BC-8, and BC-12) and two sites surveyed in 2006 (BC-1 and BC-2), and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). Six Eight study sites located downstream of the sediment deposition area, in three different reaches, were selected for surveys (Table 2-1, Figure 2-1). These sites, which are located on PG&E, U.S. Bureau of Land Management (BLM), California Department of Fish and Wildlife, and private lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and nearly all life stages of frogs were identified at each location. BC-1 and BC-2 (from 2006 relicensing studies) were not selected as these sites were located furthest downstream from the sediment deposition area, are adjacent to BC-3, had no evidence of egg masses or tadpoles documented in 2006, and had documented occurrences of American bullfrogs (Lithobates catesbeianus). BC-9 was attempted in 2024 but determined to be unsafe to survey. Monitoring will begin in 2025 at two sites in WBFR (WBFR1 and WBFR-2) and to the extent safe and feasible, include similar locations surveyed during the 2006 DeSabla-Centerville Project relicensing studies (PG&E 2008). These sites, which are located on Lassen National Forest and BLM lands in Butte County, were surveyed for FYLF during relicensing studies in 2006 and all life stages of frogs were identified at each location. Table 2-1. Foothill yellow-legged frog study sites for the Butte Creek Canal Breach. Reach Site Code Site Length (miles)a Description (2006a) BUTTE CREEK Forks of Butte Diversion Dam Area BC-12 1.2 This long, low gradient site was composed of long low gradient riffles as well as short high gradient riffles and shallow runs. The predominant substrates were boulder and cobble, with some occurrences of bedrock. DeSabla Powerhouse BC-8 1.0 High gradient site with step-run, cascade and mid-channel pool habitats. Substrate was mainly bedrock, cobble, and boulder. BC-7 0.6 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-6 0.3 Site contained mid-channel pools, low gradient riffles, and slow/deep runs. Substrate consisted of boulder, cobble, and gravel bars. BC-4 0.5 Low gradient riffles and lateral scour ools were the prominent habitat type Commented [SW3]: Please note the land of Butte Creek Ecological Preserve was transferred to the Mechoopda of Chico Rancheria in Se tember 2023. Commented [LA4]: This seems redundant to the paragraph above Commented [SW5]: If it has been decided to not include the tributaries at BC-6, please include the rational. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-2 May 2025March 2025 ©2025, Pacific Gas and Electric Company Reach Site Code Site Length (miles)a Description (2006a) BUTTE CREEK Centerville Powerhouse in this site. Substrate consisted of cobble, boulder, and large gravel patches. BC-3 0.3 This site was very low gradient, characterized by a shallow fast run with riffle habitat at the upstream end. Substrate was cobble and boulder. Banks were heavily vegetated. BC-2 1.1 The majority of this site was composed of low gradient riffles, slow-moving runs, and deep pools. Substrate was cobble and boulder throughout with some large woody debris. BC-1 1.2 The majority of this site was composed of low gradient riffles and runs, with few deep pools and slow-moving runs. Substrate was cobble and boulder throughout. WEST BRANCH FEATHER RIVER Upstream of Miocene Diversion WBFR-1 0.2 Slow lateral pools and mid-channel pools with cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. At Jordan Hill Bridge WBFR-2 0.3 Slow lateral pools and mid-channel pools with cobble bars and numerous boulder outcroppings. Site has both boulder and cobble substrate. a From PG&E 2008. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 2.0 Study Site Selection 2-3 May 2025March 2025 ©2025, Pacific Gas and Electric Company Figure 3-1. Foothill yellow-legged frog monitoring area for the Butte Creek Canal Breach. Commented [SW6]: Please add Hendricks Diversion Dam to the map Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 3.0 Methods Habitat assessments and population monitoring will be conducted based on procedures described in PG&E’s monitoring protocol A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii) (Seltenrich and Pool 2002, as previously revised). In addition to FYLF, all American bullfrogs (Lithobates catesbeianus) observed will be counted and their life stages recorded. sSurveyors will record all other amphibian and reptile species and any potential predators (e.g., fish, crayfish, and bullfrogs) observed. 3.1 Habitat Assessments and Transects At the end of each survey, general habitat for the entire survey site will be characterized and the following additional information will be recorded: air and mid-channel water temperatures; associated tributaries; fish, predators, or other aquatic herpetofauna observed; and observable anthropogenic disturbance (i.e., mining, recreation). Photographs will be taken of the survey start and end points at the downstream and upstream ends of the site and of representative habitat throughout the site. To compare potential observable changes in habitat suitability across years, surveyors established one transect per survey site across suitable breeding habitat in 2023 and/or 2024, typically located in an area with higher concentrations of observed tadpoles and/or YOY FYLF. Similar transects will be established at BC-1, BC-2, WBFR-1, and WBFR-2 in 2025. The following physical characteristics will be measured or estimated across each transect: geomorphic unit type; aquatic substrate and substrate embeddedness; wetted width and bankfull width (measured with a rangefinder); turbidity (visual assessment); river and bank gradient; upland habitat type; percent aquatic cover; percent canopy; and percent margin, emergent, and submerged vegetation by type. Photos will be taken of each transect from one or both banks looking toward the channel, and mid- channel photos will be taken looking both upstream and downstream. 3.2 Visual Encounter Surveys Monitoring of flows at PG&E gages BW-97 and , BW-98, and Department of Water Resources gage WFR (West Branch Feather River near Magalia) will begin April 15 of each year. Two to three early season surveys will target egg masses and begin as flows allow safe access to sites. Surveys at lower elevation sites may begin earlier than higher elevation sites if safely accessible earlier. Once egg masses or tadpoles are observed, each survey round will occur in intervals of 10– -14 days, in order to capture new egg mass or tadpole groups. If signs of breedingegg masses are not observed at a thatny sites, an additional survey will be conducted during the tadpole rearing season. Two later-season surveys will be performed, one in August and one in September, to target YOY.Three to four visual encounter surveys (VESs) will be conducted each year, if feasible based on flows and site access. These surveys will focus on different FYLF life stages. The first survey will target egg masses. If a relatively substantial number of egg masses are found during the first VES (e.g., as compared with 2006 surveys), or high flows delay egg mass surveys, follow-up egg mass surveys may be cancelled at the discretion of PG&E. The second to last survey will target Commented [SW7]: When the platform becomes accessible to the public, can you also record all bullfrog observations via CDFW’s ESRI Quick Capture app? This would assist with statewide efforts to gather bullfrog data. Commented [SW8]: Please clarify. Will this occur remotely by assessing flow rates and images or will it involve in-person checks of conditions at survey sites? What will be the CFS cutoff used to determine survey safety and timing? Will water temperature also be monitored? Commented [SW9]: Please clarify the survey approach for egg masses. Our preference is that once sites are deemed safe (based on CFS cutoff) surveys will be conducted every 10-14 days thereafter until eggs have hatched or until no new egg masses are found for two consecutive survey rounds at sites identified during habitat assessment surve s. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 3.0 Methods 3-2 May 2025March 2025 ©2025, Pacific Gas and Electric Company tadpoles. And the final survey will target young-of-year. Surveys will be conducted by teams of two-to-four surveyors working in tandem and moving upstream to maximize access to all shoreline habitats and minimize double counting. During egg mass surveys, one surveyor will snorkel in suitable habitat, as safe and feasible. Data collection will include location, life stage, Gosner stage (for egg masses), total length (for tadpoles), depth at observation (for egg masses and tadpoles), perch or attachment substrate, snout-urostyle length, sex (if known), body condition (e.g., emaciated, injured), dominant riparian type at observation, geomorphic unit at observation, nearest bank, plus Universal Transverse Mercator (UTM) coordinates (measured using handheld global positioning system [GPS] units) for all observations (groupings of multiple YOY are recorded as an approximate range in meters from an initial GPS waypoint). 3.3 Vegetation Encroachment Assessments Vegetation at each survey site will be assessed. If it is determined that vegetation encroachment may be impacting the suitability of a site for breeding and that localized removal of vegetation (e.g., willow, alder, blackberry) could enhance site suitability, small- scale removal efforts will be considered each fall. Consideration will be given to private property access and permitting needs, which may make it infeasible to complete vegetation removal at sites. 3.4 Decontamination Protocols Decontamination protocols will be employed as specified in handling permits, or using currently accepted protocols, to minimize the potential to spread invasive species (e.g., chytrid fungus). Decontamination of boots, waders, and equipment will be practiced for all surveys. In addition, some field gear (waders, boots, etc.) may be dedicated for use only in the Butte Creek and/or WBFR watersheds. Commented [SW10]: Is it possible to take chin spot photos as well? Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 4.0 Reporting 4-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 4.0 Reporting A technical report will be prepared by January 31 of each year following surveys, detailing survey methods and results, including a discussion of habitat assessments as well as any meaningful comparisons of survey results with 2006 results that would inform potential impacts of 2023 sediment inputs into Butte Creek. The technical report will also include a summary of prior information collected about FYLF on Butte Creek in previous years, including any incidental observations. Where data are available, the following information regarding FYLF sightings will be included: location where FYLF were observed, day/time of observation, number of each life stage present, survey methodology utilized (e.g., walking vs. snorkeling), mean streamflow (in cubic feet per second) at the time of the survey, water temperature from both thalweg and nearshore environments (where available), weather on the day of the survey, and turbidity observations. Bullfrog observations will be summarized and reported. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 5.0 Contingency Mitigation Plan Placeholder 5-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 5.0 Contingency Mitigation Plan Placeholder Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Foothill Yellow-legged Frog Study Plan: Butte Creek 2025–2028 6.0 References 6-1 May 2025March 2025 ©2025, Pacific Gas and Electric Company 6.0 References CFGC (California Fish and Game Commission). 2020. Notice of findings for Foothill yellow- legged frog (Rana boylii). CFGC March 10, 2020. FERC (Federal Energy Regulatory Commission). 2024. 2023 Project Canal Failure, Overtopping, and Erosion Incidents. Letter from Federal Energy Regulatory Commission, Office of Energy Projects, to Pacific Gas & Electric Company, dated November 19, 2024. PG&E (Pacific Gas & Electric Company) and Stillwater Sciences. 2023. Butte Creek Canal Breach—Foothill Yellow-legged Frog Study Results, 2023. Technical Memorandum to Lynn Coster, Senior Environmental Scientist, Central Valley Regional Quality Control Board; and Tanya Sheya, Environmental Program Manager, California Department of Fish and Wildlife. PG&E. 2025. Butte Creek Foothill Yellow-legged Frog Monitoring 2024. January 2025. Oakland, CA. Prepared by PG&E and Stillwater Sciences, Berkeley, CA. PG&E. 2008. DeSabla-Centerville Project (FERC Project No. 803-068), updated study results and license application sections—Updated Section 6.3.2.1: Assessment of RT&E amphibian and aquatic reptile species habitat near project reservoirs and project-affected stream reaches (Study 6.3.3-3), and Updated Section 7.3.2, Pacific Gas and Electric Company, San Francisco, CA. March 2008. Seltenrich, C. P. and A. C. Pool. 2002. A Standardized Approach for Habitat Assessments and Visual Encounter Surveys for the Foothill Yellow-legged Frog (Rana boylii). May 2002. Pacific Gas and Electric Company, Technical and Ecological Services, unpublished report. USFWS (U.S. Fish and Wildlife Service). 2023. Endangered and threatened wildlife and plants; Foothill yellow-legged frog; Threatened status with Section 4(d) Rule for two distinct population segments and endangered status for two distinct population segments. Federal Register 88:166 Pages 59698-59727. August 29, 2023. USFWS. 2025. Endangered and threatened wildlife and plants; Designation of critical habitat for four distinct population segments of the foothill yellow-legged frog. Federal Register 90:8 Pages 3412-3470. January 14, 2025. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 From:Weinmann, Sophia@Wildlife To:Herman, Andie; Allison, Anna@Wildlife; Reaves, Brittany L; Alber, Leslie@Wildlife Cc:Ramirez-Doble, Sky; Young, Megan; Cheslak, Edward Subject:RE: Butte Creek FYLF Plan 2025-2028 Version 2 Date:Thursday, February 27, 2025 11:34:34 AM CAUTION: EXTERNAL SENDER! This email was sent from an EXTERNAL source. Do you know this person? Are you expecting this email? Are you expecting any links or attachments? If suspicious, do not click links, open attachments, or provide credentials. Don't delete it. Report it by using the "Report Phish" button. Hi Andie— Thank you for the updated study plan. We will review and come prepared to discuss at our upcoming meeting. Best- Sophia Sophia Weinmann (she/her/hers) Environmental Scientist Foothill Yellow-legged Frogs From: Herman, Andie <AEHb@pge.com> Sent: Tuesday, February 25, 2025 6:27 PM To: Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov>; Reaves, Brittany L <brittany_reaves@fws.gov>; Alber, Leslie@Wildlife <Leslie.Alber@wildlife.ca.gov>; Weinmann, Sophia@Wildlife <Sophia.Weinmann@Wildlife.ca.gov> Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Young, Megan <MRY2@pge.com>; Cheslak, Edward <EFC3@pge.com> Subject: Butte Creek FYLF Plan 2025-2028 Version 2 WARNING: This message is from an external source. Verify the sender and exercise caution when clicking links or opening attachments. Hello, Thank you all for participating in the second consultation meeting regarding foothill yellow-legged frog on Butte Creek. I am providing the Butte Creek Foothill Yellow-legged Frog Study Plan 2025-2028, revised based on your comments and our discussion. I have attached a redline and a clean Word version of the revised plan for your review. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 I would like to point out one item that is new to this document. As we discussed, it may not be possible to gain access to a site above the impact area or tributaries associated with some of the sites due to private property. We also don’t have historical data for these locations. I am proposing that we include two sites on the West Branch Feather River, which were also surveyed during the 2006 relicensing studies, as control sites. I compared flows on Butte Creek and WBFR and the trends are the same. I look forward to our next meeting on March 27, 2025. Please feel free to reach out before that meeting with any questions or comments. Thank you, Andie Andie Herman | ( 530-680-9037| * andie.herman@pge.com Senior Aquatic Biologist - Herpetologist| Pacific Gas and Electric Company You can read about PG&E’s data privacy practices at PGE.com/privacy. Document Accession #: 20250519-5175 Filed Date: 05/19/2025 Document Content(s) PGE20250519_803_DeSablaCenterville_NOV_FYLF_Plan.pdf......................1 Document Accession #: 20250519-5175 Filed Date: 05/19/2025