Loading...
HomeMy WebLinkAbout06.18.2024 Board Correspondence - FW_ Environmental and Recreational Compliance Report submitted in FERC P-619-000 by Pacific Gas and Electric Company,et al.From:Clerk of the Board To:Bennett, Robin; Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Lee, Lewis; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Zepeda, Elizabeth; Loeser, Kamie Cc:Nevers, Dawn Subject:Board Correspondence - FW: Environmental and Recreational Compliance Report submitted in FERC P-619-000 by Pacific Gas and Electric Company,et al. Date:Tuesday, June 18, 2024 1:49:03 PM Please see Board Correspondence - -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Tuesday, June 18, 2024 12:16 PM Subject: Environmental and Recreational Compliance Report submitted in FERC P-619-000 by Pacific Gas and Electric Company,et al. .ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying.. On 6/18/2024, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Pacific Gas and Electric Company No Organization Found (as Agent) Docket(s): P-619-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Environmental and Recreational Compliance Report Description: Pacific Gas and Electric Company submits schedule update on improvements identified in the Table 3.1-1 Implementation Schedule of the Recreation Management Plan re the Bucks Creek Hydroelectric Project under P-619. To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20240618- 5127__;!!KNMwiTCp4spf!FeEOKwSnX3ESoPOpRoVKGNvnAB8nLfv1zfuh8LERJGax3FmrCU- RgJgCLYxOblGrYa5VjZvcPO__m65MPpPGxQqFM9myp24zBYkP$ To modify your subscriptions, click here: RgJgCLYxOblGrYa5VjZvcPO__m65MPpPGxQqFM9mypzNAd1Hs$ ------------------------------------------------------------------------ Please do not respond to this email. Online help is available here: https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!FeEOKwSnX3ESoPOpRoVKGNvnAB8nLfv1zfuh8LERJGax3FmrCU- RgJgCLYxOblGrYa5VjZvcPO__m65MPpPGxQqFM9mypzeZ2FR1$ or for phone support, call 866-208-3676. Power Generation 300 Lakeside Drive Oakland, CA 94612 Mailing Address: P.O. Box 28209 Oakland, CA 94604 Public June 18, 2024 Via Electronic Submittal (E-File) Debbie-Anne Reese, Acting Secretary Federal Energy Regulatory Commission 888 First Street, N. E. Washington, D.C. 20426 Re: Bucks Creek Hydroelectric Project, FERC No. 619-CA-CA Schedule Update – Recreation Management Plan State Water Resources Control Board 401 Water Quality Certification Condition 21 and U.S. Department of Agriculture, Forest Service’s section 4(e) Condition No. 55 Dear Secretary Reese: Pacific Gas and Electric Company (PG&E) is writing to provide a schedule update on improvements identified in the Table 3.1-1 Implementation Schedule of the Recreation Management Plan (RMP) for PG&E and City of Santa Clara’s (Licensees) Bucks Creek Hydroelectric Project, Federal Energy Regulatory Commission (FERC) No. 619. FERC issued a new license for the Bucks Creek Project on June 16, 2022. State Water Resources Control Board (SWRCB) 401 Water Quality Certification (WQC) Condition 21 and U.S. Department of Agriculture, Forest Service’s (“Forest Service”) section 4(e) Condition No. 55 require the licensees implement the Bucks Creek RMP. The RMP anticipates a 5-year, three-step planning and implementation process for the construction/reconstruction of project facilities (Planning and Designing for Construction and Reconstruction of Project Recreation Facilities). As stated in RMP Section 3.1.4, “Steps in this process include (1) site planning (design narrative and site conceptual plan); (2) preparing a site development plan and construction plan; and (3) contracting and constructing each facility.” These critical steps ensure a quality project and safe, continuous, reliable long-term access to recreational facilities for the public. Standard engineering and construction practices require design, review, and consultation, which takes more time than the current implementation schedule allows. Section 3.1.4 of the RMP also discusses scheduling uncertainties for activities such as environmental analyses, consultations, and permitting. For example, environmental analysis and permitting work could take place during all three steps of the planning and implementation process for any of the construction/reconstruction projects. The RMP goes on to clarify that, as a rule, construction may not occur until all necessary environmental review and permitting requirements have been completed. In contrast to the 5-year, three-step process and scheduling uncertainties discussed in the text of the RMP, Table 3.1-1 (Implementation Schedule for Plan Measures) identifies significant, ongoing construction/reconstruction projects beginning in the first year following license issuance (2023). The implementation schedule set forth in Table 3.1-1 does not accommodate a multi-year, three- step planning and implementation process that is described in the text of the RMP. Document Accession #: 20240618-5127 Filed Date: 06/18/2024 Debbie-Anne Reese, Acting Secretary June 18, 2024 Page 2 Public Section 3.1.4.3 of the RMP (Contracting and Construction) allows for flexibility in the implementation schedule for project facilities on Forest Service lands. Section 3.1.4.3 states that “the implementation schedule for constructing or reconstructing these facilities may be revised, as needed, upon agreement between Licensees and the Forest Service.” Forest Service section 4(e) Condition No. 49 require the licensees implement the Bucks Creek Transportation Management Plan (TMP). Table 2.10-1 of the TMP (Implementation Schedule for Long-Term Maintenance Activities) identifies ongoing, long-term roadwork beginning the first year after license issuance (2023). The TMP describes the process for reviewing and, if necessary, modifying the implementation schedule: “Licensees and the Forest Service will discuss the Plan scheduled elements at the Annual Forest Service Consultation Meeting (described in Section 2.13) and determine the [sic] whether or not to modify the implementation schedule of repairs and improvements.” Many of the measures identified in the RMP and TMP Implementation Schedules provide very little background information, justification, or context. This sort of ambiguity could be properly addressed during a multi-year, three-step planning and implementation process. There is great potential for both spatial and temporal overlap between the TMP measures and RMP measures as currently scheduled. Based on the aggressive, back-to-back Implementation Schedules in the TMP and RMP, many of these facilities could easily be closed for multiple, consecutive years. PG&E has compared the TMP and RMP implementation schedules to maximize efficiency and minimize conflicts while promoting the successful implementation of both plans. Attached is the updated TMP and RMP scheduled for years 1-9 (Enclosure 1). PG&E presented the updated schedule during the Annual Recreation Management Plan Meeting held on March 27, 2024. As outlined in the RMP, PG&E sought approval from the Forest Service in an email dated April 1, 2024. The Forest Service provided a concurrence email on June 14, 2024 (Enclosure 2). For general questions, please contact PG&E’s Senior Land Planner, Jim McKay at (530) 896-4262 or PG&E’s Senior License Coordinator, Jamie Visinoni, at (530) 215-6676. Sincerely, Matthew Joseph Supervisor, Hydro License Compliance Enclosure: 1. RMP and TMP Schedule Update 2. Schedule Update Concurrence email from Forest Service cc: via email w/Enclosure Erika Brenzovich (Forest Service) – Erika.brenzovich@usda.gov Leslie Edlund (Forest Service) – Leslie.edlund@usda.gov Kurt Sable (Forest Service) – kurt.sable@usda.gov Colleen Heard (Forest Service) – coleen.heard@usda.gov Dawn Alvarez (Forest Service) – dawn.alvarez@usda.gov Document Accession #: 20240618-5127 Filed Date: 06/18/2024 ENCLOSURE 1 Document Accession #: 20240618-5127 Filed Date: 06/18/2024 Green font Project acelerated Red font Project postponed Justification RMP Grizzly Forebay Campground 2023 - 1 2024 RMP 2025 - 3 2025 RMP Install signage 2025 - 3 2025 TMP Bucks Penstock Road Construct Downslope Stabilization 2023 - 1 2026 Schedule update approved at 2023 FS Annual Meeting, T-Line could complete several of the projects and may have additional scope added. Potential to defer to allow T-Line SWPP to closeout and better coordinate. TMP Bucks Penstock Road Construct Culvert Replacements 2025 - 3 2026 Schedule update approved at 2023 FS Annual Meeting, T-Line could complete several of the projects and may have additional scope added. Potential to defer to allow T-Line SWPP to closeout and better coordinate. TMP Bucks Penstock Road Construct Roadside Conveyance Ditches with Culverts 2029 - 7 2026 Schedule update approved at 2023 FS Annual Meeting, T-Line could complete several of the projects and may have additional scope added. Potential to defer to allow T-Line SWPP to closeout and better coordinate. TMP Mill Creek Campground 2025 - 3 2026 TMP Mill Creek Campground 2025 - 3 2026 TMP Mill Creek Campground 2027 - 5 2026 RMP 2027 - 5 2026 RMP Mill Creek Campground 2027 - 5 2026 RMP 2027 - 5 2026 RMP Replace water system 2026 - 4 2026 TMP Sandy Point Day Use Clear vegetation 2026 - 4 2026 TMP Sandy Point Day Use 2027 - 5 2026 TMP Hutchins Group Campground Reconstruct Campground Access Road Entrance 2025 - 3 2027 minimize recreation impacts over multiple TMP Hutchins Group Campground Dirt Road Resurfacing 2025 - 3 2027 minimize recreation impacts over multiple TMP Hutchins Group Campground Construct Culvert Outfall Transitions 2025 - 3 2027 minimize recreation impacts over multiple TMP Hutchins Group Campground Remove and Replace Pavement 2031 - 9 2027 minimize recreation impacts over multiple RMP Hutchins Group Campground Reconstruct campground 2031 - 9 2027 minimize recreation impacts over multiple RMP Hutchins Group Campground Hutchins Group Campground to Lower Bucks Lake Trail 2031 - 9 2027 minimize recreation impacts over multiple RMP Hutchins Group Campground Replace Water System New 2027 RMP 2029 - 7 2028 RMP 2029 - 7 2028 RMP 2030 - 8 2028 TMP Haskins Valley Campground 2030 - 8 2028 RMP Construct 2029 - 7 2029 Plan Facility Measure License Year Anticipated/Pro posed #Public Document Accession #: 20240618-5127 Filed Date: 06/18/2024 TMP Lower Bucks Lake Campground Reconstruct Campground Entrance and Signage 2028 - 6 2029 Delayed as it is in conflict with the 2027/2028 Lower Bucks Dam Repair Downstream Face TMP Lower Bucks Lake Campground Construct Campground Roads 2028 - 6 2029 Delayed as it is in conflict with the 2027/2028 Lower Bucks Dam Repair Downstream Face TMP Lower Bucks Lake Campground Address drainage issues at existing Sites 1 and 2 2028 - 6 2029 Delayed as it is in conflict with the 2027/2028 Lower Bucks Dam Repair Downstream Face RMP Lower Bucks Lake Campground and construct new CG 2028 - 6 2029 Align with Lower Bucks DUA construction to reduce rec impacts/closure RMP Reconstruct 2030 - 8 2029 TMP Sundew Campground 2024 - 2 2030 RMP Sundew Campground 2024 - 2 2030 RMP Sundew Campground 2037 - 14 2030 RMP Sundew Campground Replace Water System 2024 - 2 2030 TMP Three Lakes Road Construct Culvert Outfall Transitions 2026 - 4 2030 can be done in one season/reduce recreation TMP Three Lakes Road Construct Upslope Stabilization 2027 - 5 2030 can be done in one season/reduce recreation TMP Three Lakes Road Gravel Road Resurfacing 2027 - 5 2030 can be done in one season/reduce recreation TMP Three Lakes Road Remove and Replace Pavement 2027 - 5 2030 can be done in one season/reduce recreation TMP Three Lakes Road Construct Low Water Crossings 2027 - 5 2030 can be done in one season/reduce recreation TMP Three Lakes Road Construct Culvert Replacements 2028 - 6 2030 can be done in one season/reduce recreation TMP Three Lakes Road Conveyance Ditches with 2029 - 7 2030 can be done in one season/reduce recreation RMP Three Lakes Trailhead Install vehicle barriers 2024 - 2 2030 can be done in one season/reduce recreation TMP Lower Bucks Lake Campground Road and Mill Creek Road 2025 - 3 2031 Work planned at Lower Bucks Dam/Three Lakes Rd from 2024-2030. TMP Grizzly Forebay Road 2031 - 9 2031 TMP Grizzly Forebay Road 2031 - 9 2031 RMP Reconstruct boat launch 2029 - 7 2024-2025 TMP Bucks Penstock Road culvert entrance and unplug 2024 - 2 Annually This work is performed annually. TMP Mill Creek Campground culvert entrance and unplug 2029 - 7 Annually This work is performed annually. TMP Sandy Point Day Use Replace or unplug culverts 2027 - 5 Annually This work is performed annually. TMP Sandy Point Day Use unplug culverts 2027 - 5 Annually This work is performed annually. TMP Three Lakes Road Re-grade the drainage and culvert entrance and unplug culverts 2027 - 5 Annually This work is performed annually. TMP Grizzly Forebay Road culvert entrance and unplug 2031 - 9 Annually This work is performed annually. RMP Grizzly Forebay Campground Perform trail maintenance 2023 - 1 Complete RMP Grizzly Forebay Campground Fuel treatment 2023 - 1 Complete RMP Perform trail maintenance 2023 - 1 Complete RMP 2029 - 7 Complete #Public Document Accession #: 20240618-5127 Filed Date: 06/18/2024 ENCLOSURE 2 Document Accession #: 20240618-5127 Filed Date: 06/18/2024 From:Edlund, Leslie - FS, CA To:Visinoni, Jamie Subject:RE: Schedule Update – Bucks Creek Recreation Management Plan Date:Friday, June 14, 2024 9:48:55 AM Attachments:image001.png image002.png image003.png image004.png Classification: Public 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 Jamie, Yes, you may. Thanks. Leslie Edlund Public Service Staff Officer Forest Service Plumas National Forest, Mt. Hough Ranger District p: 530-283-7620 f: 520-283-1821 leslie.edlund@usda.gov 39696 Hwy 70 Quincy, CA 95971 www.fs.fed.us Caring for the land and serving people From: Visinoni, Jamie <JNVS@pge.com> Sent: Friday, June 14, 2024 9:44 AM To: Edlund, Leslie - FS, CA <leslie.edlund@usda.gov> Subject: RE: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public Thanks for the email, Leslie. Can we consider the email below FS approval of the new schedule? I will look into the latest on the Hutchins stuff and get back to you with the best POC. Document Accession #: 20240618-5127 Filed Date: 06/18/2024 Thanks! Jamie V From: Edlund, Leslie - FS, CA <leslie.edlund@usda.gov> Sent: Thursday, June 13, 2024 3:15 PM To: Visinoni, Jamie <JNVS@pge.com>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>; Heard, Colleen - FS, CA <colleen.heard@usda.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Carlton, Christopher - FS, CA <Christopher.Carlton@usda.gov> Cc: Stevens, Kevin <K3SN@pge.com>; Rhoads, Gavin <GTR5@pge.com>; Braught, Chrystina <CZB0@pge.com>; Young, Megan <MRY2@pge.com>; Petersen, Drew <DDP0@pge.com>; McKay, Jim <J11V@pge.com>; Zeni, Justine - FS, CA <Justine.Zeni@usda.gov> Subject: RE: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public 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 Jamie, I’m sorry for the delayed response. What you have outlined below makes sense. I’m hoping Justine can jump in here on the question about priorities. We also need to have some follow up conversations about the permit and Hutchins Campground. Are there some dates that might work for you to continue those discussion? Thanks. Leslie Edlund Public Service Staff Officer Forest Service Plumas National Forest, Mt. Hough Ranger District p: 530-283-7620 f: 520-283-1821 leslie.edlund@usda.gov 39696 Hwy 70 Quincy, CA 95971 www.fs.fed.us Caring for the land and serving people Document Accession #: 20240618-5127 Filed Date: 06/18/2024 From: Visinoni, Jamie <JNVS@pge.com> Sent: Monday, April 29, 2024 7:03 AM To: Edlund, Leslie - FS, CA <leslie.edlund@usda.gov>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>; Heard, Colleen - FS, CA <colleen.heard@usda.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Carlton, Christopher - FS, CA <Christopher.Carlton@usda.gov> Cc: Stevens, Kevin <K3SN@pge.com>; Rhoads, Gavin <GTR5@pge.com>; Braught, Chrystina <CZB0@pge.com>; Young, Megan <MRY2@pge.com>; Petersen, Drew <DDP0@pge.com>; McKay, Jim <J11V@pge.com>; Zeni, Justine - FS, CA <Justine.Zeni@usda.gov> Subject: RE: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public Hello Leslie, Thank you for the quick review of the Bucks Creek RMP Schedule Update. We have provided responses to your questions below in blue font. 1) Hutchins CG is showing a water system replacement date of 2028 and Sundew water system replacement in 2029. Since Hutchins and Sundew share the same water source and storage currently, and if we assume it stays that way in a new design, then Hutchins/Sundew should have the same water system replacement date. It seems to us that this water system should be replaced prior to any pavement reconstruction effort at Hutchins. Can you please clarify? In speaking with Justine, our facilities engineer, the priority of water system replacement would be 1) Hutchins/Sundew, 2) Mill Creek, then 3) Sandy Point, although we understand that priority may not have been known during rec plan negotiations. The main components (well pump, holding tanks) are located at Hutchins Group Campground and would be replaced first. PG&E would tie Sundew into the new system the same year the Sundew road work is planned. There was an error on our spreadsheet, the water system at Hutchins should be replaced in 2027 with the rest of the Hutchins Campground improvements. The spreadsheet has been updated. We did not put Hutchins and Sundew water system replacements in the same year due to resource issues and an increased impact to the public (closing both Hutchins and Sundew in the same year). PG&E does plan to design the two together and will kick off as soon as the updated implementation schedule is approved. Can Justine provide more context on the priority? We are still trying to understand the scope of the replacement and have tried to align the water system replacement with the campground reconstructions. Document Accession #: 20240618-5127 Filed Date: 06/18/2024 2) A full reconstruction of Sundew with additional site capacity and the parking area for the Bucks Shoreline trail is scheduled for Year 15. Since PG&E has proposed bumping the road reconstruction at Sundew out until 2030, does it make sense to complete the additional site capacity work and shoreline trail parking area at the same time? This would consolidate mobilization efforts and reduce closure time for the public. We believe we can accelerate the Sundew additional site capacity and trail parking to 2030. Our updated schedule focused on the first 9 years as that was the most intense schedule that didn’t allow for the planning and implementation process. The spreadsheet has been updated to move Sundew up. 3) Will the Sandy Point solar system be addressed with the water system replacement at Sandy Point in 2026? No, the solar system will be addressed with the Sandy Point reconstruction which is planned for Year 15. PG&E is seeking a quick resolution and approval of this schedule as we need to begin design of Mill Creek as soon as possible, we hope to begin next month with site visits (weather permitting). To initiate the design will need to get contracts in place as soon as possible. PG&E would be happy to set up a meeting to discuss the answers we provided above. If this is something PNF is interested in, here are some possible dates: April 30 – 11-12pm May 1 – 10-11am, 11-12pm, 2-3pm May 2 – 12-1pm Thank you, Jamie Visinoni Jamie Visinoni Hydro License Coordinator | Power Generation Pacific Gas and Electric Company d: (530) 894-4779 | m: (530) 215-6676 | e: jnvs@pge.com From: Edlund, Leslie - FS, CA <leslie.edlund@usda.gov> Sent: Monday, April 15, 2024 1:29 PM To: Visinoni, Jamie <JNVS@pge.com>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>; Heard, Colleen - FS, CA <colleen.heard@usda.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Carlton, Christopher - FS, CA <Christopher.Carlton@usda.gov> Cc: Stevens, Kevin <K3SN@pge.com>; Rhoads, Gavin <GTR5@pge.com>; Braught, Chrystina <CZB0@pge.com>; Young, Megan <MRY2@pge.com>; Petersen, Drew <DDP0@pge.com>; McKay, Jim <J11V@pge.com>; Zeni, Justine - FS, CA <Justine.Zeni@usda.gov> Subject: RE: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public Document Accession #: 20240618-5127 Filed Date: 06/18/2024 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 Jamie, After looking at the proposed revisions, we have a few questions. 1. Hutchins CG is showing a water system replacement date of 2028 and Sundew water system replacement in 2029. Since Hutchins and Sundew share the same water source and storage currently, and if we assume it stays that way in a new design, then Hutchins/Sundew should have the same water system replacement date. It seems to us that this water system should be replaced prior to any pavement reconstruction effort at Hutchins. Can you please clarify? In speaking with Justine, our facilities engineer, the priority of water system replacement would be 1) Hutchins/Sundew, 2) Mill Creek, then 3) Sandy Point, although we understand that priority may not have been known during rec plan negotiations. 2. A full reconstruction of Sundew with additional site capacity and the parking area for the Bucks Shoreline trail is scheduled for Year 15. Since PG&E has proposed bumping the road reconstruction at Sundew out until 2030, does it make sense to complete the additional site capacity work and shoreline trail parking area at the same time? This would consolidate mobilization efforts and reduce closure time for the public. 3. Will the Sandy Point solar system be addressed with the water system replacement at Sandy Point in 2026? Thanks. Leslie Edlund Public Service Staff Officer Forest Service Plumas National Forest, Mt. Hough Ranger District p: 530-283-7620 f: 520-283-1821 leslie.edlund@usda.gov 39696 Hwy 70 Quincy, CA 95971 www.fs.fed.us Caring for the land and serving people Document Accession #: 20240618-5127 Filed Date: 06/18/2024 From: Visinoni, Jamie <JNVS@pge.com> Sent: Tuesday, April 2, 2024 2:38 PM To: Edlund, Leslie - FS, CA <leslie.edlund@usda.gov>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>; Heard, Colleen - FS, CA <colleen.heard@usda.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Carlton, Christopher - FS, CA <Christopher.Carlton@usda.gov> Cc: Stevens, Kevin <K3SN@pge.com>; Rhoads, Gavin <GTR5@pge.com>; Braught, Chrystina <CZB0@pge.com>; Young, Megan <MRY2@pge.com>; Petersen, Drew <DDP0@pge.com>; McKay, Jim <J11V@pge.com> Subject: RE: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public Thanks, Leslie. You are correct, we are seeking Forest Service approval. Per Section 6.1 of the RMP (footnote 30) “Forest Service approval is required for any revisions to the Implementation Schedule for Plan Measures (Table 3.1-1). The revised schedule will then be submitted to FERC for approval.” Thanks, Jamie From: Edlund, Leslie - FS, CA <leslie.edlund@usda.gov> Sent: Monday, April 01, 2024 3:51 PM To: Visinoni, Jamie <JNVS@pge.com>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>; Heard, Colleen - FS, CA <colleen.heard@usda.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Carlton, Christopher - FS, CA <Christopher.Carlton@usda.gov> Cc: Stevens, Kevin <K3SN@pge.com>; Rhoads, Gavin <GTR5@pge.com>; Braught, Chrystina <CZB0@pge.com>; Young, Megan <MRY2@pge.com>; Petersen, Drew <DDP0@pge.com>; McKay, Jim <J11V@pge.com> Subject: RE: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public 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. Thanks Jamie, I appreciate you sending over the consolidated list. We will take a look and get back to you with any questions. I understand that you need our approval on the RMP requests prior to submitting to FERC. Document Accession #: 20240618-5127 Filed Date: 06/18/2024 Leslie Edlund Public Service Staff Officer Forest Service Plumas National Forest, Mt. Hough Ranger District p: 530-283-7620 f: 520-283-1821 leslie.edlund@usda.gov 39696 Hwy 70 Quincy, CA 95971 www.fs.fed.us Caring for the land and serving people From: Visinoni, Jamie <JNVS@pge.com> Sent: Monday, April 1, 2024 12:38 PM To: Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>; Edlund, Leslie - FS, CA <leslie.edlund@usda.gov>; Heard, Colleen - FS, CA <colleen.heard@usda.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Carlton, Christopher - FS, CA <Christopher.Carlton@usda.gov> Cc: Stevens, Kevin <K3SN@pge.com>; Rhoads, Gavin <GTR5@pge.com>; Braught, Chrystina <CZB0@pge.com>; Young, Megan <MRY2@pge.com>; Petersen, Drew <DDP0@pge.com>; McKay, Jim <J11V@pge.com> Subject: Schedule Update – Bucks Creek Recreation Management Plan Classification: Public Hello Forest Service, Thank you for spending the day with us virtually for the Annual Bucks Creek Forest Service Consultation Meeting and the Annual Recreation Coordination Meeting. Pacific Gas and Electric Company (PG&E) is writing to follow up on an action item from the Recreation Coordination Meeting to provide a schedule update on improvements identified in the Table 3.1-1 Implementation Schedule of the Recreation Management Plan (RMP) for PG&E and City of Santa Clara’s (Licensees) Bucks Creek Hydroelectric Project, Federal Energy Regulatory Commission (FERC) No. 619. FERC issued a new license for the Bucks Creek Project on June 16, 2022. State Water Resources Control Board (SWRCB) 401 Water Quality Certification (WQC) Condition 21 and U.S. Department of Agriculture, Forest Service’s (“Forest Service”) section 4(e) Condition No. 55 require the licensees implement the Bucks Creek Recreation Management Plan (RMP). The RMP anticipates a 5-year, three-step planning and implementation process for the construction/reconstruction of project facilities (Planning and Designing for Construction and Reconstruction of Project Recreation Facilities). As stated in RMP Section 3.1.4, “Steps in this process Document Accession #: 20240618-5127 Filed Date: 06/18/2024 include (1) site planning (design narrative and site conceptual plan); (2) preparing a site development plan and construction plan; and (3) contracting and constructing each facility.” These critical steps ensure a quality project and safe, continuous, reliable long-term access to recreational facilities for the public. Standard engineering and construction practices require design, review, and consultation, which takes more time than the current implementation schedule allows. Section 3.1.4 of the RMP also discusses scheduling uncertainties for activities such as environmental analyses, consultations, and permitting. For example, environmental analysis and permitting work could take place during all three steps of the planning and implementation process for any of the construction/reconstruction projects. The RMP goes on to clarify that, as a rule, construction may not occur until all necessary environmental review and permitting requirements have been completed. In contrast to the 5-year, three-step process and scheduling uncertainties discussed in the text of the RMP, Table 3.1-1 (Implementation Schedule for Plan Measures) identifies significant, ongoing construction/reconstruction projects beginning in the first year following license issuance (2023). The implementation schedule set forth in Table 3.1-1 does not accommodate a multi-year, three- step planning and implementation process that is described in the text of the RMP. Section 3.1.4.3 of the RMP (Contracting and Construction) allows for flexibility in the implementation schedule for project facilities on Forest Service lands. Section 3.1.4.3 states that “the implementation schedule for constructing or reconstructing these facilities may be revised, as needed, upon agreement between Licensees and the Forest Service.” Forest Service section 4(e) Condition No. 49 require the licensees implement the Bucks Creek Transportation Management Plan (TMP). Table 2.10-1 of the TMP (Implementation Schedule for Long-Term Maintenance Activities) identifies ongoing, long-term roadwork beginning the first year after license issuance (2023). The TMP describes the process for reviewing and, if necessary, modifying the implementation schedule: “Licensees and the Forest Service will discuss the Plan scheduled elements at the Annual Forest Service Consultation Meeting (described in Section 2.13) and determine the [sic] whether or not to modify the implementation schedule of repairs and improvements.” Many of the measures identified in the RMP and TMP Implementation Schedules provide very little background information, justification, or context. This sort of ambiguity could be properly addressed during a multi-year, three-step planning and implementation process. There is great potential for both spatial and temporal overlap between the TMP measures and RMP measures as currently scheduled. Based on the aggressive, back-to-back Implementation Schedules in the TMP and RMP, many of these facilities could easily be closed for multiple, consecutive years. PG&E has compared the TMP and RMP implementation schedules to maximize efficiency and minimize conflicts while promoting the successful implementation of both plans. Attached is the updated TMP and RMP scheduled for years 1-9 (Enclosure 1). PG&E is seeking Forest Service approval to implement the updated schedule. If you have any questions, please contact PG&E’s Senior Land Planner, Jim McKay at (530) 228-8664 Document Accession #: 20240618-5127 Filed Date: 06/18/2024 or PG&E’s Senior License Coordinator, Jamie Visinoni, at (530) 215-6676. Sincerely, Jamie Visinoni Hydro License Coordinator | Power Generation Pacific Gas and Electric Company d: (530) 894-4779 | m: (530) 215-6676 | e: jnvs@pge.com You can read about PG&E’s data privacy practices at PGE.com/privacy. This electronic message contains information generated by the USDA solely for the intended recipients. Any unauthorized interception of this message or the use or disclosure of the information it contains may violate the law and subject the violator to civil or criminal penalties. If you believe you have received this message in error, please notify the sender and delete the email immediately. Document Accession #: 20240618-5127 Filed Date: 06/18/2024 Document Content(s) PGE20240618_619_RMP_Schedule_Update.pdf...................................1 Document Accession #: 20240618-5127 Filed Date: 06/18/2024