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HomeMy WebLinkAbout06.13.2024 Board Correspondence - FW_ Environmental and Recreational Compliance Report submitted in FERC P-803-000 by Pacific Gas and Electric CompanyFrom: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-803-000 by Pacific Gas and Electric Company Date:Thursday, June 13, 2024 4:41:39 PM Please see Board Correspondence - -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Thursday, June 13, 2024 5:45 AM Subject: Environmental and Recreational Compliance Report submitted in FERC P-803-000 by Pacific Gas and Electric Company .ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening attachments, clicking on links, or replying.. On 6/13/2024, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Pacific Gas and Electric Company Docket(s): P-803-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Environmental and Recreational Compliance Report Description: Pacific Gas and Electric Company submits request for temporary variance from the minimum instream flow requirements at gaging stations BW-40 and BW-3 of the Hendricks Head Dam and Philbrook Reservoir part of DeSabla-Centerville Project under P-803. 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Box 28209 Oakland, CA 94604 June 12, 2024 Via Electronic Submittal (E-Filing) Debbie-Anne Reese, Acting Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 RE: DeSabla-Centerville Project, No. 803-CA Gaging Stations BW-40 and BW-3 2024 Minimum Instream Flow Variance Dear Secretary Reese: This letter presents Pacific Gas and Electric Company’s (PG&E’s) request for a temporary variance from the minimum instream flow requirements at gaging stations BW- 40 (Hendricks Head Dam) and BW-3 (Philbrook Reservoir), during the 2024 Central Valley spring run Chinook salmon (CVSRCS; Oncorhynchus tshawytscha) holding period. Hendricks Head Dam and Philbrook Reservoir are part of PG&E’s DeSabla-Centerville Project, Federal Energy Regulatory Commission (FERC) No. 803. This requested variance would provide flexibility to PG&E for the management of the cold-water storage in Philbrook Reservoir and flow discharges from Hendricks Head Dam during the holding period of the CVSRCS. PG&E developed the proposed variance in consultation with the California Department of Fish and Wildlife (CDFW), United States Fish and Wildlife Service (USFWS), United States Forest Service (Forest Service), National Marine Fisheries Service (NMFS), (hereafter referred to as Resource Group). License Requirement Project license Article 39 provides the minimum instream flow requirements for the DeSabla-Centerville Project. For reference, Article 39 is pasted below in italics. Licensee shall maintain a minimum pool volume of 250 acre-feet in Philbrook Reservoir, except when releases from the 250 acre-feet minimum pool are necessary to maintain minimum flows downstream of Philbrook Reservoir. Further, Licensee shall discharge from the DeSabla-Centerville Project facilities the following minimum instantaneous flows or inflow at points of diversion, whichever is less. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Debbie-Anne Reese, Acting Secretary June 12, 2024 Page 2 Volume of Discharge in cubic feet per second (cfs) during normal and dry water years1 Point of Discharge Normal Dry2 Time Period3 Philbrook Reservoir 2.0 2.04 Hendricks Head Dam 15 7 These flows may be temporarily modified if required by operating emergencies beyond the control of the Licensee, and for short periods upon mutual agreement between the Licensee and the California Department of Fish and Game Background The Philbrook Reservoir storage (5,000 acre-feet) is utilized during the summer holding period of CVSRCS to provide additional flows to Butte Creek. Philbrook Reservoir is located on the West Branch Feather River (WBFR) watershed. Flow released from Philbrook Reservoir, along with other flow within the WBFR, are diverted into the Hendricks Canal at the Hendricks Diversion Dam (figure 1). Depending on water availability in the watershed, water diverted from the WBFR at the Hendricks Diversion Dam can increase the total flow available in Butte Creek below DeSabla Powerhouse up to 40% in July through September. To reduce potential temperature impacts, PG&E operates the project in such a way as to reduce residency time within DeSabla Forebay (Forebay). This is achieved by providing a minimum of 60 cfs to the Forebay via Butte, Hendricks, and Toadtown Canals. In August 2023, Butte Canal sustained damage that removed the canal from service, and it will remain out of service for the 2024 CVSRCS holding period. This will result in decreased flows through the forebay. During this period, the only source of flow through the Forebay is water diverted from the WBFR at the Hendricks Head Dam into the Hendricks Canal. This variance request will help PG&E meet this target flow through the forebay during the summer months. 1 Discharge is in cubic feet per second (cfs). 2 A dry water year is any 12-month period beginning May 1 in which the natural runoff of the Feather River at Oroville for the April 1 to July 31 period, as forecast on April 1 by the State of California Department of Water Resources, and as may be adjusted by the State on May 1, will be 50 percent of less of the average for such period as computed by the State for the 50-year period used at that time. If during a designated dry year, the February 1 or later water year prediction indicates that dry year conditions no longer prevail, Licensee will resume normal year flow releases immediately upon notification by the California Department of Fish and Game. 3 Unless otherwise noted, the time period is year-round. 4 When inflow to Philbrook Reservoir is less than 0.1 cfs, a minimum flow of at least 0.1 cfs shall be discharged. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Debbie-Anne Reese, Acting Secretary June 12, 2024 Page 3 Figure 1- Locations of Philbrook Reservoir and Hendricks Head Dam On April 8, 2024, the California Department of Water Resources (DWR) issued The April Bulletin 120 report. According to the report, the water year type for the DeSabla- Centerville Project will be “Normal,” with an estimate of 101% which is above normal. The availability of water in 2024 together with this variance should assist in PG&E’s efforts to maintain 60 cfs of inflow into the Forebay. Operations and Maintenance Plan On August 21, 1997, the FERC issued an Order placing temperature restrictions (17º Celsius at Round Valley and 18º Celsius at Philbrook) on the releases from these dams. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Debbie-Anne Reese, Acting Secretary June 12, 2024 Page 4 On August 20, 1998, the FERC revised its Order to allow for modification of the criteria upon mutual agreement of NMFS, CDFW, and USFWS. An Operation and Maintenance Plan and an annual meeting held ahead of the summer holding period are the mechanisms by which PG&E consults with the agencies to gain mutual agreement on releases from these dams. To advance collaboration, PG&E has also included the SWRCB and USFS in this consultation process. The population of CVSRCS in Butte Creek is the largest remaining population of this threatened species in California. Under the annual Operations and Maintenance Plan, PG&E coordinates an annual meeting pre-holding period and weekly conference calls with the Resource Agencies during the CVSRCS’s holding period. These conference calls occur from early June through mid-September (as needed). During these conference calls, the Resource Group will discuss the results of pre-spawning mortality surveys (if provided by CDFW or NMFS), meteorological forecasts, water temperatures recorded by CDFW at Quartz Bowl Pool, flows, and storage in Philbrook Reservoir. Proposed Variance The proposed variance includes changing instantaneous minimum instream flow (MIF) requirements to averaged MIFs (over 48 hours) at compliance points as listed in Table1 below. Once approved, PG&E would like to implement the temporary variance at the Hendricks Head Dam (BW-40) beginning July 1, 2024, and complete the variance by September 30, 2024. Once approved, PG&E would like to implement the variance at Philbrook Reservoir (BW-3) as soon as approval is received and would complete the variance by September 30, 2024. Table 1: License required and variance request flows. Compliance Point Requirement (cfs) without variance Requested Flows for variance Hendricks Head Dam (BW-40) Instantaneous Minimum Instream Flow (MIF) of 15 cfs Normal WY, 7 cfs dry WY Average MIF over 48 hour – target between 15 and 7 cfs Philbrook Reservoir (BW-3) Instantaneous Minimum Instream Flow (MIF) of 2 cfs Normal WY, 2 cfs dry WY Average MIF over 48 hour – target between 1 and 2 cfs This variance will allow PG&E greater flexibility to operate around the MIFs while staying compliant during short-lived drops in instream flow readings. The variance at the Hendricks Head Dam will maximize the delivery of flow released from Philbrook Reservoir to Butte Creek. All Philbrook release flow will be utilized instead of some being used to buffer flow to meet instantaneous MIF requirements. With the implementation of the proposed variance, flow through the Forebay will also be increased. This increased flow will minimize heating effects within the Forebay, as much as possible given the absence of Butte Canal flows through the Forebay . Heating is caused by incident solar radiation and natural high air temperatures, especially during heat storms of the summer holding period. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Debbie-Anne Reese, Acting Secretary June 12, 2024 Page 5 At Philbrook Reservoir, this variance will allow greater flexibility to operate around the MIFs while staying compliant during short-lived drops in release readings. In addition, it will help PG&E retain as much storage as possible until it is needed for releases to provide flow through the DeSabla Forebay and maximize flow to Butte Creek during the hottest part of the summer CVSRCS holding period. The following conditions will be in effect during the variance time frame: 1. Continue to hold weekly CVRCS meetings with Resource Group 2. Decisions on when and how to implement the variance flows, as well as any flow changes under this variance would be done in consultation with PG&E staff and the Resource Group. CDFW, USFWS, NMFS and PG&E staff will consult with any proposed flow changes prior to implementing. 3. PG&E will maintain a 48-hour average MIF within the range listed in Table 1 for each compliance point , as agreed upon with PG&E staff and the CDFW, USFWS, and NMFS. 4. Monitor and provide weekly flow changes to the Resource Group for gauging stations BW40 and BW3 during weekly CVRCS Holding Period meetings. 5. Promptly notify the Resource Group of any event that significantly inhibits or impairs the release structures from maintaining a 48 -hour average as listed in Table 1 for each compliance point. Biological Impacts to CVSRCS PG&E fisheries biologists have reviewed this variance proposal and believe that the proposed flow changes would benefit the holding CVSRCS by maximizing the volume of water that can be delivered to Butte Creek from the WBFR during periods especially when the Butte Canal is offline. The material informing this request include the following: • The holding pattern of adult CVSRCS since the Lower Centerville Powerhouse was taken off-line (2011), has shifted to more of the population holding in the upper reaches. It is expected that >95% of adults will hold in the upstream four miles of habitat due to water temperatures. This concentration of individuals increases the potential breakout of disease among a larger portion of the holding population. • The variance will help provide a larger volume of water through to Butte Creek. This is important to minimize the effects of high ambient air temperatures which drive water temperatures. Higher water temperatures result in a higher potential and severity of a disease outbreak. This is particularly true with an increase in population density. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Debbie-Anne Reese, Acting Secretary June 12, 2024 Page 6 • Increasing inflow from Hendricks Canal shortens the travel time through the Forebay thus, decreasing heating of water by minimizing exposure to solar radiation. This minimizes the temperature of the water that enters Butte Creek. Agency Consultation On April 3, 2024, PG&E hosted a meeting with the Resource Agency Group to discuss the water management constraints and options for supporting the population of CVSRCS during the summer holding period. This variance request supports PG&E’s and the Resource Groups efforts of ensuring the availability of cold-water storage in Philbrook Reservoir to support the population and minimizing water temperature increases in the Forebay. On April 24, 2024, and subsequently on June 3, 2024, PG&E provided the Resource Agency Group with a draft of this request. Comments from CDFW and USFWS were received and are provided in enclosure 2. Resource Agency concurrence is also provided in enclosure 2. Conclusion PG&E respectfully requests the above temporary flow variance to provide flexibility to transfer the maximum amount of water through the DeSabla Forebay to Butte Creek from the WBFR during the hottest part of the summer holding period for CVSRCS in Butte Creek. If you have any questions regarding this matter, please contact PG&E’s senior license coordinator, Megan Young, at (530) 335-5602. Sincerely, Matthew Joseph Supervisor, Hydro License Management Enclosures: 1. Redlined version of the BW-3 and Bw-40 MIF Variance Request 2. Agency Consultation Record cc: See Attached List Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Debbie-Anne Reese, Acting Secretary June 12, 2024 Page 7 cc: via email w/enclosures Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, Anna Allison (CDFW) – Anna.Allison@wildlife.ca.gov Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, Grant Henley (CDFW) - Grantton.Henley@wildlife.ca.gov Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov Allison Bosworth (NOAA Fisheries) Allison.bosworth@noaa.gov Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, Tristan Leong (USFS)– tristan.leong@usda.gov, Brittany Reaves (USFWS) –brittany_reaves@fws.gov Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov Document Accession #: 20240613-5010 Filed Date: 06/13/2024 ENCLOSURE 1 Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Power Generation 300 Lakeside Drive Oakland, CA 94612 Mailing Address: P.O. Box 28209 Oakland, CA 94604 Mouthay XX, 2024 Via Electronic Submittal (E-Filing) Debbie-Anne Reese, Acting Secretary Federal Energy Regulatory Commission 888 First Street, N.E. Washington, D.C. 20426 RE: DeSabla-Centerville Project, No. 803-CA Gaging Stations BW-40 and BW-3 2024 Minimum Instream Flow Variance Dear Secretary Reese, This letter presents Pacific Gas and Electric Company’s (PG&E’s) request for a temporary variance from the minimum instream flow requirements at gaging stations BW- 40 (Hendricks Head Dam) and BW-3 (Philbrook Reservoir), during the 2024 Central Valley Spring spring Run run Chinook Salmon salmon (CVSRCS; Oncorhynchus tshawytscha) holding period. Hendricks Head Dam and Philbrook Reservoir are part of PG&E’s DeSabla-Centerville Project, Federal Energy Regulatory Commission (FERC) No. 803. This requested variance would provide flexibility to PG&E for the management of the cold-water storage in Philbrook Reservoir and flow discharges from Hendricks Head Dam during the holding period of the CVSRCS. PG&E developed the proposed variance in consultation with the California Department of Fish and Wildlife (CDFW), United States Fish and Wildlife Service (USFWS), United States Forest Service (Forest Service), National Marine Fisheries Service (NMFS), (hereafter referred to as Resource AgenciesGroup). License Requirement Project license Article 39 provides the minimum instream flow requirements for the DeSabla-Centerville Project. For reference, Article 39 is pasted below in italics. Licensee shall maintain a minimum pool volume of 250 acre -feet in Philbrook Reservoir, except when releases from the 250 acre-feet minimum pool are necessary to maintain minimum flows downstream of Philbrook Reservoir. Further, Licensee shall discharge fro m the DeSabla-Centerville Project facilities the following minimum instantaneous flows or inflow at points of diversion, whichever is less. Formatted: Not Highlight Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 2 Volume of Discharge in cubic feet per second (cfs) during normal and dry water years1 Point of Discharge Normal Dry2 Time Period3 Philbrook Reservoir 2.0 2.04 Hendricks Head Dam 15 7 These flows may be temporarily modified if required by operating emergencies beyond the control of the Licensee, and for short periods upon mutual agreement between the Licensee and the California Department of Fish and Game Background The Philbrook Reservoir storage (5,000 acre-feet) is utilized during the summer holding period of CVSRCS to provide additional flow s to Butte Creek. Philbrook Reservoir is located on the West Branch Feather River (WBFR) watershed. Flow released from Philbrook Reservoir, along with other flow within the WBFR, are diverted into the Hendricks Canal at the Hendricks Diversion Dam (figure 1). Depending on water availability in the watershed, water diverted from the WBFR at the Hendricks Diversion Dam can increase the total flow available in Butte Creek below DeSabla Powerhouse up to 40% in July and through September. In an effort toTo reduce potential temperature impacts, PG&E operates the project in such a way as to reduce residency time within DeSabla Forebay (Forebay). This is achieved by providing a minimum of 60 cfs to the forebay Forebay via Butte, Hendricks, and Toadtown Canals. In August 2023, Butte Canal sustained damage that removed the canal from service, and it will remain out of service for the 2024 CVSRCS holding period. This will result in decreased flows through the forebay. During this period the only source of flow through the DeSabla Forebay is water diverted from the WBFR at the Hendricks Head Dam into the Hendricks Canal. This variance request will help PG&E meet this target flow through the forebay during the summer months. 1 Discharge is in cubic feet per second (cfs). 2 A dry water year is any 12-month period beginning May 1 in which the natural runoff of the Feather River at Oroville for the April 1 to July 31 period, as forecast on April 1 by the State of California Department of Water Resources, and as may be adjusted by the State on May 1, will be 50 percent of less of the average for such period as computed by the State for the 50 -year period used at that time. If during a designated dry year, the February 1 or later water year prediction indicates that dry year conditions no longer prevail, Licensee will resume normal year flow releases immediately upon notification by the California Department of Fish and Game. 3 Unless otherwise noted, the time period is year-round. 4 When inflow to Philbrook Reservoir is less than 0.1 cfs, a minimum flow of at least 0.1 cfs shall be discharged. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 3 Figure 1- Locations of Philbrook Reservoir and He ndricks Head Dam On April 8, 2024, the California Department of Water Resources (DWR) issued The April Bulletin 120 report. According to the report , the water year type for the DeSabla- Centerville project Project will be “Normal”,. with an estimate of 101% which is above normal. The availability of water in 2024 together with this variance should assist in PG&E’s efforts to maintain 60 cfs of inflow into the Forebay. Operations and Maintenance Plan On August 21, 1997, the FERC issued an Order placing temperature restrictions (17º Celsius at Round Valley and 18º Celsius at Philbrook) on the releases from these dams. Commented [RC1]: I like this language. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 4 On August 20, 1998, the FERC revised its Order to allow for modification of the criteria upon mutual agreement of NMFS, CDFW, and USFWS. An Operation and Maintenance Plan and an annual meeting held ahead of the summer holding period are the mechanisms by which PG&E consults with the agencies to gain mutual agreement on releases from these dams. To advance collaboration, PG&E has also included the SWRCB and USFS in this consultation process. The population of CVSRCS in Butte Creek is the largest remaining population of this threatened species in California. Under the annual Operations and Maintenance Plan, PG&E coordinates an annual meeting pre-holding period and weekly conference calls with the Resource Agencies during the CVSRCS’s holding period. These conference calls occur from early June through mid -September (as needed). During these conference calls, the Resource Group will discuss the results of pre -spawning mortality surveys (if provided by CDFW or NMFS), meteorological forecasts, water temperatures recorded by CDFW at Quartz Bowl Pool, flows, and storage in Philbrook Reservoir. Proposed Variance The proposed variance includes changing instantaneous minimum instream flow (MIF) requirements to averaged MIFs (over 48 hours) at compliance points as listed in Table1 below. Once approved, PG&E would like to implement the temporary variance at the Hendricks Head Dam (BW-40) beginning July 1, 2024, and complete the variance by September 30, 2024. Once approved, PG&E would like to implement the variance at Philbrook Reservoir (BW-3) as soon as approval is received and would complete the variance by September 30, 2024. Table 1: License required and variance request flows . Compliance Point Requirement (cfs) without variance Requested Flows for variance Hendricks Head Dam (BW-40) Instantaneous Minimum Instream Flow (MIF) of 15 cfs Normal WY, 7 cfs dry WY Average MIF over 48 hour – target between 15 and 7 cfs Philbrook Reservoir (BW-3) Instantaneous Minimum Instream Flow (MIF) of 2 cfs Normal WY, 2 cfs dry WY Average MIF over 48 hour – target between 1 and 2 cfs This variance will allow PG&E greater flexibility to operate around the MIFs while staying compliant during short-lived drops in instream flow readings. The variance at the Hendricks Head Dam will maximize the delivery of flows released from Philbrook Reservoir to Butte Creek. All Philbrook released flows will be utilized instead of some being used to buffer flow to meet instantaneous MIF requirements. With the implementation of the proposed variance, flow through DeSabla Forebay will also be increased. This increased flow will minimize heating effects within the Forebay, as much as possible given the absence of Butte Canal flows through the Forebay. Heating is Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 5 caused by incident solar radiation and natural high air temperatures, especially during heat storms of the summer holding period. At the Philbrook Reservoir, this variance will allow greater flexibility to operate around the MIFs while staying compliant during short-lived drops in release readings. In addition, it will help PG&E retain as much storage as possible until it is needed for releases to provide flow through the DeSabla Forebay and maximize flow to Butte Creek during the hottest part of the summer CVSRCS holding period. The following conditions will be in effect during the variance time frame: 1. Continue to hold weekly CVRCS meetings with Resource AgenciesGroup 2. Decisions on when and how to implement the variance flows, as well as any flow changes under this variance would be done in consultation with PG&E staff and the Resource AgenciesGroup. CDFW, USFWS, NMFS and PG&E staff will consult with any proposed flow changes prior to implementing. 3. PG&E will maintain a 48-hour average MIF within the range listed in Table 1 for each compliance point , as agreed upon with PG&E staff and the CDFW, USFWS, and NMFS.. 4. Monitor and provide weekly flow changes to the Resource Agencies Group for gauging stations BW40 and BW3 during weekly CVRCS Holding Period meetings. 5. Promptly notify the Resource Agencies Group of any event that significantly inhibits or impairs the release structures from maintaining a 48-hour average as listed in Table 1 for each compliance point. Biological Impacts to CVSRCS PG&E fisheries biologists have reviewed this variance proposal and believe that the proposed flow changes would benefit the holding CVSRCS by maximizing the volume of water that can be delivered to Butte Creek from the WBFR during periods especially whenwhile the Butte Canal is offline. The material informing this request include the following following information supports this request: • The holding pattern of adult CVSRCS since the Lower Centerville Powerhouse was taken off-line (2011), has shifted to more of the population holding in the upper reaches. It is expected that >95% of adults will hold in the upstream four miles of habitat due to water temperatures. This concentration of individuals increases the potential breakout of disease among a larger portion of the holding population. • The variance will help provide a larger volume of water through to Butte Creek. This is important to minimize the effects of high ambient air Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 6 temperatures which drive water temperatures. Higher water temperatures result in a higher potential and severity of a disease outbreak. This is particularly true with an increase in population density. • Increasing inflow from Hendricks Canal shortens the travel time through the DeSabla Forebay thus, decreasing heating of water by minimizing exposure to solar radiation. This minimizes the temperature of the water that enters Butte Creek. Agency Consultation On April 3, 2024, PG&E hosted a meeting with the Resource Agency Group to discuss the water management constraints and options for supporting the population of CVSRCS during the summer holding period. This variance request supports PG&E’s and the Resource Groups efforts of ensuring the availability of cold -water storage in Philbrook Reservoir to support the population and minimizing water temperature increases in the DeSabla Forebay. On April 24, 2024, PG&E provided agencies with a draft of this request . Agency concurrences are included in Enclosure 1. Conclusion PG&E respectfully requests the above temporary flow variance to provide flexibility to transfer the maximum amount of water through the DeSabla Forebay to Butte Creek from the WBFR during the hottest part of the summer holding period for CVSRCS in Butte Creek. If you have any questions regarding this matter, please contact PG&E’s senior license coordinator, Megan Young, at (530) 335-5602. Sincerely, Matt Joseph Supervisor, Enclosure: 1. Agency Concurrence CC: Tracy McReynolds (CDFW) – Tracy.McReynolds@wildlife.ca.gov, Anna Allison (CDFW) – Anna.Allison@wildlife.ca.gov Beth Lawson (CDFW) – Beth.Lawson@wildlife.ca.gov, Grant Henley (CDFW) - Grantton.Henley@wildlife.ca.gov Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 7 Ellen McBride (NOAA Fisheries) – ellen.mcbride@noaa.gov Allison Bosworth (NOAA Fisheries) Allison.bosworth@noaa.gov Steve Edmondson (NOAA Fisheries) – steve.edmondson@noaa.gov, Tristan Leong (USFS)– tristan.leong@usda.gov, Brittany Reaves (USFWS) –brittany_reaves@fws.gov Stephanie Millsap (USFWS) - Stephanie_Millsap@fws.gov Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Month XX, 2024 Page 8 Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Public Enclosure 2 Agency Consultation Record Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Agency Comment PG&E Resposne CDFW Add State Water Resources Control Board? Board issued a 401 cert in 2016 in support of the relicensing effort that certification will not be in effect until a new license is issued and an order incorporates it into the license. CDFW our comments, CDFW does not believe this variance alone will provide sufficient cold water supply for water temperature management in the CVSRCS holding reaches through the summer and recommends PG&E implement additional actions as described in our April 30, 2024 letter to FERC. significant changes to project assets and would trigger regulatory authorizations and possibly additional permiting. This is a timely process and would not occur prior to the 2024 CVSRCS season. USFWS "Resource Group," so I recommend keeping it that way. Noted, edit made USFWS included in last years' variance request USFWS USFWS 2024 DeSabla- Centerville BW-3 & BW-40 Variance Comment Matrix # Document Accession #: 20240613-5010 Filed Date: 06/13/2024 From:Purdy, Colin@Wildlife To:Lawson, Beth@Wildlife; Young, Megan; McReynolds, Tracy@Wildlife; Henley, Grantton@Wildlife; Allison, Anna@Wildlife; Ellen McBride:; allison.bosworth; Steve Edmondson - NOAA Federal; Leong, Tristan -FS; Millsap, Stephanie D; brittany_reaves@fws.gov; Daniella Hanacek - NOAA Federal Cc:Reyes, Catalina; Cheslak, Edward; Joseph, Matthew; Ramirez-Doble, Sky Subject:RE: P803- 2024 DeSabla-Centerville Minimum Instream Flow Variance Date:Tuesday, June 4, 2024 4:25:57 PM Attachments:image001.png image002.png 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 Megan, Below is the Department’s (CDFW) response to Pacific Gas and Electric Company’s (PG&E) proposed flow variance for the DeSabla-Centerville Project (FERC P#803). CDFW filed a letter with FERC on April 30, 2024 describing why CDFW staff strongly believe that with the Butte Canal offline and reduced Philbrook Reservoir storage, the measures proposed within the Operations and Maintenance Plan as well as the draft flow variance are likely not sufficient to prevent additional heating in Butte Creek during the summer holding period this year as compared to historical conditions. CDFW continues to recommend PG&E pursue some form of short-term DeSabla Forebay temperature management (such as sheet piling walls or a temperature curtain) during the summer of 2024 to minimize heating of water delivered to spring-run Chinook salmon holding reaches in Butte Creek. In reply to CDFW comments on the draft variance request PG&E stated that implementing temperature management actions in DeSabla Forebay “would require significant changes to project assets and would trigger regulatory authorizations and possibly additional permitting.” If this action will not be completed this year, CDFW encourages PG&E to start work on potential DeSabla Forebay temperature management solutions and any necessary permitting to implement this action as soon as possible. CDFW staff understand that, at a minimum, the requested flow variance will help the Resource Group work together to make timely water management decisions. Through this variance, the Resource Group will be able to work collaboratively to better adjust flows below Hendricks Head Dam and Philbrook Reservoir over the summer to quickly respond to conditions this summer in the watershed. Therefore, CDFW agrees with PG&E’s proposed variance to the DeSabla-Centerville FERC license conditions as written through September 30, 2024. CDFW looks forward to continuing to work with your staff to best protect aquatic resources in the project area given the current infrastructure constraints. Thanks, Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Colin Purdy, M.S. Environmental Program Manager - Fisheries CA Department of Fish and Wildlife, North Central Region 1701 Nimbus Rd., Rancho Cordova, CA 95670 I Office (916) 358-2943 I Cell (916) 704-2154 I Fax (916) 358-2912 Colin.Purdy@wildlife.ca.gov From: Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov> Sent: Tuesday, June 4, 2024 3:30 PM To: Young, Megan <MRY2@pge.com>; McReynolds, Tracy@Wildlife <Tracy.McReynolds@wildlife.ca.gov>; Henley, Grantton@Wildlife <Grantton.Henley@Wildlife.ca.gov>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov>; Ellen McBride: <ellen.mcbride@noaa.gov>; allison.bosworth <Allison.Bosworth@noaa.gov>; Steve Edmondson - NOAA Federal <steve.edmondson@noaa.gov>; Leong, Tristan -FS <tristan.leong@usda.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; brittany_reaves@fws.gov; Daniella Hanacek - NOAA Federal <daniella.hanacek@noaa.gov>; Purdy, Colin@Wildlife <Colin.Purdy@wildlife.ca.gov> Cc: Reyes, Catalina <CERh@pge.com>; Cheslak, Edward <EFC3@pge.com>; Joseph, Matthew <MWJA@pge.com>; Ramirez-Doble, Sky <S9RV@pge.com> Subject: RE: P803- 2024 DeSabla-Centerville Minimum Instream Flow Variance I am replying to all and including Colin Purdy, our fisheries Environmental Program Manager so that he may respond to this request. From: Young, Megan <MRY2@pge.com> Sent: Monday, June 3, 2024 4:24 PM To: McReynolds, Tracy@Wildlife <Tracy.McReynolds@wildlife.ca.gov>; Henley, Grantton@Wildlife <Grantton.Henley@Wildlife.ca.gov>; Allison, Anna@Wildlife <Anna.Allison@wildlife.ca.gov>; Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>; Ellen McBride: <ellen.mcbride@noaa.gov>; allison.bosworth <Allison.Bosworth@noaa.gov>; Steve Edmondson - NOAA Federal <steve.edmondson@noaa.gov>; Leong, Tristan -FS <tristan.leong@usda.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; brittany_reaves@fws.gov; Daniella Hanacek - NOAA Federal <daniella.hanacek@noaa.gov> Cc: Reyes, Catalina <CERh@pge.com>; Cheslak, Edward <EFC3@pge.com>; Joseph, Matthew <MWJA@pge.com>; Ramirez-Doble, Sky <S9RV@pge.com>; Young, Megan <MRY2@pge.com> Subject: P803- 2024 DeSabla-Centerville Minimum Instream Flow Variance WARNING: This message is from an external source. Verify the sender and exercise caution when clicking links or Document Accession #: 20240613-5010 Filed Date: 06/13/2024 opening attachments. Good afternoon all, Attached for your review are the redlined and clean versions of the 2024 DeSabla-Centerville minimum instream flow variance. In addition I’ve also attached the comment matrix. The redlined version incorporates the edits and comments received from CDFW and USFWS. If possible it would be greatly appreciated if concurrence could be sent as soon as possible so I can get this request filed with FERC. Please feel free to reach out with any questions. Thanks so much, Megan Young Sr. Hydro License Coordinator | Power Generation Pacific Gas and Electric Company m: (530) 364-6009 | e: megan.young@pge.com You can read about PG&E’s data privacy practices at PGE.com/privacy. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 From:William Foster - NOAA Federal To:Young, Megan; steve.edmondson@noaa.gov; Ellen McBride - NOAA Federal Subject:NMFS Concurrs with DeSabla/P803 flow variance Date:Wednesday, June 12, 2024 10:30:20 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. Young, Megan (pge.com)2 more The National Marine Fisheries Service supports the variance request as presented in the “clean” version. We look forward to continuing our work together this upcoming holding season! Thanks William E. Foster, M.S., Fishery Biologist NOAA Fisheries, West Coast Region California Central Valley Area Office FERC Branch, Sacramento, CA Cell: 916-844-9836 Document Accession #: 20240613-5010 Filed Date: 06/13/2024 From:Reaves, Brittany L To:Young, Megan; McReynolds, Tracy@Wildlife; Henley, Grantton@Wildlife; Allison, Anna@Wildlife; Beth.Lawson@wildlife.ca.gov; Ellen McBride:; allison.bosworth@noaa.gov; steve.edmondson@noaa.gov; Leong, Tristan -FS; Millsap, Stephanie D; Daniella Hanacek - NOAA Federal Cc:Reyes, Catalina; Cheslak, Edward; Joseph, Matthew; Ramirez-Doble, Sky Subject:RE: [EXTERNAL] P803- 2024 DeSabla-Centerville Minimum Instream Flow Variance Date:Tuesday, June 4, 2024 1:32:53 PM Attachments:image001.png 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. The U.S. Fish and Wildlife Service supports the variance request as presented in the “clean” version. We look forward to continuing our work together this upcoming holding season! Kind regards, Brittany Reaves Fish and Wildlife Biologist U.S. Fish & Wildlife Service (916) 930-5643 *********************** I am currently working part-time: Monday – Wednesday From: Young, Megan <MRY2@pge.com> Sent: Monday, June 3, 2024 4:24 PM To: McReynolds, Tracy@Wildlife <Tracy.McReynolds@wildlife.ca.gov>; Henley, Grantton@Wildlife <Grantton.Henley@wildlife.ca.gov>; Allison, Anna@Wildlife <Anna.allison@wildlife.ca.gov>; Beth.Lawson@wildlife.ca.gov; Ellen McBride: <ellen.mcbride@noaa.gov>; allison.bosworth@noaa.gov; steve.edmondson@noaa.gov; Leong, Tristan -FS <tristan.leong@usda.gov>; Millsap, Stephanie D <stephanie_millsap@fws.gov>; Reaves, Brittany L <brittany_reaves@fws.gov>; Daniella Hanacek - NOAA Federal <daniella.hanacek@noaa.gov> Cc: Reyes, Catalina <CERh@pge.com>; Cheslak, Edward <EFC3@pge.com>; Joseph, Matthew <MWJA@pge.com>; Ramirez-Doble, Sky <S9RV@pge.com>; Young, Megan <MRY2@pge.com> Subject: [EXTERNAL] P803- 2024 DeSabla-Centerville Minimum Instream Flow Variance This email has been received from outside of DOI - Use caution before clicking on links, opening attachments, or responding. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Good afternoon all, Attached for your review are the redlined and clean versions of the 2024 DeSabla-Centerville minimum instream flow variance. In addition I’ve also attached the comment matrix. The redlined version incorporates the edits and comments received from CDFW and USFWS. If possible it would be greatly appreciated if concurrence could be sent as soon as possible so I can get this request filed with FERC. Please feel free to reach out with any questions. Thanks so much, Megan Young Sr. Hydro License Coordinator | Power Generation Pacific Gas and Electric Company m: (530) 364-6009 | e: megan.young@pge.com You can read about PG&E’s data privacy practices at PGE.com/privacy. Document Accession #: 20240613-5010 Filed Date: 06/13/2024 Document Content(s) PGE20240612_803 _MIF_Variance_Clean.pdf...................................1 Document Accession #: 20240613-5010 Filed Date: 06/13/2024