HomeMy WebLinkAbout09.18.25 Board Correspondence - FW_ Request for Delay of Action_Extension of Time submitted in FERC P-619-000 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; Lee, Lewis; Little, Melissa; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug;
Zepeda, Elizabeth
Cc:Nuzum, Danielle; Loeser, Kamie
Subject:Board Correspondence - FW: Request for Delay of Action/Extension of Time submitted in FERC P-619-000 by Pacific Gas and Electric Company,et al.
Date:Thursday, September 18, 2025 11:55:06 AM
Please see Board Correspondence -
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Subject: Request for Delay of Action/Extension of Time submitted in FERC P-619-000 by Pacific Gas and Electric Company,et al.
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On 9/18/2025, 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: Request for Delay of Action/Extension of Time
Description: Pacific Gas and Electric Company submits request for an extension of time until 10/31/2026 to complete gravel augmentation as described in the Gravel Augmentation Plan re the Bucks Creek Hydroelectric Project under
P-619.
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Power Generation
300 Lakeside Drive
Oakland, CA 94612
Mailing Address:
P.O. Box 28209
Oakland, CA 94604
September 18, 2025
Via Electronic Submittal (E-File)
Debbie-Anne Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, N. E.
Washington, D.C. 20426
Re: Bucks Creek Hydroelectric Project, FERC No. 619-CA-CA
Request for Extension of Time – Gravel Augmentation
State Water Resources Control Board 401 Water Quality Certification Condition
14 and U.S. Department of Agriculture, Forest Service’s section 4(e) Condition
No. 41
Dear Secretary Reese:
Pacific Gas and Electric Company (PG&E) is writing to seek approval for an extension of time
to complete gravel augmentation as described in the Gravel Augmentation Plan (GAP) 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 14 and
U.S. Department of Agriculture, Forest Service’s (“Forest Service”) section 4(e) Condition No.
41 require the licensees to implement the Bucks Creek GAP. Section 3 of the GAP requires
gravel augmentation at two locations:
• Bucks Creek downstream of Lower Bucks Dam Spillway upstream of the right bank
mass wasting site.
• Grizzly Creek downstream of the Grizzly Creek gaging weir.
On December 2, 2024, PG&E filed a request for an extension of time with FERC to complete
the gravel augmentation by October 31, 2025. FERC issued an order granting the extension
on May 21, 2025.
Unfortunately, the gravel augmentation originally scheduled for 2025 will not proceed as
planned due to recent regulatory clarifications. PG&E initially understood, based on early
discussions with SWRCB staff, that the activity would not require a new Section 401 Water
Quality Certification (WQC), as it was covered under the existing license and WQC. However,
during preparations for the Section 404 permit application in April, PG&E requested written
confirmation. At that time, SWRCB staff reversed their earlier guidance, citing the U.S. EPA’s
2023 Section 401 Certification Improvement Rule. Under this rule, any activity requiring a
Document Accession #: 20250918-5095 Filed Date: 09/18/2025
Debbie-Anne Reese, Secretary
September 18, 2025
Page 2
Section 404 permit must also obtain a new Section 401 certification, regardless of prior
coverage. Given the required 30-day pre-filing meeting and one-year statutory review period,
it is no longer feasible to complete the permitting process in time for 2025 implementation.
PG&E must prioritize resources where they can be most effectively utilized. As a result,
PG&E has made the difficult decision to cancel the 2025 implementation and instead focus
on completing all necessary permitting to enable construction in fall 2026. We respectfully
request an extension to perform gravel augmentation by October 31, 2026 (License Year 4),
to ensure full compliance with applicable federal and state requirements.
PG&E sought approval from the agencies in an email dated July 21, 2025. The Forest
Service provided a concurrence letter via email on August 8, 2025 (Enclosure 1). PG&E has
not yet received concurrence from the SWRCB but will promptly file with FERC upon receipt.
For general questions, please contact PG&E’s Senior Consulting Scientist, Rohit Salve, at
(925) 719-2110 or PG&E’s License Project Manager, Jamie Visinoni, at (530) 215-6676.
Sincerely,
Matthew Joseph
Supervisor, Hydro License Compliance
Enclosure:
1. EOT Concurrence email from USFS
Document Accession #: 20250918-5095 Filed Date: 09/18/2025
United States
Department of
Agriculture
Forest
Service National
Forest
Quincy, CA 95971-6025
(530)283-2050 Voice
Caring for the Land and Serving People Printed on Recycled Paper
File Code: 2770
Date: August 8, 2025
Jamie Visinoni
Hydro License Coordinator/Power Generation
Pacific Gas and Electric Company
jnvs@pge.com
Re: Bucks Creek Gravel Augmentation Plan Extension of Time
Dear Ms. Visinoni,
I have reviewed Pacific Gas & Electric’s (PG&E’s) request for an extension of time to complete
gravel augmentation as described in the Gravel Augmentation Plan (GAP) for PG&E and City of
Santa Clara’s (Licensees) Bucks Creek Hydroelectric Project, Federal Energy Regulatory
Commission (FERC) No. 619. PG&E is requesting to extend the gravel augmentation
completion date to October 31, 2026.
Under the new Bucks Creek License #619, 4(e) Condition No. 41 requires the licensees to
implement the Bucks Creek GAP. Section 3 of the GAP requires gravel augmentation at two
locations:
•Bucks Creek downstream of Lower Bucks Dam Spillway, upstream of the right bank
•mass wasting site.
•Grizzly Creek downstream of the Grizzly Creek gaging weir.
In November of 2023, PG&E requested an extension of time (EOT) until August 1, 2024, to
conduct the baseline topographic surveys required by the GAP according to Section 401 Water
Quality Certification Condition 14 and Forest Service 4(e) Condition No. 41. The Forest Service
concurred on November 3, 2023, and FERC issued an order granting the EOT on January 16,
2024. The baseline monitoring topographic surveys were completed June 27 - 28, 2024. PG&E
submitted the Bucks Creek 2024 Gravel Augmentation Monitoring Survey Report, which
included topographic survey results to FERC and the agencies on July 30, 2024.
In November of 2024, the Forest Service granted a second EOT based on the need for PG&E to
complete Section 404 review and authorization under the Clean Water Act for the gravel
augmentation. The new deadline was October 31, 2025. Since this EOT was granted, PG&E has
gained clarification on the regulatory requirements surrounding the 404 permit application from
the State Water Resources Control Board (SWRCB). The SWRCB has informed PG&E that,
under the U.S. Environmental Protection Agency’s 2023 Clean Water Act Section 401
Document Accession #: 20250918-5095 Filed Date: 09/18/2025
Certification Improvement Rule, a new Water Quality Certification is required for any activity
necessitating a Section 404 permit, regardless of prior certification status. Given the required 30-
day pre-filing meeting followed by the one-year statutory review period for Section 401
certifications, it is no longer feasible to complete the permitting process in time for 2025 gravel
augmentation implementation. For this reason, PG&E is requesting another extension of time
until October 31, 2026.
Due to the recent additional permitting requirements, I approve this extension of time through
October 31, 2026.
If you have any questions, please contact Leslie Edlund, Public Service Staff Officer at (530)
283-7620, or by email at leslie.edlund@usda.gov.
Sincerely,
RACHEL BIRKEY
Acting Forest Supervisor
cc: Leigh Ellen Johnson, Erika Brenzovich
Document Accession #: 20250918-5095 Filed Date: 09/18/2025
Digitally signed by
RACHEL BIRKEY
Date: 2025.08.08
12:34:29 -07'00'
Document Content(s)
PGE20250918_619_Bucks_Gravel_Augmentation_EOT_Ltr.pdf ....................1
PGE20250918_619_Bucks_Gravel_Augmentation_EOT_Enc1.pdf....................3
Document Accession #: 20250918-5095 Filed Date: 09/18/2025