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Home My WebLink About10.14.25 Board Correspondence - FW_ Environmental and Recreational Compliance Report submitted in FERC P-2107-000 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:Loeser, Kamie; Nuzum, Danielle Subject:Board Correspondence - FW: Environmental and Recreational Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al. Date:Tuesday, October 14, 2025 11:33:09 AM Please see Board Correspondence - -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Tuesday, October 14, 2025 9:55 AM Subject: Environmental and Recreational Compliance Report submitted in FERC P-2107-000 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 10/14/2025, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: Pacific Gas and Electric Company Pacific Gas & Electric Company (as Agent) Docket(s): P-2107-000 Lead Applicant: Pacific Gas and Electric Company Filing Type: Environmental and Recreational Compliance Report Description: Pacific Gas and Electric Company submits documentation of the United States Forest Service's approval for the Poe Invasive Weed Management Strategy re the Poe Hydroelectric Project under P-2107. To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20251014- 5151__;!!KNMwiTCp4spf!BR-QY0iTI5T-wtgOVRIA6- LZQwJkzWNqAxcAJqNNICN8HYum8mDi4KjVdtGWliAnIiusTNKxcrGLmiL_w-K9PKNtpm_YdAvqQRTz$ To modify your subscriptions, click here: https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!BR-QY0iTI5T- wtgOVRIA6-LZQwJkzWNqAxcAJqNNICN8HYum8mDi4KjVdtGWliAnIiusTNKxcrGLmiL_w- K9PKNtpm_YdAEzB6bw$ ------------------------------------------------------------------------ Please do not respond to this email. Online help is available here: https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!BR-QY0iTI5T- wtgOVRIA6-LZQwJkzWNqAxcAJqNNICN8HYum8mDi4KjVdtGWliAnIiusTNKxcrGLmiL_w- K9PKNtpm_YdCI6eMgX$ 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 October 13, 2025 Via Electronic Submittal (E-File) Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission Division of Hydropower Administration and Compliance 888 First Street, NE Washington, D.C. 20426 RE: Poe Hydroelectric Project, FERC No. 2107-CA Forest Service Approval for the Poe Invasive Weed Management Strategy Dear Secretary Reese: This letter presents documentation of United States Forest Service (Forest Service) approval for the Poe Invasive Weed Management Strategy (Strategy) for Pacific Gas and Electric Company’s (PG&E) Poe Hydroelectric Project (Project), Federal Energy Regulatory Commission (FERC) No. 2107. FERC Article 403 of the Project license and Forest Service 4(e) Condition nos. 34 and 12 requires the development of a management plan to control invasive weeds and address the use of pesticides on National Forest System Lands within the Project. To comply with the conditions, the Poe Integrated Vegetation Management Plan (Plan) was developed and approved by FERC on November 2, 2023. One component of the Plan was to develop a detailed approach to managing invasive weeds found on the Project. This document, the Strategy, was developed to provide detailed methods for invasive weed control in support of the Plan’s goal to control invasive weeds and monitor both the distribution of invasive weeds and the efficacy of invasive weed control activities. The draft Strategy was sent to the Forest Service on November 1, 2024 , and comments received were addressed in the final Strategy. The final Strategy was provided to the Forest Service on December 23, 2024, and no further comments were received. The Forest Service provided approval in a letter on August 8, 2025. The Strategy will be implemented beginning in 2026. The Strategy, dated December 2024, is enclosed with this submittal (Enclosure 1). Forest Service approval is enclosed with this submittal (Enclosure 2). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Debbie-Anne Reese, Secretary October 13, 2025 Page 2 If you have questions or comments regarding this matter, please contact Anna Urias, license coordinator for PG&E, at (530) 201-1961. Sincerely, Chadwick McCready Senior License Coordinator Enclosures: 1. Poe Invasive Weed Management Strategy, dated December 2024 2. Forest Service Approval cc: via email w/enclosures Caitlin Ostomel, Forest Service - caitlin.ostomel@usda.gov Kurt Sable, Forest Service – kurt.sable@usda.gov Loren Everest, Forest Service – loren.everest@usda.gov Erika Brenzovich, Forest Service – erika.brenzovich@usda.gov Dawn Alvarez, Forest Service - dawn.alvarez@usda.gov Emily Doe, Forest Service - Emily.Doe@usda.gov Document Accession #: 20251014-5151 Filed Date: 10/14/2025 ENCLOSURE 1 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 PACIFIC GAS AND ELECTRIC COMPANY Poe Hydroelectric Project Poe Invasive Weed Management Strategy FERC Project No. 2107 December 2024 ©2024, Pacific Gas and Electric Company Document Accession #: 20251014-5151 Filed Date: 10/14/2025 (This page intentionally left blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 PACIFIC GAS AND ELECTRIC COMPANY Poe Hydroelectric Project Poe Invasive Weed Management Strategy Prepared for: Pacific Gas and Electric Company 300 Lakeside Drive, Oakland, California 94612 Prepared by: Kleinfelder 3130 Kilgore Road, Suite 200, Rancho Cordova, California 95670 December 2024 ©2024, Pacific Gas and Electric Company Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Citation: Pacific Gas and Electric Company. 2024. Federal Energy Regulation Commission Project No. 2107. Poe Invasive Weed Management Strategy. December 2024. Oakland CA. Prepared by Kleinfelder, Rancho Cordova, CA. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Table of Contents i December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company TABLE OF CONTENTS 1.0 Introduction .................................................................................................................................... 1-1 1.1 Background and Purpose ................................................................................................. 1-1 1.2 Control Area .................................................................................................................... 1-1 1.3 Target Invasive Weed Species ......................................................................................... 1-3 1.4 Invasive Weed Comprehensive Inventory, Mapping, and Reporting .............................. 1-6 2.0 Invasive Weed Management Strategy ............................................................................................ 2-1 2.1 Pre-treatment Field Procedures ........................................................................................ 2-1 2.1.1 Pre-operations Meeting ....................................................................................... 2-1 2.1.2 Control Treatment Decision Process .................................................................. 2-1 2.1.3 Forest Service Herbicide Use Consultation Process ........................................... 2-2 2.1.4 Pre-treatment Field Preparation .......................................................................... 2-2 2.1.5 Annual Environmental Training ......................................................................... 2-2 2.2 Treatment Methods Proposed for Use in Control Area ................................................... 2-2 2.2.1 Manual Control ................................................................................................... 2-3 2.2.2 Mechanical Control............................................................................................. 2-3 2.2.3 Cultural Control .................................................................................................. 2-4 2.2.4 Chemical Control ................................................................................................ 2-4 2.2.5 Foliar and Contact Application Methods ............................................................ 2-5 2.2.6 Soil Active Application Methods ....................................................................... 2-5 2.3 Species to be Treated ....................................................................................................... 2-6 2.3.1 Barbed Goatgrass (Aegilops triuncialis) ............................................................. 2-8 2.3.2 Tree of heaven (Ailanthus altissima) .................................................................. 2-8 2.3.3 Italian thistle (Carduus pycnocephalus ssp. pycnocephalus) .............................. 2-9 2.3.4 Tocalote (Centaurea melitensis) ....................................................................... 2-10 2.3.5 Yellow star-thistle (Centaurea solstitialis) ....................................................... 2-11 2.3.6 Medusahead (Elymus caput-medusae) .............................................................. 2-12 2.3.7 French broom (Genista monspessulana) .......................................................... 2-12 2.4 Best Management Practices ........................................................................................... 2-13 2.4.1 Foothill Yellow-legged Frog Measures ............................................................ 2-14 2.4.2 Streamside Management Zones ........................................................................ 2-14 2.4.3 Water Quality Monitoring ................................................................................ 2-14 2.5 Risk Assessments ........................................................................................................... 2-14 3.0 Summary of Strategy Timeline ...................................................................................................... 3-1 4.0 Process for Modifying Strategy ..................................................................................................... 4-1 5.0 References ...................................................................................................................................... 5-1 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Table of Contents ii December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company LIST OF FIGURES Figure 1 PG&E Poe Hydroelectric Project (FERC No. 2107) location. ............................ 1-2 Figure 2 Locations of target invasive weed species in the Control Area (2024). .............. 2-7 LIST OF TABLES Target invasive weed species list for the Poe Control Area. ............................... 1-3 Poe invasive weed management priority rankings (PGE 2024) .......................... 1-5 Poe 2024 results of comprehensive target invasive weed surveys. .................... 2-6 ATTACHMENTS Attachment A. Target CDFA Noxious Weed Species and Plumas National Forest List of Noxious Weed Species of Interest for Control Attachment B. Risk Assessment Discussions for Proposed Herbicides Attachment C. Weed Treatment Best Management Practices (BMPs) for the Poe Project Attachment D. Water Quality Sampling Protocol Attachment E. US Forest Service Pesticide Use Reporting Form Attachment F. PG&E Response to USFS Comments . Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 1.0 Invasive Weed Management Strategy 1-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 1.0 INTRODUCTION 1.1 Background and Purpose On December 17, 2018, the Federal Energy Regulatory Commission (FERC) issued a new License for Pacific Gas and Electric Company’s (PG&E or Licensee) Poe Hydroelectric Project, Federal Energy Regulatory Commission (FERC) Project Number (No). 2107 (Project), located in Butte County, California (FERC 2018). FERC Article 403 of the License, and Forest Service 4(e) Condition Nos. 34 and 12 (Forest Service 2018) require the development of an Invasive Weed Management Plan, and otherwise address use of pesticides on National Forest System Lands (NFSL) within the Project. On December 12, 2019, the development of an Integrated Vegetation Management Plan to satisfy the Invasive Weed Management Plan requirements of Article 403 and Condition No. 34 as well as the Fuel Treatment Plan requirement of Article 401 and Condition No. 29. The FERC order amending Article 401 and approving development of an Integrated Vegetation Management Plan was issued on January 6, 2020. The Poe Integrated Vegetation Management Plan (Plan; PG&E 2020) was developed and finalized in December 2020. The licensee received FERC approval of the Plan on November 2, 2023. One component of the Plan is to develop a detailed approach to managing invasive weeds found on the project. This document, Poe Invasive Weed Management Strategy (Strategy), was developed to provide detailed methods for invasive weed control in support of the Plan’s goal to control invasive weeds and monitor both the distribution of invasive weeds and the efficacy of invasive weed control activities in the Project’s Control Area (Figure 1). Several Attachments included in this Strategy are excerpted from the Plan. Those include Attachment A (Target CDFA Noxious Weed species and Plumas National Forest List of Noxious Weed Species of Interest for Control), Attachment C (Weed Treatment Best Management Practices (BMPs) for the Poe Project), and Attachment D (Water Quality Sampling Protocol). 1.2 Control Area The Project is located along an approximately 7.62-mile bypassed reach (Poe Bypass Reach; Figure 1) of the North Fork Feather River (NFFR) in Butte County, California. The Project FERC boundary (Figure 1) encompasses approximately 305 acres, including 136 acres of PG&E fee-title property, 160 acres of National Forest System Lands (NFSL) managed by the Forest Service (Plumas National Forest), and 9 acres of private land. The Control Area for invasive weeds includes all lands within the FERC boundary, including PG&E fee-title property and NFSL within the FERC boundary (305 acres), and adjacent PG&E fee-title parcels (1,740 acres; total Control Area approximately 2,045 acres). The FERC Project and Control Area acreages are current as of 2024 and have been updated since the writing of the Plan (PG&E 2020). The Project is located in forested lands that are sparsely populated. The FERC Project boundary includes Poe Powerhouse, Poe Dam, Poe Tunnel, and associated access roads and appurtenant facilities. Big Bend Reservoir serves as the afterbay for the Project. The Project is located upstream of Lake Oroville, the primary storage reservoir for the California Department of Water Resources’ Feather River Project (FERC Project No. 2100), and downstream of PG&E’s Rock Creek–Cresta Project (FERC Project No. 1962). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 1.0 Introduction 1-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Figure 1 PG&E Poe Hydroelectric Project (FERC No. 2107) location. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 1.0 Introduction 1-3 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company The Survey Area for invasive weeds includes land within 200 feet of all Project features including structures, Project roads, facilities, infrastructure, and Project recreation sites. Specifically excluded from the Survey Area are areas where access is unsafe (very steep terrain or high-water flows; areas along State Route 70 where pedestrian surveys are not safe), as well as private property for which the Licensee does not have specific permission to access. Large portions of the Control Area fall into these exclusion areas. 1.3 Target Invasive Weed Species Under the License requirements, invasive weeds for the Project are those aquatic and terrestrial invasive weeds defined by the California Department of Food and Agriculture (CDFA), and species identified by the Forest Service. Target invasive weed species for the Project include all weeds rated as A, B, or Q by CDFA (3 California Code of Regulations [CCR] §4500. Noxious Weed Species, CDFA 2016, and Meyer et al. 2010) and designated by the Plumas National Forest (PNF) (Table 1, Attachment A). The target invasive weed species list is likely to change over time and can be updated on an ongoing basis as needed. Table 1 lists the rating of each of the target invasive weed species proposed for control as determined by CDFA and PNF. The target weed list includes 10 species that are rated “A” by CDFA; these species are the highest priority to the State of California for eradication (Table1). Target invasive weed species list for the Poe Control Area. Scientific Name Common Name CDFA Rating2 Aegilops cylindrica Aegilops triuncialis Ailanthus altissima Arundo donax Carduus nutans Carduus pycnocephalus pycnocephalus Italian thistle C Centaurea diffusa Centaurea melitensis Centaurea solstitialis Centaurea stoebe micranthos Spotted knapweed A Centaurea virgata squarrosa Squarrose knapweed A Chondrilla juncea Cirsium arvense Cirsium ochrocentrum Cynara cardunculus Cytisus scoparius Dittrichia graveolens Elymus caput-medusae Elymus repens Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 1.0 Introduction 1-4 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name CDFA Rating2 Euphorbia virgata E. esula Leafy spurge A Genista monspessulana Isatis tinctoria Lepidium appelianum Hairy whitetop B Lepidium chalepense Lepidium draba Lepidium latifolium Linaria dalmatica dalmatica Dalmatian toadflax A Linaria vulgaris Lythrum salicaria Onopordum acanthium Potentilla recta Rhaponticum repens Acroptilon repens Russian knapweed B Rubus armeniacus1 Spartium junceum 1Himalayan blackberry is widespread in the Project. This species is only targeted for mapping in the Project where it is found in isolated patches; treated for general vegetation management around PG&E facilities and recreation access. 2CDFA Rating (CDFA 2016) A – A pest of known economic or environmental detriment and is either not known to be established in California or it is present in a limited distribution that allows for the possibility of eradication or successful containment. A-rated pests are prohibited from entering the state because, by virtue of their rating, they have been placed on the of Plant Health and Pest Prevention Services Director’s list of organisms “detrimental to agriculture” in accordance with the FAC Sections 5261 and 6461. The only exception is for organisms accompanied by an approved CDFA or USDA live organism permit for contained exhibit or research purposes. If found entering or established in the state, A-rated pests are subject to state (or commissioner when acting as a state agent) enforced action involving eradication, quarantine regulation, containment, rejection, or other holding action. B – A pest of known economic or environmental detriment and, if present in California, it is of limited distribution. B-rated pests are eligible to enter the state if the receiving county has agreed to accept them. If found in the state, they are subject to state endorsed holding action and eradication only to provide for containment, as when found in a nursery. At the discretion of the individual county agricultural commissioner they are subject to eradication, containment, suppression, control, or other holding action. C – A pest of known economic or environmental detriment and, if present in California, it is usually widespread. C-rated organisms are eligible to enter the state as long as the commodities with which they are associated conform to pest cleanliness standards when found in nursery stock shipments. If found in the state, they are subject to regulations designed to retard spread or to suppress at the discretion of the individual county agricultural commissioner. There is no state enforced action other than providing for pest cleanliness. A management goal, or priority, consistent with Sierra Nevada Forest Plan Amendment (SNFPA) noxious weed management direction (USDA 2004), is provided for each of the species mapped during 2024 comprehensive surveys (PG&E 2024). Invasive weeds present within the Control Area were prioritized following priorities from USDA Forest Service (USDA 2004) and presented in Table 2: Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 1.0 Introduction 1-5 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Priority 1 – Prevent the introduction of new invaders. Priority 2 – Conduct early treatment of new infestations. Priority 3 – Contain and control established infestations. Poe invasive weed management priority rankings. Barbed goatgrass Aegilops triuncialis Priority 3: Contain and control established Tree-of-heaven Ailanthus altissima Priority 2: Conduct early treatment of new Italian Thistle Carduus pycnocephalus ssp. pycnocephalus Priority 2: Contain and control established Tocalote Centaurea melitensis Priority 3: Contain and control established Yellow star-thistle Centaurea solstitialis Priority 3: Contain and control established Medusahead grass Elymus caput-medusae Priority 2: Conduct early treatment of new French broom Genista monspessulana Priority 2: Conduct early treatment of new Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 1.0 Introduction 1-6 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 1.4 Invasive Weed Comprehensive Inventory, Mapping, and Reporting As described in the Plan, invasive weed inventory, mapping, and monitoring will consist of comprehensive surveys conducted every five years and annual monitoring. The first comprehensive invasive weed inventory survey for the Project was conducted in 2024. Data from comprehensive surveys form the basis for the development of specific treatment prescriptions and schedule for control. Annual monitoring and mapping surveys will document changes and in population parameters (e.g., population size, infested area) of previously mapped and treated target invasive weed occurrences compared to previous comprehensive survey results and any incidental detections new target invasive weed occurrences. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 2.0 INVASIVE W EED MANAGEMENT STRATEGY Invasive weeds are non-native plants that when introduced into an environment in which they did not evolve. They compete with native plants, dominating and often damaging native plant communities. Invasive weed control aids in the protection and conservation of native plant species, as well as improves wildlife habitat and recreational user experience (United States Fish and Wildlife Service [USFWS] 2020). In some cases, invasive weed control also reduces habitat vulnerability to wildfire. As described in the Plan, PG&E will use an integrated and comprehensive approach to target invasive weed management that includes the following: 1) prevention strategies for invasive weeds (see Attachment C of this Strategy and Section 4.3.1 of Plan, PG&E 2020); 2) an education and training program (Attachment C and Section 4.3.1.1 of the Plan, PG&E 2020); and 3) an array of control methods including manual, mechanical, and chemical. This Strategy describes part 3, the invasive weed control methods proposed for implementation over the term of the License. Proposed treatments to control target invasive weeds will be site- and species-specific. The implemented invasive weed treatments will ultimately be derived from conditions on the ground, as well as recommendations in the five-year comprehensive and annual monitoring reports. In some cases, combinations of treatments may be most effective. 2.1 Pre-treatment Field Procedures 2.1.1 Pre-operations Meeting An annual pre-operations meeting will be held between PG&E and Plumas National Forest staff. As appropriate, PG&E-contracted Pest Control Advisor (PCA), treatment, and monitoring personnel may attend the meeting. The purpose of this meeting is to apprise Forest Service personnel on the status of target invasive weed control activities and to inform PG&E on any Forest Service activities that may be taking place in the Control Area. This meeting will allow PG&E and the Forest Service to better coordinate invasive weed treatments with other activities taking place in the same area. If possible, this annual meeting will be held prior to implementing target invasive weed control activities in the Control Area for the year. Given that invasive weed control activities and locations on various hydroelectric projects may overlap, this meeting may address management for multiple PG&E projects on the Plumas National Forest. By the time of this meeting, it is expected that PG&E and the PCA will have completed and submitted pesticide use proposals (PUPs; i.e., form FS-2100-2 or current successor) for review and approval by the Forest Service. 2.1.2 Control Treatment Decision Process PG&E’s selection of proposed target invasive weed treatments will take place under the direction of a licensed PCA and will consider the following factors: • Site access; • Target invasive weed phenology and potential treatment timing; • Size and physical characteristics of the area to be treated, including soil type, terrain, and slope; • Extent of special-status plants and other desirable vegetation to be avoided during treatment; Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company • Avoiding or minimizing adverse effects to special-status wildlife; • Seasonal conditions including wind and precipitation; • Proximity to waterbodies and potential for run-off; • Proximity to cultural sites; • Proximity to recreational use areas; and • Desired post-treatment state of treated area. 2.1.3 Forest Service Herbicide Use Consultation Process The approval process for pesticide use on NFSL is described in Forest Service Region 5 supplement No. 2100-95-1 to 2150 (Forest Service 2000) and the Forest Service Handbook (Forest Service 2011). This process uses the FERC Final Environmental Assessment (EA; FERC 2007) as the National Environmental Policy Act (NEPA) document of record, and therefore applies to NFSL within the FERC boundary for the Project. Consultation for herbicide use on Forest Service land will follow the process as outlined in the Plan (see Attachment C of this Strategy, and Section 6.3 and Attachment D of the Plan, PG&E 2020). 2.1.4 Pre-treatment Field Preparation As described in the Plan, prior to the start of target invasive weed control treatments, GIS will be used to create the management grid for the Control Area showing which grid cells contain target invasive weeds. A validation survey will be performed to assess current conditions in a representative sample of those cells, during which hard-to-identify target invasive weed species may be flagged to aid crew members with species identification and occurrence locations. As described in Attachment C Measure 14 of this Strategy, prior to target invasive weed control, any known occurrences of special-status plants in proximity to planned treatment activities will be flagged to serve as herbicide exclusion buffers to protect these species during control treatments. The management grid will also include information regarding environmental constraints (e.g., streams or special-status plants) present in each cell. 2.1.5 Annual Environmental Training The environmental training will be performed as described in Attachment C, Measure 15. Prior to commencement of target invasive weed control, a qualified person (e.g., PG&E biologist, contractor biologist, the PCA) will conduct an environmental briefing for treatment personnel. The purpose of this briefing is to assure that treatment personnel follow appropriate treatment prescriptions and the Strategy’s Best Management Practices (BMPs) to minimize impacts to sensitive resources. Training will include instructions on complying with FERC license, Forest Service, and other agency requirements. 2.2 Treatment Methods Proposed for Use in Control Area As per the Plan, an integrated pest management (IPM) approach will be employed to control vegetation, including target invasive weed species, in that all appropriate methods (manual, mechanical, cultural, and chemical) will be considered and incorporated as appropriate for optimum result. Herbicides will be used Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-3 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company to optimize control while reducing ground disturbance and the need for subsequent site restoration. Pre- and post-emergent herbicides will be used, and specific formulations are described in this Strategy base on the results of the first comprehensive invasive weed survey and upon assessing Operations and Maintenance (O&M) vegetation management needs for the Project. Manual and mechanical control will be used when necessary to provide added protection of nearby sensitive resources. Decisions on types of mechanical (e.g., string trimmers, mowers, and chainsaws) and manual (e.g., hand-pulling, shovels, pruners, loppers, handsaws, McLeod tools, and weed wrenches) treatments will be made based on site conditions. 2.2.1 Manual Control Manual treatments will be used alone or in combination with mechanical treatments in areas proximal to sensitive resources, or for small areas requiring vegetation management, including some small-sized target invasive weed occurrences. Types of manual treatments that PG&E may implement include the following: • Pulling – physically pulling plants from the soil by hand or using a tool such as a weed wrench; • Cutting/lopping – using shears, clippers, or similar tools to cut above ground plant parts; • Digging – using hoes, shovels, pulaskis, McLeod tools, or similar tools to remove entire plants including roots; and/or • Solarizing – covering weed infestations with plastic or jute to superheat target plants and/or reduce access to sunlight. Each of these manual methods has advantages and disadvantages for vegetation control. In general, pulling, cutting, and digging have relatively limited use in controlling vegetation. These methods are labor-intensive and not applicable to large areas, nor do they reduce seeds in the soil. Seeds of some species can remain viable for several years. Cutting, and incomplete hand-pulling and digging, will not eliminate root systems, allowing some species to resprout. Therefore, other follow-up methods may be necessary to supplement manual methods. Removing vegetation manually can be selective and minimize effects to nearby sensitive resources and other desirable vegetation. Manual treatments may be appropriate for controlling sporadically occurring plants in small areas, in sensitive habitats, or near streams. However, trampling and/or soil disturbance caused by manual methods can stimulate further seed germination. Solarizing can be effective at controlling vegetation in small areas where aesthetic concerns are not an issue, or where retention of native plants or other ground cover is not necessary. 2.2.2 Mechanical Control Mechanical treatments, alone or in combination with manual or chemical treatments, can also be an integral part of vegetation management, including target invasive weed management. Mechanical methods of vegetation control that PG&E may implement include the following: • Cutting – using powered tools such as chainsaws and brush hogs to remove aboveground parts of undesirable woody vegetation; and • Mowing – cutting vegetation with string trimmers or mowers, or with a rotary head attached to a rubber-tired vehicle. Cutting with chainsaws or brush hogs can be effective for removing undesirable shrubs and can be applied selectively so that damage to nearby desirable vegetation is minimized. Chainsaws can also be used near Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-4 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company water, and result in minimal soil disturbance. Mowing can also be used to control undesirable herbaceous vegetation if timed appropriately but is a non-selective process and cannot be used on steep slopes or rocky terrain; string trimming has more flexibility and can be used slightly more selectively. Mechanical control methods are generally less labor-intensive than manual treatments, but the size of the practical treatment area may be limited by slope and terrain. In addition, cutting and mowing treatments may need to be repeated for greater effectiveness, sometimes multiple times in a growing season to effectively reduce the soil seed bank over time. These treatments also have some similar disadvantages to hand-cutting, in that that they do not reduce seed already present in the soil or eliminate roots. Mowing and cutting may also spread seeds if timed improperly. 2.2.3 Cultural Control The main method of cultural control available for the Project is grazing. In recent years, the use of goats for vegetation management, including invasive weed control, has gained popularity. Goats eat a wide variety of herbaceous and woody species, including yellow star-thistle and Himalayan blackberry. They are not selective and are therefore often used to control dense infestations where little desirable vegetation is present. Goats do not compact the soil compared to cattle, but they do require containment (such as fencing or careful tending). While effective at removing aboveground biomass, grazing does not reduce seeds or roots in the soil and may stimulate some species to resprout. Multiple years of treatment may be required to control invasive weed infestations. 2.2.4 Chemical Control Herbicides will likely be necessary for effective control of target invasive weeds. PG&E uses non-herbicide control techniques when appropriate; however, herbicides are an important tool for effective invasive weed management. Herbicide effectiveness depends on the type of herbicide, application rate, target species, and environmental conditions (e.g., weather and soil type). Additional herbicides may be proposed for specific target invasive weed species. The herbicides proposed below are based on the results of the first comprehensive inventory conducted in 2024. Herbicides will not be used to treat target invasive weed species until this Management Strategy is approved. Prior to use, site-specific herbicides for target invasive weeds will be proposed on PUPs (i.e., FS-2100 forms) and approved by the Forest Service prior to use on NFSL. The herbicides that are expected to be used for Project invasive weed management include, but may not be limited to, the following active ingredients: imazapyr, triclopyr, chlorsulfuron, aminopyralid, and aquatic and terrestrial formulations of glyphosate, fluazifop-p-butyl, and clopyralid. These herbicides have been previously approved for use on PG&E hydroelectric projects on the Plumas National Forest. Additives, including application visualization dyes and surfactants such as formulations of modified vegetable and soybean oil are also used to increase effectiveness. Herbicides and additives are expected to change over the life of the License as safer and/or more effective herbicides are developed. There are two groups of herbicides: non-selective (e.g., glyphosate) and selective (e.g. clopyralid). Non- selective herbicides can be used to kill both broad-leaved plants and grasses. Selective herbicides target certain families or types of vegetation, such as grasses (e.g. fluazifop-p-butyl), sunflower family (e.g., aminopyralid), or woody vegetation (e.g., imazapyr). Some herbicide formulations have been approved for use in or near water, because they break down quickly and/or adhere to the soil tightly and have little chance of run-off (e.g., aquatic formulations of glyphosate), where other formulations cannot be used in or near water due to higher potential for off-site run-off (e.g., clopyralid). In addition, post-emergent herbicides are Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-5 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company only effective on plants that have already germinated (e.g., glyphosate), while pre-emergent herbicides have residual soil activity that prevent germination and impact seedlings as they emerge (e.g., clopyralid). These factors will be considered when developing site-specific herbicide treatment recommendations. Any herbicides to be used on the Project shall be applied by licensed and certified pesticide applicators. Only herbicides registered with the Environmental Protection Agency, the California Department of Pesticide Regulations (CDPR), and Butte County Agricultural Commissioner will be used. Herbicides proposed will be those that are already approved for use on the Plumas National Forest, and for which environmental risk assessments have already been prepared. Herbicide application will typically consist of both foliar/contact and soil active application methods for target invasive weed control. 2.2.5 Foliar and Contact Application Methods Foliar applications are low-volume, directed herbicide treatments that will be used to control herbaceous and resprouting woody vegetation. Applications will typically be made using a backpack, as opposed to general broadcast applications. These applications can be selective or non-selective, depending on the type of herbicide and the application method. For example, a selective herbicide can be used to control broad-leaved invasive weeds and brush when the target vegetation is actively growing, while not affecting desirable grasses. A non-selective herbicide can also be used selectively through the use of low- volume directed backpack applications, or by timing the application aimed at undesirable vegetation to occur after the desirable native species have already produced seed. Applications to target invasive weeds are typically timed prior to seed set. Basal stem treatment is a selective contact treatment using backpack sprayers that will be used to control woody vegetation. In this treatment, an oil-compatible formulation of herbicide is diluted in an oil carrier (e.g., imazapyr or triclopyr with methylated seed oil [MSO]). This mixture is then applied to the lower 18 inches of the target woody plant where it penetrates the bark providing the desired control. Basal stem applications have an extended application window from March through November. Applications are frequently made in the fall following leaf drop, when woody stems are more accessible on deciduous plants. These late-season applications often have little visual impact because applications are made when deciduous plants have already lost their foliage. Cut-stump treatments will be used to prevent woody species from resprouting after cutting. After trees and brush are cut with a chainsaw or loppers, the stumps are treated with herbicide. This application may be done with backpack or by hand. Most cut-stump treatments can be made year- round. Frill, or hack and squirt, is another control method that will be used for woody species. In this application method, a frill or “hack” is made into the woody cambium. Small amounts of undiluted herbicide are then injected into the frill. The herbicide translocates to the roots and stems. This is a low-profile application, since the applicator carries only a hatchet and a hand-sized (e.g., 1-quart) spray bottle. 2.2.6 Soil Active Application Methods Soil active application methods are pre-emergent herbicide treatments. These methods involve applying herbicide to the soil. The herbicide permeates the upper 6 inches of the soil by rainfall and is taken up by Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-6 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company the emerging roots and shoots of germinating seeds. The application methods and materials can result in selective or non-selective treatments, as described below. Non-selective soil active herbicides are generally used where bare ground conditions are required. These non-selective herbicides will be applied to the entire area requiring bare ground conditions and will be generally applied in fall or early winter, in advance of seasonal rainfall, to prevent seedling germination. A backpack sprayer is used for application. Non-selective soil active herbicides can also be used selectively with application devices such as a spot gun, which directs the herbicide to only the targeted species. Selective soil active herbicides will be used to control undesirable broadleaf species while maintaining desirable grass species. Areas treated in this way will include dam slopes and along penstocks. A backpack sprayer is used for applications. 2.3 Species to be Treated During the 2024 botanical surveys, 323 occurrences of seven invasive weed species were documented (Table 3). Table 3 lists all target invasive weed species found during the 2024 comprehensive survey and summarizes the abundance and distribution of each species. Invasive weed species found during the surveys are described briefly below. Maps are provided in Figure 2 (Maps 1-11). Poe 2024 results of comprehensive target invasive weed surveys. Species Name Approximate Population Size in 2024 (No. of Number of Occurrences Approximate Area Occupied Barbed goatgrass (Aegilops triuncialis) 53,854* 25 2 Ailanthus altissima 210* 2 2 Italian thistle (Carduus pycnocephalus ssp. pycnocephalus) 420 12 0.05 acre (2,230 ft2) Tocalote Centaurea melitensis 131,075 16 1.03 acres 2 Centaurea solstitialis 5,107,822 228 2 Elymus caput-medusae 13,050* 11 2 Genista monspessulana 719 12 2 All Target Invasive Weed Species 5,307,150 306 43.16 acres (1,879,746 ft2) (*) indicates that stem counts were utilized for the given species. All other population numbers represent individual plants. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-7 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Figure 2 Locations of target invasive weed species in the Control Area (2024). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-8 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 2.3.1 Barbed Goatgrass (Aegilops triuncialis) Barbed goatgrass is a winter annual pest of rangelands and roadsides. It reproduces by seed, which is transported via animals, wind or water. The seeds are tough and remain viable for 2 years (DiTomaso et al. 2013). Its range in California appears to be expanding and includes the Cascade Range foothills, southern North Coast range, Sacramento Valley, northern and central Sierra Nevada foothills, Central Coast, San Francisco Bay region and South Coast Ranges, up to 3,300 feet elevation (DiTomaso and Healy 2007). Barbed goatgrass invades many types of open habitat including grasslands, oak woodlands, rangelands, pastures, and roadsides. Unlike most invasive weed species, barbed goatgrass can also tolerate and invade habitats with serpentine substrates, which often also support special-status plant species (DiTomaso et al. 2013). It is drought-tolerant and matures later in the season than most other grasses, enabling it to form monocultures. The thatch from the plants has a high silica content that then suppresses other species (DiTomaso et al. 2013). • CDFA List Status: B • PNF List Status: Priority Distribution in the Control Area: Barbed goatgrass was the second most abundant target invasive weed in 2024, with 25 mapped occurrences and approximately 53,854 stems (Table 3). Barbed goatgrass was found growing at Bardees Bar, and along Poe Powerhouse Road. (Figure 2: Maps 1,5-6). Probable Reasons for Occurrence: Barbed goatgrass is easily transported on vehicles, in contaminated hay and straw, and by livestock. Its presence in the Control Area is likely a result of seed transported into the canyon on vehicles, especially cattle trucks, which regularly use Highway 70. Control Methods on the Project: Complete control of barbed goatgrass within the Control Area will be challenging. The sites are located near environmentally sensitive areas. Feasible methods for control of barbed goatgrass within the Project include manual/mechanical and chemical methods. Hand pulling or hoeing small infestations in early growth stages may be used for some occurrences. Glyphosate (Roundup or Roundup Custom/Aquamaster, or similar aquatic labeled product depending on proximity to water), fluazifop-p butyl (Fusilade) and imazapyr (Habitat) can be used for chemical treatment. The highest level of control will be achieved if healthy plants are treated in spring (approximately May), after tillers have been produced, but before flowering. Impacts to native plants can be minimized by using an application method that minimizes spray drift (e.g., a low volume directed spray from a backpack sprayer). Both short-term and long-term follow-up treatments will be used. Follow-up treatments probably will be required for several years because the soil is likely to contain some viable seed that will germinate after the initial treatment. Hand pulling may be used as a follow-up treatment if appropriate or if desirable vegetation is located nearby. 2.3.2 Tree of heaven (Ailanthus altissima) Tree-of-heaven is a fast-growing deciduous tree in the quassia family (Simaroubaceae). This species can invade a number of disturbed habitats, including riparian areas, grasslands, woodlands, and even ruderal areas such as roadsides, vacant lots, and pavement cracks up to 4,100 feet elevation (DiTomaso et al. 2013). It spreads by a combination of seed and root sprouts. Mature trees can produce around 325,000 seeds per year; however, the seeds are not long-lived (DiTomaso and Healy 2007), remaining viable for about 1 year (DiTomaso et al. 2013). The winged seeds can be dispersed by water, wind, human disturbance, and birds. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-9 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company The roots of a single plant can reach up to 50 feet away (DiTomaso et al. 2013), so even a single plant can quickly invade a large area with many clonal shoots. The suckering roots also allow the plants to become established in shaded understories (DiTomaso et al. 2013). Tree-of-heaven will create dense thickets that replace native vegetation and have little wildlife value. In addition, the species likely produces allelopathic chemicals that inhibit the germination and growth of native plants (DiTomaso et al. 2013). Cut trees can readily resprout from the stumps. • CDFA List Status: C • PNF List Status: Priority Distribution in the Control Area: Two populations of tree of heaven comprised of 210 stems were found in a drainage along Poe Powerhouse Road (Table 3; Figure 2: Map 9). Probable Reasons for Occurrence: The population of tree of heaven may have established as the result of transport of seed on vehicle tires, or as the result of wind-blown seeds. Control Methods on the Project: Complete control of tree of heaven within the Control Area is considered feasible because the species is found in a limited number of locations, the infestations are small, and reliable control methods exist for this species. Feasible methods for control include manual/mechanical cutting, followed by chemical cut stump application (imazapyr or triclopyr). 2.3.3 Italian thistle (Carduus pycnocephalus ssp. pycnocephalus) Italian thistle is a winter annual or sometimes biennial forb in the sunflower family (Asteraceae) which typically colonized disturbed open sites, roadsides, pastures, annual grasslands, or wastelands (DiTomaso et al. 2013). It is widely distributed in the North, Central, and South Coast regions, as well as the Sierra Nevada foothills to elevations of approximately 3,000 feet. Italian thistle reproduces from seed which may be dispersed by wind, water, animals, and via human activities. The seeds of Italian thistle can remain dormant and persist in the soil seedbank for up to 7 years (DiTomaso et al. 2013). • CDFA List Status: C • PNF List Status: Priority Distribution in the Control Area: Italian thistle was mapped in 12 occurrences comprising approximately 420 individuals (Table 3). Italian thistle was found growing in small, widely scattered occurrences along Poe Powerhouse Road, along the powerline access roads above Poe Powerhouse, and at Sandy Beach (Figure 2: Maps 2, 6, and 9-11). Probable Reasons for Occurrence: Italian thistle was likely introduced to the North Fork Feather River (NFFR) canyon from large infestations in the grasslands of the Sierra Nevada foothills. It has likely been spread throughout the Control Area by long-term, ongoing reintroductions of seed, and vehicles and animals that spread the seed locally within the canyon. Control Methods on the Project: Italian thistle is currently not widespread through the Control Area, but because of the high probability of reintroduction from Highway 70 traffic, this species is expected to be controlled but not completely removed from the Highway 70 corridor. Because of its long-lived seed bank, chemical treatment with pre-emergent herbicide will be emphasized for effective control. Chlorsulfuron (Telar) is a selective pre-emergent herbicide that will provide excellent Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-10 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company control of Italian thistle. Other herbicides that can also be used for control are triclopyr (Garlon), clopyralid (Transline), aminopyralid (Milestone) and glyphosate (Roundup Custom/Aquamaster, or similar aquatic labeled product near water). Where populations are limited in size and safely accessible, some manual removal could be implemented. Where populations are dense, but access is safe, well-timed mechanical removal may be used. Treatment for Italian thistle is expected to commence each year in the spring (approximately May). Short- term follow-up treatments will be used. Long-term follow-up treatments will be required for many years; seeds will continue to germinate from the soil seedbank present in areas where infestations have been established. Although this species may be removed or controlled in individual treatment areas, particularly outside of the Highway 70 corridor, complete removal from the Control Area is not expected. 2.3.4 Tocalote (Centaurea melitensis) Tocalote is a winter annual forb in the sunflower family (Asteraceae) that has infested a variety of habitats throughout most of central and northern California since its introduction (DiTomaso and Healy 2007). Tocalote reproduces from seed and can produce up to 6,000 seeds per plant. (DiTomaso and Healy 2007). Tocalote is highly competitive with native plants, especially in grazed areas, and is capable of forming monocultures that maintain dominance over an area for many years (DiTomaso et al. 2013). While seeds are prolific and reported to be long-lived, control/removal of plants consistently for two to three consecutive years (using several treatments) will often drop population numbers considerably (DiTomaso et al. 2013). Although undocumented, cultural strategies used to control yellow star-thistle are likely to control tocalote as well (DiTomaso et al. 2013). • CDFA List Status: C • PNF List Status: Priority Distribution in the Control Area: Tocalote was mapped in 16 occurrences with an approximate Project- wide population size of 131,075 individuals (Table 3). The largest occurrences were located underneath the powerlines at Bardees Bar. Other smaller occurrences were located underneath the powerlines above Poe Powerhouse (Figure 2: Maps 5-6, and 9-11). Probable Reasons for Occurrence: Tocalote was likely introduced to the North Fork Feather River (NFFR) canyon from large infestations in the grasslands of the Sierra Nevada foothills. It has likely been spread throughout the Control Area by long-term, ongoing reintroductions of seed, and vehicles and animals that spread the seed locally within the canyon. Control Methods on the Project: Tocalote is not currently widespread through the Control Area, but because of the high probability of reintroduction from Highway 70 traffic, this species is expected to be controlled but not completely removed from the Highway 70 corridor. Because of the long-lived seed bank of this species, chemical treatment with pre-emergent herbicide will be emphasized for effective control. Chlorsulfuron (Telar) is a selective pre-emergent herbicide that will provide excellent control of tocatlote. Other herbicides that can also be used for control are triclopyr (Garlon), clopyralid (Transline), aminopyralid (Milestone) and glyphosate (Roundup Custom/Aquamaster, or similar aquatic labeled product near water). Where populations are limited in size and safely accessible, some manual removal could be implemented. Where populations are dense, but access is safe, well-timed mechanical removal may be used. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-11 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Treatment for tocalote is expected to commence each year in the spring (approximately May). Short-term follow-up treatments will be used. Long-term follow-up treatments will be required for several years; seeds will continue to germinate from the soil seedbank present in areas where infestations have been established. Although this species may be removed or controlled in individual treatment areas, particularly outside of the Highway 70 corridor, complete removal from the Control Area is not expected. 2.3.5 Yellow star-thistle (Centaurea solstitialis) Yellow star-thistle is a deep-rooted winter annual forb in the sunflower family (Asteraceae) that infests a variety of habitats throughout most of central and northern California. Yellow star-thistle is extremely invasive, and at present is spreading in mountainous regions below 7,500 feet (DiTomaso et al. 2013). It reproduces from seed, and each plant is capable of producing up to 75,000 seeds. Seeds can remain viable in the soil for up to 10 years (DiTomaso et al. 2013). One reason for yellow star-thistle’s extreme invasiveness is its ability to grow vigorously late in the season, when most native plants (except tarweeds and other late-season composites) are dormant. It is highly competitive with native plants, especially in grazed areas, and is capable of forming monocultures that maintain dominance of an area for many years. • CDFA List Status: C • PNF List Status: Priority Distribution in the Control Area: Yellow star-thistle was the most abundant target invasive weed species with 228 mapped occurrences and an approximate Project-wide population size of 5,107,822 individuals (Table 3). Large, extensive populations were mapped along most Project roads and along the powerline ROWs throughout the Control Area (Figure 2: Maps 1, 3, 5-6, and 8-11). Probable Reasons for Occurrence: Yellow star-thistle was likely introduced to the North Fork Feather River (NFFR) canyon from large infestations in the grasslands of the Sierra Nevada foothills. It has likely been spread throughout the Control Area by long- term, on-going reintroductions of seed, and vehicles and animals that spread the seed locally within the canyon. Control Methods on Project: Because yellow star-thistle is so widespread through the Control Area, and because of the high probability of reintroduction from Highway 70 traffic, this species is expected to be controlled but not completely removed from the Highway 70 corridor. However, outside of the Highway 70 corridor in less-travelled areas, yellow star-thistle may eventually be completely removed. General manual/mechanical control of yellow star-thistle is not feasible throughout the Control Area due to the number, size and extent of the infestations. Because of the long-lived seed bank of this species, chemical treatment with pre-emergent herbicide will be emphasized for effective control. Chlorsulfuron (Telar) is a selective pre-emergent herbicide that will provide excellent control of yellow star-thistle. Other herbicides that can also be used for control are triclopyr (Garlon), clopyralid (Transline), aminopyralid (Milestone) and glyphosate (Roundup Custom/Aquamaster, or similar aquatic labeled product near water). Where populations are limited in size and safely accessible, some manual removal could be implemented. Where populations are dense, but access is safe, timed mechanical removal may be used. Treatment for yellow star-thistle is expected to commence each year in the spring (approximately May). The precise date when yellow star-thistle plants will be in the appropriate growth stage for treatment will vary from year to year, depending on local environmental conditions. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-12 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Short-term follow-up treatments will be used. Long-term follow-up treatments will be required for several years; seeds will continue to germinate from the large soil seedbank present in areas where infestations have been established. Although these populations may be removed or controlled in individual treatment areas complete removal from the Control Area is not expected. 2.3.6 Medusahead (Elymus caput-medusae) Medusahead grass is a winter annual grass that reproduces solely by producing copious seeds. This species blooms later than many other annual grasses. Its roots deplete upper soil moisture in early spring and deep soil moisture as the growing season progresses (DiTomaso and Healy 2007). Medusahead grass can establish stands in grasslands and similar open areas. The dense thatch that results creates a barrier to the growth of native plant species, reduces seed germination, lowers habitat quality, and creates wildfire fuel (DiTomaso and Healy 2007). • CDFA List Status: C • PNF List Status: Priority Distribution in the Control Area: Eleven occurrences of medusahead grass with 13,050 stems were mapped mostly at the ridgetop near Parkhill (Table 3; Figure 2, Maps 1 and 10-11). Probable Reasons for Occurrence: Medusahead grass was probably introduced to the NFFR canyon from large infestations in the grasslands of the Sierra Nevada foothills. It has likely been spread throughout the Control Area by vehicles and animals that spread the seed along Highway 70. Medusahead grass may have also spread from a staging area along the highway during road construction activities. Control Methods on Project: Chemical control will be emphasized, either with a general herbicide such as glyphosate, or a selective herbicide such as fluazifop-p butyl in the spring. Short-term revisits and long- term follow-up (until no plants appear for three years) will be performed at sites with this species. 2.3.7 French broom (Genista monspessulana) French broom is a yellow-flowered leafy shrub in the pea family (Fabaceae). Its green stems and leaves are covered with silvery hairs (DiTomaso et al. 2013). It is widespread in multiple habitats throughout California. The long-lived shrubs reproduce from abundant seed which can remain viable for up to 30 years in the soil (DiTomaso et al. 2013). French broom can rapidly develop dense colonies that prevent establishment by native vegetation. These stands are considered a fire hazard and are generally unpalatable to wildlife. • CDFA List Status: C • Plumas National Forest: Priority Distribution in the Control Area: Twelve populations of French broom comprised of 719 individuals were found mostly at the ridgetop near Parkhill with one additional occurrence downhill and further along Poe Powerhouse Road (Table 3; Figure 2, Maps 9-11). Probable Reasons for Occurrence: French broom may have been introduced from seeds transported by vehicles. While uncommon in the Control Area, French broom is very common on the roadsides of Highway 70 to the west. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-13 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Control Methods on Project: Because the infestations observed during comprehensive surveys have been very small, the likelihood of control and removal of this species is high. If the infestation is still small and manageable, the plant(s) may be removed with a Weed Wrench or similar tool before seed set (approximately May). If infestations are larger or the plants are more established, chemical control may be warranted. Foliar treatment may be applied, or stems may be cut and the stumps spot-treated. Broom is sensitive to both selective and non-selective herbicides, and chemical treatment would include glyphosate, aminopyralid, and/or triclopyr. Applications in late summer or fall may be more effective than at other times. Several years of treatment and long-term follow-up are expected because of the very long-lived seed bank. 2.4 Best Management Practices The Plan describes how PG&E will implement general O&M vegetation management and target invasive weed control while protecting valuable resources such as vegetation, soils, wildlife, range, and recreation into the future. All appropriate laws and regulations governing the use of pesticides, as required by governing agencies (CalEPA, CDPR, and Butte County Agricultural Commissioner) and Forest Service policy pertaining to pesticide use, will be followed. All required licenses and permits will be obtained prior to any pesticide application. In addition to existing laws and regulations, several BMPs will be employed to ensure environmental protection of sensitive resources. By agreement with the State Water Resources Control Board, the Forest Service is the water quality management agency for the lands it administers. A series of measures were developed that California and federal water quality agencies expect the Forest Service to implement in order to maintain and improve water quality (Forest Service 2000, 2011, 2012). These measures are designed to prevent degradation of downstream water quality. Therefore, PG&E Project compliance with the Clean Water Act includes a monitoring plan approved by the Forest Service and following guidelines from the Central Valley Regional Water Quality Control Board to ensure standards are met. Based on these agency frameworks a series of BMPs that are pertinent to invasive weeds have been incorporated into the Plan and are included in Attachment C. The pertinent measures are 13 and 16 to 22: Pesticide Spill Contingency Planning; Follow Legal Requirements; Pesticide Application, Monitoring, and Evaluation; Applications Directed by a Licensed PCA; Manual or Mechanical Control Near Sensitive Resources; Cleaning and Disposal of Pesticide Containers and Equipment; Controlling Pesticide Drift During Spray Applications; and Streamside Wet Area Protection During Herbicide Spraying. These BMPs describe actions to be followed during target invasive weed treatment for the protection of Project natural resources. All herbicide applicators will be qualified, trained, and licensed pesticide contractors and will be reviewed closely by PG&E personnel or their representatives to ensure adherence to regulations, Plan requirements, and reporting requirements (e.g., Butte County Agricultural Commissioner requires monthly reporting). Other BMPs to protect Project natural resources will also be followed; for instance, manual and mechanical control will be used when necessary to provide protection of nearby sensitive resources, cultural sites, or other situations where the use of herbicides may be determined by the Plumas National Forest to be potentially problematic. PG&E’s biologists or contractors will work closely with vegetation management contractors, ensuring that environmentally sensitive resources (e.g., streams, sensitive plant populations) are identified and protected prior to herbicide applications. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-14 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 2.4.1 Foothill Yellow-legged Frog Measures The North Feather Distinct Population Segment of FYLF was listed as federally threatened on September 28, 2023 (USFWS 2023). This listing occurred after issuance of the Poe License in 2018 and the development of the Poe IVMP in 2020. There are documented occurrences of FYLF within the Control Area so the BMPs in Appendix C will be implemented to further minimize potential negative effects to FYLF during the manual and chemical invasive weed management activities. These BMPs have been adapted from Sierra Nevada Yellow-legged Frog measures from the Formal Consultation on the Pacific Gas and Electric and City of Santa Clara Bucks Creek Hydroelectric Project (Commission #P-619), Plumas County, California and applied to FYLF (USFWS 2019). 2.4.2 Streamside Management Zones PG&E will minimize the risk of herbicide inadvertently entering waters, or unintentionally altering riparian areas, streams, or wetlands (Forest Service 2000, 2011, 2012), by establishing untreated stream buffer strips (i.e., SMZs) on all stream courses and roadside ditches that might be impacted by treatment (Attachment C, Measure 22 Streamside Wet Area Protection During Herbicide Spraying). Untreated SMZ widths will be based on the type of herbicide and its chemical properties, stream class, and the presence of water during treatment (Attachment C, Table C-1). These SMZs will provide adequate protection for downstream beneficial uses. These SMZs will also provide protection for special-status organisms utilizing mesic or aquatic habitat (e.g., special-status wildlife in streams). 2.4.3 Water Quality Monitoring Based on proposed treatment prescription, a water quality monitoring protocol (following requirements from Forest Service 2000 and 2012) is included as Attachment D. Water quality monitoring will verify that no herbicides prescribed for the Project’s Control Area enter the surface waters and will confirm efficacy of SMZs. Water quality monitoring consists of qualified laboratory testing of upstream and downstream surface water “control” samples for presence of herbicides prior to herbicide application, followed by repeat samples after treatment following run- off producing rainfall to detect any herbicide entering waterbodies. The intent of the water quality monitoring protocol is to determine if the SMZs and other BMPs implemented are adequately protecting Project water bodies from herbicide run-off. As such, the protocol provides a means for halting testing after three years of negative detections if treatment methods and herbicides have not changed. 2.5 Risk Assessments Chemical control will be a significant component of this Strategy. Herbicides planned for use on invasive weeds within the Control Area will include seven active ingredients: aminopyralid, chlorsulfuron, clopyralid, fluazifop-p butyl, glyphosate, imazapyr, sulfometuron methyl and triclopyr. Surfactants would include oil-based: MSO, Hasten, Competitor; and non-ionic: Induce, Activator 90 (Attachment E). There is risk associated with any integrated pest management tool. No activity can be deemed completely safe. However, assessing the risk and then assigning mitigation measures will minimize the risk associated with invasive weed management and the applications of herbicides. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-15 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company People in the Control Area potentially at risk fall into two groups: workers and members of the public. Workers include applicators, supervisors, and other personnel directly involved in the application of herbicides. The public includes forest workers who are not directly involved in the herbicide application, and forest visitors or nearby residents who could be exposed through spray drift, through contact with sprayed vegetation, by eating food items such as berries growing in the treated areas, by placing collected plant materials in the mouth (such as in the preparation of basket weaving materials), by eating honey, game or fish containing herbicide residues, or by drinking water that contains such residues (USDA 1989). Anyone who is outside the treatment area is unlikely to be affected. The most likely individuals to be exposed to herbicides during and after this Project are the backpack applicators applying the treatments, residents who live near the treatment areas and visit the sites, hikers and backpackers, hunters, fishers, nature students, native plant material collectors, and firewood gatherers. Assumptions about workers typically involved in carrying out vegetation management projects involving chemical methods have been reviewed (USDA 1989 pages 4-103 and 4- 104). Experience on the National Forest lands involving work similar to that described in this Strategy indicates maximum production rates of 0.5 acre per hour per worker and an average 6-hour workday (actual application time). For the proposed Project, crew size during application of herbicides will not exceed four applicators, but may from time to time include up to two additional supervisory personnel. The proposed control sites on Forest System Lands include areas that might be used for dispersed recreation including activities such as hiking, hunting, fishing, woodcutting, berry-picking, or collection of plant materials for basket weaving. The public may pass through or near these sites while participating in these activities. No estimate has been made of the numbers of people potentially affected in this way, but the number is expected to be low. The exposure of the public will be limited by strict adherence to BMPs that require posting and notification of herbicide applications in the area. Accidental scenarios such as overspray on members of the public using the Control Area for recreation are unlikely as posting will be evident and applications will cease in the event the public enters the application site. Mixing and loading will occur in the backpack; this will further reduce the potential for contamination from spills. Any exposure of residents living beyond ¼ mile from treatment sites to drift from an herbicide spray project is negligible (USDA 1989 pages F-79 to F-81). According to recent work completed by the CDPR, exposure to native plant material collectors can be essentially eliminated if they remain at least 100 feet from the treated areas (Wofford et al. 2003). In the CDPR study, herbicides were detected in 19 of 227 (8%) samples taken outside both aerial and ground-based herbicide application units. The majority of these positive samples (90%) were within 70 feet of the sampled unit edge, and all positive samples had concentrations of herbicides less than or equal to 2.68 parts per million (Jones and Wofford 1999). This study did not determine whether detected amounts were due to drift or errors in application. This would indicate that with ground-based applications, negligible amounts of off-site movement due to drift would be expected beyond 75 to 100 feet from the unit edge. The Forest Service has developed a process for analyzing the risk associated with the use of a specific pesticide. Each of the pesticides listed above has undergone this analysis looking at a general set of application criteria. In addition to the generic assessment, there are Excel spreadsheets that allow for further project-specific analysis. The purpose of the analysis is to assess the risk to human health and the environment from the use of the herbicides planned for use. The assessments review the potential health effects of workers and members of the public who might be exposed to an application of each herbicide. Exposure scenarios are explained in the risk assessment reports for each of these herbicides prepared for the Forest Service by Syracuse Environmental Research Associates (SERA, SERA 2004 a-b, 2007, 2011 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 2.0 Invasive Weed Management Strategy 2-16 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company a-c, 2014), these risk assessments are incorporated by reference and can be found at http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. The assessments compare a potential exposure dose with the established daily reference dose (RfD) established by the EPA. This is expressed in the form of a hazard quotient. The RfD is a level of exposure at or below which no acute or chronic health effects will result. The hazard quotient is the project potential exposure dose and is expressed as ratio to the RfD. Excel risk assessment work sheets were prepared for this Project for all seven herbicide active ingredients and two incidental contaminants/byproducts. These sheets were prepared for additional support of the use of these products and are incorporated by reference; risks of each herbicide are discussed in Attachment E. Except where noted, each herbicide-specific spreadsheet analyzes four human and five environmental (plant and animal) risk potentials. The Project-specific spreadsheets consider human risk as well as risk to wildlife and plant life. The rates and concentrations more accurately reflect field conditions based on prescribed rates and application methods. Applications within the watershed will be spot applications treating individual plants or small groups of plants over a continuous area of 20 to 200 square feet (not more than ¼ acre) at a given location versus one continuous acre or more. Applicators will work an 8-hour day, but actual application and exposure time may be less than two hours. Remote locations and small target plant populations within a specific treatment area require significant time to access and locate. The potential risk involved with the use of herbicides prescribed for this Project is minimal. This analysis is consistent with the SERA documents for all herbicides. BMPs further ensure that risks will be minimized. Aerial broadcast application analysis was not evaluated as this method will not be used. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 3.0 Summary of Strategy Timeline 3-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 3.0 SUMMARY OF STRATEGY TIMELINE A generalized schedule for proposed target invasive weed management and reporting is included in the Plan (PG&E 2020). PG&E would begin control activities in the first year after the first comprehensive survey (i.e., 2025); initiation of control would follow the initial comprehensive survey and approval of this Management Strategy. Following the initial comprehensive survey, target invasive weed treatments and monitoring will occur annually at each location where target occurrences have been identified. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 4.0 Process for Modifying Strategy 4-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 4.0 PROCESS FOR MODIFYING STRATEGY As described in the Plan, this Strategy is considered a working document to be modified as needed following comprehensive surveys. After subsequent comprehensive surveys, or at other periods as appropriate, PG&E, in consultation with the Forest Service, may revise the Strategy on an as-needed basis. Revisions may include changes to control methods to better control existing target invasive weed occurrences or newly observed target invasive weeds to improve treatment efficiency or effectiveness. Changes in infestation conditions, treatment effectiveness, and resource conditions may result in the need to adapt treatment prescriptions. Accordingly, the tools needed for efficient treatment, including treatment methods and herbicides, may also change over time; utilizing best available technologies is a critical component of this Strategy. If new herbicides or treatment methods are proposed, this document (Poe Invasive Weed Management Strategy) will be revised with an addendum. A letter referencing the existing Poe Integrated Vegetation Management Plan and documenting revisions to this strategy and approval by the Forest Service shall be filed with FERC. The revisions and addendum may include: a) Any relevant documents such as human health and ecological risk assessment (e.g. SERA risk assessment) for the proposed changes; b) A Biological Assessment/Evaluation analyzing the effects of the proposed herbicide, surfactants, and/or treatment methods for wildlife, fish, and botanical resources (e.g. USFS Sensitive, watchlist, TES and Proposed species); and c) A No Effect determination, documentation of informal/formal consultation with USFWS or Biological Opinion for listed species. FERC will act as the lead agency for this consultation. d) Copy of the licensee’s latest version of the Poe Invasive Weed Management Strategy that covers proposed herbicides, surfactants, and treatment methods (if it has changed from the previous version). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 5.0 References and Personal Communications 5-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 5.0 REFERENCES California Department of Food and Agriculture (CDFA). 2016. Pest Rating Proposals and Final Ratings. Available: https://blogs.cdfa.ca.gov/Section3162/. Dated May 13, 2016. DiTomaso, J.M. and E. Healy. 2007. Weeds of California and Other Western States, Volumes 1 and 2. Publication 3488, University of California Agricultural and Natural Resources. Davis, California. DiTomaso, J.M., G.B. Kyser, S.R. Oneto, R.G. Wilson, S.B. Orloff, L.W. Anderson, S.D. Wright, J.A. Roncoroni, T.L. Miller, T.S. Prather, C. Ransom, K.G. Beck, C. Duncan, K.A. Wilson, and J.J. Mann. 2013. Weed Control in Natural Areas in the Western United States. Weed Research and Information Center. University of California, Davis. Jones, D. and P. Wofford. 1999. Preliminary Results of Surface Water Monitored for Forestry Herbicides in the Yurok Aboriginal Territory in the Klamath River Watershed. From California Department of Pesticide Regulation. Spring 1999. Meyer, Deborah, J. Lionakis, and Jim Effenberger. 2010. California Noxious Weed Disseminules Identification Manual. California Department of Food and Agriculture Plant Pest Diagnostics Center – Seed Laboratory. Sacramento, CA. Pacific Gas and Electric Company (PG&E). 2020. Poe Hydroelectric Project, FERC Project No. 2107, Integrated Vegetation Management Plan. Prepared by Garcia and Associates (GANDA). December 2020. PG&E. 2024. Draft Poe Hydroelectric Project, FERC Project No. 2107, 2024 Comprehensive Botanical Resources Survey Report. Prepared by Kleinfelder Inc (KLF). October 2024. Syracuse Environmental Research Associates (SERA). 2004a. Chlorsulfuron – Human Health and Ecological Risk Assessment, Final Report. SERA TR 04-43-18-01c. Prepared for USDA Forest Service. Fayetteville, New York. November 21, 2004. SERA. 2004b. Clopyralid – Human Health and Ecological Risk Assessment – Final Report. SERA TR 04- 43-17-03c. Prepared for USDA Forest Service. Fayetteville, New York. December 5, 2004. SERA. 2011a. Glyphosate – Human Health and Ecological Risk Assessment Final Report. SERA TR 052- 22-036. Prepared for USDA Forest Service. Manilus, New York. Available: http://www.fs.fed.us/foresthealt/ pesticide/risk.shtml. Dated March 25, 2011. SERA. 2011b. Imazapyr – Human Health and Ecological Risk Assessment Final Report. SERA TR 052- 29-03a. Prepared for USDA Forest Service. Manilus, New York. Available: http://www.fs.fed.us/foresthealth/pesticide/ risk.shtml. Dated December 16, 2011. SERA. 2011c. Triclopyr – Human Health and Ecological Risk Assessment, Final Report. SERA TR 052- 25-03a. Prepared for USDA Forest Service. Manilus, New York. Available: http://www.fs.fed.us/foresthealth/pesticide/risk.shtml. Dated May 24, 2011. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy 5.0 References and Personal Communications 5-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company SERA . 2014. Scoping/screening Level Risk Assessment on Fluazifop-p-butyl Final Report. SERA TR- 056-07-02a. Prepared for USDA Forest Service. Manilus, New York. Available: http;//www.fs.fed.us/foresthealth/pesticide/risk.shtml. Dated July 21, 2014. USDA Forest Service. 1989. Soil and Water Conservation Handbook. FSH 2509.22. Sierra National Forest. USDA Forest Service. 2004. Sierra Nevada Forest Plan Amendment Final Supplemental Environmental Impact Statement, Record of Decision. Online version, dated January 2004. United States Department of Agriculture – Forest Service (Forest Service). 2000. Pacific Southwest Region Water Quality Management for Forest Service Lands in California. Best Management Practices. Forest Service. 2011. Forest Service Handbook – Soil and Water Conservation Handbook, Chapter 10 (R5 FSH 2509.22), Section 12.2. Forest Service. 2012. National Best Management Practices for Water Quality Management on National Forest System Lands. Volume 1: National Core BMP Technical Guide. (FS-990a). April 2020. United States Fish and Wildlife Service. (USFWS). 2019. Formal Consultation on the Pacific Gas and Electric and City of Santa Clara Bucks Creek Hydroelectric Project (Commission #P-619), Plumas County, California. December 23, 2019. USFWS. 2020. Invasive Species webpage. Available: http://www.fws.gov/invasives. Wofford, Pamela, K. Goh, D. Jones, H. Casjens, H. Feng, J. Hsu, D. Tran, J. Medina, and J. White. 2003. Forest Herbicide Residues in Surface Water and Plants in the Tribal Territory of the Lower Klamath River Watershed of California. California Department of Pesticide Regulation Report. May 2003. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Attachment A Target CDFA Noxious Weed Species and Plumas National Forest List of Noxious Weed Species of Interest for Control Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company (This page intentionally left blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company CDFA section 4500 and list A, B, and Q noxious weed species. Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Acacia paradoxa kangaroo thorn yes none B Acaena anserinifolia bronze piri-piri-bur yes none A Acaena novae-zelandiae biddy-biddy yes none A Acaena pallida pale biddy-biddy yes none A Acroptilon repens Russian knapweed yes none B Aegilops cylindrica jointed goat grass yes none B Aegilops ovata ovate goat grass yes none B Aegilops triuncialis barbed goat grass yes none B Aeschynomene species joint-vetch yes A A Ailanthus altissima tree of heaven yes C C Alhagi maurorum camelthorn yes none A Allium paniculatum panicled onion yes none B Allium vineale wild garlic yes none B Alternanthera alligatorweed yes A A Alternanthera sessilis Ambrosia trifida Araujia sericifera Arctotheca calendula Arundo donax Asphodelus fistulosus Atriplex amnicola Baccharis halimifolia Berteroa incana Brachypodium sylvaticum Butomus umbellatus Cabomba caroliniana Carduus acanthoides Carduus crispus Carduus nutans Carduus pycnocephalus Carduus tenuiflorus Carrichtera annua Carthamus baeticus Carthamus lanatus Carthamus leucocaulos whitestem distaff thistle yes none A Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Carthamnus oxyacantha jeweled distaff thistle no B none Cenchrus echinatus southern sandbur yes none C Cenchrus incertus coast sandbur yes none C Cenchrus longispinus mat sandbur yes none C Centaurea calcitrapa purple star-thistle yes none B Centaurea diffusa diffuse knapweed yes none A Centaurea iberica Iberian star-thistle yes none A Centaurea jacea (includes C. pratensis, C. ) meadow knapweed (black or brown yes none A Centaurea melitensis Centaurea solstitialis Centaurea squarrosa Centaurea stoebe Centaurea maculosa spotted knapweed yes none A Centaurea sulphurea Ceratopteris thalictroides Chondrilla juncea Chorispora tenella Chrysanthemoides monilifera Bitou bush no A none Cirsium arvense Cirsium japonicum Cirsium ochrocentrum Cirsium undulatum Cirsium vulgare Clematis vitalba Coincya monensis Convolvulus arvensis Cortaderia jubata Crupina vulgaris Cucumis melo dudaim dudaim melon yes none A Cucumis myriocarpus Cuscuta spp. (non-native) yes none A Cynara cardunculus Cyperus esculentus Cyperus rotundus Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-3 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Rating2 Action- Oriented 3 Cytisus scoparius Scotch broom yes none C Cytisus striatus Portuguese broom no B none Diodia virginiana buttonweed yes C B Dittrichia graveolens stinkweed yes none none Dittrichia viscosa false yellowhead no A none Drymaria cordata whitesnow yes C B Echium plantagineum Paterson's curse no A none Egeria najas narrow-leaf elodea yes none A Elymus repens (same as Elytrigia repens) quack grass yes none B Enchylaena tomentosa Erica lusitanca Euphorbia dendroides Euphorbia esula Euphorbia graminea Euphorbia hypericifolia Euphorbia myrsinites Euphorbia oblongata Euphorbia serrata Euphorbia terracina Geraldton carnation spurge yes none B Fallopia japonica as Polygonum cuspidatum, Reynoutria ) Japanese knotweed yes A B Fallopia sachalinensis (same as Polygonum sachalinensis, Reynoutria sachalinensis) giant knotweed yes A B Fallopia xbohemica (same as Reynoutria xbohemica, Polygonum xbohemica Bohemian knotweed yes A none Fatoua villosa Galega officianalis Genista monspessulana Geranium lucidum Gymnocoronis spilanthoides (same as Alomia splanthoides Senegal tea plant no A none Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-4 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Gypsophila paniculata baby's breath no B none Halimodendron halodendron Russian salttree yes none A Halogeton glomeratus Helianthus ciliaris Heracleum mantegazzianum giant hogweed no A none Heteranthera reniformis kidneyleaf mud plantain no A none Heteropogon contortus Hieracium aurantiacum Hydrilla verticillata Hydrocharis morsus- ranae frogbit yes A A Hygrophila polysperma Hyoscyamus niger Hypericum canariense Canary Island Saint John’s-wort yes none B Hypericum perforatum Iris pseudacorus Isatis tinctoria Lagarosiphon major oxygen weed, African elodea yes none A Lepidium appellianum (same as Cardaria appellanum) hairy white-top, globe- podded hoarycress yes none B Lepidium chalepensis (same as Cardaria chalepensis) lens-podded hoary cress yes none B Lepidium coronopus (same as Coronopus squamatus) swinecress yes none B Lepidium draba Cardaria draba yes none B Lepidium latifolium Leptochloa chinensis (same as Dinebra chinensis) Chinese sprangletop yes none none Limnobium laevigatum South American spongeplant yes A A Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-5 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Limnobium spongia spongeplant yes none A Limnophila indica ambulia yes none A Limnophila sessiliflora dwarf ambulia yes none A Limonium durisculum European sea lavendar no B none Limonium ramosissmum Algerian sea lavendar no B Linaria dalmatica Dalmatian toadflax yes none A Ludwigia decurrens winged water-primrose yes A none Ludwigia hexapetala water-primrose yes C none Ludwigia peruviana Peruvian primrose- willow yes none A Lythrum salicaria Mantisalca salmantica (same as Centaurea salmantica) dagger-flower no A none Mercuraialis ambigua Monochoria vaginalis Muhlenbergia schreberi Myosoton aquaticum Myriophyllum aquaticum Nothoscordum gracile Nymphaea mexicana Nymphoides peltata Oenothera sinuosus (same as ) wavy-leaved gaura yes none B Oenothera xenogaura (same as Gaura drummondii) Drummond’s gaura yes none B Ononis alopecuroides Onopordum acanthium Scotch thistle yes none A Onopordum illyricum Onopordum tauricum Orobanche aeyptica Orobanche ramosa Oryza rufipogon Panicum antidotale Parthenium hysterophorus Santa Maria feverfew yes A none Peganum harmala Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-6 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Pennisetum clandestinum (same as Cenchrus clandestinus) Kikuyugrass yes C C Persicaria wallichii (same as Polygonum polystachyum, Rubrivena polystachya) Himalayan knotweed yes none B Physalis virginiana sonorae smooth groundcherry yes none A Physalis viscosa Phytolacca hetertepala Potentilla recta Prosopis strombulifera Retama monosperma Rhagadiolus stellatus Rorippa austriaca Rorippa sylvestris creeping yellow field cress yes none B Saccharum ravennae Salsola collina spineless Russian thistle yes A A Salsola damascena Salsola vermiculata wormleaf salsola yes none A Salsola gobicola barbwire Russian thistle no B none Salsola paulsenii barbwire Russian thistle yes none C Salsola tragus common Russian thistle yes C C Salvia aethiopis Salvia virgata Salvinia auriculata Scolymus hispanicus Senecio jacobaea Senecio linearifolius Senecio squalidus Sesbania punicea scarlet wisteria, rattle box, red sesbania yes none B Setaria faberi Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-7 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Solanum cardiophyllum heartleaf nightshade yes C A Solanum carolinense Carolina horsenettle yes none B Solanum dimidiatum Torrey's nightshade yes none A Solanum elaeagnifolium white horsenettle yes none B Solanum lanceolatum lanceleaf nightshade yes none B Solanum marginatum white-margined nightshade yes B B Sonchus arvensis Sorghum halapense Johnsongrass and similar perennial yes none C Spartina alterniflora hybrids hybrids yes none B Spartina anglica Spartina densiflora dense-flowered cordgrass yes none B Spartina patens Spartium junceum Sphaerophysa salsula Stipa brachyachaeta (same as Achnatherum brachychaeta, Ameliochloa brachychaeta) puna grass yes none A Striga asiatica Symphytum asperum Taeniatherum caput- medusae medusahead grass yes none C Tagetes minuta Tamarix chinensis Tamarix gallica Tamarix parviflora Tamarix ramosissima Tribolium obliterum Tribulus terrestris Ulex europaeus Vachellia nilotica Viscum album Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-8 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name California Noxious 1 Pest Rating2 Action- Oriented 3 Volutaria canariensis Canary Island knapweed yes none none Volutaria tubuliflora Youngia japonica Zizania latifolia Zostera japonica Zygophyllum fabago 1 – From 3 CCR §4500, as reported in Thomson Reuters 2020. 2 – Rating from CDFA Pest Rating (CDFA 2016). This rating system is in process, and not all noxious weed species listed in 3 CCR §4500 or those of interest to the Plumas National Forest have been rated. Some noxious weed species have been rated that are not listed in 3 CCR §4500. Ratings are as follows: A - Pests of the agricultural industry or environment which score high and are not known to occur or under official control in the State of California. Has authorized mitigating regulatory actions. B - Pests of the agricultural industry or environment which score medium to high and which are of limited distribution in the State of California. Has authorized mitigating regulatory actions. C - Pests of the agricultural industry or environment which score medium to low and are of common occurrence and generally distributed in California. Has no State-enforced authorized mitigating regulatory actions. D - An organism which scores low and is known to be of little or no economic importance to the agricultural industry or environmental detriment, has an extremely low likelihood of invasiveness, is known to be a parasite or predator or pathogen of a pest, or is an otherwise beneficial organism. No authorized mitigating regulatory actions. Q - Pests of the agricultural industry or environment which score high and which are not known to occur or where their California distribution is unknown and which are otherwise suspected of being economically harmful to the agricultural industry or the environment and which may not be completely identified or for which there is inadequate available scientific information. Has authorized mitigating regulatory actions. 3 – Rating from the older CDFA Action Oriented Rating System (Meyer et al. 2010) has also been provided, with definitions as follows: A – A pest of known economic or environmental detriment and is either not known to be established in California or it is present in a limited distribution that allows for the possibility of eradication or successful containment. A-rated pests are prohibited from entering the state because, by virtue of their rating, they have been placed on the of Plant Health and Pest Prevention Services Director’s list of organisms “detrimental to agriculture” in accordance with the FAC Sections 5261 and 6461. The only exception is for organisms accompanied by an approved CDFA or USDA live organism permit for contained exhibit or research purposes. If found entering or established in the state, A-rated pests are subject to state (or commissioner when acting as a state agent) enforced action involving eradication, quarantine regulation, containment, rejection, or other holding action. B – A pest of known economic or environmental detriment and, if present in California, it is of limited distribution. B-rated pests are eligible to enter the state if the receiving county has agreed to accept them. If found in the state, they are subject to state endorsed holding action and eradication only to provide for containment, as when found in a nursery. At the discretion of the individual county agricultural commissioner they are subject to eradication, containment, suppression, control, or other holding action. Q – An organism or disorder suspected to be of economic or environmental detriment, but whose status is uncertain because of incomplete identification or inadequate information. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-9 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Plumas National Forest Invasive Weed List Scientific Name Common Name Acroptilon repens Russian knapweed Aegilops cylindrica jointed goat grass Aegilops triuncialis barbed goat grass Ailanthus altissima tree-of-heaven Arundo donax giant reed Cardaria chalepensis lens-podded white-top Carduus nutans musk thistle Carduus pycnocephalus ssp. pycnocephalus Italian thistle Centaurea diffusa diffuse knapweed Centaurea melitensis Malta star-thistle, tocalote Centaurea solstitialis yellow star-thistle Centaurea stoebe ssp. micranthos spotted knapweed Centaurea virgata ssp. squarrosa squarrose knapweed Chondrilla juncea rush skeletonweed Cirsium arvense Canada thistle Cirsium ochrocentrum yellowspine thistle Cynara cardunculus artichoke thistle Cytisus scoparius Scotch broom Dittrichia graveolens stinkwort Elymus caput-medusae medusahead grass Euphorbia esula leafy spurge Genista monspessulana French broom Isatis tinctoria dyer's woad Lepidium appelianum hairy white-top Lepidium chalepense lens-podded hoary cress Lepidium draba heart-podded hoary cress Lepidium latifolium perennial pepperweed Linaria dalmatica ssp. dalmatica Dalmatian toadflax Linaria vulgaris butter-and-eggs Lythrum salicaria purple loosestrife Onopordum acanthium Scotch thistle Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment A A-10 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Scientific Name Common Name Potentilla recta sulfur cinquefoil Rubus armeniacus* Himalayan blackberry* Spartium junceum Spanish broom Source: Belsher-Howe 2014 *Due to the extensive distribution of Himalayan blackberry (Rubus armeniacus) in the Project and NFFR, and the ability of this species to spread through both seed dispersal and vegetative means, only populations considered critical to control because of conflicts with other land use practices or routine O&M activities will be inventoried, mapped and targeted for application of control measures. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B November 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Attachment B Risk Assessment Discussions for Proposed Herbicides Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company PG&E proposes to conduct invasive weed management activities as part of the Poe Hydroelectric Project, Federal Energy Regulatory Commission (FERC) Project No. 2107 (Project). Per the Poe Hydroelectric Project Invasive Weed Management Strategy (the Strategy), PG&E would use pesticides in combination with the manual vegetation management methods to inhibit growth and re-sprouting of incompatible species and invasive weeds within the Control Area (as defined in the Strategy). The pesticides 1 and surfactants proposed for routine invasive weed management to provide effective control of the target species are listed in Table B-1 below. Table B-1. Proposed pesticides, trade names, application rate, control type, and target species for routine vegetation and pest management at Poe Hydroelectric Project Control Area.a Active Ingredient Trade Name(s) Change) Proposed Application Rate (a.e. lbs/acre) Control Type; Target Species Pesticides Aminopyralid Milestone 0.11 Selective pre- and post-emergent; annual grasses and broadleaf weeds. Control of yellow star thistle and other thistle species. Also prescribed in combination >3 inches bolt. The combination is also effective on broom species and blackberry. Chlorsulfuron Telar XP 0.09 Selective pre-emergent; broadleaf weeds along access roads and trails, specifically for control of star thistle. Also used in combination with Oust XP (below). Clopyralid Transline 0.14 Selective post- including yellow star thistle Fluazifop-p-butyl Fusilade DX 0.25 Selective post- annuals and certain perennials, when to control grasses without impact to desirable broadleaf species  Glyphosate Roundup Custom, Aquamaster 4 Non-selective post-emergent; all vegetation Imazapyr Polaris, Polaris SP 0.5 Non-selective post-emergent; woody vegetation and perennial invasive grasses Indaziflam Esplanade 0.065 Superior broad-spectrum, pre-emergent risk considering off-target injury and movement; grasses and certain broadleaf weeds 1 The term pesticide is defined in this document to include both herbicides and surfactants. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Active Ingredient Trade Name(s) Change) Proposed Application Rate (a.e. lbs/acre) Control Type; Target Species Sulfometuron methyl Oust XP 0.19 Non-selective pre-emergent; annual grasses and broadleaf weeds along roads, trails, and canals Triclopyr (BEE) Garlon 4 2 Selective post-emergent; woody vegetation (cut stumps/basal). Triclopyr (TEA) Garlon 3A 2 Selective post-emergent; woody vegetation and broadleaf weeds Surfactants Oil-based surfactants MOC, Hasten, Competitor N/A See imazapyr; individual plant treatments, mostly as a stump or basal applications Non-ionic surfactant Induce, Activator 90 N/A N/A Notes: N/A = not applicable a.e. = acid equivalent lbs = pounds BEE: butoxyethyl ester TEA = triethylamine a If new pesticides not currently listed in this table (e.g., that would be more effective or lower risk to the environment/public) become available over the term of the new license, PG&E will consult with the appropriate federal land manager (Forest Service or BLM), follow applicable approval procedures, and obtain required authorizations (including, but not limited to, authorization under the National Environmental Policy Act) prior to use. The following sections provide information on the pesticides and exposure scenarios for pesticide use under the proposed Project to support the discussion of potential effects on biological resources. Section B.1 below summarizes each pesticide proposed for use, and Section B-2 provides a quantified risk assessment for biological resources, including wildlife (amphibians, aquatic reptiles, raptors, bats, and carnivorous mammals), sensitive plants, workers, and the public based on proposed Project pesticide application rates. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-3 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company B.1 Pesticide Summaries B.1.1 Aminopyralid Aminopyralid, the active ingredient in Milestone, is a broadleaf selective herbicide with both pre- emergent and post-emergent activity. The herbicide is used extensively in agriculture and rangeland. The compound is also used extensively in open space and wildlife areas for the control of invasive weeds. Milestone cannot be applied to water (SERA 2007; WSSA 2014). Mode of Action Aminopyralid is a synthetic auxin. It is absorbed through both the roots and leaves of susceptible plants. It moves readily through the phloem and xylem. It accumulates in the meristematic tissue of both roots and shoots. Little is known about metabolism in susceptible plants. Aminopyralid is rapidly metabolized in tolerant plants such as grasses. Susceptible plants cease growth soon after applications. Over a period of one to three weeks, plants turn from green to reddish-yellow and to brown. Epinasty at the growing point is also evident. Newer growth becomes mushy and necrotic. Plants treated prior to germination do not emerge. There is little known effect on existing vegetation from soil absorption alone (SERA 2007; WSSA 2014). Environmental Characteristics Behavior in Soil: Aminopyralid is loosely bound to soil, and while there is potential for movement, field studies suggested that leaching is not likely, but this depends on the soil chemistry, mineral content, and organic matter (Shaner et al. 2014). The half-life has a range of 14 to 143 days, depending on soil characteristics and temperature. Field studies, including locations in California, produced an average half-life of 32 days (SERA 2007; WSSA 2014). Behavior in Water: The half-life of aminopyralid in water is approximately 8 hours. Photolysis is the primary method of degradation in water (SERA 2007; WSSA 2014). Toxicological Properties Wildlife: Aminopyralid is considered practically non-toxic to wildlife: terrestrial, aquatic, and invertebrates. Feeding studies involving both quail and ducks resulted in lethal concentration (LC)50 values greater than 5,000 parts per million (ppm) for both species. The LC50 -values for shrimp, daphnia, bluegill, and trout were 100 ppm, and for minnows were greater than 120 ppm. Acute toxicity was equally low for honeybees and earthworms (SERA 2007; WSSA 2014). Human: Aminopyralid is a Category IV herbicide 2. It is considered practically non-toxic to humans. In studies, both oral and dermal acute toxicities were low, with the lethal dose (LD)50 values for both measures at greater than 5,000 milligrams per kilogram (mg/kg). Chronic toxicities 2 Herbicides are assigned a toxicity category (I-IV) for each type of exposure (acute oral, acute dermal, acute inhalation, primary eye irritation, and primary skin irritation) based on results of toxicity studies. The toxicity categories determine the signal words placed on herbicide labels: Category I: Danger; Category 2: Warning; Category III: Caution; and Category IV: None required (USEPA 2014). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-4 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company were low as well. The 24-month dietary no-observed-adverse-effect level (NOAEL) was 50 mg/kg per day. Studies on long-term effects related to cancer, birth defects, mutations, and reproductive impairment revealed no effect at levels greater than 1,000 mg/kg per day (SERA 2007; WSSA 2014). B.1.2 Chlorsulfuron Chlorsulfuron, the active ingredient in Telar, is a selective pre-emergent herbicide with limited post-emergent activity. Telar is active on many broadleaf weeds including Russian thistle, yellow star thistle, and many other members of the thistle family. It is also effective on Lepidium sp. Labeled uses include forestry, agriculture, and non-crop use (WSSA 2014; SERA 2016a). Mode of Action Chlorsulfuron is absorbed through both the shoot and root of a tolerant plant. It is primarily xylem mobile and accumulates in the meristematic tissue. Chlorsulfuron is a sulfonylurea, which means that it kills plants by interfering with an enzyme required for growth. Grasses rapidly metabolize the herbicide, while only a few broadleaf plants have the same mechanism of tolerance (WSSA 2014; SERA 2016a). Environmental Characteristics Behavior in Soil: The behavior of chlorsulfuron in soil is significantly affected by soil pH, because non-microbial hydrolysis is the primary method of degradation; the average half-life is 40 days. As pH decreases, non-microbial hydrolysis increases. The half-life and efficacy of Telar is significantly reduced when the soil pH is below seven A pH above eight or nine can significantly extend the half-life, efficacy, and persistence of Telar (WSSA 2014; SERA 2016a). Behavior in Water: Chlorsulfuron has a half-life of one month in water under artificial light. Under natural conditions, the half-life is significantly less (WSSA 2014; SERA 2016a). Toxicological Properties Wildlife: Chlorsulfuron is practically non-toxic to wildlife, both terrestrial and aquatic. For mallards and quail, studies resulted in acute toxicity of chlorsulfuron (oral LD50) and 8-day dietary LC50 values greater than 1,000 ppm and greater than 5,000 ppm, respectively. The 96-hour exposure studies of sunfish and trout determined the LC50 value to be greater than 250 mg/L for both. The LC50 value for daphnia (48 hours) was 370 milligrams per liter (mg/L) (WSSA 2014; SERA 2016a). Human: Chlorsulfuron is a Category III herbicide (slightly toxic or relatively non-toxic) and is practically non-toxic to humans. In studies, the oral LD50 was greater than 5,000 mg/kg. The dermal LD50 was greater than 2,000 mg/kg. Chronic studies suggest there is little risk from long- term exposure to Telar. A 24-month feeding study of rats produced a NOAEL of 100 ppm. A 12- month feeding study of dogs produced a NOAEL of 2,000 ppm (WSSA 2014; SERA 2016a). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-5 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company B.1.3 Clopyralid Clopyralid, the active ingredient in Transline, is a selective post-emergent herbicide. Various formulations are labeled for use in crops, forestry, range, and utility rights-of-way. Mode of Action Clopyralid is a synthetic growth-regulating herbicide. It stimulates rapid cell elongation, which results in a ruptured cell wall and the destruction of the cell wall. Transline is rapidly absorbed; 97 percent is absorbed within 24 hours. Clopyralid translocates readily within a plant. Fifty percent is translocated out of the leaf within 24 hours. It is slowly metabolized in susceptible plants. Herbicidal activity is evident within 24-to-48 hours. Symptoms include epinasty, chlorosis, and a wilted appearance (SERA 2004a; WSSA 2014). Environmental Characteristics Behavior in Soil: Clopyralid is weakly adsorbed in soil. It is moderately mobile in soil, particularly in sandy or mineral soil. There are groundwater precautions on the label; field studies have demonstrated that across most studies, clopyralid was not mobile (Washington DOT 2006). The half-life of clopyralid is 40 days. Degradation is mostly microbial, affected by moisture and soil temperature (SERA 2004a; WSSA 2014). Behavior in Water: Clopyralid is considered not persistent in water, although little data are available about the environmental fate in water. It has a short half-life. This coupled with dynamic water conditions result in a rapid degradation of this compound in water (SERA 2004a; WSSA 2014). Toxicological Properties Wildlife: Transline appears to be relatively non-toxic to wildlife, including avian, aquatic, and invertebrate species. The LD50 value for mallard ducks is 1,465 mg/kg. The 8-day dietary studies for both quail and mallard duck established LC50 values above 4,000 ppm. Clopyralid technical acid was toxic to honeybees. Studies of 48- and 96-hour exposure established LC50 values greater than 100 ppm for both fish and invertebrates (SERA 2004a; WSSA 2014). Human: Clopyralid is a Category III herbicide (slightly toxic or relative non-toxic). It has the signal word “caution” on the label. Transline and its active ingredient, clopyralid, are considered practically non-toxic. In studies, the acute toxicity of clopyralid was low. The LD50 value was above 5,000 mg/kg. Short-term feeding studies established a NOAEL of 50 to 150 mg/kg per day, depending on species. The long-term feeding studies (12 to 24 months) established a NOAEL of 50 to 500 mg/kg per day depending on species. Clopyralid is not a carcinogen, teratogen, mutagen, or reproductive toxin (SERA 2004a; WSSA 2014). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-6 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company B.1.4 Fluazifop-P-butyl Fluazifop-P-butyl is the active ingredient in Fusilade herbicide. Fusilade is post-emergent grass selective herbicide. It is effective on annual and certain perennial grasses. It is virtually ineffective against broadleaf weeds. There are numerous uses in agriculture and ornamental landscapes. It is not labeled for use in or around water (Sygenta 2023). Mode of Action Fusilade is rapidly absorbed into the tissue of the plant within two hours after application. It translocated through the plant to the meristematic tissue. Its primary mode of action is to prevent enzyme formation key to the development of cell walls, specifically, certain fatty acid production. The plant ceases to grow approximately three hours after application. A noticeable purple or reddening will occur over a period of two to three weeks after application. By three weeks the plant is completely dead. There is some evidence to support seedhead suppression and seed unviability. There are instances of resistance to this herbicide. Environmental Characteristics Behavior in Soil Fluazifop-P-butyl is bound tightly in the soil and unlikely to be mobile. The primary form of degradation is through hydrolysis and chemical breakdown. Typical soil half-life is 15 days. Behavior in water Fluazifop-P-butyl is not water soluble and is unlikely to reach groundwater levels due to its strong tendency to bind with soils. Upon contact with water surfaces, Fluazifop-P-butyl readily hydrolyzes to fluazifop-P-butyl acid, which is stable in water. Toxicological Properties Wildlife Fluazifop-P-butyl as Fusilade is practically non-toxic to terrestrial wildlife. Five-day dietary studies for quail and duck produced LD50 greater than 4,500 and 3,500, respectively. Toxicity to aquatic species is somewhat greater. LC50 for daphnia, bluegill, and trout were 10, 53 and 1.37 mg/L, respectively. Human Fluazifop-P-butyl as Fusilade is minimally toxic to humans. The oral LD50 is greater than 5,000 mg/kg. The dermal LD50 is greater than 2,400. Risk from inhalation or irritation to eyes from exposure is minimal (WSSA 2014). Use of Fusilade will be minimal. It is expected to be used judiciously where problematic populations of invasive grasses are impacting broadleaf or other desirable habitat. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-7 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company B.1.5 Glyphosate Glyphosate, the active ingredient in Roundup Custom/Aquamaster or equivalent, is a broad- spectrum, non-selective systemic post-emergent herbicide used for control of annual and perennial plants including grasses, sedges, broadleaved weeds, and woody plants. Glyphosate has no soil activity. It can be used on non-cropland and on various crops. Certain glyphosate formulations, including Aquamaster and Accord, are suitable for direct application to emergent aquatic vegetation. Glyphosate is used worldwide for the control of exotic plant species in sensitive ecosystems. Glyphosate is one of the most used herbicides in the world, and as a result, is one of the most studied herbicides. Extensive documentation is available regarding its behavior in the environment (SERA 2011a; WSSA 2014). Mode of Action Glyphosate is absorbed slowly into the leaves of the target plant and requires 6 or more hours of rain-free weather to ensure maximum uptake and efficacy. There is no root uptake. Once inside the plant, glyphosate travels readily through the phloem to key activity sites, inhibiting the formation of essential amino acids and plant-specific biochemical processes. Little metabolism of the material occurs in susceptible plants, and this – in part – is why the herbicide is so effective. Symptoms are visible within five days, usually chlorosis and the appearance of a reddish-purple tint in certain species, followed by necrosis within two weeks (SERA 2011a; WSSA 2014). Environmental Characteristics Behavior in Soil: Glyphosate rapidly and tightly binds to soil. There is little potential for leaching or runoff due to its very high adsorption to soil. As a result, glyphosate essentially becomes inactive as an herbicide upon contact with the soil. Glyphosate is so sensitive to soil that excessive dirt or dust on the leaf at time of application or mixing water that is dirty or high in mineral content can severely reduce the herbicide's efficacy. Residue can be detected 60 days post-application although there is no herbicidal activity. Glyphosate is degraded via microbial activity. It has a half-life of 47 days, but immediate metabolites are more persistent with a 60- to 90-day half-life (SERA 2011a; WSSA 2014). Behavior in Water: Glyphosate is very persistent in water with a half-life of 12 days to 10 weeks. The presence of minerals or organic matter in water will tightly bind glyphosate, making it unavailable as herbicide, despite its persistence in the aquatic environment (SERA 2011a; WSSA 2014). Toxicological Properties Wildlife: For less toxic formulations of glyphosate, the oral and dietary LD50 values for both quail and mallard duck were above 4,500 mg/kg. While technically glyphosate can be toxic to aquatic organisms, Roundup Custom or Aquamaster is not considered toxic to fish. Studies on bluegill and trout resulted in LC50 values greater than 1,000 ppm, and carp studies with LC50 values greater than 10,000 ppm. There are some concerns regarding the toxicity of glyphosate-based herbicides due to the internal surfactants used in some formulations to amphibians. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-8 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Humans: Glyphosate has the signal word “caution” on the label. Acute toxicity studies indicated that glyphosate was practically non-toxic to humans. The oral and dermal LD50 were both greater than 5,000 mg/kg. The oral inhalation LC50 value was 3.2 mg/L, and the herbicide has no potential for skin or eye irritation (SERA 2011a). The 90-day and 24-month studies produced NOAELs of 1,400 mg/kg and 400 mg/kg/day, respectively, in the most sensitive animals studied. There was no evidence of carcinogenicity, birth defects, or mutations, and there was no impact to DNA (SERA 2011a; WSSA 2014). B.1.6 Imazapyr Two herbicide formulations of imazapyr with distinctly different intended uses would be prescribed: Polaris for foliar applications and Polaris SP for basal applications. Both are non- selective herbicides used for the control of annual and perennial terrestrial grasses, broadleaf herbs and woody species. Polaris SP is an oil-soluble formulation, while Polaris is an aqueous solution with a label that includes aquatic application. Polaris is used to control riparian and emergent aquatic species. Formulations of imazapyr are used extensively throughout the world in sensitive habitats for the control of invasive species including arundo, melaleuca, pampas grass, and tamarisk. It is primarily a post-emergent herbicide with limited pre-emergent activity (SERA 2011b; WSSA 2014). Mode of Action Imazapyr is rapidly absorbed into the plant by both the root and shoot. It is very mobile in the plant, translocating readily through both the phloem and xylem, inhibiting the synthesis of branched-chain amino acids. Growth is inhibited within hours of application. Symptoms are slow to appear (one to two weeks) and are first observed in the growing point of the susceptible plant. Chlorosis followed by necrosis is observed, and the growing point becomes mushy and is easily removed 60 days after treatment. Susceptible plants metabolize imazapyr slowly, if at all. This persistence allows for translocation throughout the entire plant including the roots, making this herbicide extremely effective on perennial weeds (SERA 2011b; WSSA 2014). Environmental Characteristics Behavior in Soil: Imazapyr is weakly bound to soil. Adsorption increases as organic matter and clay content increase. Imazapyr is moderately persistent in soil, but not prone to leaching (Shaner 2014). The half-life of imazapyr ranges from 25 to 145 days, depending on soil type and environmental condition. Microbial degradation is the primary means of dissipation (SERA 2011b; WSSA 2014). Behavior in Water: Imazapyr is rapidly decomposed in water. The half-life in water is three to four days. The presence of light will reduce the half-life by 50 percent (SERA 2011b; WSSA 2014). Toxicological Properties Wildlife: There is little risk to wildlife from the application of either formulation, Polaris or Polaris SP. In studies, Polaris oral LD50 values for both quail and duck were greater than 2,000 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-9 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company mg/kg. Eight-day dietary LD50 values were greater than 5,000 mg/kg. LC50 values from all fish studies were greater than 100 ppm, indicating that imazapyr is practically non-toxic to those species. The material does not bio-accumulate (SERA 2011b; WSSA 2014). Human: Both herbicides have the signal word “caution.” Acute toxicity tests indicate imazapyr has a low mammalian toxicity and presents little risk to humans. In studies, the acute oral LD50 value was greater than 5,000mg/kg and the dermal LD50 was greater than 2,000 mg/kg. There is no evidence of eye or skin irritation and there is little risk from inhalation. The NOAEL was greater than 1,500 mg/kg, suggesting long-term effects are not likely. Imazapyr is not a carcinogen. It does not cause birth defects, mutations, or reproductive harm (SERA 2011b; WSSA 2014). B.1.7 Indaziflam Indaziflam, the active ingredient in Esplanade, is a pre-emergent herbicide with activity on grasses and some difficult-to-control broad leaf weeds. Label uses include use in orchards, grapes, turf, and non-crop, and industrial utility ROWs. While indaziflam is an effective herbicide for the control of weed seedlings, it is not exclusively selective and can adversely affect sensitive terrestrial plant species, including monocots and dicots. For exposure scenarios associated with direct spray (e.g., backpack application), the impact to sensitive species of dicots, represented by soybeans, would be severe, and damage to the vegetation would be apparent. This herbicide is stable when applied to the soil surface. Indaziflam can tolerate up to 200 inches of rainfall and still provide weed control, or less than 10 inches and be equally effective (Kestrel 2020). Mode of Action Indaziflam is a cellulose, bio synthase inhibitor. It is absorbed into the roots and shoots of germinating seedlings preventing root, growth, and development (Kestrel 2020). Environmental Characteristics Behavior in Soil: Indaziflam is persistent in the soil. Average half-life is greater than 150 days. The half-life is shorter in aerobic conditions versus anaerobic conditions. Indaziflam is expected to be moderately mobile to mobile in soil; however, in the field, leaching and runoff is expected to be minimal due to the herbicide binding tightly to the soil components. There is potential for leaching into ground water, which is affected by organic content in the soil. Degradation is primarily due to biotic and soil effects. Photo degradation is minimal making the herbicide stable on the soil without rain (Kestrel 2020). Behavior in Water: Indaziflam is expected to be persistent in aerobic (half-life greater than 200 days) and anaerobic (stable) aquatic environments. However, in clear shallow water, indaziflam is subject to aqueous photolysis, with a measured half-life of less than 5 days (Kestrel 2020). Toxicological Properties Wildlife: Indaziflam is considered non-toxic to wildlife including mallard ducks, insects, and worms (Kestrel 2020). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-10 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Human: Indaziflam is considered a minimal risk pesticide with a low mammalian toxicity, with the “caution” signal word on the label. Acute oral toxicity study results were above 2,000 mg/kg. Four-hour inhalation tests produced an LC50 value of 2.3 mg/L. There is no evidence of skin or eye irritation (Kestrel 2020). Chronic feeding studies in rats and canines produced respective NOAELs of 19 mg/kg/day and 2 mg/kg/day and LOAELs of 185 mg/kg/day and 6 mg/kg/day. While there is potential for reproductive harm at high levels, there is no evidence of mutagenicity or carcinogenicity. Exposure rates in the field are expected to be significantly below the test levels referenced above (Kestrel 2020). B.1.8 Sulfometuron Methyl Sulfometuron methyl, the active ingredient in Oust XP, is a non-selective pre-emergent herbicide with limited post-emergent activity. At lower rates, it has activity on grasses and some broadleaves. Activity on broadleaves increases as the application rate exceeds three ounces. Oust XP has various uses in both non-crop, industrial, and forestry markets (SERA 2004b; WSSA 2014). Mode of Action Oust XP is an amino acid acetolactate synthase (ALS) inhibitor. It is readily absorbed by the plant and translocated via both xylem and phloem. It accumulates in the meristematic region of the susceptible plant. Growth is restricted within hours. Symptoms include chlorosis and necrosis. A reddish or purple color is evident in some plants. There is considerable documentation on resistance to Oust XP by certain weeds. Tolerant plants metabolize the herbicide. Resistant plants have altered binding sites that prevent herbicidal activity from occurring (SERA 2004b; WSSA 2014). Environmental Characteristics Behavior in Soil: Sulfometuron bonds moderately to soil. It has a half-life of 20 to 28 days. Temperature and pH have a significant effect on its persistence and mobility in soil; higher pH and cooler soil can significantly increase its persistence. There is a greater mobility potential in soil with a high pH and lower organic matter (SERA 2004b; WSSA 2014). Behavior in Water: Little is reported on sulfometuron methyl in water. However, data on water sediment suggest light and aerobic conditions favor breakdown and a shorter half-life (SERA 2004b; WSSA 2014). Toxicological Properties Wildlife: Oust XP is practically non-toxic to wildlife. In studies, the LC50 values for quail and duck were above 5,000 ppm. The LC50 values for several aquatic organisms were listed as greater than 12.5 ppm making the herbicide slightly toxic to aquatic organisms. Note, these concentrations for aquatic organisms must be maintained for 48 to 96 hours in static water (SERA 2004b; WSSA 2014). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-11 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Human: Oust XP is a Category III herbicide (slightly toxic or relative non-toxic) with a “caution” signal word. Oust XP is practically non-toxic to humans. In studies, the oral LD50 was greater than 5000mg/Kg and the dermal LD50 value was greater than 8000 mg/kg. Risk from long term exposure is minimal. Chronic studies produced a NOAEL of 50 ppm for rats and 200 ppm for dogs. Oust XP is not considered a teratogen, carcinogen, mutagen, or reproductive toxin (SERA 2004b; WSSA 2014). B.1.9 Triclopyr Triclopyr is a broadleaf selective post-emergent herbicide used for control of annual and perennial broadleaf weeds and brush in crop and non-crop sites. It has limited herbicidal activity on certain warm season grass species. There are two distinctly different formulations of triclopyr used commercially as herbicides: triethylamine salt (TEA) and butoxyethyl ester (BEE). Vastlan (choline) and Garlon 3A (TEA formulation) can be used for terrestrial and aquatic applications. The ester formulation (Garlon 4 [BEE]) is labeled for terrestrial and riparian application only. The program will not include an assessment of the choline formulation. Mode of Action Triclopyr is an auxin-mimicking herbicide that affects cell division and expansion. It is transported through the phloem and xylem of the plant and accumulates in the meristematic tissue of the shoots of susceptible plants, accelerating growth resulting in ruptured cell walls. Triclopyr is rapidly metabolized in the plant, more so in tolerant plants than non-tolerant plants. Eighty-five percent of a dose is metabolized within three days. Susceptible plants cease growth soon after applications over a period of one to three weeks. Plants turn from green to reddish-yellow to brown. Epinasty at the growing point is evident. Newer growth becomes mushy and necrotic (SERA 2016b; 2011c; WSSA 2014) Environmental Characteristics Behavior in soil: Triclopyr is not tightly adsorbed to the soil, which can be affected by soil organic matter and clay content. The soil half-life is 30 days, depending on soil moisture. While there is potential for soil movement, studies indicate leaching and/or lateral movement in soil is unlikely (SERA 2016b; SERA 2011c; WSSA 2014). Behavior in water: Triclopyr rapidly degrades in water, mostly by photo degradation, with a half- life of six hours in most conditions (SERA 2016b; SERA 2011c; WSSA 2014). Toxicological Properties Wildlife: Both acute and chronic toxicity studies indicate the ester and amine formulations are practically non-toxic to terrestrial wildlife. The amine is also considered practically non-toxic to fish and aquatic organisms with LC50 values ranging from 600 to 891 mg/L for fish. The ester formulation, Garlon 4, is less compatible with aquatic and amphibian species. Garlon 4 is considered moderately to highly toxic to aquatic wildlife. LC50 values for fish ranged from 0.36 to 1.7 mg/L (SERA 2016b; SERA 2011c; WSSA 2014). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-12 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Human: Garlon 3A, a Category I herbicide has the signal word “danger.” The “danger” signal word is due to the potential for severe eye irritation from contact with the formulated concentrate. Garlon 4 is a Category III herbicide (slightly toxic or relatively non-toxic), with the signal word “caution.” Toxicities are similar between for both formulations. The potential for skin or eye irritation is significantly less with the ester formulation. In studies, the acute toxicity of Garlon 3A was low with LD50 values above 2,500 mg/kg for oral ingestion. Potential acute toxicity for dermal absorption and inhalation was slight to moderate. Prolonged exposure to concentrated Garlon 3A can result in skin and/or severe eye irritation. Chronic exposure studies, both 90-day and 22-month, revealed a NOAEL of 5 mg/kg per day. A decrease in body weight and some impact on kidneys were observed. The studies revealed no evidence of mutations, birth defects, tumors, or reproductive impacts. The toxicological profile of Garlon 4 is similar to that of Garlon 3A. Garlon 4 is a Category III herbicide with a “caution” signal word on the label. The acute toxicity of Garlon 4 is greater than Garlon 3A but still considered low with the oral LD50 value at 1,581 mg/kg. B.1.10 Surfactants Surfactants, such as Competitor, reduce surface tension and subsequently spread the surfactant across the leaf surface. There is a moderate amount of information about surfactants. The U.S. Department of Agriculture (USDA) Forest Service completed an extensive risk assessment for the silicone (R-11) class of surfactants (Bakke 2003). Measures of both acute and chronic toxicity classify this compound as practically non-toxic. Competitor is a Class IV cottonseed oil diluent and surfactant (relatively non-toxic). No risk assessments are available for Competitor, and little data are available on the toxicity of this compound. LD50 values were greater than 5,000 mg/kg (Wilbur-Ellis Co. 2005; Bakke 2007, 2003). B.1.11 Colorants Spray pattern indicators are dyes or colorants that identify where herbicide has been applied. There are several formulations available for use. Choices depend on many factors including spray formulation, treatment site, and target vegetation. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-13 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company B.2 Risk Assessment The USDA Forest Service has developed a process for analyzing the risk associated with pesticides. Potential effects of the application of each pesticide listed in Table B-1 to wildlife, non- target botanical resources, and humans were modeled using the Syracuse Environmental Research Associates, Inc. (SERA), risk assessment worksheets (WorksheetMaker, Version 6.02.20) (SERA 1997, 2004a–b, 2007, 2009, 2011a–c, 2012, 2014, 2016a–b; Tellevate 2020). Indaziflam is a stand alone workbook created using version 6.02.18 prepared by Colon and Burris (May 2019). The SERA analyses are intended to assess the risk to flora, fauna, and the environment posed by pesticides based on various exposure scenarios to inform the development of mitigation measures. No SERA risk assessments are available for oil-based surfactants or non-ionic surfactants. To characterize the risk of each pesticide, the SERA analyzes the toxicity of each pesticide and then assesses the potential for exposure and the likely response to that exposure. Exposure scenarios for representative wildlife groups were based on direct spray of small mammals and birds, mammals, and birds eating vegetation or insects that were sprayed with the pesticide, and predatory birds and/or mammals eating fish or small mammals exposed to the pesticide. Worst- case exposure scenarios for fish or amphibians were based on exposure to water contaminated by the pesticide. Acute exposure is a single-event or short-term exposure to a pesticide. Chronic exposure is repetitive or long- term exposure to a pesticide. Project-specific risk assessments were prepared based on the SERA spreadsheets. These assessments identify a hazard quotient (HQ) for each pesticide based on application rates, dose estimate, species biology, and environmental conditions. The HQ is the ratio of the estimated level of exposure to the highest reference dose where no adverse effects are expected (i.e., the toxicity value) or another index of acceptable exposure. The upper confidence level for exposure estimates was used to calculate the HQ for each receptor species. The HQ is used to measure risk; an HQ equal to or below 1 is below the level of concern. Values above 1 means there is a potential risk to the species by unmitigated use of the chemicals at given rate for the given scenario HQ above 1 does not mean that adverse effects will occur (USEPA 2023). An increase in the HQ value implies a greater potential risk. The risk assessments assumed specific application type/methods at the recommended label rates and considers potential exposure (high, moderate, and low) without implementation of Best Management Practices (BMPs) included in Appendix C of the Strategy. Such, exposure scenarios are conservative estimates unlikely to be realized during implementation of the proposed Project. For the Strategy, application rates based on selective, directed hand spray, or limited broadcast spray would be much lower and buffers around sensitive resources would be implemented. Exact field estimates of exposure are difficult to calculate because the amount and concentration of the pesticide ingested or absorbed by receptor species can be affected by a multitude of environmental variables (i.e., precipitation, foraging behavior of the receptor species, time since application, etc.). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-14 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company B.2.1 Wildlife Aquatic and terrestrial wildlife could be exposed to pesticides if application in the Control Area occurs in or near suitable habitat. Animals could ingest prey (e.g., fish, small mammals, insects) contaminated with pesticides via direct application, contact with recently sprayed vegetation, or consumption of contaminated vegetation or water contaminated by a pesticide leak or spill. Additionally, if a leak or spill occurs, fish, amphibians, or aquatic reptiles could experience acute or chronic exposure to contaminated water in aquatic habitats. Pesticide exposure scenarios, including exposure estimates and HQs, for aquatic and terrestrial wildlife from proposed Project pesticide applications are provided in Tables B-2 to B-8. B.2.1.1 Amphibians Amphibians within the Control Area (as defined in the Strategy) could be directly exposed to pesticides if pesticides were applied near suitable habitat or if amphibians ingest prey contaminated with pesticides. Pesticide leaks or spills within the Control Area could also directly expose amphibians to pesticides. This risk assessment was based on acute and chronic exposure scenarios where amphibians were exposed to pesticide concentrations that would result from an accidental spill. Considering the exposure scenarios, fish are considered an acceptable surrogate for amphibian hazard assessments when amphibian data were not available for a specific pesticide. The results of the risk assessment for amphibians indicated that HQ of five of the ten pesticides proposed for use exceeded the level of concern for acute exposure. The pesticides exceeding the level of concern are fluazifop-P-butyl, indaziflam, sulfometuron methyl, triclopyr TEA and BEE (Table B-2). Therefore, direct toxicological effects on amphibians from acute exposure to these 5 herbicides is possible, at the highest exposure levels (Table B-3). BMPs included in Attachment C of the Strategy, including application timing, spill response measures, targeted application method, and appropriate buffers, will mitigate and avoid the potential risk to amphibians associated with all the pesticides (acute or chronic exposure). This includes risks associated with those pesticides identified in table B-2 that exceed a level of concern. Table B-2. Hazard Quotients for accidental acute exposure scenarios for amphibians (fish as surrogate for other amphibians). Chemical Name Exposure Scenarioa Exposure Estimateb (mg/L) Toxicity Value (mg/L) Hazard Quotient Ratingc Concern? Aminopyralid olerant species 0.666 95.2 0.007 No sensitive 0.424 32 0.01 No 1.14 103 0.01 No -P-butyl 1.5 0.203 7 Yes Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-15 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Chemical Name Exposure Scenarioa Exposure Estimateb (mg/L) Toxicity Value (mg/L) Hazard Quotient Ratingc Concern? Glyphosate 12.11 340 0.04 No 9.084 10.4 0.9 No 0.59 0.464 1.3 Yes 0.833 0.38 2 Yes 0.605 0.1 6 Yes TEA) 0.605 0.1 6 Yes Notes: mg/L = milligram per liter TEA = triethylamine BEE = Butoxyethyl ester Fish are considered an acceptable surrogate for amphibians in toxicity tests. Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It takes into account the rate, the vel was Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An Table B-3. Hazard quotients for chronic exposure scenarios for amphibians (fish as a surrogate for other amphibians). Chemical Name Exposure Scenarioa Exposure Estimateb (mg/L) Toxicity Value (mg/L) Hazard Quotient Ratingc Concern? Aminopyralid 0.029 1.36 0.02 No 0.007 32 0.0004 No 0.002 10 0.0002 No -P-butyl 0.021 0.2 0.1 No 0.012 1.8 0.006 No 0.06 4 0.02 No 0.00016 0.464 .0004 No Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-16 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Chemical Name Exposure Scenarioa Exposure Estimateb (mg/L) Toxicity Value (mg/L) Hazard Quotient Ratingc Concern? Sulfometuron methyl 0.00001 0.00075 0.01 No 0.00014 0.019 0.007 No 0.12 7.4 0.02 No mg/L = milligram per liter TEA = triethylamine BEE = Butoxyethyl ester Fish are considered an acceptable surrogate for amphibians in toxicity tests. Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It takes into account the rate, the vel was Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An B.2.1.2 Aquatic Reptiles Aquatic reptiles could be directly exposed to pesticides if these were applied near suitable habitat or if aquatic reptiles ingested prey contaminated with pesticides. Pesticide leaks or spills within the Control Area could also directly expose aquatic reptiles to pesticides. The risk assessment for aquatic reptiles was based on acute and chronic exposure scenarios involving the consumption of contaminated fish by a fish-eating bird. Fish-eating birds are an acceptable surrogate for aquatic reptiles in risk assessments. The results of the risk assessment for fish-eating birds showed that the HQ does not exceed the level of concern for acute or chronic exposure to any of the pesticides proposed for use (Tables B-4 and B-5). It is unlikely that chronic or acute exposure would occur from eating fish. Constant exposure to contaminated water in a pond or body of water that is habitat could occur; however, the exposure time for aquatic reptiles is not easily estimated. Infrequent applications of pesticides in specific locations (i.e., once or twice per year), mobility of aquatic reptile species, application timing and methodology, appropriate buffers, and other BMPs included Attachment C would reduce the potential for significant acute or chronic exposure of aquatic reptiles to pesticides used for the proposed invasive weed management activities. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-17 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Table B-4. Hazard quotients for accidental acute exposure scenario for fish-eating bird (surrogate for reptiles) consuming contaminated fish. Chemical Name Exposure Estimatea (mg/L) Toxicity Value (mg/L) Hazard Quotient Ratingb Exceeds Level of Concern? Aminopyralid 0.187 14 0.02 No 0.119 300 0.0004 No 0.318 670 0.0005 No -P-butyl 174 1069 0.2 No 1.76 1500 0.001 No 1.27 2510 0.003 No 7.61 2000 0.004 No 0.817 312 0.005 No 0.141 126 0.001 No 2.82 126 0.02 No HQ equal to or below 1 is below the level of concern. mg/L = milligram per liter TEA = triethylamine BEE = Butoxyethyl ester a Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It takes into ides the vel was used. b Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. A Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-18 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Table B-5. Hazard quotients for chronic exposure scenario for a fish-eating bird (surrogate for reptiles) consuming contaminated fish. Chemical Name Exposure Estimatea (mg/L) Toxicity Value (mg/L) Hazard Quotient Ratingb Exceeds Level of Concern? Aminopyralid 0.00801 184 0.00004 No 0.00196 24.5 0.00008 No 0.0007 15 0.00005 No -P-butyl 2.38 3.3 0.7 No 0.0017 58 0.00003 No 0.00841 610 0.00001 No 0.00209 6.7 0.0003 No 0.000007 2 0.000005 No 0.000033 7.5 0.000004 No 0.0279 7.5 0.004 No mg/L = milligram per liter triethylamine Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It takes into account the rate, the vel was Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An B.2.1.3 Raptors Raptors (non-piscivorous raptors) can be directly exposed to pesticides if they were to ingest prey (i.e., small mammals) contaminated with a pesticide. The risk assessment was based on an acute exposure scenario involving the consumption of a small mammal after it was sprayed with pesticide or 100 percent of its diet was pesticide-contaminated vegetation. It would be highly unlikely that the entirety of a small mammal would be sprayed or that 100 percent of the small mammal’s diet would be contaminated vegetation because of proposed application methods and BMPs. A chronic exposure scenario does not exist for meat-eating birds; however, Strategy would not result in chronic exposure because an area would be treated only once or twice per year. The results of the risk assessment for raptors showed that the HQ does not exceed the level of concern for acute exposure to any of the pesticides proposed for use (Table B-6). Effects on raptors from the use of pesticides would be further minimized through implementation of BMPs Appendix C of the Strategy, including application timing, application method, and appropriate buffers. Hand application and low-boom application along Project roads, trails, and around Project facilities are not expected to result in direct spray of chemicals onto small mammals (raptor prey). Therefore, the risk of direct toxicological effects on raptors as a result of the pesticide use for treatment of Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-19 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company invasive weeds as described in the Strategy would be very low, and any direct exposure to pesticides would be minimal. Table B-6. Hazard quotients for acute non-accidental exposure scenario of a meat-eating bird consuming a small mammal after direct spray with pesticide. Chemical Name Exposure Estimate (mg/kg)2 Toxicity Value (mg/kg) Hazard Quotient Rating Exceeds Level of Concern? Aminopyralid 0.604 14 0.04 No 0.384 300 0.001 No 1.04 670 0.003 No -P-butyl 1.37 1,069 0.001 No 11 1500 0.007 No 2.74 2,510 0.001 No 0.357 2,000 0.0004 No 0.768 312 0.002 No 11 126 0.09 No 11 126 0.09 No mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It considers the rate, the target s Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An B.2.1.4 Bat Populations Special-status bat populations found in the Control Area are unlikely to be directly sprayed with pesticide, because they would not roost in areas that would be treated. Bats primarily obtain their nutrition and water needs from insect prey, although some bats will drink from open water sources such as lakes and ponds. Use of pesticides could result in acute and chronic effects on special- status bats if bats consume insect prey contaminated by pesticides in the Control Area. This potential effect would be minimal because most bats consume aerial insects, which can fly considerable distances, over a broad landscape. Thus, their feeding is not concentrated over the Control Area thereby decreasing their exposure. The risk assessment was based on an acute exposure scenario involving the consumption of insects after being directly sprayed with pesticide. The potential for consumption of contaminated insects would be reduced through the implementation of BMPs in the Strategy (Appendix C). In addition, pesticides would not be applied at night when bats are foraging, which would further reduce potential effects. A chronic exposure scenario does not exist for insect-eating mammals; however, Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-20 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company the invasive weed treatments would not result in chronic exposure to pesticides because an area would be treated only once or twice per year. The results of the risk assessment for insect-eating mammals showed that the HQ does not exceed the level of concern for acute exposure to any of the pesticides proposed for use (Table B-7). Therefore, the risk of direct toxicological effects on bat species as a result of the invasive weed treatments would be very low, and any direct exposure to pesticide would be minimal. Table B-7. Hazard quotients for non-accidental acute exposure scenario of an insect- eating mammal consuming insects contaminated with pesticide: Chemical Name Exposure scenario Exposure Estimatea (mg/kg) (mg/kg) Hazard Quotient Ratingb Concern? Aminopyralid 10.8 104 0. 1 No 6.88 75 0.09 No 18.7 75 0.2 No -P-butyl 24.6 43 0.03 No 196 500 0.4 No 49.1 738 0.07 No 6.39 50 0.1 No 13.8 87 0.2 No 196 440 0.4 No 196 440 0.4 No TEA = triethylamine BEE = Butoxyethyl ester Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It considers the rate, the target s Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An B.2.1.5 Carnivorous Mammals Carnivorous mammals may be indirectly exposed to pesticides if they were to ingest prey (small mammals) contaminated with pesticide. These species would be unlikely to be directly sprayed Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-21 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company with pesticide because these mostly nocturnal species would not be active during treatment activities. The risk assessment was based on an acute exposure scenario involving the consumption of a small mammal after it was sprayed with pesticide. The scenario that the entirety of a small mammal would be sprayed would be highly unlikely. A chronic exposure scenario does exist for carnivorous mammals; however, the invasive weed treatments would not result in chronic exposure to pesticides, because an area would be treated only once or twice per year. The results of the risk assessment for meat-eating mammals showed that the HQ does not exceed the level of concern for acute or chronic exposure to any of the pesticides proposed for use (Table B-8). Implementation of methods and measures described in the Appendix C of the Strategy would further minimize the potential for effects on fisher resulting from use of pesticides. Therefore, the risk of direct toxicological effects on carnivorous mammals due to the invasive weed treatments would be low, and any direct exposure to pesticides would be minimal. Table B-8. Hazard quotients for non-accidental acute exposure scenario of a carnivorous mammala consuming a small mammal after direct spray with pesticide. Chemical Name Exposure Estimateb (mg/kg) Toxicity Value (mg/kg) Hazard Quotient Ratingc Exceeds Level of Concern? Aminopyralid 0.508 104 0.005 No 0.323 75 0.004 No 0.877 75 0.02 No -P-butyl 1.15 43 0.03 No 9.23 500 0.02 No 2.31 250 0.009 No 0.300 50 0.006 No 0.646 87 0.007 No 9.23 20 0.5 No 9.23 20 0.5 No TEA = triethylamine BEE = Butoxyethyl ester Canid toxicity data were used to develop exposure estimates for mammals consuming small mammals. Exposure Estimate is an estimate of exposure to a specific pesticide from an application. It considers the rate, the target s Hazard Quotient (HQ) is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An B.2.2 Sensitive Plants Non-target sensitive plants could be adversely affected by pesticides contacting the leaves directly, from via drift or if the plant uptakes the pesticide through the soil. Risk assessments for drift suggested that application of the proposed pesticides at the highest rate could affect non-target sensitive species up to 900 feet from the application site (Table B-12). The most significant adverse effects would be within 100 feet of the application site for both pre- and post-emergent pesticides. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-22 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company These risk assessments assumed no mitigation or drift prevention measures would be taken during application. Pesticide exposure scenarios, including exposure estimates and hazard quotients, for terrestrial plants from invasive weed pesticide applications are provided in Table B-9. BMPs included in Appendix C of the Strategy (e.g., targeted application methods using low- volume, low-pressure backpack sprayers; implementation of no-spray buffers around aquatic habitat; and conducting application only during periods of dry weather and low wind speeds) would reduce the risk of drift. Although the use of several of the pesticides proposed could affect non-target sensitive plant species, site conditions (sandy loam soils, highly vegetated areas) and treatment methods (i.e., spot foliar treatment using a backpack applicator, basal stem application, cut-stump application, frill and squirt, and no large-scale broadcast applications) would reduce the potential for exposure from pesticide runoff and drift. Specific to basal applications of some pesticides, drift is limited to less than 10 feet. This is supported by 20 years of research and monitoring by the USDA Forest Service. For invasive weed treatments under the Plan and Strategy, PG&E would implement comprehensive surveys for special status plants every 10 years for the term of the license in the Control Area to maintain current knowledge of sensitive plant occurrences. Where sensitive plants occur, PG&E would implement BMPs listed in Attachment C of the Strategy. With these measures in place, exposure of sensitive plant species to pesticides would be avoided or substantially reduced. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-23 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Table B-9. Summary of exposure assessment and risk characterization for sensitive terrestrial plants from drift after backpack directed foliar application. Pesticide Aminopyralid Chlorsulfuron Clopyralid Fluazifop Glyphosate Imazapyr Indaziflam Sulfometuron methyl Triclopyr (BEE) Triclopyr (TEA) Toxicity Value 0.0002 lbs/ac 0.0000088 lbs/ac 0.0005 lbs/ac 0.0007 lbs/ac 0.0013 lbs/ac 0.000064 lbs/ac 0.000375 lb./ac 0.000024 lb./ac 0.0028 lbs./ac 0.0028 lbs/ac Distance from (feet) Effective Rate (lbs a.e./ac)HQ Effective Rate (lbs a.e./ac) HQ Effective Rate (lbs a.e./ac) HQ Effective Rate HQ Effective Rate (lbs a.e./ac)HQ Effective Rate (lbs a.e./ac)HQ Effective Rate (lbs a.e./ac)HQ Effective Rate HQ Effective Rate (lbs a.e./ac)HQ Effective Rate (lbs a.e./ac) HQ 0 0.11 550 0.07 87,500 0.19 3,800 0.25 36 2 1,538 0.5 7,813 0.065 173 0.14 5833 2 714 2 714 25 0.0009152 5 0.00058 728 0.0015808 3 0.00315 0.5 0.01664 13 0.00416 65 0.0005 1.4 0.001161 49 0.01664 6 0.01664 6 50 0.0004763 2 0.0003031 379 0.0008227 1.6 0.00185 0.3 0.00866 7 0.002165 34 0.0003 0.8 0.00061 25 0.00866 3 0.00866 3 100 0.0002651 1.3 0.0001687 211 0.0004579 0.9 0.0011 0.2 0.00482 4 0.001205 19 0.00016 0.4 0.000338 14 0.00482 1.7 0.00482 1.7 300 0.5 0..00006587 82 0.00017879 0.4 0.000475 0.07 0.001882 1.4 0.0004705 7 0.000061 0.2 0.000132 5 0.001882 .7 0.001882 0.7 500 0.3 0.00004053 51 0.00011001 0.2 0.0003 0.04 0.001158 0.9 0.0002895 5 0.000038 0.1 0.0000811 3 0.001158 .4 0.001158 0.4 900 0.2 0.00002184 27 0.00005928 0.1 0.000175 0.03 0.000624 0.5 0.000156 2 0.000021 0.05 0.0000437 2 0.000624 .2 0.000624 0.2 Notes: HQ = hazard quotient is a mathematical calculation that numerically expresses relative risk from exposure to the pesticide. An HQ equal to or below 1 is below the level of concern; bold values exceed the level of concern. lbs a.e./ac = pounds acid equivalent per acre TEA = triethylamine BEE = Butoxyethyl ester Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment E E-24 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company This Page Intentionally Left Blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-25 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company B.2.3 Worker and General Public This exposure assessment examined the potential health effects to two groups of people that would most likely be exposed to the pesticides proposed for use in the Project: workers and members of the public. Workers include applicators directly involved in the application of pesticides. The public includes other personnel, visitors, or nearby residents who could be exposed through pesticide drift, contact with sprayed vegetation, by drinking water that contains pesticide residue, or by eating contaminated vegetation (such as berries or foliage), game, or fish. In these analyses, data were evaluated for three different exposure scenarios: typical, lower, and upper. The upper level represents a conservative estimate of a worst-case scenario resulting from the highest application rate, lowest dilution rate, and largest number of acres treated per day. This approach was used to encompass as broadly as possible the range of potential exposures. B.2.3.1 Worker Exposure Pesticide applicators (workers) are the individuals who are most likely to be exposed to a pesticide during the application process. Exposure rates for workers were calculated using several factors, including proposed application rates, dilution rates, estimated hours worked per day, number of acres treated per hour, and human dermal absorption rates. Worker exposure rates are expressed in units of mg/kg of body weight per pound of chemical handled. Tables B-10 and B-11 present the exposure rates calculated for a scenario involving general exposure to the pesticides listed in Table B-10 and the associated risk to workers. This scenario represents the type of exposure that might be expected to occur over the course of each workday during a prolonged application period (chronic exposure). Typical occupational exposures may involve multiple routes of exposure (i.e., oral, dermal, and inhalation); nonetheless, dermal exposure is generally the predominant route for pesticide applicators. Wearing Contaminated Gloves: Exposure scenarios involving direct contact with solutions of the chemical were characterized by wearing contaminated gloves for one minute and one hour. For these exposure scenarios, the key element was the assumption that wearing gloves contaminated with a chemical solution was equivalent to immersing the hands in a solution. In either case, the concentration of the chemical in solution that is in contact with the surface of the skin and the resulting dermal absorption rate were essentially constant. Contamination Directly on Skin: Exposure scenarios involving chemical spills on to the skin were characterized by a spill on to the lower legs as well as a spill on to the hands without personal protective equipment. In these scenarios, it was assumed that a solution of the chemical was spilled onto a given surface area of skin and that a certain amount of the chemical adhered to the skin. Risk calculations and HQs consider the projected exposure and the toxicity of each pesticide. Four of the ten pesticides present an elevated risk from the long-term use: fluazifop, indaziflam and both formulations of triclopyr at the highest exposure levels. There is also risk from exposure Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-26 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company to triclopyr BEE considering the central exposure scenarios (Table B-10). These scenarios included daily application of each pesticide and the absence of or considerable contamination of personal protective equipment. Extended exposure to contaminated gloves elevates the risk from application/exposure of triclopyr BEE (Table B-11). PG&E anticipates that this pesticide would be used infrequently. Under the Strategy, application duration would likely be two to three weeks over an entire year with one-week segments at a time. Implementing the BMPs included in Attachment C of the Strategy would minimize potential for worker exposure. The BMPs include all pesticides administered under the supervision of a licensed Pest Control Advisor (PCA) in accordance with a Pest Control Recommendation (PCR), as required by the California Department of Pesticide Regulation (CDPR) and will be applied in accordance with label instructions. In addition, standard personal protection equipment, such as disposable gloves and frequent hand washing will further mitigate exposure to workers. Table B-10. Hazard quotients for backpack applicators from general (non-accidental) long-term exposures. Chemical Toxicity Value (mg/kg) Hazard Quotient (HQ) Central Application Rate Lower Application Rate Upper Application Rate Aminopyralid 0.5 3E-03 1E-04 2E-02 Chlorsulfuron 0.05 6E-04 6E-05 1E-02 Clopyralid 0.15 2E-02 6E-04 0.1 Fluazifop-p-butyl 0.017 0.3 1E-02 2 Glyphosate 2 1E-02 5E-04 8E-02 Imazapyr 2.5 3E-03 9E-05 2E-02 Indaziflam 0.02 0.1 1E-02 1.3 Sulfometuron methyl 0.02 0.1 3E-03 0.6 Triclopyr (BEE) 0.05 1.0 5E-02 12 Triclopyr(TEA) 0.05 0.5 2E-02 3 Note: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-27 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Table B-11. Hazard quotient for pesticides (backpack applicators) from accidental/ incidental exposures to lower and upper application rates. Chemical Hazard Quotient (HQ) Value (mg/kg) Contaminated Gloves (1 minute) Contaminated Gloves (1 hour) Spill on Hands (1 hour) Spill on Lower Legs (1 hour) Lower Upper Lower Upper Lower Upper Lower Upper Aminopyralid 1 2E-08 7E-07 1E-06 4E-05 4E-06 4E-05 1E-05 5E-04 Chlorsulfuron 0.75 7E-08 1E-06 4E-06 6E-05 2E-06 6E-05 4E-06 2E-04 Clopyralid 0.75 1E-07 3E-06 6E-06 2E-04 2E-05 6E-04 4E-04 1E-03 Fluazifop-p- butyl 1 7E-07 2E-05 4E-05 1E-03 2E-05 8E-04 5E-05 2E-03 Glyphosate 2 4E-07 1E-05 2E-05 6E-04 6E-05 8E-04 1E-04 2E-03 Imazapyr 2.5 1E-05 1E-04 8E-04 6E-03 1E-04 1E-03 2E-04 3E-03 Indaziflam 0.5 2E-04 8E-04 1E-02 5E-02 9E-05 6E-04 2E-04 1E-03 Sulfometuron methyl 0.87 3E-07 3E-06 2E-05 2E-04 4E-06 1E-04 9E-06 3E-04 Triclopyr (BEE) 1 1E-02 8E-02 0.8 5 1E-03 1E-02 3E-03 3E-02 Triclopyr (TEA/) 1 2E-05 2E-04 1E-03 1E-02 3E-04 4E-03 7E-04 1E-02 Note: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester B.2.3.2 General Public Exposure The general public has the potential for acute and chronic exposure to pesticides applied per the Strategy. The acute exposure scenarios are primarily accidental exposures, and it was assumed that an individual was exposed to the compound either during or shortly after its application. Specific scenarios were developed for direct spray, dermal contact with contaminated vegetation, and consumption of contaminated fruit, vegetation, water, and fish. Most of these scenarios should be regarded as extreme; some to the point of limited plausibility (SERA 2007b). The longer-term or chronic exposure scenarios parallel the acute exposure scenarios for the consumption of contaminated fruit, vegetation, water, and fish, but were based on estimated levels of exposure for longer periods after application. Each of these scenarios is described below. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-28 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Direct Spray: Direct sprays involving ground applications were modeled in a manner similar to accidental spills for workers. It was assumed that the individual was sprayed with a solution containing the compound and that an amount of the compound remained on the skin and was absorbed (SERA 2007b). It was also assumed that during a ground application, a naked child was sprayed directly with the pesticide and 100 percent of the body was exposed to the pesticide. This is an extremely conservative exposure scenario that represents the upper limits of plausible exposure. An additional set of scenarios included a young woman who was accidentally sprayed over the feet and legs. For each of these scenarios, some standard assumptions were made regarding the surface area of the skin and body weight. Dermal Exposure from Contaminated Vegetation: In this exposure scenario, it was assumed that the pesticide was sprayed at a given application rate and that an individual came in contact with sprayed vegetation or other contaminated surfaces at some period after the spray operation. For these exposure scenarios, some estimates of foliar residue and the rate of transfer from the contaminated vegetation to the surface of the skin must be available. When no such data were directly available for these pesticides, the estimation methods of Durkin et al. (SERA 2007b) were used. Other estimates used in this exposure scenario involved estimates of body weight, skin surface area, and first-order dermal absorption rates. Contaminated Water: Water could be contaminated from runoff as a result of leaching from contaminated soil, a direct spill, or unintentional contamination from applications. For this risk assessment, the two types of estimates made for the concentration of these pesticides in ambient water were acute/accidental exposure from an accidental spill and longer-term exposure to the pesticides in ambient water that could be associated with the typical application of these compounds to a 100-acre treatment area. The acute exposure scenario assumed that a young child (2- to 3-years old) consumed one liter (L) of contaminated water (a range of 0.6 to 1.5 L) shortly after an accidental spill of 30 gallons of a field solution into a pond with an average depth of 1 meter and a surface area of 1,000 square meters or about one-quarter acre. Because this scenario assumed that exposure occurred shortly after the spill, no dissipation or degradation of the pesticide was considered. This would be an extremely conservative scenario. The actual concentrations in the water would depend heavily on the amount of compound spilled, the size of the water body into which it was spilled, the time at which water consumption occurred relative to the time of the spill, and the amount of contaminated water that was consumed. It is also unlikely that Project reservoirs would be the water body receiving any pesticides in the proposed Project. Flowing streams would be the more likely recipients, so dilution would occur. There are some scenarios which presented an elevated risk to the public, primarily with potential water contamination with the triclopyr (TEA) formulation (Table B-14). The acute scenarios involved consumption of contaminated water by a child. Considering the general public, there is risk from the consumption of fruit and or vegetation immediately following treatment). All formulations of triclopyr, glyphosate present a significant risk at the central and upper levels of potential exposure. Potential scenarios include consumption of blackberries immediately following application of Garlon or Roundup or Native American gathering species used for basket weaving that could result in contamination. Chronic exposure scenarios of the two triclopyr Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-29 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company formulations, fluazifop, indaziflam and sulfometuron methyl, resulted in elevated risk from the continual consumption of contaminated fruit and vegetation (chronic exposure) from an area (Table B-16). Sulfometuron and indaziflam are pre-emergent compound and would be applied to areas that are already bare ground and free of vegetation. If vegetation did exist, it would most likely be annual grasses and forbs. Should this treatment site be in proximity to perennial shrubs or woody species, soil uptake in any appreciable amount would be unlikely. Implementation of measures included in Appendix C of the Strategy would minimize potential for public exposure, including buffers/avoidance of riparian areas and aquatic habitats and application timing (treating pre-flower to post-fruit drop). In addition, PG&E would install signage in areas where pesticides would be used prior to treatment that will communicate information regarding the pesticide being used, concentrations, when the treatment will occur, and contact information. Last, post-emergent treatments are expected to occur infrequently—one or two times annually to a treatment site. Implementation of these measures would minimize potential risks of the proposed use of pesticides to the general public. Table B-12. Hazard quotient for the general public – acute: direct spray scenario. Chemical Hazard Quotient (HQ) Toxicity Value (mg/kg) Child (whole body) Woman (feet and lower legs) Central Application Rate Lower Applicat Rate Upper Applicat Rate Central Applicat Rate Lower Applicat Rate Upper Applicat Rate Aminopyralid 1 1E-03 2E-04 8E-03 1E-04 2E-05 8E-04 Chlorsulfuron 0.75 4E-04 6E-05 2E-03 4E-05 6E-06 2E-04 Clopyralid 0.75 3E-03 6E-04 2E-02 3E-04 6E-05 2E-03 Fluazifop-P-butyl 0.43 3E-02 8E-03 0.1 3E-03 9E-04 1E-02 Indaziflam 0.5 1E-02 4E-03 3E-02 9E-04 4E-04 2E-03 Sulfometuron methyl 0.87 8E-04 1E-04 4E-03 8E-05 1E-05 5E-04 Triclopyr (TEA)/ a 1 4E-02 1E-02 0.2 8E-02 2E-02 0.3 Notes: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester a Toxicity value for direct spray for women was 0.05. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-30 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Table B-13. Hazard quotient for the public (adult female) – contact with vegetation sprayed with pesticides. Chemical Hazard Quotient (HQ) Toxicity Value (mg/kg) Typical Application Rate Lower Application Rate Upper Aminopyralid 1 3E-04 7E-05 2E-03 Chlorsulfuron 0.75 3E-05 6E-06 2E-04 Clopyralid 0.75 2E-04 5E-05 1E-03 Fluazifop-P-butyl 0.43 3E-03 1E-03 8E-03 Glyphosate 2 1E-03 3E-04 3E-03 Imazapyr 2.5 5E-04 2E-04 1E-03 Indaziflam 0.05 2E-02 1E-03 0.2 Sulfometuron methyl 0.87 3E-02 2E-03 0.2 Triclopyr (BEE) 0.05 0.3 0.1 0.8 Triclopyr (TEA) 0.05 9E-02 3E-02 0.3 Note: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester Table B-14. Hazard quotient for the public - drinking water contaminated by pesticides. Chemical Hazard Quotient (HQ) Acute-Spill Scenario (child) Chronic-Spill Scenario (adult male) Toxicity Value (mg/kg)Central Lower Upper Toxicity Value (mg/kg) Central Lower Upper Aminopyralid 1 2E-02 2E-03 8E-01 0.5 3E-04 4E-06 2E-03 Chlorsulfuron 0.75 2E-02 2E-03 6E-02 0.05 4E-04 3E-05 5E-03 Clopyralid 0.75 4E-02 4E-03 0.2 0.15 3E-04 3E-05 6E-04 Fluazifop-P- butyl 0.43 1E-01 1E-02 0.4 0.0063 9E-03 6E-04 0.1 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-31 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Chemical Hazard Quotient (HQ) Acute-Spill Scenario (child) Chronic-Spill Scenario (adult male) Toxicity Value (mg/kg)Central Lower Upper Toxicity Value (mg/kg) Central Lower Upper Indaziflam 0.5 7E-03 4E-04 3E-02 0.02 3E-05 2E-08 2E-04 Sulfometuron methyl 0.87 3E-02 3E-03 0.1 0.02 8E-06 1E-06 2E-05 Triclopyr (BEE)1 6E-05 1E-08 7E-03 0.05 2E-06 2E-11 1E-04 Triclopyr (TEA)1 0.3 3E-02 1.4 0.05 1E-03 2E-10 8E-02 Note: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester Table B-15. Hazard quotient for the public – consumption of fish caught from water contaminated by pesticides (upper limits are presented to represent the worst- case scenario) Chemical Hazard Quotient (HQ) Fish Consumption (Accidental Spill) Chronic Fish Consumption Toxicity Value (mg/kg) Adult Male Subsistence Population Toxicity Value (mg/kg) Adult Male Subsistence Population Aminopyralid 1 2E-03 7E-03 8E-06 7E-05 1E-03 6E-03 3E-05 5E-03 3E-02 3E-07 4E-03 2E-02 2E-06 1E-05 8E-04 4E-03 3E-05 3E-04 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-32 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Triclopyr (TEA) 1 2E-03 8E-03 0.05 2E-05 2E-04 Note: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester Table B-16. Hazard quotient for the general public – ingesting fruit and vegetation contaminated by pesticides. Chemical Hazard Quotient (HQ) Acute Exposure Chronic Exposure Toxicity Value (mg/kg) Central Applicatio Rate Lower Application Rate Upper Applicatio Rate Toxicity Value (mg/kg) Central Application Rate Lower Applicatio Rate Upper Applicatio Rate Aminopyralid Fruit Vegetation Chlorsulfuron 0.75 1E-03 5E-04 2E-02 0.05 7E-03 3E-03 0.1 0.75 2E-02 1E-03 0.1 0.05 0.1 7E-03 0.8 Clopyralid 0.75 3E-03 7E-05 2E-03 0.15 6E-03 2E-03 0.1 0.75 4E-02 3E-03 0.3 0.15 8E-02 5E-03 0.9 Fluazifop 0.43 7E-03 3E-03 0.1 0.0063 6E-02 2E-02 0.43 9E-02 7E-03 0.8 0.0063 3E-03 1E-04 5E-02 Glyphosate Fruit Vegetation 2 0.2 1E-02 2 3E-02 2E-03 0.2 Imazapyr 2.5 2E-03 1E-03 4E-02 2.5 1E-03 3E-04 2E-02 2.5 3E-02 2E-03 0.3 2.5 1E-02 5E-04 0.1 Indaziflam Fruit 0.5 2E-03 7E-04 2E-02 0.02 2E-02 8E-03 0.3 0.5 2E-02 1E-03 0.2 0.02 0.2 2E-02 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-33 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Chemical Hazard Quotient (HQ) Acute Exposure Chronic Exposure Toxicity Value (mg/kg) Central Applicatio Rate Lower Application Rate Upper Applicatio Rate Toxicity Value (mg/kg) Central Application Rate Lower Applicatio Rate Upper Applicatio Rate 0.87 2E-03 9E-04 3E-02 0.02 1E-02 6E-03 0.2 0.87 3E-02 2E-03 0.2 0.02 0.2 1E-02 Fruit 0.05 0.5 0.2 0.05 0.2 6E-02 Vegetation 0.05 0.5 0.05 0.4 8E-03 Triclopyr (TEA) 0.05 0.5 0.2 0.05 0.2 6E-02 0.05 0.5 0.05 0.6 2E-02 Note: HQ = hazard quotient, which is the exposure estimate divided by the reference dose. A hazard quotient equal to or below 1 is below the level of concern; bold values exceed the level of concern. Exceeding the level of concern does not mean there would be injury or impact because avoidance and minimization measures implemented as part of the Proposed Action would reduce the level of risk. mg/kg = milligram per kilogram TEA = triethylamine BEE = Butoxyethyl ester B.2.4 Surfactants and Colorants Competitor may be used as a surfactant with any of the proposed pesticides, or as a diluent with imazapyr. None of the ingredients in this product are known to be on U.S. Environmental Protection Agency (USEPA) List 1 or 2. Its primary ingredient is food grade ethylated canola oil. Manufacture labels recommend using 0.25–1 percent surfactant mixed with the pesticide. Other than ethylated canola oil, the chemicals in the Competitor surfactant have received very little study and scrutiny to determine what effect the chemicals may have. Overall, the Competitor surfactant appears to have a lower level of toxicity than the pesticides and would be used in small quantity compared to the pesticide. Under the proposed Project, PG&E may use colorants to identify where pesticides have been applied. PG&E would primarily use colorants that are water soluble and blue in color. Highlight Blue is a colorant that makes the pesticide more visible during application. The specific color pigment will vary with the brand name of colorant, other ingredients may not be disclosed but are identified as USEPA List 3 or 4A (Bakke, 2007). The active ingredient in these types of colorants may be Acid Blue 9, which is a food grade additive with multiple uses apart from spray pattern indicators. It is not expected that this material would result in any added risk or environmental impact. Spray pattern indicators minimize overspray and alert the public to the presence of a Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-34 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company pesticide application reducing the potential for exposure to the treatment (SERA 1997). Highlight Blue is considered virtually non-toxic to humans, although its toxicity to wildlife is unknown. BMPs included in Attachment C of the Strategy including application timing, application method, and appropriate buffers would mitigate the potential risk associated with all the pesticides on wildlife and the public. Infrequent applications of pesticides in specific locations (i.e., once or twice per year), buffers/avoidance areas, use of aquatic-safe pesticide formulations in aquatic habitats, and use of targeted application methods would reduce the potential for significant acute or chronic exposure as a result of invasive weed control activities. Therefore, direct toxicological effects of surfactants and colorants on wildlife and the public are not anticipated. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-35 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company References Cited Bakke, D. 2003. Human and Ecological Risk Assessment of Nonylphenol Polyethoxylate-based (NPE) Surfactants in Forest Service Herbicide Applications. US Forest Service. Available at: https://www.fs.usda.gov/Internet/FSE_DOCUMENTS/stelprdb5346866.pdf. Bakke, D. 2007. Analysis of issues Surrounding the Use of Spray Adjuvants with Herbicides. Original 2002, revision 2007. US Forest Service. Available at: http://www.fs.fed.us/r6/invasiveplant-eis. Kestrel Tellevate. 2020. Indaziflam—human health and ecological risk assessment. Final Report. July 31, 2020. 216 pages. Available at: https://www.fs.usda.gov/foresthealth/pesticide/pdfs/Indaziflam-Report.pdf. Syracuse Environmental Research Associates, Inc. (SERA). 1997. Use and Assessment of Marker Dyes Used with Herbicides Syracuse Environmental Research Associates. SERA TR 96-21-07-03b. Prepared for USDA Forest Service by Syracuse Environmental Research Associates, Inc. Syracuse, New York. Available at: https://www.fs.usda.gov/foresthealth/protecting-forest/integrated-pest- management/pesticide-management/pesticide-risk-assessments.shtml. SERA. 2004a. Clopyralid—human health and ecological risk assessment. Final Report. December 5, 2004. SERA TR 04-43-17-03c. SERA, Fayetteville, NY. 154 pages. Available at: https://www.fs.usda.gov/foresthealth/pesticide/pdfs/120504_clopyralid.pdf. SERA. 2004b. Sulfometuron methyl—human health and ecological risk assessment. Final Report. December 14, 2004. SERA TR 03-43-17-02c. SERA, Fayetteville, NY. 163 pages. Available at: https://www.fs.usda.gov/foresthealth/protecting-forest/integrated-pest- management/pesticide-management/pesticide-risk-assessments.shtml. SERA. 2007. Aminopyralid—human health and ecological risk assessment. Final Report. June 28, 2007. SERA TR-052-04-04a. SERA, Fayetteville, NY. 231 pages. Available at: https://www.fs.usda.gov/foresthealth/pesticide/pdfs/062807_Aminopyralid.pdf. SERA. 2011a. Glyphosate—human health and ecological risk assessment. Final Report. March 25, 2011. SERA TR-052-22-03b. SERA, Fayetteville, NY. 336 pages. Available at: https://www.fs.usda.gov/foresthealth/pesticide/pdfs/Glyphosate_SERA_TR-052-22- 03b.pdf. SERA. 2011b. Imazapyr—human health and ecological risk assessment. Final Report. December 16, 2011. SERA TR-052-29-03a. SERA, Fayetteville, NY. 215 pages. Available at: https://www.fs.usda.gov/foresthealth/pesticide/pdfs/Imazapyr_TR-052-29-03a.pdf. SERA. 2011c. Triclopyr—Revised Human Health and Ecological Risk Assessments Work Sheets. SERA TR-052-25-03c. Prepared for USDA Forest Service by Syracuse Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment B B-36 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas & Electric Company Environmental Research Associates, Inc. Syracuse, New York. Available at: https://www.fs.usda.gov/foresthealth/protecting-forest/integrated-pest- management/pesticide-management/pesticide-risk-assessments.shtml. SERA. 2016a. Chlorsulfuron - human health and ecological risk assessment.7h SERA TR 05-43- 23-05a. Prepared for USDA Forest Service by Syracuse Environmental Research Associates, Inc. Syracuse, New York. Available at: https://www.fs.usda.gov/foresthealth/protecting-forest/integrated-pest- management/pesticide-management/pesticide-risk-assessments.shtml. SERA. 2016b. Triclopyr—human health and ecological risk assessment. Final Report. July 9, 2016 (Corrections). SERA TR-052-25-03c. SERA, Fayetteville, NY. 269 pages. Available at: https://www.fs.usda.gov/foresthealth/pesticide/pdfs/Triclopyr_TR-052-25- 03b.pdf. SERA. 2019. Indaziflam Work book 6.02.18 Indaziflam Esplanande 200SC Prepared by Betzy Colon and Janet Burris. March 4 , 2019. Syngenta. 2024. Fusilade- Safety sheet. May 15 2023. Available at: https://www.syngenta- us.com/sds-label/fusilade_dx. Accessed on October 2024. U.S. Environmental Protection Agency (USEPA). 2014. Label Review Manual. Chapter 7: Precautionary Statements. Office of Pesticide Programs. Revised July 2014. Available at: https://www.epa.gov/pesticide-registration/label-review-manual. USEPA. 2023. National air toxics assessment, NATA glossary of terms: Hazard Quotient. Available at: https://www.epa.gov/national-air-toxics-assessment/nata-glossary- terms#hq. Accessed March 2023. Washington Department of Transportation (Washington DOT). February 2006. Clopyralid; Roadside Vegetation Management Herbicide Facts Sheet. Available at: https://wsdot.wa.gov/sites/default/files/2021-10/Herbicides-factsheet-Clopyralid.pdf. Weed Science Society of America (WSSA). 2014. Herbicide Handbook. 10th edition. Wilbur-Ellis Co. 2005. R-11 Adjuvant. MSDS. Cal EPA No. 2935-50142. July 2005. Available at: https://www.wilburellisagribusiness.com/product/r-11/. (This Page Intentionally Left Blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Attachment C Weed Treatment Best Management Practices (BMPs) for the Poe Project Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company (This page intentionally left blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C C-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company This section is an excerpt from the Poe Integrated Vegetation Management Plan, Attachment D (PG&E 2020) and describes all invasive weed prevention Best Management Practices (BMPs) and environmental protection measures that PG&E will perform to prevent introduction and spread of target invasive weeds and protect sensitive natural resources during vegetation management activities. The following BMPs shall be implemented on the Poe Hydroelectric Project: Measures to Prevent the Introduction and Spread of Target Invasive Weeds by PG&E Employees and Contractors 1. Education – Annual environmental training for all internal PG&E employees and contract maintenance personnel will be conducted that will emphasize the importance of preventing the further spread of target invasive weeds, including aquatic invasive weeds. This training will review the identifying characteristics of the target invasive weeds most likely to occur in the Project and review of Plan BMPs to prevent introduction and spread. Training materials may include brochures and field guides prepared by the Forest Service, Butte County Weed Management Area, or PG&E’s staff and contractors. 2.Equipment Cleaning – Heavy equipment brought into the Project from outside the watershed will be cleaned prior to its use on the Project. Equipment will be inspected to determine whether it is free of soil or other debris that could contain invasive weed seed. Equipment will be considered clean when a visual inspection does not disclose soil, seed, plant material, and other such debris. Off-road equipment used in the watershed shall be inspected and cleaned using air compressors, brooms, or similar tools, if necessary, when travelling off-road or through target invasive weed infestations. Vehicles not intended for off-road use (e.g., log trucks, chip vans, service vehicles, water trucks, pickup trucks) will not be subject to the equipment cleaning requirement. 3.Avoid Infestations – Travel through invasive weed infested areas shall be minimized. If travel through infested areas cannot be avoided, areas free of target invasive weeds will be worked on prior to areas with target invasive weed infestations to the extent practicable. 4. Use Existing Roads – Vehicles and equipment shall access work sites from existing roadways and shall be parked on pavement, existing roads, and previously disturbed areas to the extent practicable. 5.Limit Disturbance Areas – Ground disturbance, including road maintenance activities, shall not exceed the minimum necessary to safely complete operations. Precautions shall be taken to avoid damage to non-target vegetation. 6.Monitoring After Disturbance – Areas disturbed by PG&E maintenance activities and/or road maintenance will be monitored for three years after activity to ensure early detection of target invasive weeds. Any new target invasive weed occurrences will be incorporated into the management maps for the annual control program. 7.Weed-free Materials – All imported materials (e.g., straw, mulch, gravel, fill) used for work within NFSL shall be weed-free. 8.Weed-free Feed – If grazing is used as a target invasive weed control measure and supplemental feeding is necessary, only pelletized or commercially available certified weed-free feed will be used on NFSL. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C C-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Measures to Prevent the Introduction and Spread of Target Aquatic Invasive Weeds The following actions will be implemented to prevent the introduction and establishment of aquatic invasive weeds on the Project. 9.Personnel Education – PG&E will educate their Project personnel and contractors about the importance of preventing introduction and spread of aquatic invasive weeds. Educational materials will be made available, including specific suggested measures for preventing introduction and spread. 10.Measures to Avoid Introduction of Aquatic Invasive Weeds – PG&E will implement the following measures to prevent aquatic invasive weed infestations: a.Regularly inspect and thoroughly clean and dry equipment (e.g., boats, waders, felt footwear, etc.) before entering a waterbody, and when moving equipment between projects, waterbodies, or sites. b.Heavy equipment will not be used in wetted areas to the extent practical. c.If feasible, work will take place in dry conditions during the dry season. Accessing parts of the Project from a boat or wading is permitted. d. Never move live organisms from one waterbody into another. e. Use elliptical and bulb-shaped anchors to avoid snagging aquatic materials. 11.Measures to Avoid Spreading Known Aquatic Invasive Weeds – If occurrences of aquatic invasive weeds are identified in Project waterbodies, PG&E will implement the following measures: a.Prior to any construction or disturbance activities within the waterbody, inspections for aquatic invasive weeds will be performed. If aquatic invasive weeds are found in the work area, they will be treated or otherwise removed with a plan developed by a licensed PCA. This plan will be implemented prior to or during construction, as feasible (e.g., work is not an emergency). b.Conduct work in less infested areas of the waterbody prior to infested areas, when possible. c.Minimize wading and running boats into sediment to avoid relocating the aquatic invasive weeds d.Minimize the amount of sediment, plants, and/or organisms that are incidentally removed from the water with equipment, boats, or sampling gear. If any of these materials are brought out of the water, leave them at the originating site to the extent feasible (e.g., pull or rinse off vegetation and sediment at the waterbody). Measures Implemented to Protect Sensitive Environmental Resources During Vegetation Management 12.Herbicide Use Planning Process – A licensed PCA will provide PUPs on Forest Service Form FS- 2100-2 (or current version) and written pest control recommendation to be reviewed and approved by the appropriate Plumas National Forest officer prior to implementation of herbicide treatment on NFSL. This recommendation will include the proposed treatment sites, methods, and products with associated amounts. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C C-3 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 13.Pesticide Spill Contingency Planning – Prior to herbicide treatment, a spill plan will be developed describing actions to be taken in the event of a pesticide spill. Plans should include parties responsible for spill notification, time requirements for notification, and spill containment and cleanup measures (Forest Service 2000, 2011, 2012). Spill plans will be submitted with PUPs to the Plumas National Forest for review. Spill plans will identify and describe specific measures aimed at minimizing the chances and effects of herbicide spills. Measures include proper storage and handling of pesticides, designating routes of travel, and mixing sites. If a spill occurs, the spill plan will specify contact information and process for notification and containment. Spill kits will be required in contractor vehicles on site and where contractor-supplied herbicides are stored, along with safety data sheets (Forest Service 2000, 2011, 2012). 14.Pre-Treatment Flagging – Prior to start of target invasive weed control treatment representative target invasive weed occurrences may be flagged in order to aid treatment contractors with identification and location of occurrences. In addition, prior to any vegetation management, known occurrences of rare (i.e., TECS and watch list) plant species will be flagged for avoidance during herbicide application. 15.Environmental Training – Prior control treatments, PG&E’s noxious weed program manager and the PCA will conduct an environmental briefing for the treatment contractor and other Project vegetation management, as appropriate, describing target invasive weeds to be treated, and BMPs to be implemented during vegetation management activities. At a minimum, the following topics will be covered during the briefing: •All environmental constraints known in the Control Area (e.g., special-status plants and wildlife, SMZ buffers, etc.); •Forest Service-approved materials; •Safety and spill plan; •Site restoration requirements; and •Regulatory requirements that apply to herbicide use. Training materials may include existing identification brochures or field guides, or Project-specific materials prepared by PG&E’s staff or contractors. Training methods and materials may include both in-person and online components and may vary over the term of the License. 16. Follow Legal Requirements – Herbicide applications require the following: •Licensed and trained personnel; •Adherence to applicable state laws, California Department of Pesticide Regulation (CDPR) and CalEPA regulations, and label directions for application rates, methods, and mixing; •Annual safety and product training for each herbicide used; •Use of safety equipment as prescribed by state law and the pesticide label, including goggles, gloves, long pants, long-sleeved shirts, shoes and socks, as appropriate; •Written Pest Control Recommendation by a licensed PCA; •Monthly reporting of each use of herbicide by county; and •Annual inspections by the County Agricultural Commissioner. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C C-4 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Pesticide applicators will be licensed by the State of California, and as such must use pesticides according to CDPR regulations (found at CDPR 2019). Applicators will also observe guidelines provided in the Forest Service Pesticide Use Management and Coordination Handbook (Forest Service 1994). 17.Pesticide Application, Monitoring, and Evaluation – Prior to the start of application, all application equipment will be calibrated to ensure accuracy of delivered amounts of herbicide. Periodically during application, equipment will be rechecked for calibration. Colorants or dyes will be added to the herbicide mixture to determine placement. 18.Applications Directed by Licensed PCA – All herbicide treatments will be performed under the direction of a licensed PCA who will ensure that herbicide treatments are implemented properly and that BMPs are followed. The PCA will direct the work of a team of PCOs who will carry out all treatments. 19.Manual or Mechanical Control near Sensitive Resources – Manual and mechanical control will be used when necessary to protect nearby known special-status plants, cultural sites, or other sensitive situations where the use of herbicides may be potentially problematic. Any such sites will be identified annually during the pre-operations meeting and reviewed with the treatment contractor during the Environmental Training. 20.Cleaning and Disposal of Pesticide Containers and Equipment – All herbicide applications will adhere to applicable state laws, CalEPA regulations, CDPR regulations (CDPR 2003), and safety regulations for container disposal. All herbicide and adjuvant containers will be triple rinsed with clean water at an approved site. The rinsate will be disposed of by placing it in the batch tank for application. Used containers will be punctured on the top and bottom to render them unusable, unless said containers are part of a manufacturer's container recycling program, in which case the manufacturer's instructions will be followed. Disposal of non-recycled containers will be at legal dumpsites. Equipment will not be cleaned, and personnel will not bathe in a manner that allows contaminated water to enter any body of water on NFSL. 21.Controlling Pesticide Drift during Spray Applications – The following measures will be followed to reduce risk of drift during application of herbicides onto non-target areas (Forest Service 2000, 2011, 2012): •Only ground-based equipment will be used; •Application will cease when weather parameters exceed label requirements, or when precipitation occurs or is forecast with greater than a 70 percent probability in the next 24-hour period; •Spray nozzles will produce a relatively large droplet size; •Low nozzle pressures (15 pounds per square inch [psi]) will be observed; •Spray nozzles will be kept within 24 inches of vegetation during spraying; •A pressure gauge or pressure regulator will be required on each backpack sprayer; and •All applications will be low volume (less than 15 gallons per acre [gpa]). 22.Streamside Wet Area Protection During Herbicide Spraying – Streamside management zones (SMZs, i.e., untreated buffer strips) will be established on all stream courses and roadside ditches that might be impacted. Widths are based on the type of herbicide, the class of stream or ditch, and the presence of water at time of treatment (Table C-1). Untreated buffer strips will be flagged or otherwise designated on the ground. The contractor staff will be informed of the location and extent Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C C-5 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company of each of the strips prior to treatment. Applications will be monitored by the supervising PCA to determine accurate placement. Measures Implemented to Protect FYLF during Vegetation Management: 23.Pesticide application using directed spray techniques (i.e., backpack-type sprayers) will be conducted no closer than 107 ft from the water’s edge within suitable aquatic habitat for foothill yellow-legged frog. This will apply to designated Critical Habitat if and when identified by the USFWS. 24.Pesticides may be applied within the 107-ft buffer using low-pressure hand sprayers or wicking/wiping, only at disturbed areas located in or around facilities that are critical to project infrastructure (e.g., dams, powerhouses, spillways, tunnels, penstocks, etc.). Under these circumstances, only aquatic formulations of the pesticide with an aquatic-labeled surfactant will be used, except for Poe Powerhouse yard and Poe Dam. Non-aquatic formulations of pre-emergent herbicides are needed at these locations in order to maintain bare ground conditions for employee safety and fire prevention per industry best practices. 25.All mixing and loading of pesticides will take place at least 300 ft from streams containing suitable habitat; no mixing or loading will occur within 500 ft of sites occupied by FYLF. 26.As a supplement to pesticide use, manual treatment techniques including hand-pulling, digging, and hand tools (including hand-held motorized tools such as weed trimmers, brush saws, etc.) can be used to treat small populations of invasive weeds. No buffer is required for manual treatments. 27.If manual treatments are employed within suitable habitat or Critical Habitat (if or when designated by USFWS), a qualified biologist(s) will clear the work area prior to treatment on the day of work. 28.Pesticides will not be applied during the wet season to minimize herbicide transport in the environment due to precipitation and subsequent runoff. The wet season is from the first wetting rain, typically in October, through April. Table C-1. Buffer strip widths for streams and ditches. Water Class IV Including Rills and Gullies Watercourse Class III Watercourse Class II Aminopyralid (e.g., Milestone) 50 feet (ft) 25 ft 25 ft 50 ft 75 ft 75 ft 25 ft 25 ft 25 ft 75 ft Custom/Aquamaster, or similar 0 ft 0 ft 0 ft 0 ft 0 ft Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment C C-6 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company 50 ft 10 ft 25 ft 25 ft 50 ft Untreated Buffers for Roadside Ditches Herbicide Ditch with Water 4 from Wet Area or To 300 Ft Down Ditch from Aminopyralid (e.g., Milestone) 25 ft 10 ft on either side of ditch 0 ft Chlorsulfuron (e.g., Telar) 25 ft 10 ft on either side of ditch 0 ft Clopyralid (e.g., Transline) 25 ft 10 ft on either side of ditch 0 ft Fluazifop-P-butyl (e.g., Fusilade) 50 ft 50 ft 50 ft Custom/Aquamaster, or similar 0 ft Water’s edge 0 ft 25 ft Water’s edge 0 ft 1 No mixing will take place within 300 ft of a stream. Buffer widths based on physical properties of herbicide and previous experience. 2 Watercourse class characteristics are defined in California Department of Forestry and Fire Protection (2018 as follows: Class I: Domestic supplies, including springs, on site and/or within 100 feet downstream of the operations area and/or fish always or seasonally present onsite, includes habitat to sustain fish migration and spawning. Class II: Fish always or seasonally present offsite within 1,000 feet downstream and/or aquatic habitat for aquatic species (excludes Class III waters that are tributary to Class I waters). Class III: No aquatic life present, watercourse showing evidence of being capable of sediment transport to Class I and II waters under normal high water flow conditions after completion of timber operations. Class IV: Man-made watercourses, usually downstream, established domestic, agricultural, hydroelectric supply or other beneficial use. 3 Aquatic formulations of glyphosate. 4 A ditch would be considered to have water present if the immediate ditch system contains water. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment D December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Attachment D Water Quality Sampling Protocol Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment D December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company (This page intentionally left blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment D D-1 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company This is an excerpt from the Poe Integrated Vegetation Management Plan, Attachment H (PG&E 2020). PG&E shall be responsible for water quality monitoring to ensure that no pesticides prescribed according to the Poe Invasive Weed Management Strategy enter the surface waters adjacent to the application areas. PG&E proposes to implement water quality monitoring adjacent to treated areas to document the effectiveness of proposed buffers. Water samples shall be taken at times and locations specified below. Samples shall be collected, stored and transported using EPA-approved procedures, including sampling chain of custody (COC). All water samples shall be tested at a California-certified laboratory (e.g., North Coast Laboratory in Arcata, California). The laboratory Environmental Accreditation Program number will be appended to each document. The water analysis will be carried out to determine if the prescribed herbicides and their associated breakdown products are present at detectable concentrations. All water samples shall be taken in new glass bottles that have been solvent-rinsed. All water samples will be taken in mid-channel (if possible, depending upon flow and any safety concerns) and as near to the mid- depth of the stream as possible. Sediment disturbance will be minimized. Samples will be collected in flowing water. The samples will be taken upstream from the sampler’s body to ensure no contact with the skin or clothing. A field blank will be provided from each sampling day to ensure that contamination of the sample bottles does not occur while in transit to and from the sample site. The samples will be retained in coolers at 39 degrees Fahrenheit (℉, equals 4 degrees Celsius [℃]) until they are delivered to the laboratory. All samples will be delivered to the analytical laboratory within 24 to 36 hours of sampling. Chain of custody documentation will follow the samples through the analytical process and a copy of the signed COC will be provided with the analytical report. To minimize any potential cross-contamination of samples, the sampler will not be involved in any other aspect of the treatment operation, including travel in vehicles. The laboratory detection limits and full quality assurance and quality control (QA/QC) documentation will be provided by the laboratory as a part of the results package. If the detection limits are not met or the results do not meet QA/QC requirements, the samples will be rerun. The laboratory detection limits and full quality assurance and quality control (QA/QC) documentation will be provided by the laboratory as a part of the results package. If the detection limits are not met or the results do not meet QA/QC requirements, the samples will be rerun. Monitoring Locations: •Cresta Powerhouse, upstream of Control Area •Poe Powerhouse, downstream of Control Area Monitoring Methods: One sample will be taken prior to initial application of herbicides each season. One sample will be taken during the first significant runoff-producing storm event that occurs within 90 days after herbicide application. Therefore, post-treatment water monitoring sampling will occur after the treatment area receives at least 0.5 inch of rain (within any 72-hour period) based on the precipitation recorded at the Bucks Creek Powerhouse (e.g., from the National Oceanographic and Atmospheric Administration’s California Nevada River Forecast Center website, cnrfc.noaa.gov or successor). Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment D D-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company If no runoff producing storm occurs within 90 days after herbicide applications, post-treatment samples will not be taken. If monitoring results in only negative samples for three years, then monitoring for those herbicides will be suspended, pending suitable changes in herbicide or application type that warrant additional sampling. Changes in herbicides and/or treatment methods will trigger an additional three years of water quality monitoring for herbicides according to the protocol described herein. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment E December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Attachment E US Forest Service Pesticide Use Reporting Form Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment E December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company (This page intentionally left blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment E December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Pesticide Use Reporting Form Response Date: District: Person Responding: Plumas National Forest Pesticide Use Report FY Pe s t i c i d e C o m m o n Na m e Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment F December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company Attachment F PG&E Response to USFS Comments Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment F F-1 November 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company (This page intentionally left blank.) Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Poe Hydroelectric Project Poe Invasive Weed Management Strategy Attachment F F-2 December 2024 Poe Hydroelectric Project, FERC Project No. 2107 ©2024, Pacific Gas and Electric Company USFS Comments PG&E Response Sec 1.3, page 1-3 In regard to CDFA List "There seems to be some inconsistency here with which version of the CDFA list is used, Here vs. what is used in Table 1 either CDFA rated or noxious weed 4500 rated, or Forest Service sensitive, example being Stinkwort is a Forest Sensitive species. That is why it is listed despite not having a CDFA Section 2.1.2, page 2-2 Regarding decision process "Does this include pollinators?" Yes, honey bees were part of the analysis in Appendix B. They were a proxy for pollinators. Section 2.3.1, page 2-8 Regarding serpentine "Yes. One of the few that this I would suggest that those areas are prioritized for treatment in order to prevent impacts to Sensitive spp." Comment noted. We can prioritize serpentine substrate for treatment. Section 2.3.7, page 2- 13 likelihood of control high "Good to Comment noted. Attachment A, CDFA section 4500 and list A, B, and Q noxious weed species table,page A-8 Regarding explaining the rating systems for the invasive weed list used "Thanks for listing all of these and explaining the differences, I was going to comment which version was used." Comment noted. Document Accession #: 20251014-5151 Filed Date: 10/14/2025 File Code: 2770 Date: August 8, 2025 Anna Urias Hydro License Coordinator, Power Generation Pacific Gas and Electric Company (503) 201 -1961 AXUS@PGE.com Via Email RE: Poe Hydroelectric Project, FERC No. 2107 – Revised Invasive Weed Management Strategy Dear Ms. Urias This letter responds to Pacific Gas & Electric Company’s (PG&E’s) June 11, 2025 request to revise the Poe Invasive Weed Management Strategy for Pacific Gas and Electric Company’s (PG&E) Poe Hydroelectric Project, Federal Energy Regulatory Commission (FERC) No. 2107. The Poe Invasive Weed Management Strategy is a requirement under the Integrated Vegetation Management Plan (IVMP), approved by FERC on November 2, 2023. My staff have reviewed the revised Poe Invasive Weed Management Strategy which includes edits to Appendix C Weed Treatment Best Management Practices that PG&E and US Fish and Wildlife Service collaborated on to modify. We are satisfied with the changes, and I approve of the revised strategy. Please contact Kurt Sable, USDA Forest Service, Pacific Southwest Region Hydroelectric Program Coordinator at (530) 616-1823, kurt.sable@usda.gov or Erika Brenzovich, Plumas National Forest Recreation and Lands Program Manager at 530-283-7798, erika.brenzovich@usda.gov if you have any questions. Sincerely, RACHEL A. BIRKEY Acting Forest Supervisor cc: Cailtin Ostomel, Loren Everest, Erika Brenzovich, & Kurt Sable Caring for the Land and Serving People Printed on Recycled United States Department of Agriculture Service Plumas National Forest Quincy, CA 95971 530-283-2050 TDD: 530-534-7984 Document Accession #: 20251014-5151 Filed Date: 10/14/2025 Digitally signed by RACHEL BIRKEY Date: 2025.08.08 12:27:21 -07'00' Document Content(s) PGE20251013_2107_Invasive_Weed_Strategy_Ltr.pdf...........................1 PGE20251013_2107_Invasive_Weed_Strategy_Enc1.pdf .........................3 PGE20251013_2107_Invasive_Weed_Strategy_Enc2.pdf .......................103 Document Accession #: 20251014-5151 Filed Date: 10/14/2025