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HomeMy WebLinkAbout11.03.25 Board Correspondence_ FW_ General Correspondence 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: General Correspondence submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al. Date:Monday, November 3, 2025 2:25:26 PM Please see Board Correspondence -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Monday, November 3, 2025 12:50 PM Subject: General Correspondence 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 11/3/2025, 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: General Correspondence Description: Pacific Gas and Electric Company submits copy of comments and responses to stakeholder comments on the 60% Design Drawing for the Poe Hiking Trail of the Poe Hydroelectric Project under P-2107. 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Box 28209 Oakland, CA 94604 November 3, 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 Poe Hiking Trail Stakeholder Comments on 60% Design Drawing Dear Secretary Reese: This letter presents the stakeholder comments on the 60% Design Drawing for the Poe Hiking Trail, along with Pacific Gas and Electric Company’s (PG&E) formal response, for PG&E’s Poe Hydroelectric Project, Federal Energy Regulatory Commission (FERC) No. 2107. The 60% Design Drawing, in addition to an extension of time request, was submitted to FERC on September 30, 2025. Comments submitted by American Whitewater, American Whitewater, Konkow Valley Band of Maidu Indians, California Sportfishing Protection Alliance, and Mike Taylor are enclosed as (Enclosure 1). Comments submitted by the U.S. Forest Service are enclosed as (Enclosure 2). PG&E’s responses to the stakeholder comments are enclosed as (Enclosure 3). If you have questions or comments regarding this matter, please contact Anna Urias, license coordinator for PG&E, at (530) 201-1961. Sincerely, Matthew Joseph Supervisor Hydro Licensing Enclosures: 1. Comments submitted by American Whitewater, American Whitewater, Konkow Valley Band of Maidu Indians, California Sportfishing Protection Alliance, and Mike Taylor, dated September 30, 2025 2. Comments submitted by U.S. Forest Service, dated September 30, 2025 3. PG&E’s Response to Comments received on the 60% Design Drawing, dated October 30, 2025 cc: See Attached List Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Debbie-Anne Reese, Secretary November 3, 2025 Page 2 cc: via email w/enclosures Aondrea Bartoo, USFWS – aondrea_bartoo@fws.gov Jessica Dyke, SWRCB – Jessica.Dyke@Waterboards.ca.gov Nathan Fisch, SWRCB – Nathan.Fisch@waterboards.ca.gov Michael Maher, CDFW – Michael.Maher@wildlife.ca.gov Beth Lawson, CDFW – Beth.Lawson@wildlife.ca.gov Kamie Loeser, Butte County – kloeser@buttecounty.net Loren Everest, Forest Service – loren.everest@usda.gov Clay R. Davis, Forest Service – clay.davis@usda.gov Dawn Alvarez, Forest Service – dawn.alvarez@usda.gov Kurt Sable, Forest Service – kurt.sable@usda.gov Cecily Merwin, Forest Service – cecily.merwin@usda.gov Jacqueline Phipps, Forest Service – Jacqueline.Phipps@usda.gov Chuck James, Forest Service – Charles.James@usda.gov Jonathan Berry, Forest Service – jonathan.berry@usda.gov Laura Schweitzer, Forest Service – Laura.Schweitzer@usda.gov Colleen Heard, Forest Service – colleen.heard@usda.gov Emily Doe, Forest Service – Emily.Doe@usda.gov Erika Brenzovich, Forest Service – erika.brenzovich@usda.gov Caitlin Ostomel, Forest Service – caitlin.ostomel@usda.gov Scott Harding, American Whitewater – scott@americanwhitewater.org Dave Steindorf, American Whitewater – dave@americanwhitewater.org Theresa Lorejo-Simsiman, American Whitewater – theresa@americanwhitewater.org Thad Walker, BCRCD – thad@bcrcd.org Greg Mazu, Howler Group – greg@howler.group Tracey Ferguson, Plumas County – traceyferguson@countyofplumas.com Andy Pickett, Butte County – APickett@buttecounty.net Paula Daneluk, Butte County – PDaneluk@buttecounty.net Doug Teeter, Butte County – DTeeter@buttecounty.net Chris Shutes – blancapaloma@msn.com Mike Taylor – ljmftaylor68@gmail.com Peggy Moak – pmoak19@gmail.com Konkow Valley Band Tribal Chair – konkowvalleybandpoctribalchair@gmail.com Document Accession #: 20251103-5192 Filed Date: 11/03/2025 ENCLOSURE 1 Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Scott Harding Stewardship Associate scott@americanwhitewater.org PO Box 34 Forks of Salmon, CA 96031 541-840-1662 September 30, 2025 Anna Urias Hydro License Coordinator Pacific Gas & Electric Company axus@pge.com Submitted electronically Re: Stakeholder Comments on Poe Reach 60% Trail Design Dear Ms. Urias, We provide these comments in response to PG&E’s Poe Reach 60% Trail Design, as submitted to stakeholders after the close of business on August 31, 2025. We generally support the 60% design as presented and appreciate the progress made; however, we have several important concerns that must be addressed to ensure the Poe Hiking Trail meets FERC’s requirements and adequately protects cultural and natural resources. As long-standing stakeholders in the Poe Hiking Trail proceeding, we are seriously concerned by PG&E’s attempt to classify the trail as a U.S. Forest Service (USFS) Trail Class 1 or 2 in the 60% design document. This approach is inconsistent with the all-weather requirement of the FERC order, fails to provide adequate protection for natural resources, and contradicts both PG&E’s own 60% design and the advice of trail experts and agency staff. FERC has ordered PG&E to construct an all-weather trail, and this is the clear standard that must guide trail design and construction. Constructing the trail to Class 1 or 2 standards would not provide the required all-weather route while adequately protecting sensitive natural resources. As PG&E’s biological surveys confirm, the trail alignment intersects aquatic habitat supporting foothill yellow-legged frog and other species. Adequate crossings and stable tread are essential not only for recreation access but also for minimizing sedimentation and other impacts to aquatic systems. Class 3 standards are the appropriate level of development to provide a durable, all-weather trail that adequately protects natural resources. As PG&E’s 60% design demonstrates, the Poe Hiking Trail traverses steep, rocky terrain with no fewer than 16 stream crossings. The design notes the need for substantial rock structures, boardwalks, and multiple bridges (some across wide and erosive channels). These are defining Document Accession #: 20251103-5192 Filed Date: 11/03/2025 elements of a USFS Class 3 trail, which includes a continuous tread and constructed features necessary to provide all-weather access and protection of natural resources. PG&E’s attempt to classify the trail as Class 1 or 2 is not supportable. Forest Service staff and PG&E’s contracted trail design experts have indicated that Class 3 is the appropriate classification. PG&E is not an expert in trail design and must rely on its contracted professionals and agency staff to recognize that the Poe Hiking Trail must be, at minimum, a Class 3 trail—both to meet regulatory requirements and to ensure a durable trail with lower long-term maintenance needs. Constructing the trail to the necessary standard is not an excessive burden as a substantial portion of the trail only needs encroaching brush and slough removed to make it a Class 3 trail. We ask PG&E to proceed promptly with design and construction of the trail as a Class 3 trail and abandon attempts to downgrade its features to a lower trail class that would not meet the all-weather FERC license requirement or comply with natural resource protection requirements. The Poe Hiking Trail is a required license condition and a long-overdue public recreation resource. Continued delay is unacceptable. The proposed alignment contains multiple switchbacks, particularly at the north end. Switchbacks are often vulnerable to shortcutting by users. The existing switchback near Live Oak Bar on the historic trail alignment has been dropped, and two switchbacks near the Poe Road trailhead have also been eliminated from the proposed alignment. Reducing the overall number of remaining switchbacks and armoring the resulting steeper trail segments, where necessary, would minimize long-term ground disturbance and better protect the trail corridor. Additionally, we reiterate our support for fully protecting cultural resources as identified by the Konkow Valley Band of Maidu Indians. PG&E must commit to incorporating necessary measures into final design and construction, including realignment or restricted access where appropriate, the use of qualified tribal monitors during all ground-disturbing activities, and collaboration on interpretive signage. Stakeholders support the Konkow Valley Band’s request for these protections to be implemented with the seriousness and respect it deserves. Finally, we note that PG&E intends to submit its 60% Design report to FERC today, September 30, 2025—the same date it set as the deadline for stakeholder comments. This approach does not provide PG&E time to review stakeholder input and incorporate it into the 60% Design before submission, effectively circumventing FERC’s intended process in which licensees solicit, respond to, and integrate comments from agencies and stakeholders. We further note that although PG&E requested an Extension of Time on August 30, 2024 to establish September 30, 2025 as the FERC filing date for the 60% Design (with an August 31, 2025 stakeholder review milestone), FERC has never approved that request. We will provide separate comments on PG&E’s most recent Extension of Time request, transmitted to stakeholders by email on September 24, 2025. 2 Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Sincerely, Scott Harding Stewardship Associate American Whitewater Dave Steindorf Hydropower Specialist American Whitewater Matthew Williford Sr. Tribal Chairperson/Cultural Resource Director Konkow Valley Band of Maidu Indians Chris Shutes Executive Director California Sportfishing Protection Alliance Peggy Moak Concow/Yankee Hill Representative Mike Taylor Intervenor 3 Document Accession #: 20251103-5192 Filed Date: 11/03/2025 United States Department of Agriculture Forest Service Plumas National Forest 159 Lawrence Street Quincy, CA 95971-6025 (530)283-2050 Voice (530)534-7984 Text (TDD) Caring for the Land and Serving People Printed on Recycled Paper File Code:2770 Date: September 30, 2025 Anna Urias Hydro License Coordinator I Power Generation Land Planner, Environmental Management Pacific Gas & Electric Company AXUS@PGE.COM RE: POE HIKING TRAIL 60% DESIGN, (FERC NO. 2107) POE HYDROELECTRIC PROJECT Dear Ms. Urias, The Plumas National Forest (PNF) is providing feedback and comments regarding the draft Poe Hiking Trail 60% Design proposal located on the Feather River Ranger District, for the Poe Hydroelectric Project (FERC NO. 2107). The PNF has reviewed the draft 60% design and proposed route location on National Forest System (NFS) lands. The proposed route location on NFS land is aligned with initial ground truthing conducted by PNF staff in April 2024, enabling route sustainability and enhancing recreational trail opportunities in the lower North Fork Feather River Canyon. During the 30 % review process, PNF recommended that the design include planning for an alternate route that avoided private land located on NFS lands. We recommend the 60% design also include planning for an alternate route located on NFS lands to avoid sections of private land. Including and completing planning for an alternate route will enable potential future trail construction implementation to move forward without additional planning delay if PG&E is unable to obtain an easement or right of way to construct private land trail segments. Included below are PNF comments on the 60% design: •The trail should be a minimum class 2 trail. The USFS is not opposed to a higher-class trail for construction, even if it is maintained as a class 2 trail since the higher-class construction will likely be more sustainable long term (plan set page 4). •The plans need to show a typical rolling dip with reverse grade to remove water (plan set page 5). •The plans state that the trail will be full-bench construction. Where will cut material be placed if not a balanced cut-and-fill section? (General construction notes item 7, plan set page 5). Document Accession #: 20251103-5192 Filed Date: 11/03/2025 •The plans state that the cuts will be 3:1 (H:V). Will a 3:1 cut slope catch? If it will catch, what are the lengths of the cuts? (General construction notes item 8, plan set page 5). •The plans use passive language when providing construction directives. Please remove passive wording and state what is required. For example, change “spoils should be mulched” to “mulch spoils”. (General construction notes item 10, plan set page 5). •If boardwalks or bridges are installed on this project, design(s) must go through the Forest Service Regional Office for design review. Design(s) will require independent review providing quality control for the design prior to submission to the Forest Service Regional Office. Final plan sets will require stamping by a Professional Engineer. (plan set pages 6-7). •Bridges must be designed to pass Q100 flows with three feet of freeboard, and must evaluate risk of debris. (plan set page 10). •Wooden boardwalks are susceptible to fire damage. Is there a design to incorporate metal into the main structural members, similar to the proposed bridge? (plan set page 10). •Installed structures must pass the Q100 with appropriate freeboard for hydraulics and debris. All bridges (including foundation designs) must be designed providing an Engineer of record, and incorporate an independent review (a firm or entity that is not involved with the design) of all calculations, drawings and specifications. The design then will be reviewed by the Forest Service Regional Office prior to final approval. The Forest Service requires use of the American Association of State Highway and Transportation Officials Load Resistance Factored Design (AASHTO LRFD) Pedestrian Bridge Design manual as the standard to design pedestrian bridges. •A full archaeological survey of the 60% design plan must be performed. Survey results must be shared with the Feather River Ranger District archaeologist and Konkow Valley Band of Maidu Indians (KVBMI). The Forest Service and KVBMI are aware of important cultural resources inside the current trail design. The resources must be avoided in the 90% plan. It is important cultural resources potentially within the trail design be identified for avoidance. •Twenty stream crossings are identified in the project overview map, however only sixteen stream crossings are addressed in the plan. The Forest Service and US Fish and Wildlife Service (USFWS) plan to visit the site and walk the trail. Unless deemed necessary to mitigate for Federally listed foothill yellow-legged frogs, FYLF bridges may not be necessary and lesser-engineered crossings (e.g., rock armoring) may be more appropriate wherever hiker safety and resource protection can both be achieved. The Forest Service and US Fish and Wildlife cannot comment on the infrastructure needs at each crossing until a site visit and determination of need has been established. Even though the Forest Service cannot comment on specific needs for each crossing until after the normal comment period, with the prolonged and ongoing delays to this project, this delay in response seems reasonable. •After our comments that the 30% plan accessed the river at an identified village site, it appears that river access has been omitted from the 60% plan. This is not an acceptable Document Accession #: 20251103-5192 Filed Date: 11/03/2025 option for the Forest Service. If access to the river is not part of the trail as constructed, people will inevitably create their own access from the trail to the water. This could result in multiple user-created paths to the water and impacts to known or unknown cultural resources. We suggest a clear path accessing the river be included somewhere before the known resource and somewhere after, so that people are led away from the resource. River travelers have used the beach in question without serious impacts for years. If the trail is designed appropriately, looting, vandalism, and other impacts to cultural resources can be avoided. Using vegetation design to conceal the beach from the casual observer may be considered. • Any vegetation clearance needed during project planning and surveys should be the minimum needed to complete planning and surveys with no tree removal, avoiding known sensitive resources, and all cut vegetation being lopped and scattered. The PNF looks forward to continuing to work with PG&E in planning for the proposed Poe Hiking trail. If you have any questions or comments, please contact Public Service Staff Officer, Jonathan Berry at (530) 283-7853 or jonathan.berry@usda.gov, or Chuck James, Forest Recreation Program Manager at (530) 283-7755 or email charles.james@usda.gov. Sincerely, LAURA SCHWEITZER Forest Superviso cc: Loren Everest, Kurt Sable Document Accession #: 20251103-5192 Filed Date: 11/03/2025 LAURA SCHWEITZER Digitally signed by LAURA SCHWEITZER Date: 2025.09.30 17:58:09 -07'00' ENCLOSURE 3 Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Poe Hydroelectric Project, FERC No. 2107 Response to Stakeholder Comments regarding the 60% Design Drawing for the Poe Hiking Trail Stakeholder comments submitted by American Whitewater, Konkow Valley Band of Maidu Indians, California Sportfishing Protection Alliance, and Mike Taylor 1) Comment: As long-standing stakeholders in the Poe Hiking Trail proceeding, we are seriously concerned by PG&E’s attempt to classify the trail as a U.S. Forest Service (USFS) Trail Class 1 or 2 in the 60% design document. This approach is inconsistent with the all-weather requirement of the FERC order, fails to provide adequate protection for natural resources, and contradicts both PG&E’s own 60% design and the advice of trail experts and agency staff. FERC has ordered PG&E to construct an all-weather trail, and this is the clear standard that must guide trail design and construction. Constructing the trail to Class 1 or 2 standards would not provide the required all-weather route while adequately protecting sensitive natural resources. Response: In an order issued by FERC on October 20, 2022, FERC states: “We also clarify that the 2019 Rehearing Order’s requirement for PG&E to construct an “all- weather trail,” if feasible, was not meant to impose any specific Forest Service trail class standard. Rather, “all-weather trail” refers to a trail suitable for year-round use. In this case, we see no reason why construction of a Forest Service Class 1 or 2 trail on Forest Service land would not fulfill the “all-weather trail” specification.” PG&E’s proposal to classify the trail as Class 1 or 2 was based on complying with FERC’s order and reflects an effort to minimize long-term impacts to cultural resources and sensitive habitats, while still meeting the all-weather requirement. These lower trail classes, when properly constructed and maintained, can provide durable access with reduced ground disturbance, fewer structural interventions, and less disruption to aquatic and cultural resources. PG&E’s 60% Design identifies Class 1 or 2 trail design per the FERC order and the Forest Service has stated that the trail should be at minimum a Class 2. PG&E is evaluating Class 3 trail construction measures on trail segments where site-specific conditions may warrant their application for environmental resource protections. 2) Comment: As PG&E’s biological surveys confirm, the trail alignment intersects aquatic habitat supporting foothill yellow-legged frog and other species. Adequate crossings and stable tread are essential not only for recreation access but also for minimizing sedimentation and other impacts to aquatic systems. Class 3 standards are the appropriate level of development to provide a durable, all-weather trail that adequately protects natural resources. As PG&E’s 60% design demonstrates, the Poe Hiking Trail traverses steep, rocky terrain with no fewer than 16 stream crossings. The design notes the need for substantial rock structures, boardwalks, and Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Poe Hydroelectric Project FERC Project No. 2107 multiple bridges (some across wide and erosive channels). These are defining elements of a USFS Class 3 trail, which includes a continuous tread and constructed features necessary to provide all-weather access and protection of natural resources. Response: The proposed Class 1 and Class 2 trail classification for the trail alignment reflects a balanced approach informed by agency coordination and both environmental and cultural surveys. By considering these trail classes, PG&E aims to reduce the extent of ground disturbance, limit the need for extensive structural features, and avoid unnecessary disruption to sensitive habitats and cultural resources. This approach supports durable access while aligning resource protection goals and regulatory obligations. As stated in a previous response, PG&E is evaluating Class 3 trail construction measures on trail segments where site-specific conditions may warrant their application. 3) Comment: The proposed alignment contains multiple switchbacks, particularly at the north end. Switchbacks are often vulnerable to shortcutting by users. The existing switchback near Live Oak Bar on the historic trail alignment has been dropped, and two switchbacks near the Poe Road trailhead have also been eliminated from the proposed alignment. Reducing the overall number of remaining switchbacks and armoring the resulting steeper trail segments, where necessary, would minimize long-term ground disturbance and better protect the trail corridor. Response: PG&E will consider this feedback as part of the ongoing design process, working with Butte County Resource Conservation District (BCRCD) to ensure the necessary trail features are constructed. 4) Comment: Additionally, we reiterate our support for fully protecting cultural resources as identified by the Konkow Valley Band of Maidu Indians. PG&E must commit to incorporating necessary measures into final design and construction, including realignment or restricted access where appropriate, the use of qualified tribal monitors during all ground-disturbing activities, and collaboration on interpretive signage. Stakeholders support the Konkow Valley Band’s request for these protections to be implemented with the seriousness and respect it deserves. Response: PG&E remains committed to working in closely with the Konkow Valley Band of Maidu Indians to ensure that culturally significant sites and resources are properly identified and protected throughout the trail planning and construction process. During cultural surveys conducted in Spring 2025, several cultural sites were identified along the proposed trail alignment. To allow sufficient time for delineation of these sites and to ensure that consultation proceeds in a manner consistent with FERC’s Extension of Time guidelines under 18 C.F.R. § 385.2008, PG&E submitted a timely EOT request on September 30, 2025. The Section 106 consultation process is the formal mechanism through which these protections are being addressed. PG&E will continue to engage with the Konkow Valley Band and other consulting parties under Section 106 to evaluate potential effects, consider avoidance or minimization measures, and ensure that final design and construction reflect the outcome of that process. Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Poe Hydroelectric Project FERC Project No. 2107 5) Comment: Finally, we note that PG&E intends to submit its 60% Design report to FERC today, September 30, 2025—the same date it set as the deadline for stakeholder comments. This approach does not provide PG&E time to review stakeholder input and incorporate it into the 60% Design before submission, effectively circumventing FERC’s intended process in which licensees solicit, respond to, and integrate comments from agencies and stakeholders. We further note that although PG&E requested an Extension of Time on August 30, 2024 to establish September 30, 2025 as the FERC filing date for the 60% Design (with an August 31, 2025 stakeholder review milestone), FERC has never approved that request. We will provide separate comments on PG&E’s most recent Extension of Time request, transmitted to stakeholders by email on September 24, 2025. Response: PG&E acknowledges that the submission date of September 30, 2025, coincides with the deadline for stakeholder comment submittals. Throughout the stakeholder engagement process, it has been consistently communicated that all comments received will be addressed and formally submitted to the Federal Energy Regulatory Commission (FERC). PG&E continues to ensure that all feedback is appropriately considered and incorporated, as applicable, into project planning. Plumas USFS Comments: 1) Comment: The plans state that the trail will be full-bench construction. Where will cut material be placed if not a balanced cut-and-fill section? (General construction notes item 7, plan set page 5). Response: Excess cut material generated in areas of full-bench trail construction will be broadcasted downslope in a manner that minimizes visual and environmental impact. 2) Comment: The plans state that the cuts will be 3:1 (H:V). Will a 3:1 cut slope catch? If it will catch, what are the lengths of the cuts? (General construction notes item 8, plan set page 5). Response: The length of the cuts will be dependent on the vertical height of the slope and terrain characteristics. This will be determined in the 90% Design Drawings. 3) Comment: Wooden boardwalks are susceptible to fire damage. Is there a design to incorporate metal into the main structural members, similar to the proposed bridge? (plan set page 10). Response: If boardwalk installations are deemed necessary at specific locations along the proposed trail alignment, PG&E will coordinate with the U.S. Forest Service. This coordination will ensure that all design and construction components conform to applicable Forest Service standards, specifications, and resource protection protocols. 4) Comment: Twenty stream crossings are identified in the project overview map, however only sixteen stream crossings are addressed in the plan. The Forest Service and US Fish and Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Poe Hydroelectric Project FERC Project No. 2107 Wildlife Service (USFWS) plan to visit the site and walk the trail. Unless deemed necessary to mitigate for Federally listed foothill yellow-legged frogs, FYLF bridges may not be necessary and lesser-engineered crossings (e.g., rock armoring) may be more appropriate wherever hiker safety and resource protection can both be achieved. The Forest Service and US Fish and Wildlife cannot comment on the infrastructure needs at each crossing until a site visit and determination of need has been established. Even though the Forest Service cannot comment on specific needs for each crossing until after the normal comment period, with the prolonged and ongoing delays to this project, this delay in response seems reasonable. Response: PG&E acknowledges that although twenty stream crossings have been preliminarily identified along the proposed trail corridor, only sixteen are currently reflected in the 60% Design Drawing. The total number of watercourse crossings will be verified through a formal wetland delineation process following finalization of the trail alignment. It is further understood that selection of appropriate crossing types will be contingent upon site- specific conditions. These include, but are not limited to, mitigation measures for the foothill yellow-legged frog (FYLF), public safety considerations, and avoidance or minimization of impacts to cultural and natural resources. 5) Comment: After our comments that the 30% plan accessed the river at an identified village site, it appears that river access has been omitted from the 60% plan. This is not an acceptable option for the Forest Service. If access to the river is not part of the trail as constructed, people will inevitably create their own access from the trail to the water. This could result in multiple user-created paths to the water and impacts to known or unknown cultural resources. We suggest a clear path accessing the river be included somewhere before the known resource and somewhere after, so that people are led away from the resource. River travelers have used the beach in question without serious impacts for years. If the trail is designed appropriately, looting, vandalism, and other impacts to cultural resources can be avoided. Using vegetation design to conceal the beach from the casual observer may be considered. Response: The comment outlines PG&E’s primary reason to prevent unfettered river access in the area – protection of sensitive resources. Expanding the intended use beyond hiking could introduce unanticipated impacts related to historic properties, cultural resources, listed species, public safety, water quality, unauthorized use, et cetera. River access is already provided at multiple locations pursuant to the Poe Recreation Management Plan. In fact, three river access facilities have been developed in the immediate vicinity of the proposed hiking trail. Bardees Bar River Access is immediately north, and Poe Beach Trail and Poe Powerhouse River Access are immediately south of the hiking trail alignment. As a reminder, this is a through trail alignment with hiking as the intended use. Previously, the stakeholders appeared to express a greater desire for increased river access than hiking. As a result, PG&E presented a river access concept in lieu of a through trail. The concept involved trailhead(s) with out-and-back or loop trails that would also provide river access. This concept had the added benefit of avoiding two private properties that are crossed by the current, Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Poe Hydroelectric Project FERC Project No. 2107 unauthorized alignment. Unfortunately, the river access concept was not widely supported by stakeholders. If desired, PG&E and stakeholders can revisit the potential out-and-back river access options in lieu of a single hiking trail parallel to the river. Document Accession #: 20251103-5192 Filed Date: 11/03/2025 Document Content(s) PGE20251103_2107_PoeHikingTrail_R2C_60%Design_Ltr.pdf ....................1 PGE20251103_2107_PoeHikingTrail_R2C_60%Design_Enc1.pdf....................3 PGE20251103_2107_PoeHikingTrail_R2C_60%Design_Enc2.pdf....................7 PGE20251103_2107_PoeHikingTrail_R2C_60%Design_Enc3.pdf...................10 Document Accession #: 20251103-5192 Filed Date: 11/03/2025