HomeMy WebLinkAbout12.12.25 Board Correspondence - FW_ Compliance Directives issued in FERC P-2088-000From:Clerk of the Board
To:Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Krater, Sharleen;
Lee, Lewis; Little, Melissa; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Zepeda, Elizabeth
Cc:Nuzum, Danielle; Loeser, Kamie
Subject:Board Correspondence - FW: Compliance Directives issued in FERC P-2088-000
Date:Friday, December 12, 2025 8:21:47 AM
Please see Board Correspondence -
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Subject: Compliance Directives issued in FERC P-2088-000
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On 12/12/2025, the Federal Energy Regulatory Commission (FERC), Washington D.C., issued this document:
Docket(s): P-2088-000
Lead Applicant: South Feather Water & Power Agency
Filing Type: Compliance Directives
General Correspondence
Delegated Order
Description: Letter in response to filing of the Part 12D Inspection Plan and Independent Consultant Team Proposal for the 2026
Comprehensive Assessment of Miners Ranch Development of the South Feather Power Project, under P-2088.
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FEDERAL ENERGY REGULATORY COMMISSION
Office of Energy Projects
Division of Dam Safety and Inspections
888 First Street, NE Routing Code: PJ-13
Washington, DC 20426
(202) 502-6314 Office
December 12, 2025
In reply refer to: P-2088
VIA FERC Service
Mr. Rath Moseley
General Manager
South Feather Water & Power Agency
2310 Oro-Quincy Hwy
Oroville, CA 95966-5226
Subject: Part 12D Inspection Plan and IC Team Proposal, 2026 Comprehensive
Assessment, Miners Ranch Development
Dear Mr. Moseley:
This letter is to acknowledge your November 6, 2025, letter transmitting the Part
12D Inspection Plan and Independent Consultant Team (IC Team) proposal (collectively,
the Inspection Plan) for the 2026 Comprehensive Assessment (CA) of Miners Ranch
Development of South Feather Power Project, FERC No. 2088. We have reviewed the
Inspection Plan and have the following comments that require additional detail to fulfill
the expectations as outlined in Chapter 16 of the Commission’s Engineering Guidelines
for the Evaluation of Hydropower Projects (Guidelines):
1. As discussed during the initial call, the scope for the CA is the entire system
conveying flow from the Ponderosa intake structure to the Kelly Ridge
Powerhouse. While the Inspection Plan does include much of the upstream
conveyance system, it does not include the conveyance system to the point of the
diversion in the scope of the CA. A revised Inspection must include project
discussion, inspection considerations and assessment of IC Team qualification for
the following additional project features: (1) The Ponderosa intake structure, (2)
The Ponderosa to Miners Ranch Canal Tunnel, and (3) the Miners Ranch Canal
headworks (radial gate).
2. The Inspection Plan did not provide sufficiently detailed information for
hydrologic and seismic loading. The Inspection Plan must state the estimated
Document Accession #: 20251212-3020 Filed Date: 12/12/2025
2
magnitude and recurrence intervals both for seismic and hydrologic loadings as
currently understood, along with a description of any identified concerns such as
overtopping the crest of any features (particularly erodible features), and effects on
operation of the project. This information is essential in determining the
experience and expertise necessary on the IC Team for this CA. The revised
Inspection Plan should ensure that it provides all of the information requested in
Section 16-3.3 of the Guidelines. If probabilistic loading estimates for the project
have not yet been completed, it can be acceptable for the Inspection Plan to cite
the current site-specific PGA and the USGS estimates for PGAs for the 475-, 975-,
and 2,475-year recurrence intervals for comparison purposes (and similar
comparative information for hydrologic loading).
3. The Inspection Plan states the entire reservoir rim will be observed during the
inspection, but it does not explain how that inspection will be performed. The
Inspection plan also states no boat inspection is proposed at this time. As stated in
Section 16-6.7.1, the scope of the reservoir rim inspection for a CA must be
sufficient to observe all areas that could contribute to the instantiating conditions
in any identified PFMs, regardless of whether the PFMs are considered credible or
not. The revised Inspection Plan must clarify how the reservoir rim inspection will
be performed and its adequacy.
4. The Inspection Plan lists Mr. Chris Bain as a “Recorder”. Since he will not serve as
a SME for this CA, we consider him to be support staff and not a member of the IC
Team as defined in 18 CFR § 12.31(b). If this is incorrect, clarify his role with the
revised Inspection Plan.
5. The proposed date in the schedule for the CAR Review Meeting appears to be a
typo. Provide the correct date for the CAR Review Meeting with the revised
Inspection Plan.
The resume for Mr. Craig Hall demonstrates that he fulfills the requirements of 18
CFR § 12.31(a), has the appropriate experience and expertise for the project features and
type of inspection, and he is accepted to serve in the role as IC for this project.
The resumes provided for Mr. Nick Oettle, Ms. Ashley Hase and Mr. Caleb
Stewart demonstrate that they meet the requirements of 18 CFR § 12.31(b) and have the
appropriate experience and expertise to serve as Subject Matters Experts on IC Team for
the type of inspection and project features identified.
The Inspection Plan also provides satisfactory documentation to demonstrate that
the PFMA/L2RA risk facilitator, Mr. Matthew Farren, fulfills the requirements of Section
17-4.3.3 and Section 18-5.3, respectively, of the Guidelines. It should be noted that
FERC is not currently enforcing the project risk experience requirements included in
Document Accession #: 20251212-3020 Filed Date: 12/12/2025
3
Section 18-5.3 of the Guidelines. This letter constitutes approval of the Director, Division
of Dam Safety and Inspections, for Mr. Farren to serve as the PFMA/L2RA risk
facilitator.
Per 18 CFR § 12.34(a), you are required to obtain the approval of the IC Team, the
facilitators for the PFMA and L2RA, and the Inspection Plan from the Director, Division
of Dam Safety and Inspections, prior to the performance of this CA. At this time, we are
unable to provide approval of the IC Team and the Inspection Plan pending resolution of
the above comments.
Within 30 days of the date of this letter, provide a revised Inspection Plan that
addresses the above comments. File your submittal using the Commission’s eFiling
system at https://www.ferc.gov/ferc-online/overview. During eFiling make the following
menu selections: Hydro: Dam Safety; Washington, DC; Independent Consultant
Approval Request. The cover page of the filing must indicate that the material was
eFiled. For assistance with eFiling, contact FERC Online Support at
FERCOnlineSupport@ferc.gov, (866) 208-3676 (toll free), or (202) 502-8659 (TTY).
Thank you for your continued cooperation and interest in dam safety. If you have
any questions, please contact me at (202) 502-8486 or yilak.desta@ferc.gov.
Sincerely,
Yilak Desta, P.E.
Civil Engineer
Division of Dam Safety and Inspections
Document Accession #: 20251212-3020 Filed Date: 12/12/2025
YILAK DESTA Digitally signed by YILAK
DESTA
Date: 2025.12.12 10:31:16
-05'00'
Document Content(s)
P-2088 Miners Ranch CA Plan Review.pdf....................................1
Document Accession #: 20251212-3020 Filed Date: 12/12/2025