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HomeMy WebLinkAbout02.17.26 Board Correspondence - FW_ DOCKET CHANGE- Government Agency Submittal submitted in FERC P-803-128 by California Department of Fish and WildlifeFrom: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: DOCKET CHANGE- Government Agency Submittal submitted in FERC P-803-128 by California Department of Fish and Wildlife Date:Tuesday, February 17, 2026 3:40:58 PM Please see Board Correspondence - -----Original Message----- From: 'FERC eSubscription' <eSubscription@ferc.gov> Sent: Tuesday, February 17, 2026 11:06 AM Subject: DOCKET CHANGE- Government Agency Submittal submitted in FERC P-803-128 by California Department of Fish and Wildlife .ATTENTION: This message originated from outside Butte County. 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On 1/30/2026, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.: Filer: California Department of Fish and Wildlife Docket(s): P-803-128 Lead Applicant: California Department of Fish and Wildlife Filing Type: Government Agency Submittal Description: The California Department of Fish and Wildlife submits summary of consultation with Pacific Gas and Electric Company re the Fishery Mitigation Plan for the Butte Canal incident at the DeSabla-Centerville Project under P-803 To view the document for this Filing, click here https://urldefense.com/v3/__https://elibrary.ferc.gov/eLibrary/filelist?accession_num=20260130- 5028__;!!KNMwiTCp4spf!GlobA-fr2EPN6Ir- B_UjE5M2Rb0rUjaw7t2NsRqfio_Z1GopC_xd6FG9Dr6NQtKBs8W-_2axFAvl0A_94bK9b_OfOVEMun-rWpSM$ To modify your subscriptions, click here: https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!GlobA-fr2EPN6Ir- B_UjE5M2Rb0rUjaw7t2NsRqfio_Z1GopC_xd6FG9Dr6NQtKBs8W-_2axFAvl0A_94bK9b_OfOVEMumASyIE_$ ------------------------------------------------------------------------ Please do not respond to this email. 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State of California – Natural Resources Agency GAVIN NEWSOM, Governor DEPARTMENT OF FISH AND WILDLIFE VALERIE TERMINI, Acting Director North Central Region 1701 Nimbus Road Rancho Cordova, CA 95670 www.wildlife.ca.gov Conserving California’s Wildlife Since 1870 January 29, 2026 Via Electronic Submittal (E-File) Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington DC 20426 SUBJECT: DeSabla-Centerville Project No. 803, Summary of Consultation between PG&E and California Department of Fish and Wildlife on Fisheries Mitigation Plan for 2023 Butte Canal Incident (P-803-1211) Dear Debbie-Anne Reese: By letter dated November 19, 2024, the Federal Energy Regulatory Commission (Commission) notified Pacific Gas and Electric Company (PG&E) that the adverse effects on aquatic resources and other environmental effects from the Butte Canal failure on August 9, 2023, were a violation of PG&E’s license for the DeSabla Centerville Project No. 803. The adverse effects included the loss of more than half the spawning population of spring-run Chinook salmon (Oncorhynchus tshawytscha) in Butte Creek in 2023 and anticipated lower adult spring-run Chinook salmon returns in future years caused by the adult mortality in 2023. To address these impacts, the Commission required PG&E to “prepare a plan to mitigate the adverse effects for the loss of 54-59 percent (51-55 adults) of spring-run Chinook salmon, or the assumed quantity of juvenile salmon that would have resulted from the partially-lost 2023 cohort.”2 The Commission identified “habitat improvement, fish stocking, fish passage improvements, funding for habitat improvement projects or brood stock rearing, or other similar measures” as possible “mitigative action[s],” provided “[a]ny such proposal…offset[s] the adverse effects to fishery resources from the [canal failure] and [is] developed in conjunction with the National Marine Fisheries Service (NMFS) and the [California Department of Fish and Wildlife (CDFW)].”3 1 The subject of this letter is the fishery mitigation plan the Federal Energy Regulatory Commission (Commission) directed Pacific Gas and Electric Company (PG&E) to file with the Commission by letter to PG&E dated November 19, 2024, which explained, “The first page of any filing should include docket number P-803-121.” (Letter from Andrea Claros, Federal Energy Regulatory Commission, to Steffanie Maggard, Pacific Gas and Electric Company, dated November 19, 2024, p. 10 (Document Accession #: 20241119-3039).) Hence, the California Department of Fish and Wildlife is including this docket number if needed or useful for tracking. 2 Ibid., p. 7. 3 Ibid. Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 2 CDFW and NMFS met with PG&E multiple times in 2025 to discuss the fishery mitigation plan. The meeting dates were January 15, January 30, February 13, April 3, May 9, May 21, May 28, June 6, June 10, October 234, and December 3. PG&E’s original deadline to file the plan was February 17, 20255, but at PG&E’s request, and with NMFS’s and CDFW’s concurrence, the Commission extended the deadline three times. The current deadline is January 31, 2026. The purpose of this letter is to provide the Commission with a summary of CDFW’s consultation with PG&E on the fishery mitigation plan, emphasizing the significance of losing more than half the Butte Creek spring-run Chinook salmon population in 2023. As the letter explains, CDFW’s position, shared by NMFS, and reiterated to PG&E, is that the only effective mitigation to offset the loss of this cohort is for PG&E to fund a captive broodstock rearing program for Butte Creek spring-run Chinook salmon, as CDFW has proposed. CONSULTATION SUMMARY Fishery Mitigation Plan During initial meetings with PG&E in January 2025, PG&E suggested various measures to improve habitat, including gravel augmentation, fish passage improvement projects, floodplain restoration for juvenile rearing, and fish stocking, to offset the adverse effects to fishery resources from the canal failure. CDFW concluded these measures would not be sufficient to offset these effects, in part because the population is not limited by spawning habitat availability or juvenile rearing habitat.6 CDFW emphasized the fishery mitigation plan should instead focus on actions benefitting the adult spring-run Chinook salmon life stage during the adult holding phase in Butte Creek. The fish harmed by the canal failure were holding adults and impacts to this phase have the most influence over the success of the population as a whole. Given this situation and the insufficiency of PG&E’s proposed mitigation measures, CDFW explained to PG&E early on during consultation that a captive broodstock rearing program was the only effective means to offset the loss of more than half of the 2023 spring-run Chinook salmon population in Butte Creek. 4 NMFS did not attend the meeting on October 23, 2025, due to the shutdown of the federal government. 5 The Commission required PG&E to file the plan within 90 days of the date of the Commission’s letter. Ibid. 6 CDFW’s responses to PG&E’s proposed mitigation measures are below in the section on “PG&E’s Framework for Evaluating Mitigation Alternatives .” Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 3 Water Temperature In addition to the fishery mitigation plan, CDFW expressed to PG&E during the meetings, as well as in a letter previously filed with the Commission on April 30, 2024,7 the need to manage water temperatures in Butte Creek during the summer period in both the near- and long-term after PG&E took Butte Canal offline and informed CDFW that a second Project reservoir would have reduced capacity . Specifically, CDFW proposed actions to PG&E that involved facility modifications to reduce water temperatures in the holding reaches when adults are present and particularly during the hottest months of the summer (i.e., July and August) to reduce temperature-related stress, pathogen outbreaks, and mortality. PG&E agreed to consider some of the temperature mitigation options suggested by CDFW, including the installation of a thermal curtain, and completed temperature modeling to understand if the options would be effective to manage temperatures. During the meeting on May 9, 2025, PG&E presented temperature model results for a proposed thermal curtain and dredging project in DeSabla Forebay . As described by PG&E, the model results showed the proposed projects would not measurably reduce temperatures at the tailrace of the forebay and thence Butte Creek. As a follow-up to the meeting on May 9, 2025, CDFW sent PG&E an email on May 14, 2025, requesting additional temperature modeling for two other potential Project facility modifications, including: 1) the installation of a baffle wall in the forebay, and 2) the installation of a partial pipeline within the forebay. On May 21, 2025, PG&E responded to CDFW by email stating it did not intend to conduct additional temperature modeling because PG&E did not believe modifications to DeSabla Forebay would have a measurable cooling effect in Butte Creek. PG&E further stated that recent temperature modeling results showed modifications in the forebay “would not produce a measurable reduction of water temperatures in the Butte Creek holding reaches; therefore, a temperature reduction project…would not provide a benefit to the fisheries.” PG&E’s Framework for Evaluating Mitigation Alternatives At the meeting on May 9, 2025, PG&E presented a summary of the Framework for Evaluating Mitigation Alternatives for Central Valley Spring -run Chinook Salmon in Butte Creek8 (Framework). The Framework proposed habitat-related actions developed from the estimated quantity of salmon lost by life stage, including creating new holding habitat for 51-55 adults, creating new spawning habitat for 23-24 female adults, and creating new rearing habitat for 34,909-175,436 juveniles. The proposed actions in the Framework included many of the same actions described above that PG&E had initially 7 Letter from Erica Manes, Assistant Chief, CDFW to Debbie-Anne Reese, Secretary, FERC, dated April 30, 2024 (Document Accession #: 20240430-5317). 8 The Framework was included as Enclosure 3 in PG&E’s letter to Debbie-Anne Reese, Secretary, FERC, dated June 18, 2025 (Document Accession #: 20250618-5205). Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 4 suggested in early 2025, even though CDFW had explained to PG&E the actions would not be adequate mitigation. CDFW’s comments on the Framework, some of which CDFW provided PG&E when PG&E summarized the actions in the Framework at the meeting on May 9, 2025, are detailed below. General Comments. The habitat objectives provided in the Framework were based on estimates of the number of holding and spawning adults that were lost due to the canal failure and the assumed number of juveniles that would have been produced by the estimated number of spawning adults. The quantity of mitigation achieved through the habitat objectives is at a ratio of 1:1. In other words, the amount of habitat proposed to be created or restored by PG&E is directly equal to the estimated or assumed number of fish lost. The exact values for the number of adults that died due to the canal failure, the survival rate of incubated eggs from fish that survived to spawn following the canal failure, and juvenile production for the 2023 cohort is unknown. The best estimate CDFW has based on holding and spawning surveys in 2023, is that over half the adult population was lost prior to spawning. The loss of over half the spawning adults in any population of Chinook salmon is detrimental to the long-term viability of that population as the number of adults that return to spawn in subsequent years is reduced over multiple future generations. In Butte Creek, the loss of over half the adult population of spring-run Chinook salmon in 2023 was particularly devastating because the returning adult population that year was significantly lower than average. CDFW does believe it is appropriate to propose habitat restoration actions at a 1:1 ratio of an assumed quantity of any age class as mitigation to offset the lost portion of the adult population in 2023. Further, as explained by CDFW to PG&E in several meetings, habitat restoration opportunities in Butte Creek are not available at a magnitude appropriate to offset this type of population loss and long-term population impacts. The most appropriate mitigation is the contribution to a captive broodstock rearing program, which will be used to supplement the population in future years to offset the loss in 2023. Creation of New Holding Habitat. The Framework proposes creating new holding habitat by increasing existing holding pool volume through placement of large woody debris (LWD) and boulders at the tail of holding pools and by shading existing holding pools by planting riparian vegetation or creating log jams across the surface of the pools. CDFW does not believe any of these actions are feasible in upper Butte Creek and they would not provide a benefit sufficient to offset the loss of more than half of the adult holding population in Butte Creek in 2023. Most of the holding habitat in Butte Creek is in a steep canyon and/or adjacent to private property and access is extremely limited, especially in the upper reaches. Additionally, placement of these materials below pools could create passage barriers to adult salmon, excluding them from pools and making them more vulnerable to warm water temperatures in the holding reaches. Further, Butte Creek can experience rapid increases in flows during certain times of the year and in wet water years high flows can sustain through the early summer which would likely dislodge any LWD or boulders placed across or at the tails of holding pools, potentially creating passage barriers and Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 5 risking property damage downstream. As to planting riparian trees for shading, most of the substrate on the banks of the creek along the holding pools is bedrock not suitable for planting trees and other vegetation, and in the limited areas with suitable substrate, it would take several years for trees to grow tall enough to provide sufficient canopy to shade pools. Another proposed habitat action in the Framework is installation of a segregation weir to disperse holding adults. As discussed above, access to the holding reaches of Butte Creek is difficult and limited and would prohibit the transport of materials to build a segregation weir. Additionally, segregation weirs are notoriously difficult to maintain due to the amount of maintenance required to remove accumulated debris . This action would be cost prohibitive due to materials and maintenance needs with little to no benefit. Finally, because holding adults congregate into the reaches with the most suitable habitat conditions, particularly water temperature, this proposed action could force adults into reaches less suitable for holding, leading to stress and mortality. For these reasons, CDFW does not support and could not maintain a segregation weir in upper Butte Creek. None of the actions in the Framework to increase holding habitat for spring-run Chinook salmon is feasible or would successfully create new holding habitat. As a result, these actions would not adequately mitigate for the loss of holding adults caused by the canal failure in 2023. Creation of New Spawning Habitat. The Framework also proposes creating new spawning habitat through gravel augmentation by stockpiling gravel in the creek at various locations to be dispersed by creek flows, or more strategic placement and spreading of gravel within the channel of the creek. CDFW has been conducting annual spawning surveys for spring-run Chinook salmon in Butte Creek using standardized protocols since 2001. Additionally, current CDFW staff have spent as long as 30 years working within the creek and evaluating the available habitat for Chinook salmon. CDFW data do not indicate that spawning habitat is a limiting factor for the salmon population in Butte Creek, and therefore augmentation of spawning gravel is not needed. Fluctuations in the spawning population of Butte Creek spring-run Chinook salmon year to year are directly related to the number of adults that return to Butte Creek each year and survive over the summer to spawn in the fall; holding adults are the liming factor for the Butte Creek spring -run population, not the amount of spawning gravel available. Additionally, as mentioned earlier, access to upper Butte Creek is challenging, making it difficult to accommodate the transport and placement of heavy loads of gravel. The gravel augmentation action proposed by PG&E to increase spawning habitat is not beneficial, necessary, or feasible, and therefore would not adequately mitigate for the loss of holding adults caused by the canal failure in 2023. Creation of New Juvenile Rearing Habitat. The Framework document also proposes creating new rearing habitat for juvenile salmon through off-channel rearing habitat enhancement in the form of excavation of floodplain and side channels and in-channel Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 6 LWD placement. Juvenile Chinook salmon are not typically observed rearing in upper Butte Creek. Although historically CDFW has observed a very small proportion of the Butte Creek juvenile spring-run Chinook salmon population rearing over summer in upper Butte Creek in the holding reaches, most of the population has been documented demonstrating a young-of-year life history strategy by out-migrating as fry and rearing in lower Butte Creek during the spring. In recent years, few to no juveniles have been observed rearing in upper Butte Creek. The reason for this is not fully understood. However, CDFW believes it may be linked to lack of suitable rearing habitat in upper Butte Creek. In addition, there are no reaches in the upper creek that would be appropriate for excavating floodplain or side channels due to lack of appropriate topography and accessibility issues to implement a project. CDFW has been formally monitoring the emigration and rearing of juvenile salmonids on Butte Creek since the 1990s. Over the years, CDFW and other researchers have identified key rearing areas as the lower portion of Butte Creek in the “Butte Sink” and in the Sutter Bypass below Butte Creek. This lower portion of the watershed is subject to numerous water diversions and is heavily farmed, flows are highly variable depending on water year and water demand, and nearly all the land adjacent to the creek is on private property or leveed and could not be excavated. Finally, as explained above, the entire length of the watershed can experience rapid flow changes due to precipitation events and especially in the lower system, due to spring diversions and fall agricultural field draining. Any LWD placed in the watershed would likely be dislodged and transported downstream during high flow events, potentially risking property damage downstream or creation of fish passage blockages. High flow could also alter the intended topography of a constructed floodplain through sediment deposits and/or scouring. Alternatively, rapid changes in flows, especially flow decreases in the lower watershed could strand juveniles in constructed floodplains. The actions proposed by PG&E to increase juvenile rearing habitat are feasible or necessary and therefore would not adequately mitigate for the loss of holding adults caused by the canal failure in 2023. In sum, for the reasons explained above, CDFW does not believe the Framework includes actions that will adequately mitigate for the loss of over half the Butte Creek spring-run Chinook salmon spawning population in 2023. Such actions will provide negligible benefits or even cause harm to spring-run Chinook salmon. Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 7 CAPTIVE BROODSTOCK REARING PROGRAM PROPOSED BY CDFW As PG&E stated in the meeting on May 9, 2025, and in its email to CDFW on May 21, 2025, PG&E is “open to fish stocking9, funding brood stock, or another mitigation project brought forward by the agencies” as alternative mitigation actions. CDFW reiterated to PG&E in the meeting on May 28, 2025, and by email dated May 29, 2025, that the most appropriate, meaningful, and beneficial mitigation for the loss of over half the adult spring-run Chinook salmon population from the canal failure is a captive broodstock rearing program that includes the partial rehabilitation of an existing hatchery facility to an operable condition plus annual operating costs , which include equipment and labor for a portion of time, and an in-stream monitoring to evaluate the effectiveness of the broodstock program in enhancing and recovering the Butte Creek spring -run population and ensuring no negative effects from the program. Because the loss of more than half the adult spring-run Chinook population in Butte Creek during a year with depressed population numbers (less than 100 adults) had significant impacts on the genetic integrity and viability of the Butte Creek population (i.e., loss of production over multiple generations), PG&E’s contribution to the broodstock program should at a minimum include seven years of program operation beginning in 2026, which encompasses three three-year life cycles since the canal failure in 2023. CDFW estimates the cost of implementing a broodstock program, including the partial rehabilitation of an existing facility that would be used to operate the broodstock program plus annual operating costs and monitoring for seven years, would total approximately $21.2 million. CDFW bases this cost estimate on CDFW’s long-term experience producing and monitoring Chinook salmon, and current staffing and hatchery costs, including current costs to operate a captive broodstock rearing program and conservation hatchery for spring-run Chinook salmon in a different watershed on the San Joaquin River.10 During the meeting on May 9, 2025, and by email on June 10, 2025, PG&E asked CDFW questions on its broodstock program proposal and stated that once PG&E received CDFW’s responses, PG&E would discuss them internally and provide a counter proposal. CDFW’s full response to PG&E’s questions dated June 12, 2025, is 9 During initial meetings with PG&E in early 2025, when PG&E proposed fish stocking as a potential mitigation measure, CDFW explained this would not be an appropriate mitigation measure because traditional fish stocking does not currently occur in Butte Creek 10 As discussed below, CDFW provided PG&E detailed information on these costs on January 20, 2026, which is included in Attachment B, hereto. Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 8 attached hereto as Attachment A. However, CDFW would like to highlight for the Commission the following information in the response to emphasize CDFW’s position. • Spring-run Chinook salmon are listed as threatened under both the California Endangered Species Act (CESA) and federal Endangered Species Act (ESA). In addition, Butte Creek and its drainage system are designated as critical habitat for spring-run Chinook salmon under the ESA. The Butte Creek spring-run population is one of the three remaining independent populations of spring -run in the Sacramento River watershed. Spring-run population trends have been decreasing since the early 2000s. The Butte Creek spring-run population is the most abundant of the remaining populations and therefore is a stronghold for the species. In short, the Butte Creek spring-run population is critically important to the long-term viability and extinction risk of the species in California’s Central Valley. CDFW’s captive broodstock mitigation proposal is based on a deep understanding and knowledge of Central Valley spring -run Chinook salmon, and specifically the Butte Creek population. CDFW Fisheries staff who manage spring-run Chinook salmon populations in Butte Creek have from 13 to 30 years of experience working with Central Valley salmon populations, and some of these staff have spent nearly their entire careers on Butte Creek . • The Butte Creek spawning population has fluctuated over time . However, there are only two notable significant changes in the population observed in the data series over time that are related to watershed -wide changes in infrastructure in the mid-1990s and the recent decline in populations after the most recent drought period. Specifically, adult spring-run population estimates in Butte Creek were relatively low for 30 years in Butte Creek from 1964 through 1994, with annual escapement estimates ranging from 1,371 in 1986 to 14 in 1987, with an average of 983. In 1995, efforts were initiated by water districts, agricultural diverters, and federal, state, and local agencies to rehabilitate multiple facilities in the Butte Creek watershed to restore and improve passage for adult an d juvenile spring-run Chinook salmon. Following the initiation of these projects, the numbers of adult spring-run returning to Butte Creek increased from 1995 to 2022, ranging from 515 in 2017 to 21,58011 in 2021, with an average of 8,627. This population boost was due to facility improvements to provide passage for adults and screening diversion facilities. Prior to these passage improvements, the holding and spawning areas in the upper watershed had only been intermittently passable. Installing fish screens at facilities in the downstream reaches improved juvenile survival. 11 Due to poor holding conditions and disease outbreak facilitated by warm water temperatures and drought conditions, only an estimated 1,807 of the 21,580 holding population survived to spawn in 2021. Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 9 • Following the most recent drought, CDFW observed an estimated escapement of 95 adult spring-run during snorkel surveys in 2023. Post-spawn carcass surveys conducted by CDFW estimated a spawning population in 2023 of 44 fish. This was the lowest population observed since 1987 (n = 14). During the following year in 2024, CDFW estimated an escapement of 51 adult spring -run with 28 spawners. Based on CDFW carcass survey data, CDFW estimated a median annual cohort replacement rate (i.e., the rate at which each subsequent generation of salmon replaces the previous one) of 0.59 for Butte Creek spring - run for the last 20 years (2004-2024). CDFW considers brood years 2023 and 2024 to be cohort failures with cohort replacement rates estimated at 0.034 and 0.015, respectively. For a population that generally follows a three-year life cycle and has a low cohort replacement ratio, having two of three cohorts fail is devastating to the long-term viability of the population. • The Butte Canal failure resulted in the loss of over half the adult spring-run Chinook population in 2023, which contributed to an already collapsing population and further pushed the cohort to failure. Currently, the Butte Creek population is relying on one successful cohort in the last three years (2022), which had a spawning population that was well below the recent 27 -year average (n = 2900), to sustain the population over the next several life cycles and avoid extirpation. CDFW anticipates the future recovery of the two failed cohorts in 2023 and 2024 will take many years because there are no significant in-river facility modifications like the rehabilitation work done in the 1990s or other restoration actions that will boost the number of adults that survive to spawn and contribute to the effective population. • Most spring-run Chinook salmon exhibit a three-year life cycle and the number of adults that return every three years is highly dependent on the number of fish that spawned three years prior. The fish produced from the depressed spawning population in 2021 (n = 1,807) returned in 2024; the snorkel and spawning survey estimates in 2024 were 51 and 28 adult spring-run, respectively. This shows this population did not recover from the low spawning number in 2021 after one life cycle; such a low spawning population will take several life cycles to recover. • The Commission in its November 19, 2024, letter to PG&E states, “Any such (mitigation) proposal should offset the adverse effects to fishery resources from the August 2023 event.” As described above, the loss of more than half of the spawning population in 2023 has significant adverse impacts on the long -term viability of the Butte Creek spring-run Chinook salmon population and the ability of the population to sustain and recover from the failed 2023 cohort, as well as the 2024 cohort. CDFW reiterated to PG&E numerous times in consultation meetings that the impacts of the canal failure span beyond the death of an estimated 51-55 adult fish. The death of these fish pushed the cohort to failure, reduced the cohort replacement ratio, and pushed the population closer to extirpation. As CDFW explained above, the Butte Creek spring-run population is Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 10 one of three remaining independent, naturally produced populations of spring-run remaining in California’s Central Valley. Butte Creek is the largest of these three populations and considered a stronghold for the species. The decimation of the Butte Creek population will ultimately lead to the extirpation of the population and increase the extinction risk of this listed species. • The adult spawning life stage of Chinook salmon is undoubtedly the most important phase of the life cycle because it determines the maximum potential production for each brood year. There are many factors that affect salmon survival over the duration of their life cycle, including stream flows, water quality, passage obstacles, ocean conditions, predation, harvest, and disease, among other factors. However, the maximum amount of potential production is directly related to the number of spawning females in a pop ulation. The elimination of over half the spawning adults in 2023 due to the Butte Canal failure greatly reduced the production potential of the 2023 cohort and significantly decreased the number of juveniles produced, thereby imperiling the next generation, reducing genetic diversity, and making the population as a whole more susceptible to the other stressors and factors. • The purpose of the broodstock program proposed by CDFW is to conserve the genetic lineage unique to Butte Creek spring-run and to enhance the recently depressed population via supplementation through a captive broodstock rearing program and eventual conservation hatchery. As CDFW stated in the meeting with PG&E on June 10, 2025, CDFW’s current Butte Creek spring-run Chinook salmon captive broodstock rearing program is in its infancy. Currently, CDFW has captive juvenile Butte Creek spring-run Chinook being held temporarily at the University of California at Davis since late 2023. However, the fish will soon reach spawning maturity and there is an urgent need to further develop the program that includes a facility with the capacity to operate the program, implement program operation, and conduct population mon itoring to evaluate the program’s effectiveness. • The $21.2 million under CDFW’s broodstock program proposal includes the costs to temporarily partially rehabilitate a portion of an existing state hatchery facility within the Butte Creek watershed on the Feather River (Feather River facility), operate the broodstock program for seven years, and conduct population monitoring for seven years. The costs include partial rehabilitation of the facility because CDFW does not have an existing facility that would meet the purpose of the proposed broodstock program. The seven years account for a minimum of three life cycles, which is nine years in total (three-year life cycle multiplied by three life cycles). However, two years of one of the three life cycles have occurred since 2023, which reduced the time to seven years. Instream monitoring is required for both broodstock collection and to provide data on the outcome of the broodstock program. Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 11 • The impact of the loss of over half the Butte Creek adult spring-run population in a year of low returns had a significant impact on 2023 production, the next generation (2026), the next several life cycles (2026, 2029, 2032), and long -term viability of the population. For these reasons, CDFW’s position is that PG&E’s contribution to the broodstock program based on CDFW’s cost estimate is the most appropriate form of mitigation to offset the adverse impacts of the canal failure on the Butte Creek spring-run population and to help ensure the population’s viability in the future. PG&E’S COUNTER PROPOSAL On June 16, 2025, PG&E sent an email to CDFW acknowledging the additional details CDFW provided on June 12, 2025, related to its broodstock program proposal, and explaining PG&E did not have a timeline for its counter proposal but would provide one the following week. PG&E also stated its intent to request more time from the Commission to file a fishery mitigation plan (until September 18, 2025) to continue to discuss funding for a captive broodstock program with CDFW and NMFS. CDFW did not hear back from PG&E about PG&E’s counter proposal until September 15, 2025, three days prior to the new due date for the fishery mitigation plan. In its September 15, 2025, email, PG&E stated it was not PG&E’s responsibility to provide funding to rehabilitate the Feather River facility as CDFW proposed or to fund a program that will “far exceed in years and juvenile production the mitigation requirements for the Butte Canal failure.” PG&E also stated it did not agree that seven years of monitoring and operations are necessary to meet the requirements of the Commission’s November 19, 2024, letter. In the same email, PG&E provided a counter proposal for funding a broodstock program based on a per fish cost analysis for juvenile salmon. Specifically, the cost analysis estimated a value of $1.00 to $1.50 per juvenile salmon multiplied by an estimated production loss in 2023 of 175,000 juveniles for a total funding contribution to a broodstock program of $175,000 to $262,500. CDFW reviewed PG&E’s funding proposal and cost analysis and determined PG&E used financial information related to the Hatchery and Inland Fisheries Fund (HIFF) in the California State Budget for 2025-2026 to develop its cost analysis. CDFW explained to PG&E by email dated September 17, 2025, and again in the meeting on October 23, 2025, that the funding source PG&E used to develop its funding proposal and cost analysis (i.e., HIFF) was not relevant to the operation of a captive broodstock rearing program and severely underestimated the actual costs of rearing Chinook salmon generally. Specifically, HIFF funds are used for production of trout and inland salmon for recreational harvest within inland non-anadromous waters. HIFF funds do not account for full costs associated with hatchery production and tagging of anadromous Chinook salmon in the Central Valley. A captive broodstock program requires multi-year care of fish from juvenile to adulthood to the successful spawning of broodstock. HIFF funded hatcheries do not raise fish to adulthood; this has implications for both feeding and care Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 12 as well as holding facilities. The focus of the Commission’s November 19, 2024, letter was for PG&E to mitigate the adverse effects for the loss of wild, non -harvestable, CESA- and ESA-listed spring-run Chinook salmon, and not harvestable trout or inland salmon. On November 10, 2025, PG&E requested additional information from CDFW, including an estimated cost to produce 35,000-175,000 fry based on fecundity and survival rates from peer-reviewed resources, a scaled broodstock program duration, a breakdown of short-term captive broodstock costs, and clarification on any “assumptions” CDFW is using to justify its cost estimates, particularly if those assumptions extend beyond the scope of the Commission’s mitigation requirement (e.g., species recovery and multi- year population support). CDFW’s comments regarding PG&E’s November 10, 2025, information request, some of which CDFW made to PG&E in the December 3, 2025, meeting, are below. Fecundity and survival rates are variable year by year and most of the literature or available scientific data for spring-run Chinook salmon is related to hatchery Chinook salmon and is already publicly available for PG&E to research. Specific fecundity and survival data for the Butte Creek spring-run Chinook salmon population are not available currently. Further, CDFW does not know the exact number of adults that died due to the canal failure and the equivalent loss in production, and CDFW does not know the condition and survival rate of incubated eggs from fish that survived to spawn following the canal failure. The amount of sediment deposition in the spawning gravel from the canal failure is not known. For these reasons, CDFW does not feel comfortable assuming a juvenile production resulting from the 2023 cohort or using juveniles as a proxy to estimate the costs of funding a broodstock program or other mitigation proposals. Additionally, CDFW cannot provide a scaled program duration as requested by PG&E because the program will need to be operated for multiple life cycles (a minimum of three, or 9 years) to recover the impacted population in 2023. The cost estimates to develop and operate a captive broodstock program CDFW provided to PG&E in the May 28, 2025, meeting and in a May 29, 2025, email from CDFW to PG&E were based on an existing spring-run Chinook salmon captive broodstock program and conservation hatchery. CDFW is not making “assumptions” to justify its cost estimates. Further, CDFW does not agree that contribution to multiple years of a broodstock program extends beyond the scope of the Commission’s mitigation requirements because the “adverse effects” for the loss of more than half the 2023 cohort due to the canal failure includes the loss of future generations.12 12 See Letter from Andrea Claros, Federal Energy Regulatory Commission, to Steffanie Maggard, Pacific Gas and Electric Company, dated November 19, 2024, supra, p. 7. (Document Accession #: 20241119-3039), requiring PG&E to “prepare a plan to Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 13 CDFW explained that while it could provide more detailed information related to the annual operation and maintenance costs of a broodstock facility and program using similar types of programs as examples, CDFW cautioned against using this information to estimate a cost “per fish.” As mentioned above, captive broodstock rearing programs operate very differently than traditional fish hatcheries and therefore developing a cost per fish estimate based on trout or fall-run chinook salmon which are all released as juveniles would not be appropriate or accurate. For example, a traditional Chinook salmon hatchery operates on a seasonal cycle, collecting and spawning returning adults during the fall, incubating eggs during the winter, and raising juveniles to a specific size for release winter through spring. Adults are euthanized following spawning and all juveniles are released; no fish are retained for future years in traditional hatchery operations. By contrast, a captive broodstock rearing program collects juvenile fish annually from the natural environment and grows them to adulthood over multiple years, spawns the grown adults in subsequent years, retains a portion of eggs for the additional production cycles, and releases a portion of the eggs and/or juveniles to designated streams. Additionally, in a captive broodstock rearing program, spawning pairs may include individuals from different brood years. Further, some adult males might be retained after spawning to spawn again in multiple years. This practice incorporates multiple brood years (i.e., generations) to increase genetic diversity and avoid genetic bottlenecks in the population. Captive broodstock programs require year- round operation to accommodate multiple life cycles and ages of captive fish over multiple years. The development of a cost per fish estimate would be extremely complicated, if not impossible, to accurately incorporate costs of husbandry of fish of multiple ages and life stages across multiple broo d and operating years. Therefore, PG&E’s contribution to a captive broodstock rearing program for spring-run Chinook salmon should be based on the cost of program implementation, annual operation, and monitoring, not an estimated cost per fish. CURRENT STATUS CDFW last met with PG&E on January 21, 2026 . Just prior to the meeting on January 20, 2026, CDFW provided PG&E with detailed information to support CDFW’s $21.2 million cost estimate for its proposed captive broodstock rearing program . This information is included in Attachment B, hereto. During the meeting, which was very brief, PG&E explained that it disagrees with CDFW’s understanding on the scope of the mitigation described in the Commission’s November 19, 2024, letter to PG&E. According to PG&E, it is only responsible for mitigating for the estimated loss of 51-55 adult Chinook salmon or the estimated equivalent juvenile production from those adults and intends to meet this obligation by filing the Framework discussed above. PG&E mitigate the adverse effects for the loss of 54-59 percent (51-55 adults) of spring-run Chinook salmon, or the assumed quantity of juvenile salmon that would have resulted from the partially-lost 2023 cohort.” (Emphasis added.) Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 14 acknowledged that CDFW and NMFS do not support the habitat related actions in the Framework and explained that in PG&E’s evaluation, up to $5.1 million could be made available for use towards a captive broodstock rearing program or other suitable habitat mitigation projects. This despite the fact that: 1) as discussed above, in the numerous meetings CDFW has had with PG&E to discuss the fishery mitigation plan, CDFW has made it clear that habitat mitigation projects will not “offset the adverse effects to fishery resources from the [canal failure],” as the Commission requires13; 2) CDFW has told PG&E multiple times that contribution to a captive broodstock rearing program is the most appropriate mitigation action to offset the adverse effects of the canal failure on the Butte Creek spring-run Chinook salmon population; and 3) $5.1 million is insufficient to fund a captive broodstock rearing program to offset the loss for spring -run adult Chinook salmon in Butte Creek. PG&E’s proposal is contrary to the explanation PG&E provided the Commission to support its last extension request14; and in addition to ignoring CDFW’s position regarding the inadequacy of habitat mitigation projects, PG&E’s proposal is contrary to the Commission’s directive that “mitigative action[s]…offset the adverse effects to fishery resources from the [canal failure] and [are] developed in conjunction with the [NMFS] and [CDFW].”15 If PG&E files the proposal described above, CDFW urges the Commission to find it insufficient for the same reasons CDFW explained to PG&E, as detailed above. In addition, even if PG&E’s $5.1 million could be used for the captive broodstock rearing program CDFW has proposed, as CDFW’s cost estimate shows (see Attachment B), it would be insufficient even just to operate the program. As CDFW has reiterated to PG&E, this estimate is based on the fact that operating a captive broodstock rearing program for natural-origin spring-run Chinook salmon is much higher than operating a traditional hatchery program and because there are no existing facilities that can be 13 Letter from Andrea Claros, Federal Energy Regulatory Commission, to Steffanie Maggard, Pacific Gas and Electric Company, dated November 19, 2024, supra, p. 7. 14 See Order Granting Extension of Time to File Butte Creek Fisheries Mitigation Plan (Issued November 26, 2025) (Document Accession #: 20251126-3056), pp. 2-3 (“The licensee is requesting an extension of time until January 31, 2026, to file the Plan with the Commission. The licensee states that it has been consulting extensively with the agencies on the Plan since its previous extension request and all parties agree that a captive broodstock program is an acceptable means of mitigation ; however, it and the agencies are struggling to come to a consensus on the details and scope of the program. Therefore, the licensee requests additional time to resolve the differences in opinion, arrive at a mutually agreeable approach for a captive broodstock program and develop a Plan.”) (Emphasis added.) 15 Letter from Andrea Claros, Federal Energy Regulatory Commission, to Steffanie Maggard, Pacific Gas and Electric Company, dated November 19, 2024, supra, p. 7. (Emphasis added.) Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 15 used for the program proposed by CDFW, the least expensive option is to partially rehabilitate the existing Feather River facility. Thank you for your attention to this matter. If you have any questions or need more information, please contact Anna Allison at anna.allison@wildlife.ca.gov or (916) 272- 4373. Sincerely, Morgan Kilgour Regional Manager, North Central Region Attachments (2) CDFW Anna Allison (anna.allison@wildlife.ca.gov) Colin Purdy (colin.purdy@wildlife.ca.gov) Beth Lawson (beth.lawson@wildlife.ca.gov) Stephen Puccini (stephen.puccini@wildlife.ca.gov) NMFS Cathy Marcinkevage (cathy.marcinkevage@noaa.gov) Ellen Roots (ellen.roots@noaa.gov) PG&E Janet Walther (jmw3@pge.com) Ed Cheslak (efc3@pge.com) Catalina Reyes (cerh@pge.com) Sky Ramirez-Doble (s9rv@pge.com) Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 16 ATTACHMENT A Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 17 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 18 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 19 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 20 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 21 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 22 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 23 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 24 ATTACHMENT B Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 25 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 26 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 27 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 28 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 29 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 30 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 31 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 32 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 33 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 34 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 35 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 36 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 37 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 38 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 39 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 40 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 41 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 42 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 43 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 44 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission January 29, 2026 Page 45 Docusign Envelope ID: C770C27D-AA68-4502-AC10-A02D787826FEDocument Accession #: 20260130-5028 Filed Date: 01/30/2026 Document Content(s) CDFW Ltr to FERC Re Consultation for Fishery Mitigation Plan P-803.pdf....1 Document Accession #: 20260130-5028 Filed Date: 01/30/2026