HomeMy WebLinkAbout10.28.24 Board Correspondence - FW_ Environmental and Recreational Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al.From:Clerk of the Board
To:Bennett, Robin; Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts, Melissa; Lee, Lewis; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug; Zepeda,
Elizabeth; Loeser, Kamie
Cc:Nevers, Dawn
Subject:FW: Environmental and Recreational Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al.
Date:Wednesday, October 30, 2024 4:57:23 PM
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Subject: Environmental and Recreational Compliance Report submitted in FERC P-2107-000 by Pacific Gas and Electric Company,et al.
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On 10/24/2024, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington D.C.:
Filer: Pacific Gas and Electric Company
Pacific Gas & Electric Company (as Agent)
Docket(s): P-2107-000
Lead Applicant: Pacific Gas and Electric Company
Filing Type: Environmental and Recreational Compliance Report
Description: Pacific Gas and Electric Company submits requests for a temporary amendment from the minimum instream flow re the Poe Hydroelectric Project under P-2107.
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Power Generation
300 Lakeside Drive
Oakland, CA 94612
Mailing Address:
P.O. Box 28209
Oakland, CA 94604
October 24, 2024
Via Electronic Submittal (E-File)
Debbie-Anne Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, N.E.
Washington, D.C. 20426
RE: Poe Hydroelectric Project, FERC No. 2107
Poe Dam, NATDAM No. CA00328
Minimum Instream Flow and Tributary Access Monitoring Temporary
Amendment Request
Dear Secretary Reese:
This letter respectfully requests a temporary amendment from the minimum instream flow
(MIF) requirements from June 1, 2025, through November 1, 2025, for Pacific Gas and
Electric Company’s (PG&E) Poe Hydroelectric Project, Federal Energy Regulatory
Commission (FERC) No. 2107 (Project). The MIF temporary amendment will impact
tributary access monitoring; therefore, PG&E also respectfully requests to defer the
additional year of Poe tributary access monitoring, if 2025 is classified as a Critically Dry
Water Year Type. The MIF temporary amendment is needed to address maintenance
recommendations from the 2019 California Department of Water Resources Division of
Safety of Dams (DSOD) annual inspection; specifically, recoating the radial bypass gate
and replacement of seals. Additionally, the MIF temporary amendment will allow PG&E to
replace the radial bypass gate hoist and controls for flow use. These items are critical to
maintain the radial bypass gate and hoist system functionality. The recoating of the radial
bypass gate, replacement of the seals, radial bypass gate hoist, and controls will all occur
under this requested MIF temporary amendment.
License Requirements
On December 17, 2018, FERC issued a new license to PG&E for the Project. The license
incorporates California State Water Resources Control Board (SWRCB) Water Quality
Certification (WQC) Conditions and United States Department of Agriculture, Forest
Service (Forest Service) 4(e) Conditions were included as appendices A and B,
respectively. WQC Condition 1 and 4(e) Condition No. 23 specify MIFs. These MIFs are
determined by Water Year Type and month (Table 1).
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 2
Article 401 of the Poe license contains the following requirement for planned deviations
from license requirements:
Three Water Board conditions in Appendix A and three Forest Service conditions in
Appendix B would allow the licensee to temporarily modify project operations under
certain conditions. The Commission must be notified prior to implementing such
modifications, if possible, or in the event of an emergency, as soon as possible, but
no later than 10 days after each such incident. The California Department of Fish
and Wildlife and the U.S. Fish and Wildlife Service must also be notified prior to
implementing any modifications to minimum flows required by certification condition
no. 1 and Forest Service condition no. 23 (Part 1).
Table 1. Minimum streamflow measured in cubic feet per second (cfs) as determined by
Water Year Type and month.
Month Water Year Type2
Wet Normal Dry Critically Dry
October 250 250 180 180
November 275 275 180 180
December 300 300 180 180
January 325 300 180 180
February 350 325 225 225
March 350 350 300 300
April 400 400 325 300
May 500 400 350 300
June 500 400 350 300
July 500 400 350 300
August 500 400 350 300
September 400 350 300 250
The Poe Ramping Rate Plan (RRP), approved by FERC on March 27, 2023, states the
following ramping limits:
Up-Ramping Maximum
• October 1 through February 28/29 - 400 cfs/hour up-ramp
• March 1 through September 30 - 250 cfs/hour up-ramp
Down-Ramping Maximum
• Year-Round - 150 cfs/hour down-ramp
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 3
The RRP also contains two Spill Recession Protocols (Table 2). These spill recession
protocols are to be initiated as follows:
1. From April 15 through July 31, for any high flow spill event that exceeds 800 cfs,
PG&E will implement a recession protocol with an initial RTU [Remote Terminal
Unit(s)] setpoint of 800 cfs; when spills recede to this flow, PG&E will meet or
exceed this flow for the first day and thereafter reduce the outflow target at a
rate not to exceed 10% per day until baseflow is reached…
2. Beginning midnight May 15, if spill has been continuously over 1,200 cfs since
May 1, PG&E will implement an extended recession protocol with an initial RTU
setpoint of 1,200 cfs; when spills recede to this flow, PG&E will meet or exceed
this flow for the first 7 days, and thereafter reduce the outflow target at a rate not
to exceed 10% per day until total release reaches 800 cfs; PG&E will hold the
800 cfs target for 7 days, after which PG&E will reduce the outflow target at a
rate not to exceed 10% every 2 days until baseflow is reached…
Table 2. Spill Recession Protocols
Target Flow, total releases below Poe Dam (cfs)
Day Protocol 1: Trigger Flow is
800 cfs
Day Protocol 2: Trigger Flow is
1,200 cfs sustained
1 800 1-7 1,200
2 720 8 1,080
3 648 9 972
4 583 10 875
5 525 11-17 800
6 472 18-19 720
7 425 20-21 648
8 383 22-23 583
9 344 24-25 525
10 310 26-27 472
… 10% every day until baseflow
based on WY type
… 10% every two days until
baseflow based on WY Type
Background
At the 2019 Annual DSOD Inspection of Poe Dam, DSOD noted that the radial bypass
gate needed to be recoated and have the seals replaced. During 2020, the Poe Dam radial
bypass gate hoist experienced a mechanical failure causing a MIF deviation. Repairs have
been made to the hoist. Additional repairs are needed to increase reliability and operating
frequency. PG&E will install a cofferdam to compete both projects and the utilization of the
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 4
cofferdam will require the MIF to temporarily be lowered to 100 cfs, from June 1, 2025,
through November 1, 2025.
The radial bypass gate project was originally scheduled for 2023 and PG&E submitted an
authorization request to FERC’s San Francisco Regional Office (SFRO) on May 10, 2023.
To support this work, PG&E submitted an amendment request to FERC’s Division of
Hydropower Administration and Compliance (DHAC) on April 7, 2023, and supplemented it
on May 30, June 9, July 3, and July 7, 2023. On July 28, 2023, DHAC approved the
amendment request; however, SFRO did not approve PG&E’s authorization request.
On August 24, 2023, SFRO provided comments on PG&E’s authorization request. PG&E
responded to SFRO on November 10, 2023, SFRO responded to PG&E on February 14,
2024, and PG&E provided three additional responses dated February 14, 2024, April 5,
2024, and July 1, 2024. PG&E believes that all SFRO’s comments have been satisfactorily
addressed and is waiting for SFRO’s approval of the work.
SWRCB Condition 13 and Forest Service 4(e) Condition 23 required PG&E to create and
file with FERC a Tributary Access Monitoring Plan, which was approved by FERC July 23,
2020. The objective of this plan is to characterize the response to the new license -required
flows on various resources through monitoring and analysis. In an order dated July 28,
2023, FERC required PG&E to conduct an additional year of Poe tributary access
monitoring and seek agreement of the substitute monitoring year with the Californi a State
Water Resources Control Board, Forest Service, United States Fish and Wildlife Service,
and California Department of Fish and Wildlife (collectively, Agencies). PG&E and the
Agencies agreed to conduct tributary monitoring during the next Critically Dry Water Year
Type to observe passage during lower license required MIF. This was communicated to
FERC in a letter dated July 3, 2024.
On October 15, 2024, PG&E filed an authorization request to replace the radial bypass
gate hoist and controls. PG&E has yet to receive a response from SFRO on this request.
Operating Plan
PG&E complies with MIFs by releasing water from the radial bypass gate. However, with
the cofferdam installed upstream of the radial bypass gate, PG&E can only provide
streamflow through an existing 36” pipe. The pipe capacity allows a release of
approximately 100 cfs to 150 cfs, depending on reservoir elevation. This pipe will be left
fully open to allow the highest streamflow possible. However, to preserve some operational
flexibility and allow a compliance buffer, PG&E respectfully requests for MIF to be lowered
to 100 cfs from June 1, 2025, through November 1, 2025 , measured at NF23.
PG&E plans to implement a multi-week down-ramp at a target rate of one foot per three
weeks, measured at NF23, from the license MIF to 100 cfs plus buffer. Operationally, this
will be met by making downward adjustments in flow once or twice per week. The flow
adjustments will not exceed the maximum hourly down-ramp rate of 150 cfs/hour. If Spill
Recession Protocol 1 or 2 is initiated, there may not be enough time to implement the
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 5
multi-week down-ramp target rate of one foot per three weeks. In this instance, PG&E
requests the flexibility to follow Spill Recession Protocol 1 or 2 of 10% flow reduction every
day or every two days, respectively, until the amended MIF of 100 cfs (plus buffer) is
reached. These proposed ramping rates are more conservative than the license required
ramping rates. Consequently, PG&E will comply with the license required ramping rates
during this temporary amendment of MIF.
The down-ramp will be initiated with adequate time to reach the amended flow before
construction begins in August. There is some uncertainty in the necessary length of the
ramp period as the starting summer MIF will not be known until the May Bulletin 120 sets
the final Water Year Type (WYT).
Agency Consultation
PG&E began agency consultation for this flow modification request by meeting with the
SWRCB, Forest Service, United Stated Fish and Wildlife Service (USFWS), and California
Department of Fish and Wildlife (CDFW) (Agencies) on July 29, 2024. The SWRCB and
Forest Service were sent the temporary amendment request on September 9, 2024, and
CDFW and USFWS were notified of the temporary amendment request concurrently.
The SWRCB requested on September 11, 2024, that the temporary WQC amendment be
sent to the SWRCB Executive Director. Comments from USFWS were received
September 13, 2024, and September 27, 2024. PG&E held a meeting with the SWRCB on
October 7, 2024, to clarify the temporary WQC amendment request. Comments were
received from CDFW and the Forest Service on October 9, 2024 , requesting a meeting to
be scheduled with PG&E to further discuss the temporary amendment. The amendment
request was sent to the SWRCB Executive Director on October 10, 2024, and resubmitted
on October 15, 2024. PG&E emailed the Agencies on October 15, 2024, to schedule a
meeting to discuss comments on the temporary amendment requests.
Biological Evaluation and Environmental Impacts
PG&E’s staff scientist and biologists have reviewed the potential adverse effects to the
resources in the Poe Bypass Reach that may result from this MIF temporary amendment.
Their review is summarized in the sections below by resource.
Water Quality
The impacts to water temperature resulting from the flow variance are not known and are
likely to be non-detectable.
Flows in the North Fork Feather River are typically low in the summer and have a
significantly reduced capacity to transport fine sediments. So, the flow variance will not
result in sediment loads significantly different from those during the summer months
without the flow variance.
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 6
Amphibians
The North Feather Distinct Population Segment of the f oothill yellow-legged frog (Rana
boylii; FYLF) was listed as threatened by USFWS on September 28, 2023. Surveys for
FYLF are ongoing within the Poe Project (Poe Amphibian Monitoring Plan), having
occurred yearly since relicensing studies were first implemented in 2000. FYLF are known
to breed throughout the Poe Reach, including at Monitoring Site 7 just downstream of the
work area. Egg laying has occurred between mid-April through early-June, with onset and
duration dependent on spring flows. Tadpoles can be present in the river through August
but are mobile and most are capable of moving with changing flows.
The lower MIF proposed by this amendment should not impact FYLF breeding or rearing,
however the transition from the license required baseflow to the construction required flow
could cause stranding of egg masses and/or tadpoles. To minimize impacts and protect
these vulnerable lifestages, PG&E will not exceed a ramping rate of one foot over three
weeks or 10% flow reduction every two days (Spill Recession Protocol 2). Once WYT is
designated, back-calculations will be made to determine a June or July start date to begin
implementing the down-ramp, allowing the MIF to be reached prior to the start of
construction.
During the down-ramp performed in 2023 (prior to the USFWS listing), PG&E observed
stranding of 1% of tadpoles while 12% of tadpoles observed were rescued from stranding
and moved out of harm’s way. The down-ramp has the potential to strand egg masses
and/or tadpoles the amendment may affect, and is likely to adversely affect, FYLF. PG&E
will request to be FERC’s non-federal representative to conduct formal Section 7
consultation with the USFWS. This will allow PG&E and the USFWS to develop
conservation measures to minimize effects and to allow for FYLF lifestages to be moved
out of harm’s way, should potential stranding be observed during the down-ramp.
Fish
Based on 2021 – 2023 fish surveys in the Poe Bypass Reach, fishes that occur in the
reach include mostly native fish species - Sacramento sucker (Catostomus occidentalis),
hardhead (Mylopharodon conocephalus), Sacramento pikeminnow (Ptychochelius
grandis), riffle sculpin (Cottus gulosus), and resident rainbow trout (Oncorhynchus mykiss),
specked dace (Rhinichthys osculus). Non-native species observed included smallmouth
bass (Micropterus dolomieu). Hardhead are a Forest Service sensitive species and riffle
sculpin are a CDFW species of special concern.
The timing of this project will not affect the breeding season which generally is from
February – April for all native fish species in the Poe Bypass Reach. The amendment is
planned to start in the June to July timeline during the rearing season for young of the
year. During this period, the young of the year will be big enough to respond to the
proposed flow down-ramp.
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 7
As described in the water quality section, temperature, turbidity, or sedimentation is not
expected to impact fishes or other aquatic organisms.
Conclusion
PG&E respectfully requests a temporary amendment to lower MIF to 100 cfs, from June 1,
2025, through November 1, 2025. This proposed MIF has been analyzed by PG&E
biologists and is twice as high as the MIF from the previous license, which was 50 cfs
year-round. The Project operated at those flows for over 50 years and no significant
environmental impacts were observed in the reach.
If 2025 is a Critically Dry Water Year Type, PG&E respectfully requests that the additional
year of monitoring agreed to by Agencies and PG&E be delayed until the next Critically
Dry Water Year Type. This is consistent with the goals of the Tributary Access Monitoring
Plan. The same amount of monitoring will be collected, the schedule will just be pushed
into the future.
These temporary amendments are needed to address recommendations from the 2019
DSOD inspection and to perform equipment replacement for increased reliability and
improved operating frequency. Once concurrence from the SWRCB and Forest Service
are obtained, PG&E will file those letters with FERC. To accommodate the construction
schedule, please respond with approval by January 31, 2024.
Documentation of agency consultation is provided as (Enclosure 1).
For questions, please contact PG&E’s license coordinator, Anna Urias, at (530) 201-1961.
Sincerely,
Matthew Joseph
Supervisor, Hydro License Management
Enclosure:
1. Agency Consultation
cc: See Attached List
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Debbie-Anne Reese, Secretary
October 24, 2024
Page 8
cc: via email w/enclosure
Nathan Fish, SWRCB – Nathan.Fish@waterboards.ca.gov
Jessica Dyke, SWRCB – Jessica.Dyke@waterboards.ca.gov
Leslie Edlund, Forest Service - leslie.edlund@usda.gov
Kurt Sable, Forest Service – kurt.sable@usda.gov
Loren Everest, Forest Service – loren.everest@usda.gov
Erika Brenzovich, Forest Service - erika.brenzovich@usda.gov
Dawn Alvarez, Forest Service - dawn.alvarez@usda.gov
Leigh Bartoo, USFWS - Aondrea_Bartoo@fws.gov
Beth Lawson, CDFW - Beth.Lawson@wildlife.ca.gov
Michael Maher, CDFW – Michael.Maher@wildlife.ca.gov
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
ENCLOSURE 1
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
From:Urias, Anna
To:Sable, Kurt - FS, CA; Fisch, Nathan@Waterboards; Dyke, Jessica@Waterboards; Everest, Loren - FS, CA; Bartoo,
Aondrea; Brenzovich, Erika - FS, CA; Alvarez, Dawn - FS, CA; Lawson, Beth@Wildlife; Maher, Michael@Wildlife;
Edlund, Leslie - FS, CA; Hopson, Rick - FS, CA; Phipps, Jacqueline - FS, CA
Cc:Ramirez-Doble, Sky; McKay, Jim; Bennett, Jim; Reyes, Catalina; Herman, Andie; Stevens, Kevin; Salve, Rohit
Bcc:Joseph, Matthew
Subject:RE: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy Regulatory Commission
(FERC) No. 2107
Date:Tuesday, October 15, 2024 10:53:00 AM
Attachments:Att. 1-Poe MIF Variance.pdf
image002.png
image003.png
image004.png
image005.png
Hi folks,
This email presents a meeting invite to discuss PG&E’s minimum instream flow and tributary
access monitoring temporary amendment requests (attached) for PG&E’s Poe Hydroelectric
Project, Federal Energy Regulatory Commission (FERC) No. 2107.
Please use the doodle link below to select your availability for a meeting by the end of this
week.
https://doodle.com/meeting/participate/id/e53kWYYb
Regards,
A N N A U R I A S
H Y D R O L I C E N S E C O O R D I N A T O R I P O W E R G E N E R A T I O N
P A C I F I C G A S & E L E C T R I C C O M P A N Y
( 5 3 0 ) 2 0 1 - 1 9 6 1 I A X U S @ P G E . C O M
From: Urias, Anna <AXUS@pge.com>
Sent: Monday, October 14, 2024 4:46 PM
To: Sable, Kurt - FS, CA <kurt.sable@usda.gov>
Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Joseph, Matthew <MWJA@pge.com>; Fisch,
Nathan@Waterboards <Nathan.Fisch@Waterboards.ca.gov>; Dyke, Jessica@Waterboards
<Jessica.Dyke@Waterboards.ca.gov>; Everest, Loren - FS, CA <loren.everest@usda.gov>; Bartoo,
Aondrea <aondrea_bartoo@fws.gov>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>;
Alvarez, Dawn - FS, CA <dawn.alvarez@usda.gov>; Lawson, Beth@Wildlife
<Beth.Lawson@wildlife.ca.gov>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>;
Edlund, Leslie - FS, CA <leslie.edlund@usda.gov>; Hopson, Rick - FS, CA
<Richard.Hopson@usda.gov>; Phipps, Jacqueline - FS, CA <Jacqueline.Phipps@usda.gov>
Subject: RE: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy
Regulatory Commission (FERC) No. 2107
Hi Kurt,
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Thank you for your comments on PG&E’s MIF variance request. I will be sending out a doodle
poll this week to schedule a meeting between PG&E and agencies to further discuss the
variance.
Regards,
A N N A U R I A S
H Y D R O L I C E N S E C O O R D I N A T O R I P O W E R G E N E R A T I O N
P A C I F I C G A S & E L E C T R I C C O M P A N Y
( 5 3 0 ) 2 0 1 - 1 9 6 1 I A X U S @ P G E . C O M
From: Sable, Kurt - FS, CA <kurt.sable@usda.gov>
Sent: Wednesday, October 9, 2024 5:59 PM
To: Urias, Anna <AXUS@pge.com>
Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Joseph, Matthew <MWJA@pge.com>; Fisch,
Nathan@Waterboards <Nathan.Fisch@Waterboards.ca.gov>; Dyke, Jessica@Waterboards
<Jessica.Dyke@Waterboards.ca.gov>; Everest, Loren - FS, CA <loren.everest@usda.gov>; Bartoo,
Aondrea <aondrea_bartoo@fws.gov>; Brenzovich, Erika - FS, CA <erika.brenzovich@usda.gov>;
Alvarez, Dawn - FS, CA <dawn.alvarez@usda.gov>; Lawson, Beth@Wildlife
<Beth.Lawson@wildlife.ca.gov>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>;
Edlund, Leslie - FS, CA <leslie.edlund@usda.gov>; Hopson, Rick - FS, CA
<Richard.Hopson@usda.gov>; Phipps, Jacqueline - FS, CA <Jacqueline.Phipps@usda.gov>
Subject: RE: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy
Regulatory Commission (FERC) No. 2107
Classification: Public
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Hello Anna,
Thank you for the chance to comment. As our partner agencies have stated, there are concerns with
this flow variance and we are not yet ready to write a concurrence letter. There are several resource
concerns with the lower instream flows, particularly in the heat of the summer; specifically the
foothill yellow-legged frog breeding season and temperature concerns for cold water fish in the North
Fork Feather River. Current instream flows were decided on after rigorous analysis and numerous
negotiations. The effects of these lower flows need to be considered in light of our current
understanding of this system.
The Forest Service would also like to meet with PG&E personal to discuss options and hear what may
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
come of Section 7 consultation and obtaining a water quality permit.
Thank you for your time
Kurt Sable on behalf of the Plumas National Forest.
Kurt Sable, MS (he/his)
Hydropower Coordinator / Hydrologist
Regional Hydropower Assistance Team
Forest Service
Pacific Southwest Region, Public Services
C: 530-616-1823
kurt.sable@usda.gov
10811 Stockrest Springs Road
Truckee CA 96161
www.fs.fed.us
Caring for the land and serving people
From: Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>
Sent: Wednesday, October 9, 2024 4:44 PM
To: Urias, Anna <AXUS@pge.com>
Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Joseph, Matthew <MWJA@pge.com>; Fisch,
Nathan@Waterboards <Nathan.Fisch@Waterboards.ca.gov>; Dyke, Jessica@Waterboards
<Jessica.Dyke@Waterboards.ca.gov>; Sable, Kurt - FS, CA <kurt.sable@usda.gov>; Everest, Loren -
FS, CA <loren.everest@usda.gov>; Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Brenzovich, Erika -
FS, CA <erika.brenzovich@usda.gov>; Alvarez, Dawn - FS, CA <dawn.alvarez@usda.gov>; Lawson,
Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>
Subject: RE: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy
Regulatory Commission (FERC) No. 2107
Hello Anna,
Thank you for the opportunity to review and comment on the PG&E Minimum Instream Flow Variance
notification you provided on September 9, 2024. Following discussions with other agencies it is our
understanding that prior to approval of the variance request for the Poe Dam repairs, PG&E must
engage in Section 7 consultation with the US Fish and Wildlife Service as well as pursue an
amendment of the Water Quality Certification for the variance. Given the potential for new
information to come to light during these processes, CDFW is not prepared to concur at this time
until they have been completed. CDFW has an interest in protecting the foothill yellow-legged frogs
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
(FYLF) that would likely be affected by the requested variance and would like to participate in any
discussions surrounding these two processes.
Additionally, although PG&E has stated in the variance request that temperature is not expected to
impact fishes or other aquatic organisms in the Poe Reach of the North Fork Feather River, CDFW
has concerns regarding potential temperature impacts to rainbow trout during the variance period.
Temperature modeling undertaken by PG&E, CDFW, the State Water Resources Control Board, and
the United States Forest Service (see the attached 2006 modeling memo) during the relicensing
process projected that water temperatures at 150 cfs would often exceed 20°C in June and July
when they are exceeded 42% and 76% of the time in these months respectively. The modeling also
indicated that there is a fair chance that 21°C could be exceeded approximately 40% of the time at
150 cfs in July (halfway between the 110cfs [52%] and 180 cfs [29%] projections listed in tables 2
and 3 in the modeling memo respectively).
Because of these FYLF and potential temperature concerns we would like to request a meeting be
scheduled to discuss with PG&E staff and staff from the other agencies prior to our decision to
concur with the variance.
Thank you Anna,
Michael Maher
Region 2 FERC Coordinator | ( Cell: 916-597-5505
California Department of Fish & Wildlife | North Central Region
1701 Nimbus Road, Rancho Cordova | michael.maher@wildlife.ca.gov
From: Urias, Anna <AXUS@pge.com>
Sent: Monday, September 30, 2024 5:06 PM
To: Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Lawson, Beth@Wildlife
<Beth.Lawson@wildlife.ca.gov>; Maher, Michael@Wildlife <Michael.Maher@wildlife.ca.gov>
Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Joseph, Matthew <MWJA@pge.com>; Fisch,
Nathan@Waterboards <Nathan.Fisch@Waterboards.ca.gov>; Dyke, Jessica@Waterboards
<Jessica.Dyke@Waterboards.ca.gov>; Kurt Sable <kurt.sable@usda.gov>; loren.everest@usda.gov;
Brenzovich, Erika -FS <erika.brenzovich@usda.gov>; Dawn Alvarez <dawn.alvarez@usda.gov>
Subject: RE: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy
Regulatory Commission (FERC) No. 2107
WARNING: This message is from an external source. Verify the sender and exercise caution when clicking links or
opening attachments.
Classification: Public
Hi Leigh,
Thank you for your email and comments. I will bring these items to my team and have a
response to you as soon as possible.
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Regards,
A N N A U R I A S
H Y D R O L I C E N S E C O O R D I N A T O R I P O W E R G E N E R A T I O N
P A C I F I C G A S & E L E C T R I C C O M P A N Y
( 5 3 0 ) 2 0 1 - 1 9 6 1 I A X U S @ P G E . C O M
From: Bartoo, Aondrea <aondrea_bartoo@fws.gov>
Sent: Friday, September 27, 2024 3:54 PM
To: Urias, Anna <AXUS@pge.com>; Lawson, Beth@Wildlife <Beth.Lawson@wildlife.ca.gov>; Michael
Maher <Michael.Maher@wildlife.ca.gov>
Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Joseph, Matthew <MWJA@pge.com>; Fisch,
Nathan@Waterboards <Nathan.Fisch@waterboards.ca.gov>; Dyke, Jessica@Waterboards
<Jessica.Dyke@Waterboards.ca.gov>; Kurt Sable <kurt.sable@usda.gov>; loren.everest@usda.gov;
Brenzovich, Erika -FS <erika.brenzovich@usda.gov>; Dawn Alvarez <dawn.alvarez@usda.gov>
Subject: Re: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy
Regulatory Commission (FERC) No. 2107
CAUTION: EXTERNAL SENDER!
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The USFWS has some concerns and recommendations regarding this request for a variance for
2025.
Impacts to foothill yellow-legged frog (and potentially other native species dependent
upon the North Fork Feather River system) may be significantly reduced by deferring this
type of flow variance for during a Dry or Critically Dry water year type. The USFWS
understands deferring may not be feasible for repairs being described in the letter.
USFWS recommends FERC conduct an ESA Section 7 formal consultation for this
variance. The USFWS anticipates that PG&E will be designated by FERC as the non-
federal representative for that consultation. The USFWS looks forward to working with
PG&E regarding development of measures to reduce impacts to the frog. The USFWS
envisions that some of the proposed measures would include:
increased monitoring for the frog throughout the variance period when ramping is
in process, with the locations and timing of this monitoring developed
collaboratively;
implementing a frog rescue plan for the variance period when ramping is in
process, with the locations and timing of the rescue developed collaboratively;
and
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
inclusion of a checkpoint for if/how the variance should be implemented if
FERC’s San Francisco Regional Office (or whichever FERC office has the authority
to approve) hasn’t provided approval of the work prior to completion of section 7
consultation
USFWS recommends PG&E conduct 2D mapping of some of the breeding locations
within the project area; with the mapping locations developed collaboratively. The
USFWS plans to utilize the information obtained from this effort to assess when perched
breeding pools and depressions (that hold tadpoles and eggs) may become stranded
and eventually desiccated during the variance ramping. Having this information is
expected to support the impacts analysis, incidental take statement, and reasonable
and prudent actions of the section 7 consultation for this and potentially other Poe
projects in the future. In the event that the time to complete this mapping would exceed
the time until initiation of section 7 consultation, the USFWS recommends completing
this effort for at least one breeding area prior to initiating consultation and then
completing the remainder of the mapping in the near future.
We appreciate the opportunity to comment. Please direct any concerns, clarifications, or
queries to Leigh Bartoo.
A. Leigh Bartoo
US Fish and Wildlife Service
Bay-Delta Fish and Wildlife Office
650 Capitol Mall, Suite 8-300
Sacramento, California 95814
916-930-5621
Pronouns: she/her/hers
Please contact me by email while staff are working from home.
From: Urias, Anna <AXUS@pge.com>
Sent: Monday, September 9, 2024 2:29 PM
To: Bartoo, Aondrea <aondrea_bartoo@fws.gov>; Lawson, Beth@Wildlife
<Beth.Lawson@wildlife.ca.gov>; Michael Maher <Michael.Maher@wildlife.ca.gov>
Cc: Ramirez-Doble, Sky <S9RV@pge.com>; Joseph, Matthew <MWJA@pge.com>; Fisch,
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Nathan@Waterboards <Nathan.Fisch@waterboards.ca.gov>; Dyke, Jessica@Waterboards
<Jessica.Dyke@Waterboards.ca.gov>; Kurt Sable <kurt.sable@usda.gov>; loren.everest@usda.gov
<loren.everest@usda.gov>; Brenzovich, Erika -FS <erika.brenzovich@usda.gov>; Dawn Alvarez
<dawn.alvarez@usda.gov>
Subject: [EXTERNAL] MIF Variance Notification for Poe Hydroelectric Project, Federal Energy
Regulatory Commission (FERC) No. 2107
This email has been received from outside of DOI - Use caution before clicking on
links, opening attachments, or responding.
Hello,
This email provides notification of a minimum instream flow (MIF) variance request to the
Forest Service and State Resources Water Control Board for Pacific Gas and Electric
Company’s (PG&E) Poe Hydroelectric Project, Federal Energy Regulatory Commission (FERC)
No. 2107. This notification satisfies Article 401 of the Poe license which contains the following
requirement for planned deviations from license requirements:
Three Water Board conditions in Appendix A and three Forest Service conditions in
Appendix B would allow the licensee to temporarily modify project operations under
certain conditions. The Commission must be notified prior to implementing such
modifications, if possible, or in the event of an emergency, as soon as possible, but no
later than 10 days after each such incident. The California Department of Fish and
Wildlife and the U.S. Fish and Wildlife Service must also be notified prior to
implementing any modifications to minimum flows required by certification condition
no. 1 and Forest Service condition no. 23 (Part 1).
The details of the MIF variance request can be found in the Att. 1. If you have comments,
please provide them by October 9, 2024.
Regards,
A N N A U R I A S
H Y D R O L I C E N S E C O O R D I N A T O R I P O W E R G E N E R A T I O N
P A C I F I C G A S & E L E C T R I C C O M P A N Y
( 5 3 0 ) 2 0 1 - 1 9 6 1 I A X U S @ P G E . C O M
Document Accession #: 20241024-5203 Filed Date: 10/24/2024
You can read about PG&E’s data privacy practices at PGE.com/privacy.
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If you believe you have received this message in error, please notify the sender and delete the
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Document Accession #: 20241024-5203 Filed Date: 10/24/2024
Document Content(s)
PGE20241024_2107_Poe_MIF_Temp_Amendment.pdf...............................1
Document Accession #: 20241024-5203 Filed Date: 10/24/2024