HomeMy WebLinkAbout08.14.26 Board Correspondence - FW_ Environmental and Recreational Compliance Report submitted in FERC P-803-121 by Pacific Gas and Electric Company,et al.From:Clerk of the Board
To:Clerk of the Board; Connelly, Bill; Cook, Holly; Cook, Robin; Durfee, Peter; Jessee, Meegan; Kimmelshue, Tod; Kitts,
Melissa; Krater, Sharleen; Lee, Lewis; Pickett, Andy; Ritter, Tami; Stephens, Brad J.; Sweeney, Kathleen; Teeter, Doug;
Zepeda, Elizabeth
Cc:Loeser, Kamie
Subject:Board Correspondence - FW: Environmental and Recreational Compliance Report submitted in FERC P-803-121 by
Pacific Gas and Electric Company,et al.
Date:Monday, August 17, 2026 8:14:28 AM
Please see Board Correspondence -
Lewis Lee
Administrative Technician - Confidential
Butte County Administration
25 County Center Drive, Suite 200 • Oroville, CA 95965
T: 530.552.3326
www.buttecounty.ca.gov | lelee@buttecounty.ca.gov
-----Original Message-----
From: 'FERC eSubscription' <eSubscription@ferc.gov>
Sent: Friday, August 14, 2026 6:36 AM
Subject: Environmental and Recreational Compliance Report submitted in FERC P-803-121 by Pacific Gas and Electric
Company,et al.
.ATTENTION: This message originated from outside Butte County. Please exercise judgment before opening
attachments, clicking on links, or replying..
On 8/14/2026, the following Filing was submitted to the Federal Energy Regulatory Commission (FERC), Washington
D.C.:
Filer: Pacific Gas and Electric Company
PG&E Corporation (as Agent)
Docket(s): P-803-121
Lead Applicant: Pacific Gas and Electric Company
Filing Type: Environmental and Recreational Compliance Report
Description: Pacific Gas and Electric Company submits response to FERC's 07/15/2026 additional information request
re the Butte Creek Fisheries Mitigation Plan for the DeSabla-Centerville Hydroelectric 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=20260814-5010__;!!KNMwiTCp4spf!BYeuQGqq-
To modify your subscriptions, click here:
https://urldefense.com/v3/__https://ferconline.ferc.gov/eSubscription.aspx__;!!KNMwiTCp4spf!BYeuQGqq-
kci82cExCoiKvmNbm4Xk0DEoFXT97jxm03Ee3N8eTqY5QsRJ04JgCvZFMzKj_2J7OPaj6IZR811cYucqEFrkTPz-
TC7$
------------------------------------------------------------------------
Please do not respond to this email.
Online help is available here:
https://urldefense.com/v3/__http://www.ferc.gov/efiling-help.asp__;!!KNMwiTCp4spf!BYeuQGqq-
kci82cExCoiKvmNbm4Xk0DEoFXT97jxm03Ee3N8eTqY5QsRJ04JgCvZFMzKj_2J7OPaj6IZR811cYucqEFrkRU-
aOpU$
or for phone support, call 866-208-3676.
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Power Generation
300 Lakeside Drive
Oakland, CA 94612
Mailing Address:
P.O. Box 28209
Oakland, CA 94604
August 13, 2026
Via Electronic Submittal (E-File)
Debbie-Anne Reese, Secretary
Federal Energy Regulatory Commission
888 First Street, NE
Washington, D.C. 20426
RE: DeSabla-Centerville Hydroelectric Project, FERC No. 803–121
2023 Butte Canal Incident – Fisheries Mitigation Plan
Response to FERC’s July 15, 2026, Additional Information Request
Dear Secretary Reese:
This letter provides Pacific Gas and Electric Company’s (PG&E) response to the Federal Energy
Regulatory Commission’s (FERC) July 15, 20261 Additional Information Request (AIR) regarding
PG&E’s January 30, 2026,2 Butte Creek Fisheries Mitigation Plan (Plan) for PG&E’s DeSabla-
Centerville Hydroelectric Project, FERC No. 803. FERC requested that PG&E provide additional
information within 30 days, including a response to the California Department of Fish and Wildlife’s
(CDFW) January 29, 2026 filing,3 a plan and schedule for continued consultation with CDFW and
the National Marine Fisheries Service (NMFS; collectively, agencies), and a proposed deadline for
filing a revised Fisheries Mitigation.
PG&E remains committed to satisfying FERC’s November 19, 20244 directive, continuing
consultation with NMFS and CDFW, and developing a mitigation approach that is scientifically
supported, technically defensible, feasible, measurable, and proportional to the incident-related
effects identified by FERC. PG&E also recognizes that FERC has encouraged the parties to
continue working toward a mutually agreeable approach that balances effective mitigation with
economic feasibility.
Response to CDFW’s January 29, 2026, Filing
By letter dated November 19, 2024, FERC directed PG&E to prepare a plan to mitigate the
adverse effects associated with the loss of 54 to 59 percent (51 to 55 adults) of adult spring-run
Chinook salmon, or the assumed quantity of juvenile salmon that would have resulted from the
partially lost 2023 cohort. FERC identified potential mitigation actions that may include habitat
improvement, fish stocking, fish passage improvements, funding for habitat improvement projects
or broodstock rearing, or other similar measures.
1 July 15, 2026, Additional Information Request – January 30, 2026, Butte Creek Fisheries Mitigation Plan, FERC
Accession Number 20260715-3011
2 January 30, 2026, 2023 Butte Canal Incident – Fisheries Mitigation Plan, FERC Accession Number
20260130-5495
3 January 29, 2026, DeSabla-Centerville Project No. 803, Summary of Consultation between PG&E and CDFW on
Fisheries Mitigation Plan for 2023 Butte Canal Incident, FERC Accession Number 20260130-5028
4 November 19, 2024, 2023 Project Canal Failure, Overtopping, and Erosion Incident, FERC Accession Number
2024119-3039
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Debbie-Anne Reese, Secretary
August 13, 2026
Page 2
On January 29, 2026, CDFW filed comments with FERC summarizing its consultation with PG&E
and stating its position that the only effective mitigation to offset the loss of the 2023 cohort is
funding a captive broodstock rearing program for Butte Creek spring-run Chinook salmon. CDFW
estimated the cost of that program at approximately $21.2 million over seven years.
PG&E filed the Plan on January 30, 2026. The Plan described PG&E's incident response,
environmental monitoring, consultation history, mitigation framework, and proposed mitigation
approach. Based on the Framework for Evaluating Mitigation Alternatives for Central Valley Spring-
Run Chinook Salmon in Butte Creek5, PG&E estimated that the loss associated with the 2023
incident was equivalent to approximately 35,000 to 175,000 fry. To mitigate that loss, PG&E
proposed either implementation of habitat enhancement measures or, at the agencies' election,
funding support for a broodstock program in the amount of $5.1 million. The proposed two-year
funding period reflected the anticipated timing for distributing mitigation funds and initiating
implementation of the selected mitigation approach, rather than a limitation on the duration of
biological benefits. Under PG&E's proposal, mitigation actions funded during the two-year period
would continue to provide biological benefits beyond the initial funding period. The distinction
between PG&E's proposal and CDFW's proposal is therefore primarily one of mitigation scale and
scope rather than the duration of biological benefit.
CDFW recommended a seven-year captive broodstock rearing program estimated at
approximately $21.2 million, while PG&E proposed a mitigation approach scaled to the estimated
biological loss associated with the 2023 incident, consisting of either habitat enhancement
measures or $5.1 million in funding support for a broodstock program, if selected by the agencies.
PG&E respectfully disagrees that a seven-year, $21.2 million broodstock program is necessary to
satisfy FERC's November 19, 2024, directive. FERC directed PG&E to mitigate the effects
associated with the estimated loss of approximately 54 to 59 percent (51 to 55 adults) of spring-run
Chinook salmon, or the corresponding reduction in juvenile production attributable to those adults.
PG&E's mitigation framework was developed specifically to evaluate incident-related loss and
concluded that the effect to be mitigated is equivalent to approximately 35,000 to 175,000 fry.
PG&E's proposed funding amount was developed to address the specific incident-related effects
identified by FERC and the estimated reproductive loss evaluated in the mitigation framework.
During consultation, CDFW did not provide a biological replacement target, mitigation ratio,
performance metric, or other technical basis demonstrating why a seven-year broodstock program
is necessary to offset the specific incident-related effects identified by FERC.
Information provided by CDFW during consultation indicates that the proposed broodstock
program would maintain approximately 20,000 broodstock fish and produce approximately 250,000
fry annually. However, CDFW did not explain how annual production of approximately 250,000 fry
and maintenance of approximately 20,000 broodstock fish corresponds to the incident-related loss
identified by FERC or the evaluation in PG&E's mitigation framework (35,000-175,000 fry). While
such a program may provide broader conservation and recovery benefits to the Butte Creek
spring-run Chinook population, CDFW did not provide a technical justification demonstrating why
that scale of effort is necessary to mitigate the specific effects identified in FERC's November 19,
2024, directive.
5 June 18, 2025, Fishery Mitigation Plan Regarding 2023 Project Canal Incident – Extension of Time Request, Encl
3 – Framework for Evaluating Mitigation Alternatives for CVSRCS, FERC Accession Number 20250618 -5205
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Debbie-Anne Reese, Secretary
August 13, 2026
Page 3
PG&E recognizes the agencies' concerns regarding recent population trends and the importance of
long-term species recovery. However, those broader conservation objectives extend beyond the
scope of the discrete incident evaluated by FERC. PG&E remains committed to satisfying FERC's
November 19, 2024, directive by supporting mitigation that is scientifically supported, technically
defensible, measurable, and proportional to the incident-related effects. PG&E's proposed funding
approach was developed to address the specific reproductive loss associated with the 2023 canal
failure rather than to fund a long-term species recovery program. PG&E acknowledges CDFW's
position that the 2023 incident occurred during a period of reduced population abundance.
However, population trends, unrelated to the incident and outside of PG&E’s control, should not be
used to establish the scale or duration of mitigation necessary to address the specific incident-
related effects identified by FERC.
Continued Consultation and Revised Plan Schedule
PG&E remains committed to continued consultation with CDFW and NMFS regarding the Butte
Creek Fisheries Mitigation Plan. Following submittal of this response, PG&E will continue
consultation with the agencies to discuss the technical information supporting the respective
mitigation proposals, evaluate remaining areas of disagreement, and determine whether a mutually
agreeable mitigation approach can be identified. On August 13, 2026, PG&E emailed CDFW and
NMFS to begin this process.
PG&E anticipates working with CDFW and NMFS to establish consultation milestones, document
agency comments, and maintain a complete consultation record consistent with FERC's July 15,
2026, Additional Information Request. Because consultation schedules and technical information
needs have not yet been established with the agencies, PG&E believes that identifying a revised
filing deadline at this time would be premature.
Accordingly, PG&E proposes to provide FERC with an updated consultation status report and a
proposed deadline for filing a revised Fisheries Mitigation Plan within 90 days of this filing. At that
time, PG&E expects to have sufficient information regarding consultation schedules, agency
participation, and any additional technical evaluation needed to develop a realistic filing schedule.
Conclusion
PG&E remains committed to complying with FERC's November 19, 2024, directive and continuing
consultation with CDFW and NMFS. PG&E considered CDFW's recommendations during
development of the Fisheries Mitigation Plan but did not find sufficient technical support
demonstrating that a seven-year, $21.2 million broodstock program is necessary to mitigate the
incident-related effects identified by FERC. PG&E recognizes the agencies' concerns regarding
recent population trends, long-term population viability, and species recovery. However, FERC's
November 19, 2024, directive concerns mitigation of the specific incident-related effects associated
with the 2023 canal failure and not the unrelated conservation objectives identified by CDFW.
PG&E remains committed to supporting mitigation that is scientifically supported, technically
defensible, measurable, and proportional to those effects. PG&E's proposed funding approach was
developed to address the specific reproductive loss associated with the 2023 canal failure rather
than broader recovery objectives that extend beyond the scope of the incident evaluated by FERC.
PG&E's detailed responses to CDFW's January 29, 2026, comments are provided in (Enclosure 1).
Documentation that PG&E emailed CDFW and NMFS is provided as (Enclosure 2).
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Debbie-Anne Reese, Secretary
August 13, 2026
Page 4
If you have questions or comments regarding this matter, please contact Sky Ramirez-Doble,
license coordinator for PG&E, at (530) 250-7002.
Sincerely,
Janet Walther
Director, Hydro Licensing & Compliance
Pacific Gas and Electric Company
Enclosures:
1. Comment Matrix
2. Agency Communication
cc: via email w/enclosures
Andrea Claros, FERC – andrea.claros@ferc.gov
Cathy Marcinkevage, NMFS – cathy.marcinkevage@noaa.gov
Ellen Roots, NMFS – Ellen.roots@noaa.gov
Hannah Mone, NMFS – hannah.mone@noaa.gov
Morgan Kilgour, CDFW – morgan.kilgour@wildlife.ca.gov
Anna Allison, CDFW – Anna.allison@wildlife.ca.gov
Beth Lawson, CDFW – Beth.lawson@wildlife.ca.gov
Colin Purdy, CDFW – colin.purdy@wildlife.ca.gov
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
ENCLOSURE 1
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
Fishery Mitigation Plan
1 2 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.
CDFW does not cite scientific literature or provide a technical analysis supporting its assertion that impacts to the adult
holding life stage have the greatest influence on population success as a whole. While adult survival is important, this
characterization oversimplifies the processes regulating salmon populations. Salmon abundance reflects cumulative
survival across all life stages, and improvements at any stage can increase overall productivity.
Life-cycle modeling for Central Valley spring-run Chinook salmon (Oncoryhnchus tshawytscha;CVSRCS) indicates that
population dynamics are influenced not only by adult survival but also by egg -to-fry survival, juvenile freshwater survival,
and ocean survival (Cordoleani et al. 2020). Egg-to-fry survival has also been reported as a limiting factor for the
recovery of spring-run Chinook salmon populations in other systems (Honea et al. 2009), and embryo survival is
strongly influenced by gravel permeability and hyporheic flow (McBain and Trush 2000; Bilski et al. 2022; Johnson et al.
2025).
Accordingly, habitat enhancement measures such as gravel augmentation can improve spawning and incubation
conditions, increase reproductive success, and contribute to replacement of the juvenile production los s as a result of
the incident. For this reason, PG&E does not agree that mitigation must be limited exclusively to actions targeting adult
holding habitat.
Water Temperature
2 3 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.
The PG&E CE-QUAL-W2 model indicated that the combination of dredging and a thermal curtain in DeSabla Forebay
would provide an average summer reduction in water temperature of 0.23 °C in the tailrace, which would equate to a
maximum 0.12 °C benefit in Butte Creek after mixing with ambient water (PG&E 2025d). Temperature logger instrument
accuracy is ±0.05°C (i.e., a range of 0.1°C). When measuring temperature changes across two locations, the combined
accuracy range could be as large as 0.2°C. Therefore, the average temperature benefit to DeSabla Forebay and Butte
Creek, of the proposed actions, would be within instrument accuracy. If the temperature benefit is within instrument
accuracy, it is difficult to conclude that this temperature reduction would be biologically meaningful. As stated in PG&E’s
June 18, 20251 filing, PG&E CE-QUAL-W2 model was presented to CDFW and NMFS on May 9, 2025. A report on the
model, DeSabla Forebay Water Temperature Modeling was sent to CDFW and NMFS on May 27, 2025, and provided to
FERC in the June 18, 2025, filing.
1 June 18, 2025, Fishery Mitigation Plan Regarding 2023 Project Canal Incident – Extension of Time Request, Encl 2 – DeSabla Forebay Temperature Modeling, FERC Accession Number 20250618-5205
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
3 3 … 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 provided two reports to CDFW in an email on May 27, 2025, as evidence for the reasoning to not model
additional potential modifications. First, DeSabla Forebay Water Temperature Modeling was the report that provided
details on the CE-QUAL-W2 model that was used to model the first two potential project modifications that were
presented at the May 9, 2025, meeting (PG&E 2025 d). Second, Evaluation of Hypothetical Mitigation on Heating in
DeSabla Forebay and the Resultant Effect on Water Temperature in Butte Creek which provided an analysis of how
hypothetical reductions in DeSabla Forebay water temperatures would affect temperatures in Butte Creek . This
information was presented at a meeting on April 3, 2025 (PG&E 2025e). A mass balance analysis (based on years
where temperature was measured at all locations) was completed to evaluate an idealized 80% reduction in heating
across DeSabla Forebay. This analysis showed that an average reduction of summer temperatures of 0.5 °C in Butte
Creek at Lower Centerville Diversion Dam could be achieved. However, during 14 of the 15 years used to complete the
analysis, Butte Canal was also operating. The loss of Butte Canal changes the thermal dynamics of the system (as
water in the canal now travels down the natural creek channel). When the mass balance analysis was completed for
2024, a year when Butte Canal was offline, an idealized 80% reduction in heating across DeSabla Forebay would result
in an average reduction of summer temperatures of only 0.1 °C in Butte Creek at Lower Centerville Diversion Dam. This
reduction is equal to instrument error for a single temperature logger. Based on these results, PG&E concluded that the
requested forebay modifications were unlikely to produce measurable temperature benefits in Butte Creek and therefore
additional modeling was not warranted.
PG&E’s Framework for Evaluating Mitigation
Alternatives – General Comments
4 Page 4, Under
Heading
General
comments
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
From the context of the remainder of the paragraph, PG&E assumes that CDFW intended to say “CDFW states that it
does not believe it is appropriate to propose habitat restoration actions at a 1:1 ratio.” If this assumption is correct,
PG&E’s comment to this statement is that habitat improvements can increase survival across multiple life stages and
generations so that actions may exceed a 1:1 offset ratio.
Prior to implementing habitat enhancement activities, physical data including hydrology, channel gradient, and channel
width would be collected within Butte Creek to help ensure that habitat improvements remain effective across multiple
generations. These data would be used to identify reaches with the highest likelihood of retaining gravel and large
woody debris over multiple years. As a result, the proposed action could benefit multiple cohorts of spawning CVSRCS.
In its budget, PG&E has included monitoring costs within the habitat mitigation program to evaluate and estimate project
benefits over time. When evaluated over appropriate timeframes (including multiple life stages and generations), a
combination of gravel augmentation and woody debris placement may potentially result in benefits far exceeding a 1:1
offset ratio.
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
5 Page, 4,
Under
Heading
General
Comments
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.
In a letter to FERC dated January 30, 2026, PG&E proposed a mitigation plan (Plan) that was based on the
reproductive loss associated with the partial loss of the 2023 cohort. A summary of population objectives and
quantifiable habitat improvements in Butte Creek were recommended for several life stages and were provided in the
Plan. PG&E’s document titled Framework for Evaluating Mitigation Alternatives for Central Valley Spring-Run Chinook in
Butte Creek2 (Framework; PG&E 2025c) provided details on how these recommendations were derived. PG&E's
Framework evaluated habitat restoration opportunities in Butte Creek. It also quantified the scale of restoration needed
to mitigate the partial loss of adults and juvenile production associated with the 2023 incident. The Framework identified
several mitigation measures capable of increasing production and survivorship and replacing the estimated quantity of
juveniles lost.
Habitat restoration in regulated river systems has been successfully implemented throughout California, including gravel
augmentation in Hat Creek below the Hat 1 diversion dam, Sacramento River below Keswick Dam, Clear Creek below
Whiskeytown Dam, and Yuba River below Englebright Dam. When PG&E submitted its mitigation plan to FERC (PG&E
2026), the proposed mitigation activities were intentionally presented at a conceptual level. Selection, refinement, and
evaluation of specific restoration projects would ordinarily occur during subsequent consultation and implementation
planning. However, CDFW was unwilling to engage in discussions regarding the logistics or implementation of potential
habitat restoration projects.
PG&E's property (e.g., Centerville Powerhouse) may provide access and logistical support for upstream habitat
enhancement activities, including gravel augmentation. Additionally, substantial restoration opportunities exist in more
accessible downstream reaches, such as within the Butte Creek Ecological Preserve. PG&E has extensive experience
implementing spawning gravel augmentation projects in watersheds that support its hydroelectric facilities. Similarly,
PG&E’s contractors have experience employing innovative approaches for the installation of large woody material and
other habitat enhancement features. Additionally, there are several other organizations who have explored habitat
restoration in Butte Creek. The funding proposed by PG&E could be used for a collaborative effort with those
organizations.
With further investigation, a combination of habitat restoration that includes gravel augmentation (to expand spawning
gravels and/or improve conditions within existing gravels) with the addition of large woody debris could be at a sufficient
scale to offset the estimated production losses. With appropriate planning, coordination, and adaptive implementation,
logistical constraints do not preclude development of habitat-based mitigation in the Butte Creek watershed.
PG&E’s Framework for Evaluating Mitigation –
Creation of New Holding Habitat
6 5 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.
The Framework evaluated all potential mitigation actions based on habitat capacity to mitigate for the effects of the loss
of 54-59 percent (51-55 adults) of adult spring-run Chinook, or the assumed quantity of juvenile salmon that would have
resulted from the partially lost 2023 cohort (PG&E 2025c). Once the framework was established, PG&E evaluated
mitigation actions based on certainty of the action meeting life-stage-specific population objectives. A high-level
assessment of implementation success was one aspect considered to determine whether the objective could be met. A
matrix was included in the Framework and presented to CDFW on May 9, 2025, that identified the likelihood a mitigation
action could be accomplished and would meet the life-stage-specific population objectives. Due to low certainty that the
2 June 18, 2025, Fishery Mitigation Plan Regarding 2023 Project Canal Incident – Extension of Time Request, Encl 3 – Framework for Evaluating Mitigation Alternatives for CVSRCS, FERC Accession Number 20250618-5205
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
mitigation measures evaluated to create new holding habitat were feasible, these measures were not included in the
mitigation plan proposed to FERC in the January 30, 2026 letter.
.
PG&E’s Framework for Evaluating Mitigation –
Creation of New Spawning Habitat
7 Page 5, Under
heading
Creation of
New
Spawning
Habitat
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.
Please see Comment 1 for PG&E’s response.
PG&E’s Framework for Evaluating Mitigation –
Creation of Juvenile Rearing Habitat
8 Page 6, Under
heading
Creation of
New Juvenile
Rearing
habitat
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.
PG&E agrees with CDFW that the lack of observations of juveniles is likely because there is no suitable rearing habitat
in upper Butte Creek. Although PG&E did not include creation of off-channel habitat in the habitat mitigation portion of
the plan, the proposed $5.1 million could be used, in combination with the efforts of third-party organizations, to create
suitable rearing habitat so that juveniles can be retained in the upper reaches of Butte Creek. Currently, a number of
organizations are working to advance, or are interested in advancing, habitat restoration in upper and lower reaches of
Butte Creek (Bureau of Reclamation 2026, Chico State 2022, NCW 2025). PG&E’s proposed funding could be used to
support the efforts of these organizations, specifically areas near the Butte Creek Ecological Preserve appear suitable
for gravel augmentation, floodplain reconnection, and off -channel habitat creation.
PG&E’s Plan includes large woody debris placement in Butte Creek. Large woody debris would add additional in -
channel rearing habitat at a smaller scale to retain juveniles in the upper Butte Creek. Recent work indicates that late -
migrating juveniles can contribute disproportionately to cohort success under drought and marine heatwave conditions
(Cordoleani et al. 2021). Large woody debris, together with additional gravel in existing spawning beds or creation of
new spawning beds, would provide a multi-benefit approach. The California Water Resilience Portfolio, State Wildlife
Action Plan, and California’s Salmon Strategy for a Hotter, Drier Future, all emphasize floodplain connectivity, habitat
complexity, and improved spawning and rearing conditions as core strategies for salmon recovery. These policies reflect
a broad scientific and management consensus that long -term population resilience, viability, and increasing abundance
depends on restoring ecological processes. Incorporating habitat restoration into mitigation for the Butte Canal failure is
therefore aligned with established state priorities and recovery objectives.
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
9 Page 6, Under
heading
Creation of
New Juvenile
Rearing
habitat
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.
PG&E does not agree that habitat restoration opportunities are unavailable due to topography, accessibility constraints,
or a lack of suitable locations. The Framework for Evaluating Mitigation Alternatives for CVSRCS in Butte Creek
evaluated habitat restoration measures throughout the Butte Creek watershed and identified multiple pathways capable
of increasing production and survivorship, including gravel augmentation, floodplain reconnection, off -channel habitat
creation, and large woody debris placement.
Habitat restoration opportunities are not limited to upper Butte Creek. Mitigation activities can be implemented in
upstream and downstream reaches of the watershed and can be designed to benefit multiple life stages. The
Framework concluded that habitat-based mitigation measures could contribute toward offsetting the estimated
production losses associated with the 2023 incident.
While site-specific project identification, engineering, permitting, and implementation planning would be necessary prior
to construction, available information does not support the conclusion that logistical constraints preclude habitat
restoration within the Butte Creek watershed. Rather, further evaluation would be expected to identify and refine
restoration opportunities capable of contributing to the mitigation objective identified in the Framework. Captive Broodstock Rearing Program Proposed
by CDFW
10 Page 9,
Captive
Broodstock
Rearing
Program
Proposed by
CDFW
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
In its January 29, 2026 letter, CDFW identified the 2023 and 2024 cohorts as failed cohorts. While PG&E acknowledges
the importance of accountability for the partial loss of the 2023 CVSRCS population associated with the Butte Canal
failure, PG&E maintains that CDFW should not base mitigation requirements on the low returns observed in 2023 (95
estimated; Henley 2023) and 2024 (51 individuals; Henley 2024b), as those returns were influenced by a variety of
regional and ocean-wide factors unrelated to the Butte Canal failure. As directed by FERC, PG&E is focused on
mitigating for "the adverse effects associated with the loss of 54 to 59 percent, or 51 to 55 adults, of adult spring -run
Chinook salmon, or the assumed quantity of juvenile salmon that would have resulted from the partially lost 2023
cohort".
Habitat monitoring data collected during the 2024 holding and spawning period showed that sediment deposited as a
result of the Butte Canal failure (red colored sediment) was removed with winter storm flows (PG&E 2025a). The
remaining red colored sediment was found behind large rocks and along edges in slow moving microhabitats where one
would expect to find sediment deposition. Therefore, there is no evidence that the Butte Canal failure contributed to the
poor performance of the 2024 cohort3.
Evidence that the sediment release had limited effects on CVSRCS habitat is further supported by the results of post -
incident benthic macroinvertebrate (BMI) surveys. These surveys were conducted to assess the condition of the benthic
macroinvertebrate community following the incident in 20234 and 20245 (PG&E 2023c & 2024b). The results did not
indicate any clear reach-wide adverse effects on BMI populations that could be attributed to sediment originating from
the incident.
The life history of CVSRCS is complex, and adult return numbers are influenced by many factors beyond conditions in
Butte Creek, including ocean productivity, climate conditions, and harvest rates. Low salmon returns observed
3 November 19, 2025, Final Water Quality Monitoring Data, FERC Accession Number 20251120-5033
4 December 31, 2024, Update on Project Canal Incidents and Response to Notice of Violation, Enclosure 3 – 2023 BMI Monitoring Related to the Butte Canal Breach, FERC Accession Number 20241231-5425
5 March 25, 2025, BMI Monitoring Report, FERC Accession Number 20250325 -5168
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
throughout California in 2022, 2023, and 2024, indicate that the reduced returns were not unique to Butte Creek and
cannot be attributed to PG&E. In response to historically low salmon returns across California in 2022 and 2023, ocean
fishery restrictions and closures were implemented in 2023 and 2024 to protect salmon populations (CDFW 2023
&2026; NOAA 2023 & 2024).
Assuming that most returning adults are three-year-old fish, the return of approximately 5,000 individuals observed thus
far in 2026 (per communications with CDFW) is substantial when compared to the estimated 51 individuals believed to
have survived the 2023 Butte Canal slide event. This illustrates the complexity of salmon population dynamics and the
influence of factors operating across multiple life stages. Based only on observed size, CDFW speculates that much of
the fish returning in 2026 are believed to be four-year-old adults originating from the 2022 production cohort. While this
does not diminish the impacts of the 2023 event, it demonstrates that population perform ance is strongly affected by
factors outside of PG&E's control and beyond conditions occurring in Butte Creek.
The existence of broader population challenges and low returns does not, by itself, establish that a recovery -scale
conservation program is necessary to mitigate the specific effects of the 2023 incident. As directed by FERC, PG&E's
mitigation obligation is limited to addressing the adverse effects associated with the loss of 51-55 adult spring-run
Chinook salmon, or the associated reduction in juvenile production attributable to that loss. While population status may
be a relevant consideration in selecting a mitigation approach, it does not by itself establish that a recovery-scale
conservation program is necessary or proportional to the incident -related effects identified by FERC.
11 12 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
An effective mitigation plan should establish a measurable and achievable objective that addresses the documented
loss.
In PG&E’s Framework, the estimated loss of 51-55 adult individuals likely resulted in a loss of approximately 34,909-
175,437 fry (PG&E 2025c). This estimate is based on the relationship between female fork length and fecundity, as
described in peer reviewed literature, combined with egg-to-fry survive estimates derived from sediment core analysis of
Butte Creek spawning gravels. Fork length data from spawned female carcasses observed by CDFW during the 2017,
2018, 2021, and 2022 spawning period (Garmin 2017, 2018; Nichols 2022; Henley 2024 a) were used to estimate range
of female CVSRCS fecundity in Butte Creek.
CDFW has used female fork lengths to estimate fecundity in CVSRCS populations in Mill and Deer Creeks (CDFW
1998). These systems also support non-hatchery influenced runs of CVSRCS. The estimated fecundity per female in
these systems ranged from 1,350 to 7,193 eggs per female, which is comparable to PG&E’s estimated range of 2,448 to
7,459 eggs per female (PG&E 2024b & 2025a).
With respect to the comment “The amount of sediment deposition in the spawning gravel from the canal failure is not
known,” PG&E conducted subsurface sediment core analysis to identify fine sediment levels (sand, silt and clay) known
to affect salmon embryo development, survival, and emergence (Tappel and Bjornn 1993). This study was requested by
CDFW and developed with input from CDFW’s geomorphologist. This study was incorporated into PG&E’s monitoring
plan developed in consultation with CDFW (PG&E 2024a).
Sub-surface core analyses were performed in reaches historically used by spawning CVSRCS. Results from the 2023
and 2024 studies indicated limited levels of fine sediments within spawning gravels. Based on sediment composition in
cores, estimated CVSRCS embryo survival exceeded 80 percent at three of the four study sites. At Honey Run Bridge
site, estimated embryo survival ranged from 62 to 86 percent in 2023 and improved with a range from 79 to 91 percent
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Comment No. Page # CDFW's Comment PG&E's Response to Comment
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.
in year 2024 (PG&E 2024b and 2025a). Furthermore, there were no statistical differences in estimated embryo survival
between sites upstream and downstream of the slide and between study years (PG&E 2024b & 2025a). These findings
suggest that sediment associated with the slide did not accumulate within spawning gravels at levels likely to
substantially reduce embryo-to-fry survival.
Although CDFW ultimately reached different conclusions regarding the interpretation of these results, PG&E notes that
the study design, methods, and monitoring approach were developed in coordination with CDFW and were based on
established, peer-reviewed scientific methodologies. PG&E conducted these studies to quantitatively evaluate the
effects of the canal failure and to ensure that mitigation is appropriately aligned with the impacts documented through
scientific investigation. While CDFW does not agree with PG&E's estimate of loss, PG&E believes this estimate
represents the best available scientific basis for establishing an achievable and proportional mitigation target.
As described in PG&E's Mitigation Plan, PG&E does not consider a recovery-scale conservation program to be an
appropriate mitigation measure for the partial loss of a single spawning cohort. PG&E believes such a program would be
disproportionate to the scale of the documented impact and inconsistent with the objective of developing mitigation
measures that are commensurate with the estimated loss.
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Literature cited
Bilski, R. L., J. M. Wheaton, and J. E. Merz. 2022. Effects of in -channel structure on
Chinook salmon spawning habitat and embryo production. Water 14:83.
Bureau of Reclamation. 2026. Website: Reclamation, Fish and Wildlife Service announce
awards for Central Valley Project fish habitat and directed studies. Accessed July
31, 2026. Released July 2, 2026.
California Department of Fish and Wildlife (CDFW). 2023. Website: CDFW News | Fishery
Scientists Announce Poor 2023 Outlook for California’s Ocean Salmon Stocks.
Accessed July 31, 2026. Released March 1, 2023.
CDFW. 2026. Website: CDFW News | Ocean Salmon Fishing Comeback Continues.
Accessed July 31, 2026. Released April 12, 2026.
Cordoleani, F., W. H. Satterthwaite, M. E. Daniels, M. R. Johnson, J. M. Phillis, J. A.
Sturrock, S. M. Carlson, and R. B. MacFarlane. 2020. Using life-cycle models to
identify monitoring gaps for Central Valley spring-run Chinook Salmon. San
Francisco Estuary and Watershed Science 18(4).
Chico State Today. 2022. Website: Ancestral Land in Butte Creek Canyon Returned to
the Mechoopda Tribe - Chico State Today. Accessed July 31, 2026. Garmin, C.
2017. Butte Creek spring-run Chinook Salmon escapement survey September
2017-October 2017. Department of Fish and Wildlife. Chico, California.
Garmin, C. 2018. Butte Creek spring-run Chinook Salmon escapement survey
September 2018-October 2018. Department of Fish and Wildlife. Chico,
California.
Henley, G. 2023. 2023 Butte Creek adult spring-run Chinook salmon holding snorkel
survey. October 12, 2023. California Department of Fish and Wildlife.
Henley, G. 2024a. Butte Creek Spring-run Chinook Salmon Annual Adult Monitoring
Report 2022. February 2024. California Department of Fish and Wildlife.
Henley, G. 2024b. 2024 Butte Creek adult spring-run Chinook salmon holding snorkel
survey. August 26, 2024. California Department of fish and Wildlife.
Honea, J. M., J. C. Jorgensen, M. M. McClure, T. D. Cooney, K. Engie, D. M. Holzer, and
R. Hilborn. 2009. Evaluating habitat effects on population status: influence of
habitat restoration on spring-run Chinook Salmon. Freshwater Biology 54:1576–
1593.
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
McBain, S. M., and W. J. Trush. 2000. Spawning gravel composition and permeability
within the Garcia River watershed, California. Report prepared for Mendocino
County Resource Conservation District, Ukiah, California.
National Oceanic and Atmospheric Administration (NOAA). 2023. Fisheries off west coast
states; west coast salmon fisheries; 2023 specifications and management
measures. Federal Register 88: 91. Pages 30235 – 30235.
NOAA. 2024. Fisheries off west coast states; west coast salmon fisheries; 2024
specifications and management measures. Federal Register 89: 99. Pages 44553
– 44567.
Northern California Water (NCW). 2025. Website: collaborative salmon Recovery efforts
takingsShape in Butte Creek. Accessed July 3, 2025.
Pacific Gas and Electric Company (PG&E). 2024a. Monitoring plan for assessing effects
of the Butte Canal slide on benthic macroinvertebrate and fish habitat. Updated
Version January 23, 2024. Oakland Ca.
Pacific Gas and Electric Company (PG&E) 2024b. Butte Canal breach Central Valley
spring-run Chinook salmon habitat assessment: year 1 study. February 2024.
Oakland, CA. Prepared by Cramer Fish Sciences, West Sacramento, CA.
PG&E. 2024c. 2023 Benthic Macroinvertebrate Monitoring Related to the Butte Canal
Breach. April 2024. Oakland, CA. Prepared by Spring Rivers Ecological
Sciences LLC, Cassel, CA.
Pacific Gas and Electric Company (PG&E). 2025a. Butte Canal breach Central Valley
spring-run Chinook salmon habitat assessment: year 2 study. February 2025.
Oakland, CA. Prepared by Cramer Fish Sciences, West Sacramento, CA.
Pacific Gas and Electric Company. 2025. 2024b. Benthic Macroinvertebrate Monitoring
Related to the Butte Canal Breach. March 2025. Oakland, CA. Prepared by
Spring Rivers Ecological Sciences LLC, Cassel, CA.
Pacific Gas and Electric Company (PG&E). 2025c. Framework for evaluating mitigation
alternatives for Central Valley spring-run Chinook salmon in Butte Creek. May
2025. Oakland, CA. Prepared by Cramer Fish Sciences, West Sacramento, CA.
PG&E. 2025d. DeSabla forebay water temperature modeling. May 2025. Oakland, CA.
Prepared by Kleinschmidt Associates.
PG&E. 2025e. Evaluation of hypothetical mitigation on heating in DeSabla Forebay and
the resultant effect on water temperature in Butte Creek. May 2025. Oakland, CA.
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Tappel P. D, and T. C. Bjorn. 1983. A new method of relating size of spawning gravel to
salmonid embryo survival. North American Journal of Fisheries Management
3(2):123–135.
Johnson, C., Roni, P., De Boer, T., Murdoch, A. and Quinn, T.P., 2025. Factors affecting
the survival of Chinook salmon (Oncorhynchus tshawytscha) embryos in upper
and middle Columbia River watersheds, Washington State, USA. Canadian
Journal of Fisheries and Aquatic Sciences, 82, pp.1-21
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
ENCLOSURE 2
Document Accession #: 20260814-5010 Filed Date: 08/14/20268/13/26, 10:06AM Mail -Drummond , Duncan -Outlook
Outlook
Proposed Meeting to Discuss Butte Creek Fisheries Mitigation Plan and Schedule
From Drummond, Duncan <DGDH@pge.com>
Date Thu 8/13/2026 9:59 AM
To Allison, Anna@Wildlife <Anna.allison@wildlife.ca.gov>; Beth.Lawson@wildlife.ca.gov
< Beth.Lawson@wildlife.ca.gov>; cathy.marcinkevage@noaa.gov <cathy.marcinkevage@noaa.gov>;
ellen.roots@noaa.gov <ellen.roots@noaa.gov>; Grant Henley (Grantton.Henley@Wildlife.ca.gov)
<Grantton.Henley@Wildlife.ca.gov>; Purdy, Colin@Wildlife <colin.purdy@wildlife.ca.gov>
Cc Walther, Janet <JMW3@pge.com>; Cheslak, Edward <EFC3@pge.com>; Reyes, Catalina <CERh@pge.com>;
Williamshen, Brian <BOW2@pge.com>; Brunswick, Betsy <BMB7@pge.com>; Ramirez-Doble, Sky
<S9RV@pge.com>; Joseph, Mat thew <MWJA@pge.com>
Greetings Agencies,
On July 15, 2026, the Federal Energy Regulatory Commission's Division of Hydropower Administration and
Compliance (DHAC) requested additional information from Pacific Gas and Electric Company (PG&E) regarding the
Butte Creek Fisheries Mitigation Plan (Mitigation Plan) for the DeSabla-Centerville Hydroelectric Project, FERC
Project No. 803. Specifically, DHAC requested that PG&E provide the following additional information:
"2} Identify a plan and schedule for meeting with the agencies to make progress on a plan that effectively
mitigates for the effects to the Butte Creek fishery following the failure of Butte Creek Canal.
3}Identify a new deadline for filing the Plan, taking the abovementioned requests into consideration. As a
reminder, a complete consultation record should be included in your filing. This must include documentation of
consultation with both agencies, including their specific comments, thereby demonstrating that each agency was
included in the development of the Plan and that each agency's comments were considered. 11
To support the progress of the Mitigation Plan, PG&E would like to schedule an initial consultation meeting with
the agencies. The purpose of this initial meeting would be to discuss a plan and schedule for continued
consultation, establish a recurring meeting cadence as needed, identify the information necessary to support
updates to the Mitigation Plan, and discuss an appropriate target date for filing the revised Mitigation Plan.
PG&E proposes the following dates and times for the initial meeting:
•August 25, 2026 14:00-15:00
•August 31, 2026, 15:00-16:00
•September 9, 2026, 10:00 -11:00
Please respond by August 20, 2026, with your preferred meeting date from the options above. If none of the
proposed times are available, please provide alternative dates and times for consideration. PG&E appreciates the
agencies' continued engagement and looks forward to working collaboratively to advance the Mitigation Plan
consistent with the Commission's July 15, 2026 request.
https://outlook.office.com/mail/sentitems/id/AAkALgAAAAAAHYQDEapmEc2byACqAC%2FEWg0ArO Gv%2FVov3UOJktS6GcZCWgAKQffYTQAA?nat... 1/2
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Document Accession #: 20260814-5010 Filed Date: 08/14/2026
Document Content(s)
PGE20260813_803_Fisheries_Plan_AIR2.pdf...................................1