Details for: PG&E's Reply to Comment of Advice 5606-E.pdf


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Pacific Gas mid 
 Electric Cfliiljliatllya 
 
 David T. Kuska Mailing Address 
 Attorney F‘.O. BOX 7442 
 San Francisco, CA 94170 
 
 Street/Courier Address 
 Law Departmenl 
 
 77 Beale Street, B3oA 
 san Francism. CA 94105 
 
 [415) 9734503 
 Fax: (415) 973-5520 
 Email David.Kraska@pge mm 
 
 September 4, 2019 BY ELECTRONIC DELIVERY 
 
 Mr. Andrew Barnsdale 
 
 Energy Division 
 
 California Public Utilities Commission 
 505 Van Ness Avenue 
 
 San Francisco, CA 94102 
 
 Re: Advice Leltcr 5606-E 
 Comment letter from the California Department oi'Fish and Wildlife 
 
 Dear Mr. Rarnsdalez 
 
 I am writing regarding a comment letter to Pacilie Gas and Elcetrie’s Advice Letter 
 5606—E submitted by the California Department of Fish and Wildlife (“CDFW”) on August 20, 
 2019 (“comments”), PG&F, is happy to provide this detailed response, which we hope will 
 resolve any remaining questions and allow Commission staff to approve the advice letter. 
 
 PG&F, appreciates CDFW’s comments on the Aera Energy LLC Victory Substation 
 Interconnection to the Follow-Midsun 115 kV Power Line project and shares it commitment to 
 ensure that all project impacts to biological and other resources will be To 
 that end, Aera Energy LLC and PG&l:‘ have incorporated many of the measures recommended 
 by CDF and made other niodifications to the proposed interconnection project to further 
 reduce project impacts. 
 
 1. INTRODUCTION 
 
 l’G&E filed Advice Letter 5606-131 with the Commission on August 1, 2019, concerning its 
 proposal to connect the existing Fellows-Midsun 115 kV Power Line to anew customer-owned 
 substation in Kern County. As indicated in the advice letter, the interconnection project is 
 exempt from permitting requirement under the General Order 131-I) (“G0 13 I 
 Section 111.132 (g) because die power line facilities will be located within existing public 
 utility easements or franchise areas. No exceptions to this exemption apply. l’G&E’s 
 interconnection project involves replacement of existing power line facilities with equivalent 
 facilities in an already disturbed utility corridor‘ and includes Avoidance and Minimization 
 Measures (“AMMS”), many consistent with those recommended by CDFW, that will ensure that 
 all environmental impacts will remain less than significant. 




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Pacific Gasamd I Electrieflolripatry“ Mr. Andrew Bamsdale September 4, 2019 Page II. PROJECT DESCRIPTION Acra Energy LLC, an oil and gas company. has requested PG&E to connect the existing Fe|lows—Midsun 115 kV Power Line to a new customer-owned substation in Kern County. The substation is located in a remote mineral and petroleum area approximately miles northwest of the intersection of Highway 33 and Midway Road, To connect the power line into the customer’s substation, PG&E will replace approximately five existing wood poles on the existing Fellows- Mirlsun ll5 kV Power l.ine with approximately four new light-duty steel, wood or engineered direct embedded poles, approximately to 15 feet taller. PG&E will also construct a new approximate 950-foot 115 l<V power line from the existing ellows—Midsun 115 kV Power Line to the new customer-owned substation to interconnect Acra l1'nergy’s new metering facilities. Approximately 850 feet of the new power line wi ll be located within existing franchise along the south side of Crneker Springs Road. The remaining 100 feet olpower line will be located on Aera Energy LLC substation-owned property. The new power line will be supported by approximately five new light-duty steel poles, approximately 64 to 72 feet tall. The heights of all new structures and replacement structures have been designed to comply with CPUC General Order 95 minimum ground-to-conductor clearance requirements. Construction is tentatively scheduled to begin in October 2019 or as soon as interconnection project plans and approvals are place. Construction will be completed in November 2019, or as soon as possible after construction begins, ANALYSIS The species-specific iesponses below were derived from analyses that included a review of the CNPS records, aerial imagery, and internal survey data. Pre-activity surveys were completed by biologists contracted by Aera on |2/20/ and again on 6/25/19. In addition to the pre-activity surveys, protocol surveys for San Joaquin antelope squirrels were completed over a three—day period between 6/25/19 and 6/27/19. ARCO Western Energy Habitat Conservation Plan (“AWEHCP”) ln its August 20, 2019 letter, CDFW states its understanding that PG&E’s interconnection project would he completed as a covered activity under l’G&l:"s San Joaquin Valley Habitat Conservation Plan (SJ Vl-lCl’) and CESA Incidental Take Permit No. 2081-2008—()()l-00. This assumption is inconect. Instead, PG&E’s interconnection project activities will be covered under the ARCO Western Energy Habitat Conservation Plan (AWEHCP). 'l'l1e AWEHCP addresses impacts of oil and gas operations on listed and candidate species in a large portion ofwestern Kern County, California. The major activities included in the are oil and gas production activities which may involve oil well construction, oil well vvorkovers, oil well abandonment, facility maintenance, road construction and maintenance, fire prevention, oil spill response and clean-up, pipeline and powerline construction and maintenance, and health and safety activities required by other
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Pacific Gas and I Electric L'ampany"‘ Mr. Andrew September 4, 2019 Page industry regulators. However, does not convey State authorization for take of species listed pursuant to CESA; thus, the intercomtection project must comply with all Mitigation Measures established on the Environmental Pt‘evActiviLy Surveys (EPAS) and follow CDFW recommendations to ensure complete avoidance of State listed and fully protected species. All work will occur in accordance with the provi 'ons and stipulations set forth in the AWEHCP, including mitigating for activity disturbances. Temporary and permanent impacts to habitat will be compensated through the with credits debited from the Coles Levee Ecological Preserve. The interconnection project /\MMs include the following mitigation measures that are applicable to the interconnection project: 1. Design of project should minimize areal extent olldisturbanccs, habitat loss, and amount of land. 2. Project site to be designed, constructed. and operated to prevent erosion, oll‘-site degradation, and reduce maintenance/repair cost. 3. Raptor perches required on construction of new lines for transformers. poles, and tangent poles. 4. Dens, burrows, or plant populations in project area shall be staked or flagged and protective buffer zones shall be established. 5. Biological monitor‘ on-call species are observed in the project area. 6. Biological monitor required on-site during initial ground disturbance and on-call for duration of project. 7. All cquipment staging areas, materials, and personnel shall be restricted to project site or disturbed off-site areas that are not habitat for listed species. 8. Maintain all well cellars for protection of wildlife and leakage from facilities. 9. Operate facility and equipment to prevent harm to wildlife (use of belt guards, oil drain screens. etc.) 10. No oil‘-road driving or driving on trails without an Fnvironmental Pre-activity Survey. No pets or firearms pemiitted on projects. 12. Solid wastes should be cleaned up to pro-spill conditions or as required. 13. Oil/chemical spill should be cleaned up to pre-spill conditions or as required. 14. linvilvonmental Prc-activity Survey for protected species must be conducted prior to action, which may cause disturbance. I 5. Recettification survey must be conducted it‘ project hasn’l commenced within 60 days (within 30 days at CLEP) of original survey. 16. USFWS should be notified prior to excavation of any San Joaquin kit fox den. 17. Pipes/culverts must be and inspected prior to moving/welding to prevent wildlife injury. 18. Any take of wildlife must be rcpurlcd to Coordinator. 19. Exit ramps are required on all steep-walled trenches/excavations and must be inspected twice per day. 20. Speed limit ol'25 Ml’!-l must be observed on Aera property, unless posted otherwise.
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Pacific Gas and Electric Campany“’ Mr. Andrew Barnsdale September 4, 2019 Page 21. Employees and contractors who may impact Endangeted Species are to be trained for awareness/mitigation of presence. 22. unidentified (lcns/burrows/plants must be avoided, and biological monitor notified immcdizttely. 23. Risk of hmnancaused fire should be minimized by following fire preventative procedures. 24. Daylight work only except for drilling operations or emergencies threatening human safety, or the environment (e.g. fire or spill). Blunt-nosed Leopard Lizard (BNLL) Surveys completed at the project site included an assessment of habitat and suitability for blunt- noscd leopard lizard. The results of the assessment were recorded on the AWE]-lCl’ l-.'l’AS forms and a determination was made that the potential for BN LL presence within the pmject area was low, based on the conditions within the project area consisting of disturbed habitat associated with past oil producing infrastructure, roadways, and other activities. Since protocol level surveys were not conducted and are not anticipated to be completed in accordance with the approved survey methodology, the interconnection project will be required to avoid all burrows by a minimum of 50-feet to avoid take and potentially impacts 01' burrow collapse, as recommended by CDFW. PG&l:' and Acrn will coordinate the design and plan to ensure avoidance of suitable BNLL burrows. If avoidance is dett-;rtn'med to not be feasible, construction will he reqttiretl to stop work in those specific stress and activities until further consultation and coordination with CDFW occurs. Crotch Bumble Bee (CHB) Surveys completed in 2018 and 2019 by Aera contract biologists did not obsewe signs of CBB activity or presence. The proposed project consists of work locations that have been disturbed by past oil producing activities mixed with small fragmented patches of saltbush scrub combined with ruderal or weedy species that were determined to be unsuitable for CBB. l-lowevcr, CDl"W’s rcconunendution that all stnall mammal burrows and thatched/bunch grasses be avoided by a minimum of 50-feet will be implemented. CD1-‘ W’s recommend avoidance butler combined with all other AWE]-ICP measures for avoidance and minimization will ensure impacts to CHE are less than significant. State Species of Special Concern Biological surveys and assessments conducted in August 2018, December 201 8. and July 2019 that no potential dens, special-status plants, special-status lizards or nesting birds were observed. Aerzfs AWE] ICP incorporates requirements to conduct additional pre-activity surveys prior to initiating construction activities to verify absence of sensitive resources, including state species of special concem.
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Pacific Gas and Electric Company” Mr. Andrew Barnsdale September 4, 20 Page Interconnection project development and implementation will comply with all wildlife mitigation measures including: a biological assessment prior to any work activity, use of hiological monitors during ground disturbance activities, staking or flagging ot‘but1'ers around all dens, burrows, or plant populations in the project area, ensuring no off-road travel shall occur, requiring work activities to be limited to daylight hours only, completion of a post-construction assessment report, and all other mitigation measures incorporated in the AWl:'l-{GP that could niinimize habitat disturlmnee. Nesting Birds No nests were identified dining the biological assessments conducted by Aera contract biologists, and the current interconnection project schedule would allow completion of activities during the general hird non-nesting season However, the interconnection project will still comply with all Migratory Bird Treaty Act and nesting bird—ielcvant Fish and (jainc Codes by recommend mezisures to ensure any potential impacts are less than significant, including: assessment and survey conducted no more than 10 days prior to the start ollany work activity conducted during the nesting bird season, use of monitors for construction activities within (‘DFW recommended huffers of 250-feet for non-listed birds, and S00-feet for non—listed raptors, and a post-construction assessment report. In addition, the interconnection project will be designed, constructed and operated to nvian safe standards. IV. CONCLUSION PG&E appreciates CDFW’s suggestions and has incorporated many into its proposed interconnection project. While CDFW’s comments do not mention the AWEHCP, the additional AMMS from the incorporated into PG&L"s proposed project provide enhanced protections for any species present in the project area. For the reasons stated above, PG&F. respectfully requests that Energy Division staff approve Advice Letter 5606-E under General Order 96—B, Section 7.6.1. Very truly yours, David T. Kraskn Chief Counsel, Environrnental DTK/dl cc: Julie A Vance, Regional Manager, CDFW Craig Bailey, Supervisor, CDFW
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