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STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE SAN FRANCISCO, CA 94102-3298 June 28, 2016 Sam Danner Senior Land Planner Pacific Gas and Electric Company 2730 Gateway Oaks Drive #220 Sacramento, CA 95833 RE: Notice to Proceed Request No. 2 for the Missouri Flat-Gold Hill 115 kV Power Line Reconductoring Project Dear Mr. Danner: On March 4, 2016, Pacific Gas and Electric Company (PG&E) submitted a Notice to Proceed Request (NTP #1) to the California Public Utilities Commission (CPUC) regarding the Missouri Flat-Gold Hill 115 kV Power Line Reconductoring Project (Project), seeking the authority to proceed with construction of minor temporary modifications at the PW Pipe Substation and minor permanent modifications at the Limestone Substation. These modifications were requested to ensure reliable distribution to customers prior to the construction of the rest of the Project in approximately September 2016. The CPUC authorized PG&E to proceed with the proposed construction activities requested under NTP #1 on March 18, 2016, provided that all proposed actions and construction projects were to be carried out in accordance with the methods and conditions described in NTP #1, and subject to completion of certain implementing actions by PG&E prior to the start of construction. On May 18, 2016, PG&E submitted NTP #2 to the CPUC seeking the authority to proceed with construction of the main components of the Project. PG&E submitted the following items in accordance with Applicant Proposed Measures (APMs) and Mitigation Measures (MMs) described in the Mitigation Monitoring, Reporting, and Compliance Program for actions proposed under NTP #2: Applicant Proposed Measure / Mitigation Measure Implementing Actions Status/Determination APM AQ-3: Minimize Potential Naturally Occurring Asbestos Emissions Submit documentation of PG&E consultation with local air districts to determine if air monitoring for asbestos will be required Documentation submitted; see below regarding Asbestos Dust Mitigation Plan APM BIO-5.2: Noxious Weed Assessment and Control Plan Submit plan to CPUC for review Plan submitted; CPUC has follow-up comments/questions, see below MM 3.4-6: Oak Mitigation Plan Submit plan to CPUC for review Plan submitted; CPUC has follow-up comments/questions, see below APM TRA-2: Temporary Traffic Controls Obtain applicable transportation and/or encroachment permits prior to construction Encroachment Permit approval received from Caltrans for work over U.S. Highway 50
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STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC ... · • As stated in APM BIO-5.2, the Noxious Weed Assessment and Control Plan will assess areas at risk for noxious weed

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Page 1: STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC ... · • As stated in APM BIO-5.2, the Noxious Weed Assessment and Control Plan will assess areas at risk for noxious weed

STATE OF CALIFORNIA Edmund G. Brown Jr., Governor

PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

June 28, 2016 Sam Danner Senior Land Planner Pacific Gas and Electric Company 2730 Gateway Oaks Drive #220 Sacramento, CA 95833 RE: Notice to Proceed Request No. 2 for the Missouri Flat-Gold Hill 115 kV Power Line Reconductoring

Project Dear Mr. Danner: On March 4, 2016, Pacific Gas and Electric Company (PG&E) submitted a Notice to Proceed Request (NTP #1) to the California Public Utilities Commission (CPUC) regarding the Missouri Flat-Gold Hill 115 kV Power Line Reconductoring Project (Project), seeking the authority to proceed with construction of minor temporary modifications at the PW Pipe Substation and minor permanent modifications at the Limestone Substation. These modifications were requested to ensure reliable distribution to customers prior to the construction of the rest of the Project in approximately September 2016. The CPUC authorized PG&E to proceed with the proposed construction activities requested under NTP #1 on March 18, 2016, provided that all proposed actions and construction projects were to be carried out in accordance with the methods and conditions described in NTP #1, and subject to completion of certain implementing actions by PG&E prior to the start of construction. On May 18, 2016, PG&E submitted NTP #2 to the CPUC seeking the authority to proceed with construction of the main components of the Project. PG&E submitted the following items in accordance with Applicant Proposed Measures (APMs) and Mitigation Measures (MMs) described in the Mitigation Monitoring, Reporting, and Compliance Program for actions proposed under NTP #2: Applicant Proposed Measure / Mitigation Measure Implementing Actions Status/Determination

APM AQ-3: Minimize Potential Naturally Occurring Asbestos Emissions

Submit documentation of PG&E consultation with local air districts to determine if air monitoring for asbestos will be required

Documentation submitted; see below regarding Asbestos Dust Mitigation Plan

APM BIO-5.2: Noxious Weed Assessment and Control Plan Submit plan to CPUC for review Plan submitted; CPUC has follow-up

comments/questions, see below

MM 3.4-6: Oak Mitigation Plan Submit plan to CPUC for review Plan submitted; CPUC has follow-up comments/questions, see below

APM TRA-2: Temporary Traffic Controls

Obtain applicable transportation and/or encroachment permits prior to construction

Encroachment Permit approval received from Caltrans for work over U.S. Highway 50

Page 2: STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC ... · • As stated in APM BIO-5.2, the Noxious Weed Assessment and Control Plan will assess areas at risk for noxious weed

Sam Danner June 28, 2016 Page 2 The Project was evaluated in accordance with the California Environmental Quality Act and a Permit to Construct (PTC) was granted by the CPUC on October 22, 2015 (Decision 15-10-033). PG&E is authorized to proceed with construction activities for the Project, provided that all proposed actions and construction projects are carried out in accordance with the methods and conditions described in NTP #2, and subject to completion of the following implementing actions by PG&E prior to the start of construction:

• In accordance with APM AQ-3, PG&E will develop Asbestos Dust Mitigation Plans (ADMPs) to identify all necessary best management practices that will be implemented if naturally occurring asbestos (NOA) is encountered during construction. PG&E will submit the final ADMPs to the CPUC.

• As indicated on the Worker Environmental Awareness Program (WEAP) brochure submitted to the CPUC on March 23, 2016, PG&E shall insert maps of areas with NOA pending results of geological evaluation and final ADMPs.

• As stated in APM BIO-5.2, the Noxious Weed Assessment and Control Plan will assess areas at risk for noxious weed introduction and/or spread, and will identify measures for equipment and vehicle inspection. Approximately 20 invasive plant species were identified in the Pine Hill Preserve during botanical surveys. Please identify areas within the Pine Hill Preserve that are infested with weeds and measures that will be taken to prevent spreading weeds within the Preserve. Identification typically would involve flagging infested areas; typical avoidance measures include avoiding or minimizing vehicle/equipment operation/traffic in infested area, confining vehicle/equipment traffic to established access routes, washing vehicles/equipment before exiting infested areas or entering areas without weeds. If invasive populations are sparse enough that weed removal described in Section 3.5 of the plan would be sufficient to prevent spreading, please revise this section accordingly.

• PG&E submitted an Oak Mitigation Plan in accordance with MM 3.4-6. Please respond to comments and questions embedded in the Oak Mitigation Plan attached to this memorandum.

• In accordance with APM TRA-2, PG&E will provide El Dorado County and City of Folsom Encroachment Permits to the CPUC prior to initiation of construction.

• PG&E will implement the MMRCP to ensure implementation of all Applicant Proposed Measures (APMs), applicable Project mitigation measures, compliance plans, and permit conditions during construction activities. Some measures are on-going and/or have time-sensitive requirements and shall be implemented prior to and during construction as applicable. A copy of the MMRCP will be kept at the construction sites.

• Copies of all permits, compliance plans (e.g., MMRCP, Storm Water Pollution Prevention Plan, etc.), and the NTP shall be maintained on-site for the duration of the construction activities.

• Prior to construction activities, PG&E will conduct WEAP training for all Project personnel, including construction and monitoring personnel. PG&E will maintain training logs at the construction site and be made available upon request.

• In accordance with APM BIO-2, a qualified biologist will perform a pre-construction survey for any work areas within 100 feet of suitable habitat for special-status species. Surveys shall be submitted to the CPUC.

• In accordance with APM BIO-3, a qualified biologist will conduct pre-construction surveys for nesting birds prior to any tree trimming or other potential nest-disturbing activities. Surveys shall be submitted to the CPUC.

Page 3: STATE OF CALIFORNIA Edmund G. Brown Jr., Governor PUBLIC ... · • As stated in APM BIO-5.2, the Noxious Weed Assessment and Control Plan will assess areas at risk for noxious weed

Sam Danner June 28, 2016 Page 3

• As required by Mitigation Measure 3.4-5, any retained oak trees shall be protected by establishment of tree protections zones (TPZs). PG&E shall notify the CPUC when any TPZs have been established for review by CPUC construction monitors.

• Please provide proof of notification that PG&E has informed residences (and other noise-sensitive receptors) within 200 feet of construction areas, at least 30 days prior to the start of construction, of the construction schedule and potential nuisance (Mitigation Measure 3.12-4).

Sincerely, Connie Chen CPUC Environmental Project Manager cc: Mike Manka, ESA

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Oak Tree Mitigation and Monitoring Plan  

for the Missouri Flat‐Gold Hill 115 kV 

Reconductoring Project 

 

P R E P A R E D F O R P R E P A R E D B Y

Pacific Gas & Electric Company 2730 Gateway Oaks Drive Sacramento, CA 95833   

Stillwater Sciences2855 Telegraph Avenue, Suite 400 Berkeley, CA 94705 and American River Conservancy Post Office Box 562 Coloma, CA 95613  

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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy i

Suggested citation: Stillwater Sciences and American River Conservancy. 2016. Oak Tree Mitigation and Monitoring Plan for the Missouri Flat-Gold Hill 115 kV Reconductoring Project. Prepared for Pacific Gas and Electric Company, Sacramento, California. Cover photos: upper left = examples of oak trees along the project alignment; upper right = looking northwest at mitigation planting site at Salmon Falls Ranch; lower left = looking northeast at mitigation planting site at Salmon Falls Ranch; lower right = examples of oak trees along the project alignment.

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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy ii

Table of Contents

1  INTRODUCTION .................................................................................................................. 1 

1.1  Project Purpose and Description .................................................................................. 1 1.2  Project Area ................................................................................................................. 1 1.3  Mitigation and Monitoring Plan Purpose ..................................................................... 3 

2  MITIGATION QUANTITY .................................................................................................. 3 

3  MITIGATION LOCATION .................................................................................................. 4 

4  PLANTING METHODS ........................................................................................................ 4 

5  MAINTENANCE AND IRRIGATION ................................................................................ 6 

6  MONITORING AND REPORTING .................................................................................... 7 

6.1  Success Criteria ............................................................................................................ 7 6.2  Survival and Vigor Monitoring .................................................................................... 7 6.3  Photo Monitoring ......................................................................................................... 7 6.4  Data Analysis ............................................................................................................... 8 6.5  Monitoring Reports ...................................................................................................... 8 6.6  Remedial Actions ......................................................................................................... 8 

7  REFERENCES ........................................................................................................................ 9 

Tables Table 1. Vigor categories to assess oak planting condition. ........................................................ 7 Figures Figure 1. Missouri Flat-Gold Hill 115 kV Reconductoring project location. ............................... 2 Figure 2. American River Conservancy property where mitigation plantings will occur. ........... 5

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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy 1

1 INTRODUCTION

1.1 Project Purpose and Description

Pacific Gas and Electric Company (PG&E) currently owns and operates the double-circuit Missouri Flat-Gold Hill 115 kilovolt (kV) Power Line (numbers 1 and 2), and the Gold Hill-Clarksville 115 kV Power Line, which serve electric customers in El Dorado and Sacramento counties including the communities of El Dorado Hills, Cameron Park, Shingle Springs, and Diamond Springs, and the City of Placerville. To provide safe and reliable service to these growing communities, PG&E is planning to reconductor the section of the line between Gold Hill and Shingle Springs substations as part of the Missouri Flat-Gold Hill 115 kV Reconductoring Project (project). The project includes the following components.

a) Missouri Flat-Gold Hill Power Line Reconductoring. Approximately 12.5 miles of the Missouri Flat-Gold Hill double-circuit 115 kV power line interconnecting Shingle Springs, Clarksville, and Gold Hill substations (including two spans east of the Shingle Springs Substation to facilitate construction activities) will be reconductored. To accommodate the reconductored line, this project component also involves replacement of approximately 60 existing tubular steel poles (TSPs); and modifications to 10 existing steel lattice towers.

b) Gold Hill No. 1 Power Line Reconductoring. Approximately 7 miles of existing 60 kV line along the Gold Hill No. 1 power line from Clarksville Substation to just beyond Shingle Springs Substation will be reconductored to increase its capacity to 115 kV. To accommodate the reconductored line, this project component also involves replacement of approximately 80 existing wood poles with light-duty steel poles (LDSPs).

c) Substation Modifications. Minor modifications will be made to tie-in equipment at Shingle Springs, Missouri Flat, and Gold Hill substations to accommodate the power line upgrades.

1.2 Project Area

The project is oriented primarily east-west from Gold Hill Substation in the city of Folsom (northeastern Sacramento County), through Clarksville Substation in the community of El Dorado Hills, to Shingle Springs Substation in the community of Shingle Springs (western El Dorado County) (Figure 1). The project area is approximately 12.5 miles long and 300 feet wide, and totals approximately 634 acres. This area includes the 7-mile Gold Hill No. 1 power line, which runs directly alongside the Missouri Flat-Gold Hill power line for half of its distance (Figure 1). Approximately 45% of the project area is developed, while other areas include open grassy fields (30% of the project area), oak and riparian woodlands (11% of the project area), and chaparral and scrub (9% of the project area).

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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy 2

Figure 1. Missouri Flat-Gold Hill 115 kV Reconductoring project location.

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1.3 Mitigation and Monitoring Plan Purpose

The project is regulated by the California Public Utilities Commission (CPUC) and per CPUC General Order No. 131-D it is exempted from local land use and zoning regulations and discretionary permitting. However, PG&E considered local policies or ordinances when determining the potential significance of impacts resulting from implementation of the Project. El Dorado County General Plan Policy 7.4.5.2 identifies the County’s policy to protect and maintain native trees, including oaks and landmark and heritage trees. Policy 7.4.5.2 requires an Oak Tree Removal Permit for the removal of native oak trees at least 6-inches in diameter at breast height (dbh) or multiple trunks with an aggregate of at least 10-inches dbh. The project would remove up to approximately 225 trees, 125 of which have been identified as native oak trees meeting El Dorado County’s oak removal permit criteria, Policy 7.4.5.2. In addition, the operation of construction vehicles and other heavy equipment on or in the root zone of oak trees would result in damage to retained trees and/or their roots. Depending on the extent of such damage, and the particular circumstances of each retained tree, damaged trees may decline in health and suffer mortality at a rate faster than normally expected. To reduce the magnitude of the project impact on native oak trees and comply with the intent of El Dorado County’s General Plan Policy 7.4.5.2, PG&E will implement Application Proposed Measure (APM) BIO-1.4 (Tree Removal and Mitigation) and Mitigation Measures 3.4-5 (Tree Protection Zones and Mitigation) and 3.4-6 (Oak Mitigation Plan) from the CPUC’s Initial Study/Mitigated Negative Declaration (IS/MND) for the project (ESA 2015). These measures collectively require PG&E to replace removed native oak trees and retained native oak trees (as defined in Policy 7.4.5.2) that are significantly impacted by construction-related activities at a 1:1 ratio. As part of this mitigation, PG&E shall prepare an Oak Mitigation Plan when tree planting locations have been determined. The plan shall include, but is not limited to, details of the number of oak trees to be planted, based on the final total of trees removed or significantly impacted (Mitigation Measure 3.4-5d) by the Project, specific planting locations, maintenance and irrigation needs, monitoring requirements (i.e., at least 5 years monitoring plant vigor and growth), reporting requirements (e.g., annual reporting to the CPUC), and success criteria to be met before monitoring is concluded (e.g., 100 percent survival at a 1:1 replacement ratio; an independent assessment of “good” overall tree vigor; and tree viability without irrigation). This Plan fulfills the requirement of Mitigation Measure 3.4-6 and will be submitted to the CPUC for review and approval prior to implementation.

2 MITIGATION QUANTITY

The exact number of native oak trees meeting Policy 7.4.5.2 criteria that may be removed or significantly impacted by the project is unknown at this time. Construction monitors will be responsible for establishing tree protection zones (per Mitigation Measure 3.4-5) and maintaining a list and tally of native oak trees that meet Policy 7.4.5.2 criteria and are removed by the project or determined by a CPUC monitor to potentially decline and result in tree mortality at a rate faster than expected. Based on the current project schedule, it is anticipated that the number of removed oak trees will be known by early spring 2017, and the number of retained oak trees that may potentially decline and result in tree mortality at a rate faster than expected as a result of the project by late 2018.

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Applicant
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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

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For the time being, and based on the impact analysis in the IS/MND, it is estimated that up to 125 native oak trees meeting Policy 7.4.5.2 criteria may be removed or otherwise impacted by the project activities, and will have to be replaced. The mitigation location, planting methods, maintenance requirements, and monitoring and reporting included in this plan are appropriate for mitigation on this scale, but will also be appropriate if the mitigation quantity is somewhat less or more.

3 MITIGATION LOCATION

All oak mitigation plantings will occur at the American River Conservancy’s (ARC’s) Salmon Falls Ranch Trailhead property off of Salmon Falls Road, near Folsom Lake, in El Dorado County (Figure 2). This site is approximately 10 miles north of the project and is considered to be ideal for the mitigation plantings, as it already supports oak woodland vegetation and has soil and exposure conditions conducive to oak tree establishment and growth. ARC will be constructing a parking area, driveway and trail on approximately 152 acres (APN 104-060-48) immediately east of Salmon Falls Road and ¼ mile north of the Salmon Falls bridge crossing over the South Fork American River (SFAR). This recreational trailhead facility will serve as a western terminus for the SFAR Trail. The purpose of the Salmon Falls Ranch Trailhead project is to enhance and improve trail-related recreational facilities associated with the SFAR for County residents and visitors from surrounding areas. Construction is expected to commence in mid-2016. As a part of the Salmon Falls RanchTrailhead project, ARC will be planting native oaks and associated oak woodland tree, shrub, and herbaceous species that are compatible with the constructed trailhead and public access features (i.e., plantings that will enhance the public access experience but not be located where they are at high risk of being damaged or destroyed). Oak mitigation plantings for PG&E’s project will be done concurrently with ARC’s planned plantings, and will be integrated into the site in a naturalistic way, but will be located somewhat separately from other oak tree plantings to ensure they can be easily differentiated during monitoring and maintenance.

4 PLANTING METHODS

Native oaks, of the species impacted by the project (which are anticipated to be valley oak [Quercus lobata], blue oak [Q. douglasii], and interior live oak [Q. wizlizenii]), will be planted approximately 10–15 feet apart from one another in the mitigation planting area (Harper and Strandiford 2016). The Conservancy may use container stock of locally collected oaks that have been grown in their native plant nursery, but mitigation plantings are anticipated to be locally collected acorns, which typically have higher long-term success rates and reduce the risk of introducing plant pathogens such as sudden oak death (Phytophthora ramorum).Where container stock is used, one oak seedling/sapling will be planted for each required mitigation planting. Where acorns are used, a cluster of two to four acorns will be planted for each required mitigation planting (Harris 2013, Harper and Strandiford 2016).

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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy 5

Figure 2. American River Conservancy property where mitigation plantings will occur.

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I suggest adding a reference map insert so reader can get a bearing of restoration site location.
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The ground at each planting location will be prepared by clearing grass, thatch, and any herbaceous vegetation in a three-foot diameter circle and digging or augering a 10-inch deep planting basin to loosen the ground (Anderson 2010, Harris 2013). Locally sourced acorns will be planted in clusters of two to four at a depth of 1-2 inches (Harris 2013, Harper and Strandiford 2016). If container stock is used, planting basis will be dug deeply enough to contain the entire rootball plus surrounding soil up to the base of the seedlings/saplings trunk. Planting basins will be backfilled with a weed-free topsoil mix (sand and topsoil) in order to discourage weed competition at each planting site. The 3-foot diameter area around each planting will be covered with weed inhibiting fabric and a thick layer (4-6 inches deep) of oak/manzanita chippings obtained locally. Each planting location will be tagged with a label indicating the number of acorns planted and oak species, for identification during the monitoring period, and recorded on a map and/or with a handheld geographic positioning station (GPS) receiver. Tubex Treeshelters will be used to protect seedlings from animal browse damage, wind, and other natural occurrences. In addition, the greenhouse environment created by the shelter can promote seedling growth. Plant protectors will remain in place until saplings reach a height of approximately three feet. Unless the ground is saturated at the time of planting, all planting locations will be “watered in” with supplemental irrigation immediately following planting. A mitigation planting spreadsheet will be developed and maintained to record the:

species of each planting, method of planting (nursery stock or acorns), date of planting and any re-planting that may be necessary, and date of last irrigation application.

5 MAINTENANCE AND IRRIGATION

Maintenance of the mitigation plantings is anticipated to primarily involve weeding, watering, reinstalling protectors and tags, and replacement plantings if necessary. Weeds within approximately 2 feet of plantings will be removed approximately annually, or more often if needed, by hand or mower (herbicide will not be used) until it is obvious that the plantings can out-compete the type and density of weeds at the site, or up to five years. Temporary irrigation will be provided by water truck (once the trailhead and parking lot work is completed there will be vehicle access to the portion of the site where mitigation plantings will occur) as needed until plantings have become established, which is anticipated to take approximately three years. The specific irrigation schedule and quantity will be determined by American River Conservancy land stewardship staff based on site-and season-specific conditions. Watering will be tapered off following seedling establishment to prevent irrigation dependency by the seedlings. The date of any watering will be recorded in mitigation planting spreadsheet. If monitoring (see section below) determines that a planting has not germinated or otherwise been unsuccessful, replacement plantings will be made. An effort will be made to determine why the initial planting was not successful, and the replacement planting methods (see section above) will be revised accordingly.

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This language is ambiguous. Who decides that it is "obvious" and how is it determined? Often time, mitigation plans use % of weed cover in the plot (in this case, 3' diameter circle) to determine if weeds are out-competing the mitigation planting. Example: non-native weed species shall not exceed 20% of the mitigation planting area (a 3' diameter circle).
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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy 7

6 MONITORING AND REPORTING

Monitoring and maintenance of the oak mitigation plantings will occur annually toward the end of the plant growing season (approximately August/September) for up to five years to determine the need for maintenance and if the success criteria (see section below) are being met. If success criteria are not met, remedial actions (e.g., replanting) will be implemented.

6.1 Success Criteria

The native oak mitigation will be considered successful when the following criteria have been met:

100 percent survival at a 1:1 replacement ratio at the end of five years (i.e., the number of mitigation plantings alive at the end of five years is the same as the number of oaks impacted by the project)

The vigor of mitigation plantings is an average of “fair” at the end of five years Mitigation plantings have survived for at least two consecutive growing seasons without

irrigation Evaluation of the survival success criteria may be conducted as early as year 1 or 2 to determine if the plantings are on track to meet the criteria by the end of five years.

6.2 Survival and Vigor Monitoring

Using the mitigation planting spreadsheet, the vigor of each oak mitigation planting will be evaluated and recorded using the vigor categories listed in Table 1. For any planting with a vigor category of 0 or 1, a note will be taken of the presumed reason for poor health or mortality (e.g., herbivory, water stress, pathogens, etc.).

Table 1. Vigor categories to assess oak planting condition.

Category Description

3 Good. Less than 30% of the plant affected by cumulative symptoms of poor health, (e.g., disease, insect damage, mechanical damage, or poor structure)

2 Fair. 31 to 75 percent of the plant affected by cumulative symptoms of poor health

1 Poor. Greater than 75% of plant affected by cumulative symptoms of poor health

0 Dead

6.3 Photo Monitoring

Fixed locations for photo monitoring (i.e., photopoints) will be established during the initial planting effort to capture changing conditions throughout the mitigation planting area. To ensure consistency, the location of photopoints will be recorded using a handheld GPS receiver, all photos will be taken from a standing position, and a compass bearing of the direction the camera is facing will be taken (or the compass bearing for the start and end of a panoramic series of photographs). Photographs will be taken from the photopoints immediately after the planting effort and during each annual vigor monitoring effort.

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I suggest that 2 surveys (spring, fall) be conducted following the initial planting to allow for more flexible management and response to issues such as drought, herbivory, weed maintenance, replanting, etc. Monitoring can taper off to once per year after oak plants become established (perhaps in Year 3). Fall surveys should be conducted before deciduous oaks drop their leaves.
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The mitigation measure (MM 3.4-6) requires that success criteria be based on 100% survival at a 1:1 replacement ratio; an independent assessment of "good" overall tree vigor; and tree viability without irrigation. The "good" overall tree vigor is for each individual plant, not an average of all plantings. Average of fair or better means that some oaks could potentially be in poor vigor/condition. These oaks have a low likelihood of surviving past seedling stage. An oak with a poor vigor has greater than 75% of the plant affected by symptoms of poor health.
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How were these categories derived?
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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy 8

Photographs of other notable features or incidental observations will also be taken during each monitoring effort. Qualitative observations of plant stress and likely cause (e.g., herbivory, water stress, pathogens, etc.), and distribution and abundance of weeds will also be noted during annual monitoring efforts.

6.4 Data Analysis

After each monitoring effort, the vigor data will be analyzed for: Survival by species (i.e., the number of plantings of individual oak species with vigor

categories greater than 0) Average vigor category for each species Total survival of all plantings together Average vigor category of all plantings

Beginning as early as year 1, these metrics will be compared to the required number of mitigation plantings and the success criteria to determine if remedial actions are needed (see section below). After irrigation has begun to be tapered off, the vigor data will be analyzed by date of last irrigation, to determine the survival of plantings that have not been receiving irrigation.

6.5 Monitoring Reports

An annual monitoring report will be prepared, submitted to PG&E for review, and ultimately submitted to the CPUC. The annual reports will document the data collected during the monitoring, the data analyses (see section above), and comparisons with relevant success criteria. If these comparisons suggest that the success criteria may not be met by the end of five years, remedial actions (e.g., planting) to be implemented prior to the following years’ monitoring effort will be described. Reports will include the following sections:

Introduction/Background Activities Performed (e.g., initial plantings in the year 1 report, and major maintenance or

remedial actions in subsequent monitoring years) Monitoring Methods and Date Monitoring Results (e.g., qualitative and quantitative results, comparisons with previous

years’ data, etc.) Comparison with Success Criteria Recommendations for Remedial Actions (if needed)

6.6 Remedial Actions

Remedial actions are anticipated to include replanting of species that did not survive (these would be planted using the same methods as initial plantings, unless the planting method was determined to contribute to the plant mortality), more frequent or higher quantities of irrigation, more frequent weeding, and/or additional herbivore protection measures. These may be undertaken at any time to help ensure success criteria are achieved by the end of five years.

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Plants in vigor category 1 (poor condition) is not acceptable to contribute to success criteria because these oaks have low likelihood of survival past active management. Category 1 should not be included in the average. One of the success criteria include independent assessment of "good" overall tree vigor; this is not an average but an assessment of individual trees. If this measure is interpreted as "average," then the average still needs to be in the "good" category for success to be achieved.
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Missouri Flat-Gold Hill Oak Tree Mitigation and Monitoring Plan

March 2016 Stillwater Sciences and

American River Conservancy 9

Should the success criteria (see section above) not be met at the end of the five-year monitoring period, discussions with CPUC will occur to determine the necessary course of action. During any remedial actions phase, PG&E may choose to develop interim success criteria to allowing the remedial actions more time to work, and increase the likelihood of meeting the final success criteria.

7 REFERENCES

Anderson, M. 2010. Procedures for planting fully sheltered acorns. Access at http://ucanr.org/sites/gsobinfo/files/152320.pdf. ESA. 2015. Pacific Gas and Electric’s Missouri Flat-Gold Hill 115 kV Power Line Recondutoring Project (CPUC A13-08-014) final Initial Study/Mitigated Negative Declaration. Prepared for the California Public Utilities Commission, March 2015. Harris, R. R. 2013. Oak woodland restoration potential: Placer County Conservation Plan. Harper, J. M., and R. B. Standiford. 2016. How to grow California oaks. The Oak Woodland Conservation Workgroup. Division of Agriculture and Natural Resources, University of California. http://ucanr.edu/sites/oak_range/Oak_Articles_On_Line/Oak_Regeneration_Restoration/How_to_Grow_California_Oaks/ [Accessed online on 21 January 2016].

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Will the interim success criteria be communicated to CPUC?
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STATE OF CALIFORNIA Edmund G. Brown Jr., Governor

PUBLIC UTILITIES COMMISSION 505 VAN NESS AVENUE

SAN FRANCISCO, CA 94102-3298

July 26, 2016 Sam Danner Senior Land Planner Pacific Gas and Electric Company 2730 Gateway Oaks Drive #220 Sacramento, CA 95833 RE: Notice to Proceed Request No. 2 for the Missouri Flat-Gold Hill 115 kV Power Line Reconductoring

Project Dear Mr. Danner: On October 22, 2015 the California Public Utilities Commission (CPUC) adopted the Final Initial Study and Mitigated Negative Declaration (IS/MND) for the Missouri Flat-Gold Hill 115 kV Power Line Reconductoring Project (Project) and approved the Project (Application 13-08-014) in a decision issued on October 27, 2015. The decision grants Pacific Gas and Electric Company (PG&E) a Permit to Construct and approves the Project conditionally with the implementation of Applicant Proposed Measures and Mitigation Measures adopted in the Mitigation Monitoring, Compliance, and Reporting Program (MMRCP). On March 4, 2016, PG&E submitted a Notice to Proceed Request (NTP #1) to the CPUC seeking the authority to commence with construction of minor temporary modifications at the PW Pipe Substation and minor permanent modifications at the Limestone Substation. The CPUC authorized PG&E to proceed with the proposed construction activities requested under NTP #1 on March 18, 2016, provided that all proposed actions and construction projects were to be carried out in accordance with the methods and conditions described in NTP #1, and subject to completion of certain implementing actions by PG&E prior to the start of construction. On May 18, 2016, PG&E submitted NTP #2 to the CPUC seeking the authority to proceed with construction of the main components of the Project. This letter authorizes PG&E to commence work described in the NTP #2 on a conditional basis. The conditions of approval for commencing work are described below. NTP Request PG&E requested NTP #2 from the CPUC to begin construction of the Project. The Project would reconductor 12.8 miles of the Missouri Flat-Gold Hill Line (115 kV) and 7 miles of the Gold Hill No. 1 Line (60 kV). Modifications to the Missouri Flat-Gold Hill Line include:

• Replacement of 60 double-circuit tubular steel poles (TSPs) and one single-circuit TSP with new TSPs. • Modification of 13 double-circuit lattice steel towers. • Undergrounding of approximately 1,000 feet of existing 21 kV overhead distribution line.

Modifications to the Gold Hill No. 1 Line include:

• Replacement of 102 wood poles with new wood or light-duty steel poles and one new TSP. • Replacement of 1-3 wood switch poles with TSPs.

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Sam Danner July 26, 2016 Page 2

• Relocation of 150 feet of distribution feeder line and wood pole replacement. Minor modifications to substation equipment and facilities would also occur at the Shingle Springs, Pacific Western Pipe, Limestone, Clarksville, and Gold Hill substations, and Missouri Flat Switching Station. These modifications would tie the new conductor into the substations and modify existing equipment to accommodate the line upgrades. All substation equipment would be sized adequately to match or exceed new line requirements. All modifications would be completed within existing substations or switching station fence lines and no substation expansions would occur. Construction activities would include preparation of temporary staging areas, work areas, and access road improvements; installation of temporary guard structures to prevent conductor from falling onto roadways or contacting other utility lines during replacement activities; installation of new poles; removal of existing conductor and replacement with new conductor; removal of old poles; and cleanup/site restoration. Authorization of NTP #2 This NTP authorizes PG&E to commence all construction and mitigation activities for the approved Project, as described in the Final IS/MND. NTP #2 Conditions of Approval The NTP is approved by the CPUC with conditions. PG&E is authorized to proceed with construction activities for the Project, provided that all proposed actions and construction projects are carried out in accordance with the methods and conditions described in NTP #2, and subject to completion of the following implementing actions by PG&E prior to the start of construction:

• In accordance with APM TRA-2, PG&E will provide El Dorado County and City of Folsom Encroachment Permits to the CPUC prior to initiation of any project activities that would be subject to the encroachment permits.

• In accordance with APM BIO-2, a qualified biologist will perform a pre-construction survey for any work areas within 100 feet of suitable habitat for special-status species. Surveys shall be submitted to the CPUC.

• In accordance with APM BIO-3, a qualified biologist will conduct pre-construction surveys for nesting birds prior to any tree trimming or other potential nest-disturbing activities. Surveys shall be submitted to the CPUC.

• As required by Mitigation Measure 3.4-5, any retained oak trees shall be protected by establishment of tree protections zones (TPZs). PG&E shall notify the CPUC when any TPZs have been established for review by CPUC construction monitors.