`
`PLACER COUNTY WATER AGENCY
`SINCE
`BOARD OF DIRECTORS
`Gray Allen, District |
`PrimoSantini, District 2
`
`144 Ferguson Road
`MAIL
`
`BUSINESS CENTER
`
`.
`water « energy * stewardship
`
`Mike Lee, District 3
`Robert Dugan, District 4
`Joshua Alpine, District &
`Andrew Fecko, General Manager
`
`P.O. Box 6570
`Auburn, CA 95604
`mea
`PHONE
`(530) 823-4850
`(800) 464-0030
`AAA. PCA. NET
`
`May 22, 2023
`
`FILED ELECTRONICALLY
`
`Kimberly D. Bose, Secretary
`Federal Energy Regulatory Commission
`ATTN: OEP/DHAC
`888 First Street NE
`Washington, DC 20426
`
`Subject:
`
`Middle Fork American River Project (FERC Project No. 2079)
`French MeadowsTransmission Line Project (FERC Project No. 2479)
`
`Informational Letter Alerting FERC of Grid Interconnection Issues that Jeopardize
`Middle Fork American River Project License Requirements
`
`Dear Secretary Bose:
`
`On September 6, 2022, an equipment failure at a Pacific Gas and Electric (PG&E) facility adjacent to the
`Oxbow Powerhouse ledto the ignition of the Mosquito Fire in the American River watershed in Northern
`California, which eventually burned nearly 77,000 acres of the Middle Fork American River and Rubicon
`River watersheds. As a result of the fire, Placer County Water Agency (PCWA) has requested, and FERC has
`granted, several extensions of time necessary to complete requirements of the Middle Fork American River
`Project’s (Project 2079) operating license. PCWA appreciates those extensions; andit writes today to alert
`FERC and requestits assistance with respect to additional Project 2079 license compliance issues that may
`arise later this month as a result of PG&E’s refusal to reconnect PCWA’s Oxbow Powerhouse to the
`California electricity grid through PG&E’s French MeadowsTransmission Line Project (Project 2479).
`
`The Oxbow Powerhouse has been disconnected from the California electricity grid since a significant and
`prolonged below nominal voltage condition occurred on the afternoon of September 6, 2022, on the
`transmission line that Oxbow Powerhouse is interconnected with. This condition caused Oxbow
`
`Powerhouseto separate from the transmission line in order to protect itself. Several hours later, and
`unrelated to the condition at Oxbow Powerhouse, an event occurred on PG&E’s transmission line that
`sparked the Mosquito Fire. Oxbow Powerhouse’s primary transmission line is the Oxbow Tap, whichis
`owned and operated by PG&E as part of PG&E’s French MeadowsTransmission Line Project (Project
`2479). The Oxbow Tap is a 0.16-mile-long, 60-kV transmission line extending from PCWA’s Oxbow
`powerhouse to the interconnection at PG&E’s non-project Weimar #1 60kVtransmission line.
`
`While the Mosquito Fire caused significant damage to PG&E’s transmission facilities in the vicinity of the
`Oxbow Powerhouse,including French MeadowsProjectfacilities such as the Oxbow Tap,it is PCWA’s
`understanding that those transmission facilities have now been fully rebuilt and/or repaired. PCWA has
`
`1 Pacific Gas & Elec. Co., 140 FERC 4] 62,062, P 1 (2012) (“French MeadowsLicense”).
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`

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`therefore requested, and continues to request, that PG&E restore the interconnection of the Oxbow
`Powerhouse to the California electric grid.
`
`However, PCWA has been notified by PG&E operational staff that as of this date, the Oxbow Powerhouse
`Interconnection remains on a “legal hold” as a result of a directive by PG&E’s legal counsel involved in
`pendinglitigation related to the Mosquito Fire. Since the Oxbow Powerhouse was islanded and not
`connected to the Oxbow tap and Weimar #1 60kV fine at the time of the fire incident, it is unclear why
`PG&E's counsel have any interest in blocking the reconnection. Regardless, PG&E has not identified any
`engineering or technical reasons forits refusal to reconnect the Oxbow Powerhouse, and PCWAis not
`aware of any such reasons; in particular, PCWA is not aware of any reason to believe that the equipment
`failure that sparked the Mosquito Fireis likely to recur. Furthermore, the Oxbow Powerhouse has
`undergonesignificant protection relay upgrades, planned and approved by PG&E long before the start of
`the Mosquito Fire, which must be tested jointly by PCWA and PG&E before interconnection can be
`completed. The ‘legal hold’ is preventing completion of this critical testing.
`
`The Oxbow Powerhouse facility, and its associated reservoir, Ralston Afterbay, are critical facilities. Most
`importantly these facilities are key water flow regulating features of the Middle Fork American River
`Project that allow our larger upstream generating facilities to provide peaking generation services to the
`California electric market without fluctuating the Middle Fork American River flows up and down
`unnecessarily. By buffering energy peaking operations, the facilities allow PCWA to make predictable and
`safe releases for recreation and environmental purposes at rates prescribed by PCWA's Project 2079
`license. Without the Oxbow Powerhouse online and operating, PCWA only has three ways to release water
`to the Middle Fork American River: using Ralston Afterbay spill gates, which are not designedfor precise
`flow releases and must be opened manually, a mid level “fish-flaw” valve, which has been impacted by
`Mosquito Fire induced sediment and mud flows and the low level outlet of Ralston Afterbay dam, which is
`unable to pass flow rates necessary for recreation rafting and has also been severely impacted by Mosquito
`Fire induced sediment and mud flows .
`
`The Oxbow Powerhouse also contributescritical grid services that heip provide reliable electric service to
`neighboring communities, including Foresthill, California, that are continuing to experience frequent power
`outages since the Mosquito Fire.
`
`PCWA’s Middle Fork American River Project License requirements for recreational releases begin on May
`27. These include flows for commercial and private whitewater rafting, as well as flows designed around
`recreational angling opportunities. Without interconnection and full operation of the Oxbow powerhouse,
`PCWA cannot assure that these flow releases can be made inareliable, predictable, and safe manner.
`Given that PCWA requires up to three days of testing of the new plant protection relay equipment after
`interconnection of the facility, if PG&E does not agree to interconnection by May 24, it will be impossible
`to guarantee license condition compliance by Monday, May 27.
`
`The purpose of PG&E’s French Meadows Transmission Line Project (Project 2479} is to deliver electricity
`from PCWA’s Middle Fork American River Project (Project 2079), including the Oxbow Powerhouse,to the
`California electricity grid; Project 2479 is the primary transmission line for Project 2079,’ and the two
`projects form a “complete unit of improvement or development.”? PCWA respectfully requests FERC’s
`assistance in assuring that PG&E,as licensee for the French MeadowsProject, promptly resumes operation
`of the Oxbow Tap and restores the Oxbow Powerhouseinterconnection consistent with that purpose.
`
`2 td.
`3 See 16 U.S.C. § 796(11); see also French MeadowsLicense P 1, P 34 & n.20.
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`

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`If PG&E nevertheless continues to withhold interconnection for the Oxbow Powerhouse, PCWAwill provide
`FERC with an updateof its plans and any requested waivers or extensions regarding recreational releases
`by Friday, May 26, 2023.
`
`If you have any questions regarding these filings please contact me by phone at 530-823-4860 or via e-mail
`at afecko@pcwa.net.
`
`Sincerely,
`
`PLACER COUNTY WATER AGENCY
`
`Andrew Fecko
`
`General Manager
`
`