Pacific Gas and Electric Company Reports Non-Compliance with Regulatory Conditions at Spring Gap-Stanislaus Hydroelectric Project

Strategic Insights -

Pacific Gas and Electric Company (PG&E) recently submitted a self-report of non-compliance to the Federal Energy Regulatory Commission (FERC) regarding the late installation of fish screens at the Philadelphia Diversion Dam, a project component of the Spring Gap-Stanislaus Hydroelectric Project, FERC No. 2130. The non-compliance was discovered on March 26, 2025, and resulted in no personal injuries, damage to private property, or impacts to biological or cultural resources.

Key Takeaways:

  • PG&E's self-report of non-compliance was submitted to FERC regarding the late installation of fish screens at the Philadelphia Diversion Dam, resulting from an error in the company's internal planning, maintenance, and regulatory compliance tracker (SAP).
  • The non-compliance was discovered on March 26, 2025, and was related to Forest Service Section 4(e) Condition No. 40 and Water Quality Certification Condition No. 20.
  • PG&E's biologist concluded that no fish or other aquatic biota were harmed during the period between March 15 and March 26 when fish screens were missing from the Philadelphia Diversion Dam.
  • PG&E has implemented multiple corrective actions, including adjusting the notification due date for fish screen installation to March 15th of each year, establishing a notification start date one month in advance, and reviewing the Winter Operating Plan to confirm the removal of fish screens.
  • PG&E's License Management has also reviewed the Winter Operating Plan to ensure compliance with licensing conditions and uphold the company's commitment to environmental stewardship and operations accountability.

Statistics:

  • 0.65%: The percentage of open S-9 canal head gate used to keep the Spring Gap penstock full on November 27, 2024.
  • 0.306": The approximate height of the S-9 canal head gate opening to allow 0.8 cfs into the Philadelphia ditch.
  • 0.8 cfs: The amount of water allowed into the Philadelphia ditch to keep the Spring Gap penstock full.
  • 11.99: The number of days between removing the top row of fish screens on December 8, 2024, and discovering the non-compliance on March 26, 2025.

Sources:

  • Letter from Pacific Gas and Electric Company to Debbie-Anne Reese, Secretary Federal Energy Regulatory Commission, dated March 26, 2025 (Source: Letter to FERC, March 26, 2025)
  • Federal Energy Regulatory Commission License Number 2130 for the Spring Gap-Stanislaus Hydroelectric Project (Source: FERC License No. 2130)
  • U.S. Department of Agriculture, Forest Service, terms and conditions pursuant to Section 4(e) of the Federal Power Act (Source: USDA Forest Service Terms and Conditions)
  • State Water Resources Control Board's (SWRCB) Water Quality Certification pursuant to Section 401 of the Clean Water Act (Source: SWRCB Water Quality Certification)