KC Hydro a collaboration of Davis Hydro LLC & Sackheim Consulting 5096 Cocoa Palm Way Fair Oaks, CA 95628

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1 June 7, 2010 KC Hydro a collaboration of Davis Hydro LLC & Sackheim Consulting 5096 Cocoa Palm Way Fair Oaks, CA The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 1st Street, NE, Mail Code PJ-12.3 Washington, DC filed electronically Ref: Kilarc-Cow Creek Hydroelectric Project, FERC No Application for Surrender of License by Licensee Pacific Gas and Electric Company Re: Cultural Resources Analysis in Environmental Impact Statement and Section 106 Consultation Dear Ms. Bose: KC Hydro supports the intention of the Federal Energy Regulatory Commission (FERC) to prepare an Environmental Impact Statement (EIS) before taking action in this proceeding, as noticed in Accession No KC LLC also supports the Section 106 Consultation process, as reflected in the FERC letter filed under Accession No , as a vehicle to minimize and mitigate project impacts to culturally significant properties. As reflected in our letter (copy filed as FERC Accession No ) to the federal Advisory Council on Historic Preservation (ACHP) and State Historic Preservation Officer (SHPO), we dispute the completeness of the Cultural Resource Inventory and Evaluation addressing the historic features of the project, prepared on behalf of PG&E by Garcia and Associates (GANDA, revised version dated March 12, 2009). We are joined in our concern by the Shasta Historical Society and Whitmore Community Stakeholders (see FERC Accession No ). We specifically dispute the assertion that a majority of the resources do not qualify for listing in the National Register of Historic Places (NHRP) either individually or as part of a historic district. Although more than 60 days have passed since our letter, and the FERC request for comments and recommendations within 30 days, we are aware of no response from the SHPO or ACHP. Meeting Energy Needs with Renewable Power Development and Conservation

2 The Honorable Kimberly D. Bose, Secretary Ref: Kilarc-Cow Creek Hydroelectric Project, FERC No Application for Surrender of License by Licensee Pacific Gas and Electric Company Re: Cultural Resources Analysis in Environmental Impact Statement and Section 106 Consultation June 7, 2010 Page 2 I prepared the attached map locating some of the features that we believe should be considered eligible, both individually and as components of a historic district encompassing the Kilarc Development, for listing in the NRHP. We believe that dismantling of these facilities as proposed by PG&E would be properly characterized as a significant impact to cultural resources and could easily be avoided. We further believe that concerned stakeholders should have the opportunity to view the facilities in place before any action is taken, but have been rebuffed by PG&E in our attempt to organize an informational tour to easily accessed areas that are in current (perhaps unwanted) use by the public (see attached correspondence). We respectfully request that the FERC timely address our concerns concurrent with consultation with the SHPO and preparation of an environmental analysis of alternatives that do not require dismantling of facilities upon license surrender. Kelly W. Sackheim, Principal KC Hydro Attachments cc: augmented P-606 Service List 5096 Cocoa Palm Way fax: 916/ Fair Oaks, CA KC Hydro ph: 916/

3 FERC PDF (Unofficial) 6/7/ :48:39 AM Historic Features of the Kilarc Hydroelectric Project

4 1 of 2 6/7/2010 8:37 AM Response Re: Access Permission FERC PDF Request (Unofficial) for Public Group 6/7/2010 to View Hist... 11:48:39 AM Subject: Response Re: Access Permission Request for Public Group to View Historic Features of the Kilarc Hydroelectric Project From: "Kelly W. Sackheim" <kws@sackheimconsult.com> Date: Mon, 07 Jun :33: To: "Whitman, Lisa" <LxWt@pge.com> CC: "Evans, Stacy" <SXEF@pge.com>, Jan Caster <JCaster@spi-ind.com>, Herb Baldwin <HBaldwin@spi-ind.com>, Mark Emmerson <memmerson@spi-ind.com>, "Livingston, Randy" <RSL3@pge.com>, "Walther, Janet" <JMW3@pge.com>, Sandy Winters <sandwint@aol.com>, shs@shastahistorical.org, Laura Carnley <calass@frontiernet.net> BCC: "Carnley, Laura@CWS-CMS" <Laura.Carnley@CWS.state.ca.us> Lisa, As demonstrated in the FERC public record (FERC Accession No ) and correspondence to the pertinent federal and state cultural resource agencies (FERC Accession No , co-signed by Sandra Winters, Volunteer, Shasta Historical Society), Whitmore Community Stakeholders and KC Hydro (a collaboration of Davis Hydro and Sackheim Consulting) dispute the completeness and conclusions of the "thorough" Cultural Resource Inventory and Evaluation addressing the historic features of the project, prepared on behalf of PG&E by Garcia and Associates (GANDA, revised version dated March 12, 2009). Members of the public have expressed interest in visiting specific historic features that are proposed for demolition, notwithstanding our belief that these remain valuable cultural resources that should not be destroyed and were not part of the two public tours of the project facilities led by PG&E. We regret that PG&E chooses not to accommodate efforts to better inform the public and improve the record regarding the nature of these facilities. Kelly Whitman, Lisa wrote: Kelly, Thank you for your inquiry. PG&E has prepared a thorough Cultural Resource Inventory and Evaluation that addresses the historic features of the Project, and has also led two public tours of the project facilities that visited several of the features included in your May 24th . We are now awaiting the release of FERC's draft environmental document to determine what additional action might be required. While you are clearly free to visit project facilities located in areas open to the public (e.g. around Kilarc Forebay), PG&E will not be offering or authorizing additional public tours at this time. -Lisa Lisa Whitman License Project Manager Pacific Gas & Electric Company Mail Code N11C, P.O. Box San Francisco, CA Phone: /Fax: /Cell: lxwt@pge.com -----Original Message----- From: Kelly W. Sackheim [mailto:kws@sackheimconsult.com] Sent: Monday, May 24, :19 PM To: Mark Emmerson; RSL3@pge.com Cc: sxef@pge.com; Whitman, Lisa; Herb Baldwin; Jan Caster Subject: Access Permission Request for Public Group to View Historic Features of the Kilarc Hydroelectric Project Members of the public have expressed interest in learning more about historic features

5 2 of 2 6/7/2010 8:37 AM Response Re: Access Permission FERC PDF Request (Unofficial) for Public Group 6/7/2010 to View Hist... 11:48:39 AM of the Kilarc project that presently remain in place. I prepared the attached graphic using a USGS map and photographs from the Cultural Resources Evaluation and Inventory prepared by GANDA for PG&E and found in Appendix M of the License Surrender Application. I would like to take members of the public who are interested in seeing the historic features on a tour of the site on Saturday, June 26, to coincide with the annual Tuscan Heights Lavender Gardens Festival in Whitmore. I am aware that PG&E's and SPI's liability concerns must be addressed, and request to be provided a point of contact with whom I may discuss your requirements and arrangements that would minimize your concerns while allowing this informative tour to occur. I have not yet begun to coordinate with the Shasta Historical Society, as I would appreciate your feedback first, but I do anticipate they will be interested in co-sponsoring this activity. I would appreciate your prompt attention to this matter. Kelly Sackheim, Principal, KC LLC ph: 916/ fax: 916/ kws@sackheimconsult.com or ferc@sackheimconsult.com or kelly@kchydro.com

6 CERTIFICATE OF SERVICE I hereby certify that I have on this day served the foregoing document by first class mail postage prepaid or upon each person designated on the official service list compiled by the Secretary of the Commission in this proceeding. Dated at Fair Oaks, CA this 7th day of June Kelly W. Sackheim, Principal Sackheim Consulting 5096 Cocoa Palm Way Fair Oaks, CA 95628

7 Document Content(s) kwskcculturalissues_p-606.pdf...1-6