Annual Report Structure

The appendix outline of the annual compliance report. Field duties left out.

Type
Compliance Index List
Project
Delta Conveyance
Exported
2026-10-19
Actions
81
Obligations
24
ItemTypeCommitments
Reporting to CDFW
Monthly and annual reports
Actions
Deliver Final Phase Mitigation Report to CDFWReportingCOA 10.15
Deliver Mitigation Status Report Before ITP ExpirationReportingCOA 10.15.1
Submit Photo Monitoring Documentation ReportReportingCOA 10.6
Take, injury and non-compliance
Actions
Consult CDFW on Deceased CTS Specimen DisposalApproval & ConsultationCOA 11.52.3
Notify CDFW of Inability to Comply with the ITPReportingCOA 9.3
Notify CDFW of Potential CBB Nest LossReportingCOA 11.102
Notify CDFW of TRBL Nest or Colony Abandonment or DistressReportingCOA 11.93
Notify the Designated Biologist of CBB, CTS or SWHA Take or InjuryReportingCOA 11.52, COA 11.81, COA 11.103
Notify the Designated Biologist of Covered Species Take or InjuryReportingCOA 10.16, COA 11.68, COA 11.93
Report CBB, CTS and SWHA Take or Injury Incidents to CDFWReportingCOA 11.52, COA 11.52.2, COA 11.81, COA 11.103
Report Covered Species Take or Injury to CDFWReportingCOA 10.16, COA 11.2, COA 11.52.4, COA 11.68, COA 11.68.2, COA 11.68.4, COA 11.93
Report GGS Relocations to CDFWReportingCOA 11.67.1
Report ITP Non-Compliance to CDFWReportingCOA 10.2
Submit Phase 2 Project Operations Report to CDFWReportingCOA 7.5
Obligations
Carcass salvage, labeling and storage for the wildlife health labAdhereCOA 11.103
Species sightings
Actions
Report Covered Species Sightings to CDFWReportingCOA 10.7, COA 11.1
Submit Covered Species Observations to CNDDBReportingCOA 10.14
Obligations
Biological Monitor daily communication and immediate reports to the Designated BiologistNotifyCOA 9.2.2
Approvals and notices
Agency approvals
Actions
Calculate Phase Security Amount Before Phase ApprovalFinancialCOA 13.1
Consult CDFW on Federal Biological OpinionsApproval & ConsultationCOA 4
Coordinate with CDFW on Breeding Habitat Buffer EncroachmentApproval & ConsultationCOA 11.40
Notify and Consult CDFW on ITP Amendment ConditionsApproval & ConsultationCOA 8, COA 10.18.3, COA 12
Obtain CDFW Approval for In-Channel Work in the GGS Active SeasonApproval & ConsultationCOA 11.60
Obtain CDFW Approval of Dewatering Measure DeviationsApproval & ConsultationCOA 11.61
Obtain CDFW Approval of HM Lands Before AcquisitionApproval & ConsultationCOA 12.11.3
Obtain CDFW Approval of Nighttime Covered ActivitiesApproval & ConsultationCOA 11.7
Obtain CDFW Approval of the Mitigation or Conservation BankApproval & ConsultationCOA 12.10
Obtain CDFW Approval to Extend Phase 1 OperationsApproval & ConsultationCOA 11.110
Obtain CDFW Approval to Work Outside the Seasonal WindowApproval & ConsultationCOA 11.59
Obtain CESA Authorization for HM Lands ActivitiesApproval & ConsultationCOA 12
Submit Aquatic Conditions Assessments with the Phase 2 PackageReportingCOA 10.18
Submit Construction Phase Authorization Package to CDFWApproval & ConsultationCOA 6, COA 6.2
Submit Fish Study Plans and Reports for CDFW ApprovalApproval & ConsultationCOA 10.18.1
Submit Joint Operations Study Results and Compliance ReportReportingCOA 10.21.8
Submit Phase 2 Authorization Package to CDFWApproval & ConsultationCOA 7, COA 7.1
Submit Pre-implementation Phase Authorization Package to CDFWApproval & ConsultationCOA 6.1
Submit Preconstruction Habitat Survey Results in the Phase PackageReportingCOA 10.8
Submit Species and Habitat Survey Protocols to CDFWPlanCOA 6.1, COA 11.38
Submit Subsurface Vibration Study Results to CDFWReportingCOA 10.17
Submit Supplemental Phase 1 Operations Data Before Phase 2ReportingCOA 7.1
Schedule notices
Actions
Conduct Preconstruction GGS SurveySurveyCOA 11.56
Notify CDFW 14 Days Before Starting Covered ActivitiesReportingCOA 10.1
Notify CDFW 60 Days Before In-Water MaintenanceReportingCOA 11.31.2
Mitigation lands and funding
Mitigation lands
Actions
Complete Baseline Biological Assessment and Land SurveySurveyCOA 12.11.6
Complete HM Lands Start-Up Fencing, Signage and EnhancementRestoration & MitigationCOA 12.11.6
Complete Mitigation and HM Lands Protection Before ImpactsRestoration & MitigationCOA 12, COA 13.3
Demonstrate Project Funding Arrangements to CDFWReportingCOA 13.3
Designate CDFW-Approved Interim and Long-Term Land ManagersApproval & ConsultationCOA 12.11.5
Establish Long-Term HM Lands Management EndowmentFinancialCOA 12.12
Fund Annual Endowment Deposit Amount InstallmentFinancialCOA 12.12, COA 12.12.3
Notify CDFW and Provide a Plan for a Stay-Ahead ShortfallReportingCOA 12
Notify CDFW of a Land Manager ChangeReportingCOA 12.11.5
Obtain CDFW Approval of Mitigation Habitat Restoration ProjectsApproval & ConsultationCOA 12, COA 12.6.1, COA 12.6.2, COA 12.6.4, COA 12.7.1, COA 12.7.2, COA 12.8.1, COA 12.8.2
Obtain CDFW Approval of the HM Lands Conservation EasementApproval & ConsultationCOA 12.11.2
Prepare HM Lands Management PlanPlanCOA 12.11.6
Prepare Phase Security Cost Estimate for HM LandsAnalysisCOA 12.9, COA 12.9.1, COA 12.9.3
Provide Annual Long-Term HM Lands Management FundingFinancialCOA 12.12
Provide Title and Environmental Documentation for HM LandsReportingCOA 12.11.4
Reimburse CDFW Costs for ITP Issuance and MonitoringFinancialCOA 12.13
Submit and Update the CESA Mitigation Funding StrategyFinancialCOA 13.2
Submit Credit Bill of Sale and Payment Receipt to CDFWReportingCOA 12.10
Obligations
Compensatory habitat acreage for each covered speciesAdhereCOA 12
Fee title to Habitat Management landsAdhereCOA 12.11.1
Habitat Management lands stay-ahead ratioAdhereCOA 12
Integration of the spawning habitat study into shallow spawning habitat designAdhereCOA 12.6.1
Interim management of Habitat Management landsAdhereCOA 12.11.7
Long-term monitoring of tidal habitat mitigation sitesMonitorCOA 12.6.1
Ongoing demonstration of mitigation performance during the permit termNotifyCOA 13.3
Perpetual management, maintenance and monitoring of Habitat Management landsAdhereCOA 12.12
Funding and endowment
Actions
Fund CHNWR, CHNSR and White Sturgeon Operations MitigationFinancialCOA 12.7.2, COA 12.8.2
Obtain CDFW Approval of the Endowment Management AgreementApproval & ConsultationCOA 12.12.4
Prepare Endowment Assessment for CDFW ApprovalAnalysisCOA 12.12.2, COA 12.12.2.1, COA 12.12.2.2, COA 12.12.2.2.1, COA 12.12.2.2.2, COA 12.12.2.2.3
Submit Endowment Assessment for CDFW ApprovalApproval & ConsultationCOA 12.12.2
Submit Endowment Manager Proposal to CDFWApproval & ConsultationCOA 12.12.1
Obligations
Funding of interim management of Habitat Management landsAdhereCOA 12.11.7
Holding, pooling and disbursement of the EndowmentAdhereCOA 12.12.4
Security and assurances
Actions
Submit Covered Fish Monitoring Funding Strategy to CDFWFinancialCOA 13.2
Habitat accounting
Disturbance tracking
Actions
Calculate Phase Impacts and Mitigation for Authorization PackageAnalysisCOA 12
Complete Pre-Disturbance Habitat Photo DocumentationSurveyCOA 10.3
Conduct Photo Monitoring of Temporary Impact AreasMonitoringCOA 10.6
Establish Restoration Treatment and Reference TransectsSurveyCOA 12.3.3
Notify CDFW of Likely Impact Exceedance and Revised ScheduleReportingCOA 10.9
Report Habitat Disturbance Acreage and GIS Layers to CDFWReportingCOA 10.3, COA 10.5
Survey Riverbank and Vegetation Conditions at Barge SitesMonitoringCOA 11.36
Verify Impact Multipliers in the Annual Status ReportMonitoringCOA 12.1
Obligations
GIS tracking of land disturbance and suitable habitat feature impactsMonitorCOA 10.3
GIS tracking of land disturbance and suitable habitat feature impactsMonitorCOA 10.4, COA 10.9
Restoration
Actions
Backfill and Restore Preconstruction Investigation SitesRestoration & MitigationCOA 12.2
Develop Temporary Impact Restoration SchedulePlanCOA 12.3.2
Develop Tidal Wetland Restoration Efficacy Study PlanAnalysisCOA 10.21.4
Remove Temporary Fill and Construction Refuse at CompletionAvoidance & BMPsCOA 9.17
Restore Riverbank Eroded by Barge OperationsRestoration & MitigationCOA 11.36
Restore Temporarily Impacted Habitat to Pre-Project ConditionsRestoration & MitigationCOA 11.17, COA 11.41, COA 11.65, COA 11.66, COA 12, COA 12.3, COA 12.3.1
Submit Restoration and Revegetation PlanPlanCOA 12.3, COA 12.3.1, COA 12.3.3
Submit Restoration Monitoring Reports to CDFWReportingCOA 12.3.4
Obligations
Erosion protection of restoration soils until vegetation establishesAdhereCOA 12.3.3
Invasive plant management and cover limit at restoration sitesAdhereCOA 12.3.3
Monitoring and maintenance of habitat restoration areasMonitorCOA 12.3.4
Monitoring of restored habitat until successMonitorCOA 11.66
Restoration survivorship and cover success standards with remedial actionAdhereCOA 12.3.3, COA 12.3.4
Seed mix composition and sourcing for restorationAdhereCOA 12.3.3
Seeding timing and reseeding at restoration sitesAdhereCOA 12.3.3
Substrate removal, topsoil salvage and imported fill in restoration areasAdhereCOA 12.3.3
Target native vegetation community for each restoration areaAdhereCOA 12.3.3
Vehicle Barriers on Restored ShouldersAdhereCOA 12.3.3

Reporting to CDFW

Monthly and annual reports

Actions

Deliver Final Phase Mitigation Report to CDFW

COA 10.15

Within 45 days of completing Covered Activities and all mitigation measures for a Project Phase — and again after all Phases are complete — the Designated Biologist or Biological Monitor prepares and Permittee delivers a Final Phase Mitigation Report to CDFW summarizing the Phase's Monthly Compliance Reports and Annual Status Reports, MMRP implementation dates, incidental take and impacts, Covered Activity start and end dates, an effectiveness assessment and recommendations.

Type
Reporting
Frequency
One time
Timing
no later than 45 days after completion of Covered Activities and all mitigation measures for each Project Phase
Twin Cities Complex
Not StartedDue 2026-07-10
Deliver Mitigation Status Report Before ITP Expiration

COA 10.15.1

Ninety days before the ITP expires, the Designated Biologist, Fisheries Biologist or Biological Monitor prepares and Permittee delivers to CDFW a Mitigation Status Report summarizing all Final Phase Mitigation Reports, the MMRP table with implementation dates, all incidental take and other impacts, Covered Activity dates, an effectiveness assessment of the Conditions and recommendations.

Type
Reporting
Frequency
One time
Timing
Ninety days prior to the expiration of this ITP
Southern Forebay & Pumping Plant
Not StartedDue 2026-08-28
Submit Photo Monitoring Documentation Report

COA 10.6

Photo monitoring obtained at the stations established for each temporarily impacted habitat area is delivered to CDFW for each calendar month with the Monthly Compliance Report, in a geographic format with the coordinate system identified, and all photo monitoring for the year is included with the Annual Status Report.

Type
Reporting
Frequency
Recurring
Timing
provided for each calendar month with the Monthly Compliance Report ... and included with the Annual Status Report
Intake C — North Delta
Not StartedDue 2027-01-252 of 3 done
Bethany Reservoir Aqueduct
On HoldDue 2026-10-051 of 3 done

Take, injury and non-compliance

Actions

Consult CDFW on Deceased CTS Specimen Disposal

COA 11.52.3

When a recently deceased CTS specimen is preserved, Permittee consults CDFW on the method of specimen disposal and follows the method CDFW agrees to.

Type
Approval & Consultation
Frequency
As needed
Byron Tract Forebay
Not Started
Notify CDFW of Inability to Comply with the ITP

COA 9.3

If the Designated Biologist or Biological Monitor becomes unable to comply with the ITP, that biologist or monitor immediately notifies the CDFW Representative.

Type
Reporting
Frequency
As needed
Timing
immediately
Intake B — North Delta
Not Started
Intake C — North Delta
In Progress
Notify CDFW of Potential CBB Nest Loss

COA 11.102

If a CBB nest may be lost to ground disturbance, or cannot be avoided and will be lost, CDFW is contacted immediately — within 24 hours — to determine next steps.

Type
Reporting
Frequency
As needed
Timing
immediately (within 24 hours)
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Not Started
Notify CDFW of TRBL Nest or Colony Abandonment or Distress

COA 11.93

The Designated Biologist immediately notifies CDFW, within 24 hours, if TRBL abandon nests or nestlings or if a nesting or roosting colony exhibits distress or abnormal nesting behavior, giving location, species, date, circumstances, receiving facility if applicable and the ITP number.

Type
Reporting
Frequency
As needed
Timing
within 24 hours
Bethany Reservoir Aqueduct
Not Started
Southern Forebay & Pumping Plant
Not Started
Notify the Designated Biologist of CBB, CTS or SWHA Take or Injury

COA 11.52, COA 11.81, COA 11.103

Permittee immediately notifies the Designated Biologist when a CBB, CTS or SWHA is taken, injured or killed by a Covered Activity, or is found dead or injured within the vicinity of a preconstruction activity, construction site or maintenance area.

Type
Reporting
Frequency
As needed
Timing
immediately
Intake C — North Delta
In Progress
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Not Started
Notify the Designated Biologist of Covered Species Take or Injury

COA 10.16, COA 11.68, COA 11.93

Permittee immediately notifies the Designated Biologist, Fisheries Biologist or Biological Monitor whenever a Covered Species — including GGS or TRBL — is taken or injured by a Covered Activity, or is found dead or injured in the vicinity of preconstruction, construction or maintenance work.

Type
Reporting
Frequency
As needed
Timing
immediately
Intake B — North Delta
In Progress
Report CBB, CTS and SWHA Take or Injury Incidents to CDFW

COA 11.52, COA 11.52.2, COA 11.81, COA 11.103

For the species-specific conditions, the Designated Biologist or Designated Representative notifies the CDFW Representative within one business day of finding an injured or killed CBB, CTS or SWHA, giving location, species, number, receiving facility and ITP number, and Permittee sends CDFW a written incident report within two business days documenting the circumstances, the procedure followed and the final disposition of the animal.

Type
Reporting
Frequency
As needed
Timing
within two business days
Intake B — North Delta
In Progress
Report Covered Species Take or Injury to CDFW

COA 10.16, COA 11.2, COA 11.52.4, COA 11.68, COA 11.68.2, COA 11.68.4, COA 11.93

On any take, injury or death of a Covered Species, the Designated Biologist or Designated Representative calls the CDFW Bay-Delta Region Stockton Office with the GPS location, date, time, species, number, injury type or likely cause of death, receiving facility and ITP number, and Permittee follows with a written incident report to CDFW within two business days covering circumstances, photographs, procedure followed and final disposition. The written report is also included in the next Monthly…

Type
Reporting
Frequency
As needed
Timing
within two business days
Bethany Reservoir Aqueduct
In Progress
Southern Forebay & Pumping Plant
Not Started
Report GGS Relocations to CDFW

COA 11.67.1

The Designated Representative or Designated Biologist notifies CDFW by telephone and email within 24 hours each time a GGS is relocated, giving date, time, location and circumstances, and follows with a written incident report that is also included in the Monthly Compliance Report.

Type
Reporting
Frequency
As needed
Timing
within 24 hours each time GGS is relocated
Intake C — North Delta
In Progress
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Not Started
Report ITP Non-Compliance to CDFW

COA 10.2

The Designated Representative immediately notifies CDFW of any non-compliance with a Condition of Approval, including actual or anticipated failure to implement measures within ITP or MMRP time periods, and follows up within 24 hours with a written report detailing the non-compliance and suggested remedies.

Type
Reporting
Frequency
As needed
Timing
follow up within 24 hours with a written report
Intake C — North Delta
Not Started
Submit Phase 2 Project Operations Report to CDFW

COA 7.5

No more than six months after Phase 2 Operations begin, Permittee provides CDFW a Phase 2 Project Operations Report summarizing all Monthly Compliance Reports and Annual Status Reports, the MMRP table with implementation dates, all Project-related take and other impacts, Covered Activity start and end dates, an effectiveness assessment and recommendations.

Type
Reporting
Frequency
One time
Timing
No more than six months after the initiation of Phase 2 Operations
Byron Tract Forebay
Completed
Intake B — North Delta
Not StartedDue 2026-05-20

Obligations

Carcass salvage, labeling and storage for the wildlife health lab

COA 11.103

The carcass shall be photographed, salvaged, and placed in a labeled, clean plastic, resealable bag or vial and stored in a freezer by the Designated Biologist(s) for shipment to CDFW Wildlife Health Lab.

Class
Adhere
Audience
Crews

Species sightings

Actions

Report Covered Species Sightings to CDFW

COA 10.7, COA 11.1

Any Covered Species sighting anywhere in the construction site before or during construction, including dewatering, is reported to CDFW by email within one working day of discovery. The Designated Biologist, Fisheries Biologist or Biological Monitor records the location with GPS, including datum and horizontal accuracy in feet, and reports the observed location to CDFW within one business day.

Type
Reporting
Frequency
As needed
Timing
within one working day of the discovery
Byron Tract Forebay
Not Started
Intake B — North Delta
Completed
Submit Covered Species Observations to CNDDB

COA 10.14

The Designated Biologist or Biological Monitor files each Covered Species observation with CDFW's California Natural Diversity Database within 60 calendar days of the observation, and includes copies of the submitted CNDDB forms with the next Monthly Compliance Report or Annual Status Report, whichever comes first.

Type
Reporting
Frequency
As needed
Timing
within 60 calendar days of the observation
Intake C — North Delta
Not Started
Bethany Reservoir Aqueduct
Not Started

Obligations

Biological Monitor daily communication and immediate reports to the Designated Biologist

COA 9.2.2

The Biological Monitor(s) shall receive training and direction from the Designated Biologist(s) or Fisheries Biologist(s) for each task performed, and shall communicate daily with the Designated Biologist(s) or Fisheries Biologist(s) and immediately report any occurrence of Covered Species within the Project construction site, as well as any apparent non-compliance with any provision of this ITP.

Class
Notify
Audience
Compliance staff

Approvals and notices

Agency approvals

Actions

Calculate Phase Security Amount Before Phase Approval

COA 13.1

Before CDFW approves each Project Phase, the Permittee calculates that Phase's Security following the Phase Authorization Form (Attachment 6) instructions and COA 12.9, submitting the cost estimates CDFW uses to determine an amount sufficient for CDFW or its contractors to complete land acquisition, property enhancement, start-up, initial and long-term management, studies and monitoring.

Type
Financial
Frequency
As needed
Timing
The Security for each Phase shall be calculated prior to approval of that Phase
Twin Cities Complex
Not Started
Bouldin Island Geotechnical Exploration
On Hold
Byron Tract Forebay
Not Started
Consult CDFW on Federal Biological Opinions

COA 4

When USFWS or NMFS issues a Biological Opinion for construction or operation of the Project, Permittee consults with CDFW on its terms as described in COA 8 and documents the consultation; where federal terms are less protective than or conflict with this ITP, the ITP conditions control.

Type
Approval & Consultation
Frequency
As needed
Bethany Reservoir Aqueduct
On Hold
Southern Forebay & Pumping Plant
Completed
Coordinate with CDFW on Breeding Habitat Buffer Encroachment

COA 11.40

Where suitable aquatic breeding habitat south of Byron Highway cannot be avoided by 300 feet, Permittee notifies CDFW and develops site-specific avoidance and minimization measures with CDFW through the appropriate Phase Authorization Package, and consults CDFW on further habitat protection measures at the Bethany Complex to maintain breeding-to-upland connectivity.

Type
Approval & Consultation
Frequency
As needed
Bouldin Island Geotechnical Exploration
Not Started
Byron Tract Forebay
Not Started
Notify and Consult CDFW on ITP Amendment Conditions

COA 8, COA 10.18.3, COA 12

When a listed amendment-triggering condition occurs — including impacts documented in a Phase Authorization Package that are greater or less than anticipated, or a proposal to modify the January–February operating criteria in COA 11.111 and 11.111.2 — Permittee notifies CDFW in writing, consults on whether an amendment is necessary, and files an amendment application when one is required.

Type
Approval & Consultation
Frequency
As needed
Byron Tract Forebay
In Progress
Intake B — North Delta
Not Started
Intake C — North Delta
Completed
Obtain CDFW Approval for In-Channel Work in the GGS Active Season

COA 11.60

If in-channel work must occur during the GGS active season, Permittee requests and obtains written CDFW approval, has the Designated Biologist or Biological Monitor survey for GGS under the CDFW-approved protocol before work begins, and keeps monitoring throughout the Covered Activities.

Type
Approval & Consultation
Frequency
As needed
Byron Tract Forebay
Completed
Obtain CDFW Approval of Dewatering Measure Deviations

COA 11.61

Permittee and the Designated Biologist obtain written CDFW approval for any deviation from the dewatering measure and coordinate the alternative actions with CDFW before carrying them out.

Type
Approval & Consultation
Frequency
As needed
Bouldin Island Geotechnical Exploration
On Hold
Byron Tract Forebay
Not Started
Obtain CDFW Approval of HM Lands Before Acquisition

COA 12.11.3

At least three months before acquiring or transferring HM lands, Permittee submits documentation identifying the land to be purchased or the property interest to be conveyed to an approved entity as mitigation, and obtains CDFW's written approval; HM lands may be proposed and approved in segments or subsets.

Type
Approval & Consultation
Frequency
One time
Timing
at least three months before acquisition and/or transfer of the HM lands
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-10-31
Obtain CDFW Approval of Nighttime Covered Activities

COA 11.7

Where nighttime work is proposed, Permittee details the activity type, assesses site-specific impacts to Covered Species, identifies impact-reduction measures and justifies the need in the appropriate Construction Phase Authorization Package, and conducts nighttime work only after CDFW approves.

Type
Approval & Consultation
Frequency
As needed
Southern Forebay & Pumping Plant
On Hold
Twin Cities Complex
In Progress
Bouldin Island Geotechnical Exploration
In Progress
Obtain CDFW Approval of the Mitigation or Conservation Bank

COA 12.10

If Permittee elects to purchase Covered Species credits for a Project Phase, it obtains CDFW approval confirming the mitigation or conservation bank is appropriate to compensate for that Phase's impacts before any credits are purchased.

Type
Approval & Consultation
Frequency
As needed
Timing
prior to purchase of Covered Species credits
Southern Forebay & Pumping Plant
Overdue
Twin Cities Complex
On Hold
Bouldin Island Geotechnical Exploration
In Progress
Obtain CDFW Approval to Extend Phase 1 Operations

COA 11.110

If Phase 1 Operations must run beyond one calendar year, Permittee requests and obtains CDFW approval of the extension, keeping the combined duration of Phase 1 and Phase 2 Operations within two calendar years.

Type
Approval & Consultation
Frequency
As needed
Intake B — North Delta
Not Started
Obtain CDFW Approval to Work Outside the Seasonal Window

COA 11.59

To conduct Covered Activities in suitable GGS habitat before May 1, or otherwise outside the seasonal work restriction where initial ground disturbance predates September 15 and an exclusion barrier is already installed, Permittee submits a written request with justification, National Weather Service temperature evidence and any information CDFW requires, and obtains written CDFW approval before starting.

Type
Approval & Consultation
Frequency
As needed
Timing
48 hours preceding construction activities
Byron Tract Forebay
Completed
Obtain CESA Authorization for HM Lands Activities

COA 12

Because this ITP authorizes no take for HM lands activities, Permittee obtains separate CESA authorization, and any separate CEQA evaluation, before implementing HM land protection, restoration and perpetual management.

Type
Approval & Consultation
Frequency
As needed
Twin Cities Complex
Not Started
Bouldin Island Geotechnical Exploration
Not Started
Submit Aquatic Conditions Assessments with the Phase 2 Package

COA 10.18

Permittee includes assessments of aquatic conditions for each Covered Fish Species monitoring period in the Phase 2 Operations Authorization Package and in the Final Mitigation Report following completion of Phase 2 Operations, so CDFW can evaluate changes in aquatic conditions across construction and operations.

Type
Reporting
Frequency
One time
Timing
in the Phase 2 Operations Authorization Package and the Final Mitigation Report following completion of Phase 2 Operations
Intake C — North Delta
Not StartedDue 2026-03-26
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Not StartedDue 2026-08-26
Submit Construction Phase Authorization Package to CDFW

COA 6, COA 6.2

For each Construction Phase, Permittee submits a complete Construction Phase Authorization Package — Attachment 6 form with annual schedule and impact and mitigation calculations, biological report, habitat delineation, baseline survey results, 95% engineering plan, site-specific plans and the Phase's avoidance, minimization and mitigation measures — to WBSWPPermitting@wildlife.ca.gov 90 days before that Phase's Covered Activities, and does not begin the Phase until it holds the CDFW-signed…

Type
Approval & Consultation
Frequency
One time
Timing
90 days prior to the commencement of Covered Activities defined in that Phase
Southern Forebay & Pumping Plant
Completed
Submit Fish Study Plans and Reports for CDFW Approval

COA 10.18.1

Permittee submits draft fish study plans and reports on the timelines in the CDFW-approved Covered Fish Species Monitoring and Science Plan and in each Condition of Approval, returns a revised final draft within six months of receiving CDFW comments, and obtains CDFW approval of every plan and report before implementing it or finalizing it.

Type
Approval & Consultation
Frequency
Ongoing
Timing
within six (6) months of receiving comments from CDFW on a draft plan or report
Twin Cities Complex
In ProgressDue 2026-08-12
Bouldin Island Geotechnical Exploration
Not StartedDue 2026-10-24
Byron Tract Forebay
Completed
Submit Joint Operations Study Results and Compliance Report

COA 10.21.8

Permittee includes in the Phase 2 Authorization Package a final report documenting the joint operations study results and demonstrating the Project's ability to meet the Covered Fish Species Biological Criteria.

Type
Reporting
Frequency
One time
Timing
as a part of the Phase 2 Authorization Package
Intake B — North Delta
In ProgressDue 2026-11-02
Submit Phase 2 Authorization Package to CDFW

COA 7, COA 7.1

No more than 120 days before Phase 1 Operations begin, Permittee submits a complete Phase 2 Authorization Package — Attachment 6 form, covered fish life cycle models, joint operations modeling, science and monitoring reports, preconstruction engineering studies, operations monitoring results, 100% design and applicable measures and plans — and does not begin Phase 2 Operations until CDFW has signed the Phase 2 Authorization Form.

Type
Approval & Consultation
Frequency
One time
Timing
No more than 120 days before the initiation of Phase 1 Operations
Southern Forebay & Pumping Plant
Not StartedDue 2026-11-17
Submit Pre-implementation Phase Authorization Package to CDFW

COA 6.1

Permittee submits the completed Pre-implementation Phase Authorization Package — Phase Authorization Form, monitoring and management plans and final survey methodology — no less than one year before preconstruction activities begin, and starts no Covered Activity until CDFW has reviewed and signed it.

Type
Approval & Consultation
Frequency
One time
Timing
one year before initiation of preconstruction activities
Bethany Reservoir Aqueduct
Not StartedDue 2026-08-03
Southern Forebay & Pumping Plant
Not StartedDue 2026-03-04
Submit Preconstruction Habitat Survey Results in the Phase Package

COA 10.8

Permittee includes the Designated Biologist's initial preconstruction field survey results in the appropriate Construction Phase Authorization Package, identifying the spatial extent of suitable habitat for each Covered Species and the total area surveyed.

Type
Reporting
Frequency
One time
Timing
in the appropriate Construction Phase Authorization Package
Intake C — North Delta
Not StartedDue 2026-09-12
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Not StartedDue 2026-03-13
Submit Species and Habitat Survey Protocols to CDFW

COA 6.1, COA 11.38

Permittee develops with CDFW the final protocol-level species and habitat survey methodology for CTS, GGS, SWHA, TRBL, CBB and MALI, submits it in the Pre-implementation Phase Authorization Package, and obtains written approval before any Covered Activity including preconstruction field investigations and preconstruction species site surveys. The protocols specify survey number, timing and spacing, habitat types, methods and rationale, capture and identification protocols and presence or…

Type
Plan
Frequency
One time
Timing
prior to initiation of any Covered Activity
Twin Cities Complex
In ProgressDue 2026-08-29
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-06-29
Submit Subsurface Vibration Study Results to CDFW

COA 10.17

Permittee submits the results of the Subsurface Testing and Monitoring Study, with suggested vibratory monitoring protocols for fossorial Covered Species, to CDFW as part of the appropriate Construction Phase Authorization Package.

Type
Reporting
Frequency
One time
Intake C — North Delta
Completed
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Not StartedDue 2026-10-16
Submit Supplemental Phase 1 Operations Data Before Phase 2

COA 7.1

Permittee submits the additional data collected during Phase 1 Operations, with associated reports, to CDFW no less than 90 days before Phase 2 Operations begin, to augment the Phase 2 Authorization Package.

Type
Reporting
Frequency
One time
Timing
no less than 90 days prior to initiation of Phase 2 Operations
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
In ProgressDue 2026-10-10

Schedule notices

Actions

Conduct Preconstruction GGS Survey

COA 11.56

Before any Covered Activities, including preconstruction activities, during the GGS active season (May 1 to October 1), the Designated Biologist with Biological Monitor assistance conducts CDFW-approved preconstruction surveys within each Project site and a three-foot buffer, and Permittee submits the results to CDFW in the Construction Phase Authorization Package.

Type
Survey
Frequency
One time
Timing
prior to initiation of any Covered Activities
Byron Tract Forebay
In ProgressDue 2026-07-11
Notify CDFW 14 Days Before Starting Covered Activities

COA 10.1

The Designated Representative sends CDFW written notice 14 calendar days before Covered Activities begin at a construction site within an approved Phase, and before Project operations begin. The notice identifies the site and the activities about to start.

Type
Reporting
Frequency
One time
Timing
14 calendar days before starting Covered Activities
Southern Forebay & Pumping Plant
Not StartedDue 2026-11-29
Twin Cities Complex
Not StartedDue 2026-06-25
Bouldin Island Geotechnical Exploration
Not StartedDue 2026-11-09
Notify CDFW 60 Days Before In-Water Maintenance

COA 11.31.2

After construction, Permittee notifies CDFW 60 days before beginning any in-water maintenance, providing site locations, schedules, work activities, anticipated effects on water quality and Covered Species, and agency communications about temporary partial channel closures, and obtains CDFW's written approval before proceeding.

Type
Reporting
Frequency
As needed
Timing
notify CDFW 60 days before beginning any in-water maintenance activities
Byron Tract Forebay
In Progress
Intake B — North Delta
In Progress
Intake C — North Delta
In Progress

Mitigation lands and funding

Mitigation lands

Actions

Complete Baseline Biological Assessment and Land Survey

COA 12.11.6

Within four months of recording or transfer of approved HM lands, field biologists complete a baseline biological assessment and land survey report for the property as the first of the start-up activities, alongside GIS data development and transfer where applicable.

Type
Survey
Frequency
One time
Timing
within four months of recording or transfer
Twin Cities Complex
Not StartedDue 2026-03-10
Bouldin Island Geotechnical Exploration
Not StartedDue 2026-11-08
Byron Tract Forebay
Not StartedDue 2026-03-21
Complete HM Lands Start-Up Fencing, Signage and Enhancement

COA 12.11.6

Once CDFW approves HM lands, the Permittee develops and transfers GIS data where applicable, establishes initial fencing, removes litter, performs initial habitat restoration or enhancement where applicable, and installs signage. These start-up tasks complete on each approved HM land parcel.

Type
Restoration & Mitigation
Frequency
One time
Intake C — North Delta
On HoldDue 2026-08-10
Complete Mitigation and HM Lands Protection Before Impacts

COA 12, COA 13.3

Before Covered Activities start for each Phase, the Permittee completes purchase of Covered Species credits, required restoration, acquisition and permanent protection and transfer of all HM lands with conservation easements recorded, and funding for perpetual monitoring and management — or posts COA 13 Security covering every uncompleted obligation before impacts to Covered Species are incurred. The completion package is assembled and dated per Phase.

Type
Restoration & Mitigation
Frequency
One time
Timing
before starting Covered Activities for each Phase, or, where COA 13 Security is provided for all uncompleted obligations, before incurring impacts to Covered Species
Bethany Reservoir Aqueduct
Not StartedDue 2026-05-14
Southern Forebay & Pumping Plant
OverdueDue 2026-11-22
Twin Cities Complex
In ProgressDue 2026-05-01
Demonstrate Project Funding Arrangements to CDFW

COA 13.3

Before incurring impacts to Covered Species, Permittee delivers to CDFW copies of the contracts or arrangements made under Water Code section 85089(a) and documentation, acceptable to CDFW, showing that the financial agreements covering repayment of Project bonds explicitly identify funding for pre-construction studies, monitoring and all other Conditions of Approval as Project construction costs.

Type
Reporting
Frequency
One time
Timing
Before incurring impacts to Covered Species
Twin Cities Complex
Completed
Designate CDFW-Approved Interim and Long-Term Land Managers

COA 12.11.5

Permittee designates an interim and a long-term land manager for the HM lands, obtains CDFW approval of each, and identifies both in the land management documents; the conservation easement grantee may not serve as manager without CDFW's express written authorization.

Type
Approval & Consultation
Intake B — North Delta
Completed
Intake C — North Delta
Not StartedDue 2026-11-15
Bethany Reservoir Aqueduct
Not StartedDue 2026-12-18
Establish Long-Term HM Lands Management Endowment

COA 12.12

If SWP charges to the SWP Contractors are no longer available as a funding source, the Permittee establishes a long-term management fund (Endowment) held in a CDFW-approved fund, permanently restricted to the perpetual management, maintenance, monitoring and stewardship of the HM lands and sized by the Property Analysis Records prepared under COAs 12.12 and 12.12.2.

Type
Financial
Frequency
As needed
Timing
If SWP charges to the SWP Contractors are no longer available as funding
Bouldin Island Geotechnical Exploration
Completed
Byron Tract Forebay
Completed
Fund Annual Endowment Deposit Amount Installment

COA 12.12, COA 12.12.3

Each year beginning in the fiscal year SWP Contractor charges cease to be available, the Permittee deposits at least 10 percent of the PAR-required Endowment Deposit Amount, adjusted for inflation and present value, into the mutually agreed account, until the Endowment is fully funded over a maximum of 10 years. Each installment amount is as approved by CDFW in writing.

Type
Financial
Frequency
Recurring
Timing
over a maximum 10-year period, in annual amounts of at least 10%, commencing the fiscal year that SWP charges to the SWP Contractors are no longer an available funding source
Twin Cities Complex
In ProgressDue 2026-09-121 of 3 done
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-06-251 of 3 done
Byron Tract Forebay
Not StartedDue 2027-03-152 of 3 done
Notify CDFW and Provide a Plan for a Stay-Ahead Shortfall

COA 12

If anticipated habitat impacts in a given year would leave the 10 percent stay-ahead requirement unmet for a Covered Species, Permittee immediately notifies CDFW and provides a plan for permanent protection, and restoration if required, of the necessary HM lands before proceeding with the Covered Activities causing the impact.

Type
Reporting
Frequency
As needed
Timing
immediately
Bethany Reservoir Aqueduct
Not Started
Southern Forebay & Pumping Plant
Overdue
Notify CDFW of a Land Manager Change

COA 12.11.5

Permittee notifies CDFW within 30 days of any subsequent change in the interim or long-term HM lands land manager.

Type
Reporting
Frequency
As needed
Timing
within 30 days of the change
Southern Forebay & Pumping Plant
In Progress
Twin Cities Complex
Not Started
Obtain CDFW Approval of Mitigation Habitat Restoration Projects

COA 12, COA 12.6.1, COA 12.6.2, COA 12.6.4, COA 12.7.1, COA 12.7.2, COA 12.8.1, COA 12.8.2

Every individual protection and restoration project proposed to satisfy compensatory mitigation — Delta smelt tidal perennial, shallow spawning and tidal wetland habitat, longfin smelt mesohaline habitat, and CHNWR, CHNSR and white sturgeon tidal perennial and channel margin habitat — is submitted to CDFW with its restoration design and approved in writing before it counts toward the mitigation requirement.

Type
Approval & Consultation
Frequency
Ongoing
Timing
subject to CDFW approval in writing
Southern Forebay & Pumping Plant
Not StartedDue 2026-08-08
Twin Cities Complex
Completed
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-11-10
Obtain CDFW Approval of the HM Lands Conservation Easement

COA 12.11.2

Permittee obtains CDFW's written approval of any conservation easement over the HM lands before the easement is executed or recorded, with the easement complying with Civil Code sections 815-816 and Government Code sections 65965-65968 and expressly addressing sections 65966(j) and 65967(e).

Type
Approval & Consultation
Frequency
One time
Timing
before its execution or recordation
Southern Forebay & Pumping Plant
Not StartedDue 2026-11-07
Twin Cities Complex
In ProgressDue 2026-10-09
Bouldin Island Geotechnical Exploration
Not StartedDue 2026-06-12
Prepare HM Lands Management Plan

COA 12.11.6

As a start-up activity on each approved Habitat Management lands parcel, Permittee prepares a final management plan and submits it to CDFW for approval; start-up activities continue until CDFW approves the plan.

Type
Plan
Frequency
One time
Twin Cities Complex
Not StartedDue 2026-11-24
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-09-18
Prepare Phase Security Cost Estimate for HM Lands

COA 12.9, COA 12.9.1, COA 12.9.3

For each Project Phase, Permittee prepares the cost estimate that sets the Security amount, sufficient for CDFW or its contractors to complete acquisition, protection and perpetual management of the COA 12 HM lands. The estimate values land acquisition at local fair market current value per acre for lands meeting mitigation habitat requirements, adds all other costs to review and acquire the land in fee title and record a conservation easement under COAs 12.11.1 and 12.11.2, and includes an…

Type
Analysis
Frequency
As needed
Timing
for the purposes of determining the Security amount for each Project Phase
Bethany Reservoir Aqueduct
Completed
Southern Forebay & Pumping Plant
Completed
Twin Cities Complex
In Progress
Provide Annual Long-Term HM Lands Management Funding

COA 12.12

After CDFW approves an HM lands site, the Permittee provides that site's long-term management funding every year, in the amount set by the CDFW-approved Property Analysis Record or equivalent, adjusted for inflation and for actual management costs as CDFW approves, on written terms acceptable to CDFW.

Type
Financial
Frequency
Recurring
Timing
After obtaining CDFW approval of the HM lands, Permittee shall provide long-term management funding for the perpetual management of the HM lands
Twin Cities Complex
Not StartedDue 2026-07-131 of 3 done
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-10-241 of 3 done
Byron Tract Forebay
Not StartedDue 2026-09-221 of 3 done
Provide Title and Environmental Documentation for HM Lands

COA 12.11.4

For each HM lands parcel, Permittee provides CDFW a recent preliminary title report, a Phase I Environmental Site Assessment and the other documents CDFW lists, and secures approval of all conveyance documents and conditions of title from CDFW and, where applicable, the Wildlife Conservation Board and the Department of General Services.

Type
Reporting
Frequency
As needed
Intake C — North Delta
Completed
Bethany Reservoir Aqueduct
Not Started
Southern Forebay & Pumping Plant
In Progress
Reimburse CDFW Costs for ITP Issuance and Monitoring

COA 12.13

As CDFW bills them, the Permittee reimburses all reasonable CDFW costs related to issuance and monitoring of the ITP, including transaction, account set-up and administrative fees, title and documentation review and related title transactions, other state agency review costs, and overhead related to transfer of HM lands to CDFW.

Type
Financial
Frequency
As needed
Timing
Permittee shall reimburse CDFW for all reasonable costs incurred by CDFW related to issuance and monitoring of this ITP
Twin Cities Complex
Completed
Bouldin Island Geotechnical Exploration
Overdue
Byron Tract Forebay
In Progress
Submit and Update the CESA Mitigation Funding Strategy

COA 13.2

Within one year of State Water Board approval of the change in point of diversion, the Permittee submits an initial CESA mitigation funding strategy to CDFW for review and approval, with detailed cost estimates for construction-related monitoring and avoidance and for mitigation — bank credits; HM lands acquisition, start-up and interim management; restoration design, environmental review, permitting, construction and interim management; and long-term management of all HM lands. Detailed…

Type
Financial
Frequency
Recurring
Timing
initial strategy within one year of issuance of a State Water Board approval of a change in point of diversion; detailed updates as part of any Phase Authorization Package, and every three years if a Phase will exceed three years
Twin Cities Complex
Not StartedDue 2026-10-101 of 3 done
Bouldin Island Geotechnical Exploration
In ProgressDue 2027-03-041 of 3 done
Byron Tract Forebay
In ProgressDue 2026-10-151 of 3 done
Submit Credit Bill of Sale and Payment Receipt to CDFW

COA 12.10

Permittee submits a copy of the Bill of Sale and Payment Receipt for purchased Covered Species credits to CDFW before initiating Covered Activities and in advance of incurring impacts to Covered Species habitat.

Type
Reporting
Frequency
As needed
Timing
prior to initiating Covered Activities in advance of incurring impacts to Covered Species habitat
Southern Forebay & Pumping Plant
Not Started

Obligations

Compensatory habitat acreage for each covered species

COA 12

Permittee shall either purchase Covered Species credits from a CDFW- approved mitigation or conservation bank pursuant to Condition of Approval 12.10 to achieve the acreage requirements described in Table 12-1 and Table 12-2, or shall provide for both the permanent protection, restoration, and initial and long-term management and monitoring of Habitat Management (HM) lands pursuant to Condition of Approval 12.11 below and consistent with Covered Species habitat criteria described in Attachment…

Class
Adhere
Audience
Crews
Fee title to Habitat Management lands

COA 12.11.1

Transfer fee title of the HM lands to CDFW pursuant to terms approved in writing by CDFW.

Class
Adhere
Audience
Crews
Habitat Management lands stay-ahead ratio

COA 12

Permittee shall ensure the ratio of cumulative HM lands protection and restoration for each Covered Species remains at least 10 percent (10%) greater than the proportional cumulative impacts to each Covered Species habitat until the compensatory mitigation acreages in Table 12-1 and Table 12-2 have been achieved.

Class
Adhere
Audience
Crews
Integration of the spawning habitat study into shallow spawning habitat design

COA 12.6.1

Permittee shall integrate the results from the Ecological Response Evaluation Study: Delta Smelt and Longfin Smelt Spawning Habitat Study (Condition of Approval 10.21.5) into shallow spawning habitat design and implementation.

Class
Adhere
Audience
Crews
Interim management of Habitat Management lands

COA 12.11.7

Interim management period activities described in the final management plan shall include fence repair, continuing trash removal, site monitoring, vegetation and invasive species management, and any other expected management activities.

Class
Adhere
Audience
Crews
Long-term monitoring of tidal habitat mitigation sites

COA 12.6.1

Permittee shall monitor habitat mitigation sites for a period of at least 10 years to ensure the effectiveness both as refuge and spawning habitat.

Class
Monitor
Audience
Monitors
Ongoing demonstration of mitigation performance during the permit term

COA 13.3

During the permit term, Permittee shall demonstrate to CDFW that Covered Species’ requirements have been satisfied on an ongoing basis and consistent with the requirements of Condition of Approval 12, as evidenced by: • Written documentation of the acquisition of the HM lands; • Copies of all executed and recorded conservation easements; • Written confirmation from the approved Endowment Manager of its receipt of the full Endowment, if required; and • Timely submission of all required reports.

Class
Notify
Audience
Compliance staff
Applies When
During the permit term, Permittee shall demonstrate to CDFW that Covered Species’ requirements have been satisfied on an ongoing basis and consistent with the require
Perpetual management, maintenance and monitoring of Habitat Management lands

COA 12.12

After the interim management period, Permittee shall ensure that the designated long-term land manager implements the management and monitoring of the HM lands according to the final management plan.

Class
Adhere
Audience
Crews
Applies When
After the interim management period, Permittee shall ensure that the designated long-term land manager implements the management and monitoring of the HM lands accor

Funding and endowment

Actions

Fund CHNWR, CHNSR and White Sturgeon Operations Mitigation

COA 12.7.2, COA 12.8.2

Upon State Water Board approval of the Project's change in point of diversion, the Permittee provides $8,000,000 for projects benefiting winter-run and spring-run Chinook salmon in the Delta or the Sacramento River watershed upstream of the Delta, and $1,300,000 for projects benefiting white sturgeon in the Sacramento River, Delta or San Joaquin watersheds. Project selection for both is subject to CDFW approval, and all approved white sturgeon projects are completed before Phase 1 Operations.

Type
Financial
Frequency
One time
Timing
upon approval of the change in point of diversion for the Project by the State Water Board
Bouldin Island Geotechnical Exploration
On HoldDue 2026-04-27
Byron Tract Forebay
Completed
Obtain CDFW Approval of the Endowment Management Agreement

COA 12.12.4

No agreement governing the management and expenditure of the Endowment is executed until Permittee has obtained CDFW's written approval of it.

Type
Approval & Consultation
Frequency
As needed
Intake B — North Delta
In Progress
Intake C — North Delta
On Hold
Bethany Reservoir Aqueduct
Not Started
Prepare Endowment Assessment for CDFW Approval

COA 12.12.2, COA 12.12.2.1, COA 12.12.2.2, COA 12.12.2.2.1, COA 12.12.2.2.2, COA 12.12.2.2.3

Once an Endowment is required and CDFW has approved the HM lands, the long-term management plan and the Endowment Manager, Permittee prepares a PAR-equivalent endowment assessment of the Endowment Deposit Amount, excluding the easement holder's endowment. The assessment applies the Endowment Manager's capitalization rate adjusted for administrative, periodic and annual fees, and includes the viability buffers: a 10 percent contingency, an assumption of no spending for the first three years…

Type
Analysis
Frequency
As needed
Bethany Reservoir Aqueduct
Not Started
Southern Forebay & Pumping Plant
In Progress
Submit Endowment Assessment for CDFW Approval

COA 12.12.2

Permittee prepares the PAR-equivalent endowment assessment of the Endowment Deposit Amount and submits the results to CDFW for review and approval before transferring any funds to the Endowment Manager.

Type
Approval & Consultation
Frequency
As needed
Intake C — North Delta
In Progress
Bethany Reservoir Aqueduct
Completed
Submit Endowment Manager Proposal to CDFW

COA 12.12.1

Where an Endowment is required, Permittee submits a written proposal naming the proposed Endowment Manager, its entity type, whether it holds the property or an interest for conservation under Government Code section 65968(b)(1) or the basis for a 65968(b)(2) exception, and a copy of its section 65968(e) certification.

Type
Approval & Consultation
Frequency
As needed
Bethany Reservoir Aqueduct
On Hold

Obligations

Funding of interim management of Habitat Management lands

COA 12.11.7

Permittee shall provide funding for interim management of the HM lands by using revenues derived from SWP charges to the SWP Contractors under long-term water supply contracts and any subsequent agreements.

Class
Adhere
Audience
Crews
Holding, pooling and disbursement of the Endowment

COA 12.12.4

the approved Endowment Manager may pool the Endowment with other endowments for the operation, management, and protection of HM lands for local populations of the Covered Species but shall maintain separate accounting for each Endowment.

Class
Adhere
Audience
Crews
Applies When
If CDFW determines in its sole discretion that an expenditure needs to be made from the Endowment to preserve the conservation values of the HM lands, the Endowme

Security and assurances

Actions

Submit Covered Fish Monitoring Funding Strategy to CDFW

COA 13.2

With the draft Covered Fish Species Monitoring and Science Plan, the Permittee submits a funding strategy to CDFW for review and approval covering the costs of planning and implementing the required studies and monitoring and the costs of preparing and submitting the required reports.

Type
Financial
Frequency
One time
Timing
With submittal of the draft Covered Fish Species Monitoring and Science Plan
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-08-16
Byron Tract Forebay
In ProgressDue 2026-05-20

Habitat accounting

Disturbance tracking

Actions

Calculate Phase Impacts and Mitigation for Authorization Package

COA 12

Before each Project Phase begins, Permittee calculates the total impacts on Covered Species for that Phase and the corresponding compensatory mitigation, on-site restoration and other mitigation obligations. The calculation is included in the Phase Authorization Package submitted to CDFW for review under COAs 6.2 and 7.1.

Type
Analysis
Frequency
One time
Timing
prior to the beginning of each Phase
Bethany Reservoir Aqueduct
Not StartedDue 2026-03-25
Southern Forebay & Pumping Plant
In ProgressDue 2026-10-15
Complete Pre-Disturbance Habitat Photo Documentation

COA 10.3

No more than 14 days before Covered Activities begin at a construction site, Permittee photographs each distinct suitable habitat area with at least five photographs per area, one each from the north, south, east and west plus one facing the area, separately for each Covered Species' habitat, and files the images in the GIS habitat tracking.

Type
Survey
Frequency
One time
Timing
no more than 14 days prior to initiation of Covered Activities
Bethany Reservoir Aqueduct
Not StartedDue 2026-11-01
Conduct Photo Monitoring of Temporary Impact Areas

COA 10.6

Permittee photographs each established photo monitoring station before construction and every month until construction and initial restoration are complete, then every three months until restoration success is reached, visiting all stations within two days per cycle and delivering the images in a geographic format monthly with the Monthly Compliance Report and in full with the Annual Status Report.

Type
Monitoring
Frequency
Recurring
Timing
each month thereafter until construction and initial restoration is complete, then every three months following the initial restoration until restoration success is reached
Intake B — North Delta
Not StartedDue 2026-08-151 of 3 done
Establish Restoration Treatment and Reference Transects

COA 12.3.3

Before ground disturbance, Permittee establishes a representative number of numbered treatment transects in areas to be disturbed, pairs each with a reference site of intact habitat of similar slope, aspect and hydrology, photographs both in spring (March to June) while flowering plants are in bloom, and evaluates reference-site species composition to guide restoration.

Type
Survey
Frequency
One time
Timing
Prior to initiating ground disturbance
Southern Forebay & Pumping Plant
Not StartedDue 2026-11-12
Notify CDFW of Likely Impact Exceedance and Revised Schedule

COA 10.9

When impacts tracked for the Annual Status Report are likely to exceed the permanent or temporary impacts CDFW approved for any Covered Species, Permittee notifies CDFW and submits a revised Project Phase schedule within 10 business days of that notice, keeping temporary impacts within the COA 11.66 and 12.3 criteria.

Type
Reporting
Frequency
As needed
Timing
within 10 business days of the notification
Intake C — North Delta
Not Started
Report Habitat Disturbance Acreage and GIS Layers to CDFW

COA 10.3, COA 10.5

Permittee attaches to each Monthly Compliance Report the current GIS layers of suitable habitat features and disturbance with full metadata, plus cumulatively disturbed acreage per Covered Species and the acreage anticipated to be disturbed over the next 30 days. Updated per-species maps and an annual summation of all habitat feature disturbance go to CDFW with the Annual Status Report.

Type
Reporting
Frequency
Recurring
Timing
attached to the Monthly Compliance Report
Intake B — North Delta
Not StartedDue 2026-09-032 of 3 done
Survey Riverbank and Vegetation Conditions at Barge Sites

COA 11.36

A Fisheries Biologist or Biological Monitor visits each site requiring barges, including each north Delta intake and geotechnical exploration site, during the growing season before work begins, during construction, and annually for up to five years after construction, recording the extent of emergent and riparian vegetation, bank conditions on both riverbanks and general site conditions.

Type
Monitoring
Frequency
Recurring
Timing
during the growing season prior to initiation of construction activities, during construction, and then annually for up to five years after construction
Bouldin Island Geotechnical Exploration
On HoldDue 2026-06-161 of 3 done
Byron Tract Forebay
Not StartedDue 2026-12-282 of 3 done
Intake B — North Delta
Not StartedDue 2027-01-012 of 3 done
Verify Impact Multipliers in the Annual Status Report

COA 12.1

Permittee verifies through Annual Status Report documentation of impacts and mitigation that the assumed impact multipliers for the 230 kV transmission lines and for preconstruction activities hold, comparing actual disturbance against the assumed tower footprint, work area and temporary surface impact shares.

Type
Monitoring
Frequency
Recurring
Timing
Annual Status Report
Southern Forebay & Pumping Plant
Not StartedDue 2026-11-272 of 3 done
Twin Cities Complex
Not StartedDue 2027-06-022 of 3 done

Obligations

GIS tracking of land disturbance and suitable habitat feature impacts

COA 10.3

Permittee shall maintain Geographic Information System (GIS) shapefile layers and associated maps depicting: 1) mapped areas of all land disturbances within each Project construction site; and 2) mapped areas of disturbed identified habitat features suitable for Covered Species (see Condition of Approval 10.4 for habitat features) within the Project construction site.

Class
Monitor
Audience
Monitors
Applies When
If there are any…
GIS tracking of land disturbance and suitable habitat feature impacts

COA 10.4, COA 10.9

Permittee shall track suitable habitat for the Covered Species in each Project construction site and surrounding species-specific buffers.

Class
Monitor
Audience
Monitors

Restoration

Actions

Backfill and Restore Preconstruction Investigation Sites

COA 12.2

The Permittee backfills every subsurface pit, trench and borehole from preconstruction field investigations with the excavated material, places stockpiled topsoil at the surface, and fully restores each investigation site under COA 12.3.3, within one year of initiating Covered Activities.

Type
Restoration & Mitigation
Frequency
One time
Timing
within one year of initiating Covered Activities
Intake C — North Delta
On HoldDue 2026-08-23
Develop Temporary Impact Restoration Schedule

COA 12.3.2

Before any temporary impact begins, Permittee develops a Temporary Impact Restoration Schedule ensuring invasive substrate removal, recontouring and seeding of each temporary impact area occur within the same year at times suited to seedling success, and that all prior-year temporary impacts meet the recontouring and seeding criteria and the vegetation success standards of the Restoration and Revegetation Plan.

Type
Plan
Frequency
One time
Timing
Prior to initiating any temporary impacts
Twin Cities Complex
OverdueDue 2026-09-24
Bouldin Island Geotechnical Exploration
In ProgressDue 2026-03-31
Develop Tidal Wetland Restoration Efficacy Study Plan

COA 10.21.4

Before Phase 1 Operations begin, Permittee develops the Tidal Wetland Restoration Efficacy Study Plan, using Fish Restoration Program and other monitoring data to analyze how the restored tidal wetlands required by COAs 12.6 through 12.8 produce food web resources. Results are incorporated into the Covered Fish Species life cycle models to evaluate how the restoration offsets Project impacts against the Biological Criteria.

Type
Analysis
Frequency
One time
Timing
Before Phase 1 Operations begin
Intake B — North Delta
Not StartedDue 2026-08-07
Intake C — North Delta
In ProgressDue 2026-10-09
Bethany Reservoir Aqueduct
Completed
Remove Temporary Fill and Construction Refuse at Completion

COA 9.17

Remove temporary fill and construction refuse upon completion of Covered Activities.

Type
Avoidance & BMPs
Frequency
One time
Timing
Upon completion of Covered Activities
Byron Tract Forebay
OverdueDue 2026-06-19
Restore Riverbank Eroded by Barge Operations

COA 11.36

If barge operations erode 20 percent or more of a bank, the Permittee retains a qualified restoration specialist to restore the eroding bank. The completed bank restoration is the tracked deliverable.

Type
Restoration & Mitigation
Frequency
As needed
Timing
If barge operations result in 20% or more of a bank eroding
Southern Forebay & Pumping Plant
Not Started
Twin Cities Complex
In Progress
Restore Temporarily Impacted Habitat to Pre-Project Conditions

COA 11.17, COA 11.41, COA 11.65, COA 11.66, COA 12, COA 12.3, COA 12.3.1

For every area temporarily disturbed by Covered Activities — power line work, SCADA and transmission corridors, access roads, channel and upland work, and the on-site acreages in Table 12-1 — the Permittee removes temporary fill, debris and stockpiles, regrades to pre-existing contour and hydrology, and recontours, reseeds and replants with CDFW-approved native species under the Restoration and Revegetation Plan. Each area is restored to pre-Project conditions or better within the year of the…

Type
Restoration & Mitigation
Frequency
One time
Timing
within the year of the impact initially occurring, and in all cases within one year of disturbance
Bethany Reservoir Aqueduct
Not StartedDue 2026-03-30
Southern Forebay & Pumping Plant
In ProgressDue 2026-03-30
Twin Cities Complex
Not StartedDue 2026-06-29
Submit Restoration and Revegetation Plan

COA 12.3, COA 12.3.1, COA 12.3.3

Permittee submits the Restoration and Revegetation Plan to CDFW in the appropriate Phase Authorization Package as construction plans are finalized and Covered Species suitable habitats are identified, covering the seventeen required elements from site conditions and nonnative removal through seed mixes, irrigation, weed management, fencing and signage to success standards and remedial actions, and including the species-specific restoration guidelines CDFW must approve. No Covered Activity…

Type
Plan
Frequency
One time
Timing
until the Restoration Plan is approved in writing by CDFW
Byron Tract Forebay
Not StartedDue 2026-04-09
Intake B — North Delta
In ProgressDue 2026-10-04
Intake C — North Delta
Not StartedDue 2026-07-23
Submit Restoration Monitoring Reports to CDFW

COA 12.3.4

For each restored site, Permittee submits the first monitoring report to CDFW six months after restoration is complete — covering vegetation establishment, percent invasive species, site photos and other success observations — a second at the end of the first year stating whether restoration succeeded, then annual reports until standards are met for three consecutive years, or semiannual reports while standards remain unmet.

Type
Reporting
Frequency
Recurring
Timing
After the first six months following completion of restoration activities at a Project Site
Bethany Reservoir Aqueduct
Not StartedDue 2026-09-031 of 3 done
Southern Forebay & Pumping Plant
On HoldDue 2027-03-181 of 3 done
Twin Cities Complex
On HoldDue 2027-03-211 of 3 done

Obligations

Erosion protection of restoration soils until vegetation establishes

COA 12.3.3

Minor recontouring may be conducted; however, Permittee shall limit grading, compaction, fill, and other earthmoving activities to the Project construction site.

Class
Adhere
Audience
Crews
Applies When
If feasible, seed shall be applied immediately…
Invasive plant management and cover limit at restoration sites

COA 12.3.3

Permittee shall oversee the management of invasive plants within Project construction sites and Project maintenance areas and may use control methods such as hand removal, light grubbing, mowing, or grazing within seeding and planting areas following vegetation restoration.

Class
Adhere
Audience
Crews
Monitoring and maintenance of habitat restoration areas

COA 12.3.4

Permittee is responsible for monitoring and maintaining the habitat restoration areas for a period of three years or until the Restoration Plan success criteria have been met as determined by the Designated Biologist(s) and/or Biological Monitor(s) and CDFW in writing.

Class
Monitor
Audience
Monitors
Monitoring of restored habitat until success

COA 11.66

Permittee shall monitor the restoration for one year or until restoration success is achieved as determined by the Designated Biologist(s) and/or Biological Monitor(s) and CDFW.

Class
Monitor
Audience
Monitors
Restoration survivorship and cover success standards with remedial action

COA 12.3.3, COA 12.3.4

Success standards to ensure a minimum of 70 percent survivorship for three years after the last planting at each site and proposed remedial actions if those standards are not met.

Class
Adhere
Audience
Crews
Applies When
After the last planting at each site and proposed remedial actions if those standards are not met
Seed mix composition and sourcing for restoration

COA 12.3.3

Seed mixes shall be identified for approval as part of the Restoration Plan and shall include a mix of locally native species and non-native forage species (no species designated by the California Invasive Plant Council (Cal-IPC) as high or moderate invasive species may be used), including diverse assemblages of native and non-native flora, with an emphasis on nonnative bunchgrasses and other grassland species including local, native wildflowers and/or shrub seeds.

Class
Adhere
Audience
Crews
Seeding timing and reseeding at restoration sites

COA 12.3.3

Minor recontouring may be conducted; however, Permittee shall limit grading, compaction, fill, and other earthmoving activities to the Project construction site.

Class
Adhere
Audience
Crews
Applies When
If feasible, seed shall be applied immediately…
Substrate removal, topsoil salvage and imported fill in restoration areas

COA 12.3.3

Gravel and other invasive substrate shall be removed from restoration areas. (2) To the maximum extent feasible, topsoil shall be salvaged from within on-site Project areas prior to construction.

Class
Adhere
Audience
Crews
Applies When
Prior to construction
Target native vegetation community for each restoration area

COA 12.3.3

Seed mixes shall be identified for approval as part of the Restoration Plan and shall include a mix of locally native species and non-native forage species (no species designated by the California Invasive Plant Council (Cal-IPC) as high or moderate invasive species may be used), including diverse assemblages of native and non-native flora, with an emphasis on nonnative bunchgrasses and other grassland species including local, native wildflowers and/or shrub seeds.

Class
Adhere
Audience
Crews
Vehicle Barriers on Restored Shoulders

COA 12.3.3

Drivers may attempt to use adjacent shoulders for parking or to avoid ruts that form in roadways.

Class
Adhere
Audience
Crews