20240814Bi-Annual Report.pdf

RECEIVED
Wednesday, August 14, 2024
IDAHO PUBLIC
_ UTILITIES COMMISSION
ROCKY MOUNTAIN
1407 W.North Temple,Suite 330
POWER. Salt Lake City,Utah 84116
A DIVISION OF PACIFICORP
August 14, 2024
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
1131 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
Re: CASE NO. PAC-E-21-01
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
FOR APPROVAL OF THE TRANSFER OF THE LOWER KLAMATH
HYDROELECTRIC PROJECT GENERATING FACILITIES
I. BACKGROUND
On January 14, 2021, PacifiCorp, (the "Company"), filed an application with the Idaho
Public Utilities Commission, ("Commission"), requesting an order approving the Property
Transfer Agreement, ("Transfer Agreement"), between the Company and the Klamath River
Renewal Corporation, ("Renewal Corporation"),with a determination that the property disposition
is in the public interest. The Transfer Agreement provided for the transfer of four hydroelectric
dams; J.C. Boyle, Copco No. 1, Copco No. 2, and Iron Gate, (collectively the "Lower Klamath
Project"), as well as approximately 8,000 acres of real and personal property associated with the
dams from PacifiCorp to the Renewal Corporation.
On July 8, 2021, the Commission issued Order No. 35097; approving the Transfer
Agreement, authorizing the Company to create a regulatory asset for any remaining plant balances
after the transfer, and requiring PacifiCorp to file bi-annual reports with the Commission on the
status of the license transfer with the Federal Energy Regulatory Commission, ("FERC"), and any
additional capital investments on the Lower Klamath Project.

Pursuant to Order No. 35097 PacifiCorp hereby submits its semi-annual status report on
the license transfer,along with additional capital investments,and the June 30,2024,plant balance
of the Lower Klamath Project. The report covers the period of January 1, 2024, through June 30,
2024.
II. BI-ANNUAL REPORT
As previously reported, on June 17, 2021, FERC issued an orders approving PacifiCorp's
application to transfer the license for the Lower Klamath Project, FERC Project No. 14803,to the
Renewal Corporation, the State of Oregon, and the State of California (the "Co-Licensees").
Transfer of the license was to be effective upon transfer of the title of the properties under the
Lower Klamath Project to the Co-Licensees and the acceptance by the Co-Licensees of a FERC
license surrender order for the project.
FERC approved the license surrender application at its regular meeting on November 17,
2022, and issued the license surrender order2 on the same date. Following FERC's action, the Co-
Licensees formally accepted the FERC surrender order and executed the necessary steps with
PacifiCorp to complete transfer of the project license and real property, which was effective on
December 1, 2022.
PacifiCorp was obligated under the terms of the Klamath Hydroelectric Settlement
Agreement to continue to operate and maintain the Lower Klamath Project in compliance with the
existing FERC license and other regulatory requirements until the Lower Klamath Project is
disconnected from the electrical grid and no longer benefitting customers with generation
produced from the facilities. This operation and maintenance obligation was formalized in an
amended and restated Operation and Maintenance Agreement between PacifiCorp and the Co-
1 PacifiCorp,Order Approving Transfer of License, 175 FERC¶61,236(2021),Issued June 17,2021,Project Nos.
2082-062, 14803-000, 14803-004,FERC Accession#:20210617-3060.
2 PacifiCorp,Order Modifying and Approving Surrender of License and Removal of Project Facilities, 181 FERC¶
61,122(2022),Issued November 17,2022,Project Nos.2082-063, 14803-001,FERC Accession#:20221117-3021.

licensees that went into effect on December 1, 2022, concurrent with the transfer of the license.
This contract was effective with respect to each facility in the Lower Klamath Project until
generation from the facility ceased.
During this reporting period, the Renewal Corporation continued dam removal activities,
with its removal contractor beginning the removal of the Iron Gate, Copco No. 1, and J.C. Boyle
developments. Removal activities began in earnest after PacifiCorp terminated power operations
at the three facilities in January 2024 and handed operational control of the facilities to the Renewal
Corporation. At this time,the Operation and Maintenance Agreement between PacifiCorp and the
Co-Licensees was terminated. The removal contractor began drawdown of the reservoirs for the
three developments in January 2024, and began revegetation activities as the reservoir footprints
were exposed during drawdown.Dam removal activities at Iron Gate,Copco No. 1,and J.C.Boyle
have proceeded ahead of schedule and significant progress has been made in removing the dams.
Full removal of the dams is anticipated to be completed by October 2024, with reservoir
revegetation and restoration activities continuing thereafter.
III. REGULATORY ASSET BALANCE
The Lower Klamath Project's regulatory asset balance as of June 30, 2024 is summarized
in Table 1. While amortization of the legacy regulatory asset was completed, a new regulatory
asset balance was established in 2023 as a result of the FERC's reply to the Company's proposed
accounting entries associated with the disposition of the Lower Klamath Project assets.3
Originally, the Company retained the net book value of the Lower Klamath Project assets in the
plant accounts due to its continuing to operate and benefit from the output of the facilities with the
intent to transfer the net book value to a regulatory asset upon cessation of operations. However,
the FERC did not accept this accounting and directed the Company to transfer the net book value
3 FERC Docket No.AC23-26-000 dated May 5,2023.

directly to a regulatory asset. As a result, the Company transferred the net book value to a
regulatory asset in 2023 upon receiving the FERC's reply. In addition to this net book value, and
as noted in the Company's previous filing, the Company recorded an additional $117,017 in 2023
to the regulatory asset for residual amounts associated with final costs and other adjustments such
as return of materials.
Table 1. Lower Klamath Project Regulatory Asset Balance as of June 30, 2024
Description Total Idaho
Regulatory Asset $ 4,582,172 $ 248,062
Amortization Expense January to
June 2024 $ 619,185 $ 33,520
Any informal inquiries related to this report may be directed to Mark Alder, Idaho
Regulatory Manager at mark.alderkpacifiCorp.com or by phone at(801) 220-2313.
Very truly yours,
)A 9L Q-l"D
Joelle Steward
Senior Vice President, Regulation