20250206Application.pdf

_ ROCKY MOUNTAIN 1407 W.North Temple,Suite 330
POWER. Salt Lake City,UT 84116
A DIVISION OF PACIFICORP
RECEIVED
2025 February 6
February 6, 2025 IDAHO PUBLIC
UTILITIES COMMISSION
VIA ELECTRONIC DELIVERY
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714
RE: CASE NO. PAC-E-25-01
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR
APPROVAL OF THE DECOMMISSIONING AND SALE OF THE PARIS
HYDROELECTRIC PROJECT GENERATING FACILITIES
Attention: Commission Secretary
Pursuant to Idaho Code § 61-328, Rocky Mountain Power, a division of PacifiCorp, submits its
application to the Idaho Public Utilities Commission requesting approval of the decommissioning
and disposition of the Paris Hydroelectric Project and generating facilities.
Informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at(801) 220-2313.
Very truly yours,
9k--)a1--'-D
Joe Steward
Senior Vice President, Regulation
Enclosures
CC: Chris McEwan

Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas(a�pacifico1p.com
Attorney for Rocky Mountain Power
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ) CASE NO. PAC-E-25-01
ROCKY MOUNTAIN POWER FOR )
APPROVAL OF THE DECOMMISSIONING ) APPLICATION OF
AND SALE OF THE PARIS ) ROCKY MOUNTAIN
HYDROELECTRIC PROJECT GENERATING ) POWER
FACILITIES )
Comes now PacifiCorp, d/b/a Rocky Mountain Power ("Rocky Mountain Power" or
"Company")pursuant to Idaho Code(LC.) § 61-328 and IDAPA 31.01.01.052 hereby submits this
application to the Idaho Public Utilities Commission ("Commission"). Rocky Mountain Power
respectfully requests an order approving the decommissioning of the Paris Hydroelectric Project
generating facilities ("Paris Project") and determining that the decommissioning and property
disposition is in the public interest.
The Paris Project, originally constructed in 1910 and operating under a Federal Energy
Regulatory Commission ("FERC") conduit exemption, has served the region for over a century.
As part of this filing, PacifiCorp proposes the decommissioning of the facility, removal of
infrastructure, and restoration of Paris Creek to its natural flow. This initiative is guided by the
Paris Creek Restoration Agreement, a collaborative effort between PacifiCorp and stakeholders
within the Bear River Hydroelectric Project Environmental Coordination Committee ("ECC").
The Paris Creek Restoration Agreement and proposed decommissioning provides for a reduction
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in minimum stream flow requirements at the Grace Hydroelectric Development, offsetting the loss
of generation from the Paris Project and represents the most cost-effective solution to address aging
infrastructure, operational limitations, and evolving resource management needs.
In support of this Application, Rocky Mountain Power states as follows:
I. NAME AND ADDRESS OF THE APPLICANT
1. Rocky Mountain Power, a division of PacifiCorp, an Oregon Corporation, whose
address is 1407 West North Temple, Suite 320 Salt Lake City,Utah 84116, is authorized to do and
is doing business in the state of Idaho. The Company provides retail electric service to
approximately 91,000 customers in the state and is subject to the jurisdiction of the Commission.
The Company's retail certificated service territory encompasses portions of Fremont, Madison,
Teton, Clark, Jefferson, Lemhi, Oneida, Bannock, Franklin, Caribou, Butte, Bingham, Bear Lake
and Bonneville counties. Rocky Mountain Power is a public utility in the state pursuant to I.C. §
61-129.
2. Formal correspondence and requests for additional information regarding this
matter should be addressed to:
By email (preferred): datarequest(&,pacificorp.com
By regular mail:
Data Request Response Center
PacifiCorp
825 NE Multnomah, Suite 2000
Portland, Oregon 97232
With copies to:
Mark Alder
Idaho Regulatory Affairs Manager
1407 W.North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
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Email: mark.alderkpacificorp.com
Joe Dallas
Attorney
Rocky Mountain Power
825 NE Multnomah, Suite 2000
Email:joseph.dallaskpacificorp.com
Informal inquiries related to this Application should be directed to Mark Alder, Idaho
Regulatory Affairs Manager, at(801) 220-2313.
II. BACKGROUND
3. The Paris Project is a 715-kilowatt ("kW") hydroelectric project located in Paris
Canyon within Bear Lake County, Idaho, which began service in 1910 being operated by the Bear
Lake Power Company. The FERC regulated portion of the Paris Project is located on
approximately 30 acres of land owned by PacifiCorp. The Paris Project is located within the Bear
River watershed in Idaho along with PacifiCorp's Bear River Hydroelectric Project, that includes
the Soda Hydroelectric Development with a capacity of 14 megawatts ("MW"), the Grace
Hydroelectric Development ("Grace Development") with a capacity of 33 MW, and the Oneida
Hydroelectric Development with a capacity of 30 MW.
4. In 1999, PacifiCorp filed an application with the FERC for relicensing of the Bear
River Hydroelectric Project ("Bear River Project").' After lengthy discussions between
PacifiCorp, state and federal agencies, tribes, and non-governmental organizations, a settlement
agreement on FERC relicensing was signed by all parties on August 28, 2002. The Bear River
Relicensing Settlement Agreement ("Settlement Agreement") was based on resource agency
mandates and mutual agreement of the signing parties to employ an ecosystem restoration
approach to accomplish resource restoration and enhancement in conjunction with hydropower
'The Paris Project is currently operated under a FERC Order granting an exemption from hydroelectric plant licensing.
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operations, recreation uses, and other beneficial uses of the Bear River.
5. The ECC, a stakeholder group comprised of signatories to the Settlement
Agreement, was formed to consult and make decisions regarding the use of funding and other
license requirements for the Bear River Project.These responsibilities include,among other things,
facilitating coordination and consultation among the Parties on implementation of the Settlement
Agreement measures; proposing and approving restoration and flow measures; establishing
monitoring criteria to evaluate the effects of Settlement Agreement measures; and coordinating
and implementing Settlement Agreement measures.
6. PacifiCorp has been working with the Parties and entered into the Paris Creek
Restoration Agreement with the ECC, which provides for habitat restoration by returning flows
back to Paris Creek for the enhancement and restoration of approximately 3.5 miles of high-quality,
cold-water habitat for Bonneville cutthroat trout in the currently bypassed reach of Paris Creek.
This agreement amended the Bear River Relicensing Settlement Agreement and provides the basis
of the Company's request to decommission the Paris Project. A unique component of this
agreement is a reduction in minimum stream flow releases at PacifiCorp's Grace Development to
provide additional water for generation to offset a portion of the lost generation from the
decommissioning.
7. As a result of the Paris Creek Restoration Agreement, the Company filed an
application with FERC requesting to decommission and surrender the FERC conduit exemption
order (the Paris Project primarily operates on senior irrigation water rights passed through the
project) for the Paris Project and a separate application to amend the FERC license for the Bear
River Project to reduce the required minimum instream flow at the Grace Development, which
will allow for additional generation that will mitigate the loss of hydroelectric generation
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associated with the Paris Project.'
A. Paris Project
8. Water is diverted from Paris Creek into an earthen canal by a concrete diversion
structure that is located approximately 600 feet downstream of Paris Springs, the headwaters of
Paris Creek. The canal extends for approximately four miles from the diversion structure to the
upstream-most feature of the Paris Project—the forebay. A concrete intake structure at the
upstream end of the Paris Project forebay connects the forebay to the canal.
9. The diversion structure near the headwaters of Paris Creek, and the first 0.78 mile
of the canal are located on federal lands administered by the United States Department of
Agriculture Forest Service ("USFS"). Approximately 0.54 mile of the canal is located on federal
lands administered by the United States Department of Interior Bureau of Land Management
(`BLM").The remainder of the canal between the diversion structure and the intake for the forebay
is located on privately owned land. PacifiCorp owns the diversion structure and the rights to the
canal and currently operates and maintains the canal. See Figure 1 below for a map of the Paris
Project.
2 PacifiCorp proposed to amend Article 408(b)of the FERC license for the Bear River Hydroelectric Project to adjust
minimum instream flows at the Grace Development's bypass reach through the remaining term of the Bear River
Hydroelectric Project license.
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■ Diversion
O Paris Plant
- Canal
�. Penstock
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PacifiCorp Land
.r 't National Forest
eyti .`
BLM Land
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Paris y 4 r,
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CARIBOU-TARGHEE
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Figure 1. Map of Paris Project
10. Water moves through the Paris Project starting with its diversion from Paris Creek
on USFS lands at the location labelled "Diversion" on Figure 1. Water eventually reaches the
forebay and enters the "penstock" to the Paris Powerhouse. The penstock is primarily above
ground until it nears the powerhouse where it goes underground. The penstock rises through the
powerhouse floor and joins the turbine of a horizontal above-floor generating unit. After exiting
the turbine the water moves through the tailrace piping that delivers the water directly into Paris
Relief Canal Company's irrigation infrastructure or it is returned to Paris Creek.
III. DECOMMISSIONING AND SALE
11. PacifiCorp,in collaboration with the ECC,will decommission the Paris Project and
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will offer the Company land for sale.In an agreement with the ECC,PacifiCorp will decommission
the Paris Project in exchange for a 15 cubic feet per second ("cfs") reduction in the Grace
Development's bypassed reach,which will result in increased water available for generation at the
Grace Development.
12. The decommissioning activities for the Paris Project include: 1) removing the
concrete forebay inlet structure and the slide gate; 2) grading the earthen forebay embankments to
resemble natural landforms; 3) removing the concrete outlet structure, gates, and trash racks; 4)
removing the steel penstock and support piers; 5)removing the concrete elements of the spillway
and flume; 6) decommissioning the power house by removing and disposing of its contents and
disconnecting the power house from PacifiCorp's distribution system to leave the structure secure
and empty on-site; 7)removing the discharge pipe sections across the road from the power house;
8) removing the concrete tailrace basin and slide gates; 9) leaving the Paris Relief Flume (an iron
pipe and trestle structure) in-place; and 10) demolishing the employee house and disposing of the
material off-site.All disturbed areas will be graded and seeded.'
13. The total cost of decommissioning the Paris Project is approximately $1.6 million.
The specific details of the Paris Project decommissioning and reclamation are:
a. Forebgy. The forebay is approximately 350 feet-long by 60-feet wide with a
total surface area of approximately 0.61 acres. The earthen forebay
embankments will be graded to resemble natural landforms. Disturbed areas
will be graded and seeded.
b. Inlet Structure. There is a concrete inlet structure at the upstream end of the
forebay. This structure has a slide gate where an abandoned irrigation ditch
connects to the forebay. PacifiCorp proposes to decommission the inlet
structure by removing the concrete structure and the slide gate. Concrete will
be broken up and buried on-site. Disturbed areas will be graded and seeded.
c. Outlet Structure. At the downstream end of the forebay is a concrete outlet
s The FERC approved the Company's request to decommission the Paris Project and to reduce the required minimum
instream flow released at the Grace Development in an Order issued on August 27,2024.
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structure with two bays, one leading to the penstock and one leading to the
spillway. PacifiCorp will decommission the outlet structure by removing the
concrete, gates, and trash racks. Concrete will be broken up and buried on-site.
Disturbed areas will be graded and seeded.
d. Penstock. Downstream of the forebay outlet structure is a 1,366 foot-long, 22-
30 inch diameter steel penstock supported on concrete piers spaced
approximately every 15 feet. The penstock travels downhill from the forebay
outlet structure to the powerhouse. PacifiCorp will decommission the penstock
by removing the steel penstock, salvage or dispose of it off-site, remove the
concrete piers and break up/bury the concrete on-site. Appropriate erosion
control measures will be deployed on the steep slope. Disturbed areas will be
graded and seeded.
e. S12illwa. a�pillway Flume. Downstream of the forebay outlet structure is an
overflow spillway channel. The first short portion of the channel is cast
concrete, and the remainder of the channel is natural. PacifiCorp will remove
the concrete elements of the spillway and flume, and will break up/bury the
concrete on-site. The natural channel will not be modified. Disturbed areas will
be graded and seeded.
f. Powerhouse. Downstream of the penstock is a rock and brick powerhouse
containing one horizontal (above floor) Francis turbine/generator unit with a
capacity of 715-kW. The powerhouse will be decommissioned by letter a
salvage contract for all equipment within the powerhouse. The penstock entry
into the powerhouse and the tailrace pipe will both be filled with concrete. The
powerhouse will be disconnected from PacifiCorp's distribution and
transmission system. The secure and empty powerhouse structure will remain
in place on-site.
g. Discharge Pipe. Exiting the Francis turbine/generator downstream of the
powerhouse is a 60-feet long, 30-inch diameter steel discharge pipe. The
discharge pipe will be decommissioned by removing the portion of pipe across
the road from the powerhouse but will leave in place the approximately 60-feet
long section of discharge pipe located under the county road that connects to
the powerhouse and will fill this section of pipe with concrete. Disturbed areas
will be graded and seeded.
h. Tailrace. At the downstream end of the discharge pipe is a concrete tailrace
basin with two slide gates. The tailrace will be decommissioned by removing
the concrete tailrace basin and associated slide gates, and by disposing of
concrete on-site.
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i. Paris Relief Flume. Downstream of the tailrace basin is an iron pipe and trestle
structure which crosses over Paris Creek and discharges the water that has
passed through the Paris Project into an irrigation canal. This structure will
remain in place.
j. Employee House and Garage. There is an employee house, an associated
freestanding garage, and a drain field located on the Paris Project site. The
employee house will be decommissioned by first abating asbestos in
compliance with all applicable laws regarding the handling of asbestos and then
demolishing the house and disposing of the material off-site. Concrete will be
broken up and buried on-site. The free-standing garage will remain in place
surrounded and secured by an existing metal fence. The drain field will also
remain in place. Disturbed areas will be graded and seeded.
k. Paris Project Lands.After decommissioning the forebay,penstock,powerhouse,
discharge pipe, tailrace basin, spillway flume, employee house, garage, and
drain field, PacifiCorp will likely divest itself of the Paris Project Lands,
including the empty powerhouse and empty garage with surrounding fence.
14. At the conclusion of decommissioning the following assets would be sold:
approximately 31.7 acres of land; an empty stone powerhouse; a domestic well; and garage. A
request for proposal process will be used to solicit bids to salvage the generation equipment. An
additional 4.3 acres will be donated to a public entity for public access to Paris Creek as part of
the Paris Creek Restoration Agreement.
IV. REQUEST FOR APPROVAL OF TRANSFER AGREEMENT
15. I.C. § 61-328(1) requires the Company to obtain Commission approval before
transferring property used in the generation of electric power to the public. As relevant here, in
order to approve a property transfer, I.C. § 61-328(3) requires that the Commission determine:
"(a) That the transaction is consistent with the public interest; [and] (b) [T]hat the cost of and
rates for supplying service will not be increased by reason of such transaction[.]"4
4 I.C. §61-328(3)(c)also requires a finding,"That the applicant for such acquisition or transfer has the bona fide
intent and financial ability to operate and maintain said property in the public service." Part(c)of is not applicable
to this filing since the Company is seeking approval for decommissioning and there will not be a transfer of the sale
to another operating party.
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16. The approval of the disposition and decommissioning of the Paris Project aligns
with the public interest for several reasons. The Paris Creek Restoration Agreement and the
proposed decommissioning restore 3.5 miles of habitat for Bonneville cutthroat trout while
including a reduction in the minimum stream flow requirements at the Grace Hydroelectric
Development, helping to offset the generation loss from the Paris Project. This approach offers
the most cost-effective solution to address the challenges of aging infrastructure, operational
constraints, and evolving resource management priorities. Further background on the
alternatives considered, cooperation with the ECC, and the increased generation at Grace
Development are described below.
A. Public Interest
17. PacifiCorp began evaluating options to divest of the Paris Project in 2017. A
potential sale of the project was the primary alternative initially explored. Several barriers to a sale
of the Paris Project were identified. They include an open-ended 1909 canal enlargement and
maintenance agreement, a 1936 agreement to use senior irrigation water rights for generation that
can be cancelled with 60-day notice, the rights of ranchers watering stock in the power canal, a
lengthy interconnect that would cost more than the value of the Paris Project and a special use
permit with the USFS that is not assignable or transferable and expired December 31, 2022
(currently operating on yearly extensions). Lastly, the canal crosses BLM lands and no written
right-of-way document exists. Thus, a buyer would be exposed to considerable uncertainty around
their ability to run the project.
18. Given the unlikely prospect of receiving a positive acquisition proposal for a project
that could lose its generating water with 60-day notice and a potential buyer not knowing under
what conditions the USFS would issue a special use permit for the diversion, a best alternative to
a sale was developed with the ECC. The ECC proposed that in exchange for decommissioning the
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Paris Project(an action that will return senior irrigation water rights to 3.5 miles of the substantially
dewatered Paris Creek for the benefit of native fish), they agreed to reduce the Grace
Development's bypass reach minimum stream flow requirement by 15 cfs through the end of the
Bear River Hydroelectric Project's operating license (2033). This flow reduction would increase
generation at the Grace Development. The ECC also took the lead in securing funding for a new
irrigation diversion on Paris Creek for the irrigators whose water is diverted through the Paris
Project. Other funding sources were used to remove the reliance of stock waterers on the power
canal. Prior to PacifiCorp's application submittal to the FERC, agreements were put in place with
the ECC, BLM, USFS, Bloomington Grazing Association and Ward Brothers Dairy, and the Paris
Relief Irrigation Company and Upper Southfield Irrigation Company. These agreements address
actions and funding commitments of all the Parties to assure a clean exit and provide assurance for
irrigation and stock water interests that previously relied on PacifiCorp for water delivery and that
irrigation infrastructure will be in place for their continued operations.To this end,Trout Unlimited
has secured approximately $1.3 million in funding to provide a new irrigation diversion near the
Paris Project's tailrace. State of Idaho 319 funding was also used to support new stock water
systems.
19. The Paris Project's 0.715 MW of generation capacity is a small part of PacifiCorp's
overall portfolio that consists of over 10,000 MW of Company-owned generation capacity
consisting of a diverse mix of hydroelectric, wind, natural gas, coal, solar, and geothermal
resources.
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20. The Paris Creek Restoration Agreement included a reduction in required instream
flows at PacifiCorp's Grace Hydroelectric Project bypassed reach to provide an offset to lost
generation and decommissioning costs. The extra water, as a result of the reduced bypassed reach,
will increase generation at the Grace Development through 2033.
B. Economic Analysis
21. The Company's decision was based on an economic analysis comparing two
alternatives, continued operation or decommissioning the Paris Project.'For both of these options,
the Company compared the costs and benefits of each scenario over a 30-year period. The
economic analysis showed that the decommissioning (including the increased generation water at
the Grace Development) resulted in a PVRR of approximately $1.4 million and the PVRR of the
continued operation of the Paris Project for another 30 years was approximately $1.7 million.
22. The results of the economic analysis are provided within a confidential workpaper
filed with this Application.
23. The Paris Project connects directly to the distribution circuit in Paris Canyon.
Decommissioning of the Paris Project will have no effect on the quality of service provided to
PacifiCorp customers. The minimum streamflow reduction at the Grace Development will
potentially contribute to generation 74 percent of the time on a 12-month basis and is projected
to contribute an additional 3,298 MWh to annual generation at the Grace Development.The Paris
Project base generation is 2,278 MWh.
24. The approval of this transfer will not impact current rates. The Company's
present Application seeks authorization for the decommissioning and sale of the Paris Hydro
s The decommissioning scenario includes the water swap,allowing for increased generation at the Grace Development.
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Project with a PVRR lower than the alternatives considered Therefore, the transfer proposed in
this proceeding will not affect current rates.
V. REQUEST FOR MODIFIED PROCEDURE
25. Rocky Mountain Power believes that a hearing is not necessary to consider the
issues presented herein and respectfully requests that this Application be processed under Modified
Procedure, i.e., by written submissions rather than by hearing, in accordance with Idaho Public
Utilities Commission Rules of Procedure 201 —204.
VI. CONFIDENTIAL INFORMATION
26. This filing, specifically the confidential workpaper with the PVRR analysis,
includes trade secrets and confidential information exempt from public review under Idaho Code
§§ 74-104-109 and Idaho Public Utilities Commission's Rule of Procedure 67.
VII. CONCLUSION
27. WHEREFORE, Rocky Mountain Power respectfully requests an order approving
the decommissioning of the Paris Project pursuant to I.C. § 61-328 and determining that the
decommissioning and property disposition is in the public interest.
28. Respectfully submitted this 6th day of February 2025.
Joe Dallas (ISB# 10330)
PacifiCorp, Senior Attorney
825 NE Multnomah Street, Suite 2000
Portland, OR 97232
Email:joseph.dallas&pacificorp.com
Attorney for Rocky Mountain Power
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