20251224Direct Dumas.pdf

RECEIVED
DECEMBER 24, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF IDAHO POWER COMPANY' S )
COMPLIANCE WITH ORDER NOS . 34031 ) CASE NO. IPC-E-25-35
AND 35816 FOR A PRUDENCE )
DETERMINATION OF HELLS CANYON )
COMPLEX RELICENSING COSTS FROM )
JANUARY 1, 2016, THROUGH )
DECEMBER 31, 2025 . )
IDAHO POWER COMPANY
DIRECT TESTIMONY
OF
BRETT DUMAS

1 Q. Please state your name, business address, and
2 current position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Brett Dumas . My business address is
5 1221 West Idaho Street, Boise, Idaho 83702 . I am employed
6 by Idaho Power as the Environmental Affairs Director in the
7 Power Supply Business Unit.
8 Q. Please describe your educational background.
9 A. I obtained a Bachelor of Science degree in
10 Range Sciences from Humboldt State University in 1987 and a
11 Master of Science in Rangeland Ecology from the University
12 of Idaho in 1992 .
13 Q. Please describe your work experience with
14 Idaho Power.
15 A. I joined Idaho Power in 1999 as a Landscape
16 Ecologist . In 2005, I was promoted to Environmental Manager
17 of the Terrestrial Program, where I was responsible for
18 cultural, wildlife, and botanical resources, as well as for
19 permitting of power lines across federal lands . In 2017, I
20 was promoted to my current position as the Director of
21 Environmental Affairs, where I oversee department
22 activities, personnel, and budget related to hydro
23 relicensing and compliance.
24 Q. What is the purpose of your testimony in this
25 case?
DUMAS, DI 1
Idaho Power Company

1 A. The purpose of my testimony is to provide a
2 history of the Company' s Hells Canyon Complex ("HCC")
3 relicensing efforts and to provide support for the
4 relicensing costs incurred over the last ten years,
5 demonstrating that they were necessary and prudent to
6 ensure future operations of this key component of Idaho
7 Power' s generation portfolio.
8 Q. How is your testimony organized?
9 A. My testimony is organized into three sections .
10 First, I provide an overview of the Hells Canyon Complex
11 and the relicensing process . Second, I discuss the
12 regulatory requirements for relicensing and Idaho Power' s
13 efforts to meet them. Finally, I summarize the current
14 status of the long-term license.
15 Q. Are you sponsoring any exhibits?
16 A. Yes . I am sponsoring Exhibit 1 - Relicensing
17 Expenditures by Project 2015-2025 .
18 I . OVERVIEW OF HCC AND RELICENSING PROCESS
19 Q. What is the HCC and why is it significant to
20 Idaho Power?
21 A. The HCC consists of three hydroelectric
22 developments : Brownlee, Oxbow, and Hells Canyon dams,
23 located on the Snake River at the Idaho-Oregon border. The
24 HCC provides approximately 70 percent of Idaho Power' s
25 hydroelectric generating nameplate capacity and about 30
DUMAS, DI 2
Idaho Power Company

1 percent of the Company' s total generating capacity. It is
2 Idaho Power' s largest hydroelectric asset and is essential
3 to delivering reliable, affordable, and clean energy to
4 customers .
5 Q. Is a license required to operate the HCC?
6 A Yes . Idaho Power is required to obtain a
7 license for the HCC from the Federal Energy Regulatory
8 Commission ("FERC") . The licensing process involves
9 extensive public review and consultation with multiple
10 resource and environmental agencies to ensure compliance
11 with federal and state laws .
12 Q. What is the status of Idaho Power' s current
13 license for the HCC?
14 A. In July 2003, Idaho Power applied to FERC for
15 a new long-term license in anticipation of the expiration
16 of the then-existing license in July 2005 . Since that
17 expiration, Idaho Power has operated the HCC under annual
18 licenses issued by FERC while the relicensing process
19 continues .
20 Q. Can you describe the key regulatory processes
21 that must be completed in order to obtain a long-term
22 license for the HCC?
23 A. Yes . After submitting the license application,
24 Idaho Power must secure Clean Water Act ("CWA") Section 401
25 certifications from both Idaho and Oregon to demonstrate
DUMAS, DI 3
Idaho Power Company

1 compliance with state water quality standards . FERC
2 conducts its review under the National Environmental Policy
3 Act ("NEPA") concurrently, preparing an Environmental
4 Impact Statement ("EIS") to evaluate potential
5 environmental impacts .
6 FERC also initiates formal consultation under
7 Section 7 of the Endangered Species Act ("ESA") to assess
8 potential impacts on federally listed species and their
9 habitats . After the ESA consultation is complete, and all
10 relevant studies and mitigation measures are incorporated,
11 FERC finalizes the EIS and can then issue a long-term
12 license for the Hells Canyon Complex.
13 Q. Can you provide an overview of the Company' s
14 relicensing efforts since the Commission' s prudence review
15 in Case No. IPC-E-16-32?
16 A. Yes . Since the Commission' s prudence review
17 for relicensing expenditures through 2015, Idaho Power' s
18 efforts have focused primarily on advancing the three
19 regulatory requirements I previously described: Clean Water
20 Act Section 401 water quality certifications from Idaho and
21 Oregon, the ESA Consultation, and FERC' s review under NEPA
22 ("NEPA Analysis") .
23
24
25
DUMAS, DI 4
Idaho Power Company

1 II . REGULATORY REQUIREMENTS
2 Clean Water Act Section 401 Certification
3 Q. Has Idaho Power received the CWA Section 401
4 certifications from both Idaho and Oregon?
5 A. Yes .
6 Q. Can you provide a summary of Idaho Power' s
7 efforts to secure the CWA Section 401 certifications?
8 A. Yes . In 2003, Idaho Power submitted its first
9 Section 401 certification applications to the Idaho and
10 Oregon Departments of Environmental Quality ("DEQ") . Given
11 the complexity of the issues, the Company, consistent with
12 both states' directions, annually withdrew and submitted
13 amended applications to reflect new data and study results .
14 This effort ultimately identified elevated Snake River
15 water temperature as the principal water quality issue
16 requiring resolution. More specifically, ongoing studies
17 indicated that the HCC contributed to modest exceedances of
18 the fall salmonid spawning temperature criteria. ' In
19 response, Idaho Power began developing mitigation
20 strategies and incorporating those measures into its
21 updated applications . Over time, those strategies evolved
22 into a comprehensive Temperature Management and Compliance
23 Plan, which I will discuss later in my testimony.
1 Fall salmonid spawning criteria refers to water-temperature thresholds
established by the States of Idaho and Oregon to protect salmonid eggs and
alevins during the fall spawning and incubation period.
DUMAS, DI 5
Idaho Power Company

1 In 2016, conflicts emerged between the Idaho and
2 Oregon certification processes . Oregon' s draft
3 certification included mandatory fish passage and
4 reintroduction requirements, while Idaho' s certification
5 prohibited actions that would reintroduce fish species into
6 Idaho waters without state approval . Idaho Power filed a
7 petition with FERC seeking clarification that the Federal
8 Power Act preempted the Oregon statute. FERC dismissed the
9 petition as premature; rehearing was denied, and the
10 Company appealed to the D.C. Circuit Court, while the
11 governors of Idaho and Oregon continued negotiations .
12 In April 2019, Idaho Power, the state of Idaho, and
13 the state of Oregon reached a settlement agreement
14 resolving outstanding issues related to the CWA Section 401
15 certifications . Under that agreement, Idaho Power committed
16 to expanding Chinook salmon hatchery production and
17 providing $12 million over 20 years for research on the
18 viability of reintroduction and funding water quality
19 improvements in Oregon tributaries . In exchange, Oregon
20 agreed that its CWA Section 401 certification would not
21 require fish passage for the first 20 years of the new
22 license.
23 Both states issued their final Section 401
24 certifications in May 2019, and in December 2019, Idaho
25 Power filed an Offer of Settlement with FERC requesting
DUMAS, DI 6
Idaho Power Company

1 that the terms of the agreement among Idaho Power, the
2 state of Idaho, and the state of Oregon be incorporated
3 into the new HCC license.
4 Q. Have there been any developments or
5 proceedings related to the CWA Section 401 certifications
6 since 2019?
7 A. Yes . After Oregon issued its certification,
8 litigation was filed challenging it on issues related to
9 fish passage, water temperature, and mercury. Two cases
10 were consolidated, and Idaho Power intervened. A third case
11 was dismissed with prejudice. In September 2021, all
12 remaining challenges were resolved, and the earlier
13 agreement among Idaho Power, the state of Idaho, and the
14 state of Oregon regarding fish passage was preserved.
15 Q. Can you summarize the primary requirements
16 established in the CWA Section 401 certifications?
17 A. Yes . The CWA Section 401 certifications
18 establish technical requirements to ensure that operations
19 at the HCC comply with state water quality standards for
20 temperature, dissolved oxygen, total dissolved gas,
21 nutrients (primarily nitrogen and phosphorus) , and mercury.
22 Q. Can you provide additional details on the
23 requirements for temperature?
24 A. Yes . Temperature management is a central
25 component of the CWA Section 401 certifications . Idaho
DUMAS, DI 7
Idaho Power Company

1 Power is required to implement a comprehensive Temperature
2 Management and Compliance Plan ("TMCP") , which outlines
3 operational, monitoring, and watershed-scale measures to
4 meet water quality criteria. Under the TMCP, Idaho Power
5 must monitor and manage temperatures throughout the HCC to
6 provide reasonable assurance the states' water quality
7 standards, including criteria that support fall Chinook
8 salmon spawning and rearing conditions in the Snake River
9 system, will be met.
10 The primary component of the TMCP consists of
11 watershed-scale measures implemented through the Snake
12 River Stewardship Program ("SRSP") , which provides thermal
13 benefits to the Snake River above Brownlee Reservoir and in
14 tributaries feeding the reservoir.
15 In addition, the Company manages water temperature
16 through operational measures, including forecasting the HCC
17 seven-day average maximum outflow temperature at the start
18 of the salmonid spawning period and adjusting dam
19 operations as needed, such as increasing fall drafting of
20 Brownlee Reservoir to release cooler water downstream.
21 Q. What is the SRSP?
22 A. The SRSP is Idaho Power' s long-term effort to
23 address elevated water temperatures in the Snake River by
24 improving river and tributary habitat. The program focuses
25 on restoring and narrowing sections of the river channel
DUMAS, DI 8
Idaho Power Company

1 and planting native vegetation to shade the river along key
2 tributaries to reduce heat gain and improve ecological
3 conditions . Restoration activities include reshaping
4 floodplain areas to increase water velocity, reducing
5 surface area exposed to solar heating, and limiting algae
6 and aquatic plant growth.
7 Q. Can you describe the types of projects that
8 have been implemented under the SRSP?
9 A. Yes . One key project implemented under the
10 SRSP is the Bayha Island Project, which was completed in
11 2016 . This project involved deepening the river channel and
12 creating approximately 10 acres of floodplain, with native
13 vegetation such as willows, rabbitbrush, currants, grasses,
14 and sedges planted to stabilize banks and provide shade .
15 The completion of this project was instrumental in
16 demonstrating to the Idaho and Oregon DEQs that the SRSP is
17 a viable temperature mitigation program, ultimately
18 supporting the issuance of CWA Section 401 certifications .
19 Q. Can you provide additional details on the
20 requirements for dissolved oxygen ("DO") established in the
21 CWA Section 401 certifications?
22 A. Idaho Power is required to implement
23 operational and watershed-scale measures to meet DO
24 criteria at Brownlee Reservoir and downstream of Hells
25 Canyon Dam. Operational measures include operating
DUMAS, DI 9
Idaho Power Company

1 distributed aeration systems at Brownlee Dam to increase DO
2 in outflows as well as using the Oxbow Bypass
3 Destratification system to prevent anoxic conditions .
4 One of the Company' s key watershed-scale measures to
5 meet DO requirements is the Grand View Project. The project
6 reduces sediment and nutrient loading to the Snake River by
7 converting upstream agricultural lands from surface,
8 gravity irrigation to pressurized sprinkler systems, which
9 decreases the amount of phosphorus entering the river.
10 Reducing phosphorus in the river is the primary mechanism
11 for improving DO levels .
12 In 2018, Idaho Power conducted feasibility testing
13 and converted approximately 420 acres of cultivated
14 agricultural land to pressurized sprinkler systems as part
15 of this effort. Research and monitoring confirmed that this
16 initial conversion achieved significant phosphorus
17 reductions . Work on the Grand View Project continues to
18 this day, but the costs under review in this case are
19 limited to those associated with the initial proof-of-
20 concept phase.
21 Q. What requirements for total dissolved gas were
22 established in the CWA Section 401 certifications?
23 A. Idaho Power must maintain total dissolved gas
24 levels below 110 percent of saturation at specified
25 sampling locations, except during periods of extremely high
DUMAS, DI 10
Idaho Power Company

1 flow. To support compliance, flow deflectors are proposed
2 to be installed and operated at Brownlee, Oxbow, and Hells
3 Canyon dams .
4 Q. How are nutrients, such as nitrogen and
5 phosphorus, managed under the CWA Section 401
6 certifications?
7 A. Nutrients are monitored as indicators of
8 excessive algal growth. This monitoring involves developing
9 a comprehensive plan, conducting quantitative sampling when
10 risks are identified, issuing advisories as needed, and
11 adjusting efforts over time to protect public safety.
12 Q. What measures are in place to manage mercury
13 under the CWA Section 401 certifications?
14 A. At the time the Idaho and Oregon DEQs issued
15 the Section 401 certifications, Idaho Power was conducting
16 a 10-year study of methylmercury in partnership with the
17 U. S . Geological Survey. The results from this ongoing study
18 informed the development of a methylmercury mitigation
19 plan, which was a prerequisite for the DEQs to issue the
20 final certifications . Ongoing mercury management focuses on
21 minimizing the conversion of elemental mercury to
22 biologically toxic methylmercury in the reservoirs through
23 continued study and implementation of mitigation measures .
24 Q. Can you provide an overview of the primary
25 costs associated with obtaining and maintaining the CWA
DUMAS, DI 11
Idaho Power Company

1 Section 401 certifications included in the Company' s
2 request?
3 A. Yes . Most expenses associated with meeting the
4 CWA Section 401 certification requirements relate to
5 projects and studies required under the TMCP and its
6 associated programs . These include water temperature and
7 mercury studies, development and implementation of the
8 Snake River Stewardship Program, and project-specific
9 restoration and mitigation work such as the Bayha Island
10 Project and the Grand View Project. Please see Exhibit 1
11 for additional information regarding the costs associated
12 with meeting the CWA Section 401 certification
13 requirements .
14 Endangered Species Act ("ESA") Consultation
15 Q. Can you summarize the requirements associated
16 with the Section 7 Consultation under the Endangered
17 Species Act?
18 A. Section 7 of the ESA requires FERC to
19 consult with the United States Fish and Wildlife Service
20 ("USFWS") and the National Marine Fisheries Service
21 ("NMFS") , collectively referred to as "the Wildlife
22 Agencies, " to ensure that a given action, in this case
23 relicensing the HCC, will not jeopardize listed species or
24 adversely modify critical habitat.
25
DUMAS, DI 12
Idaho Power Company

1 If adverse effects are likely, formal consultation
2 is required, which involves the preparation of a biological
3 assessment detailing potential impacts and proposed
4 mitigation measures . The Wildlife Agencies then review the
5 assessment and issue a biological opinion evaluating
6 effects on listed species and critical habitat.
7 Q. Can you provide an overview of Idaho Power' s
8 efforts related to the ESA consultation?
9 A. Yes . In 2007, as part of FERC' s NEPA review,
10 FERC requested formal consultation under Section 7 of the
11 ESA to assess the effects of the HCC on threatened species .
12 The Wildlife Agencies noted at that time that measures to
13 address water quality impacts were not yet fully defined,
14 as the CWA Section 401 certification process was still
15 ongoing, and recommended delaying formal ESA consultation
16 until the certifications were complete . During that period,
17 Idaho Power engaged with the Wildlife Agencies as FERC' s
18 non-federal designated representative for informal
19 consultation, addressing issues raised by both the USFWS
20 and NMFS .
21 After receiving the CWA Section 401 certifications,
22 Idaho Power coordinated with the Wildlife Agencies to
23 prepare draft biological assessments, filing the first
24 assessments with FERC in 2020 and submitting updated
25 versions in 2025 .
DUMAS, DI 13
Idaho Power Company

1 Q. Can you summarize the key issues raised by the
2 Wildlife Agencies during the ESA consultation?
3 A. Yes . The issues identified by the Wildlife
4 Agencies focused primarily on the protection and
5 conservation of bull trout, fall Chinook salmon, and
6 steelhead. The USFWS, which has jurisdiction over bull
7 trout, emphasized the need to better understand how dam
8 operations affect their movement and habitat within HCC
9 tributaries and the mainstem Snake River. NMFS, which
10 oversees Chinook salmon, focused on water quality
11 conditions, habitat availability, and the risks of
12 entrapment and stranding of juveniles .
13 In addition, both agencies raised concerns about
14 potential harmful effects from methylmercury in fish within
15 the HCC, noting elevated levels in certain species and the
16 possible implications for ESA-listed species .
17 Q. What monitoring and research has Idaho Power
18 conducted to address these issues?
19 A. Idaho Power has implemented a comprehensive
20 monitoring and research strategy to assess the effects of
21 HCC operations on listed species and their habitats . This
22 strategy includes programs for monitoring sediment and fall
23 Chinook spawning gravel as well as fish populations such as
24 bull trout.
DUMAS, DI 14
Idaho Power Company

1 Q. Can you describe the program for monitoring
2 sediment and fall Chinook spawning gravel?
3 A. The program for monitoring sediment and fall
4 Chinook spawning gravel evaluates how sediment moves
5 through the 60-mile stretch of the Snake River from Hells
6 Canyon Dam to the Salmon River confluence, and how those
7 changes affect spawning gravels and river habitat. Data
8 collection involves surveying the river channel, mapping
9 sandbars, photographing spawning gravels, measuring
10 tributary sediment inputs, and sampling gravel and sand.
11 Analysis focuses on changes in sediment volumes and
12 particle sizes relative to river hydraulics, estimating
13 sediment loads from tributaries, and comparing modern
14 conditions to historical sediment levels .
15 Q. Can you provide additional information on the
16 monitoring of fall Chinook salmon populations?
17 A. Yes . Idaho Power conducts long-term monitoring
18 of fall Chinook salmon spawning success below Hells Canyon
19 Dam to the Salmon River by identifying the location and
20 number of redds (spawning nests) each year. This data
21 provides an important measure of the population' s health.
22 In addition, the Company monitors the entrapment of
23 juvenile fall Chinook salmon in off-channel waters during
24 the spring to ensure that dam operations are not adversely
25 affecting the population.
DUMAS, DI 15
Idaho Power Company

1 Q. Can you provide additional information on the
2 monitoring of bull trout populations?
3 A. Yes . Idaho Power conducts long-term bull trout
4 monitoring through its Fish Population Monitoring program.
5 This program evaluates bull trout distribution, habitat
6 use, movement, and survival in Hells Canyon and Oxbow
7 reservoirs, in the Snake River downstream of Hells Canyon
8 Dam, and in tributaries that support or may support bull
9 trout . The monitoring also provides information needed to
10 plan and refine measures such as bull trout passage and
11 habitat protection within the HCC.
12 Q. Can you provide an overview of the primary
13 costs associated with these programs that are included in
14 the Company' s request?
15 A. The primary costs associated with these
16 programs include ongoing monitoring, data collection,
17 habitat assessments, and reporting required for ESA
18 compliance. Study of the HCC' s potential effect on, and
19 population viability of, ESA-listed fall Chinook salmon and
20 bull trout will continue as part of relicensing costs until
21 biological opinions are released by the Wildlife Agencies .
22 NEPA Analysis
23 Q. Can you summarize the requirements associated
24 with the NEPA Analysis?
DUMAS, DI 16
Idaho Power Company

1 A. Yes . Under NEPA, FERC must evaluate the
2 environmental effects of issuing a new long-term license
3 for the HCC. This evaluation includes preparing an EIS,
4 which describes existing environmental conditions, analyzes
5 potential impacts from project operations, considers
6 reasonable alternatives, and identifies mitigation
7 measures .
8 Q. Has FERC issued an EIS with regard to Idaho
9 Power' s 2003 HCC license application?
10 A. Yes . In 2006, FERC issued a draft EIS, which
11 reviewed and analyzed Idaho Power' s proposed operations and
12 mitigation measures together with comments, terms,
13 prescriptions, and recommendations . Various parties filed
14 comments on the draft EIS and in 2007, FERC issued a final
15 EIS .
16 Q. Can you provide an update on the status of the
17 NEPA Analysis?
18 A. In July 2020, Idaho Power submitted to FERC a
19 supplement to the final license application that
20 incorporated the settlement agreement reached between Idaho
21 and Oregon on the CWA Section 401 certifications, updated
22 the 2003 license application, and provided feedback on
23 proposed modifications of the 2007 final EIS . The filing
24 also contained an updated cost analysis of the HCC and a
DUMAS, DI 17
Idaho Power Company

1 request for FERC to issue a 50-year license and initiate a
2 supplemental NEPA process .
3 In June 2022, FERC issued a Notice of Intent to
4 prepare a supplemental EIS in accordance with NEPA. The
5 supplemental EIS will address new and revised measures
6 resulting from the CWA Section 401 certification
7 settlement, including the specific conditions contained in
8 the Oregon and Idaho water quality certificates, as well as
9 information provided in the biological assessments through
10 the ESA consultation . As of December 2025, FERC has not yet
11 issued a supplemental EIS .
12 Q. What programs has Idaho Power implemented to
13 support FERC' s environmental review under NEPA?
14 A. Idaho Power has implemented several targeted
15 conservation and research programs to support FERC' s NEPA
16 environmental review. A major effort is the Cultural
17 Resources Program, which identifies, documents, and
18 protects archaeological sites, historic structures, and
19 culturally significant areas along the Snake River. This
20 includes sites associated with Native American use,
21 homesteading, mining, and other historical activities . The
22 Company also collaborates with the Nez Perce Tribe and
23 other tribes and stakeholders to identify locations of
24 cultural and religious significance.
25
DUMAS, DI 18
Idaho Power Company

1 Through initial relicensing surveys and ongoing
2 monitoring, Idaho Power tracks the condition of nearly
3 1, 000 potentially significant cultural sites that could be
4 affected by HCC operations . This monitoring includes site
5 inspections, condition assessments, and coordination with
6 tribes and regulatory agencies . The data collected through
7 these efforts supports FERC' s NEPA review by ensuring that
8 project-related effects on cultural and historic resources
9 are identified, evaluated, and appropriately considered in
10 relicensing decisions .
11 Other Relicensing Activities
12 Q. What is Section 4 (e) of the Federal Power Act
13 ( F PA") ?
14 A. Section 4 (e) of the Federal Power Act gives
15 federal land-managing agencies, such as the United States
16 Forest Service ("Forest Service") , the authority to
17 prescribe mandatory license conditions for hydropower
18 projects located on federal reservations, including
19 National Forest System lands . FERC is required to include
20 any Section 4 (e) conditions in the license it issues .
21 Q. Does FPA Section 4 (e) apply to the HCC?
22 A. Yes . Portions of the Hells Canyon Complex are
23 located on National Forest System lands . As a result, the
24 Forest Service has the authority to issue mandatory Section
DUMAS, DI 19
Idaho Power Company

1 4 (e) conditions that must be incorporated into any new FERC
2 license for the project.
3 Q. Has Idaho Power worked with the Forest Service
4 regarding FPA Section 4 (e) conditions?
5 A. Yes . In October 2024, Idaho Power filed a
6 settlement with FERC on behalf of itself and the Forest
7 Service regarding Section 4 (e) conditions for the HCC. The
8 settlement establishes mutually agreed-upon requirements
9 for continued operation on federal lands . It specifically
10 addresses measures such as sand augmentation within the
11 Hells Canyon National Recreation Area and administrative
12 measures related to recreation. Idaho Power' s sediment
13 monitoring program was instrumental in these negotiations,
14 providing data that helped limit the scope and cost of
15 additional sand augmentation measures .
16 III . CONCLUSION
17 Q. Can you summarize the current status of
18 relicensing the Hells Canyon Complex?
19 A. Idaho Power filed its application for a new
20 long-term license for the Hells Canyon Complex in July
21 2003 . FERC issued the final EIS in August 2007 . In December
22 2019, Idaho Power filed an Offer of Settlement reflecting
23 agreements with Oregon and Idaho regarding fish passage
24 measures and other water quality protections, which was
25 executed in April 2019 . Both states subsequently issued
DUMAS, DI 20
Idaho Power Company

1 final CWA Section 401 water quality certifications in May
2 2019 .
3 Since that time, Idaho Power has supplemented the
4 license application with updated information on
5 environmental resources, revised fish-related protection
6 measures, and draft biological assessments for ESA-listed
7 species . In June 2022, FERC issued a Notice of Intent to
8 prepare a draft and final supplemental EIS to evaluate
9 these updates . Procedural schedules for the supplemental
10 EIS have been revised multiple times, most recently to
11 allow sufficient time to analyze Idaho Power' s October 2024
12 settlement with the Forest Service under FPA Section 4 (e)
13 and the revised biological assessments, which were filed in
14 June 2025 . As of December 2025, FERC has not yet issued the
15 draft supplemental EIS, and the relicensing process is
16 ongoing, pending review of these materials .
17 Q. Please summarize your testimony.
18 A. My testimony provides a history of Idaho
19 Power' s relicensing efforts for the Hells Canyon Complex
20 and supports the prudence of costs incurred from 2016
21 through 2025 . These efforts have included securing CWA
22 Section 401 water quality certifications, supporting ESA
23 consultation for listed species, and providing data for
24 FERC' s NEPA Analysis . In addition, Idaho Power reached a
25 2024 settlement with the Forest Service under FPA Section
DUMAS, DI 21
Idaho Power Company

1 4 (e) to address mandatory conditions on federal lands .
2 Collectively, these actions ensure that the necessary
3 environmental, operational, and mitigation measures are in
4 place to support the eventual issuance of a new long-term
5 license for the project.
6 Q. Does this conclude your testimony?
7 A. Yes, it does .
8
DUMAS, DI 22
Idaho Power Company

1 DECLARATION OF BRETT DUMAS
2 I, Brett Dumas, declare under penalty of perjury
3 under the laws of the state of Idaho:
4 1 . My name is Brett Dumas . I am employed by
5 Idaho Power Company as the Environmental Affairs Director
6 in the Power Supply Department.
7 2 . On behalf of Idaho Power, I present this
8 pre-filed direct testimony and Exhibit No. 1 in this
9 matter.
10 3 . To the best of my knowledge, my pre-filed
11 direct testimony and exhibits are true and accurate .
12 I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
14 it is made for use as evidence before the Idaho Public
15 Utilities Commission and is subject to penalty for perjury.
16 SIGNED this 24th day of December 2025, at Boise,
17 Idaho .
18
19 Signed:
DUMAS, DI 23
Idaho Power Company

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-25-35
IDAHO POWER COMPANY
DUMAS, DI
TESTIMONY
EXHIBIT NO. 1

HCC RELICENSING EXPENDITURES
BY BUDGET ID AND WORK ORDER(INCLUDING AFUDC)
JANUARY 1,2016-September 30,2025
Year
Outstanding Regulatory
Note Cost Center Description Process Budget ID Description WO Project ID Description 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025(9/30) WO Status
601 Power Supply All HCC Relicensing B032000-HC Relicensing Legal 27134878-HELLS CANYON RELICENSING OUTSIDE LEGAL FEES 3,129,539 3,426,260 3,349,190 3,411,479 3,184,325 3,197,078 3,344,364 3,674,719 3,830,832 2,978,350 Active
Administration
601 Power Supply 27238462-LEGAL DEPT.LABOR FOR RELICENSING: HELLS
All HCC Relicensing B032000-HC Relicensing Legal 675,101 724,420 779,443 705,155 609,045 586,498 617,533 684,174 695,032 540,636 Active
Administration CANYON COMPLEX
B00400502-Rel-HCC Baker County Agreement: 27185311-RELICENSING:BAKER COUNTY SETTLEMENT
1 604 Oxbow PP Maint Crews All HCC Relicensing 199,426 (497,654) 12,313 - - - - - - Closed
Western Region Sponsored AGRMT-LAW ENFORCE,ROAD
2 661 River Engineering N/A. Removed from CHQB100109-HC Hydraulic Model Development, 27360909-HC HYDRAULIC MODEL DEVELOPMENT, (225,368) - - Closed
Relicensing. Maintenance and Operation MAINTENANCE AND OPERATION
1 661 River Engineering All HCC Relicensing CHQB100111-HC Relocate Compliance Gage 27470807-HC COMPLIANCE GAGE PERMITTING AND 1,777 1,266 (181) Complete
CONSTRUCTION
ESA Consultation primarily,
1 661 River Engineering but also some aspects CHQB110140-HC Evaluation of Mainstem Sediment 27360905-HC EVALUATION OF MAINSTEM SEDIMENT 342,360 (190,710) (3,681) Closed
related to all HCC Transport TRANSPORT
relicensing and NEPA
ESA Consultation primarily,
1 661 River Engineering but also some aspects CHQB110141-HC Prepare Annual Sediment Report 27360906-HC PREPARE ANNUAL SEDIMENT REPORT 43,164 (54,652) Closed
related to all HCC
relicensing and NEPA
ESA Consultation primarily,
1 661 River Engineering but also some aspects CHQB110143-Below HCD Tributary Sediment Supply 27360908-BELOW HCD TRIBUTARY SEDIMENT SUPPLY 160,368 (111,251) Closed
related to all HCC
relicensing and NEPA
1 661 River Engineering CWA§401 Certification CHQB130016-HCC Watershed Development Support 27388669-HCC WATERSHED DEVELOPMENT SUPPORT 262,247 92,601 (114,514) Complete
1 661 River Engineering CWA§401 Certification CHQB130016-HCC Watershed Development Support 27471740-SNAKE RIVER STEWARDSHIP PROJECT 2 - 114,612 (3,164) - - - - - - Complete
ESA Consultation primarily,
661 River Engineering but also some aspects CHQB170026-HC Sediment Programs 27474654-HC SEDIMENT PROGRAMS - 552,409 635,639 645,318 866,286 901,286 735,363 877,825 894,438 628,601 Active
related to all HCC
relicensing and NEPA
670 Environmental Admin All HCC Relicensing B0040043S-Annual Oregon Water Resources 27161764-REL-HCC OREGON REAUTHORIZATION 346,576 380,080 409,785 442,191 468,783 SOS,909 644,437 693,351 888,005 718,207 Active
Department Fees For The HCC
670 Environmental Admin All HCC Relicensing CHQB200001-HCC Relicensing 27530938-HCC RELICENSING: APPLICATION REVIEW - - - 46,795 49,743 72,599 78,486 230,644 95,058 137,792 Active
1 671 Environmental-Terrestrial All HCC Relicensing B00600391-HCC Relicensing Baker County 27219994-TERR-HCC BAKER COUNTY WEED PAYMENTS 10,545 (24,935) - - - - - - - Closed
Settlement-weeds (RELICENSING)
671 Environmental-Terrestrial NEPA BLPR100100-HCC Relicensing Eagle Monitoring&EIS 27361422-TERR:HCC RELIC WILDLIFE 12,389 12,516 21,226 27,302 15,147 10,410 11,143 11,986 12,589 10,015 Active
Preparation
671 Environmental-Terrestrial NEPA BLPR100104-HCC Relicensing Cultural Resource 27361424-TERR:HCC RELIC CULTURAL 6,769 75,228 65,280 66,225 59,155 52,537 98,219 123,343 108,214 86,517 Active
Management
671 Environmental-Terrestrial All HCC Relicensing BLPR100117-HCC Relicensing Weed Control 27361426-TERR:HCC RELIC COUNTY WEEDS 9,834 1 12,634 15,052 19,740 13,130 16,036 1 19,738 20,440 22,818 17,523 Active
1 672 Environmental-Recreation All HCC Relicensing B00400465-HCC Relicensing:Recreation Sponsored 27161796-REL-REC HCC RELICENSING PROCESS 46,792 47,890 52,586 57,275 58,728 (506,733) (4,524) - Closed
1 672 Environmental-Recreation All HCC Relicensing B00400466-HCC Baker County Settlement: 27234342-REC-BAKER COUNTY SETTLEMENT AGREEMENT 141,883 (507,057) 0 - - - Closed
Recreation Sponsored LITTER&SAN PLAN
1 672 Environmental-Recreation All HCC Relicensing B00400466-HCC Baker County Settlement: 27278220-REC-BAKER COUNTY SETTLEMENT AGREEMENT 80,916 (125,076) (409) - - Closed
Recreation Sponsored
673 Environmental-Water B01100174-Hells Canyon Relicensing 27330380-HCC RELICENSING: HART AND 401 FEES-STATE
1 Quality CWA§401 Certification Reauthorization&Relicensing From State of Oregon OF OREGON 14S,561 190,449 112,037 76,710 31,271 (419,875) Closed
(Hart and 401)
673 Environmental-Water CHQB110104-WQ Hells Canyon 401 Application 27359878-WQ HCC401 APPLICATION,REVISION,
1 CWA§401 Certification 293,748 248,833 312,208 211,996 209,672 (1,129,350) - - - Closed
Quality Revision,Communication,Consultation COMMUNICATION,CONSULTATION
673 Environmental-Water CWA§401 Certification CHQB110121-HCC Relicensing Mercury Studies 27359880-WQ HCC401 CERTIFICATION OPS AND ENG 960,039 1,079,543 1,170,662 1,592,709 1,377,486 2,004,409 2,126,098 2,230,802 1,657,550 896,383 Active
Quality TEMPERATURE STUDIES
1 673 Environmental-Water CWA§401 Certification CHQB110122-HCC Relicensing Water Quality 27359876-HCC RELICENSING WATER QUALITY MONITORING 279,626 323,582 308,445 352,532 378,703 (758,798) 1,671 (13,629) - Closed
Quality Monitoring
673 Environmental-Water CHQB130007-HCC Snake River Stewardship Program 27379855-HCC WATERSHED ENHANCEMENT PROGRAM
CWA§401 Certification 1,099,013 1,738,294 1,503,416 167,404 853,221 848,006 829,396 889,374 907,500 700,781 Active
Quality lDevelopment IDEVELOPMENT
it No.1
Case No.IPC-E-25-35
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Year
Outstanding Regulatory
Note Cost Center Description Process Budget ID Description WO Project ID Description 2016 2017 2018 2019 2020 2021 2022 2023 2024 2025(9/30) WO Status
1 673 Environmental-Water CWA§401 Certification CHQB160060-HCC Bayha Research Project 27438918-BAYHA ISLAND RESEARCH PROJECT 3,472,503 723,207 446,666 498,346 417,232 (1,480,494) (0) Closed
Quality
673 Environmental-Water CHQB160061-HCC Grand View Irrigation Upgrade 27438915-GRAND VIEW IRRIGATION UPGRADE RESEARCH
1 CWA§401 Certification 608,817 730,998 993,650 338,474 298,360 (826,776) - - - Closed
Quality Research Project PROJECT
673 Environmental-Water CHQB160062-HCC Powder River Tributary Research
1 CWA§401 Certification 27438920-TRIBUTARY ENHANCEMENT RESEARCH PROJECT 244,356 194,903 244,270 134,407 159,971 125,058 (334,916) (4,857) - Closed
Quality Project
673 Environmental-Water CHQB160064-HCC Daly Creek Riparian Enhancement 27455091-DALY CREEK RIPARIAN ENHANCEMENT RESEARCH
1 CWA§401 Certification 88,656 39,228 22,632 15,942 12,828 13,856 14,833 (72,791) 70 (1,003) Closed
Quality Project PROJECT
673 Environmental-Water CHQB170054-HCC Weiser River Tributary Research 27481527-WEISER RIVER TRIBUTARY ENHANCEMENT
1 CWA§401 Certification 53,995 193,747 145,254 133,932 40,811 (101,958) (2,333) Closed
Quality Project RESEARCH PROJECT
673 Environmental-Water All HCC Relicensing CHQB110121-HCC Mercury Numeric Model 27534334-HCC MERCURY NUMERIC MODEL DEVELOPMENT - - 99,821 187,587 282,341 445,881 379,960 108,528 83,310 Active
Quality Development
673 Environmental-Water All HCC Relicensing CHQB200003-Snake River Stewardship Program 27532310-REPORTING MODEL FOR SNAKE RIVER 1,480,435 993,440 765,291 544,544 384,327 318,352 272,882 Active
Quality Database and Reporting Tool STEWARDSHIP(SRSP)
674 Environmental-Fisheries ESA Consultation BLPR110118-Fall Chinook Salmon Population 27360126-FALL CHINOOK PROGRAM-FC VIABILITY (6,514) - Closed
Viability Analysis ANALYSIS-HCC RELICENSE
674 Environmental-Fisheries ESA Consultation BLPR110118-Fall Chinook Salmon Population 27465187-FALL CHINOOK SALMON VIABILITY-PART 2 25,724 111,603 Closed
Viability Analysis
674 Environmental-Fisheries ESA Consultation BLPR140001-Bull Trout Program-HCC Relicensing 27359954-BULL TROUT PROGRAM-ADMINISTRATION-HCC 569,664 642,596 728,085 800,965 825,509 912,436 930,675 1,171,823 1,126,612 908,887 Active
RELICENSING
674 Environmental-Fisheries ESA Consultation BLPR140002-Fall Chinook Program-HCC Relicensing 27360122-FALL CHINOOK PROGRAM-REDD SURVEYS 294,868 320,021 317,364 364,719 365,635 439,734 499,033 575,112 560,941 353,352 Active
674 Environmental-Fisheries ESA Consultation BLPR140002-Fall Chinook Program-HCC Relicensing 27360123-FALL CHINOOK PROGRAM-ENTRAPMENT 84,204 54,453 128,418 125,472 145,213 189,587 198,366 195,132 189,363 196,573 Active
MONITORING
1 674 Environmental-Fisheries ESA Consultation BLPR140002-Fall Chinook Program-HCC Relicensing 27360125-PACIFIC LAMPREY STATUS MONITORING -HCC (1,143) - - - - - - - - Closed
RELICENSE
674 Environmental-Fisheries NEPA BLPR140003-Pacific Lamprey-HCC Relicensing 27590758-PACIFIC LAMPREY-2021 AND 202 - - - - - 14,578 1,240 3,856 19,799 2,186 Active
1 674 Environmental-Fisheries NEPA BLPR170008-White Sturgeon Program-HCC 27469334-WHITE STURGEON PROGRAM-HCC RELICENSING 393,710 251,254 288,357 522,340 555,423 484,775 (475,468) (10,371) - Closed
Relicensing
674 Environmental-Fisheries ESA Consultation CHQB130005-HCC Relicensing-Anadromous 27368568-HELLS CANYON NOAA BIOLOGICAL ASSESSMENT 22,332 61,497 32,872 87,188 324,496 183,552 111,726 219,282 153,467 129,712 Active
Biological Assessment
1 674 Environmental-Fisheries NEPA CHQB130012-Tributary Habitat Enhancement Plan- 27384922-THEP-WATER EFFICIENCY PILOT PROGRAM 21,123 (27,314) - - - - - - - Closed
Pilot Project
674 Environmental-Fisheries CWA§401 Certification HCPR130004-HCD Surface Collector 27462725-HCD SURFACE COLLECTOR FEASIBILITY STUDY 543,158 - - Closed
3 699 Power Supply Accounting All HCC Relicensing BO_REL_ROLLUP-Relicensing Rollup RELICBLP-ROLLUP RELIC COST BROWNLEE 6,874,565 8,442,290 8,355,763 8,967,895 9,438,677 13,372,637 12,183,209 12,659,851 13,280,109 10,564,760 Active
Charge
3 699 Power Supply Accounting All HCC Relicensing BO_REL_ROLLUP-Relicensing Rollup RELICHCP-ROLLUP RELIC COST HELLS CANYON 4,684,257 5,733,444 5,695,843 6,106,826 6,427,412 9,067,565 8,280,867 8,609,700 9,031,711 7,185,021 Active
Charge
3 699 Power Supply Accounting All HCC Relicensing BO_REL_ROLLUP-Relicensing Rollup RELICOBP-ROLLUP RELIC COST OXBOW 2,176,098 2,677,155 2,650,672 2,841,135 2,990,284 4,261,241 3,869,624 4,017,922 4,214,659 3,352,899 Active
Charge
4 699 Power Supply Accounting All HCC Relicensing BO_REL_ROLLUP-Relicensing Rollup RELICRESV-Relicensing Rollup - (8,075,157) (693,517) (692,762) (729,130) (787,583) (843,085) (906,883) (952,491) (757,738) Active
Charge
28,118,682 19,443,455 28,030,153 29,659,287 30,721,566 32,438,620 33,826,497 36,642,760 37,163,155 29,005,645
Notes:
1-Credits for AFUDC reclassifications to the HCC roll-up work orders are included in this total. The offsetting debits were reclassified to the three roll-up projects. These entries net to zero.
2-Determined not to be a relicensing expense. Removed from relicensing balance.
3-Primarily AFUDC charges on the accumulated relicensing balance that has been reclassified to the Hells Canyon roll-up work orders.
4-2017 includes the expenditures that were reclassified to either a regulatory asset or O&M per Order No.34031.2018 is made up of primarily AFUDC credits on work orders that have a credit balance.
Exhibit No.1
Case No.IPC-E-25-35
B.Dumas,IPC
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