20160906AVU to Staff 123.doc

AVISTA CORPORATION
RESPONSE TO REQUEST FOR INFORMATION

JURISDICTION: IDAHO DATE PREPARED: 08/31/2016
CASE NO: AVU-E-16-03 WITNESS: Scott Kinney
REQUESTER: IPUC RESPONDER: Michele Drake
TYPE: Production Request DEPARTMENT: Environmental
REQUEST NO.: Staff - 123 TELEPHONE: [phone]

REQUEST:

Please provide copies of all mitigation agreements and a list of all associated pre-determined spending commitments for the Spokane River Hydroelectric and Post Falls FERC Dam Safety requirements.

RESPONSE:

The Post Falls Hydroelectric Development is one of six Avista-owned hydroelectric developments on the Spokane River. Post Falls, Upper Falls, Monroe Street, Long Lake, and Nine Mile hydroelectric developments are regulated by the Federal Energy Regulatory Commission under a collective license for the “Spokane River Project.” Little Falls Hydroelectric Development, which is also located on the Spokane River, is regulated by the Washington State Department of Ecology’s Dam Safety Division.

There are no mitigation agreements or pre-determined spending commitments for dam safety. There are some set requirements, such as Annual FERC Dam Safety Inspections, Emergency Action Plans, and periodic Independent Consultant’s (Part 12) Inspections, required for various projects depending upon hazard classification and regulatory oversight. Avista must complete these requirements in a timely manner, but there is no pre-determined spending commitment associated with these requirements.

Expenditures related to dam safety are not separately tracked in a single account or project. This is because dam safety-related work originates in a variety of settings, including:

Regulatory requirements (both state and federal)
Independent Consultant’s recommendations (that are filed with FERC)
FERC or Ecology inspector’s recommendations
Scheduled maintenance/repair
Coincident with structural modifications serving to mitigate for an environmental condition (such as Cabinet Gorge spillway bay modifications for total dissolved gas)
Coincident with capital projects to upgrade, replace, or expand equipment, structures, or facilities
Correspondence with FERC or Ecology dam safety staff

Once identified, dam safety tasks are assigned to the appropriate staff member for completion. Those charged with completing dam safety related work include engineers, crews, environmental, administrative and operations staff. Dam safety work is an integral part of various operations, maintenance and capital budget accounts within the Environmental and Generation, Production and Substation Support departments.

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