HomeMy WebLinkAbout20170306IPC to Staff 1-14.pdf3Iffi*.!li:iii: iVIt)An IDACORP Company
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LISA D. NORDSTROTT'I
Lead Counsel
I nordstrom@idahopower.com
March 6,2017
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re Case No. IPC-E-16-32
Hells Canyon Complex Relicensing Costs Through 2015 - ldaho Power
Company's Response to the First Production Request of the Commission
Staff
Dear Ms. Hanian:
Enclosed forfiling in the above matter please find an originaland three (3) copies of
ldaho Power Company's Response to the First Production Request of the Commission
Staff.
Also enclosed are four (4) copies each of non-confidential and confidential disks
containing information responsive to Staffs production requests. Please handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
Lisa D. Nordstrom
LDN:csb
Enclosures
1221 W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
:: rQC, lr.1irti I 1:,.-rli-r11./,r :
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
1221West ldaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5825
Facsimile: (208) 388-6936
I no rd strom @ id a hopowe r. com
ftEfiTIVED
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Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF HELLS CANYON
RELICENSING COSTS THROUGH 2015
AS PRUDENTLY INCURRED
GASE NO. !PC-E-16-32
IDAHO POWER COMPANY'S
RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Compshy'), and in
response to the First Production Request of the Commission Staff to ldaho Power dated
February 13,2017 , herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
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REQUEST NO. {: Please provide the complete Transaction Detail File of all
expenditures and entries charged to the Hell's Canyon Complex relicensing CWIP
account.
RESPONSE TO REQUEST NO. 1: Please see the confidential Excel file
provided on the confidential CD for the transaction detail file of expenditures and entries
charged to the Hells Canyon Complex ('HCC") relicensing construction work in progress
("CW|P') account. The "Master File" tab includes the transaction file used for the
independent transaction review. The "DCE Descriptions" tab includes a detailed
description of ldaho Power's Detailed Cost Elements ("DCE'). The "Relicensing
Category Descr" tab includes a list of the HCC relicensing related work orders, their
description, and the category under which they are classified. The "DCEs" tab is a high
level summary of the Company's DCEs and is used as a source to populate data in the
Master File.
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Ken Petersen, Vice President,
Controller, and Chief Accounting Officer, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
REQUEST NO. 2: Please provide a list of all Detailed Work Orders for the Hell's
Canyon Complex (HCC) relicensing. Please include a brief description of each work
order.
RESPONSE TO REQUEST NO. 2: Please see the confidentia! attachment
provided with the Company's response to the ldaho Public Utilities Commission Staffs
("Staff') Request No. 1 for a list of all detailed work orders associated with HCC
relicensing costs and a description of each work order.
The response to this Request is sponsored by Ken Petersen, Vice President,
Controller, and Chief Accounting Officer, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
REQUEST NO. 3: Please provide all Variance Reports for the Detailed Work
Orders for the HCC relicensing.
RESPONSE TO REQUEST NO. 3: ldaho Power's capital budgets are
developed and approved by leadership and the Company's Board of Directors at an
aggregated level rather than at the individual work order level. Multiple detail work
orders are aggregated to the budget level. Therefore, budget variance analysis is not
available at the detail work order level.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
REQUEST NO. 4: Please provide a listing of all Detailed Cost Elements (DCE's)
used by ldaho Power with definitions of each DCE.
RESPONSE TO REQUEST NO. 4: Please see the confidential attachment
provided with the Company's response to Staffs Request No. 1 lor a list of all DCEs,
and their definitions, used by ldaho Power.
The response to this Request is sponsored by Ken Petersen, Vice President,
Gontroller, and Chief Accounting Officer, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
REQUEST NO. 5: Please provide a brief description of how work order numbers
and DCE's are developed and assigned.
RESPONSE TO REQUEST NO. 5: A relicensi ng work order is typically written
for managing and tracking expenditures associated with a project. A project manager
has the discretion to create a new work order when he/she determines it is preferable to
collect costs for a discrete Hells Canyon relicensing activity or body of work. This is
often done to support project management and reporting activities. Work orders are
created in ldaho Power's Asset Suite work management system. Each work order is
assigned a unique number at the time it is developed. All relicensing expenditures must
be charged to a work order. Every work order requires a Budget lD. ldaho Power's
annual budgets are approved by the Board of Directors. A work order cannot be
approved without a valid Budget lD, and no expenditures can be charged to the work
order until it has been approved. Multiple work orders can be assigned to a single
Budget lD. A work order must be approved by an individual with the appropriate level of
authority, as noted on the disbursement authority template in the confidential
attachment provided with the Company's response to Staff's Request No. 7.
The list of DCEs was developed by ldaho Power. The DCE is a three-digit code
that identifies a type of expenditure and is primarily used for budgeting, cost tracking,
and reporting purposes. Each detail DCE is assigned to one of the following broad
categories: labor, materials, purchased services, accounting entries, and other
expenses. A new DCE may be requested based on the Company's reporting needs.
Any request for a new DCE must be approved by the Finance Department.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.6
REQUEST NO. 6: Please provide a listing describing all of the Cost Centers
used by ldaho Power. Please include with your list the ldaho Power personnel
responsible for each cost center.
RESPONSE TO REQUEST NO. 6: Please see the Excel file provided on the
non-confidential CD for a list of the Cost Centers used by ldaho Power and the
associated personnel responsible for each cost center.
The response to this Request is sponsored by Aubrae Sloan, Accounting
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
REQUEST NO. 7: Please provide the calculation of each AFUDC entry charged
to the Hell's Canyon Relicensing CWIP account.
RESPONSE TO REQUEST NO. 7: The Hells Canyon relicensing data file
(provided as a confidential attachment to the Company's response to Staffs Request
No. 1) contains 18,910 rows of Allowance for Funds Used During Construction
("AFUDC") transactions. Each of the transactions is calculated within the Company's
software and is not available in Excel with formulas intact, requiring the Company to
manually recreate the transactions in Excel. !n place of the entire data set, ldaho Power
has provided a demonstration of the recalculation of AFUDC in the independent review
(please see the confidential attachment provided with the Company's response to
Staffs Request No. 9, "Testing File, E.11 - AFUDC Testing," tab "AFUDC Detail Test").
Provided on the confidential CD in response is a confidential example of a recalculation
of an AFUDC transaction from the Hells Canyon relicensing data file. This transaction
was tested in the independent review (referenced above) as Year 2011, Sample #3.
ldaho Power can provide similar calculation detail and information for any selections
made by Staff.
AFUDC is applied to individua! work orders on a monthly basis via system
calculation within ldaho Power's accounting software, PeopleSoft. This system
calculation is accomplished by applying the applicable allowance for other funds ('AO')
and allowance for borrowed funds (.A8") rates for the month to the average work order
balance provided by the cumulative beginning of month balance and the end of month
balance for the work order. The system calculation of AFUDC allows for partial month
proration for the opening month of a work order and the closing month of a work order.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
Monthly AO and AB rates are calculated and reviewed for accuracy (Sarbanes-
Oxley Act ("SOX") control Fixed Assets Month-End Processing (.FAME") C04 as
described in the attachment provided with the Company's response to Staffs Request
No. 10. Once rates are reviewed, the rates are input into PeopleSoft. A separate team
member then queries PeopleSoft for the AO and AB rates that were input and verifies
that the rates were input into the system correctly (SOX control FAME C08 as described
in the attachment provided with the Company's response to Staff's Request No. 10).
The confidential CD will be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Sonse Sutezzo, Operations Audit
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
REQUEST NO. 8: Please provide all exhibits and tables embedded in testimony
in Excel format with all formulas intact.
RESPONSE TO REQUEST NO. 8: The enclosed non-confidential CD contains
all exhibits and tables embedded in testimony in executable format. Please note, the
tables on page 15 of the Direct Testimony of Mr. Petersen are also presented in Exhibit
No. 5 and therefore contained in the Exhibit No. 5 Excelfile.
The response to this Request is sponsored by Ken Petersen, Vice President,
Controller, and Chief Accounting Officer, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1O
REQUEST NO. 9: Please provide all supporting documents and workpapers for
the "independent review" performed by ldaho Power of the HCC relicensing expenses.
RESPONSE TO REQUEST NO. 9: Please see the confidential files provided on
the confidential CD for the supporting documents and workpapers for the independent
review. Due to the volume of files being provided in response to this Request, the
individual file names and the actual documents have not been labeled with the word
"confidential." However, the main file folder and subfolders have been labeled
confidential; all files provided in response to this Request should be treated as
confidential and handled accordingly. The confidential CD will be provided to those
parties that have executed the Protective Agreement in this matter.
The response to this Request is sponsored by Sonse Sutezzo, Operations Audit
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
REQUEST NO. {0: Please provide all lnternal Audit Reports and SOX 404
Reports pertaining to the HCC relicensing project.
RESPONSE TO REQUEST NO. 10: Per a discussion with Staff on February 14,
2017, a list of controls that would potentially impact HCC relicensing activities is
provided in the spreadsheet provided on the non-confidential CD; a sample of reports
can be selected for review on-site. At Staffs request, the Company will make the
selected sample of reports available at the Company's corporate headquarters. Please
contact Mark Annis at 388-5208 or Camilla McClusky at 388-5821 lo arrange a time to
review the selected material.
The response to this Request is sponsored by Sonse Sutezzo, Operations Audit
Manager, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 12
REQUEST NO. 11: Please provide access to all Board of Directors meeting
minutes, including handouts and presentations, related to HCC relicensing.
RESPONSE TO REQUEST NO. 11: Without waiving IDACORP, lnc.'s or ldaho
Power's ability to object to demands for access to its books and records under the ldaho
Business Corporation Act, responsive excerpts from ldaho Power's Board of Directors'
meetings from 2000-2017 are produced in the confidential PDF provided on the
confidential CD. The confidential CD will be provided to those parties that have
executed the Protective Agreement in this matter.
The response to this Request is sponsored by Pat Harrington, Corporate
Secretary, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
REQUEST NO. 12: Please provide the approval requirements for all
expenditures for the HCC relicensing, including dollar levels and the ldaho Power
personnelwith approva! authority at each expenditure level.
RESPONSE TO REQUEST NO. {2: Please see the confidential Excel file
provided on the confidential CD for a current list as of February 23,2017, for each ldaho
Power employee's dollar level of approva! authority for non-labor expenditures, based
upon the type of expenditure. This list includes approval levels for transactions,
including work orders, material purchases, payment authorizations for vendor invoices,
and Company purchasing cards. Approva! levels are determined based on each
employee's job type. Please note, if the "Employee Name" field is blank, the existing
position is currently not filled at the date of this report. Although an employee may
spend up to an authorized level, expenditures must be reviewed and approved. For
example, purchasing card expenditures are reviewed monthly and approved by the
employee's supervisor. Additionally, an informal work order review is performed by the
project manager at the end of each project to verify that expenditures appear to be
reasonable. As noted in the Company's response to Staffs Request No. 4, a formal
SOX review is required quarterly after the work order balance reaches $200,000. As
part of this SOX review, the work order planner must review all expenditures booked
during the quarter, document whether they were correct, and request a reclassification
of any expenditures that were not correct.
Employees allocate labor hours for each day during the bi-weekly pay period into
the Labor Entry and Reporting system in Asset Suite, by entering their time to work
orders. Timesheets are reviewed and approved by the employee's direct supervisor or
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 14
by an authorized individual the supervisor has designated in the event they are
unavailable.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
REQUEST NO. 13: Please provide a detailed description of all cost containment
measures, analysis, and studies for the HCC relicensing.
RESPONSE TO REQUEST NO. 13: ldaho Power's initial cost containment
measures for HCC relicensing studies included hiring of ldaho Power resource experts,
conducting baseline resource information studies, and consulting within collaborative
work groups.
ln the initial stages of relicensing, the Company realized that extensive resource
study efforts would be required. ln an effort to contro! costs through the expected
lengthy process of preparing these studies, ldaho Power undertook the development of
in-house resource experts to address study needs. Management recognized the long-
term value of having ldaho Power staff develop and conduct studies; develop
protection, mitigation, and enhancement ("PM&E") measures; and be responsible for
the compliance with new Federal Energy Regulatory Commission ("FERC") license
articles. This contained costs by retaining ldaho Power staff with the experience and
knowledge of resource issues, ensuring that operational impacts to natural resources
were not exaggerated, and resource conditions were accurately portrayed. As a result,
the EnvironmentalAffairs Department now employs the Northwest's regional experts on
terrestrial, water quality, recreation, and fisheries associated with the HCC.
Another cost containment measure performed at the outset of the relicensing
process was the development of studies that described baseline conditions (i.e.,
existing conditions) and HCC operational studies that described impacts to natural
resources due to proposed operations. The Company used FERC criteria for
appraising resource values to the public and used best professional judgment to
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
recognize the value of a proposed study to meet the requirements of preparing a license
application. Detailed resource studies were developed after reviewing existing literature
and consulting appropriate resource management agencies, and members of the
collaborative team work groups. The Company published developed study proposals
for comment in the "Formal Consultation Package for Relicensing" in January 1997.
This package is available on ldaho Power's website via the following Iink:
http://tropic:807/AboutUs/RatesRequlatory/Relicensins/hellscanyon/HCapp.cfm. The
development of these baseline studies served to contain costs by relying on existing
literature when possible and avoiding potential duplication of work, as well as
developing a solid baseline from which to evaluate study proposals.
Additionally, as discussed in the Direct Testimony of Chris Randolph beginning
on page 11, the collaborative process was designed to involve stakeholders and
increase the likelihood of consensus on relicensing issues and strike an appropriate
balance between project operations and the protection of resource values. Consensus
on resource studies was intended to avoid costly debate at FERC over which resource
studies were appropriate.
Lastly, in addition to the cost containment efforts detailed above, the Company
also implemented a thorough review process for expenditures related to HCC, which
are described in detail in the Company's response to Staffs Request No. 12.
The response to this Request is sponsored by Chris Randolph, Environmental
Affairs Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
REQUEST NO. 14:Please provide all the studies referred to in Company
Witness Randolph's testimony and Exhibit No. 2.
RESPONSE TO REQUEST NO. 14: Resource study result reports were
presented in the final License Application for the HCC in 2003. This package is
available on ldaho Power's website via the following link:
http://tropic:807/AboutUs/RatesRequlatorv/Relicensinq/hellscanvon/HCaop.cfm. Resource
study reports are found via the above link as follows:
Master List of Technical Appendices
Appendix No. Technical Appendix Title
No.
Sediment and
Geomorphology
CD
1of
2
3
E.1-1
E.1-2.....................
E.1-3.....................
E.1-4.....................
E.1-4 Chapter 1....
E.1-4 Chapter 2....
E.1-4 Chapter 3....
E.1-4 Chapter4....
E.14 Chapter 5....
E.1-4 Chapter 6....
E.1-4 Chapter 7....
Water Quality
Sediment Tnnsport, Supply, and Stability in the Hells Canyon Reach of the Snake River
Geomorphology of the Hells Canyon Reach of the Snake River
Topogmphic lntegntion for the Hells Canyon Sfudies
Project Hydrology and Hydraulic Models Applied to the Hells Canyon Reach of the Snake River
lntegration of Hydrologic lnformation and Models for Hells Canyon Complex Sfudrbs
Development of lnflow Hydrology for Hells Canyon Complex Sfudrbs
Hells Canyon Complex Operations Modeling
Hells Canyon Complex Reseruoir Water Quality Modeling
Hells Canyon MIKE 11 Hydrodynamic Model
Hells Canyon MIKE 11 Temperaturc and Total Drsso/ved Gas
Seven HD Models on the Snake River
Tibutary Pollutant Sources to the Hells Canyon Complex 1of
E.2.2-2.......... Pollutant Transpoft and Prccessing in the Hells Canyon Complex
E.2.2-1
3
E.2.2-3.
E.2.2-4.
Flows
E.2.3-1.
of3
Hydro Machine Oil Monitoing at Hells Canyon Complex Power Plants
Hells Canyon Complex Total Dissolved Gas Study
Oxbow Bypass Minimum Flow Evaluation
Aquatic
E.3.1-1..
E.3.1-2..
E.2.3-2.......... Hells Canyon lnstreamFlowAssessmenf
E.3.1-2 Chapter 1....
E.3.'l-2 Chapter 2....
E.3.'l-2 Chapter 3....
E.3.1-2 Chapter 4....
Anadromous Fish
of3
E.3.1-2 Chapter 5....
E.3.1-2 Chapter 6....
E.3.1-2 Chapter 7....
E.3.1-2 Chapter 8....
E.3.1-2 Chapter 9....
lntegration of Aquatic Sfudies in the Hells Canyon Relicensing
Feasibility of Reintrcduction of Anadromous Fish Above orWthin the Hells Canyon Complex
I ntrod uction and Overuiew
History of the Hells Canyon Complex
Habitat of the Snake River Plain
Existing Habitat Conditions of Tibutaies Formedy Used by
2
Existing Habitat Conditions of the Mainstem Snake River Formedy Used by Anadromous Fish
Histoical Abundance of Anadromous Fr.sh Upstrcam of the Hells Canyon Complex
Estimators of Potential Anadromous Fish Smolt Yield
Potential Smolt Yield of Anadrcmous Fish frcm Subbasins Above the Hells Canyon Complex
Conceptual Design of Passage Facilities for the Hells Canyon Complex
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
E.3.1-2 Chapter 10... Pathogen Assessment and Suitability of Sfocks for Reintroduction Above the Hells Canyon
Complex
E.3.1-2 Chapter 11... Evaluation of Reintrcduction Altematives
E.3.1-2 Appendices .. Annotated Bibliographies on the Chrcnology of Decline of Anadrcmous Fish in the Snake RiverBasin above the Hells Canyon Dam
Master List of Technical Appendices (continued)
Appendix No.
No.
Technical Appendix Title CD
Anadromous Fish (cont.) 2
of3E.3.1-3.......... Evaluation of Anadrcmous Fish Potential Wthin the Mainstem Snake River, Downstrcam of the
Hells Canyon Complex of Reseruoirs
E.3.1-3 Chapter 1..... The Timing and Distribution of Fall Chinook Salmon Spawning Downstrcam of the Hells Canyon
Complex
E.3.1-3 Chapter 2..... Physical Habitat and Water Quality Citeia for Chinook Salmon Associafed with the Hells
Canyon Complex
E.3.1-3 Chapter 3..... The Quality and Availability of Fall Chinook Salmon Spawning and lncubation Habitat
Downstream of the Hells Canyon Complex
E.3.1-3 Chapter 4..... A Desciption of Pacific Lamprcy Life History, Physical Habitat and Water Quality Citeia, and
Their Cunent Status Downstream of theHells Canyon ComplexE.3.1-4.......... Evaluation of ldaho Power Hatchery Mitigation ProgramE.3.1-5.......... Hells Canyon Complex Resident Fish Study
E.3.1-5 Chapter 1..... Water-level lmpacts to Spawning Smallmouth Bass, Crappie spp.,and Channel Catfish
E.3.1-5 Chapter 2..... Eafly Reaing Success
E.3.1-5 Chapter 3..... Stafus of the Fish Community 1991-2000
E.3.1-5Chapter4..... RelativePotential Consequencesof AltemativeOperational ScenanosforCentrarchid
Populations in Brownlee Reseruoir
E.3.1-5 Chapter5..... A Literaturc Review and Drccussion of the Trcphic Structure in Reservoirs Similarto Hells
Canyon ComplexE.3.1-6.......... Sfafus and Habitat Use of Snake RiverWhite Sturyeon Assocrafed with the Hells Canyon
Complex
E.3.1-6 Chapter 1..... Sfafus of Snake RiverWhite Sturgeon Associated with the Hells Canyon Complex
E.3.1-6 Chapter 2..... Physical Habitat Use and Water Quality Citeia for Snake RiverWhite Sfurgeon
E.3.1-6 Chapter 3..... Population Viability Model for Snake RiverWhite Sturgeon
E.3.1-6 Chapter4..... Conceptual Designfortllhite Sturgeon Passage Facilities atthe HellsCanyon ComplexE.3.1-7.......... Redband Trout and BullTrout Associated with the Hells Canyon Complex
E.3.1-7 Chapter 1..... Physical Habitat Use and Water Quality Citeia for Redband Trcut and Bull Trout Associated
with the Hells Canyon Complex
E.3.1-7 Chapter 2..... Population Viability of Bull Trout Living Wthin the Hells Canyon Reach of the Snake River
Basin-Using a BayVAM Assessmenf
E.3.1-7 Chapter 3..... Differcntiation of Oncorhynchus mykiss Associafed with the Hells Canyon Complex Using
Allozyme Electrophore si s
E.3.1-7 Chapter 4..... Distibution, Sfafus, Life History, and Limiting Factors of Redband Trout and Bull Trout
Associated with the Hells Canyon ComplexE.3.1-8.......... BenthicMacroinveiebratesofHellsCanyon
Wildlife 3of3E.3.2-1.......... An lnvestigation of Avian Communities and AviarrHabitat Relationships in the Hells Canyon
Study ArcaE.3.2-2.......... Migrant Shorebird Use of Mudflats along Brownlee ReservoirE.3.2-3.......... Spnng Distibution and Relative Abundance of Upland Game Bids in Hells CanyonE.3.2-4.......... Validation of a Mountain Quail Survey Technique
E.3.2-5.......... Resu/fs of a Pilot Study: Suruey of Mountain Quail in Big Canyon Crcek, ldahoE.3.2-6.......... A Landscape-level Habitat Assessmenf forMountain Quail in Hells CanyonE.3.2-7.......... Assessmenf of Chukar and Gray Paftidge Populations and Habitat in Hells CanyonE.3.2-8.......... Distribution of Sage and Sharp-tailed Grcuse in Hells Canyon and Transmission Line Conidors
Associated with the Hells Canyon Complex
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF. 19
E.3.2-911O..... An Assessment of Sage Grouse and Shary-Tailed Grouse Habitat inTransmission Line
Conidors Associated with the Hells Canyon Hydrcelectic Complex
E.3.2-11................... . Summer Surveys of Watertowl Broods in Hells CanyonE.3.2-12........ Winteing Wateiowl in the Hells Canyon Study ArcaE.3.2-13........ A Suruey of Nesting ColonialWatehids in the Hells Canyon Study AreaE.3.2-14........ Suruey Methodology for Cliff-Nesting Raptors in Hells Canyon lllustnted with a Prcliminary
Assessmenf of Raptors from Big Bar to Hells Canyon Dam
E.3.2-15.
E.3.2-16.
E.3.2-17.
A Desciption of the Raptor Nestlng Community Nesting in the Hells Canyon Area
Distribution and Abundance of Wntering Bald Eagles in Hells Canyon
Habits of Bald Eagles Wnteing in Noftheastem Orcgon and Adjacent Arcas of Washinglon
Master List of Technical Appendices (continued)
Technical Appendix Title CD
Contaminant Evaluation forthe Brownlee Reseruoir Snake River Basin, ldaho
A Description of the Small Mammal Community (Orders Rodentia and lnsectivora) in the Hells
A Prcliminary Assessmenf of Bats along Snake River, Hells Canyon National Recreation Arca
Distibution and Relative Abundance of Mammalian Camivorcs and Furbearcrc in Hells Canyon
Literaturc and Status Review of Big Game Species in Hells Canyon
lce Formation on Brcwnlee Reseruoir and Potential Effects on Big Game Populations
lntegration of Tenestial Resource Analyses and lmpacts
lnfluences of Human Activities on Tenestial Resources Assocrafed with the Hells Canyon
Vegetation of the Snake River Conidor in Hells Canyon-Weiser, ldaho, to the Salmon River
Wildlife (cont.) 3
of3E.3.2-'18........ Percgine Falcon Surveys in Hells CanyonE.3.2-19........ An Evaluation of Avian Electrocution at Transmission Lrnes Assocr,ated with the Hells Canyon
Hydroelectic Complex
E.3.2-20 An Evaluation of Avian Collision at Transmission Lrnes Associated with the Hells Canyon
Hydroelectic ComplexE.3.2-21........ Wldlife Resources of the Snake River Arca of Oregon: An Annotated Bibliography of
lnformation Contained in Orcgon Depafiment of Fish and Wldlife Files
and ldaho
Appendix No.
No.
E.3.2-22.
E.3.2-23.
E.3.2-27.
E.3.2-28.
E.3.2-34..
E.3.2-35..
E.3.245.
E.3.246.
Hydrcelectic Project
Botanica!
3of3
E.3.3-1
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
Canyon Study AreaE.3.2-24........ Small and Medium-sized Mammals of the Hells Canyon Arca of the Snake River in
ldaho/OrcgonE.3.2-25........ Medium-sized Mammal Resources in the Hells Canyon Study ArcaE.3.2-26........ A Habitat Suruey forthe ldaho Grcund Squinel
E.3.2-29........ Wolveine Suruey in the Seven Devils Mountains of Hells CanyonE.3.2-30........ Mule Deer Population Suruey in Hells Canyon
E.3.2-31 ........ Delineation andAssessment of Big Game Wnter Range Associated with the Hells Canyon
Hydroelectic Complex: Mule Deer, Elk, Mountain Goats, and Rocky Mountain Bighom SheepE.3.2-32........ Winteing Mule Deer Ecology in the Reseruoir Reach of the Hells Canyon Hydrcelectric
ComplexE.3.2-33........ Distribution and Abundance of Mountarn Goats in Hells Canyon
E.3.2-36........ Species Occunence and Distibution of Amphibians and Reptiles in Hells CanyonE.3.2-37........ Effects of Roads and Tnnsmission Line Rights-of-Way on Wldlife Resources lncluding Species
of Special ConcemE.3.2-38........ A Description of State and Fedenl Specles of Special Concem in Hells CanyonE.3.2-39........ Hells Canyon Complex Conseruation Reserye Study Final ReportE.3.2-40........ Hells CanyonWildlife Habitat AssessmenfE.3.2-41........ Effects of Water-Level Fluctuations on Ripaian Habitat FragmentationE.3.2-42........ Shorcline Erosion in Hells Canyon
E.3.2-43.
Concem
lnfluences of Roads in the Hells Canyon Complex Arca on Wldlife and Botanical Species of
E.3.244........ Effects of Constructing and Operating the Hells Canyon Complex on Wldlife Habitat
E.3.3-2.......... lnventory of Rare Plants and Noxious Weeds Along the Snake River Conidor in Hells Canyon-
Weiser, ldaho, to the Salmon River
E.3.3-3.Ecology of Ripaian Vegetation of the Hells Canyon Conidor of the Snake River Field Data,
Analysis and Modeling of Plant Responses to lnundation and Regulated FlowsE.3.3-4.......... Effects of Road and Tnnsmission-Line Rightsof-Way on Botanical Resources
Cultural
3of3
E.4-11.
7950s
E.4-12.
Non-Native Exploration, Seftlement, and Land Use of the Greater Hells Canyon Arca, 1800s to
An Archival Review and Ethnographic Study for the Relicensing of the Hells Canyon Complex
CD
3of
Genenl Recrcation Findings fiom Hells Canyon National RecrcationArca: 1999 Visitor Suruey
Reseruoir Level Issues in the Hells Canyon Complex
River Level /ssues in the Hells Canyon National Recrcation Arca
Hyd rcelectical Plants Hells Canyon, ldahuO regon
E.4-14.Hells Canyon Complex Historic Buildings Reconnar.ssance SurueyE.4-15........... Histoic Properties Management Plan Hells Canyon Complex
Recreation
3of3E.5-1............. A Review of Past Recrcation /ssues and Use in the Hells Canyon Complex and the Hells
Canyon National Recrcation Area
E.5-2.Reseruoir-Related Recrcational Use atthe Hells Canyon ComplexE.5-3............. RecrcationalUse Assocrafed with the Snake River in the Hells Canyon National Recrcation
ArcaE.5-4............. Genenl Recreation Findings frcm Hells Canyon Complex Reseryoirs.' 199+2000 Onsife
lnteruiews and 2000 Mail Suruey
Master List of Technical Appendices (continued)
Appendix No.
No.
Technical Appendix Title
Recreation l(cont.)
3
E.5-5.
E.5-6
E.5-7E.5-8............. Desciption of Existing Developed Recrcation Sifes rn the Hells Canyon Complex and
Assocrafed Recrcational UseE.5-9............. Desciption of Existing Recreation Arcas in the Hells Canyon Complex and Hells Canyon
National
Recrcation ArcaE.5-10........... Reseruoir Angling in the Hells Canyon ComplexE.5-11........... Angling on the Snake River in the Hells Canyon National Recreation AreaE.5-12........... Hunting Associated with the Hells Canyon Complex and the Hells Canyon National Recreation
ArcaE.5-13........... Recrcation in the Hells Canyon Recreation Arca: Selected Photos and Major Study Findings
Land Management 3
of3
E.6-1 Hells Canyon Resource Management PlanE.6-2............. lnfluences of Land Management Practices of IPC-Owned Lands on Tenestial ResourcesE.6-3............. Hells Canyon Complex Aesthetic Resource lnventory and Evaluation
ln response to submission of the 2003 final HCC License Application, FERC requested
Additiona! lnformation Requests ("AIR") it determined was needed to complete its
evaluation of the Application. ln 2007, the final AIR was submitted to FERC. Table 3 in
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
Chris Randolph's testimony outlines the AIR study reports. These reports can be found
on ldaho Power's website via the following link:
http://tropic:8O7/AboutUs/RatesRequlatorv/Relicensino/hellscanvon/HC AIR Reports.cfm.
Table 3. Additional Information Requests.
Resource/AlR Number
General Operations
oP-1
oP-2
Geolory and Soils
s-l
Water Quantity and Quality
wo-lwo-2
Aquatic Resources
AR-I
AR.2
Terrestrial Resources
TR.I
Land Use
LU-1
Developmental Resources
DR.I
DR-2
DR-3
DR-4
Transmission Lines
TL-1
AIR Description
Operational Scenarios
Current Operations Scenario
Sediment Transport
Dissolved Oxvsen Auementation
Temperature Control
Hells Canyon Fish Trap Modifications
Listed Molluscs
Thermal Altemative Cost of Capital
Flood Control
Power Economics
Estimated Cost of PM&E Measures
Habitat Resource Management 9 months
Project Boundary Change 6 months
Filine Due
9 months
3 months
9 months
9 months
9 months
6 months
9 months
3 months
6 months
6 months
9 months
Transmission Line Jurisdiction 3 months
The response to this Request is sponsored by Chris Randolph, Environmenta!
Affairs Director, ldaho Power Company.
DATED at Boise, ldaho, this 6th day of March 2017.
LI D. NORD M
Attorney for ldaho
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 22
r Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 6th day of March 2017 I served a true and
correct copy of IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF upon the following named
parties by the method indicated below, and addressed to the following:
Gommission Staff
Camille Christen
Brandon Karpen
Deputy Attorneys General
ldaho Public Utilities Commission
472 West Washington (83702)
P.O. Box 83720
Boise, ldaho 83720-007 4
lndustrial Customers of ldaho Power
Peter J. Richardson
RICHARDSON ADAMS, PLLC
515 North 27th Street (83702)
P.O. Box 7218
Boise, ldaho 83707
Dr. Don Reading
6070 Hill Road
Boise, Idaho 83703
ldaho Conseruation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
X Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email camille.christen@puc.idaho.qov
brandon. karpen@puc. idaho. qov
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXxEmail peter@richardsonadams. com
_Hand DeliveredX U.S. Mail
_Overnight Mail
FAX
x Email dreading@mindsprinq.com
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email botto@idahoconservation.org
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email elo@echohawk.com
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23
Anthony Yankel
12700 Blake Avenue, Unit 2505
Lakewood, Ohio 4r'.107
_Hand DeliveredX U.S. Mail
Ovemight Mail
_FA)(X Email tony@yankel.net
BeaffY,Assistant
IDAHO POWER COMPANY'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF THE COMMISSION STAFF.24