20170410IPC to Staff 15-24.pdf

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An IDACORP CompanY
LISA D. NORDSTROTUI
Lead Counsel
[e-mail]
April 7, 2017
VIA HAND DELIVERY
Diane Hanian, Secretary
ldaho Public Utilities Commission
472 West Washington Street
Boise, ldaho 83702
Re: Case No. !PC-E-16-32
Hells Canyon Complex Relicensing Costs through 2015 - ldaho Power
Company's Response to the Second Production Request of the Commission
Staff
Dear Ms. Hanian
Enclosed forfiling in the above matter please find an originaland three (3) copies of
Idaho Power Company's Response to the Second 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. PIease handle the
confidential information in accordance with the Protective Agreement executed in this
matter.
Very truly yours,
Ul-
Lisa D. Nordstrom
3tffi*
O4*t>q,.-,
LDN:csb
Enclosures
122'l W. ldaho St. (83702)
PO. Box 70
Boise, lD 83707
LISA D. NORDSTROM (lSB No. 5733)
ldaho Power Company
'1221West ldaho Street (83702)
P.O. Box 70
Boise, ldaho 83707
Telephone: [phone]
Facsimile: [phone]
lnordstrom@idahopower. com
Attorney for ldaho Power Company
!
-D
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR A
DETERMINATION OF HELLS CANYON
RELICENS!NG COSTS THROUGH 2015
AS PRUDENTLY INCURRED
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CASE NO. rPC-E-16-32
IDAHO POWER COMPANY'S
RESPONSE TO THE SECOND
PRODUCTION REQUEST OF
THE COMMISSION STAFF
COMES NOW, ldaho Power Company ("ldaho Power" or "Comp?ny"), and in
response to the Second Production Request of the Commission Staff to ldaho Power
dated March 17 ,2017, herewith submits the following information:
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 1
REQUEST NO. 15: ln Chris Randolph's testimony (p. 20), he states the
Collaborative Team included over 100 organizational affiliations and Resource Work
Groups that undertook over 90 studies to evaluate the project-related impacts of Hells
Canyon Complex (HCC) operations. Please explain why it was necessary to complete
over 90 studies and to include over 100 organizational affiliations on the Collaborative
Team. Furthermore, please explain how the Company used a least-cost approach to
manage the relicensing process and to evaluate the project-related impacts of HCC
operations.
RESPONSE TO REQUEST NO. 15:
A. Whv Was lt Necessarv to Gomplete Over 90 Studies?
Studies were performed for the HCC relicensing effort to meet Federal Energy
Regulatory Commission ("FERC") requirements that must be satisfied prior to the
issuance of a new license. Additionally, as discussed in more detail below, the studies
performed by Idaho Power ensure that the HCC license is achieved in a least-cost
manner by limiting study proposals and potential Protection, Mitigation, and
Enhancement ("PM&E") measures to areas impacted by the operation of the HCC.
ldaho Power followed the traditional relicensing process that requires the
development of resource studies with input from stakeholders (agencies, tribes, and the
public). During this process, stakeholders may claim that impacts have resulted from
the operation of the HCC, and may subsequently request a study be performed or a
PM&E measure be implemented to address the alleged impact. Consequently, ldaho
Power must perform studies to address these claims and ensure that the PM&E
measures ultimately agreed upon are limited to areas that are, in fact, impacted by the
operation of the HCC. By performing these studies and possessing the underlying
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 2
scientific analysis to rebut unfounded claims of HCC impacts, ldaho Power can ensure
that relicensing costs are not unduly increased by proposed studies and PM&E
measures that address issues unrelated to HCC operations.
Through the relicensing process, resource issues were collected during public
meetings held between January 1996 and January 1997 and then compiled into
problem statements, which were in turn developed into resource study plans. Study
plans for 82 studies were submitted to FERC and stakeholders in the Formal
Consultation Package in January 1997. Study plans were also presented at FERC-
required Joint Agency Public Consultation Meetings held in March 1997.
Ultimately, a total of 123 studies were conducted and included in the final license
application. These studies included both descriptive studies and impact studies.
Descriptive studies were used to determine the status of the resources associated with
the HCC and inform resource impact studies. lmpact studies were used to determine
the resource impacts of project-specific operations, which served as the basis for the
development of PM&E measures. Categories and the corresponding number of
resource studies were as follows: Sediment and Geomorphology - 11, Water Quality -
4, Flows - 2, Aquatic - 6, Anadromous Fish - 31, Wildlife - 45, Botanical - 4, Cultural -
4, Recreation - 13, and Land Management - 3.
After the final license application was submitted, FERC requested 14 Additional
lnformation Requests ("AlRs"). FERC initiates AlRs when it determines that additional
information is needed to inform the relicensing process. Responses to these AlRs were
required before the environmental impact statements could be published. lf the 123
studies had not been completed, the number and costs of AlRs would have been
greater.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 3
The value of conducting HCC relicensing studies is also seen in how FERC
utilized impact study information in evaluating 1Ofi) recommendations from state and
federal agencies. Section 10O of the Federal Power Act requires that FERC include
conditions for the PM&E of fish and wildlife affected by a project. ln Table 108 Volume
2 of the HCC Final Environmental lmpact Statement ('FE|S"), FERC adopts or does not
adopt 10(j) recommendations. Please see page 716 of the following link:
http ://elibrary.ferc.qov/id mws/common/Open Nat. asp?filel D= 1 1 438425.FERC stated,
"ln the draft ElS, of the 173 recommendations we considered to be within the scope of
section 10O, we wholly included 92 measures in the Staff Alternative, included 27 in
part, and did not include 54." FERC HCC FEIS, page 715. The 54 10U)
recommendations not adopted would likely have been adopted at additional cost if
ldaho Power had not conducted the necessary studies to demonstrate that these
recommendations were either out of scope or unnecessary.
B. Whv Was lt Necessarv to lnclude {00 Oroanizational Affiliations on
the Collaborative Team?
ldaho Power chose to form the Collaborative Team of over 100 organizational
affiliations to control costs by capturing and identifying areas of concern early in the
relicensing process so they could be organized into studies and addressed in a cost-
efficient manner. ldaho Power formed a collaborative relicensing process in January
1996 to improve the level of understanding of resource issues and the potential for
agencies, tribes, and interested parties to resolve these issues. The process
augmented the traditional FERC process by including more open discussion of studies
and resource issues earlier in the relicensing process.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 4
c Please Explain How the Gompanv Used a Least-Cost Approach to Manaqe
the Relicensinq Process and to Evaluate the Proiect-Related lmpacts of
HCC Operations.
There are multiple facets of ldaho Power's approach intended to complete the
relicensing process in a least-cost manner. As discussed above, the Company
developed a collaborative dialogue early in the process to allow for settlement when
possible and to identify known issues at the outset of the planning process. This
allowed for the development of a study framework that would address known issues in
the most efficient manner possible. The Company also performed studies to satisfy
FERC requirements for licensure while providing ldaho Power with a solid foundation
from which to evaluate study proposals and PM&E measures. These studies contribute
to a least-cost approach by limiting the scope of HCC relicensing efforts to areas that
are truly impacted by dam operations. The following three examples demonstrate how
the Company's analyses served to limit costs throughout the relicensing process.
1. Operationa! lmpact Bookend Analvsis.
During operational impact study development, several operational scenarios
were requested by stakeholders. To complete the operational analysis in a least-cost
manner, ldaho Power chose to limit the analysis to two "bookend" operational impact
scenarios-full pool no operations and proposed operations. lmpacts of operations
were determined as the environmental effects between no operations and proposed
operations. These bookend analyses provided for a least-cost approach, as they
served to set the parameters for the range of future studies and PM&E measures
performed by ldaho Power.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 5
As an example of how ldaho Power managed operational impact analysis
through these bookend studies, ldaho Fish and Game ("IDFG") submitted the following
comment to the HCC draft license application (lDFG1-3)):
The Aquatic and Terrestria! Work Groups recommended a
number of potential operational scenarios to lPC. IPC
dismissed these recommendations and advised that such
modeling was unnecessary for the license application.
ldaho Power responded as follows:
Therefore, IPC's proposed measures take into consideration
their impact on power production and are aimed at
addressing project-related impacts while preserving the
power values of the project. By doing so, IPC's plan
adequately and equitably protects, mitigates, or enhances
the resources affected by HCC operations.
While FERC ultimately disagreed with ldaho Power and determined that a
defined number of additional operational scenarios were necessary, ldaho Power
avoided the additional cost and resources that would have been required to perform all
of the multiple operational scenarios requested by IDFG
2. Limitinq Analysis to FERG Requirements.
ldaho Power demonstrated a least-cost approach by following FERC guidelines
on not theorizing on pre-development conditions, and not unduly expanding the scope
of its analysis beyond what was required by FERC to obtain a new license. For
example, IDFG made the following comment to the HCC draft license application
(rDFG 1-1aa):
lnstead of conducting the requested study, IPC funded a
study to describe wildlife habitat conditions during two
periods the 1950s and the 1990s. This study neither
quantified nor characterized wildlife habitat quality prior to
European influence and habitat capability without the project
in place.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 6
ldaho Power responded as follows
FERC does not attempt to recreate pre-project conditions or
hypothesize an environmental baseline that assumes that
the project does not exist nor attempt to determine what
might have occurred had the project been configured,
operated, or maintained differently under the prior license.
By maintaining its position that FERC relicensing guidelines do not require
analysis of pre-development conditions, Idaho Power was able to avoid the additional
cost and resources associated with a requested study that was not within the scope of
the relicensing process.
3. Baseline Studv Development.
As described in the Company's response to the Idaho Public Utilities
Commission Staff's ("Staffl') Request No. 13, ldaho Power performed baseline studies
at the outset of the relicensing process to control costs. These studies formed a
baseline from which to evaluate future study proposals, as well as providing a
comprehensive foundation of information to evaluate the impacts of HCC operations.
These studies served to limit costs by avoiding duplication of work and allowing ldaho
Power to identify and limit study proposals to issues strictly related to the actual
operations of the HCC.
To summanze, the relicensing process allows stakeholders to request studies
and propose PM&E measures that address what they believe to be impacts resulting
from the operation of the HCC. Idaho Power developed a collaborative process in 1996
to identify areas of concern related to relicensing, providing for informal resolution of
issues when possible, and allowing the Company to organize its study framework in the
most efficient manner possible. Additionally, through efforts such as the bookend
operational studies, adherence to FERC guidelines, and the development of baseline
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 7
analyses, ldaho Power could control costs associated with the relicensing process by
reducing the number of AIRs required by FERC and limiting studies and PM&E
measures to HCC-specific impacts.
The response to this Request is sponsored by Chris Randolph, Environmental
Affairs Director, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 8
REQUEST NO. 16: ln Chris Randolph's testimony (p. 20), he states that there
were over 90 studies to evaluate the project-related impacts of HCC operations. lf
some of these studies are not outlined in Exhibit No. 2, please explain the purpose of
the study. Please also provide the cost of each study, including those shown in Exhibit
No. 2. Furthermore, please explain the Company's criteria for determining if studies
were "reasonable and necessary," as shown for the first step of the second stage.
RESPONSE TO REQUEST NO. {6:
A. !f Some of These Studies Are Not Outlined in Exhibit No. 2. Please Explain
the Puroose of the Studv-
To provide clarification, the studies listed in Exhibit No. 2 reflect the 82 studies
proposed in the Formal Consultation Package. The Final License Application included
123 studies. Additionally, as discussed in the Company's response to Staffs Request
No. 15, FERC issued 14 AlRs after the Final License Application was submitted in
2003, for a combined total of 137 studies. A list of all 137 studies and the subject
matter of each study can be found in the Company's response to Staff's Request No.
14.
B. Please AIso Provide the Cost of Each Study, lncludinq Those Shown in
Exhibit No. 2.
Costs are tracked by cost center and work order, rather than by individual study.
After approval of the capital budget, 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
HCC relicensing activity or body of work. This is often done to support project
management and reporting activities. Table 1 below provides details regarding
expenditures by cost center during the time when relicensing studies were being
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 9
conducted, as wel! as a listing of the studies that were conducted. At Staffs request,
the Company will make any additional requested documentation available at the
Company's corporate headquarters. Please contact Matt Larkin at 388-2461 or Camilla
McClusky at 388-5821 to arrange a time to review the selected material.
C. Please Explain the Companv's Griteria for Determininq if Studies Were
"Reasonable and Necessary," as Shown for the First Step of the Second
Staqe.
As discussed in the Company's response to Staffs Request No. 15, ldaho
Power's approach throughout the relicensing process has been to limit relicensing
efforts to FERC requirements as well as studies and PM&E measures directly related to
the operation of the HCC. The basis for determining if studies were "reasonable and
necessary" was based on information gathered during resource descriptive studies, in
addition to the Company's professional judgment on potential resource impacts from
project operations. The baseline studies and the bookend operational analyses detailed
in the Company's response to Staffs Request No. 15 provide additional information with
regard to the baseline data the Company utilized to determine if study proposals were
reasonable and necessary.
The response to this Request is sponsored by Chris Randolph, Environmental
Affairs Director, ldaho Power Company.
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IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. 1O
Table 1. Technical Appendix Studies Grouped by the Lead Cost Centers Directly Conducting the Efforts
and Expended Cost by Those Cost Centers During the Years 1997-July 2fl)3
Appendix No.Technical Appendix Title Lead Cost Centers Cost Centers Costs
Sediment and
Geomorphology
PP Eng & Const
Leadership,
Water Manasement
$6,220,936
E.1-1 Sediment Transport Supply
and Stability in the Hells
Canyon Reach ofthe Snake
River
E.1-2 Geomorphology of the Hells
Canyon Reach ofthe Snake
River
E.1-3 Topographic lntegration for the
Hells Canvon Studies
E.1-4 Project Hydrology and
Hydraulic Models Applied to
the Hells Canyon Reach of the
Snake River
E.1-4 Chapter 1 lntegration of Hydrologic
lnformation and Models for
Hells Canvon Comolex Studies
E.1-4 Chapter 2 Development of lnflow
Hydrology for Hells Canyon
ComDlex Studies
E.1-4 Chapter 3 Hells Canyon Complex
Ooerations Modelino
E.14 Chapter 4 Hells Canyon Complex
Reservoir Water Quality
Modelino
E.1-4 Chapter 5 Hells Canyon MIKE 1'l
Hvdrodvnamic Model
E.14 Chapter 6 Hells Canyon MIKE 11
Temperature and Total
Dissolved Gas
E.1-4 Chapter 7 Seven HD Models on the
Snake River
Water Quality Environmental - Water
Quality
$ 1,988,027
E.2.2-1 Tributary Pollutant Sources to
the Hells Canvon Comolex
E.2.2-2 Pollutant Transport and
Processing in the Hells
Canvon Comolex
E.2.2-3 Hydro Machine Oil Monitoring
at Hells Canyon Complex
Power Plants
E.2.24 Hells Canyon Complex Total
Dissolved Gas Studv
E.3.1-8 Benthic Macroinvertebrates of
Hells Canvon
Aquatic Environmental - Fisheries $ I1,455,429
E.3.1-1 lntegration of Aquatic Studies
in the Hells Canyon
Relicensinq
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 11
E.3.1-2 Feasibility of Reintroduction of
Anadromous Fish Above or
Within the Hells Canyon
Comolex
E.3.1-2 Chapter 1 lntroduction and Overview
E.3.1-2 Chapter 2 History of the Hells Canyon
Complex
E.3.1-2 Chapter 3 Habitat of the Snake River
Plain
E.3.1-2 Chapter 4 Existing Habitat Conditions of
Tributaries Formerly Used by
Anadromous Fish
E.3.1-2 Chapter 5 Existing Habitat Conditions of
the Mainstem Snake River
Formerly Used by Anadromous
Fish
E.3.'l-2 Chapter 6 Historical Abundance of
Anadromous Fish Upstream of
the Hells Canvon Complex
E.3.1-2 Chapter 7 Estimators of Potential
Anadromous Fish Smolt Yield
E.3.1-2 Chapter 8 Potential Smolt Yield of
Anadromous Fish from
Subbasins Above the Hells
Canvon Complex
E.3.'l-2 Chapter 9 Conceptual Design of Passage
Facilities for the Hells Canyon
Complex
E.3.1-2 Chapter 10 Pathogen Assessment and
Suitability of Stocks for
Reintroduction Above the Hells
Canvon Comolex
E.3.1-2 Chapter 11 Evaluation of Reintroduction
Alternatives
E.3.'l-2 Appendices Annotated Bibliographies on
the Chronology of Decline of
Anadromous Fish in the Snake
River Basin above the Hells
Canyon Dam
E.3.1-3 Evaluation of Anadromous
Fish Potential Within the
Mainstem Snake River
Downstream of the Hells
Canvon Comolex of Reservoirs
E.3.1-3 Chapter 1 The Timing and Distribution of
Fall Chinook Salmon
Spawning Downstream of the
Hells Canvon Complex
E.3.1-3 Chapter 2 Physical Habitat and Water
Quality Criteria for Chinook
Salmon Associated with the
Hells Canvon Comolex
E.3.1-3 Chapter 3 The Quality and Availability of
FallChinook Salmon
Spawning and lncubation
Habitat Downstream of the
Hells Canvon Comolex
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. 12
E.3.1-3 Chapter4 A Description of Pacific
Lamprey Life History Physical
Habitat and Water Quality
Criteria and Their Current
Status Downstream of the
Hells Canvon Comolex
E.3.1-4 Evaluation of ldaho Power
Hatcherv Mitioation Prooram
E.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 Chapter2 Earlv Rearinq Success
E.3.1-5 Chapter 3 Status of the Fish Community
1991-2000
E.3.1-5 Chapter4 Relative Potential
Consequences of Alternative
Operational Scenarios for
Centrarchid Populations in
Brownlee Reservoir
E.3.1-5 Chapter 5 A Literature Review and
Discussion of the Trophic
Structure in Reservoirs Similar
to Hells Canyon Complex
E.3.1-6 Status and Habitat Use of
Snake River White Sturgeon
Associated with the Hells
Canvon Complex
E.3.1-6 Chapter 1 Status of Snake River White
Sturgeon Associated with the
Hells Canyon Complex
E.3.1-6 Chapter 2 Physical Habitat Use and
Water Quality Criteria for
Snake River White Sturqeon
E.3.1-6 Chapter 3 Population Viability Model for
Snake River White Sturgeon
E.3.1-6 Chapter 4 Conceptual Design for White
Sturgeon Passage Facilities at
the Hells Canyon Complex
E.3.1-7 Redband Trout and Bull Trout
Associated with the Hells
Canvon Complex
E.3.1-7 Chapter 1 Physical Habitat Use and
Water Quality Criteria for
Redband Trout and Bull Trout
Associated with the Hells
Canvon Comolex
E.3.1-7 Chapter 2 Population Viability of Bull
Trout Living Within the Hells
Canyon Reach ofthe Snake
River Basin-Using a BayVAM
Assessment
E.3.1-7 Chapter 3 Differentiation of
Oncorhynchus mykiss
Associated with the Hells
Canyon Complex Using
Allozvme Electrophoresis
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 13
E.3.1-7 Chapter4 Distribution Status Life History
and Limiting Factors of
Redband Trout and BullTrout
Associated with the Hells
Canvon Comolex
E.2.3-1 Oxbow Bypass Minimum Flow
Evaluation
E.2.3-2 Hells Canyon lnstream Flow
Assessment
Wildlife Environmental -
Terrestrial
$ 11,694,433
E.3.2-1 An lnvestigation of Avian
Communities and Avian-
Habitat Relationships in the
Hells Canvon Studv Area
E.3.2-2 Migrant Shorebird Use of
Mudflats along Brownlee
Reservoir
E.3.2-3 Spring Distribution and
Relative Abundance of Upland
Game Birds in Hells Canvon
E.3.24 Validation of a Mountain Quail
Survev Technioue
E.3.2-5 Results of a Pilot Study:
Survey of Mountain Quail in
Bio Canvon Creek ldaho
E.3.2-6 A Landscape-level Habitat
Assessment for Mountain
Quail in Hells Canvon
E.3.2-7 Assessment of Chukar and
Gray Partridge Populations
and Habitat in Hells Canvon
E.3.2-8 Distribution of Sage and
Sharp{ailed Grouse in Hells
Canyon and Transmission Line
Corridors Associated with the
Hells Canvon Comolex
E.3.2-9t10 An Assessment of Sage
Grouse and Sharp-Tailed
Grouse Habitat in
Transmission Line Corridors
Associated with the Hells
Canvon Hvdroelectric Comolex
E.3.2-11 Summer Surveys of Waterfowl
Broods in Hells Canvon
E.3.2-12 Wintering Waterfowl in the
Hells Canyon Studv Area
E.3.2-',13 A Survey of Nesting Colonial
Waterbirds in the Hells Canyon
Study Area
E.3.2-14 Survey Methodology for Cliff-
Nesting Raptors in Hells
Canyon lllustrated with a
Preliminary Assessment of
Raptors from Big Bar to Hells
Canvon Dam
E.3.2-15 A Description of the Raptor
Nesting Community Nesting in
the Hells Canvon Area
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. 14
E.3.2-16 Distribution and Abundance of
Wintering Bald Eagles in Hells
Canvon
E.3.2-',t7 Habits of Bald Eagles
Wintering in Northeastern
Oregon and Adjacent Areas of
Washinqton and ldaho
E.3.2-18 Peregrine Falcon Surveys in
Hells Canvon
E.3.2-19 An Evaluation of Avian
Electrocution at Transmission
Lines Associated with the Hells
Canvon Hvdroelectric Complex
E.3.2-20 An Evaluation of Avian
Collision at Transmission Lines
Associated with the Hells
Canvon Hvdroelectric Complex
E.3.2-21 Wildlife Resources of the
Snake River Area of Oregon:
An Annotated Bibliography of
lnformation Contained in
Oregon Department of Fish
and Wildlife Files
E.3.2-22 Contaminant Evaluation for the
Brownlee Reservoir Snake
River Basin ldaho
E.3.2-23 A Description of the Small
Mammal Community (Orders
Rodentia and lnsectivora) in
the Hells Canvon Studv Area
E.3.2-24 Smalland Medium-sized
Mammals of the Hells Canyon
Area of the Snake River in
ldaho/Oreqon
E.3.2-25 Medium-sized Mammal
Resources in the Hells Canyon
Studv Area
E.3.2-26 A Habitat Survey for the ldaho
Ground Souirrel
E.3.2-27 A Preliminary Assessment of
Bats along Snake River Hells
Canyon National Recreation
Area
E.3.2-28 Distribution and Relative
Abundance of Mammalian
Carnivores and Furbearers in
Hells Canvon
E.3.2-29 Wolverine Survey in the Seven
Devils Mountains of Hells
Canvon
E.3.2-30 Mule Deer Population Survey
in Hells Canyon
E.3.2-3',1 Delineation and Assessment of
Big Game Winter Range
Associated with the Hells
Canyon Hydroelectric Complex
Mule Deer Elk Mountain Goats
and Rocky Mountain Bighorn
Sheep
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 15
E.3.2-32 Wintering Mule Deer Ecology
in the Reservoir Reach of the
Hells Canyon Hydroelectric
Comolex
E.3.2-33 Distribution and Abundance of
Mountain Goats in Hells
Canyon
E.3.2-y Literature and Status Review
of Big Game Species in Hells
Canyon
E.3.2-35 lce Formation on Brownlee
Reservoir and Potential Effects
on Biq Game Populations
E.3.2-36 Species Occurrence and
Distribution of Amphibians and
Reptiles in Hells Canyon
E.3.2-37 Effects of Roads and
Transmission Line Rights-of-
Way on Wildlife Resources
lncluding Species of Special
Concern
E.3.2-38 A Description of State and
Federal Species of Special
Concern in Hells Canvon
E.3.2-39 Hells Canyon Complex
Conservation Reserve Study
Final Report
E.3.240 Hells Canyon Wildlife Habitat
Assessment
E.3.2-41 Effects of Water-Level
Fluctuations on Riparian
Habitat Fraqmentation
E.3.242 Shoreline Erosion in Hells
Canvon
E.3.2-43 lnfluences of Roads in the
Hells Canyon Complex Area
on Wildlife and Botanical
Species of Concern
E.3.244 Effects of Constructing and
Operating the Hells Canyon
Comolex on Wildlife Habitat
E.3.245 lntegration of Terrestrial
Resource Analyses and
lmoacts
E.3.2-46 lnfluences of Human Activities
on Terrestrial Resources
Associated with the Hells
Canvon Hvdroelectric Proiect
E.3.3-1 Vegetation of the Snake River
Corridor in Hells Canyon-
Weiser ldaho to the Salmon
River
E.3.3-2 lnventory of Rare Plants and
Noxious Weeds Along the
Snake River Corridor in Hells
Canyon-Weiser ldaho to the
Salmon River
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 16
E.3.3-3 Ecology of Riparian Vegetation
of the Hells Canyon Corridor of
the Snake River: Field Data
Analysis and Modeling of Plant
Responses to lnundation and
Reoulated Flows
E.3.34 Effects of Road and
Transmission-Line Rights-of-
Way on Botanical Resources
E.4-11 Non-Native Exploration
Settlement and Land Use of
the Greater Hells Canyon Area
1800s to 1950s
E.4-12 An Archival Review and
Ethnographic Study for the
Relicensing of the Hells
Canyon Complex
Hydroelectrical Plants Hells
Canvon ldaho-Oreqon
E.4-14 Hells Canyon Complex Historic
Buildings Reconnaissance
Survey
E.4-15 Historic Properties
Management Plan Hells
Canvon Comolex
Recreation Environmental -
Recreation
$ 3,096,896
E.5-1 A Review of Past Recreation
lssues and Use in the Hells
Canyon Complex and the Hells
Canyon National Recreation
Area
E.5-2 Reservoir-Related
Recreational Use at the Hells
Canvon Comolex
E.5-3 Recreational Use Associated
with the Snake River in the
Hells Canyon National
Recreation Area
E.5-4 General Recreation Findings
ftom Hells Canyon Complex
Reservoirs 1 994-2000 Onsite
lnterviews and 2000 Mail
Survev
E.5-5 General Recreation Findings
from Hells Canyon National
RecreationArea 1 999 Visitor
Survev
E.5-6 Reservoir Level lssues in the
Hells Canvon Comolex
E.5-7 River Level lssues in the Hells
Canyon National Recreation
Area
E.5-8 Description of Existing
Developed Recreation Sites in
the Hells Canyon Complex and
Associated Recreational Use
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 17
E.5-9 Description of Existing
Recreation Areas in the Hells
Canyon Complex and Hells
Canyon National Recreation
Area
E.5-10 Reservoir Angling in the Hells
Canvon Comolex
E.5-11 Angling on the Snake River in
the Hells Ganyon National
Recreation Area
E.5-12 Hunting Associated with the
Hells Canyon Complex and the
Hells Canyon National
Recreation Area
E.5-13 Recreation in the Hells Canyon
Recreation Area: Selected
Photos and Major Study
Findinos
Land Management Geognphic Support,
GIS Applications,
Lands Depaftment,
CADD|GIS Production
$ 1,280,655
E.6-1 Hells Canyon Resource
Manaqement Plan
E.6-2 lnfluences of Land
Management Practices of IPC-
Owned Lands on Terrestrial
Resources
E.6-3 Hells Canyon Complex
Aesthetic Resource lnventory
and Evaluation
Total Study Cost by Cost
Centerc
$35,736,375
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 18
REQUEST NO. 17: ln Tim Tatum's testim ony (p. 11), he states "Assuming total
HCC relicensing costs of $400 million and 1,167 MW generating capacity, ldaho Power
estimates the HCC cost per kilowatt ('kW") is $358." Please provide the total estimated
cost per kilowatt, including investments that could be necessary to comply with !ong-
term HCC relicensing requirements. Please supply supporting workpapers with cost
categories identified.
RESPONSE TO T NO_ 17: The $358 per-kW figure included in Mr
Tatum's testimony reflects the estimated capital expenditures required to obtain the new
S0-year license for the HCC. This figure was provided as a comparison to the capital-
cost estimate for construction of a combined-cycle combustion turbine of $1,145 per
kW. ldaho Power has not performed an analysis that provides a similar comparison on
a per-kW basis for potential ongoing costs (capital or expense) that may be incurred
after the resources are placed in service.
The response to this Request is sponsored by Tim Tatum, Vice President of
Regulatory Affairs, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF. 19
REQUEST NO. 18: !n the Com pany's response to Audit Request No. 2(c), the
Company indicated that some contracts were destroyed in compliance with the ldaho
Power records retention policy. Please provide a list of all contracts destroyed that
related to Hell's Canyon relicensing efforts.
RESPONSE TO REQUEST NO. 18: Contracts associated with the HCC
relicensing efforts exist in multiple locations throughout the Company and in various
formats. Consequently, compiling a comprehensive list of contracts and indicating
which contracts have been destroyed would be labor intensive and administratively
burdensome. In the alternative, ldaho Power has provided on the non-confidential CD a
comprehensive list of contracted purchased services transactions,l and respectfully
requests that Staff employ a sampling technique to examine these contract payments.
ldaho Power will make available any documentation in its possession to support the
selections made, and applicable Idaho Power personnel may be available to provide
additional context or background related to work performed by contractors. At Staffs
request, the Company will make the requested documentation available at the
Company's corporate headquarters. Please contact Matt Larkin at 388-2461 or Camilla
McClusky at 388-5821 to arrange a time to review the selected material.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
' The file provided in response to this Request includes all purchased services transactions from
the Master Transaction File (provided as a confidential attachment to Staffs Request No. 1). Because
purchased services transactions do not contain confidential information, the transactions detailed in the
attachment provided in response to this Request are not designated as confidential.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 20
REQUEST NO. 19: ln the Company's response to Audit Request No. 2(c), the
Company provide a copy of the contract with the Oregon Dept. of Fish and Wildlife
(ODF&W). The terms of the contract state that ldaho Power is to pay the full amount of
the overdue reauthorization fees, plus interest ol To/o per annum from the date payments
were originally due. Please provide all overdue/late payment fees, including interest
charges.
RESPONSE TO REQUEST NO. 19: ldaho Power has not incurred any Iate
payment or interest fees related to the ODF&W contract.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 21
REQUEST NO. 20: The Company's response to Audit Request No. 2(c)
identifies the terms of the contract that the reauthorization fee structure and the current
fee structure may change legislatively on January 1,2000. Please provide any updates
to the fee structures and the dates that the updates became effective.
RESPONSE TO REQUEST NO. 20: The current rate for reauthorization fees is
$0.13 per theoretical horsepower, as outlined in Oregon Revised Statute 543A.415, a
copy of which is provided on the non-confidential CD. The rate was increased
legislatively by $0.04 per theoretical horsepower, effective on January 1, 2000. There
have been no changes to this rate since January 2000.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, Idaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 22
REQUEST NO. 21: ln the Company's response to Audit Request No. 2(c), the
contract with ODF&W states that any studies or additional work undertaken by ODF&W
at the request of ldaho Power may require reimbursement and that those arrangements
would be negotiated separately. Please provide detailed narratives, including scope of
work and costs, of any separate negotiations that occurred with ODF&W.
RESPONSE TO REQUEST NO.21: ODF&W performed work related to HCC
relicensing activities in the 1998-2001 time frame. Payments to the ODF&W (i.e.,
reimbursements to ODF&W for work performed) totaling approximately $87,000 were
made for studies related to bull trout, rainbow trout, wildlife, and game animals. Most of
this work was related to one study. ODF&W provided ldaho Power with a literature
review and bibliography of information and documents held by ODF&W that were
relevant to the description of wildlife resources and evaluation of impacts associated
with the relicensing of the HCC. ldaho Power requested that ODF&W perform this
additional work to control costs by relying on information that had already been
prepared by ODF&W, thereby avoiding the cost of recreating existing information.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 23
REQUEST NO. 22: Please provide a description of the process on how labor
costs are assigned to work orders, including direct or indirect, as well as annualized vs.
non-annualized labor.
RESPONSE TO REQUEST NO. 22: ldaho Power employees record any direct
time (hours) spent on construction activities to work orders in the Company's time entry
system each biweekly pay period. Work hours for a pay period and how an employee
has reported his/her time to work orders and FERC accounts is reviewed and approved
by each employee's supervisor.
ln addition to direct wage expense, the indirect cost of benefits provided to each
employee is charged to work orders each pay period based on a clearing rate. Clearing
rates are set to "clear" actual benefits costs incurred for the year and are closely
monitored to ensure that the total cost of benefits provided by the Company from year to
year is allocated to each employee. The established clearing rate is applied to all direct
time, including time charged to work orders. Lastly, the cost of employer paid taxes is
allocated to work orders by distributing the actual tax expenses each month
proportionally across the employee's labor transactions for the period. There is no
annualizing adjustment incorporated into the process detailed above.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 24
REQUEST NO. 23: Please provide a list showing a summary of all consultants
and attorneys (internal and external) who have performed services for the HCC
relicensing process. Please include services performed, accounts charges, and
amounts paid.
RESPONSE TO REQUEST NO. 23:The Excel workbooks (Attachment 1 and
confidential Attachment 2) on the non-confidential and confidential CDs provide a
summary of the vendors and names of internal legal counsel who have performed
services for the HCC relicensing process, by amount paid and year. To develop this
summary, ldaho Power extracted transactions charged to the 3O0-series detailed cost
element (purchased services) from the master transaction file. Attachment 1 contains
non-confidential purchased services transactions, while confidential Attachment 2
contains costs associated with internal legal fees. The confidential CD will only be
provided to those parties that have executed the Protective Agreement in this matter.
Given the volume of data and manual process required to extract and prepare
the payment detail, ldaho Power requests that Staff employ a sampling technique to
examine payments included in the master transaction file made to consultants,
attorneys, and other contractors. The Company will provide Staff with documentation to
support selections made. Lastly, certain ldaho Power personnel may be available to
provide additional context or background related to work performed by contractors if
needed. At Staffs request, the Company will make the requested documentation
available at the Company's corporate headquarters. Please contact Matt Larkin at 388-
2461 or Camilla McClusky at 388-5821 to arrange a time to review the selected
material.
The response to this Request is sponsored by Randy Henderson, Finance Team
Leader ll, ldaho Power Company.
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 25
REQUEST NO. 24: Please provide details regarding the estimation of the $20-
$30M annual licensing cost on page 10, lines 13-20, of Tim Tatum's direct testimony.
RESPONSE TO REQUEST NO. 24: The $20-30 million estimated annual spend
is based on a 2015 forecast of the expected increase to the HCC relicensing balance of
$125.8 million by 2020 ($125.8 million / 5 years). The estimate was calculated using a
2015 forecast that included future spend of $33.1 million over the remaining five years,
$92.7 million in Allowance for Funds Used During Construction, and assumed a 2020
license date. Please see the confidential Excel file provided on the confidential CD for
the detail behind the forecasted spend. While the forecast has not been updated since
2015,ldaho Power believes the estimated annual spend is still accurate.
The confidential CD will only be provided to those parties that have executed the
Protective Agreement in this matter.
The response to this Request is sponsored by Chris Randolph, Environmental
Affairs Director, ldaho Power Company.
DATED at Boise, tdaho, this 7th day of Apnl2017.
LISA D. NOR
Attorney for ldaho Power Company
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 26
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7th day of April 2017 I served a true and correct
copy of IDAHO POWER COMPANY'S RESPONSE TO THE SECOND PRODUCTION
REQUEST OF THE COMMISSION STAFF upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff
Camille Christen
Brandon Karpen
Deputy Attorneys General
!daho 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, ldaho 83703
ldaho Conservation League
Benjamin J. Otto
ldaho Conservation League
710 North 6th Street
Boise, ldaho 83702
ldaho lrrigation Pumpers Association, !nc.
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
_FAXxEmail camille.christen@puc. idaho.qov
brandon. karpen@puc. idaho.qov
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mai!
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 27
Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
c
IDAHO POWER COMPANY'S RESPONSE TO THE SECOND
PRODUCTION REQUEST OF THE COMMISSION STAFF - 28
_Hand DeliveredX U.S. Mail
_Overnight Mail
_FA)(X Email [e-mail]
hrista Bearry,lAss