20190228Annual Report 2018.pdf

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An IDACORP Company
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LISA D. NORDSTROM
Lead Counsel
I [e-mail]
VIA HAND DELIVERY
February 28,2019
Ms. Diane Hanian
Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, ID 83720-0074
RE Case No. IPC-E-16-32 - ldaho Power Company's Application for a
Determination of Hells Canyon Complex ("HCC") Relicensing Costs
through 2015 as Prudently Incurred - Annual Report for 2018
Dear Ms. Hanian
Pursuant to Order No. 34031 and the agreement between ldaho Power Company
("!daho Power"), ldaho Public Utilities Commission ("Commission") Staff, and the ldaho
lrrigation Pumpers Association, ldaho Power submits its first annual report as set forth in
the Hells Canyon Complex Relicensing Expenditures Annual Report Outline filed with the
Commission in this docket on December 27,2018.
lf you have any questions regarding this report, please contact Senior Regulatory
Analyst Courtney Waites at [phone] or [e-mail].
Sincerely,
X,-C.A-ru,*,*-
Lisa D. Nordstrom
LDN/KKI
HELLS CANYON qOMPLEX RELTCENSTNG EXPENpTTURES
2018 ANNUAL REPORT
February 28,2019
ln Order No.34031, the ldaho Public Utilities Commission ("Commission") approved a
Stipulation between ldaho Power Company ("ldaho Power" or "Company"), Commission Staff,
and the ldaho lrrigation Pumpers Association (collectively referred to as "Signing Parties"),
providing for interested parties to (1) collaborate on a process for filing future Hells Canyon
Complex ('HCC") Relicensing Expenditures annual reports, including the content of the report,
and (2) work to identify the detail requested to be contained within a work order description to
allow for the reporting of work orders by projects specific to HCC relicensing work.
Throughout 2018, the Signing Parties collaborated on both items and reached an
agreement on an outline detailing the content to be incorporated in future annual reports. The
outline identified those items that will be recurring with each annual report and specified some
items exclusive to the 2018 Annual Report, including an explanation of ldaho Power's efforts to
enhance accounting records to better identify how expenditures are necessary to relicensing
efforts.
BACKGROUND
The HCC, located on the Snake River where it forms the border between ldaho and
Oregon, provides approximately 68 percent of ldaho Power's hydroelectric generating nameplate
capacity and 32 percent of its total generating nameplate capacity. ln July 2003, the Company
filed an application with the Federal Energy Regulatory Commission ("FERC") for a new license
in anticipation of the July 2005 expiration of the then-existing license. Since the expiration of that
license, ldaho Power has been operating the project under annual licenses issued by FERC. The
Company's efforts towards relicensing the HCC have spanned nearly three decades yet there are
three issues that must be resolved in advance of a license issuance: (1) the Clean Water Act
("CWA") S 401 certification ('S 401 certification"), (2) The Endangered Species Act ("ESA')
consultation, and (3) the potential for a revised supplemental National Environmental Policy Act
('NEPA') analysis.
ldaho Power must receive $ 401 certification from both ldaho and Oregon. The Company
has filed water quality certification applications with the states requesting that each state certify
that any discharges from the project comply with applicable state water quality standards. The
Company has been working with the states to identify measures that will provide reasonable
assurance that discharges from the HCC will adequately address applicable water quality
standards. ln the 2016 S 401 certification application process, Oregon required ldaho Power to
comply with fish passage and reintroduction conditions. ldaho's water quality certification,
however, provides that ldaho Power shall take no action that may result in the reintroduction or
establishment of spawning populations of any fish species into ldaho's waters without consultation
with and express approval of the State of ldaho. ln 2016, ldaho Power filed a petition with FERC
requesting that FERC resolve the conflict between Oregon and ldaho's conditions and declare
that the Federal PowerAct pre-empts the Oregon state law. FERC issued an order denying ldaho
Power's petition. ldaho Power sought rehearing, which FERC denied as well. A discussion of
ldaho Power's efforts in2018 to obtain $ 401 certifications is contained below.
After the states issue their final $ 401 certifications, FERC will likely need to provide a
supplemental NEPA analysis given the HCC final Environmental lmpact Statement was issued in
2007. Following a NEPA decision, FERC will conduct formal ESA consultation with the
1
Department of Commerce National Oceanic and Atmospheric Administration's National Marine
Fisheries Service ('NMFS') and the United States Fish and Wildlife Service ("USFWS'). The
consultation, including issuance of biological assessments will evaluate impacts the HCC may
have on ESA-listed species, including bulltrout, fall Chinook salmon, and steelhead. The NMFS
and USFWS, who have jurisdiction of the ESA-listed species, recommended that formal
consultation under the ESA will be delayed until the S 401 certification process is completed.
FERC cannot issue a license for the HCC until both states have issued water quality certifications
under $ 401 of the CWA and ESA consultation on the licensing project is complete.
SUMMARY OF ACTIVITIES IN 2018
ln February 2Ol8,ldaho Power filed with the D.C. Circuit Court an appeal of FERC's order
denying ldaho Power's petition requesting FERC resolve the conflict with Oregon and ldaho with
respect to the Company's $ 401 certification, which is pending. ln 2018 the governors of Oregon
and ldaho continued to work to negotiate a potential resolution of the disputed issues. As of June
2018, the states had not resolved their ditferences, requiring ldaho Power to again withdraw and
resubmit its $ 401 certification applications in both states.
ln December 2018, the states of ldaho and Oregon, along with ldaho Power, reached a
proposed settlement that requires ldaho Power to increase the number of Chinook salmon it
releases each year through expanded hatchery production. Additionally, ldaho and Oregon will
require ldaho Power to fund a total of $12 million of research and water quality improvements in
the HCC over a 29-year period following the issuance of the license. These measures are in
exchange for Oregon removing the fish passage requirement from the Oregon $ 401 certification
for at least the first 20 years after final license issuance. The combined cost of the mandated
water quality improvements and expanded hatchery production is $20 million over the term of the
new license. ldaho and Oregon $ 401 certifications were released for public comment in
December 2018. Following the public comment period, which closed in February 2019,ldaho
Power anticipates the states will evaluate the comments and draft final $ 401 certifications, which
must be completed by June 2019 for the current cycle.
ldaho Power continues to work with ldaho and Oregon in the development of measures
to provide reasonable assurance that any discharges from the HCC will comply with applicable
state water quality standards so that appropriate water quality certifications can be issued for the
project, and the Company continues to cooperate with the USFWS, NMFS, and FERC in an effort
to address ESA concerns.
ACCOUNTING DETAIL IMPROVEMENTS / CHANGES
ldaho Power's request in Case No. IPC-E-16-32 included a prudence review of HCC
relicensing expenditures incurred for nearly 20 years, from 1997 through December 31,2015.
During their extensive review and audit of the expenditures, Commission Staff requested the
Company ensure that future reviews of accounting detail better aligned the project descriptions
with specific HCC relicensing activities. As part of collaborative efforts on a process for filing
annual reports, the Signing Parties worked to identify the detail requested be contained within a
work order description in the Company's accounting system to allow for the reporting of work
orders by project specific to HCC relicensing work.
All 1997 relicensing charges were written to one work order. ln 1998, the Company
upgraded its accounting system whereby the work order project identification ("1D") description
field allowed for more characters to better describe the work order's activity. At that time, and
through the early 2000s, ldaho Power began writing separate work orders for specific types of
2
activities, but in many cases new work orders were written annually. ldaho Power's current
process is to write separate work orders for specific types of activities and those work orders
remain open until the work is complete. Each work order is assigned a budget lD. The budget
lD allows the Company to further categorize the expenditures into broader HCC relicensing
efforts. For example, the work order project lD with a description titled HCC Watershed
Enhancement Program Development has a budget lD of HCC Snake River Stewardship Program
('SRSP') Development. The budget lD gives the Company the ability to quickly identify all
projects associated with a specific effort, in this example, the HCC SRSP Development efforts.
As part of the annual report, ldaho Power will compile a list of all budget lD and work order
project lDs specific to HCC relicensing expenditures incurred over the reporting period. The
Company will also identify the outstanding issue for which the expenditure is associated: $ 401
certification, ESA consultation, NEPA, or all HCC relicensing efforts. Because the reporting of
detailed expenditures commences with the 2018 annual report, ldaho Power has included all
expenditures incurred since December3l ,2015 -the point in which the Company's expenses
covered in the prudence request in Case No. IPC-E-16-32 concluded. The summary of the HCC
relicensing expenditures incurred over the reporting period is included as Attachment 1. ln
addition, Attachment 2 includes a chart that summarizes all HCC relicensing expenditures
incurred during the 1997 through 2018 time period.
2016 HCC Relicensinq Expenditures. As can be seen in Attachment 1, ldaho Power
incurred $28.2 million in HCC relicensing expenses in 2016. With respect to activities in 2016,
over half the expenditures were associated with two items: $3.5 million with the Bayha lsland
research project and $3.1 million in outside legal fees. ln addition, the Company spent
approximately $t.0 million each on water temperature studies for $ 401 certification and
watershed enhancement program development. The largest of the expenditures, or $13.7 million,
are associated with the HCC relicensing roll-up work orders which primarily contain Allowance for
Funds Used During Construction ("AFUDC") for 2016. The roll-up work orders, one each for the
Brownlee ($6.9 million), Hells Canyon ($4.7 million), and Oxbow dams ($2.2 million), include
those costs associated with relicensing efforts that have been completed in prior years.
The Bayha lsland Research Project expenditures of $3.5 million were required to develop
processes for implementing ldaho Power's SRSP, including the Company's proposal and
potential cost efficiencies. The SRSP is intended to address the causes of elevated water
temperatures and other water quality concerns in the Snake River through a watershed-scale
restoration program that will increase shade and water velocity, decrease water temperatures and
aquatic algae proliferation, and provide improved habitat. ln 2016, approximately seven acres of
riparian enhancement conditions were constructed and planted at Bayha lsland.
The majority of the outside legal fees incurred in 2016 was for legal advice on the CWA S
401 certification for both ldaho and Oregon. ln addition, ldaho Power received counsel and
support seeking and litigating the site-specific criteria, navigating the hydro-relicensing process in
Oregon, advice on relicensing with an emphasis on tribal law, and guidance on water rights for
the HCC.
ln 2016, the Company spent approximately $960,000 on an ongoing collaborative study
with the U.S. Geologic Survey and ldaho Department of Environmental Quality to understand the
effects of the HCC on methyl mercury in fish. The focus in 2016 was to understand how mercury
is being methylated and transported in the HCC. The study is critical to gathering scientific
information to develop future mercury mitigation plans. ln addition, approximately $1.1 million of
expenditures were incurred to develop an administrative and reporting application and associated
3
tools to meet the Company's commitments under the SRSP compliance management and
reporting requirements.
2017 HCC Relicensinq Expenditures.Tolal 2017 HCC relicensing expenditures were
$19.6 million. Similar to 2016, the majority of the activity expenditures were associated with
continued work on the watershed enhancement program development and collaborative water
temperature studies to understand the effects of the HCC on methyl mercury in fish. The
Company incurred $3.4 million in outside legal fees in 2017 for continued legal counsel on the
CWA S 401 certification for both ldaho and Oregon. As can be seen at the end of lhe 2017
expenditures, a total of $16.9 million was associated with the HCC relicensing roll-up work orders,
primarily AFUDC. Finally, an adjustment of $8.1 million was made to record the reclassification of
expenditures as a result of Order No. 34031, reducing the total HCC relicensing expenditure
balance.
2018 HCC Relicensinq Expenditures. ldaho Power incurred approximately $28.6 million
in expenses in 2018. More than $1 .5 million and $1 .2 million was spent on continued watershed
enhancement program development and collaborative water temperature studies, respectively.
Another $3.3 million in outside legal fees associated with legal advice on the CWA S 401
certification for both ldaho and Oregon and for relicensing matters before FERC. Also in 2018,
the Company incurred expenses conducting testing of reasibility and the associated costs of
converting approximately 420 acres of cultivated agricultural land from surface, gravity irrigation
to pressurized sprinkler irrigation. This will reduce sediment and nutrient loading to the Snake
River and is associated with ldaho Power's efforts to obtain S 401 certification. The conversion
of the 420 acres of cultivated agricultural land occurred in 2018 and is a component of the
approximately $t.0 million of expenses associated with the Grand View lrrigation Upgrade project.
Finally, $16.7 million of the 2018 expenditures was primarily associated with AFUDC on the HCC
relicensing roll-up work orders.
CONCLUSION
After the public comment period closes in February 2019 for the ldaho and Oregon $ 401
certifications, ldaho Power anticipates the states will evaluate the comments and draft final $ 401
certifications by June 2019 for the current cycle. ldaho Power continues to work with ldaho and
Oregon in the development of measures to provide reasonable assurance that any discharges
from the HCC will comply with applicable state water quality standards so that appropriate water
quality certifications can be issued for the project. Likewise, ldaho Power continues to cooperate
with the USFWS, NMFS, and FERC in an effort to address ESA concerns. The Company is
unable to predict the timing of issuance by FERC of any license order but estimates it will occur
no earlier lhan 2022.
4
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
GASE NO. IPC-E-16-32
IDAHO POWER COMPANY
ATTAGHMENT 1
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BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E -16-32
IDAHO POWER COMPANY
ATTACHMENT 2
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 28th day of February 2019 I served a true and
correct copy IDAHO POWER COMPANY'S ANNUAL HELLS CANYON RELICENSING
REPORT FOR 2018 upon the following named parties by the method indicated below,
and addressed to the following:
Commission Staff
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 lrrigation Pumpers Association, Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ldaho 83205
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXxEmail [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
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Anthony Yankel
12700 Lake Avenue, Unit 2505
Lakewood, Ohio 44107
_Hand Delivered
_U.S. Mail
_Overnight Mail
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Towell,
b
Assistant
_Hand Delivered
_U.S. Mail
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