20210225Annual Report 2020.pdf

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AnD|CORPCornp.ry
LISA D. NORDSTROM
Lead Counsel
I [e-mail]
VIA ELECTRONIC FILING
February 25,2021
Jan Noriyuki, Secretary
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714)
PO Box 83720
Boise, ldaho 83720-0074
RE: Case No. IPC-E-16-32 - ldaho Power Company's Application for a
Determination of Hells Canyon Complex Relicensing Costs through 2015
as Prudently lncurred - Annual Report for 2020
Dear Ms. Noriyuki:
Pursuant to Order No. 34031 and the agreement between ldaho Power Company
("ldaho Powe/'), ldaho Public Utilities Commission ("Commission") Staff, and the ldaho
lrrigation Pumpers Association, ldaho Power submits its third annual report as set forth
in the Hells Canyon Complex Relicensing Expenditures Annual Report Outline filed with
the Commission in this case on December 27,2018.
lf you have any questions regarding this report, please contiact Regulatory
Consultant Courtney Waites at [phone] or [e-mail].
Sincerely,
X*!.(,a,+,-*,
Lisa D. Nordstrom
LDN:slb
Enclosurescc: Teni Carlock (w/encls.)
Donn English (w/encls.)
3Em.
lnD cotPcompany
HELLS CANYON COMPLEX RELICENSING EXPENDITURES
2O2O ANNUAL REPORT
February 25,2021
ln Order No. 34031 issued in Case No. IPC-E-16-32 on April 13,2018, the ldaho Public
Utilities Commission ("Commission") approved a Stipulation between ldaho Power Company
("ldaho Powe/' or "Company"), Commission Staff, and the Idaho 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 identiff 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 wil! be recuning with each annual report and specified some
items exclusive to the 2018 Annual Report, including an explanation of ldaho Powe/s efforts to
enhance accounting records to better identiff how expenditures are necessary to relicensing
efforts. Because the Company reported on improvements to the accounting records in the 2018
Annual Report, this report includes only those items agreed to by the Signing Parties for recuning
discussion.
BACKGROUND
The HCC, located on the Snake River where it forms the border between ldaho and
Oregon, provides approximately 68 percent of Idaho 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.
Hells Canyon Complex Relicensing Expenditures 2020 Annual Report - Page 1
Clean Water Act 6 401 Certification
S 401 certification from both ldaho and Oregon is required before FERC can issue itsfinal
license. ldaho Powerfiled water quality certification applications with the states requesting that
each state certiff that any discharges from the project comply with applicable state water quality
stiandards. The Company worked with the states to identify measures that wi!! 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 approvalof the State of ldaho. \n2016, ldaho Powerfiled
a petitionl with FERC requesting that FERC resolve the conflict between Oregon's and ldaho's
conditions and declare that the Federal Power Act pre-empts the Oregon state law. FERC
issued an ordeP dismissing ldaho Powe/s petition as premature. ldaho Power then sought
rehearing, which FERC denied as well. ln early 2018,ldaho Power filed with the D.C. Circuit
Court an appeal3 of FERC's order denying ldaho Power's petition requesting that FERC resolve
the conflict with Oregon and ldaho with respect to the Company's S 401 certification while the
govemors of Oregon and ldaho continued to negotiate a potential resolution of the disputed
issues.
ln April 2019, the states of ldaho and Oregon, along with ldaho Power, reached a
settlement that requires ldaho Power to increase the number of Chinook salmon it releases each
year through expanded hatchery production. Additionally, ldaho Power is required to fund a
totalof $12 million of research and waterquality improvements in the HCC overa 2}-year period
following the issuance of the license. These measures are in exchange for Oregon removing
the fish passge requirement from the Oregon S 401 certification for at least the first 20 years
after final license issuance. The estimated combined cost of the mandated water quality
improvements and expanded hatchery production is $20 million over the first 20 years of the
new license term. ln May 2019, Oregon and ldaho issued final $ 401 certifications. These
certifications have been submitted to FERC as part of the relicensing process.
ln July 2019, three third-party lawsuits were filed against the Oregon Department of
Environmental Quality in Oregon stiate court challenging the Oregon S 401 certification based
on fish passage, water temperature, and mercury issues associated with the Snake River and
HCC. Two of the lawsuits were @nsolidated, and the Company intervened in that lawsuit. ldaho
Power is closely monitoring the other pending lawsuit. No parties challenged the ldaho S 401
certification. ln December2019, ldaho Powerfiled an Offerof Settlementwith FERC requesting
specific language be included in the new HCC license based upon settlement among the
Company, ldaho and Oregon. FERC has received several comments opposing the Offer of
1 Petition of ldaho Power Company for Declaratory Order on Preemption and Request for Expedited Action, P- 1971-
079 (filed November 23,2016).
2 ldaho Power Company, 158 FERC 1161 ,048 (2017) (January 1 9 Order).
s ldaho Power Company v. FERC, Case No. 18-1046 (D.C. Cir).
Hells Canyon Complex Relicensing Expenditures 2020 Annual Report -Page 2
Settlement and its decision relating to the Offer of Settlement is pending as of the date of this
report.
Endanqered Species Act Consu ftation
ln September 2007, in connection with the issuance of its final Environmental lmpact
Statement ("ElS"), FERC notified the Department of Commerce National Oceanic and
AtmosphericAdministration's NationalMarine Fisheries Service ('NMFS') and the United States
Fish and Wildlife Service ('USFWS") of its determination that the licensing of the HCC was likely
to adversely affect ESA-listed species, including the bull trout and fall Chinook salmon and
steelhead, under the NMFS's and USFWS's jurisdiction and requested that the NMFS and
USFWS initiate formal consultation under Section 7 of the ESA on the licensing of the HCC.
Each of the NMFS and USFWS responded to FERC that the conditions relating to the Iicensing
of the HCC were not fully described or developed in the final EIS as the measures to address
the water quality effects of the project were yet to be fully defined by the S 401 certification
process. The NMFS and USFWS therefore re@mmended that formal consultation under the
ESA be delayed untilthe S 401 certification process is completed.
SUMMARY OF ACTIVITIES IN 2O2O
In July 2O2O, ldaho Power submitted to FERC its supplement to the final license
application that incorporated the settlement agreement reached between ldaho and Oregon on
the $ 401 certifications, updated the 2003 license application, and provided feedback on
proposed modification of the 2007 final EIS for the HCC. The July 2020 filing also contained an
updated cost analysis of the HCC and a requestfor FERC to issue a SO-year license and initiate
a supplemental NEPA process at FERC. ln addition, the Company prepared draft biological
assessments in consultation with the USFWS and the NMFS and filed those with FERC in
October 2020. The draft biological assessments provide the necessary information to the
USFWS and the NMFS to issue their biologica! opinion as required under the ESA.
FUTURE RELICENSING ACTIVITIES
Now that the states have issued their final $ 401 certifications, FERC will likely need to
provide a supplemental NEPA analysis given the HCC final EIS was issued in 2007. ldaho
Power anticipates FERC will issue a public notice of the process and timeline for the HCC in
2021 which will indicate whether or not a revised supplemental NEPA analysis will be provided.
Following a NEPA decision, FERC wil! conduct the forma! ESA consultation with the NMFS and
the USFWS, which had been delayed untilthe S 401 certification processwas completed. FERC
cannot issue a license for the HCC until ESA consultation on the licensing project is complete.
ACCOUNTING DETAIL
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 align the project descriptions
with specific HCC relicensing activities. As part of collaborative efforts to develop a process for
Hells Canyon Complex Relicensing Expenditures 2020 Annual Report - Page 3
filing annual reports, the Signing Parties to the Stipulation in Case No. IPC-E-16-32 identified
the detail to 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. They agreed
that 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 identiff the outstanding issue with which each expenditure is associated: $
401 certification, ESA consultation, NEPA, or all HCC relicensing efforts.
The Company has included all expenditures incurred since December 31,2015 - the
point in which ldaho Powe/s expenditures covered in the prudence request in Case No. IPC-E-
16-32 concluded, in the summary of the HCC relicensing expenditures included as Attachment
1 . ln addition, Attiachment 2 includes a table that summarizes allHCC relicensing expenditures
incurred during the 1997 through 2020 time period. Please note, in 2020, the Company has
identified two work orders that needed to be recategorized based upon evaluation of the project
types; one was categorized as relicensing and was determined to be compliance-related and
therefore removed from the HCC relicensing expenditures reportswhile the otherwas previously
excluded from the HCC relicensing expenditures reports when the project should have been
classified as relicensing related. Due to the two work order type conections, the expenditures
reported in prior years (2016-2019) have changed.
As can be seen on Attachment2,the majority of the $30.7 million in2020 costs is AFUDC
on HCC relicensing expenditures. The following summarizes the projects associated with HCC
relicensing expenditureworkordersdetailed in Athchment 1 comprising the majorityof the 2020
costs:
Mercurv Studies and Lesal Costs. Similar to 2019, the Company spent an
additional $1.4 million on water temperature studies in support of CWA S 401
certifications and incuned $3.2 million in outside legalfees associated with legal
advice on the CWA S 401 certifications and associated Iegal challenges for both
stiates and for ongoing relicensing matters before FERC.
a
a Snake River Stewardship Prooram Database and Reportino Tool. A new item
included in the HCC relicensing expenditures work order detail is the reporting tool
required to support implementiation of the Snake River Stewardship Program.
Work to develop the required technology that wil! be functional when a license is
issued and deployed to monitor and maintain all aspects of the mitigation program
began in 2019, for a total of $1 .5 million, and continued in 2020, with expenditures
of approximately $1 million. The work order type associated with this project was
the work order mentioned earlier that was not classified as relicensing related
when first established so the expenditures did not appear on the HCC relicensing
expenditures work order detail previously provided.
HCC Sediment Proqrams. Expenses incuned for developing a sediment
monitoring plan and the fall Chinook gravel monitoring plan increased to
approximately $865,000 in 2020. Under these plans, collection and analysis of
data will occur to quantiff the amount of sediment entering, moving through and
o
Hells Canyon Complex Relicensing Expenditures 2020 Annual Report - Page 4
Ieaving the 60 miles of the river system from the Hells Canyon Dam to the
confluence with the Salmon River. Data collection includes surveying the river
channelwith a multibeam sonar, Light Detection and Ranging (LiDAR) surveys of
sandbars, underwater photography of fall Chinook spawning gravels, measuring
sediment inputs from tributaries, water velocity mapping, and taking gravel and
sand samples. Data analysis includes mapping changes in sediment volumes
and particle sizes and relating these changes to the local hydraulics, estimating
the sediment load from tributary streams, and calculating the modem and historic
sediment loads to the system. The work also supports the aquatic, water quality
and cultural resource studies and is required under the final ElS.
Snake River Stewardshio Proqram Development. ldaho Power's expenditures
associated with the watershed enhancement program, which are primarily
AFUDC charges as program development is nearly complete, were approximately
$850,000. Although the costs appear significantly higher than the prior year
expenditures of $167,403, 2019 included a one-time conection of $915,000 for
expenses that were more appropriately classified to a separate relicensing work
order, and othenrise consists primarily of AFUDC, similar to 2O2O expenditures.
Bull Trout Prooram. The Company spent approximately $825,000 for continued
evaluation of the status of bull trout populations in the HCC and to understand the
potential effects of the HCC on those populations. This work involves population
assessments in the tributaries to the HCC, including Pine Creek, lndian Creek and
the Wildhorse River and in the mainstem Snake River below the HCC. The bull
trout program supports the preparation of a biological assessment, including those
assessmentsfiled with FERC in October 2020,thatwill be used by FERC to initiate
formal consultation with the USFWS. ldaho Power anticipates these expenses
will continue until FERC issues a new license as they are a @mponent of the
supplemental environmental analysis required under NEPA and for ongoing ESA
consultiation.
White Sturseon Proqram. Also in 2020, administration of the white sturgeon
program resulted in approximately $555,000 of expenses. The program is being
developed in consultation with state management agencies, tribes, and other
stakeholders to support relicensing information needs relative to the status of
white sturgeon populations in the Snake River, including below the HCC.
Recently, focus of the progmm has been on factors that influence successfu!
reproduction of white sturgeon and how the operations of the HCC may affect that
success. This work will support FERC's supplemental NEPA environmental
evaluation.
Rofl-Up Work Orders. Finally, $18.9 million of the 2020 expenditureswas primarily
associated with the Allowance for Funds Used During Construction on the HCC
relicensing rcll-up work orders.
Hells Canyon Complex Relicensing Expenditures 2020 Annual Report - Page 5
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CONCLUSION
ldaho Power continues to work with ldaho and Oregon on measures to provide
reasonable assurance that any discharges from the HCC will comply with applicable state water
quality standards and associated measures identified in the final $ 401 certifications, and
continues to cooperate with the USFWS, NMFS, and FERC in an effort to address ESA
@ncems. Once the final EIS and ESA consultation is complete, FERC can issue a license. The
Company is unable to predict the timing of issuance by FERC of any license order, which could
occur as early as2022, but believes issuance is more likely in 2023 or thereafter.
Hells Canyon Complex Relicensing Expenditures 2020 Annual Report - Page 6
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 25th day of February 2021, I served a true and
correct copy IDAHO POWER COMPANY'S HELLS CANYON COMPLEX
RELICENSING EXPENDITURES 2020 ANNUAL REPORT upon the following named
parties by the method indicated below, and addressed to the following:
Gommission Staff
Karl KIein
Deputy Attomey General
ldaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A(83714)
Boise, lD 83720-0074
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
P.O. Box 7218
515 N.27th Street
Boise, lD 83702
Dr. Don Reading
6070 Hill Road
Boise, lD 83703
ldaho lrrigation Pumpers Association, lnc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Ave., Suite 100
PO Box 61 19
Pocatello, lD 83205
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mai!
_Overnight Mail
_FAXX Email [e-mail]
_Hand Delivered
_U.S. Mail
_Overnight Mail
_FAX
-[ Email [e-mail]
Anthony Yankel
127OO Lake Ave., Unit 2505
Lakewood, OH 441OT
_Hand Delivered
_U.S. Mail
Overnight Mail
_FAXX Email [e-mail]
Stephanie Buckner, Executive Assistant
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. IPC-E-16-32
IDAHO POWER COMPANY
ATTACHMENT 1
TO HELLS CANYON GOMPLEX RELICENSING
EXPENDITURES 2O2O ANNUAL REPORT
(Excel Spreadsheet attached to Emaill
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
cAsE NO. IPC-E-16-32
IDAHO POWER COMPANY
ATTAGHMENT 2
TO HELLS CANYON COMPLEX RELIGENSING
EXPENDITURES 2O2O ANNUAL REPORT
lExcel Spreadsheet attached to Emaill
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