20230215Bi-Annual Report.pdf

February 15, 2023

VIA ELECTRONIC DELIVERY

Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
1131 W. Chinden Blvd
Building 8 Suite 201A
Boise, ID 83714

Re: CASE NO. PAC-E-21-01
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER
FOR APPROVAL OF THE TRANSFER OF THE LOWER KLAMATH
HYDROELECTRIC PROJECT GENERATING FACILITIES

I. BACKGROUND
On January 14, 2021, PacifiCorp, (the “Company”), filed an application with the Idaho
Public Utilities Commission, (“Commission”), requesting an order approving the Property
Transfer Agreement, (“Transfer Agreement”), between the Company and the Klamath River
Renewal Corporation, (“Renewal Corporation”), with a determination that the property disposition
is in the public interest. The Transfer Agreement provided for the transfer of four hydroelectric
dams; J.C. Boyle, Copco No. 1, Copco No. 2, and Iron Gate, (collectively the “Lower Klamath
Project”), as well as approximately 8,000 acres of real and personal property associated with the
dams from PacifiCorp to the Renewal Corporation.
On July 8, 2021, the Commission issued Order No. 35097; approving the Transfer
Agreement, authorizing the Company to create a regulatory asset for any remaining plant balances
after the transfer, and requiring PacifiCorp to file bi-annual reports with the Commission on the
RECEIVED
2023 February 15, 4:38PM
IDAHO PUBLIC
UTILITIES COMMISSION
status of the license transfer with the Federal Energy Regulatory Commission, (“FERC”), and any
additional capital investments on the Lower Klamath Project.
Pursuant to Order No. 35097 PacifiCorp hereby submits its semi-annual status report on
the license transfer along with new capital expenditures and the December 31, 2022, plant balance
of the Lower Klamath Project. The report covers the period of July 1, 2022, through
December 31, 2022.
II. BI-ANNUAL REPORT
As previously reported, on June 17, 2021, FERC issued an order1 approving PacifiCorp’s
application to transfer the license for the Lower Klamath Project, FERC Project No. 14803, to the
Klamath River Renewal Corporation, the State of Oregon, and the State of California (the
“Co-Licensees”). Transfer of the license was to be effective upon transfer of the title of the
properties under the Lower Klamath Project to the Co-Licensees and the acceptance by the
Co-Licensees of a FERC license surrender order for the project.
During this reporting period, FERC made substantial progress with its review of the license
surrender application and FERC issued a final environmental impact statement (“EIS”) for the
license surrender and decommissioning application on August 28, 2022. The final EIS mirrored
the conclusions in the draft EIS that was issued in February 2022, and concluded that while the
proposed action would have some significant adverse effects, it would also provide significant
benefits and was therefore the preferred alternative. With environmental review completed, FERC
turned its attention to completion of consultation under Section 106 of the National Historic
Preservation Act. After consultation with the Klamath River Renewal Corporation, affected tribes,
and the State Historic Preservation Officers for Oregon and California, FERC issued a
programmatic agreement that was acceptable to all parties. The Klamath River Renewal

1 PacifiCorp, Order Approving Transfer of License, 175 FERC ¶ 61,236 (2021), Issued June 17, 2021, Project Nos.
2082-062, 14803-000, 14803-004, FERC Accession #: 20210617-3060.
Corporation, tribes, and State Historic Preservation officers executed this agreement in early
November 2022.
FERC approved the license surrender application at its regular meeting on
November 17, 2022, and issued the license surrender order2 on the same date. Following FERC’s
action, the Co-Licensees formally accepted the FERC surrender order and executed the necessary
steps with PacifiCorp to complete transfer of the project license and real property, which was
effective on December 1, 2022.
PacifiCorp is obligated under the terms of the Klamath Hydroelectric Settlement
Agreement to continue to operate and maintain the Lower Klamath Project in compliance with the
existing FERC license and other regulatory requirements until the Lower Klamath Project is
disconnected from the electrical grid and no longer benefitting customers with generation
produced from the facilities. This operation and maintenance obligation is formalized in an
amended and restated Operational and Maintenance Agreement between PacifiCorp and the
Co-licensees that went into effect on December 1, 2022, concurrent with the transfer of the license.
This contract will remain in place with respect to each facility until generation from the facility in
Lower Klamath Project ceases. The Klamath River Renewal Corporation plans to begin dam
removal activities in 2023 and to complete the removal of the dams in 2024. At this time,
PacifiCorp anticipates that generation from the Lower Klamath Project facilities will cease at the
end of 2023.
III. CAPITAL EXPENDITURES
The Lower Klamath Project’s net book value, electric plant in-service less accumulated
depreciation reserve balances as of December 31, 2022, along with the annual depreciation

2 PacifiCorp, Order Modifying and Approving Surrender of License and Removal of Project Facilities, 181 FERC ¶
61,122 (2022), Issued November 17, 2022, Project Nos. 2082-063, 14803-001, FERC Accession #: 20221117-3021.
expense and regulatory asset balance are summarized in Table 1. Amortization of the regulatory
asset has been completed.
Table 1. Lower Klamath Project Net Book Value – December 31, 2022
Description Total Idaho
Electric Plant In-Service $ 100,657,562 $ 5,573,711
Accumulated Depreciation $ (94,874,527) $ (5,253,487)
Net Book Value $ 5,783,035 $ 320,224

Annual Depreciation Expense $ 1,092,217 $ 60,479
Re ulator Asset (Full Amortized as of 12/31/2022) $ 0

PacifiCorp’s total capital expenditures, made to support the continued operation of the
Lower Klamath Project, transferred to electric plant in-service between July 1, 2022, through
December 31, 2022, was $2,456,369.56. This total includes projects initiated prior to calendar year
2022 that were transferred to electric plant in-service during the reporting period. Of the
$2,456,369.56 transferred to electric plant in-service through December 31, 2022, only
$727,893.55 was for new 2022 capital projects (See Table 2 for project detail).

Table 2. Lower Klamath Project Capital Additions Placed In-Service in 2022
Projec Project Description (* 2022 Project) Amount ($)
CITC/2019/C/603 Wireless Bridge Replacemen $ 41,223.67
HKCA/2016/C/007 Iron Gate Hatchery Replace Recirc System $ (7,537.05)
HKCA/2019/C/005 Copco Waterline Section Replacement $ 5.74
HKCA/2021/C/002 Copco 1 Station Service Breakers Replace $ 177,712.22
HKCA/2021/C/009 IGH Raceway Headbox Low Level Alarm Upg ade $ 1,962.80
HKCA/2021/C/011 IGH Supplemental Water Supply Pump $ 141,950.35
HKCA/2021/C/017 Copco 21 Brake Rotor Refurbishmen $ 31.95
HKCA/2021/C/019 Copco 2 Roadway Bridge Refurbishmen $ 145,387.16
HKCA/2021/C/020 Klamath CA Road Refurbishment $ 263,986.69
HKCA/2021/C/022 Copco 1 Tailrace Level Senso $ 10,429.74
HKCA/2022/C/008 Copco 1 Common PLC Cabinet Components * $ 5,287.46
HKCA/2022/C/009 Copco 2 Powerhouse HVAC * $ 21,231.77
HKCA/2022/C/010 IKL-Iron Gate Dam Weather Station * $ 4,518.82
HKCA/2022/C/011 Copco 2 Office Building HVAC * $ 35,756.89
HKCA/2022/C/013 Klamath, CA Rec. Facilities Decommission * $ 112,499.92
HKCA/2022/C/014 Copco 2 Wood Stave Flowline Refurbishmen * $ 105,377.33
HKCA/2022/C/015 Iron Gate Hatchery Fish Pump * $ 107,962.85
HKCA/2022/C/018 Iron Gate Hatchery Housing Upgrades * $ 146,048.62
HKCA/2022/C/019 Iron Gate Hatchery Facility Upgrades * $ 88,465.47
HKOR/2017/C/006 JC Boyle Tailrace Stop Logs $ 6.61
HKOR/2020/C/008 Copco 2 Refurbish Wood Stave flowline $ 9.82
HKOR/2021/C/001 JC Boyle CSIR Mandated Improvements 2020 $ 240,557.22
HKOR/2021/C/006 JC Boyle Traveling Screen Rebuild $ 247,706.19
HKOR/2021/C/009 JC Boyle Road Refurbishmen $ 82,725.73
HKOR/2022/C/003 JC Boyle Canal Road Stabilization * $ 57,408.76
HKOR/2022/C/004 JC Boyle TIV Hydraulic Cylinder Pedestal * $ 35,755.54
HLEW/2020/C/055 Surveillance Camera Replacement 2020 $ 69,168.75
HPOR/2020/C/001 Elec / Instrument / Comm 2020 $ 5,078.68
HPOR/2020/C/002 Facilities 2020 $ 2,271.62
HPOR/2021/C/002 Facilities 2021 $ 27,379.46
HPOR/2021/C/005 Mechanical 2021 $ 4,520.47
HPOR/2021/C/008 Hydro Vehicles 2021 $ 273,898.19
HPOR/2022/C/002 Facilities 2022 * $ 2,136.98
HPOR/2022/C/007 Small Tools 2022 * $ 2,716.49
HPOR/2022/C/010 Elec / Instrument / Comm 2022 * $ 2,726.65
Total $ 2,456,369.56

Any informal inquiries may be directed to Mark Alder, Idaho Regulatory Manager at
[e-mail] or by phone at [phone].

Very truly yours,

Joelle R. Steward
Senior Vice-President of Regulation and Customer Solutions