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Coumbia Basin JUN 29 2016 Banks Lake App.Pdf Generation from Irrigation 457 1st Avenue NW Bus: (509) 754-2227 P.O. Box 219 Fax: (509) 754-2425 Ephrata, WA 98823 June 29, 2016 ELECTRONIC FILING The Honorable Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, N. E. Washington, D. C. 20426 Re: Banks Lake Pumped Storage Project FERC No. 14329-000, Application for Extension of the Preliminary Permit and Sixth Six-month Progress Report Dear Secretary Bose: The Federal Energy Regulatory Commission (FERC) issued the preliminary permit for Columbia Basin Hydropower’s1 (CBHP) Banks Lake Pumped Storage Project, FERC No. 14329 (Project) on August 22, 2013 with an effective date of August 01, 2016. The current preliminary permit expires on July 31, 2016. CBHP requests a two-year extension of the preliminary Permit to July 31, 2018. Supporting information is provided below, as well as within the attached Preliminary Permit Amendment Application as required under 18CFR §4.82. This Application for Extension of the Preliminary Permit serves also as the Sixth Six-month progress report. Background Six-month progress reports for this proposed hydroelectric project were submitted on January 9, 2014; July 18, 2014; January 22, 2015; July 8, 2015 and January 15, 2016. Each of these progress reports, along with this filing, details CBHP’s studies and consultations necessary to determine the feasibility of the project and to support an application for a license. Preferred Alternative for Analysis The preliminary permit identifies two potential alternatives for development at Banks Lake. Through investigations already completed and as reported in the Fourth and Fifth progress reports, July 8, 2015 and January 15, 2016 respectively, CBHP determined that Alternative 2 was not practical for a pumped storage project. CBHP has no plans to conduct further investigations or evaluations of Alternative 2; therefore, all additional analyses and consultations will focus on ‘Alternative 1’ only. 1 Columbia Basin Hydropower filed a name change and updated general office location with FERC on July 10, 2015. 1 Documentation of Progress Consultation with Bureau of Reclamation and Bonneville Power Administration In addition to the consultations and site visits previously reported in the progress reports, CBHP met on April 18, 2016 in Portland, OR with officials including BPA Vice President Kieran Connolly, Reclamation’s Regional Director Lorri Lee and Deputy Regional Director Terry Kent. At that meeting, Reclamation and BPA expressed their concerns regarding the Project but agreed to a cooperative effort by CBHP, Reclamation and BPA to model the proposed project’s operations to determine compatibility with the Banks Lake and Lake Roosevelt operational constraints. Subsequent to that meeting, Reclamation and BPA issued a letter to CBHP formalizing their concerns and agreeing to cooperate with the modeling effort (May 19, 2016, PN-1600, ADM 1.10, Attachment A). That letter also discussed the problem of duplicative regulatory jurisdiction by both FERC and Reclamation for the development of the Project. CBHP again met with Reclamation and BPA on May 23, 2016 in Boise, ID. That meeting included a full presentation of Kleinschmidt’s Preliminary Feasibility Report. That presentation (Attachment B) had been requested by Regional Director Lee at the conclusion of the April 18 meeting in Portland. Much of the agenda dealt with how best to get the modeling effort underway. BPA suggested potentially using a model previously developed by HDR Engineering, Inc.2 as a tool to alleviate the need to develop an entirely new model. The HDR model was discussed in the First Six Month Progress Report. At the meeting’s conclusion a working group with representatives of Reclamation, BPA and CBHP was appointed to investigate the feasibility of applying the HDR model to this task and to otherwise develop a modeling work plan. Regulatory Jurisdiction At all five of CBHP’s meetings with Reclamation and BPA, the topic of regulatory jurisdiction by both FERC and Reclamation for the development of this project was discussed. Currently, CBHP’s understanding is that Reclamation will have jurisdiction for the Lake Roosevelt portions of the development and FERC will have jurisdiction for the Banks Lake and North Dam portions of the project. This situation will require that CBHP obtain both a Lease of Power Privilege from Reclamation and a federal hydropower license from FERC. While CBHP is of the opinion that Reclamation should have the overall federal jurisdiction since the entire proposed development will be situated on or near facilities owned, controlled and operated by Reclamation, it nonetheless recognizes FERC authority and the requirement to proceed with the FERC process. One of the primary reasons CBHP is petitioning for this extension is because it must run parallel proceedings to develop the Project; consequently, additional time (and expense) is necessary to deal with the requirements of the duplicative jurisdictions. CBHP notes that in its May 19, 2016 letter, Reclamation pledges to use the Regional Director’s discretionary authority to attempt to coordinate the timelines for the Lease of Power Privilege process with the FERC licensing process. Deputy Regional Director Kent reaffirmed this during the May 23 meeting at Boise. 2 “Hydroelectric Pumped Storage for Enabling Variable Energy Resources within the Federal Columbia River Power System” – September 30, 2010 for Bonneville Power Administration by HDR Engineering, Inc. 2 Lease of Power Privilege Application Currently, CBHP plans to submit a Lease of Power Privilege application following FERC’s approval of this preliminary permit extension application. The timing of the application will be determined in consultation with Reclamation. Project Awareness and Marketing and Communication with Interested Parties Since a pumped storage project at Banks Lake would be a regional power feature, coordination with regional power interests is fundamental. Additionally, the scale of the Project requires a team to finance and to construct. As reported in the Fifth Six Month Progress Report, CBHP met with public and private northwest utilities, power marketers, industry groups and regulators including: . Northwest Power and Conservation Council . Pacific Northwest Utilities Conference Committee . Washington Utilities and Transportation Commission . Energy Northwest . Washington Department of Commerce/State Energy office . Puget Sound Energy . Avista Utilities . EDF Renewable Energy . Tacoma Public Utilities . Snohomish County PUD Since that last Progress Report, CBHP has also met with: . Shell Energy Pacific . Northwest National Laboratory . Iberdrola Renewables . Powerex (B. C. Hydro) . Portland General Electric . United States Department of Energy . FERC . Pacific Northwest Delegation (see Attachment C) Consultations with Stakeholders and other Interested Parties During the most recent six-month period CBHP has initiated a series of consultations with natural resource agencies, tribes, communities and other organizations that may be stakeholders or interested parties in the Banks Lake and Lake Roosevelt areas. These include: May 9, 2016 –The cities of Grand Coulee, Elmer City, Electric City and Coulee Dam. This consultation was part of a public meeting that is a periodic meeting of the Mayors of the four cities where they review common issues. In addition to the four Mayors, other city staff, the press and a citizen were present. May 11, 2016 –Grant County Planning Department. This meeting was with the Planning Director. A subsequent meeting with the Board County Commissioners is being planned. 3 May 12, 2016 –U.S. Bureau of Reclamation. This meeting was in a different context than the previously reported joint meetings with Reclamation and BPA. Reclamation’s Deputy Regional Director and Regional Power Manager, who had participated in the joint meetings with BPA, were present at this meeting also. Also attending were management and staff from Grand Coulee Dam, the Columbia Basin Project/Ephrata Field Office and the Columbia-Cascades Area Office. May 12, 2016 –U.S. Fish and Wildlife Service - Ecological Services May 16, 2016 –Washington State Department of Fish and Wildlife May 16, 2016 –Yakama Nation – This meeting was with staff biologists for the Tribe, not with tribal officials. May 17, 2016 –National Oceanic and Atmospheric Administration Fisheries – National Marine Fisheries Service May 17, 2016 –State of Washington Department of Ecology – Water Quality Program May 25, 2016 –Grant County Public Utility District. The purpose of this meeting was twofold, Grant PUD has facilities in the Banks Lake area and also has a contractual right of first refusal to any future generating projects that CBHP develops within Grant County. May 26, 2016 Washington State Parks. Steamboat Rock State Park is located near North Dam. June 16, 2016 – Grand Coulee Dam Area Chamber of Commerce Additionally, meetings are being scheduled for early August with the Spokane Tribe, Colville Tribe, and National Park Service. Meeting summary notes can be found in Appendix A of the Pre-Application Document filed on June 27, 2016 (see below). Similar stakeholder consultation meetings are being planned over the next several months with the Spokane Tribe of Indians, the Colville Confederated Tribes, the City of Coulee City and the Department of Interior’s National Park Service. Pre-Application Document (PAD) CBHP submitted a Notice of Intent, Request for TLP, and a Pre-Application Document
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