Idaho Power Company Responses to Comments U.S. ARMY CORPS OF ENGINEERS—COE1 Hells Canyon Complex Page 1 Responses to Comments Idaho Power Company U.S. Army Corps of Engineers—COE1 Page 2 Hells Canyon Complex Idaho Power Company Responses to Comments U.S. Army Corps of Engineers—COE1 Hells Canyon Complex Page 3 Responses to Comments Idaho Power Company U.S. Army Corps of Engineers—COE1 Page 4 Hells Canyon Complex Idaho Power Company Responses to Comments RESPONSE TO COMMENT COE1-1 Comment noted. Please see Exhibit B for more information regarding IPC’s proposal for flood control requirements in the license application. RESPONSE TO COMMENT COE1-2 The flood control routine incorporated into the CHEOPS operations model uses the U.S. Army Corps of Engineer’s (ACOE) 1998 modified procedure. This methodology is presented in Exhibit B. The flood control target elevations calculated by the model are based on observed flows through the HCC, providing a theoretical drawdown of Brownlee Reservoir during this period. This theoretical drawdown is not influenced by day-to-day influences or human intervention. By establishing this theoretical operation, other reservoir operation scenario comparisons can be made on a consistent basis. It is not IPC’s intention to change the general flood control requirements for the HCC in the new license. IPC is currently working with Chan Modini of the ACOE’s Hydrologic Engineering Branch (in Portland, OR) to develop an updated flood control article for the new license. The article would be based on the 1998 modified procedure for determining the flood control draft at Brownlee Reservoir. The modified procedure generally maintains the same level of flood control that is in the current license. In recent discussions with the ACOE about their HCC DLA comments, the ACOE indicated that winter flood control would be needed infrequently, if at all; would best be handled on a case-by-case basis; and would not necessarily need to be part of the license article. If language for a flood control article is completed before submittal of the FLA, it will be included therein. RESPONSE TO COMMENT COE1-3 In the summer of 1988, the ACOE agreed that 6,500 cfs was the safe flow for navigation on the Hells Canyon reach of the Snake River. Although 5,000 cfs is the license minimum flow at Johnson Bar, IPC has voluntarily maintained a minimum flow of 6,500 cfs since 1988, except for a few very short periods for adverse operating conditions and special relicensing-related flow studies. IPC proposed a normal minimum operating flow of 6,500 cfs in the DLA, which until just recently was considered safe for navigation by the ACOE. In Section VI–Water Control Plan from the ACOE’s Water Control Manual (revised 1993) for the HCC, the ACOE stated: 6.06 OPERATION FOR NAVIGATION. River Flows Required For Navigation. The Corps of Engineers has interviewed most river boat operators using the Snake River above Lewiston, Idaho, to gain the benefit of their navigation experience in establishing the reasonably safe, minimum navigable flow for the reaches above and below the mouth of Salmon River. Engineering personnel familiar with open-river navigation have accompanied the mail boat operator from Lewiston to Johnson’s Bar Landing to observe the operating conditions experienced with various river discharges. The July 1988 field investigation indicated that more optimum jet boat operating conditions are experienced when the minimum navigable flow is limited to Hells Canyon Complex Page 5 Responses to Comments Idaho Power Company 6,500 cfs for the Snake River above its confluence with the Salmon River. However, more experienced jet boat operators can navigate the river, if necessary, when the flow at Johnson’s Bar is 5,000 cfs. Article 43 of the Federal Power Commission license allows Idaho Power Company to reduce the river flow at Johnson’s Bar to 5,000 cfs during periods of low flow or for normal minimum plant operations. When it becomes apparent that minimum flows must be reduced below requirements for safe navigation, the Idaho Power Company will advise the Corps of Engineers and downstream interests as far in advance as possible. In order to maintain navigable flows below Johnson’s Bar Landing for as much of the time as possible, releases for power will be coordinated with navigation schedules during low flows. This will be accomplished so that navigable flows can be maintained for certain days of the week, most desirable for navigation interests, as determined from time to time, with less than navigable flows for the other days of the week. The Corps of Engineers Reservoir Control Center (RCC) will confer with the Idaho Power Company and navigation interests in formulating and coordinating such schedules. Due to the recent low flow conditions, IPC had requested a variance from the13,000 cfs Lime Point license flow requirement. In 2001 and 2002, IPC, in cooperation with the ACOE and the Northwest Professional Passenger Vessel Association (NWPPVA), developed and coordinated minimum flow release schedules that were in the best interest of power generation and navigation. The minimum flow schedules consisted of providing timed releases of 8,500 cfs. These timed pulses met upstream and downstream needs for the commercial navigation community, while still maintaining the normal operating minimum flow of 6,500 cfs and allowing IPC to retain as much inflow as possible to use for generating electricity during heavy load periods. While these flow schedules did put constraints on the operation of the HCC, the ACOE agreed with IPC that these timed flow pulses were an effective balance between the need for power generation and navigation and did not greatly harm the overall public interest. IPC has worked with the ACOE and the commercial navigation community to provide increased flows during certain hours of the day when the commercial traffic on the river is at its highest. It is critical that IPC have the lowest minimum flow possible during light load periods in order to conserve Brownlee Reservoir storage for as long as possible—especially in low-flow years—for use during the highest demand periods. Congress established the Hells Canyon National Recreation Area (HCNRA) in 1975. At the time the HCNRA Act was passed, the HCC license contained essentially the same restrictions (minimum flow and ramp rate) on Snake River flows that are proposed in the DLA. In the HCNRA Act, the U.S. Forest Service (USFS) was charged with maintaining the quality of the recreational experience that made the HCNRA special. Since 1975, the USFS has allowed many commercial outfitters to add and operate boats larger than any used in 1975. The largest commercial boats currently operating on the Hells Canyon reach of the Snake River—some measuring 44 feet long with a 12-foot-wide bottom—began to appear in the late 1980s and early 1990s. Since their inception, these large boats have been able to operate successfully with the 6,500-cfs minimum flow, as evidenced by their continuous operation. However, over the past two low-flow years, the commercial operators have not been comfortable Page 6 Hells Canyon Complex Idaho Power Company Responses to Comments operating with a minimum flow of 6,500 cfs. IPC believes that this is due in part to the size of the boats that are presently being built and the insufficient skill level of some of the boat pilots. Based on discussions that IPC has had with commercial boaters, there are plans to construct even larger boats than are currently in operation. If there is a problem associated with very large boats and navigation, it is not due to changes in operations by IPC. IPC maintains that the USFS did not fulfill its congressional mandate of maintaining the recreational experience. The increase in the number of larger boats has introduced navigation issues that did not exist in the recreational experience that Congress mandated the USFS to maintain. Higher minimum flow requirements for recreational navigation should be prohibited under the FPA because the FERC and the ACOE are without authority to impose indirectly that which has been directly prohibited by Congress in the HCNRA Act, such as establishing a “flow requirement of any kind” or a rule which “limits, constricts or conflicts” with existing uses of the river for power purposes. See Appendix 2 for further discussion of the HCNRA Act. IPC is currently working with Ed Kim in the ACOE’s Walla Walla District, the Northwest Professional Passenger Vessel Association, and other interested parties to determine the new navigation criteria for the FLA. If language for a navigation article is completed before submittal of the FLA, it will be included therein. RESPONSE TO COMMENT COE1-4 IPC provides data transmittal of Brownlee Reservoir inflow, Hells Canyon outflow, and Brownlee Reservoir elevation via the ACOE’s CROHMS system each weekday. Every effort is made to transmit the data by 06:30 Pacific Standard Time, although there are some instances when the data is unavailable to IPC personnel by that time. IPC provides expected Brownlee Reservoir elevation and a daily average Hells Canyon outflow forecast for five days into the future on both its website and through its toll-free recreation phone number. This forecast is updated each weekday afternoon. The toll-free recreation number is (800) 422-3143. The web address is http://www.IdahoPower.com. IPC will work with the ACOE to provide additional project data electronically. RESPONSE TO COMMENT COE1-5 Hourly temperature and TDG data from the forebay of Brownlee Dam and the Hells Canyon Dam tailrace are not available for real-time reporting at this time.