a few Excerpts

from the 2019 Draft IWIA report and the 2016 Klamath Comprehensive Agricultural Power Plan

Comments due date EXTENDED to 12/2/2019

***Public comment for irrigation power cost reports, H&N 11/10/19.

Klamath River Basin America’s Water Infrastructure Act Affordable Power Measures Report/AWIA

https://www.usbr.gov/mp/kbao/docs/usbr-klamath-basin-awia-apm-draft-report-nov-07-2019.pdf

p 28 Chapter 3 Historical Power Costs for Irrigation and Drainage in the Upper Klamath River Basin, and more current Costs

p 35: These alternatives were subjected to a rigorous screening process and then ranked into three separate tiers based upon a combination of factors including economics, environmental impacts, potential regulatory issues, and consistency with the KBRA.

p 45: Identifying the Affordable Power Measures, "large-scale solar PV facilities could help replace a portion of - or perhaps all of - the approximately 180 MW of capacity and associated energy that PacifiCorp will lose when it retires and removes four hydroelectric dams located on the Klamath River.

p 46: Siting Considerations: "A 200 MW solar PV facility in the Upper Klamath Basin would require approximately 2,400 acres of land."

p 47: Anticipated Net Power Cost Savings: "1) the cost of constructing and maintaining the facility, and 2) the value derived from the generation output and how that value is monetized and distributed to covered water users in the form of either direct, or indirect benefits."

P 48:
...locating new utility-scale solar PV generation in the Basin might also provide locational benefits to PacifiCorp by helping to replace the hydroelectric generation that will be lost when PacifiCorp removes its four dams on the Klamath River.

p 51  "In Oregon there are no payments for Excess Energy deliveries made by the customer to the utility"

p 52: "the terms and conditions of the programs are subject to change, and 2) PacifiCorp’s retail irrigation rate tariffs are also subject to change."

p 54  The three main constraints associated with renewable energy investments outside the Upper Klamath Basin are: 1) risk, 2) equitable distribution of benefits to covered water users, and 3) and public perception...s, the development of any new power generating facilities is always subject to multiple regulatory permitting processes, the outcome of which is always subject to some level of uncertainty and/or potential unexpected costs. Also, the electric utility transmission interconnection process for new generating facilities (of any type) can be very involved and time consuming as well.

p55   The expected returns on an out-of-Basin investment in renewable energy are subject to a number of uncertainties including, but not necessarily limited to: 1) the specific structure of the investment vehicle, 2) long-term capital financing rates, 3) future Federal, State and Local tax policies, 4) future Federal, State and Local environmental policies including programs to reduce Green House Gas emissions, 5) Pacific Northwest regional electric utility load growth rates, and 6) future state-level renewable portfolio standards.33

p 59  PacifiCorp has implemented Pilot Time-of-Use Service programs that are available to a limited group of its irrigation customers located both in Oregon and California.36 In Oregon the Time-ofUse rate tariff is referred to as Schedule 215 and in California the Time-of-Use tariff is Schedule PA-115. Currently, participation in both pilot programs has been limited by PacifiCorp to a small number of irrigation customers (100 in Oregon and 25 in California)...

p 61  While PacifiCorp’s Pilot Time-of-Use tariffs provide an opportunity for irrigation customers to reduce their power costs, such reductions are not guaranteed.... Large-scale Time-of-Use programs have the potential to disrupt water deliveries in the Klamath Irrigation District and the Tulelake Irrigation District to an unknown degree, and to result in increased operational spills that increase the need for pumping (primarily at D Plant) and attendant power costs.

p 66   W. Of the six sites, the CAPP concluded that the installation of a 3.8 MW hydropower facility at Keno Dam appeared to be the most economically feasible alternative, in part due to the year-round flows available at this particular site. The CAPP Report did not identify any low-head hydro plant development sites in the California area of the Klamath Basin.42
    KBC NOTE: the problem with the Keno Dam option is, those who voted against PacifiCorp continuing to honor their low power rater promised (long ago, at cost power for irrigators in exchange for free regulated (by dams) power coming from Klamath Project water), are the same NGO's who have sued against and lobbied against Klamath Irrigator power and water, and have vowed to destroy Keno Dam as soon as they destroy the other 4 Klamath River Hydroelectric dams.

p 68  KENO  "To be considered as a Qualifying Facility, a hydropower facility requiring a new diversion must demonstrate that there is no adverse effect on the environment, including recreation and water quality, pursuant to Title 18 of the Code of Federal Regulations (CFR) §292.208.

p 70  "... power generated at the (Keno) dam(s) could possibly be sold to other Pacific Northwest regional utilities through a long-term purchased power agreement at negotiated rates.

p 76  "While end-use PacifiCorp irrigation customers have an opportunity to reduce their overall power costs by voluntarily taking service under Schedule 741, such savings are not guaranteed. In fact, depending upon the specific terms and conditions that apply to a customer’s power purchase made from a non-PacifiCorp entity, the customer’s overall total power costs could be higher than what they would have paid under PacifiCorp’s standard Schedule 41 irrigation tariff. In addition, short-term wholesale power prices in the Pacific Northwest tend to be very volatile; customers therefore need to be aware that when they commit to a purchase at a specific price for a specified time period with a third-party power supplier or retail aggregator, there is no guarantee that the price will remain the same for a future purchase period. Another potential challenge is that irrigation-related loads are very seasonal in nature and, in addition, can vary due to prevailing weather conditions."

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https://www.usbr.gov/mp/kbao/programs/docs/capp-iair-final-rpt-02-04-2016.pdf
Klamath Comprehensive Agricultural Power Plan - CAPP Objectives from 2016 report

p 37: "CAPP Objectives The CAPP was established to plan and implement an affordable power program for the Upper Klamath Basin, defined as the Klamath Project and upstream Off-Project area, in close alignment with the PWMP of the KBRA, and in collaboration with the KBRA PWMP management entity, the Klamath Basin Power Alliance (KBPA). The objectives of the PWMP are to provide affordable electricity to: • “Allow efficient use, distribution, and management of water within the Klamath Reclamation Project and the National Wildlife Refuges, and facilitate the return of water to the Klamath River as part of the implementation and administration of the OnProject Plan • Implement the Water Use Retirement Program and Off-Project Water Settlement • Realize objectives of the Fisheries Restoration Program • Provide power cost security to assist in maintaining sustainable agricultural communities in the Upper Klamath Basin” The PWMP “includes measures and commitments based on a delivered power cost target that will be at or below the average cost for similarly situated Reclamation irrigation and drainage projects in the surrounding area….” (KBRA 2010)

p 39" Authority: "The primary authority to undertake the CAPP study is the Enhancement Act. In addition, although not a party to the KBRA, the U.S. Department of the Interior (DOI) has expressed its intent to the signatory parties to take actions consistent with the KBRA that are consistent with the agency’s existing legal authorities and the appropriations available for such purposes."

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