Review of the Colorado FERC Pilot Project and the Hydropower Regulatory Efficiency Act Kurt Johnson Telluride Energy 970-729-5051 kurt@tellurideenergy.com September 12, 2013 NW Hydro Association Small Hydro Meeting Bend, OR
Issues for Discussion Colorado FERC Streamlining Pilot Project History of the Hydropower Regulatory Efficiency Act Key Provisions of the HREA New Conduit Hydro Exemption: Creates an offramp for conduit projects under 5 MW 2 Year Licensing. Directs FERC to explore a potential two-year licensing process for hydropower development at existing non-powered dams and closed-loop pumped storage projects. Small Hydro Exemption Increase: Increases the FERC small hydro exemption from 5 to 10 MW. Preliminary Permits: Authorizes FERC to grant developers preliminary permit extensions DOE Studies: Directs DOE to study pumped storage project opportunities as well as hydropower potential from existing conduits.
About Telluride Energy Hydro project and policy consulting Offices in Colorado and California Clients include water districts, local governments, utilities
CO FERC Pilot Program Process Applicant Role -> State Role 1. Complete pre-screen application 2. Supply requested documents 3. Wait 4. Supply supplemental information 5. Supply final documents 6. Respond to FERC requests 7. Wait 8. Supply post application docs 1. Notification of Acceptance 2. Compile draft application 3. Submit draft to resources agencies 4. Coordinate with resource agencies 5. Compile final application-ferc 6. Coordinate with FERC 7. Wait
Colorado FERC MOU Projects Wenschhof Cattle Company 23 kw Pelton - Rancher Existing irrigation conduit fed by an irrigation ditch Town of Basalt 40 kw Pelton - Municipality Existing raw water supply to treatment plant Grand Valley Irrigation Canal 185 kw Low Head Ditch Company Drop in an existing irrigation canal Harvey Gap Inlet 50 kw PAT Irrigation District Inlet canal to a reservoir Harvey Gap Outlet 400 kw PAT Irrigation District One mile of piped irrigation ditch fed by a reservoir Lake Catamount 695 kw Kaplan - Developer Rebuilt outlet of a reservoir Rio Grande Canal 140 kw Low Head Ditch Company Existing diversion dam on the Rio Grande River Grand Valley Irrigation Company 450 kw Low Head Ditch Company Drop in an existing irrigation canal
What Worked Encouraged/motivated applicants to step forward Educated applicants on the application process Removed fear Educated resource agencies on the process Assisted applicants with resources agency communication Provided a project manager to spearhead the process Provided a direct line to FERC
What Didn t Work Applicants expected a more streamlined process FERC requirements weren t reduced Post application filing requirements were unclear Consultant assistance was still required in addition to state-supported assistance
Colorado FERC Pilot Program Outcomes 26 applications into the program 9 projects completed CO program 6 projects have received FERC exemptions 2 projects have been built Wenschhof Cattle Company Town of Basalt
Wenschhof Cattle Company Feb 2010 Feb 2011 Mar 2011 Apr 2011 May 2011 July 2011 Sept 2011 Nov 2011 Design and Funding Applied to streamlined program Completed full application Submitted additional information Sent to Resource Agencies Submitted Final App to FERC FERC Exemption Granted Project constructed and commissioned
Reasons for Projects That Have Not Been Developed Harvey Gap Inlet Harvey Gap Outlet Rio Grande Canal GVIC First Street GVIC Dividers 50 kw Economic feasibility was not adequately evaluated 450 kw Feasibility depends on the construction of a water system that has not been approved 140 kw Property rights issues delayed the project 400 kw Property rights issues delayed the project 185 kw Difficulty arranging a PPA
2013 Legislative History of the HREA Congress finally found an energy source everyone likes hydropower Washington Post, August 2, 2013
Conduit Small Hydro FERC Exemption: Old Application Requirements
Conduit Small Hydro FERC Exemption: Key Criteria for New Requirements
Required Items for Inclusion in New Exemption Application Introductory Statement Explanation of Non-Federal Conduit Attest as Original Project (Not Previously Licensed) Project Information Drawings/Maps/Diagrams Applicant Verification
FERC Exemption Determination Within 15 Days FERC issues public notice regarding preliminary determination
FERC Timeline/Process
Next Steps on Two Year Licensing FERC Workshop October 2 nd, 12-4 PM (Eastern) Written comments due to FERC November 1 st Additional information at http://www.ferc.gov/media/news-releases/2013/2013-3/09-03-13-hydro.asp#.uioolj9h_xu
Thank You to Legislators for Bipartisan Leadership on the HREA Rep. Cathy McMorris-Rodgers (R-WA) Rep. Diana DeGette (D-CO)
For More FERC Information http://www.ferc.gov/industries/hydropower/indusact/efficiency-act.asp
Thank You Kurt Johnson kurt@tellurideenergy.com 970-729-5051 PO Box 1646 100 West Colorado, Suite 222 Telluride, CO 81435