The Districts convened a meeting with stakeholders (federal agencies, state agencies, conservation groups and property owners) on March 2, 2015 at which the Districts proposed that stakeholders agree to 2,000 cfs (cubic feet per second) minimum flow remaining in the Osgood Reach after diverting river flow to feed their two proposed hydroelectric plants. Flow remaining in the reach after diverting water to power plant feed is referred to as “minimum bypass flow” or “MBF”. Here is a link to a PDF of Districts’ proposal: District proposal for minimum flow Feb 2015. The following occurred at this meeting:
- Districts stated that the 2,000 cfs MBF was selected to achieve economic viability of two projects without consideration of project impacts. Districts stated that Idaho Irrigation’s hydroelectric project will be economic and New Sweden’s project will be “marginally” economic at 2,000 cfs MBF;
- Districts wanted stakeholders to agree to allow them to progressively lower the MBF below 2,000 cfs if future fish studies showed the fishery was not harmed, but never raise the MBF if studies showed 2,000 cfs harmed the fishery;
- State and federal agencies unequivocally rejected the Districts’ proposal because it called for agencies to expend their resources for years for protracted fish studies;
- Districts then proposed stakeholders agree to 2,000 cfs MBF without future adjustments;
- Districts requested that they be absolved from completing existing project impact studies or having to do additional impact studies;
- Districts polled each stakeholder individually regarding whether they would agree to 2,000 cfs MBF;
- All but one stakeholder said that their starting point for a negotiated MBF would be greater than 2,000 cfs in order to protect river habitat;
- Districts said it was in stakeholders’ interest to agree to 2,000 cfs MBF because otherwise the Districts would defend 1,000 cfs MBF to the Federal Energy Regulatory Commission (FERC) and the FERC might issue a license with a MBF less than 2,000 cfs.
The Districts followed through on their threat and requested FERC license 1,000 cfs MBF year round. Such a license would result in 1,000 cfs Osgood Reach flow throughout most of the winter. The lowest flow ever seen historically in the Osgood Reach is 950 cfs, which has occurred on only 3 days.
The lower the licensed MBF, the more river water can be divert to Districts hydroelectric projects resulting in more District revenues.
The following information sheds light on economics of the east side (Idaho Irrigation) and west side (New Sweden Irrigation) hydroelectric plants:
- Idaho Irrigation filed a request for a diversion water right with the Idaho Department of Water Resources (IDWR) before New Sweden Irrigation filed their request for a diversion water right. IDWR addresses water right requests in the order received. This means that Idaho Irrigation would have a senior diversion right over New Sweden Irrigation. Idaho Irrigation would be able to secure all of its turbine feed flow first with New Sweden taking whatever amount of water diversion remains after considering the licensed MBF.
- Districts stated in their Pre-Application Document regarding the east and west side power turbines:
- Maximum (1,000 cfs) and minimum (300 cfs) design flows are identical
- Estimated annual power at requested 1000 cfs MBF
- 9,900 MWh for Idaho Irrigation’s plant
- 8,400 MWh for New Sweden Irrigation’s plant
- Annual flow through New Sweden’s hydroelectric plant must be less than that of Idaho Irrigation otherwise annual power production would be the same.
The following is readily derived from Districts’ information:
- Districts do not require a MBF less than 2,000 cfs for both hydroelectric projects to be economically viable;
- The 1,000 cfs MBF requested by the Districts is driven by greed or is a “strawman” for purposes of negotiating a MBF of at least 2,000 cfs so both projects can be economically viable;
- Idaho Irrigation’s project is economically viable at a MBF well above 2,000 cfs;
- Adverse project impacts on public recreation are exacerbated at lower MBF (see tab “CLHP Impacts). Elimination of one of the two hydroelectric projects will reduce adverse project impacts on recreation .
- Empirical data collected by the Idaho Department of Fish and Game shows that reduction of reach flow during the winter kills juvenile trout. Elimination of one of two hydroelectric projects will reduce adverse project impacts on fish population.