Rapids relicensing

Non-federal hydro power projects in the US, including those that affect navigable waters, occupy US lands, utilise the surplus water or water power from any government dam or affect interests of interstate commerce are required to obtain an operating licence from the Federal Energy Regulatory Commission (FERC) in accordance with the Federal Power Act. The regulatory process used to licence or relicence a project is a complex, multi-year effort that typically involves the project owner, federal and state agencies, Indian tribes, other public stakeholders and FERC. The proposals for the licence are reflected in a Final Licence Application that is filed according to regulation with FERC.

FERC examines many issues in evaluating the terms and conditions under which a licence is issued, including fisheries, wildlife, cultural resources, recreation, water quality and power generation. FERC also evaluates the dam operator's record with regard to safety and operations. The overall goal is to maximize the benefits of the US’ public waterways. After the licence application has been reviewed and all regulatory requirements have been met, a new licence is typically issued for a period of 30 to 50 years. It is then the project owner, or licencee’s responsibility to meet compliance requirements.

Priest Rapids

The Priest Rapids Hydroelectric project (FERC No. 2114) consists of two hydroelectric developments – Priest Rapids and Wanapum. Located in the Northwest corner of the US on the Columbia river in Washington State, the project has a generating capacity of nearly 2000MW and is the largest hydroelectric project of its kind licenced by the FERC. The Priest Rapids project was built and is owned and operated by the Public Utility District No. 2 of Grant County (Grant PUD), a consumer-owned utility located in rural central Washington State, USA.

The current licence for Priest Rapids expires in October 2005 and through this relicensing process, Grant PUD is seeking a new 50-year licence to continue operation. The process of relicensing this project began nearly a decade ago and is the result of involvement and broad collaboration with hundreds of people, representing over 80 organisations and including federal and state agencies, tribal representatives, special interest groups and local residents.

The Final Licence Application for GCPUD was published with the help of Eureka Software, Inc., a multimedia communications firm located in Eastern Washington, who specialise in electronic publishing for hydro relicensing. Included in the Final Licence Application are the results of more than 30 studies of how to best protect and enhance natural and cultural resources, improve recreation opportunities and serve the broad public interest. The application, consisting of 39 volumes of information, studies, analysis and plans developed during the process was filed with the FERC on 29 October 2003 as a printed set and compact disc version with searchable capabilities. Grant PUD spent more than US$40M on its relicensing process over the past decade leading up to filing the final application. Licensing a hydroelectric project is a costly, complex process and licencees are constantly seeking innovative, more effective ways to meet the regulatory requirements while generating the information necessary for the FERC and others to make decisions that are in the best interest of the public. In order to file less paper copies of the final licence application than required by regulation, and supplement with electronic versions, Grant PUD received a waiver from the FERC. The searchable compact disc version of the application not only offered the FERC and all stakeholders a simple, convenient way to access the information, but it provided a more cost-effective way for the utility to disseminate the information as well since each print version cost over US$1000 compared to the compact disc version at less than US$5.

Electronic publishing

The process of developing an integrated licensing publication strategy has been refined and developed as technology emerges and digital publishing becomes more the norm.

Eureka Software has been involved in hydro-related activities since the early 1990s, applying new web and digital publishing technologies to the industry, mainly in the area of relicensing.

Beginning with a process and resource inventory of the client’s current publishing systems and staff, Eureka builds a structure to integrate existing management methods with more effective technology. A typical relicensing project may include a web site to distribute information about meetings, documents, correspondence, an intranet or bulletin board for the exchange of documents and information, development of knowledge management strategies, document preparation, training, and assistance with outside vendor selection.

GCPUD and Eureka

The goals of the Preist Rapids relicencing project were to produce a high quality, usable product in the form of an interactive CD-ROM set and a bound, printed version of the licence application and supporting documentation. The FERC regulatory process is strictly defined with strict time constraints. Deadlines, planning, and organisation were of the utmost importance. Eureka Software worked closely with Grant PUD relicensing staff to make sure the project stayed on track and was being produced in a manner that would satisfy the needs of the client and the FERC. Grant PUD is a consumer-owned utility and prudent financial decisions were important throughout the project. Producing a high volume of the printed version of the project – without assurance they would be the most effective or useable way of disseminating the information – presented a challenge.

Issues included maintaining document integrity throughout the process as many documents were received from many different sources. Finding the best file formats for both CD ROM and print without compromising the output was also a challenge. The great divide comes from a misunderstanding of pixel versus vector data as well as the proper assembly of original documents for conversion to the Portable Document Format (PDF). Each document presented its own unique challenges and a high degree of cooperation and organisation were needed to keep track of changes and quality control issues. The need to minimise file sizes was important to control the digital mass for the CD ROMs. Document integrity needed to be maintained for the printing process. The challenge of producing a document that can be used in both mediums is complex and requires a working knowledge of digital documents and conventional printing methods.

Discovering the best ways to plan and organize such a large and complex project was a huge undertaking. Eureka Software has developed and organized a tracking system for producing such a complex document. This internal tracking system eventually became the basis for ES Compliance Tracker, Eureka’s new process tracking software for managing the compliance process.

Staff needed to cooperate and maintain the tracking system which specifically described the status of a particular document or piece in the application. File sharing was conducted using a main server that was structured to mirror the process. Both the tracking system and the file architecture meant everyone knew where a document lived and what stage of the production cycle had been completed.

Several software programs were used in processing documents including Microsoft Word, Adobe Acrobat, Adobe Photoshop, and Adobe Illustrator to produce the files for the printed document, the interface and documents for the electronic version. Massive amounts of RAM memory were consumed during this project dealing with large drawings and scanned images as well as large document sizes. This required current server technology and desktop systems with enough power to process and assemble these documents.

Eureka Software’s staff provided the skill and expertise from years of working with licence applications originating with the use of a relicensing web site to publish on CD ROM the six month update to the consultation record for Chelan County PUD in 1998 as part of an experimental electronic filing in cooperation with the FERC. The web site received the Technical Achievement Award from the National Hydro Association in 2000. The process has become more streamlined as Eureka worked with different clients.

Conclusion

Electronic publishing is not just ‘pushing a button’. It requires knowledge, experience, architecture and attention to detail to ensure all documents are of the highest quality whether intended for print or an interactive CD. The GCPUD project represented its own unique set of challenges helping to evolve the management and publishing processes Eureka Software uses. The next unique hydro relicensing e-publishing challenge lies in the publication of the Draft Licence Application for the Sacramento Municipal Utility District’s Upper American River project.