Denver Water is Colorado’s oldest utility; it maintains a large network of reservoirs, pipelines, and treatment plants that deliver water to 1.5 million people in the state’s largest city and surrounding suburbs. Denver Water also operates multiple hydroelectric plants that generate energy as stored water is released through dams.

In 2018, the utility determined it needed to replace the electrical instrumentation and controls system and an existing turbine and generator at Strontia Springs Reservoir. A decision to replace the equipment was made because of the age and obsolescence of the system, the risk of equipment failure, and the need to comply with the latest design and safety standards.

Strontia Springs Reservoir stores water from the South Platte River and diverts it into a 3.4-mile tunnel under the Rocky Mountains to the Foothills Water Treatment Plant.

We helped Denver Water complete an Application for Exemption of Small Hydroelectric Power Project from Licensing. This was done in lieu of filing an application to relicense the project. Denver Water’s original 40-year license for the project was set to expire in 2023.

In its application, Denver Water proposed to increase the capacity of the project from 1,087 kilowatts (kW) to 1,250 kW. Under federal regulations, the Federal Energy Regulatory Commission (FERC) is authorized to exempt small hydroelectric projects like Strontia Springs with an installed capacity of 10 megawatts (MW) or less from licensure.

Our Environmental team helped write the application and completed supporting documents in about eight months. The application consisted of a project overview and details about the proposed construction and power generation. It also included a description of the expected environmental impacts from construction and the operation of the project and how Denver Water would mitigate the impacts on the environment.

We coordinated with Denver Water’s project engineers on a set of drawings that showed the structures and equipment associated with the proposed expansion to the FERC project boundary.

Our team assisted Denver Water’s environmental and engineering teams with public outreach and helped host a joint stakeholder meeting and site visit. We supported consultations with multiple agencies, including the U.S. Forest Service, U.S. Fish and Wildlife Service, Colorado Parks and Wildlife, and the Colorado Department of Public Health and Environment. We also helped Denver Water consult with the Colorado State Historic Preservation Officer on behalf of FERC.

Olsson e-filed the final application for exemption on behalf of Denver Water in January 2019. FERC issued an order granting exemption from licensing on July 2, 2020. Exemption orders from FERC are issued in perpetuity.

We are now working with Denver Water to address some of the administrative provisions of the order. An exemption order does not remove FERC’s jurisdiction over a project pursuant to the Federal Power Act and federal implementing regulations, but it does afford applicants an expedited regulatory process compared to the licensing process.