For the hydro industry, the latest fallout from the Oroville spillway failures in February 2017 is revised engineering guidelines from the Federal Energy Regulatory Commission (FERC). One element of those new guidelines addresses requirements for the content of the Supporting Technical Information Document (STID). The FERC released their guidance in a new chapter of their Engineering Guidelines for the Evaluation of Hydropower Projects (Chapter 15) on December 16th, 2021. Chapter 15 attributes many of the enhancements to conclusions and recommendations from the Oroville Spillway Independent Forensic Team (IFT) and/or the FERC After-Action Panel (FAAP).
The most notable changes with respect to the FERC’s previous guidance on the STID include:
- Substantial additional detail regarding what information should be included in each section of the STID
- Section 9, which was previously entitled “Spillway Gates,” was expanded to include all types of gates, valves, and other reservoir control devices
- Each section of the STID provides guidance for the types of references that should be included in the Digital Project Archive (DPA), which replaces what was previously referred to as the companion DVD
If incorporated properly, these enhancements could significantly increase the value and utility of the STID by making critical information easier to find and assembling all the relevant source documents in a single, well-organized location. This would undoubtedly pay dividends during each successive Part 12D Comprehensive Assessment (CA), which includes a thorough review of the STID.
However, depending on when the original STID was developed and how often it has been updated over the years, revising a project’s STID to follow the new Chapter 15 guidelines could be a substantial effort. In some cases, it may be easier to set the original STID aside and develop an entirely new STID from scratch. It will be interesting to see how the industry navigates these changes and how the FERC enforces the new guidelines. For instance, if the revised STID outline calls for information from a study that has not been undertaken for the project, will the FERC require this study to be performed?
