20170926Staff 52-56 to PAC.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.7956
Street Address for Express Mail:
472 W.WASHINGTON
BOISE,IDAHO 83702-5918
Attorneys for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
PACIFICORP DBA ROCKY MOUNTAIN )CASE NO.PAC-E-17-07
POWER FOR A CERTIFICATE OF PUBLIC )CONVENIENCE AND NECESSITY AND )BINDING RATEMAKING TREATMENT FOR )THIRD PRODUCTION
NEW WIND AND TRANSMISSION FACILITIES)REQUESTOF THE
)COMMISSION STAFF
)TO ROCKY MOUNTAIN
)POWER
The Staff of the Idaho Public Utilities Commission requests that Rocky Mountain Power
provide the followingdocuments and information as soon as possible,but no later than
TUESDAY,OCTOBER 17,2017.
This Production Request is to be considered continuing,and Rocky Mountain Power is
requested to provide,by way of supplementary responses,additional documents that it or any
person acting on its behalf may later obtain that will augment the documents or information
produced.
Please provide answers to each question,supporting workpapers that provide detail or are
the source of information used in calculations,and the name,job title and telephone number of
the person preparing the documents.Please identify the name,job title,location and telephone
number of the record holder.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 1 SEPTEMBER 26,2017
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
REQUESTNO.52:Please provide a comprehensive list and description (purpose of the
permit,authorizing agency,etc.)of all permits and authorizations needed to site each of the four
benchmark wind projects including those required for interconnection.In addition,please
provide the following:
1.For each permit/authorization,please provide a copy of the permit application and all
documents required by the siting authority.
2.Please provide the timeframe that the permitting process will be conducted and an
estimate of the time required to obtain each permit/authorization.
3.Please provide a current status for each permit/authorization.This should include
what has been done and what is required for completion.
4.Please list any risks or mitigating factors that could potentiallydelay receiving each
authorization.
REQUESTNO.53:Please explain the overall impact to the project if the Bureau of
Land Management (BLM)determines that a full Environmental Impact Statement is required due
to cumulative impacts of the wind projects selected from the RFP.
REQUESTNO.54:Please explain the impact to the project if a lawsuit is filed due to
violation of the National Environmental Policy Act process.
REQUESTNO.55:Please provide a comprehensive list and a description (purpose of
item)of all items PacifiCorp has yet to submit/provide to the BLM in order to obtain a Notice-to-
Proceed (NTP)for each line segment of the Gateway West Transmission line included in this
case.In addition,please provide the following:
1.For each item listed above,please provide a copy of any documents necessary to
fulfill the requirements for each item submitted to the BLM.
2.Please provide the date that the item needs to be submitted to the BLM in order for
the Company to receive the NTP in time to complete construction by 2020.
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 2 SEPTEMBER 26,2017
3.Please provide a current status for each item and whether or not the item has been or
will be submitted on time.
4.Please list any risks or mitigating factors for each item that could potentiallydelay
receiving the NTP.
REQUESTNO.56:Will PacifiCorp need to obtain a new right-of-waygrant from the
BLM in order to reconstruct the 14 mile section of existing 230 kV transmission line between
Freezeout and Standpipe substations and the four miles of existing 230 kV line between Aeolus
and Freezeout substations?If not,why not?If so,please explain the authorization process that
will be required by the BLM (i.e.Environmental Assessment or a full Environmental Impact
Statement),the amount of time required to complete the process,and any risks that could delay
authorization.
DATED at Boise,Idaho,this y of September 2017.
Bran n Karpen
Deputy AttorneyGeneral
Technical Staff:Mike Louis/52-56
i:umisc:prodreq/pace17.7bkml prod req 3
THIRD PRODUCTION REQUEST
TO ROCKY MOUNTAIN POWER 3 SEPTEMBER 26,2017
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 26TH DAY OF SEPTEMBER 2017,
SERVED THE FOREGOING THIRD PRODUCTION REQUESTOF THE
COMMISSION STAFF TO ROCKY MOUNTAIN POWER,IN CASE NO.
PAC-E-17-07,BY MAILING A COPY THEREOF,POSTAGE PREPAID,TO THE
FOLLOWING:
TED WESTON YVONNE R HOGLE
ROCKY MOUNTAIN POWER ASSITANT GENERAL COUNSEL
1407 WEST NORTH TEMPLE STE 330 ROCKY MOUNTAIN POWER
SALT LAKE CITY UT 84116 1407 WN TEMPLE STE 320
E-MAIL:ted.weston pacificorp.com SALT LAKE CITY UT 84116
E-MAIL:[e-mail]
DATA REQUEST RESPONSE CENTER RANDALL C BUDGE
E-MAIL ONLY:RACINE OLSON NYE &BUDGE
[e-mail] PO BOX 1391
POCATELLO ID 83204-1391
E-MAIL:reb racinelaw.net
BRUBAKER &ASSOCIATES RONALD L WILLIAMS
16690 SWINGLEY RIDGE RD #140 WILLIAMS BRADBURY PC
CHESTERFIELD MO 63017 PO BOX 388
E-MAIL:[e-mail] BOISE ID 83701
[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ELECTRONIC ONLY
JOHN DUKE KYLE WILLIAMS
IDAHOAN FOODS BYU IDAHO
E-MAIL:[e-mail] E-MAIL:[e-mail]
ELECTRONIC ONLY ERIC L OLSEN
VAL STEINER ECHO HAWK &OLSEN
NU-WEST INDUSTRIES INC PO BOX 6119
E-MAIL:[e-mail] POCATELLO ID 83205
E-MAIL:[e-mail]
ANTHONY YANKEL BRADLEY MULLINS
UNIT 2505 333 SW TAYLOR
12700 LANE AVENUE SUITE 400
LAKEWOOD OH 44107 PORTLAND OR 97204
E-MAIL:[e-mail] E-MAIL:[e-mail]
SECRETA
CERTIFICATE OF SERVICE