20171016PAC to Staff 52-56.pdf

O O
ROCKY MOUNTAINPOWER
A DMSION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
October 16,2017
Diane Hanian
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702-5918
[e-mail](C)
RE:ID PAC-E-17-07
IPUC 3rd Set Data Request (52-56)
Please find enclosed Rocky Mountain Power s Responsesto IPUC 3rd Set Data Requests 52-56.
Also provided are Attachments IPUC 52 and 55.
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Ronald L.Williams/PIIC [e-mail](C)
Brad Mullins/PIIC [e-mail] (C)
Jim Duke/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail] (W)
Val Steiner/[e-mail] (W)
Brian C.Collins/Brubaker&Associates [e-mail] (C)(W)
James R.Smith/Monsanto [e-mail] (C)(W)
Maurice Brubaker/Monsanto [e-mail] (C)(W)
Katie Iverson/[e-mail] (C)
Eric Olsen/IIPA [e-mail] (C)
AnthonyYankel/IIPA [e-mail](C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanto [e-mail] (C)(W)
ROCKY MOUNTAIN
POWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
October 16,2017
Diane Hanian
Idaho Public Utilities Commission
472 W.Washington
Boise,ID 83702-5918
[e-mail] (C)
RE:ID PAC-E-17-07
IPUC 3rd Set Data Request (52-56)
Please find enclosed Rocky Mountain Power's Responses to IPUC 3rd Set Data Requests 52-56.
Also provided are Attachments IPUC 52 and 55.
If you have any questions,please feel free to call me at [phone].
Sincerely,
J.Ted Weston
Manager,Regulation
Enclosures
C.c.:Ronald L.Williams/PIIC [e-mail] (C)
Brad Mullins/PIIC [e-mail] (C)
Jim Duke/PIIC [e-mail] (W)
Kyle Williams/PIIC [e-mail](W)
Val Steiner/PIIC [e-mail] (W)
Brian C.Collins/Brubaker &Associates [e-mail] (C)(W)
James R.Smith/Monsanto [e-mail] (C)(W)
Maurice Brubaker/Monsanto [e-mail] (C)(W)
Katie Iverson/Monsanto -(C)
Eric Olsen/IIPA e_loßLachohawls.com(C)
AnthonyYankel/IIPA [e-mail] (C)
Randall C.Budge/Monsanto [e-mail] (C)
Thomas J.Budge/Monsanto [e-mail] (C)(W)
PAC-E-17-07 /Rocky Mountain Power
October 16,2017
IPUC 3rd Set Data Request 52
IPUC Data Request 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.
Response to IPUC Data Request 52
(1)The projects are currentlyin early stages of project development and
permitting.Many permits and authorizations cannot be obtained without
identifyingthe final project layout and design (ie SPCC,wetland impact
permitting,cultural/artifact impacts,etc.).A spreadsheet (Exhibit 52)has been
provided that outlines permits and authorizations that may be required for
project development at the Ekola Flats,TB Flats I,TB Flats II,and McFadden
Ridge II wind projects.The Exhibit includes web links to the applications
and/or guidance documents (if available).The projects are located in
Wyoming in the same,or adjoining,counties and general ecological habitat
(high plains/high desert).Therefore,the permitting efforts and authorizations
are generally similar at all projects.Permitting and authorizations
requirements may change as project layouts,designs,capacity,and/or
equipment needs evolve.
(2)As discussed above,the projects have entered various early stages of
development to meet the commercial operation date in the fourth quarter of
2020.The permitting process has begun for several action items,including the
Wyoming Industrial Siting Division application,county Conditional Use
Permits,Certificate of Public Convenience and Necessity (CPCN),and
various other permits.All required permits will be obtainedprior construction
and operations of the projects.
(3)Please see Attachment IPUC 52.
PAC-E-17-07 /Rocky Mountain Power
October 16,2017
IPUC 3rd Set Data Request 52
(4)No risks or mitigating issues have been identified that would potentiallydelay
receiving the permits or applicable authorizations for construction and
operations of the projects by Quarter 4 of 2020.
Recordholder:Travis Brown
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
October 16,2017
IPUC 3rd Set Data Request 53
IPUC Data Request 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.
Response to IPUC Data Request 53
The Company objects to this request as requiring speculation,as requesting
development of a legal opinion,and as requesting disclosure of information
protected by the attorney-client privilege or the attorney work product doctrine.
Without waivingthese objections,the Company responds as follows:
There is no federal nexus for the benchmark wind projects or any other wind
projects that would trigger the National Environmental Policy Act known at this
time.
Recordholder:Rod Fisher
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
October 16,2017
IPUC 3rd Set Data Request 54
IPUC Data Request 54
Please explain the impact to the project if a lawsuit is filed due to violation of the
National Environmental Policy Act process.
Response to IPUC Data Request 54
The Company objects to this request because it is speculative,requests a legal
opinion requests disclosure of information protected by the attorney-client
privilege or the attorney work product doctrine.Without waiving these
objections,the Company responds as follows:
It is unclear if this data request is regarding the new wind projects or the
transmission.As stated in response to IPUC Data Request 53,there is no NEPA
required for the wind projects.On November 13,2013,the Bureau of Land
Managementissued its final action on the Gateway West transmission project
with the issuance of their Record of Decision.This decision was appealed by
three parties to the Interior Board of Land Appeals (IBLA).IBLA finally issued
their ruling and denied all three appeals.These appeals dealt with issues not
related to the proposed transmission segments,so it is unlikely any of the parties
will file a lawsuit in U.S.District Court.
Recordholder:Rod Fisher
Sponsor:Rick Vail
PAC-E-17-07 /Rocky Mountain Power
October 16,2017
IPUC 3rd Set Data Request 55
IPUC Data Request 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.
(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 potentially
delay receiving the NTP.
Response to IPUC Data Request 55
(1-3)Please refer to the United States (U.S.)Bureau of Land Management (BLM)
website with Record of Decision (ROD)and Final Environmental Impact
Statement (FEIS).
(4)Please refer to Attachment IPUC 55.
Recordholder:Rod Fisher
Sponsor:Rick Vail
i httos://eplanning.blm.cov/epl-front-office/eplanning/planAndProjectSite.do?methodName=dispatchToPatternPage&currentPageld=92763
PAC-E-17-07 /Rocky Mountain Power
October 16,2017
IPUC 3rd Set Data Request 56
IPUC Data Request 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.
Response to IPUC Data Request 56
The existing four miles of 230 kilovolt (kV)line between Aeolus and Freezeout
was authorized in the November 2013 United States (U.S.)Bureau of Land
Management(BLM)Record of Decision (ROD).PacifiCorp will obtain a new
right-of-waygrant from the BLM for this segment of the 230 kilovolt (kV)
transmission line.On July 31,2017,a preapplication meeting was held and a
preliminaryapplication was submitted August 23,2017.The BLM has agreed to
the Company's approach to prepare an applicant prepared Environmental
Assessment (EA).The schedule calls for the draft EA in December 2017,and a
decision record and grant in February 2018.The necessary field surveys are
underway according to plan and schedule.
Recordholder:Rod Fisher
Sponsor:Rick Vail