20171109PAC to Staff 3rd Suppl WY-17 Peterson 1-3.pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
November 6,2017
Brandon L.Jensen
BUDD-FALEN LAW OFFICES,LLC
300 East 18th Stæd
Post Office Box 346
Cheyenne,Wyoming 82003-0346
[e-mail](C)
RE:Wyoming Docket 20000-520-EA-17
Peterson Outfitter 16'Set Data Request (1-3)
Please find enclosed Rocky Mountain Power's Responses to Peterson 16'Set Data Requests 1.1-
1.3.Also provided is Attachment Peterson 1.2.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Meridith Bell/WPSC [e-mail](C)
Lori L.Brand/WPSC [e-mail] (W)
John Burbridge/WPSC [e-mail] (W)
Michelle Bohanan/WPSC [e-mail] (W)
Kara Seveland/WPSC [e-mail](W)
Morgan Fish/WPSC [e-mail] (W)
Dave Walker/WPSC [e-mail] (W)
Perry McCollom/WPSC [e-mail](W)
Abigail C.Briggerman/WIEC [e-mail]
Patti Penn/WIEC [e-mail](W)
Bob Pomeroy/WIEC [e-mail] (W)
Thor Nelson/WIEC [e-mail] (W)
Emanuel Cocian/WIEC [e-mail] (W)
Nik Stoffel/WIEC [e-mail] (W)
Christopher Leger/OCA [e-mail] (C)
Crystal J.McDonough/[e-mail] (C)
Lisa Tormoen Hickey/[e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
Peterson Data Request 1.1
Peterson Data Request 1.1
Please provide all surveys,research,studies,examinations,inspections,or analyses
performed on,or regarding,any real property owned by Peterson Outfitters,LLC in
Carbon County,Wyoming.
Response to Peterson Data Request 1.1
The Company objects to the request on the grounds that it seeks information that is not
likelyto lead to the discovery of admissible evidence.The request does not seek
information relevant to matters properly considered by the Public Service Commission of
Wyoming in this proceeding.Rocky MountainPower is not required to demonstrate that
it has acquired or is attempting to acquire rights-of-wayfrom any individual landowner
and the Commission may not properly require such a showing by Rocky Mountain Power
as a condition of granting a certificate of public convenience and necessity in this
proceeding.Without waivingthe objection,survey work has consisted only of items
identified in the signed Right of Entry agreement:wetland surveys in accordance with
Water of the US Section 404,and cadastral surveys to identify the right of way alignment
on said property.A geotechnical bore sample was also conducted on property owned by
Peterson Outfitters,LLC with approval of landowner.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
Peterson Data Request 1.2
Peterson Data Request 1.2
Please provide all written communications or correspondence between Rocky Mountain
Power,or any agent or representative of Rocky Mountain Power,and Peterson Outfitters,
LLC,regarding the new transmission project.
Response to Peterson Data Request 1.2
The Company objects to the request on the grounds that it seeks information that is not
likely to lead to the discovery of admissible evidence.The request does not seek
information relevant to matters properly considered by the Public Service Commission of
Wyoming in this proceeding.Rocky Mountain Power is not required to demonstrate that
it has acquired or is attempting to acquire rights-of-wayfrom any individual landowner
and the Commission may not properly require such a showing by Rocky Mountain Power
as a condition of granting a certificate of public convenience and necessity in this
proceeding.Without waiving the objections,please see Attachment Peterson 1.2,which
provides the requested correspondence.
Respondent:Rod Fisher /Todd Jensen /Stuart Smith
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
Peterson Data Request 1.3
Peterson Data Request 1.3
Please provide all internal correspondence,communication or email regarding acquisition
of a right-of-wayor easement from Peterson Outfitters,LLC,or the installation or
construction of the new transmission project on real property owned by the Peterson
Outfitters,LLC.
Response to Peterson Data Request 1.3
The Company objects to the request on the grounds that it seeks information that is not
likely to lead to the discovery of admissible evidence.The request does not seek
information relevant to matters properly considered by the Public Service Commission of
Wyoming in this proceeding.Rocky Mountain Power is not required to demonstrate that
it has acquired or is attempting to acquire rights-of-wayfrom any individual landowner
and the Commission may not properly require such a showing by Rocky Mountain Power
as a condition of granting a certificate of public convenience and necessity in this
proceeding.The Company further objects to the extent the request seeks information that
is protected by attorney-client privilege and the attorney work product doctrine.
Respondent:Heidi Gordon
Witness:Rick Vail