20171109PAC to Staff 3rd Suppl WY-17 RMSC 2 1-12.pdf

ROCKY MOUNTAIN
POWER
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
Rocky Mountain Sheep Company 2nd Set Data Request (1-12)
Please find enclosed Rocky Mountain Power's Responses to RMSC 2nd Set Data Requests 2.1-
2.12.Also provided are Attachments RMSC 2.9 and 2.11.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Meridith Bell/WPSC me (C)
Lori L.Brand/WPSC lori.brand@wyos (W)
John Burbridge/WPSC johnkrubride@_wy_o.pav (W)
Michelle Bohanan/WPSC [e-mail] (W)
Kara Seveland/WPSC [e-mail](W)
Morgan Fish/WPSC [e-mail](W)
Dave Walker/WPSC (W)
Perry McCollom/WPSC [e-mail] (W)
Abigail C.Briggerman/WIEC [e-mail]
Patti Penn/WIEC [e-mail] (W)
Bob Pomeroy/WIEC .co_m (W)
Thor Nelson/WIEC [e-mail] (W)
Emanuel Cocian/WIEC [e-mail](W)
Nik Stoffel/WIEC [e-mail] (W)
Christopher Leger/OCA ogstop_her_.leger@wy_ogov (C)
Crystal J.McDonough/NLRA (C)
Lisa Tormoen Hickey/[e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.1
RMSC Data Request 2.1
What is the current demand for electricitywithin the State of Wyoming that will be
transmitted from the Aeolus substation to the Jim Bridger power plant?
Response to RMSC Data Request 2.1
The dispatch of individual resources in the PacifiCorp system to serve retail load,
includingload in the state of Wyoming,is not "color-coded"to specific end uses or
location.The Company dispatches its fleet of resources across its transmission system to
serve its total requirements,includingboth retail loads and wholesale sales,to provide a
least cost economic dispatch.The use of transmission is an integral part of being able to
deliver the least cost generation solution to customers across PacifiCorp's six-state
service territory,includingthe state of Wyoming.
Respondent:Kelcey Brown
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.2
RMSC Data Request 2.2
What is the current demand for electricityoutside the State of Wyomingthat will be
transmitted from Aeolus substation to the Jim Bridger power plant?
Response to RMSC Data Request 2.2
Please refer to the Company's response to RMSC Data Request 2.1.
Respondent:Kelcey Brown
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.3
RMSC Data Request 2.3
Please admit there is no immediate demand for the electricitythat will be transmitted via
the new transmission project.
Response to RMSC Data Request 2.3
Deny.Please refer to the direct testimony of Company witness,Rick T.Link,
specifically,page 3,lines 15-22,which discusses the need for the proposed Transmission
Projects.
Respondent:Joe Hoerner
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.4
RMSC Data Request 2.4
Please admit that none of the electricitytransmitted via the new transmission project is
intended for the citizens of the State of Wyoming.
Response to RMSC Data Request 2.4
Deny.The Company plans and operates its system to serve customers within all of its
state jurisdictions.System resources are used to serve system load.When placed in
service,electricitytransmitted through the new transmission project will supplement
existing system resources,will be used to serve system load,and will be used to lower net
power costs for all customers,includingcustomers in Wyoming.
Respondent:Randy Baker
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.5
RMSC Data Request 2.5
Please provide any cost analysis or feasibilitystudy concerning burial of the new
transmission project underground on either public or private lands.
Response to RMSC Data Request 2.5
Please refer to the Bureau of Land Management Final Environmental Impact Statement
Section 2.6.3 -Underground Alternatives in Chapter 2,which can be accessed by
utilizingthe followingwebsite link:
https://eplanning.blm.cov/epl-front-office/eplanning/docset_view.do?projectId=65164&currentPageId=92763&documentId=
78833
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.6
RMSC Data Request 2.6
Please provide all research,studies or analyses concerning potential impacts to the
Greater Sage Grouse and/or its habitat on private lands in the State of Wyomingfrom
construction and operation of the new transmission project.
Response to RMSC Data Request 2.6
The Company objects to the request on the basis that it is overlybroad.Without waiving
the objection,please refer to the Bureau of Land ManagementRecord of Decision
Appendix C,which can be accessed by using the followingwebsite link:
https://eplanning.blm.gov/epl-front-office/projects/nepa/65164/78832/90505/05-
AppendixC-SageGrouseMitigationPlan.pdf
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.7
RMSC Data Request 2.7
Please provide all research,studies or analyses regarding potential adverse impacts to
livestock from construction and operation of a high-voltage electrical transmission line.
Response to RMSC Data Request 2.7
The Company objects to the request on the basis that it is overlybroad.Without waiving
the objection,please refer to the Bureau of Land ManagementRecord of Decision Plan of
Development's Appendix K -Agricultural Protection Plan,which can be accessed by
using the followingwebsite link:
https://eplanning.blm.gov/epl-front-office/projects/nepa/65164/78832/90504/04-
AppendixB-PlanofDevelopment.pdf
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.8
RMSC Data Request 2.8
Please provide all surveys,research,studies,examinations,inspections,or analyses
performed on,or regarding,any real property owned by Rocky Mountain Sheep
Company in Carbon County,Wyoming.
Response to RMSC Data Request 2.8
The Company objects to the request on the grounds that it is vague and 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 Wyomingin this proceeding.Assuming the request is seeking the
information related to rights of way issues,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 waivingthe objection,survey work has consisted
only of items identified in the signed Right of Entry agreement:cultural surveys in
accordance with the State of Wyoming Historical Protection Office,wetlands surveys in
accordance with Water of the US Section 404,and cadastral surveys to identify the right-
of-way alignment on said property.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.9
RMSC Data Request 2.9
Please provide all written communications or correspondence between Rocky Mountain
Power,or any agent or representative of Rocky Mountain Power,and Rocky Mountain
Sheep Company,regarding the new transmission project.
Response to RMSC Data Request 2.9
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
Wyomingin 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 objection,please refer to Attachment RMSC 2.9,which
provides PDF Communications Summary and individual PDF documents.
Respondent:Shawn Graff
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.10
RMSC Data Request 2.10
Please provide all internal correspondence,communication or email regarding acquisition
of a right-of-wayor easement from Rocky Mountain Sheep Company,or the installation
or construction of the new transmission project on real property owned by the Rocky
Mountain Sheep Company.
Response to RMSC Data Request 2.10
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
Wyomingin 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
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.11
RMSC Data Request 2.11
Please provide all written communication or correspondence between Rocky Mountain
Power,or any agent or representative of Rocky Mountain Power,and Carbon County,
Wyoming,regarding the new transmission project,includingacquisition of the Carbon
County conditional use permit.
Response to RMSC Data Request 2.11
Please refer to Attachment RMSC 2.11,which provides the followingdocuments:
letter from Board of Carbon County Commissioners,
minutes from an Energy Gateway Transmission presentationto the Carbon County
Council of Governments,and
email request for updated company contact information.
There is currentlyno correspondence with Carbon County regarding the conditional use
permit requirements.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
November 6,2017
RMSC Data Request 2.12
RMSC Data Request 2.12
Please provide any draft or final plans or strategies implemented by Rocky Mountain
Power to mitigate,minimize,or reclaim adverse impacts to private property or
agricultural or ranching lands during construction and operation of the new transmission
project.
Response to RMSC Data Request 2.12
Please refer to the Bureau of Land Management Record of Decision Plan of
Development's Appendix Z -Environmental Protection Measures,which can be accessed
by using the followingwebsite link:
https://eplanning.blm.gov/epl-front-office/projects/nepa/65164/78832/90504/04-
AppendixB-PlanofDevelopment.pdf
Respondent:Rod Fisher
Witness:Rick Vail