20171218PAC to Staff Attachment WY Anadarko Set 1 (1-16).pdf

ROCKY MOUNTAINPOWER
A DIV1SION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
December 5,2017
Constance E.Brooks
Danielle Bettencourt
C.E.BROOKS &ASSOCIATES,P.C.
5445 DTC Parkway,Suite 940
Greenwood Village,Colorado 80111
[e-mail]
Paul Kapp,WSB #5-2267
Sundahl,Powers,Kapp &Martin,LLC
1725 Carey Avenue
P.O.Box 328
Cheyenne,Wyoming 82003
[e-mail] (C)
RE:Wyoming Docket 20000-520-EA-17
Anadarko 16'Set Data Request (1-16)
Please find enclosed Rocky Mountain Power's Response to Anadarko 16'Set Data Request 1-16.
Also provided is Attachment Anadarko 1.14.
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)
Brandon L.Jensen/RMSC [e-mail] (C)
Lisa Tormoen Hickey/[e-mail] (C)
J.Kenneth Barbe/[e-mail]
Roxane Perruso/TOTCO [e-mail]
Jane M.France/TOTCO [e-mail] (C)
Lisa Christian/TOTCO [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.1
Anadarko Data Request 1.1
Please describe the width of the transmission line right-of-wayanalyzed under
Rocky Mountain Power's Application and the width of the impacted area.
Response to Anadarko Data Request 1.1
The right-of-way(ROW)width for the 500 kilovolt (kV)transmission line is 250 feet.
The ROW width for the 230 kV transmission line is 125 feet.The majority of disturbance
will occur within the ROW with the exception of access roads,temporary use areas such
pulling and tensioning sites at angle structures and multi-purpose yards.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.2
Anadarko Data Request 1.2
Please identify the number of natural gas,oil,or water pipelines and utilities that are
located within the right-of-wayor will intersect the proposed transmission line right-of-
way.
(a)With respect to said pipelines or other utilities,please describe the additional
measures that Rocky Mountain Power will undertake to mitigate the effect of
electromagnetic corrosion or effects of alternate current.
Response to Anadarko Data Request 1.2
Rocky Mountain Power objects to the data request on the basis that the information
Anadarko seeks is not likelyto lead to the discovery of admissible evidence.In certificate
of public convenience and necessity ("CPCN")proceedings,the Wyoming Commission
is authorized to determine whether "the present or future public convenience and
necessity will require"the proposed construction and to address conflicts between
utilities that may arise in connection with the grant of a CPCN for the construction of
new utility facilities or the enlargement of a utility's service territory.W.S.§37-2-
205(c)provides,
The commission shall have power,after hearing involvingthe financial
ability and good faith of the applicant and the necessity of additional service
in the community,to issue said certificate as prayed for,or to refuse to issue
the same,...and may attach to the exercise of the rights granted by said
certificate such terms and conditions as in its judgment the public
convenience and necessity may require.
The Wyoming Supreme Court has interpreted this language to require the Commission
determine three things prior to issuing the CPCN."The PSC must determine whether the
applicant has the financial ability to provide the proposed service,whether the applicant
has a good faith intention to provide the proposed service and whether the public needs
the proposed service."Tri-CountyTel.Ass'n v.Wyoming Public Serv.Comm'n.,910 P.2d
1359,1361 (Wyo.1996).
Rocky Mountain Power recognizes W.S.§37-2-205 empowers the Commission to
condition CPCNs that have been issued,but does not empower the Commission to attach
conditions precedent.Id.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.3
Anadarko Data Request 1.3
The RAV 14 attachment to the Rick Vail Direct Testimony identifies mine operations
within a one mile buffer or along the transmission line,including uranium,coal,and sand
and gravel operations.Please describe the oil and natural gas,includingcoalbed methane
gas,leases,development,and production occurring within a one mile buffer or along the
transmission line right of-way.
Response to Anadarko Data Request 1.3
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR l.2.
Without waiving the objection,curing the siting and routing studies for the project,the
Company utilized known data and visual analysis to site the line and structures.A
minimum clearance of 250 feet from the right-of-way(ROW)to known well sites was
employed as a siting criteria.As part of the ongoing final engineering design process,
Rocky Mountain Power (RMP)is commencing an engagement program with all entities
owning facilities such as those described to finalize the project siting and mitigate
potential disruptions.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.4
Anadarko Data Request 1.4
Please explain the basis for not addressing the impacts of the Transmission Line on the
Bitter Creek Coal Mines.
Response to Anadarko Data Request 1.4
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.5
Anadarko Data Request 1.5
Page 40 of the Rick Vail Direct Testimony states:
No mineral rights or minerals are required for the construction,operation,and
maintenance of the Transmission Projects.If during negotiations with landowners,
conflicts arise with the placement of the transmission line,mineral rights or extraction
terms will be negotiatedwith the landowner to mitigate the impact (i.e.,line relocation,
compensation,etc.).
(a)Please describe how the relocation process referred to in Rick Vail's testimony would
be implemented to avoid conflicts with existing mineral operations,such as a coal
mine or trona mine,includinghow far Rocky MountainPower could and would move
a transmission line.
(b)Please state if Rocky Mountain Power has initiated negotiations with landowners and
the status of those negotiations.
(c)Please identify and describe the information that Rocky Mountain Power has
regarding the number of plugged wells and abandoned mines within the right-of-way.
Response to Anadarko Data Request 1.5
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Without waiving this objection,the company responds to part (b)as follows:
Please refer to the response to WPSC Data Request 4.5 in this proceeding,which is
provided in Attachment Anadarko 2.1-1.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.6
Anadarko Data Request 1.6
If Rocky Mountain Power has procured appraisals on private lands,either surface or
mineral estate,within the right-of-way,please provide copies of the appraisals and state
when those appraisals were conducted.
(a)If the appraisals do not include the value of the mineral estate,please explain the
reasons for limitingthe scope of the appraisal.
Response to Anadarko Data Request 1.6
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.7
Anadarko Data Request 1.7
Please provide an assessment of the lost coal,natural gas and oil royalties that would
otherwise be paid to the United States and shared with the State of Wyoming due to the
construction and operation of the transmission line.
Response to Anadarko Data Request 1.7
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.8
Anadarko Data Request 1.8
Please provide an assessment of the lost severance taxes that will not be paid to the State
of Wyoming due to the transmission line right-of-waylimitingcoal,trona,or oil and gas
development and production.
Response to Anadarko Data Request 1.8
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.9
Anadarko Data Request 1.9
How many miles of access roads will Rocky Mountain Power need to build the Aeolus to
Bridger segment of the transmission line?If Rocky Mountain Power has a map showing
the probable location of such access roads,please provide copies.
Response to Anadarko Data Request 1.9
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.10
Anadarko Data Request 1.10
Please describe the existing access roads,both public (State or County roads)and private,
that Rocky Mountain Power intends to use in Sweetwater and Carbon Counties.
If Rocky Mountain Power has maps depicting the access,please provide copies;
(a)In cases where Rocky MountainPower needs to secure permission to use a road,has
Rocky Mountain Power begun that process,where and for which road segments.
Response to Anadarko Data Request 1.10
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.11
Anadarko Data Request 1.11
The Rocky Mountain Power Application,page 9,states that the transmission lines will
also increase transfer capability out of eastern Wyoming,provide critical voltage support
to the transmission system in southeastern Wyoming,and increase reliability,relieve
congestion,reduce capacity and energy losses,and provide greater flexibilitymanaging
existing generationresources.Does the transmission line have independentutility and
need separate from the wind projects?
Response to Anadarko Data Request 1.11
The benefits of the transmission line,independentof the wind projects,were outlined in
the Rocky Mountain Power (RMP)application,page 9.
Respondents:Craig Quist /Robyn Kara
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.12
Anadarko Data Request 1.12
The Rocky Mountain Power Application repeatedly states that the expiring production
tax credits make it essential that the certificate of public convenience and necessity be
issued as soon as possible.
(a)Are the wind energy and transmission line projects dependent on the production tax
credits for their economic viability?
(b)Explainthe economic consequences to the proposed wind farm and transmission line
products if the production tax credit were repealed or modified.
Response to Anadarko Data Request 1.12
(a)Yes,as described in direct testimony,the economic benefits of the new wind and
transmission projects are dependent upon the time-limited opportunity represented by
the production tax credits (PTC).The wind projects rely on the transmission project
for interconnection,and the transmission project is supported by the economic
benefits associated with the new wind resources.
(b)The Company deems it exceedingly unlikely that the United States (U.S.)Congress
will repeal or modify the 2015 PTC legislation so as to create negative and retroactive
impacts on U.S.companies that have engaged in planning and financial commitments
in accordance with the established law.Nonetheless,if PTCs were repealed,the
proposed project would become uneconomic and the Company would not proceed.
The economic impact of a modification to PTCs would depend upon the specific
modifications implemented.
Respondent:Randy Baker
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.13
Anadarko Data Request 1.13
Please describe the status of the co-development agreement between Rocky Mountain
Power /PacifiCorp and TransWest Express and provide copies of any such agreements.
Response to Anadarko Data Request 1.13
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR 1.2.
Without waiving the objection,Rocky Mountain Power is in continuing discussions with
TWE.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.14
Anadarko Data Request 1.14
Page 40 of the Rick Vail Direct Testimony acknowledges that the right-of-waywill affect
cultural and historic resources,if Rocky Mountain Power has initiated any new studies of
the affected cultural resources,please identify the contractor,nature of the studies and
produce copies of any reports.
Response to Anadarko Data Request 1.14
For the Aeolus-Standpipe 230 kilovolt (kV)Project:
Rocky Mountain Power (RMP)has initiated cultural resource studies along the
proposed 230 kilovolt (kV)right-of-way(ROW)between Freezeout and Shirley
Basin substations of which includes a small portion of Anadarko land within
Sections 28 and 29,T22N,R8 l W.There was one,in-eligible site identified
during the survey for geotechnical studies.Please refer to Attachment Anadarko
1.14,which provides the report submitted to the United States (U.S.)Bureau of
Land Management(BLM)under Section 106 requirements.Additional surveys
for the transmission line study are not complete at this time,reports/findings will
be provided to Anadarko when available.
For the Aeolus-Jim Bridger Segment (500kV/345kV -GWW D2)Project:
RMP has initiated cultural resource studies along the proposed 500 kV ROW
between Aeolus substation and Jim Bridger power plant.The culturalresources
study area,which includes the 500 kV ROW and associated access roads,includes
approximately 1,769 acres of Anadarko land within the sections indicated in
Table 1 of Attachment Anadarko 1.14.There were 34 cultural resource sites or
site segments identified during geotechnical surveys and survey of the 500 kV
ROW (Table 2).Of these sites,ten are eligible for the National Register of
Historic Places (NRHP)or are contributing segments of NRHP-eligible sites.
The reports for the geotechnical surveys,in which four sites were documented,
were submitted to the U.S.BLM per requirements of Section 106 of the National
Historic PreservationAct.Copies of the geotechnical survey reports are provided
in Attachment Anadarko 1.14.The report for the 500 kV ROW survey is in
progress and will be provided to Anadarko when available.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.15
Anadarko Data Request 1.15
Pages 40-41 of the Rick Vail Direct Testimony refers to Rocky Mountain Power's 2010
stipulation agreement to develop a sage grouse mitigation plan "to demonstrate
compliance with BLM and state policies designed to minimize impacts to sage grouse
and their habitat,and support the position that a listing as threatened or endangered under
the ESA is not needed."Testimony at 40-41.Please provide a copy of the mitigation
plan.
(a)In lightof the September 2015 determination by the U.S.Fish and Wildlife Service
that the proposed listing of the sage grouse was not warranted and the more recent
Interior Department Secretarial Orders on mitigation (Secretarial Order No.3349)
and sage-grouse management (Secretarial Order No.3353),how does this affect the
implementation of the mitigation plan?
(b)Please provide information and estimates of how much of the construction and
surface disturbance will occur outside the right-of-wayand within the Priority Habitat
Management Areas or General Habitat ManagementAreas.
(c)Has Rocky Mountain Power secured approval from the State of Wyoming regarding
construction and related surface use for the transmission line or its construction on
lands outside the transmission line right-of-way?If so,please identify the approval,
provide copies of all correspondence relating to this approval and the persons with
whom Rocky Mountain Power has communicated.
Response to Anadarko Data Request 1.15
The Company objects to the data request on the basis described in the Company's
response to Anadarko DR l.2.
Without waiving the objection,Rocky Mountain Power states as follows:
(a)The plan was analyzed as part of the Final Environmental Impact Statement (FEIS)
and Record of Decision (ROD)and the statements in the plan that Rocky Mountain
Power (RMP)would compensate for the unavoidable impact to sage-grouse habitat.
The implementation plan is the same now as it would have been had the bird been
listed
(b)Table summary of disturbance outside of right-of-way(ROW)for the entire Shirley
Basin to Jim Bridger segment (assumes that grading extents of substations would be
part of ROW).This does not include acreages associated with previously disturbed
sites that are included in the infrastructure files for Gateway West (GWW).Examples
of existing disturbances that are not included in the table are rail yards,existing roads,
and improved roads.All of those have existing disturbance so the use of those
facilities by GWW would not increase overall surface disturbance.
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.15
Disturbance Type Acres of
Disturbance
Pullingand Tensioning 92.2
(temporary)
Fly Yards (temporary)56.6
New Temporary Road 16.6
(temporary)
Regen Sites (long-term)2.0
New Road (long-term)45.7
Total Temporary 165.4
Total Long Term 47.7
Total All Disturbance 213.1
(c)RMP is in the process of securing approval from the State of Wyomingregarding
construction and related surface use for the transmission line.There is no planned
construction on lands outside the transmission ROW.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 5,2017
Anadarko Data Request 1.16
Anadarko Data Request 1.16
REQUESTFOR PRODUCTION OF DOCUMENTS
Please provide a copy of the staff report submitted to the Oregon Public Utility
Commission regarding PacifiCorp's Vision 2020 and reported in the Oregonian
Newspaper on October 11,2017.
Response to Anadarko Data Request 1.16
The Company assumes the Public Utility Commission of Oregon (OPUC)staff
comments referenced in the October 11,2017 Oregonian article are the comments filed
October 6,2017 (and errata page filed October 10)in Docket LC 67 (the 2017 Integrated
Resource Plan (IRP)proceeding).These comments are publicly available and can be
accessed by using the followingwebsite link:
http://apps.puc.state.or.us/edockets/docket.asp?DocketID=20532
Respondent:Betsy Watkins
Witness:TBD