20171218PAC to Staff Attachment WY Set 1(1-14).pdf

ROCKY MOUNTAIN 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116POWER
A DIVISION OF PACIFICORP
December 8,2017
Roxane Perruso
Lisa Christian
Vice President and General Counsel
The Overland Trail Cattle Company LLC
555 Seventeenth Street,Suite 2400
Denver,Colorado 80202
[e-mail]
[e-mail] (C)
Jane M.France,WSB #7-4828
Sundahl,Powers,Kapp &Martin,LLC
1725 Carey Avenue
P.O.Box 328
Cheyenne,Wyorning 82003
[e-mail] (C)
RE:Wyoming Docket 20000-520-EA-17
TOTCO 13'Set Data Request (1-14)
Please find enclosed Rocky Mountain Power's Response to TOTCO 16'Set Data Request 1.1-
1.14.Also provided is Attachment TOTCO 1.1.
S
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 (W)
Bob Porneroy/WIEC rltomeroyl@giagagrkema(W)
Thor Nelson/WIEC toekson hollapínlartcom(W)
Emanuel Cocian/WIEC (W)
Nik Stoffel/WIEC (W)
Christopher Leger/OCA cluistapher.leggggwyo gov (C)
Crystal J.McDonough/NLRAgygal@rnc<dlo gl<awlle com (C)
Brandon L.Jensen/RMSC brandon@by dfaln co (C)
Lisa Tormoen Hickey/Interwest (C)
Constance E.Brooks/Anadarko [e-mail]
Danielle Bettencourt/Anadarko danießeggebiges.com
Paul Kapp/Anadarko pim92@spignarg (C)
J.Kenneth Barbe/Southland kbarbe@ivsnilarcom
Lisa Christian/TOTCO (C)
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.1
TOTCO Data Request 1.1
Please state the width of and identitythe location of the proposed Transmission Right-of-
Way across the Subject Lands.
Response to TOTCO Data Request 1.1
The proposed transmission right-of-way(ROW)width is 250 feet.A map showing the
transmission line across the subject lands is provided as Attachment TOTCO 1.1
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.2
TOTCO Data Request 1.2
Please identifywhat facilities and their location,whether such facilities will be temporary
or permanent,in addition to the proposed Transmission Line that Rocky Mountain Power
intends to locate on the Subject Lands.For example,this includes but is not limited to
access roads,substations,laydown yards and communication sites.
Response to TOTCO Data Request 1.2
Objection.The information TOTCO seeks is not likelyto lead to the discovery of
admissible evidence.Acquisition of all rights-of-wayis not required before commission
approval of the CPCN.The Company recognizes W.S.§37-2-205 empowers the
Commission to condition the initiation of construction of a project approvedpursuant to a
CPCN on final acquisition of rights-of-way,therefore the information sought by TOTCO
is not admissible or relevant in this proceeding.See Tri-CountyTel.Ass'n v.Wyoming
Public Serv.Comm'n.,910 P.2d 1359,1361 (Wyo.1996).Without waiving this
objection,the Company responds as follows:
Please refer to the Company's response to TOTCO Data Request 1.1;specifically
Attachment TOTCO 1.1.There are no laydown,substation or communication sites on
the subject lands.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.3
TOTCO Data Request 1.3
Please identify all natural gas,oil,or water pipelines,fiber optics,and other utility
infrastructure that are either located within or will intersect the proposed Transmission
Right-of-Wayacross the Subject Lands.
Response to TOTCO Data Request 1.3
Objection.See the Company's response to data request 1.2.Without waiving this
objection,the Company responds as follows:
As part of the ongoing final engineering design process,Rocky Mountain Power (RMP)
is ready to engage with The Overland Trail Cattle Company (TOTCO)to identify in
detail and review the location of facilities such as those described.RMP's plan is to
review the project and its potential impacts and to explore micro-siting opportunities to
reduce impacts and avoid conflicts with existing facilities.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.4
TOTCO Data Request 1.4
With respect to all infrastructure identified in response to InterrogatoryNo.3,and with
respect to fencing on the Subject Lands please describe the measures that Rocky
Mountain Power will undertake to mitigate the effect of electromagnetic corrosion or
effects of induced currents.
Response to TOTCO Data Request 1.4
Objection.See the Company's response to data request 1.2.Without waivingthis
objection,the Company responds as follows:
As part of the ongoing final engineeringdesign process,the Company will engage with
The Overland Trail Cattle Company (TOTCO)to review facilities such as those
described in TOTCO Data Request 1.3 (such as pipelines,utilities).For such facilities,
AlternatingCurrent Interference,includingcorrosion potential,will be studied to
determine any impacts the transmission line may cause.Site-and condition-specific
protective mitigations will be designed and installed where indicated.Mitigations may
include facility grounding,line micro-siting adjustments,operator protection,corrosion
protection,or other appropriate solutions.
With respect to fences on the property,the project is designed to meet all National
Electric Safety Code (NESC)requirements,includingclearances to avoid induced current
on metallic objects,this also includes grounding of all transmission structures.Upon
energization of the project,the Company can perform measurements on fences for any
induced currents that may occur.If present,the Company will appropriately ground the
fence against the current.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.5
TOTCO Data Request 1.5
Rocky Mountain Power's Application states that it needs a certificate of public
convenience and necessity as soon as possible in order to take advantage of expiring
production tax credits.
(a)How would failure to qualify for any level of production tax credit affect the
economic viabilityof the wind energy and Transmission Project addressed in the
Application and the need and necessity for them.
(b)Explain the economic consequences to the proposed wind farm and Transmission
Project and the need and necessity for the projects if the production tax credit is
modified as currentlyprovided in H.R.1 passed by the House on November 16.2017.
Response to TOTCO Data Request 1.5
The Company objects to this request because it is speculative.Without waiving the
objection,the Company states as follows:
(a)Please refer to the Company's response to Anadarko DR l.12(a)and 1.12(b).
(b)The Company has not performed the study.The Company will provide updated
economic analysis based on the best available information in its January,2018
supplemental filing.
Respondent:Yvonne R.Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.6
TOTCO Data Request 1.6
Explain how Rocky Mountain Power has and will coordinate with TOTCO to avoid
interfering with the Chokecherry and Sierra Madre Wind Energy Project,which relies on
a wind developmenteasement granted by TOTCO to Power Company of WyomingLLC.
Specifically,address how Rocky Mountain Power will avoid interfering with the
operations center,1101thern access road,and rail facility,as generally depicted on
Exhibit A.
Response to TOTCO Data Request 1.6
Objection.See the Company's response to data request 1.2.Without waiving this
objection,the Company responds as follows:
The Company has engaged in numerous coordination discussions and meetings with The
Overland Trail Cattle Company (TOTCO)and the Power Company of Wyomingfor
almost a decade.In addition,in 2012,the U.S.Bureau of Land Managementrequired
TOTCO and PacifiCorp to conduct joint engineering to co-locate both companies'
transmission projects.The Company will address and finalize precise routing during
right-of-waynegotiations.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.7
TOTCO Data Request 1.7
Explain how Rocky Mountain Power has and will coordinate with TOTCO to avoid
interfering with agreements between TOTCO and with TransWest Express LLC
regarding the siting of the TransWest Express Transmission Project on the Subject Lands.
Specifically,address how Rocky Mountain Power will avoid interfering with the siting of
the terminal for the TransWest Express Transmission Project on TOTCO's private lands,
as generally depicted on Exhibit A.
Response to TOTCO Data Request 1.7
Objection.See the Company's response to data request 1.2.Without waiving this
objection,the Company responds as follows:
Please refer to the Company's response to TOTCO Data Request 1.6.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.8
TOTCO Data Request 1.8
Explain whether and how Rocky Mountain Power will work with TOTCO and
TransWest Express LLC to:
(a)Minimize the number of access roads needed on TOTCO's private lands for both
transmission projects.
(b)Utilize existing ranch roads to the maximum extent possible.
Response to TOTCO Data Request 1.8
Objection.See the Company's response to data request 1.2.Without waiving this
objection,the Company responds as follows:
The Company will engage with The Overland Trail Cattle Company (TOTCO)and
TransWest Express LLC (TWE)and work on a final access road plan that respects the
conditions of the Energy Gateway West Record of Decision (ROD),plan of development,
landowner requests,and construction efficiencies for the projects while minimizing the
construction of new access roads.The Company prefers using suitable existing roads
instead of constructing new roads.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.9
TOTCO Data Request 1.9
Identify when Rocky Mountain Power is planning on constructing the Energy Gateway
South Project,and address how Rocky Mountain Power will coordinate the multiple
transmission lines that include the Energy GatewayWest and TransWest Express
Transmission Project.
Response to TOTCO Data Request 1.9
Objection.See the Company's response to data request 1.2.Without waiving this
objection,the Company responds as follows:
The Energy Gateway South Project is currentlyscheduled for completion in 2024.The
transmission lines associated with Energy GatewayWest and the TransWest Express
Transmission Project have been coordinatedthrough the Western Electricity
Coordinating Council (WECC)processes for project coordination,path rating,and
progress reporting.The Company is an active participant in WECC and was the project
sponsor of path-rating studies for all Energy Gateway technical studies and is an active
member of the TransWest Express (TWE)project-review group.Independentof the
coordination efforts at the WECC level,TWE has initiated the transmission
interconnection process and signed a transmission interconnection study agreement with
the Company.The study process includes technical studies that will fully evaluate
interconnecting TWE's project with the Company's Gateway South and West projects
and one existing 230 kilovolt transmission line in Wyoming.
Respondent:Craig Quist
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.10
TOTCO Data Request 1.10
Identify when Rocky Mountain Power will commence the permitting process for the
Energy GatewayWest project before the Wyoming Department of Environmental
Quality Industrial Siting Council.
Response to TOTCO Data Request 1.10
The Company initiated the permitting process with a formal jurisdictionalmeeting and
letter of determination in October 2012.The Company anticipates submitting an
application to the Wyoming Industrial Siting Division (ISD)in Q2 2018.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.11
TOTCO Data Request 1.11
Explain how Rocky Mountain Power will coordinate with TOTCO to prevent interfering
with TOTCO's grazing leases on Bureau of Land Managementland and grazing on
TOTCO's private lands.
Response to TOTCO Data Request 1.11
The Company and its contractors will work with landowners and leaseholders on an
individual basis to implement measures for the protection or relocation of livestock
during construction,including the use of temporary fencing and gates,if necessary.
Grazing will not interfere with the operation and maintenance of the proposed power line
and can safely occur within the proposed right-of-way.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.12
TOTCO Data Request 1.12
One of the alternative portfolios for the combined wind and Transmission Projects
analyzed in the IRP was front office market transactions.Explain how these combined
projects that need to be executed on an expedited basis to realize net economic benefits
represents the "least-risk resources relative to front office market transactions that would
presumably utilize the existing transmission system and not require new transmission
across the Subject Lands.
Response to TOTCO Data Request 1.12
The wind and transmission projects produce a lower risk-adjusted present value of
revenue requirements (PVRR)than portfolios relyingmore heavilyon front-office
transactions (FOTs)through the near-to mid-term.While FOTs are subject to available
market depth and price risks,the wind and transmission resources provide a hedge
against market and fuel volatilities,reducing risk.Further,with federal production tax
credits (PTCs),the proposed new wind and transmission assets reduce nominal revenue
requirement relative to a portfolio without the new wind and transmission within three to
five years of being placed in service.The new resources also lower carbon dioxide (CO2
emissions and produce PTCs,lowering net costs.
Respondent:Dan Swan/Randy Baker
Witness:Rick Link
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.13
TOTCO Data Request 1.13
Produce all leases and agreements Rocky Mountain Power has entered into with the State
of Wyomingwith respect to developmentof Rocky Mountain Power's transmission lines
on state lands within the last 3 years,includingthose executed with respect to the Energy
GatewayWest project described in the subject application.
Response to TOTCO Data Request 1.13
Objection.See the Company's response to data request 1.2.
Respondent:Yvonne Hogle
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
December 8,2017
TOTCO Data Request 1.14
TOTCO Data Request 1.14
Produce a copy of the Right-of-WayGrant from the Bureau of Land Managementfor the
Energy Gateway West transmission project.
Response to TOTCO Data Request 1.14
Objection.See the Company's response to data request 1.2.
Respondent:Yvonne R.Hogle
Witness:TBD