20171218PAC to Staff Attachment WY Southland Set 1 (1-4).pdf

ROCKY MOUNTAINPOWER
4 A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
December 7,2017
J.KENNETH BARBE (5-2158)
Welborn Sullivan Meck &Tooley,P.C.
159 North Wolcott,Suite 220
Casper,WY 82601
RE:Wyoming Docket 20000-520-EA-17
Southland 16 Set Data Request (1-4)
Please find enclosed Rocky Mountain Power's Responses to Southland 1"Set Data Requests
1.1-1.4.Also provided is Attachment Southland 1.1-1.Confidential Attachment Southland 1.1-2
will be provided once the non-disclosure agreement is received.Southland 1.1 is a request for
copies and the Attachments to this response are being provided to the requesting party only.
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 (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)
Constance E.Brooks/Anadarko [e-mail]
Danielle Bettencourt/Anadarko [e-mail]
Paul Kapp/Anadarko [e-mail](C)
Roxane Perruso/TOTCO [e-mail]
Jane M.France/TOTCO [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
December 7,2017
SouthlandData Request 1.1
Southland Data Request 1.1
Please provide a copy of all responses given to all other discovery requests.
Response to Southland Data Request 1.1
Please refer to Attachment Southland 1.1-1.
Confidential Attachment Southland 1.1-2 will be provided once SouthlandRoyalty
Company (Southland)signs the non-disclosure agreement.
Going forward,Southlandwill be provided responses of data request and responses.
Respondent:Kaley McNay
Witness:Not applicable
20000-520-EA-17 /Rocky Mountain Power
December 7,2017
Southland Data Request 1.2
Southland Data Request 1.2
Please describe all cathodic protection plans for the proposed transmission line across
Southland's property to prevent damage to pipelines,well bores and other metal items or
under on Southland's property.
Response to Southland Data Request 1.2
Objection.The information Southlandseeks 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 approved pursuant to a
CPCN on final acquisition of rights-of-way,therefore the information sought by
Southlandis 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 the objection,as part of the ongoing final engineering design process,
the Company is beginning an engagement program with all entities owning facilities such
as those described.AlternatingCurrent (AC)Interference,including corrosion 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.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 7,2017
SouthlandData Request 1.3
Southland Data Request 1.3
Please provide copies of all drawings and plans for the proposed transmission line across
Southland's property.
Response to Southland Data Request 1.3
The Company objects to the data request on the basis described in the Company's
response to Southland DR 1.2.
Without waiving the objection,the design work is currentlyongoing and subject to final
detailing.Distribution of critical infrastructure details to outside parties is a potential
security risk.Data establishing the route is available in the Energy Gateway West Final
Environmental Impact Statement (FEIS).The Company proposes a meeting or meetings
to review the current layouts and design with Southlandto understand any issues and
concerns so mutuallyacceptable mitigations can be developedif required.
Respondent:Todd Jensen
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
December 7,2017
SouthlandData Request 1.4
Southland Data Request 1.4
Please explain all plans Rocky Mountain Power has to avoid interfering with Southland's
use of its property,includingplans by Southland and/or its lessees and assigns,to explore
for and produce oil,gas and other minerals from the property.
Response to Southland Data Request 1.4
The Company objects to the data request on the basis described in the Company's
response to Southland DR 1.2.
Without waiving the objection,the Company's plan for all landowners is to review with
the landowner the project and its potential impacts on the use and utility of affected lands
to explore micro-siting opportunities to reduce impacts.The Company is aware of the
varyingopportunities for energy development across the project and is prepared to work
toward solutions for compatibility.
Respondent:Todd Jensen
Witness:Rick Vail