20180105PAC to Staff Attachment_WY_ Anadarko Set 1 (1-16).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
January 3,2018
Constance E.Brooks
Danielle Bettencourt
C.E.BROOKS &ASSOCIATES,P.C.
5445 DTC Parkway,Suite 940
GreenwoodVillage,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 1"Set Data Request (1-16)
Please find enclosed Rocky Mountain Power's 1"SupplementalResponses to Anadarko 1"Set
Data Requests 1.6-1.10.Also provided is Attachment Anadarko 1.10 1"Supplemental.SS
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](C)
Patti Penn/WIEC PPPenn@hollanhart co_m (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/[e-mail] (C)
Lisa Christian/TOTCO [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
January 3,2018
Anadarko Data Request 1.6 16'Supplemental
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.
1"*SupplementResponse to Anadarko Data Request 1.6
Without waiving Rocky Mountain Power's prior objection to this Data Request regarding
the scope of certificate of public convenience and necessity (CPCN)proceedings (see the
Company's response to Anadarko Data Request 1.2),the Company supplements its prior
objection.
Appraisals for private lands within the right-of-wayare outside the scope of a CPCN
filing,which addresses the overall public interest,not the impact of the project on
individual private property interests.There is no requirement for providing private
property appraisals in CPCN filings,and such a requirement would be contrary to the
public interest.Appraisals are highly sensitive commercial information.Disclosing this
information to individual property owners who will be counter-parties in negotiations and
possible litigation over valuation of their private property could be highly detrimental to
Rocky Mountain Power's customers and the Company.Individual property owners could
misuse this information to gain unfair advantage in valuation negotiations with the
Company,driving up project costs.
In addition,this information may have broader commercial ramifications on acquisition
of all rights-of-wayassociated with future transmission projects to the detriment of
Rocky Mountain Power's customers.The Company is concerned that such a requirement
would set an unacceptable precedent in CPCN dockets in particular,and would
negatively impact future commercial negotiations for the Company,to the detriment of
its customers and against the public interest.
Finally,the question of whether or not mineral estates are included in the Company's
appraisals is irrelevant because the establishment of a transmission right-of-way,if
pursued with the reasonable approaches that the Company has described in its testimony
in this docket and successfully implemented with landowners across its transmission
system historically,will not result in foreclosure of an entire mineral estate.
Respondent:Yvonne Hogle
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 3,2018
Anadarko Data Request 1.7 16'Supplemental
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.
16*SupplementalResponse to Anadarko Data Request 1.7
Without waiving Rocky Mountain Power's prior objection to this Data Request regarding
the scope of certificate of public convenience and necessity (CPCN)proceedings (see the
Company's response to Anadarko Data Request 1.2),the Company provides the
followingsupplemental response.
The Company's assessment is that the Aeolus-to-Bridger/Anticlinetransmission line will
not have a material impact on mineral estates,or the coal,natural gas,and oil royalties
that would otherwise be paid to the United States and shared with the State of Wyoming.
There are transmission lines in Wyoming that cross thousands of acres of land
encumbered by mineral interests which are generally compatible with those uses.
Because the transmission project is a linear feature,it can be compatible with oil and gas
development,especially with advancements in horizontal drilling.Surface activity would
only be limited within the transmission line right-of-wayand does not preclude surface
mining of adjacent lands outside of the right-of-way as long as access to the towers is
maintained.The Company is confident that it can work together with all affected
landowners,includingAnadarko,to minimize the Aeolus-to-Bridger/Anticline
transmission line's impact on mineral development.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 3,2018
Anadarko Data Request 1.8 16*Supplemental
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
developmentand production.
16*SupplementalResponse to Anadarko Data Request 1.8
Without waiving Rocky Mountain Power's prior objection to this Data Request regarding
the scope of certificate of public convenience and necessity (CPCN)proceedings (see the
Company's response to Anadarko Data Request 1.2),the Company provides the
followingsupplemental response.
The Company's assessment is that the Aeolus-to-Bridger/Anticline transmission line will
not have a material impact on mineral estates,or the severance taxes paid to the State of
Wyoming.There are transmission lines in Wyoming that cross thousands of acres of land
encumbered by mineral interests which are generally compatible with those uses.
Because the transmission project is a linear feature,it can be compatible with oil and gas
development,especially with advancements in horizontal drilling.Surface activity would
only be limited within the transmission line right-of-wayand does not preclude surface
mining of adjacent lands outside of the right-of-wayas long as access to the towers is
maintained.The Company is confident that it can work togetherwith all affected
landowners,includingAnadarko,to minimize the Aeolus-to-Bridger/Anticline
transmission line's impact on mineral development.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 3,2018
Anadarko Data Request 1.9 16*Supplemental
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.
16*SupplementalResponse to Anadarko Data Request 1.9
Without waivingits prior objection to this data request regarding the scope of certificate
of public convenience and necessity (CPCN)proceedings (see the Company's response
to Anadarko Data Request 1.2),the Company provides the followingsupplemental
response.
Rocky Mountain Power has identified 487 miles of access roads between Aeolus and
Bridger to date.This includes existing roads,existing roads that need improvement,and
new permanent or temporary roads.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 3,2018
Anadarko Data Request 1.10 16'Supplemental
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;
In cases where Rocky Mountain Power needs to secure permission to use a road,has
Rocky Mountain Power begun that process,where and for which road segments.
1"*SupplementalResponse to Anadarko Data Request 1.10
Without waiving its prior objection to this Data Request regarding the scope of certificate
of public convenience and necessity (CPCN)proceedings (see the Company's response
to Anadarko Data Request 1.2),the Company provides the followingsupplemental
response.
Please refer to the Company's lst Supplementalresponse to Anadarko Data Request 1.9.
Please also refer to Attachment Anadarko 1.10 16'Supplemental,which provides the
associated GIS shapefiles.
Respondent:Rod Fisher
Witness:Rod Fisher