20180118PAC to Staff WY_BP Set 1 (1-17).pdf

ROCKY MOUNTAIN
POWER
A DWISION OF MCWICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
January 12,2018
Nicol Thompson Kramer
Beatty &Wozniak,P.C.
123 W.lst Street,Suite 120
Casper,WY 82601
niranler@bwenemylaggpon1 (C)
James B.Martin
Beatty &Wozniak,P.C.
216 16th Street,Suite 1100
Denver,CO 80202
j
RE:Wyoming Docket 20000-520-EA-17
BP 16 Set Data Request (1-17)
Please find enelosed Rocky Mountain Power's Responses to BP 1 Set Data Requests I 1-1 17.
Also provided are Attachments BPl.15 and 1.17.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.C.:Lori L.Brand/WPSC lorid2Lam!TULgov (W)
John Burbridge/WPSC john12ngdk@y agov (W)
Michelle Bohanan/WPSC _Michellelo_hanan@wyogov (W)
Kara Seveland/WPSC kara-s_eveland@wyogov (W)
Morgan Fish/WPSC nMLrganigwysšgov (W)
Dave Walker/WPSC dave alk_erkgv (W)
Perry McCollom/WPSC geBXJneconoEL ELGÁLoy (W)
Meridith Bell/WPSC nieridith);[e-mail](C)
Abigail C.Briggerman/WIEC acbrjgg_errrian@hdandhartagn (C)
Patti Penn/WIEC PPenn@hollanhagsen(W)
Thor Nelson/WIEC tn_gkon Roll gihartsom (C)(W)
Emanuel Cocian/WIEC et_cocian@h_oolla_nharkcom (W)
Adele Lee/WIEC ACLee(Rhollandhart.com (W)
Nik Stoffel/WIEC [e-mail](C)(W)
Christopher Leger/OCA c_hhristopherjegengwyo.gov (C)
Crystal J.McDonough/NLRAeBZlal@Ble InoßghhLwica2m(C)
Callie Capraro/NLRA callie@¾oglle.com
Lisa Tormoen Hickey/Interwestlisabjiejseygne_wlawgü2BP n2 (C)
Brandon L.Jensen/RMSC brandon@bigklfalnacyp (C)
Roxane Perruso/TOTCO Ro;[e-mail]
Jane M.France/TOTCO jfranegagp_km.org (C)
Constance E.Brooks/Anadarko connLegeggoo_k m
Danielle Bettencourt/Anadarko [e-mail]
Paul Kapp/Anadarko pkapggsglg:nkrg(C)
Lisa Christian/TOTCO [e-mail] (C)
J.Kenneth Barbe/Southland kbgdie@wsnitla m (C)
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.1
BP Data Request 1.1
Describe the process,if any,by which You have or will identify and assess potential
conflicts with oil and gas resource developmentas You acquire rights-of-wayfor the
Transmission Projects and identify the person(s),if any,responsible for such
assessments.
Response to BP Data Request 1.1
Various means have been and will be used to identify potential conflicts includingaerial
photography analysis,Wyoming Oil and Gas Conservation Commission data,title
research and most importantly,personal interaction with landowners,leaseholders and
developers.Persons responsible include several across various disciplines within the
project team.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.2
BP Data Request 1.2
Describe the process by which You will seek to resolve conflicts with oil and gas
resource development on the route selected for the 140-mile Aeolus-to-Anticline 500 kV
transmission line,includingconstruction of the new Aeolus and Anticline substations,
and identify the person(s)who will be responsible for such activities,when such conflict
resolution will occur,and Your plans if You cannot resolve these conflicts.
(a)If You have a written procedure for such activities,please provide a copy.
(b)Describe the buffer,if any,You have determinedthat You will use to minimize
conflicts between the route for the transmission line and existing oil and gas
production locations,includingfuture well completions and re-completions and well
workovers.
(c)Describe the budget,if any,You have created to compensate oil and gas companies
that will be unable to site well pads and ancillaryfacilities at the optimal locations for
development of lateral wells from such section lines and section corners should the
route for the 140-mile Aeolus-to-Anticline 500 kV transmission line not be able to
avoid section lines and section corners,includinghow such budget will affect the
total cost of constructing the 140-mile Aeolus-to-Anticline 500 kV transmission line.
Response to BP Data Request 1.2
The process is engaging in discussions with landowners,leaseholders and developers to
best understand potential conflicts and opportunities for resolution.Conflict resolution
will occur as soon as said landowners,leaseholders and developers are willing to begin
discussions.The Company is confident conflicts can be resolved throughmicro-siting
opportunities and easement terms that will allow for co-existence.Discussions will be led
by Company property agents supported by technical and other staff.
(a)No written procedure is available.
(b)The Company attempted to maintain a 250'distance from any active well head during
the original siting.
(c)The Company objects to this request because the budget information requested is
beyond the scope of a CPCN proceeding.Without waiving the objection,
compensation will be addressed during right-of-waynegotiations with each affected
party.The Company is confident conflicts can be resolved through micro-siting
opportunities and easement terms that will allow for co-existence.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.3
BP Data Request 1.3
State whether You have identified the companies that have oil and gas leases within the route
selected for the 140-mile Aeolus-to-Anticline 500 kV transmission line and construction of
the new Aeolus and Anticline substations,describe what steps You have taken to make such
identification.
(a)If You have identified existing well pads within 500 feet of the selected transmission
route for the 140-mile Aeolus-to-Anticline 500 kV transmission line,please list those
well pads with GPS coordinates or their equivalent.
Response to BP Data Request 1.3
The Company is in the process of reviewing all oil and gas leases that the transmission
line right-of-waycrosses.Steps taken include public information research and title
research.The best information available will be from landowners,leaseholders and
developers throughpersonal communication.
(a)A GPS coordinate list is not specifically available;however,the final alignment of the
transmission line right-of-wayavoids all existing well pads with a buffer of 250 feet.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.4
BP Data Request 1.4
Please identify and describe the process You will use to adjust the route for the 140-mile
Aeolus-to-Anticline 500 kV transmission line for conflicts with wildlife,including
raptors and greater sage grouse,includingany written policy or process for making such
adjustments.
Response to BP Data Request 1.4
The transmission line was sited during the U.S.Bureau of Land Management
Environmental Impact Statement process,which considered how to mitigate conflicts
with wildlife.Please refer to Rebuttal Testimony of Company witness,Roderick D.
Fisher,pages 3 through11.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 12,20 18
BP Data Request 1.5
BP Data Request 1.5
State whether You have evaluatedhow Your use of cathodic protection could affect
cathodic protection used by oil and gas companies to minimize corrosion of flowlines,
gathering lines,and pipelines and describe the results of such evaluation.
Response to BP Data Request 1.5
Rocky Mountain Power (RMP)is fully aware of the impacts high voltage transmission
lines may have on pipelines and similar metallic facilities,particularlywhere the
transmission line parallels pipeline facilities.All projects evaluate the potential impact
and mitigations.As part of the ongoing final engineering design process,the Company is
commencing an engagement program with all entities owning facilities such pipelines,
well bores and other metal items to analyze potential impacts.RMP is ready to engage
with BP as soon as possible to begin the engineering study and mitigations process.
AlternatingCurrent (AC)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 and/or other appropriate solutions.Please refer to the Supplemental Rebuttal
Testimony of Company witness,Roderick D.Fisher,pages 9-10.
Respondent:Stuart Smith
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.6
BP Data Request 1.6
Identify and describe the budget You have created for expenses for mitigation of adverse
impacts to plants,wildlife,cultural or historical sites,water resources,and other
resources,includingbut not limited to the process You underwent to determine the
budget;whether You can or will revise the budget;and how mitigation expenditures will
be identified,qualified and disbursed.
Response to BP Data Request 1.6
The Company objects to this request because the budget information requested is beyond
the scope of a CPCN proceeding.Compensation will be addressed during right-of-way
negotiations with each affected party.Disclosing this information to individual property
owners who will be counter-partiesin 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.
Without waiving this objection,the Company has worked with several environmental
contractors and the U.S.Bureau of Land Management since 2007 during the
environmental impact study process and developeda comprehensive plan of development
that includes all construction,reclamation and restoration plans and use of environmental
protection measures for the transmission project.All costs for the above items including
any mitigation requirements are built into the overall project cost.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.7
BP Data Request 1.7
Describe the process You underwent to "preliminarily site []project components to
mitigate potential environmental and natural resource impacts in the project area."See
Direct Testimony of Chad A.Teply,CAT-1 at 7.
Response to BP Data Request 1.7
Preconstruction desktop analyses and on-site surveys were completed and/or are currently
underway for various wildlife species,wetland sites,and sensitive habitats.The data
available from the analyses and surveys was used to develop preliminarysetbacks and
avoidance areas within the project areas to minimize environmental and natural resource
impacts.The setbacks and avoidance areas were factors that informed the design process
of the preliminaryproject layouts.
Respondent:Ken Clark
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.8
BP Data Request 1.8
Describe Your plans to mitigate effects to wildlife identified by You,including
"temporary displacement of individuals for some wildlife species that would move on in
response to project activities,and lead to permanent impacts to wildlife."See Direct
Testimony of Chad A.Teply,CAT-1 at 8.
Response to BP Data Request 1.8
The Company objects to this request because the wildlife mitigation information
requested is beyond the scope of a CPCN proceeding.Impacts on wildlife were addressed
in the permitting process with the U.S.Bureau of Land Management.
As noted in the Direct Testimony of Chad A.Teply,CAT-1 at 9,the Company will develop
and implement site specific wildlife management plans as necessary.Depending upon the
species,seasonal and temporal construction setbacks will be implemented based on
recommendations/guidance from U.S.Fish and Wildlife Service and Wyoming Game and
Fish Department guidance documents and coordination.This may include lek buffer areas
and seasonal setbacks for sage grouse,non-disturbance buffers for eagle nests,and/or micro-
siting of turbines in response to known wildlife usage.
Respondent:Travis Brown
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.9
BP Data Request 1.9
Identify Your proposed reclamation,remediation and restoration plans,includingbut not
limited to:
(a)Whether You have consulted with any remediation,reclamation or restoration experts
or contractors,and,if so,what requirements those experts or contractors have
identified as necessary for the Transmission Projects;
(b)Whether You have identified or hired "environmental inspector(s)to ensure that
environmental considerations,and any unforeseen environmental incidents,are
appropriately addressed"(see Direct Testimony of Chad A.Teply,CAT-1 at 8);
(c)The process by which You will reclaim "lands disturbed during construction to
current conditions to the extent practicable"(see Direct Testimony of Chad A.Teply,
CAT-1 at 8);
(d)The timeframe by which You will reclaim "lands disturbed during construction to
current conditions to the extent practicable"(see Direct Testimony of Chad A.Teply,
CAT-1 at 8);and
(e)The best management practices You will employ to minimize ground disturbance and
environmental impacts.See Direct Testimony of Chad A.Teply,CAT-1 at 8.
Response to BP Data Request 1.9
The Company objects to this request because the environmental impact information
requested is beyond the scope of a CPCN proceeding.Environmental impacts were
addressed in the permitting process with the U.S.Bureau of Land Management.Without
waiving this objection,the Company states:
Yes.The Company has worked with several environmental contractors and the U.S.Bureau of
Land Managementsince 2007 during the environmental impact study ("EIS")process and
developeda comprehensive plan of development that includes remediation,reclamation and
restoration plans and use of environmental protection measures for the transmission project.The
necessary requirements are reflected in the final EIS.
(a)Yes.The Company went out to bid for a third-partyConstruction Inspection
Compliance ("CIC")contractor for its transmission project on December 1,2017,and
bids are due January 8,2017.The CIC will work at the direction of the U.S.Bureau
of Land Management.
(b)Please refer to the Company's response to subpart (a)above.
(c)Please refer to the Company's response to subpart (a)above.
(d)Please refer to the Company's response to subpart (a)above
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.9
Respondent:Rod Fisher
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.10
BP Data Request 1.10
Describe when and how "Site specific wildlife management plans will be developed and
implemented."See Direct Testimony of Chad A.Teply,CAT-1 at 9.
Response to BP Data Request 1.10
Objection.See the objection to the response to BP America DR 1.8.Without waiving the
objection,the Company states as follows:
Site specific wildlife management plans will be developed and/or finalized upon
completion of ongoing wildlife survey efforts,such as raptor nest searches,sage grouse
usage,swift fox surveys,raptor prey based mapping,etc.The plans would be
implemented during various,and appropriate,stages of construction and operations.
Respondent:Travis Brown
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.11
BP Data Request 1.11
Describe the conditions that will be required for the site-and project-specific
environmental protection plans that "each on-site contractor will be expected to develop,
publish and orchestrate."See Direct Testimony of Chad A.Teply,CAT-1 at 9.
Response to BP Data Request 1.11
The Company objects to this request because the environmental protection plan
informationrequested is beyond the scope of a CPCN proceeding.Environmental
protection was addressed in the permitting process with the U.S.Bureau of Land
Management.Without waiving the objection,the Company states as follows:
Conditions in site and project specific plans may include:seasonal and temporal setbacks
for various wildlife;spill prevention,control and countermeasure action items;wildlife
impact reporting;watershed/wetland setbacks;stormwater management;and/or
emergency response actions,such as fire and other safety response requirements.
Respondent:Travis Brown
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.12
BP Data Request 1.12
Describe the creation and operation of the ARO,includingbut not limited to the process
by which funds will be placed into the ARO account,how the ARO account will be
maintained,how funds in the ARO account will be utilized for site restoration,any
limitations or restrictions that You will place on the use of ARO funds,and how much
money You expect will be required "to restore the site to near natural conditions"(see
Direct Testimony of Chad A.Teply,CAT-1 at 8).
Response to BP Data Request 1.12
The Company objects to this request because the accounting treatment of obligations due
to the retirement of assets is beyond the scope of a CPCN proceeding.Without waiving
the objection,the Company states as follows:
PacifiCorp falls under the jurisdiction of various state and federal regulatory bodies
relating to asset retirement activities.Accounting treatment of obligations due to the
retirement of assets is described in Accounting Standards Codification (ASC)Subtopics
410-20,Asset Retirement and Environmental Obligations -Asset Retirement
Obligations,and 980-410,Regulated Operations -Asset Retirement and Environmental
Obligations.ASC Subtopic 980-410 states retirements that require related costs be
accrued and reported in the company's financial statements.
Accounting Standards as described above do not require funds be set aside in trust to
meet the ARO obligation.At the time of asset retirement and decommissioning,general
company funds will be used and charged to the ARO liabilityto restore the site to near
natural conditions.
A specific ARO estimate has not been completed;however,other wind sites'ARO
estimates range from $25,000 to $45,000 per installed nameplate megawatt of capacity.
Respondent:Tom Evans
Witness:TBD
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.13
BP Data Request 1.13
Identify the results of any DDCT processes You have run,includingbut not limited to,
the locations for which You have used the DDCT.
Response to BP Data Request 1.13
The Company objects to this request because the DDCT information requested is beyond
the scope of a CPCN proceeding.Withoutwaiving the objection,the Company states as
follows:
The only Disturbance Density Calculation Tool (DDCT)processed and approved was for
the larger Energy Gateway West transmission project and occurred due to a landslide
area within designated corridor in Lincoln County,outside of the transmission project
area.The DDCT was approved by Wyoming Game and Fish in 2014 and U.S.Bureau of
Land Management authorization was received in 2015.
Respondent:Rod Fisher
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.14
BP Data Request 1.14
Identify Your budget for the right-of-wayand reclamation bonding requirements related
to the Transmission Projects,includingbut not limited to the process You underwent to
determine the budget,and whether You can or will revise the budget.
Response to BP Data Request 1.14
The Company objects to this request because the budget information requested is beyond
the scope of a CPCN proceeding.Compensation will be addressed during right-of-way
negotiations with each affected party.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.Without waiving the objection,the Company states as follows:
The right-of-waybudget for acquiring transmission line and access road easements for
the Transmission Projects is based on current market property values.The budget may be
revised as necessary to reflect changes in market conditions or other factors.
Construction and reclamation bond requirements are a condition of the U.S.Bureau of
Land Management's record-of-decision (ROD)and right-of-waygrant,and the costs
have been included in the overall project costs.
Respondent:Shawn Graff /Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.15
BP Data Request 1.15
State whether You reviewed the Continental Divide-Creston Natural Gas Development
Project Final Environmental Impact Statement and Record of Decision,and,if so,
describe whether and how You modified the Transmission Projects to be consistent with
the Record of Decision.
Response to BP Data Request 1.15
The Company is familiar with the U.S.Bureau of Land Management's final
environmental impact statement (FEIS)published in April 2016,and has reviewed the
record of decision (ROD)issued in September 2016.Attachment BP 1.15 provides a
copy of FEIS Chapter 5 -Cumulative Impacts,pages 5-4 and 5-5 which provides a list
and map of Ongoing and Reasonably Foreseeable Future Actions,includingEnergy
Gateway West,Energy Gateway South,and TransWest Express Transmission Projects.
The Energy Gateway West ROD was issued November 2013,and no modification to the
authorized right-of-wayhas occurred in this area.Any adjustments or micro siting will
occur during final engineering in 2018,in consultation with land and mineral owners.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
January 12,2018
BP Data Request 1.16
BP Data Request 1.16
Please produce each and every document You identified,described,referred to,or
otherwise relied upon in respondingto the above interrogatories and identify the
Interrogatorywith which the documents are associated.
Response to BP Data Request 1.16
To the best of the Company's knowledge,all documents identified,described,referred to,
or otherwise relied upon in responding to BP Data Request 1.1 through BP Data Request
1.15,and which are not publicly available either as part of the record for this docket (e.g.
testimony)or otherwise (e.g.Records of Decision,legal precedent,etc.),have been
provided as part of the Company's responses to these requests.However,the Cornpany
will provide any referenced documents that are not publicly or readily available that are
specifically identified by BP America.
Respondent:Yvonne Hogle
Witness:TBD
20000-520-EA-17 /Rocky MountainPower
January 12,2018
BP Data Request 1.17
BP Data Request 1.17
Please provide the shapefiles that describe the route You have selected for construction of
the 140-mile Aeolus-to-Anticline500 kv transmission line.
Response to BP Data Request 1.17
Please refer to Attachment BP 1.17.
Respondent:Rod Fisher
Witness:Rick Vail and Rod Fisher