20180208PAC to Staff WY Anadarko Set 3 (1-17).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
February 2,2018
Constance E.Brooks
Danielle Bettencourt
C.E.BROOKS &ASSOCIATES,P.C.
5445 DTC Parkway,Suite 940
Greenwood Village,Colorado 80111
[e-mail] (C)
[e-mail](C)(W)
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 3rd Set Data Request (1-17)
Please find enclosed Rocky Mountain Power's Responses to Anadarko 3rd Set Data Requests
3.1-3.17.Also provided is Attachment Anadarko 3.17.Provided on the enclosed Confidential
CD is Confidential Attachment Anadarko 3.9.Confidential information is provided subject to
the terms and conditions of the protective agreement in this proceeding.
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](C)
Patti Penn/WIEC [e-mail](W)
Thor Nelson/WIEC [e-mail] (C)(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)
Callie Capraro/NLRA [e-mail]
Brandon L.Jensen/RMSC [e-mail] (C)
Lisa Tormoen Hickey/[e-mail] (C)
J.Kenneth Barbe/[e-mail] (C)
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
February 2,2018
Anadarko Data Request 3.1
Anadarko Data Request 3.1
Roderick D.Fisher states in his supplemental rebuttal testimony that "[if]the Company
locates a transmission tower on the surface,Anadarko will not be able to construct a well
pad at that very same site or under the transmission line....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."
(a)Does Rocky Mountain Power deny that the Transmission Line Project can interfere
with development of the mineral resources within the transmission line right-of-way?
(b)Can underground coal mining occur within the transmission line right-of-way?If yes,
then what is the appropriate support needed and the appropriatedistances between
any subsurface mine and the transmission line to mitigate impacts from blasting and
prevent subsidence from occurring?
(c)Does Rocky Mountain Power deny that the transmission line,both at the construction
and operation stage,can interfere with oil and gas development?
Response to Anadarko Data Request 3.1
(a)Please refer to the Company's response to Anadarko Data Responses 1.5 (a)First
Supplementaland 3.2.
(b)Yes,underground mining can occur under a transmission line right-of-way.It is
Rocky Mountain Power's understanding that underground coal mining generally
occurs on deep deposits,typically in excess of 180 feet below the surface.Mining
advances through the coal seam,leaving behind columns of material sufficient to
safely support the roof of the mine.The columns of material are recovered as the
mine is closed,allowingthe roof of the mine to collapse.That is the mechanism that
can cause surface subsidence.The magnitude of subsidence,expressed at the surface,
is dependent on several factors,includingthe underlyingsoil type(s)and geology,as
well as the depth and height of the collapse.Any impact on a transmission line is
completely dependent on the magnitude of the subsidence.
Where there exists the potential for surface subsidence,Rocky Mountain Power will
coordinate with the mining entity to determine the timing and magnitude of the
impact and determine the appropriate course of action to protect the transmission line,
if any.Actions may include compensating the mining entityto leave supporting
columns in the area of concern,doing nothing since the transmission line can tolerate
some non-differential settlement,or some other appropriately selected action.
(c)Please refer to subpart (a)above.
Respondents:Jim Higgins /Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.1
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.2
Anadarko Data Request 3.2
The Bureau of Land Managementbased its approval of the Gateway West Transmission
Line Project right-of-wayon the Final Environmental Impact Statement (FEIS)and
Record of Decision (ROD).Does Rocky Mountain Power have any factual basis to
conclude that the followingstatements are untrue?If yes,then please provide such
information.
(a)"The presence of existing mineral claims and leases could interfere with plans to
construct the Project.As part of the pre-construction process,the Proponents would
identify active mining claims and mineral leases and either negotiate permission to use
the land surface in these areas or re-locate the transmission line to avoid existing active
claims and leases....Where access to mineral resources may be restricted,the
Proponents would provide compensation for damage,access rights,and easements to
mine owners,claimants and lease holders."Gateway West FEIS at Ch.3.12,p.11.
(b)"The construction of the Project could restrict exploration of mineral resources during
the 2-year construction period.Construction activities could also restrict mining
companies'ability to access land for mining or exploration."Gateway West FEIS at
Ch.3.12,p.11.
(c)"The Scoping Report (Tetra Tech 2009)indicated concern that the high-voltage
transmission lines would restrict access to drill rigs conducting exploration or repair of
oil or gas wells.Project operations would remove acreage that would not be available for
mining for the life of the Project."Gateway West FEIS at Ch.3.12,p.12.
(d)"A total of 312 acres of mineral interests would be affected in the Segment 3
construction disturbance area.The affected area would consist almost entirelyof oil and
gas leases,and 22 acres of coal leases which are also contained within the oil and gas
leases.The operations area would contain 39 acres of affected area.Despite the high
percentage of oil and gas leases,no oil or gas wells would be located within the
disturbance areas."Gateway West FEIS at Ch.3.12,p.21.
Response to Anadarko Data Request 3.2
The Company objects to this request because the accuracy of specific FEIS findings is
beyond the scope of a Certificate of Public Convenience and Necessity (CPCN)
proceeding.Without waiving the objection,the Company states as follows:
The Company does not dispute the truth of the statements take from the GatewayWest
FEIS.But the excerpts provided in Anadarko Data Request 3.2 were selectively edited
and do not include the entire context of the assessment made by the Bureau of Land
Managementwhen it prepared the FEIS.
The followingprovides complete excerpts (the material omitted by Anadarko in its data
requests is underlined):
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.2
(a)"The presenceof existing mineral claims and leases could interfere with plans to
construct the Project.As part of the pre-construction process,the Proponents would identify
active mining claims and mineral leases and either negotiate permission to use the land
surface in these areas or re-locate the transmission line to avoid existing active claims and
leases.However,the Mining Act of July 23,1955,provides the opportunityfor surface rights
for multiple uses on mining claims established after that date.Where access to mineral
resources may be restricted,the Proponents would provide compensation for damage,access
rights,and easements to mine owners,claimants,and lease holders."
If necessary,mine operators would be provided with mine access across the Transmission
Project area during construction.
(b)"The construction of the Project could restrict explorationof mineral resources during the
2-year construction period.Construction activities could also restrict mining companies'
ability to access land for mining or exploration.Construction of the Project would result in
the need for saleable minerals,including fill material for grade changes,sand and gravel for
concrete production,gravel for road beds,and similar uses.The use of saleable minerals
would provide an economic benefit to local mineral providers but would also result in
consumption of materials that would not be available for other uses."
(c)"During the operations period,the Project could restrict the operation of new mines
within the transmission line ROW.The operations area is smaller than the construction
disturbance area but the time interval is much longer:50 years for operations compared to
about 2 years for construction.The Scoping Report (Tetra Tech 2009)indicated concern that
the high-voltagetransmission lines would restrict access to drill rigs conducting exploration
or repair of oil or gas wells.Project operations would remove acreagethat would not be
available for mining for the life of the Project.However,the Project would only impact a
small fraction of the total resource area available."
(d)"This section evaluates the Proposed Route and details the differences between the
Proposed Route and the Route Alternatives with respect to impacts to mining claims and
mineral leases.Tables 3.12-3 and 3.12-4 present the locatable,leasable,or saleable mineral
development present within the Project construction and operations disturbance areas,as
noted in the LR-2000 database.Table 3.12-5 presents the number of active oil or gas wells
within the construction and operations disturbance areas.
Segment 3
A single-circuit 500-kV line would link the former location of the Creston Substation,
approximatelv 2.1 miles south of Wamsutter,Wyoming,to the proposed Anticline Substation
near the existing Jim Bridger Power Plant.Segment 3 would be approximately45.9 miles
long.This segment also includes a 5.1-mile segment of 345 kV line to connect to the existing
Jim Brideer Power Plant Substation (Segment 3A).There are no alternatives proposed along
Segment 3.Figure A-4 in Appendix A shows the location of the Segment 3 routes.A total of
312 acres of mineral interests would be affected in the Segment 3 construction disturbance
area.The affected area would consist almost entirely of oil and gas leases,and 22 acres of
coal leases which are also contained within the oil and gas leases.The operations area would
contain 39 acres of affected area.Despite the high percentage of oil and gas leases,no oil or
gas wells would be located within the disturbance areas."
Respondent:Nancy Smith /Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.2
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.3
Anadarko Data Request 3.3
Does Rocky Mountain Power admit that the Bureau of Land Managementapproved four
segments in Wyoming for the Gateway West Transmission Line Project and that Rocky
Mountain Power's CPCN Application only addresses three of these segments?
Response to Anadarko Data Request 3.3
Rocky Mountain Power has agreed to a phased implementation of the Energy Gateway
West Transmission Line project with the United States Bureau of Land Management
(BLM).The record of decision (ROD)dated November 2013 details a transmission line
project from the Windstar substation,near Glenrock,Wyomingto the Wyoming/Idaho
stateline near Cokeville,Wyoming.The certificate of public convenience and necessity
(CPCN)application covers certain elements of the Energy Gateway West Transmission
Line Project as described above,from Shirley Basin substation to the Jim Bridger
generating station,near Point of Rocks,Wyomingonly.
Respondents:Todd Jensen /Stuart Smith
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.4
Anadarko Data Request 3.4
Roderick D.Fisher states in his Rebuttal Testimony from December 18,
2017 (p.3),that "The Company believes that many of the landowner issues raised here
are better addressed in forums designed to specifically address landowner issues,not in
this case.Moreover,many of the issues raised here have alreadybeen addressed during
the federal permitting process."Please identify the forums that Rocky Mountain Power
concludes are designed to address landowner issues?Please identify the federal
permitting process for the Wind Projects where landowner issues were addressed?
(a)If the "landowner issues"were addressed in the federal permitting process,then does
Rocky Mountain Power admit that the Transmission Line right-of-waywill interfere with
mineral development?
(b)Does Rocky Mountain Power admit that the Gateway West FEIS did not address the
Wind Projects now proposed in the Supplemental Testimony filed January 16,2018 as a
cumulative,similar or connected action?
Response to Anadarko Data Request 3.4
The most productive forum to address landowner issues is in direct dialogue with Rocky
Mountain Power.Landowners also have the opportunityto engage in the Industrial Siting
Council permitting processes and local county conditional use permitting processes for
the transmission projects and wind projects.The wind projects have been developed to
avoid federal nexus,and as such do not require federal permitting of the nature completed
for the Transmission Projects.Please refer to Anadarko Data Request 3.9 for a
description of how landowner issues are addressed for the wind projects.
(a)Please refer to the Company's response to Anadarko Data Request 3.2.
(b)See above.The wind projects are not addressed in the Gateway West Transmission
Line Project FEIS process.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.5
Anadarko Data Request 3.5
Rocky Mountain Power has indicated in its August 23,2017,response to OCA's Data
Request 1.053 that the estimated acquisition cost for rights-of-wayfor the 500 kV
transmission line total $20 million and the estimated acquisition cost for the rights-of-
way for the 230 kV transmission line total $2.08 million.Does this estimated acquisition
cost include the cost to compensate subsurface right owners for any lost right to mineral
development?Does this amount include the inverse condemnation of mineral estates
associated with the Wind Power Projects?
Response to Anadarko Data Request 3.5
The Company objects to this request because the budget information requested is beyond
the scope of a Certificate of Public Convenience and Necessity (CPCN)proceeding.
Compensation will be addressed during right-of-way(ROW)negotiations with each
affected party.Disclosing this information to individual property owners who will be
counterparties in negotiations and possible litigation over valuation of their private
property could be highly detrimental to 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 responds as follows:The Company's current estimated rights-of-way
acquisition costs referenced above were developedbased upon the Company's experience
with past transmission projects and are intended to capture the cost to compensate
subsurface rights owners for any compensable lost mineral development rights,as well as
other rights-of-wayacquisition costs and contingencies.This estimated cost is only
applicable to acquisition of rights-of-wayand access for the transmission line facilities
and not the wind projects.
Respondent:Shawn Graff
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.6
Anadarko Data Request 3.6
When has Rocky Mountain Power initiated any negotiations with Anadarko Land Corp.
for a right-of-wayfor the Transmission Line Projects or the Wind Projects?
Please identify the persons representingRocky Mountain Power who made each
communication,the person from Anadarko Land Corp.to whom the communication was
made,the form of communications,the dates that each communication occurred,and the
outcome of such communications.
Response to Anadarko Data Request 3.6
See table below for a summary of communications with Anadarko regarding the projects.
Negotiation of definitive agreements for right-of-wayacquisition for the transmission
projects and associated access roads will begin when remaining survey data is prepared
for deliveryof the right-of-way offer.Now that a final shortlist has been identified from
the 2017R RFP,the Company is confirmingthe mineral interests affected by the Wind
Projects,and will commence negotiations accordingly.
DATE RMP Rep Anadarko Rep Communications Purpose/Outcome
2009-Erik Grill George Peters several e-mails and Rights of entry for
2011 or and Suzanne phone calls studies and surveys -
2012 Turner entry agreements
2009-Glenda Fisher George Peters several e-mails and Coordinate entry on
2014 and Suzanne phone calls Anadarko lands
Turner
2/22/20 Several Several meeting at Anadarko Discuss project design
12 in Denver and coordination
between companies
2012 Stuart Smith Don Ballard e-mails Confidentiality
agreement
2012-Shawn Graff Andrew Volker several e-mails and Coordinate entryon
2013 phone calls Anadarko lands and
discuss project details
10/16/2 Several Ted Huss meeting with Rock Review project design
013 Springs Grazing and existing Anadarko
Assoc facilities
2014 Glenda Fisher Nolan e-mails Coordinate entryon
McWherter Anadarko lands
2014-Shawn Graff Nolan several e-mails and Coordinate entryon
2015 and Pam McWherter phone calls Anadarko lands and
Anderson discuss project details
5/9/201 Shawn Graff Andrew e-mail Introduction to
7 Wurdack Andrew upon Nolan
McWherter's departure
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.6
May-Shawn Graff Andrew dozens of e-mails Sharing project details
Nov Wurdack and several phone and coordination
2017 calls includingshapefiles;
entry agreement;
coordinating entryon
Anadarko lands for
studies;scheduling
meetings;sharing
documents
8/30/20 Several Several meeting at Anadarko Discuss project design
17 in Denver and coordination
between companies
Respondent:Shawn Graff
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.7
Anadarko Data Request 3.7
Does Rocky Mountain Power admit that the Gateway West Transmission
Line Project FEIS only identified possible wind energy regions and did not identify or
discuss the ~9 ~Wind Projects included in Rocky Mountain Power's Applicationor in
the four Wind Projects identified in Rocky Mountain Power's SupplementalTestimony
from January 16,2018?
Response to Anadarko Data Request 3.7
Yes.See Gateway West Transmission Line Project FEIS,Chapter 1.3.6,p.24-26.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.8
Anadarko Data Request 3.8
Where in the Gateway West Transmission Line Project FEIS or any other
National Environmental Policy Act document are the effects of the Wind Projects in
Uinta and Converse Counties disclosed and analyzed?Please identify the federal lands
within the Wind Projects'boundaries or immediately adjacent.In doing so,use the
definition of public lands found in the Federal Land Policy and ManagementAct,43
U.S.C.§1702(e).
Response to Anadarko Data Request 3.8
It was unnecessary for the Uinta and Cedar Springs wind projects to be disclosed and
analyzed as part of the Gateway West transmission line project FEIS as they were not
foreseen at the time and are independentof the transmission projects.
Known property information for the Uinta project was presented as Confidential Exhibit
RMP (CAT-4SD-2-A).
Known property information for the Cedar Spring project was presented as Confidential
Exhibits RMP_(CAT-lSD-4),RMP (CAT-lSD-5),and RMP (CAT-1SD-6).
All public lands managed by the Bureau of Land Management (BLM)will be avoided
within the wind project boundaries.The wind project developers will continue to identify
and map any public lands managed by the BLM immediately adjacent to the referenced
property limits.Affected land owners will be contacted as required.Any emerging
federal permitting issues will be addressed.
Respondents:Rod Fisher /Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.9
Anadarko Data Request 3.9
Please identify each permit that the Wind Projects will require from any federal agency,
includingthe BLM.
(a)Please identify the process to be followed under the National Environmental Policy
Act.
(b)If Rocky Mountain Power has concluded it does not need to comply with the National
Environmental Policy Act for any of the Wind Projects,please identify the Bureau of
Land Managementofficial or any other federal agency concurring with this decision.
Response to Anadarko Data Request 3.9
Please refer to the TB Flats I and II benchmark project Confidential Exhibit CAT2-16 for
the anticipated list of required permits,includingfederal pennits.Please refer to the
McFadden Ridge II benchmark project Confidential Exhibit CAT3-17 for the anticipated
list of required permits,includingfederal permits.Please refer to the Cedar Springs
NextEra project Confidential Exhibit RMP_(CAT-1SD-9)for the anticipated list of
required permits,includingfederal permits.Please refer to the Uinta Invenergyproject
Confidential Attachment Anadarko 3.9 for the anticipated list of required permits,
includingfederal permits.
(a)The proposed Wind Projects avoid public lands managed by the Bureau of Land
Managementand are not subject to a federal land nexus that would trigger the
National Environmental Policy Act process.Acquisition of a voluntaryeagle take
permit would likelyrequire an Environmental Assessment under the National
Environmental Policy Act process.The process is detailed at the followinglink:https://elips.doi.gov/ELIPS/DocView.aspx?id=1739.Other federal permits would be
obtained as identified in the aforementionedexhibits.
(b)None identified.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
Respondents:Richard Goff /Travis Brown /Suzan Baker
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.10
Anadarko Data Request 3.10
Does Rocky Mountain Power admit that the Wind Projects affect resources regulated by
a federal agency,such as Migratory Birds,Golden Eagles,cultural and historical
resources,or federal mineral estate?
Response to Anadarko Data Request 3.10
Similar to all energy production activities (i.e.,oil and gas production,mining,etc.),
developmentof the Wind Projects may impact various resources regulatedby federal
agencies.
Respondent:Richard Goff /Travis Brown
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.11
Anadarko Data Request 3.11
Does Rocky Mountain Power or the third party developers of the Wind Projects intend to
negotiaterights-of-wayor use condemnation authorityto secure rights-of-wayover the
underlyingmineral estate for the Wind Projects?
Response to Anadarko Data Request 3.11
For areas where mineral extraction is active or mineral estate development is imminent or
anticipated (i.e.,areas with existing mine permits,applications for permits to drill,etc.),it
is expected that the wind developer will secure agreements with the mineral estate owner
via some form of surface and accommodation agreement.
Respondent:Erik Carlson
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.12
Anadarko Data Request 3.12
For Segments 2 and 3 of the Gateway West Transmission Line Project,about 52 and 67
percent,respectively,of the right-of-wayanalysis area is classified as having subsidence
prone soils.GatewayWest FEIS at Ch.3.14,p.12.How does Rocky Mountain Power plan
to deal with the subsidence issue as it constructs the Transmission Line?
Response to Anadarko Data Request 3.12
The Company objects to this request because the subsidence information requested is
beyond the scope of a Certificate of Public Convenienceand Necessity (CPCN)
proceeding.Without waiving this objection,the Company responds as follows:Where
there exists the potential for surface subsidence,Rocky Mountain Power will perform
technical assessments and incorporate appropriate engineeringto determine the potential
magnitude of any impact and select the appropriate course of action to protect the
transmission line,if any.
Respondent:Jim Higgins
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.13
Anadarko Data Request 3.13
In its January 8,2018 Supplemental Response to Anadarko Land Corp.'s Data Request
1.2,Rocky Mountain Power stated that it would coordinate with "pipeline businesses
during the permitting,engineering,and construction phases of high voltage transmission
line projects to ensure final designs and necessary corrosion mitigations do not impact the
daily operation and long-term life expectancy of the pipelines."Rocky Mountain Power
identified the followingmitigation options:"facility grounding,line micro-siting
adjustments,operatorprotection,corrosion protection and/or other appropriate solutions."
(a)What is the maximum design current for each phase of the transmission line and for
the total transmission line?
(b)What are the location and arrangement of phase transpositions where the transmission
line right-of-wayis within 2,000 feet of APC pipelines?
(c)What conductor sizes and types are being used?
(d)What are the grounding conductor designs for the 500 kV towers?Are the drilled
piers part of the grounding configuration or is there a different grounding plan?
(e)What minimum spacing is planned to be maintained between the tower
foundations/grounding equipment and existing infrastructure/equipment (i.e.APC
pipelines)?
(f)Will a fault notification system be in place to communicate when and where faults
occur along the transmission lines,and provide the nature of the faults?
Response to Anadarko Data Request 3.13
(a)The line is designed to carry 1500 megawatts.For this line the normal maximum
current is 3150 Amps per phase or 9450 Amps for all three phases of the circuit.
(b)Each phase transposition tower is proposed at approximately one third distances
between Anticline and Aeolus substations.These towers individuallyaccomplish a
one third roll of phases with the left phase moving to the center position,the center
position moving to the right and the right position moving to the left.A review of
APC pipeline shape files would be required to verify if any of these towers are within
200 feet of the pipeline.
(c)There is one conductor type for the entire line.The conductor will be triple bundle
per phase 1272 kcm ACSR 45/7 "Bittern"
(d)Rocky Mountain Power utilizes the drilled piers as ground electrodes for the
transmission line.Stub angles are bonded to the steel reinforcement inside the
concrete.Once the conductors are installed,a Megger or other meter is used to
measure resistance at each tower location.Where measured resistance exceeds 15
ohms,a ground wire is bonded to the tower stub angle and connected to a ground rod
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.13
driven near the foundation.Resistance is measured and ground rods added until it
measures less than 15 ohms.In areas of high resistivity,counterpoise may be installed
within the ROW to achieve less than 15 ohms of resistance.The Aeolus to Jim
Bridger Project is located in generally fine grained,low resistivitysoils.Therefore the
500 kilovolt tower drilled piers are expected to be sufficient to provide grounding for
the transmission line.
(e)Rocky Mountain Power has not standardized a "minimum"spacing between tower
foundations/grounding equipment and existing infrastructure.Rocky Mountain Power
observes the National Electric Safety Code regarding electrical clearance from
adjacent facilities.Often that clearance provides for concerns associated with
foundations and adjacent infrastructure.In the case of APC pipelines,Rocky
Mountain Power will microsite towers,and their foundations,such that the
foundation,its excavation and construction will not impose loading on the existing
pipeline.That spacing is dependent on the expected foundation loads,the soil type(s),
the dimensions of the foundation and depth of the pipeline.
(f)The transmission line will be constructed with communications equipment providing
notifications to PacifiCorp dispatch of any fault.This information for faults of
significant duration will be passed on to maintenance crews to restore the line to
proper working order.
Respondent:Joe Hallman /Jim Higgins
Witness:Rick Vail
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.14
Anadarko Data Request 3.14
Rocky Mountain Power states it "has done prudent legal research on its rights as a
surface lease holder,as compared to those of subsurface right holders,and is comfortable
that the law does not allow subsurface right holders to unilaterallydisplace the
Company's facilities and that any subsurface right holder would be required to enter into
good faith negotiations to reasonably accommodate its subsurface extraction objective."
See e.g.Direct Testimony of Chad A.Teply at Ex.RMP_(CAT-1)Page 12 of 13.Is it
Rocky Mountain Power's position that Wyoming law no longer recognizes that "mineral
rights are dominant to wind energy rights"(see Jakle et al.,Commercial Wind Energy
Development in Wyoming:A Guidefor Landowners (Second Edition June 2011)
(referring to the WyomingWind Energy Rights Act of 2011))even if the mineral estate
rights,includingmineral leases or mining claims,vested prior to the wind energy project
or transmission line right-of-way?
Response to Anadarko Data Request 3.14
The Company objects because this data request seeks a legal opinion,it impliedly
characterizes Wyominglaw in a manner with which the Company disagrees,and it seeks
information outside the scope of a Certificate of Public Convenience and Necessity
(CPCN)proceeding.
Respondent:Yvonne Hogle
Witness:None
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.15
Anadarko Data Request 3.15
Please identify the surface right leases that Rocky Mountain Power holds other than the
Bureau of Land Managementright-of-way for both the Wind Projects and the
Transmission Line?
Response to Anadarko Data Request 3.15
PacifiCorp does not hold any other surface right leases for the GatewayTransmission
Line at this time.
The McFadden Ridge II and TB Flats I and II Wind Projects will be built on land
PacifiCorp owns,has options to purchase,has agreements in place to acquire wind leases
and access agreements that include the rights to build the Wind Projects and associated
infrastructure,or is currentlynegotiating agreements to acquire wind leases and access
agreements that include the rights to build the Wind Projects and associated agreements.
For the McFadden Ridge II project surface right holder information,see Highly
Confidential Exhibit RMP (CAT-3-7).
For the TB Flats I and II projects surface right holder information,see Highly
Confidential Exhibit RMP (CAT-2-7).
For the Cedar Springs project surface right holder information,see Confidential Exhibit
RMP_(CAT-lSD-4),Confidential Exhibit RMP_(CAT-1SD-5),and Highly
Confidential Exhibit RMP (CAT-1SD-6).
For the Uinta project surface right holder information,see Confidential Exhibit
RMP (CAT-4SD-1-A)and Highly Confidential Exhibit RMP_(CAT-4SD-5)
To make arrangements to view highly confidential exhibits,please contact Stacy
Splittstoesser at [phone] or Yvonne Hogle at [phone].
Respondent:Ken Clark
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.16
Anadarko Data Request 3.16
If Rocky Mountain Power claims it will negotiate concessions with landowners how can
it reconcile this willingness with the statement that litigation over landowner issues will
delay and defeat the CPCN proceedings?
(a)If Rocky Mountain Power claims that the Industrial Siting Council is the forum to
address landowner issues,please explain why those proceedings will not also delay
the initiation of construction?
Response to Anadarko Data Request 3.16
The Company objects to this request because it is argumentative and requests information
on the Company's legal position on its pending motion to strike.Without waiving this
objection,the Company responds as follows:The Company recognizes that development
of wind and transmission projects requires the Company to engage in multipleregulatory
processes.Each of these processes has a defined scope and purpose.The expansion of
any of these processes beyond its proper scope and purpose could unnecessarily delay
development of the new wind and transmission projects.
Respondent:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
Anadarko Data Request 3.17
Anadarko Data Request 3.17
WyomingStatute requires that each landowner who may be affected by a high voltage
electric transmission line must receive notice of the hearing on the certificate for the
construction and operation of the line.Wyo.Stat.§37-2-205(e).Please produce all
records Rocky Mountain Power provided to the Commission for purposes of fulfilling
this notice requirement.
Response to Anadarko Data Request 3.17
The Company objects because the statute speaks for itself and the Company does not
necessarily agree with its characterization in this data request.Without waiving this
objection,the Company responds as follows:Please see Attachment Anadarko 3.17.
Respondent:Stacy Splittstoesser
Witness:Rod Fisher