20180208PAC to Staff WY BP Set 2 (18-24).pdf

ROCKY MOUNTAINPOWER
ADIVISIONOFPAClFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
February 2,2018
Nicol Thompson Kramer
Beatty &Wozniak,P.C.
123 W.Ist Street,Suite 120
Casper,WY 82601
[e-mail] (C)
James B.Martin
Beatty &Wozniak,P.C.
216 16th Street,Suite 1100
Denver,CO 80202
[e-mail] (C)
RE:Wyoming Docket 20000-520-EA-17
BP 2nd Set Data Request (18-24)
Please find enclosed Rocky Mountain Power's Responses to BP 2nd Set Data Requests 18-24.
If you have any questions,please call me at [phone].
Sincerely,
Stacy Splittstoesser,
Manager,Regulation
Enclosures
C.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)
Meridith Bell/WPSC [e-mail](C)
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)
Adele Lee/WIEC [e-mail] (W)
Nik Stoffel/WIEC [e-mail] (C)(W)
Christopher Leger/OCA [e-mail] (C)
Crystal J.McDonough/[e-mail] (C)
Callie Capraro/NLRA [e-mail]
Lisa Tormoen Hickey/[e-mail] (C)
Brandon L.Jensen/RMSC [e-mail] (C)
Roxane Perruso/TOTCO [e-mail]
Jane M.France/TOTCO [e-mail] (C)
Constance E.Brooks/Anadarko [e-mail] (C)
Danielle Bettencourt/Anadarko [e-mail](C)(W)
Paul Kapp/Anadarko [e-mail] (C)
Lisa Christian/TOTCO [e-mail] (C)
J.Kenneth Barbe/Southland [e-mail] (C)
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 18
BP Data Request 18
Identify all projects during the last ten years in which You have traversed active oil and
gas fields and describe what those projects entailed,includingbut not limited to,
construction of new facilities,transmission lines,wind turbines,solar panels,or access
roads.
Response to BP Data Request 18
No such projects have been identified in the last ten years.
Respondent:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 19
BP Data Request 19
For all projects identified in InterrogatoryNo.18,please describe how You resolved
conflicts,whether throughright-of-waynegotiations,condemnation proceedings or
otherwise,with surface owners,mineral owners and mineral leaseholders.
Response to BP Data Request 19
Not applicable.No projects were identified in the Company's response to BP Data
Request 18.
Respondent:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 20
BP Data Request 20
For all projects identified in InterrogatoryNo.18,please describe when conflicts with
surface owners,mineral owners and mineral leaseholders were resolved.Specifically,
were conflicts resolved prior to a hearing on a certificate for public convenience and
necessity,prior to proceedings before the Wyoming Industrial Siting Council (or
equivalent agency),or prior to beginning construction on the project.
Response to BP Data Request 20
Not applicable.No projects were identified in the Company's response to BP Data
Request 18.
Respondent:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 21
BP Data Request 21
Identify all projects during the past ten years in which terms or conditions related to
property interests,mitigation or reclamation requirements,or reporting requirements
were placed on any certificate of public convenience and necessity that You received.
Response to BP Data Request 21
No projects identified.
Respondent:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 22
BP Data Request 22
For all projects identified in Interrogatory No.21,describe the terms or conditions
attached to the certificates of public convenience and necessity.
Response to BP Data Request 22
Not applicable.No projects were identified in the Company's response to BP Data
Request 21.
Respondent:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 23
BP Data Request 23
Please produce each and every document You identified,described,referred to,or
otherwise relied upon in responding to the above interrogatories and identify the
Interrogatorywith which the documents are associated.
Response to BP Data Request 23
No projects identified.
Respondent:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
February 2,2018
BP Data Request 24
BP Data Request 24
Please produce all agreements into which You entered with a mineral owner or mineral
leaseholder during the past ten years in which You agreed to modify a project of Yours to
allow for or preserve the ability of the mineral owner of mineral leaseholder to develop
the mineral estate or to conduct mineral exploration or production operations.
Respectfullysubmitted this 26th day of January,2018.
Response to BP Data Request 24
No projects have been identified where the Company would have had such agreements.
Respondent:Richard Goff
Witness:Chad Teply