20180329PAC to Staff WY Anadarko Set 4 (1-5).pdf

ROCKY MOUNTAIN
POWER
ADIV1SIONOFPACIFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
March 16,2018
Constance E.Brooks
Danielle Bettencourt
C.E.BROOKS &ASSOCIATES,P.C.
5445 DTC Parkway,Suite 940
Greenwood Village,Colorado 80111
[e-mail] (C)
(danielle@cebrook_s (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 4th Set Data Request (1-5)
Please find enclosed Rocky MountainPower's Responses to Anadarko 4th Set Data Requests
4.1-4.5.Also provided is Attachment Anadarko 4.4.Provided on the enclosed Confidential CD
is Confidential Attachment Anadarko 4.2.Confidential information is provided subject to the
terms and conditions of the protective agreement in this proceeding.
Sincerely,
Stacy Sp ittstoesser,
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/Southland [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
March 16,2018
Anadarko Data Request 4.1
Anadarko Data Request 4.1
On page 9,lines 4-10 of her Direct Testimony,Cindy Crane states the Transmission
Project "will lead to a slight reduction in coal-based generationfrom the Company's
Wyomingcoal fleet.Even with this reduced dispatch,Wyoming will experience a net
benefit in tax receipts,as the projected property tax and wind production tax significantly
exceed the projected reduction in royalties associated with reduced coal utilization."
(a)Did Rocky Mountain Power base this calculation on the Bridger Coal mine or did it
take into account decreased coal production elsewhere along the route of the
Transmission Line?
(b)Did Rocky Mountain Power consider other mine closures along this system?
Response to Anadarko Data Request 4.1
(a)The referenced calculation was based upon the Wyomingsourced tonnage for the
respective coal-based generation affected by reduced dispatch.
(b)The referenced calculation is not based on mine closures.
Respondents:Chad Teply
Witness:Cindy Crane
20000-520-EA-17 /Rocky Mountain Power
March 16,2018
Anadarko Data Request 4.2
Anadarko Data Request 4.2
The Rocky Mountain Power Application used Dunlap Wind Power Project as a proxy for
the geological report on the proposed Ekola Flats Wind Power Project.Chad A.Teply
Direct Test.,Ex.RMP_(CAT-1)Page 5 of 13,Confidential Ex.CATl-8.Has Rocky
Mountain Power conducted a geological study pursuant to Rule 21(c)(ii)(C)for Ekola
Flats?
Response to Anadarko Data Request 4.2
The Dunlap geological report continues to serve as the proxy geological report for the
Ekola Flats project in the Company's filings to date,as it provides regional geological
information representative of the project site.Please refer to Confidential Attachment
Anadarko 4.2,which provides a copy of a preliminarygeotechnical report prepared
specifically for the Ekola Flats Wind Farm and dated September 13,2017,that provides
site-specific geological study information in support of Rule 21(c)(ii)(C)requirements.
Additional geotechnical studies will be completed,should project implementation and
detailed engineering be authorized to proceed.
Confidential information is provided subject to the terms and conditions of the protective
agreement in this proceeding.
Respondents:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 16,2018
Anadarko Data Request 4.3
Anadarko Data Request 4.3
The Rebuttal Testimony by Cindy Crane dated December 18,2017 at page 6 states:
"[t]he Company will also prudentlynegotiateprecautionary off ramps in the contracts to
allow it to exit the Transmission Projects if they become uneconomic.The timing and
terms of the execution of the contracts necessary to procure or construct the Wind
Projects will also provide flexibilityto allow the Company to reassess project economics,
if necessary,before executing the contracts."
(a)Does Rocky Mountain Power still have off-ramps if the schedule were to change such
that the wind power projects cannot be completed in time to exercise the production
tax credits?
(b)What will trigger the off-ramp and when?
Response to Anadarko Data Request 4.3
(a)Yes.
(b)Off-ramps could be triggered by a varietyof circumstances along the project
implementation schedule including,but not limited to,failure to obtain timely
regulatory approvals,failure to obtain timely permits,failure to timely acquire right
of way,unsuccessful procurement and negotiation of major contracts,significant
changes in assessed economic benefits,policy changes,or other force majeure events.
Respondents:Chad Teply
Witness:Cindy Crane
20000-520-EA-17 /Rocky Mountain Power
March 16,2018
Anadarko Data Request 4.4
Anadarko Data Request 4.4
In his Supplemental Rebuttal Testimony dated January 8,2018 at page 10,lines14-18,
Roderick Fisher refers to:"the Company's existing Glenrock RollingHills wind farm has
existing oil and gas wells and access roads located within and adjacent to the project
boundaries,as well as a bentonite surface mine.Coordinating with affected landowners
can provide for multiplecompatible,different land uses with appropriateplanning."
Please identify the location of the bentonite mine in relation to the wind farm operations.
Response to Anadarko Data Request 4.4
Please refer to Attachment Anadarko 4.4.
Respondents:Laine Anderson
Witness:Roderick Fisher
20000-520-EA-17 /Rocky Mountain Power
March 16,2018
Anadarko Data Request 4.5
Anadarko Data Request 4.5
With respect to Confidential Exhibits for the wind projects,Rocky Mountain Power lists
the landowners,both surface and subsurface.Please provide the data bases and
information Rocky Mountain Power used to compile the landowner information.
Response to Anadarko Data Request 4.5
The data bases and information used to compile landowner information include the
following:
Surface Rights:
Whitestar Corporation provided County land ownership data,last pulled from Carbon
County and Albany County records,May 2017.
Subsurface Rights:
1.Carbon County,Wyoming Clerk's Office
--Recorded land records
2.Carbon County Assessor's Office
--Property ownership records
3.Wyoming Second District Judicial Court
--Probate and last will and testament files for Carbon County
4.AlbanyCounty,Wyoming Clerk's Office
--Recorded land records
5.Wyoming Second District Judicial Court
--Probate and last will and testament files for AlbanyCounty
6.Laramie County,Wyoming Clerk's Office
--Recorded land records
7.United States (U.S.)Bureau of Land Management(BLM),Cheyenne,Wyoming
--Master Title Plats
--Oil and Gas plats
--LR2000 Program
--Active oil and gas leases
--Active mining claims
8.Wyoming Oil and Gas Conservation Commission
--Producing oil and gas wells
9.State of Wyoming,Office of State Lands and Investments
--Property ownership records
--Mineral ownership records
20000-520-EA-17 /Rocky Mountain Power
March 16,2018
Anadarko Data Request 4.5
--Oil,gas,mining and wind lease records
Respondents:Richard Goff
Witness:Chad Teply