20180329PAC to Staff WY Anadarko Set 5 (1-25).pdf

ROCKY MOUNTAINPOWER
A DIVISION OF PACFFICORP 1407 W North Temple,Suite 330
Salt Lake City,Utah 84116
March 22,2018
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 5th Set Data Request (1-25)
Please find enclosed Rocky Mountain Power's Responses to Anadarko 5th Set Data Requests
5.1-5.25.Also provided is Confidential Response Anadarko 5.25.Confidential informationis
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
March 22,2018
Anadarko Data Request 5.1
Anadarko Data Request 5.1
Rocky Mountain Power admits that high voltage transmission lines can impact pipelines
and similar metallic facilities,particularlywhen paralleling pipeline facilities.In
locations where facilities closely parallel the transmission line and are constructed of
conductive materials,Rocky Mountain Power admits that there is a potential for induced
voltage on such facilities.If Rocky Mountain Power does not admit,explain why they
disagree.
(a)Rocky Mountain Power admits that AC transmission lines have potential to induce
currents on adjacent metallic structures,such as transmission lines,pipelines,fences,
or structures parallel to,cross,or are adjacent to the transmission line.Induced
current may occur on these facilities during steady-state operating conditions or
during a fault condition on the transmission line.If Rocky Mountain Power does not
admit,explain why they disagree.
(b)Rocky Mountain Power admits electrical and magnetic currents may interfere with
operating facilities and abandoned facilities within the transmission project siting
area.If Rocky Mountain Power does not admit,explain why they disagree.
Response to Anadarko Data Request 5.1
The Company denies this request except as stated in the Supplemental Rebuttal of
Roderick Fisher (Part 2)at page 17,line 11 to page 23,line 9.As explained in that
testimony,Rocky Mountain Power recognizes the potential for AC Interference on
metallic facilities adjacent HVAC transmission lines.Rocky Mountain Power is
committed to working with affected pipeline companies to mitigate quantified AC
Interference impacts according to industrystandards and guidelines.
Respondents:Jim Higgins,Stuart Smith
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.2
Anadarko Data Request 5.2
Rocky Mountain Power admits that electrical studies of specific facilities and lines must
be undertakento determine the mitigation measures most likely to succeed.If Rocky
Mountain Power does not admit,explain why theydisagree.
(a)Rocky Mountain Power will use pre-and post-installation surveys to determine the
impact and potential need for mitigation,and will also monitor the potentially
impacted structures and mitigate issues as identified or encountered.If Rocky
Mountain Power does not agree,explain why they disagree.
(b)Rocky Mountain Power admits that techniques like grounding and shielding are
required to prevent electrical and magnetic interference from transmission lines on
adjacent facilities.If Rocky Mountain Power does not admit,explain why they
disagree.
(c)Rocky Mountain Power admits that for a line power of 1500 MW,at least 36 feet of
separation is required between the nearest grounding electrode and any other buried
conductor or structure at crossings and a minimum spacing requirement of 2,500 feet
for parallel segments.If Rocky Mountain Power does not admit,explain why they
disagree.
Response to Anadarko Data Request 5.2
(a)Rocky Mountain Power denies this request except as stated in the Supplemental
Rebuttal of Roderick Fisher (Part 2),page 17,line 11 to page 23,line 9.As explained
in that testimony,the Company may use a variety of pre-installation and post-
installation surveys to determine impacts and potential mitigations based upon the
specific circumstances of each location and the requirements of impacted structure
owners.
(b)Rocky Mountain Power denies this request except as stated in the Supplemental
Rebuttal of Roderick Fisher (Part 2),page 17,line 11 to page 23,line 9.The
Company may use such techniques where proven to be required by the pre-
installation and,where applicable,post-installation studies
(c)Rocky Mountain Power denies this request except as stated in the Supplemental
Rebuttal of Roderick Fisher (Part 2),page 17,line 11 to page 23,line 9.As explained
in that testimony,INGAA separation guidelines are developed to demonstrate the
severity of AC interference over a range of distances.The INGAA does not require
that separations be physicallyapplied,theymerely provide a range of distances to
demonstrate unmitigated impacts.Application of suitable mitigation strategies
developed through engineering study will reduce the severity of the AC interference
over the same range of distances shown in the INGAA guidelines.
Respondents:Jim Higgins,Stuart Smith
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.2
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.3
Anadarko Data Request 5.3
Rocky Mountain Power admits that it will negotiate with landowners,both surface and
mineral estate holders,regarding possible conflicts the placement of the transmission line
will have on mineral rights and will mitigate such impacts through transmission line
relocation or compensation.If Rocky Mountain Power does not admit,explain why they
disagree.
(a)However,Rocky Mountain Power admits that relocating the transmission line is not
always possible due to the Bureau of Land Management alreadyapproving the right
of-way for the transmission line right-of-wayacross public lands and the
impossibilityof avoiding conflicts with all resources in the area.If Rocky Mountain
Power does not admit,explain why they disagree.
Response to Anadarko Data Request 5.3
The Company denies this request except as stated in the pre-filed rebuttal and
supplemental rebuttal testimony of Mr.Roderick Fisher.As explained in that testimony,
due to the federal permitting process,currentlyapproved record-of-decision right-of-way
grant,and the need to minimize or avoid disturbance and conflicts with resources,it may
not always be possible to relocate the transmission line on United States (U.S.)Bureau of
Land Management (BLM),(or other Federal property covered by NEPA)property.
Respondents:Stuart Smith,Nancy Smith
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.4
Anadarko Data Request 5.4
Roderick Fisher in his Rebuttal Testimony,page 3 lines 15-17,of March 14,2018 states:
"[I]ncluding conditions in a CPCN that provide an advantage to an intervening property
owner could increase the costs or risks of a project to all customers,which would be
contrary the public convenience and necessity."
(a)Please provide facts supporting the conclusion that the conditions would increase the
costs or risks of the project to all customers with respect to each condition identified
by Susan Aldridge of Anadarko.
(b)Please explain the factual basis upon which Mr.Fisher bases his conclusion that it is
contrary to the public interest to protect the rights of landowners and especially the
owners of mineral interests.
(c)Please explain the factual basis upon which Mr.Fisher bases his statement that it is
contrary to the public interest to adopt mitigation measures to protect existing
pipeline systems from electromagnetic interference such as sufficient separation
between the transmission line and pipeline systems or to install monitoring equipment
to address electromagneticinterference and potential corrosion.
(d)Please explain how such mitigation measures to protect existing pipeline systems
from electromagnetic interference such as sufficient separation between the
transmission line and pipeline systems or to install monitoring equipmentto address
electromagnetic interference and potential corrosion would delay the project,increase
risks,and increase costs to Rocky Mountain Power customers.
Response to Anadarko Data Request 5.4
(a)Rocky Mountain Power asserts that a CPCN condition,of any type,in the favor of
one or more particular intervenors imposing individuallypreferred requirements
which may or may not have been required as a result of detailed study and analysis as
per Company standard practice or other governing codes and standards,would delay
the project,increase risks,and increase costs to a project if inappropriately leveraged
to drive individuallypreferred outcomes determined to be unnecessary other than to
meet a pre-establishedCPCN condition.See SupplementalRebuttal Testimony of
Roderick Fisher,pages 2-4,and SupplementalRebuttal of Roderick Fisher (Part 2),
pages 2-23.
(b)See response to subsection (a).
(c)See response to subsection (a).
(d)See response to subsection (a).
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.4
Respondents:Rod Fisher/Todd Jensen/Stuart Smith
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.5
Anadarko Data Request 5.5
Roderick Fisher in his Rebuttal Testimony,page 4 lines 14-17,of March
14,2018 states:
"Contraryto Anadarko's testimony,subsection (C)does not specifically address mineral
rights issues,and there is no reference to a one-mile radius in either subsection;the only
reference to such a radius is in subsection (B),describing the requirements of the
geological report."
(a)Please explain the basis for the statement that subsection (C)does not require the
applicant to address mineral rights issues when Chapter 3,Rule 21(c)(ii)(B)requires
disclosure of operating mineral deposits within a one-mile radius.
(b)Is it the Company's position that split-estates do not include mineral rights issues?
Response to Anadarko Data Request 5.5
(a)Chapter 3,Rule 21(c)(ii)contains different requirements in different subsections.
Subsection Rule 21(c)(ii)(B),relating to the requirements of the geological report,
specifies a one-mile radius.Rule 21(c)(ii)(C),relating to other background
information requirements,does not contain a specific geographicalradius.With
respect to mineral rights,the rule refers only to "mineral rights associated with the
facility."
(b)No.
Respondents:Richard Goff
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.6
Anadarko Data Request 5.6
Roderick Fisher in his Rebuttal Testimony,page 5 lines 15-16,of March 14,2018 states:
"Rule 21(c)(ii)requires the filing of certain information about a project.It does not
purport to set a standard for approval or authorize conditions for approval."
(a)Please provide the factual basis for the above statement and copies of any and all
documents upon which Rocky Mountain Power relies to support the above
conclusion.
Response to Anadarko Data Request 5.6
Rocky Mountain Power's statement relies on the plain language of Wyo.Stat.37-2-
205(c)and Rule 21(c)(ii),as explained in the SupplementalRebuttal Testimony of
Roderick Fisher (Part 2),page 3,line 9 to page 5,line 16.
Respondents:Yvonne Hogle
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.7
Anadarko Data Request 5.7
Roderick Fisher in his Rebuttal Testimony,page 5 lines 18-23,of March
14,2018 states:
"A majorityof the conditions proposed by Anadarko are specific to their individual
property interests and the Company intends to address these directlywith Anadarko in
right-of-waynegotiations or permitting processes,as appropriate...The Commission
should not pre-judge the outcome of the right-of-waynegotiations or the permitting
process by adopting Anadarko's conditions."
(a)Please provide the basis for Rocky Mountain Power's statement that "requir[ing]an
agreement with the split-estate land owners assuring access within the transmission
line or wind power projects for exercise of split-estate rights includingmineral
development,active,planned and future"(Susan Aldridge Supp.and Response Test.
page 2)is unique to Anadarko when the wind projects overlie land owned by the
United States and that under lease.
Response to Anadarko Data Request 5.7
No party other than Anadarko has proposed to condition the CPCN on required
agreements between the Company and a mineral rights owner.Such agreements are
necessarily specific to a property owner,in this case,Anadarko.
As stated in the Supplemental Rebuttal Testimony of Roderick Fisher at pages 4-5,most
of the Aeolus-to Bridger/Anticlinetransmission line is sited in a corridor that tracks
Interstate 80 and includes existing 230 kV transmission lines,buried gas pipelines and
fiber optic cables,and a Union Pacific railroad line.As a result,the majority of the line
will not have a significant impact on mineral rights.To extent that the transmission line
does have an impact on an individual property owner's mineral rights,the Company is
committed to reasonable mitigation or fair compensation.
Respondents:Yvonne Hogle
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.8
Anadarko Data Request 5.8
Roderick Fisher in his Rebuttal Testimony,page 6 lines 5-8,of March 14,
2018 states:
"As a practical matter,CPCN conditions such as those Anadarko proposes are so broad
and general that their imposition could preclude the Company from moving forward with
the Combined Projects.The conditions could increase the costs and risks of the
Combined Projects,and allow Anadarko to unreasonablydelay their construction."
(a)With respect to each of the conditions identified in the Aldridge Supplemental and
Response Testimony,please provide the specific facts that support the Company's
position that each condition is unreasonablybroad and would allow Anadarko to
unreasonably delay construction.
Response to Anadarko Data Request 5.8
Please see Supplemental Rebuttal Testimony of Rod Fisher (Part 2),page 6,lines 7-13.
Respondents:Yvonne Hogle
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.9
Anadarko Data Request 5.9
Roderick Fisher in his Rebuttal Testimony,page 9 lines 6-11,of March
14,2018 states:
"In the proper forum of rights-of-waynegotiations,the Company will explore with
Anadarko opportunities to minimize or otherwise address potential impacts to future
surface or long wall mining developments that may occur within the footprints of
Anadarko's identified coal interests.The Company's experience is that safe and reliable
mining operations and maintenance of transmission infrastructure can be achieved
together,including certain operational activities under transmission lines."
(a)Is it still the Company's position as stated in its Application that the transmission line
will have no impact on split-estate interests?
(b)If yes,please provide all facts in support of this conclusion?
(c)On what grounds does the Company object to a condition attached to the CPCN that
would protect the owners of split-estate interests?Please provide all documents,facts
upon which the Company bases its position.
Response to Anadarko Data Request 5.9
(a)Please see Rocky Mountain Power's Response to Anadarko 5.7.
(b)Not applicable.
(c)Please see Rocky Mountain Power's Response to Anadarko 5.6.
Respondents:Yvonne Hogle
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.10
Anadarko Data Request 5.10
Roderick Fisher in his Rebuttal Testimony,page 9 lines of March 14,
2018 states:
"The Company also understands that the Transmission Projects could preclude the
extraction of some minerals depending upon the scope of future developments,for
example,an area around and under the transmission line towers,and the Company is
prepared to address micro-siting,right-of-wayterms and conditions for future
development opportunities,and valuation issues where potential impairment of near term
mineral extraction is identified in the right-of-wayprocess,as appropriate."
(a)In the context of micro-siting,how far can the Company move a transmission tower
and stay within its right-of-wayfrom the Bureau of Land Managementwithout also
compromising the functionalityof the transmission line?
(b)Is it the Company's position that it need only accommodate current and imminent
development rights of split-estate owners?
(c)What does Rocky Mountain Power consider as near-tern mineral extraction when the
transmission line has an assumed life of 62-years?(See Rick T.Link Direct Test.at
28).
Response to Anadarko Data Request 5.10
(a)The transmission line can be adjusted in-line to avoid specific resource conflicts and
stay within the Bureau of Land Management right-of-way grant.The actual distance
of a move is dependent on the specific site and the potential for up or down line tower
adjustments.
(b)The Company will work to accommodate development plans for the surface or
mineral estate where reasonable and reliable evidence exists defining development in
the foreseeable future.
(c)See Rocky Mountain Power's Response to 5.10(b).
Respondents:Todd Jensen,Stuart Smith,Shawn Graff,Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.11
Anadarko Data Request 5.11
Roderick Fisher in his Rebuttal Testimony,page 9-10 lines 22-23,1-2,of March 14,2018
states:
"While the 500 kV towers are,in fact,heavier than their 230 kV counterparts and will
result in different below-grade impacts and requirements to maintain subadjacent support,
the overall right-of-wayrequirements for the 500 kV line are similar in nature to the 230
kV line as it relates to Anadarko's future coal mining interests."
(a)Please provide all facts and data supporting the statement that 500 kV transmission
line will have similar or same impacts on underground coal mining below the
transmission towers.
(b)Has the company ever built a transmission line above an underground coal mine?If
the answer to the question is yes,then please provide details of the underground coal
mine operation,includingdepth,type of mining,and any mitigation the Company
undertook.
(c)Has the Company every built transmission lines above a long wall coal mine
operation?If the answer to the question is yes,then please describe the depth and
nature of the coal mine operation and any mitigation measures that the Company
undertook.
Response to Anadarko Data Request 5.11
(a)With respect to Anadarko's future interest,there is no practical difference between the
effect of 230 kilovolt (kV)structures and the 500 kV structures on the Anadarko
property.Neither structure can tolerate removal of material that would compromise
their foundation,e.g.removal of subjacent support.
(b)The Company is aware that the Dave Johnston to Rock Springs 230 kV transmission
line traverses a number of former underground coal mines.Details of the facilities are
not available but the Company is unaware of any impacts to its operations due to the
presence of these facilities.
(c)The Company is unaware of any circumstance of constructing a transmission line
above a long wall coal mine.
Respondents:Todd Jensen
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.12
Anadarko Data Request 5.12
Roderick Fisher in his Rebuttal Testimony,page 13 lines 8-12,of March 14,2018 states:
"Ms.Aldridge repeats this claim here,pointing to only one specific example-apotential
loss in tax revenues from the Bridger Mine if long wall mining is impacted.(Aldridge
Supp.Response,page 8,line 17.)The Company co-owns the Bridger Mine,and given the
Company's knowledge of the mine's operations,it can definitively state that the
Combined Projects will have no impact on long wall mining at the mine."
(a)How many employees are currentlyemployed at the Bridger Mine?
(b)Please state the taxes paid by the Company to the state (severance taxes)and to
Sweetwater County each year for the previous six years for the Bridger Mine.
Response to Anadarko Data Request 5.12
The Company objects to the data request on the basis that it seeks information that is
commercially sensitive that if disclosed could be used by Anadarko to the detriment of
PacifiCorp's customers.Anadarko is an owner of the Black Butte mine (approximately
50 percent)from which PacifiCorp purchases coal for the Jim Bridger plant.
Respondents:Yvonne Hogle
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.13
Anadarko Data Request 5.13
Roderick Fisher in his Rebuttal Testimony,page 13 line 16,of March 14,2018 agrees
that there will be some disturbance of sage grouse core habitat outside of the transmission
line corridor.With respect to the wind projects,please identify the number of leks
affected and the status of discussions with the Wyoming Game and Fish Department.
Response to Anadarko Data Request 5.13
No structures will be built within core sage grouse areas for the TB Flats,Ekola Flats,
Uinta,and Cedar Springs new wind projects.
The Company will be maintaining the one-quartermile no surface occupancy setback and
implementing further seasonal restrictions and setbacks from sage grouse leks that are
present on project sites.
There are zero known sage grouse leks within the TB Flats project area.At TB Flats,
there are occupied leks within two miles of the project,and appropriatebuffers will be
applied during construction.
There are two known sage grouse leks in the Ekola Flats project area.
There are two known sage grouse leks in the Uinta project area.
The project developer began discussions with WyomingGame and Fish Department
(GFD)for Ekola Flats,TB Flats,and Uinta new wind projects in 2015,and
communications and coordination has been ongoing since.The developer has
communicated through in-person meetings,phone calls,and informally on numerous
occasions on avoidance and minimization measures.WyomingGFD will be very
involved in the state permitting process through the WyomingIndustrial Siting Council
(ISC)and the project will generally seek to incorporate avoidance and minimization
measures recommended by WyomingGFD guidance.
There are four "historic"known sage grouse leks in the Cedar Springs project area based
on a preliminarydesktop analysis.Cedar Springs lek field surveys are scheduled to
commence in late-Spring 2018.For the Cedar Springs project,initial project discussions
were held with the WyomingGFD on February 21,2018.
Respondents:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.14
Anadarko Data Request 5.14
Roderick Fisher in his Rebuttal Testimony,page 15 lines 13-16,of March 14,2018
states:
"The BLM or other federal agency would 'require'the Company to file an Application
for Right of Way if they determined the Wind Projects were a connected action.The
BLM has not requested the Company or the wind developers to address this item due to
the fact that the wind development is contained within private property."
(a)Is it Rocky Mountain Power's position that the split-estate managed by the Bureau of
Land Management and owned by the United States is not public land?
(b)If yes,please provide any written confirmation from the Bureau of Land Management
stating that it agreed with this conclusion?
Response to Anadarko Data Request 5.14
(a)No.
(b)Not applicable.
Respondents:Richard Goff
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.15
Anadarko Data Request 5.15
Roderick Fisher in his Rebuttal Testimony,page 15 lines 18-24,of March 14,2018
states:
"The Final Gateway West EIS and Record of Decision presented a full National
Environmental Policy Act ('NEPA')analysis of each transmission line segment
addressing interrelated segments of the same action,dependent actions,reasonably
foreseeable future actions,and a cumulative analysis of all actions.The Final EIS
addresses the transmission line segments as having independentutility,i.e.,as being
usable regardless of additional transmission segments or generation improvements in the
project area are constructed."
(a)Is it Rocky Mountain Power's position that there has been no change in the relation of
the wind power projects to the transmission line?
(b)How does Rocky Mountain Power reconcile its statement that the transmission line
has independentutility with its testimony and admission that it would not build the
transmission line but for the wind power projects and the production tax credits?
Response to Anadarko Data Request 5.15
(a)In the context of NEPA for the Energy Gateway West final environmental impact
study (EIS)and record of decision and as stated in Roderick Fisher's Supplemental
Rebuttal Testimony page 15 and 16 lines 25 and 1-7,March 2018,there is no change
in the relation of the wind and transmission projects.
(b)It is unclear what "testimony and admission"Anadarko is citing.The Company's
testimony addresses the economic synergies between the Wind Projects and the
Transmission Projects and the resulting costs and benefits to customers.See,for
example,the Supplemental Response testimony of Mr.Wurdack at page 23,citing
Mr.Vail's testimony on financial feasibility.Notably,this testimony does not
address whether the Company will build the transmission line.The Company's long-
term transmission plan reflects construction of the transmission line in 2024.
Respondents:Rod Fisher
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.16
Anadarko Data Request 5.16
Roderick Fisher in his Rebuttal Testimony,pages 18-19 lines 19-23,1,of March 14,
2018 states:
"Mr.Naherny specifically cites the Interstate Natural Gas Association of America
('INGAA')Criteria for Pipelines Co-Existing with Electric Power Lines (October,2015)
for both his 1,000 feet and 2,500 feet separations.These distances are not mandated
separation requirements,but rather 'best practice guidelines and summary criteria,'
designed to convey the degree of AC Interference present at different levels of proximity
between facilities."
(a)Is it Rocky Mountain Power's position that it has no obligation to minimize AC
interference?
(b)If Rocky Mountain Power does have an obligation to minimize AC interference,what
is the basis for not applying best practice guidelines under INGAA?
(c)If Rocky Mountain Power believes that the 1,000 foot and 2,500 foot separations are
best practices but should not be used,please explain the rationale for that position.
Response to Anadarko Data Request 5.16
(a)No.Rocky Mountain Power recognizes the potential for AC Interference on metallic
facilities adjacent HVAC transmission lines.Rocky Mountain Power is committed to
working with affected companies to mitigate quantified AC Interference impacts
according to IndustryStandards and Guidelines.
(b)As noted in the supplemental testimony of Mr.Roderick Fisher,page.18,lines 19-23
and page.19,lines 1-2,the guidelines are developedto demonstrate the severity of
AC interference over a range of distances.Application of suitable mitigation
strategies developed through site and condition-specific engineering studies will
reduce the severity of the AC interference over the same range of distances shown in
the INGAA guidelines.
(c)See Rocky Mountain Power's response to Anadarko 5.16(b).
Respondents:Todd Jensen
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.17
Anadarko Data Request 5.17
Roderick Fisher in his Rebuttal Testimony,page 19 lines 5-11,of March 14,2018 states:
"...[T]he Company has developed a process to work with each pipeline owner to identify
potential mitigation measures for AC Interferenceon a case-by-case basis,taking into
account separation distances.The process will generally include pre-project information
gathering and evaluation and pre-and post-project monitoring.This process may take up
to five years after a project is put into service to complete in order to identify actual
impacts and associated mitigation measures,if needed."
(a)Please document the discussions if any with Anadarko on AC Interference.
(b)If Rocky Mountain Power does not plan to immediately put an AC MitigationPlan
into effect when it begins runningpower through the transmission line,please explain
its objection to committing to do so.
Response to Anadarko Data Request 5.17
(a)The topic of AC interference was discussed generally with Anadarko in a project
meeting in the Anadarko offices in Denver,Colorado,August 30,2017.
(b)Rocky Mountain Power intends to implement the AC Mitigation Plan developed with
each facility owner on the timeline set in the facility owner's AC MitigationPlan.
This could mean that plan implementation would occur pre-energization.
Respondents:Todd Jensen
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.18
Anadarko Data Request 5.18
Roderick Fisher in his Rebuttal Testimony,page 20 lines 7-10,of March 14,2018 states:
"The Company will study AC interference for impacted systems,including
interconnections,where conditions exist that indicate the potential for impacts.It is
unlikelythat whole systems are impacted,as AC Interference diminishes as proximity
increases."
(a)Please provide the basis for Rocky Mountain Power's statement that AC Interference
is less when the pipeline is closer.
(b)Please provide the factual basis for the statement that it is unlikely that whole systems
are affected and also provide the basis for why it is less of an impact for a whole
system when the concern is a failure at a single point in a pipeline.
Response to Anadarko Data Request 5.18
(a)The Company's testimony incorrectlystates that AC Interference diminishes as
proximity increases.The testimony should read that "...AC Interference diminishes
as proximity diminishes."The Company will make this correction to Mr.Fisher's
testimony at hearing.
(b)Whole systems typically cover vast areas and distance,this can be many miles away
from the transmission line.As the AC interference decreases with distance from the
transmission line,the potential for whole systems to be impacted decreases too.If any
whole systems are within an area of potential impact they will be studied and
mitigations applied as determined by study.
Respondents:Todd Jensen /Stuart Smith
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.19
Anadarko Data Request 5.19
Roderick Fisher in his Rebuttal Testimony,page 20 lines 18-20,of
March 14,2018 states:
"The information Mr.Taylorcites as lacking [documentation of mitigation of AC
Current]is an important aspect of the detailed design and engineering of transmission
systems,which is still underway at this stage of the Project."
(a)When does Rocky Mountain Power expect it will complete its AC current mitigation?
(b)If it is not done,what is Rocky Mountain Power's objection to committing to AC
current mitigation?
(c)Is is Rocky Mountain Power's position that AC current mitigation is not in the public
interest?
Response to Anadarko Data Request 5.19
(a)Rocky Mountain Power will complete all AC mitigation on a schedule as required by
the various impacted facility owners.This may be pre-or post-energization based
upon the requirements of each owner.
(b)Rocky Mountain Power does not object to the study and development of appropriate
AC current mitigation for each circumstance where it may occur.
(c)No.As examples of commitment to AC current mitigation commitment,the
Company refers to the SupplementalRebuttal of Roderick Fisher (Part 2)at page 17
lines 20 -page 18,line 5,where Mr.Roderick Fisher states "Cathodic Protection is
an issue the Company takes very seriously"and "it falls within the Company's
normal business to work with pipeline companies to address potential AC
interference."The Company's position is that AC mitigation is both facility-specific
and a prudent engineering practice,so a general CPCN condition could be counter-
productive,and is unnecessary.To the Company's knowledge,the Commission has
not conditioned past CPCNs on the details of constructing a facility.Instead,the
Commission requires the Company to demonstrate its prudence in constructing a
facility before it may recover the costs in rates.
Respondents:Stuart Smith,Jim Higgins
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.20
Anadarko Data Request 5.20
Roderick Fisher in his Rebuttal Testimony,page 22 lines 6-12,of March
14,2018 states:
"As noted above,the minimum suggested spacing cannot always be maintained due to
pre-existing conditions that do not allow for the suggested separation distance.This can
occur when,as here,facilities are co-located in existing infrastructure corridors to
mitigate environmental impact or other siting concerns.Rocky Mountain Power will
work with Anadarko to develop an AC Interference plan that takes into account
separation severity guidelines,as all necessary information is gathered,evaluated,and
monitored."
(a)What "necessary information"is needed for the AC Interference plan?
(b)Please describe why Rocky Mountain Power has not gathered this information
already?
Response to Anadarko Data Request 5.20
(a)The followinginformation is required to commence development of an AC
Interference plan:
Informationneededfrom the pipeline company:
Pipeline Owner
Pipeline Name
Product Transported
Routing Geometry
Diameter (in)
Burial Depth (ft)
Wall Thickness (in)
Coating Type
Coating Resistance (kohm-ft^2)
Location and type of Cathodic Protection (CP)
Resistance of CP groundbed(s)
Bonding to foreign pipelines
Existing AC mitigations
Informationffom the utilitv:
Transmission line voltage (kV)
Average Tower Span (feet)
Substation Ground Grid Impedance (ohms)
Number of Circuits
Phase Angle,Height and Horizontal Offset Dimensions (ft)for all conductors
Shield wire configuration(s)
Minimum Ground Clearance
Peak Loading (Amps)
Emergency Loading (Amps)
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.20
Emergency Loading Time (hours)
Fault Clearing Time (cycles)
Average Tower Resistance (ohms)
Beginning,Middle and End of Collocation from left and right substations
(b)As stated in Roderick Fisher's SupplementalRebuttal Testimony,page 10,lines 1-6,
the typical timeframe for AC Interference coordination begins during final
engineering and continues through construction.The Companyhas begun gathering
such information from a range of pipeline companies and welcomes the interaction
and receipt of further information from all pipeline/facility owners along the project
route.
Respondents:Jim Higgins,Stuart Smith
Witness:Rod Fisher
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.21
Anadarko Data Request 5.21
Chad Teplyin his Rebuttal Testimony,page 6 lines 6-9,of March 14,2018 states:
"Wyoming law does not allow mineral rights holders to unilaterallydisplace the Wind
Projects and any mineral rights holder is required to enter into good faith negotiations to
reasonably accommodate its mineral extraction objective."
(a)Please provide the basis for the above statement.
Response to Anadarko Data Request 5.21
(a)The rights being exercised by the Wind Projects are particular to the surface rights.
According to the WyomingOil and Gas Commission,in 2005 the Wyoming Split
Estate Act came into effect,which provides that the oil and gas operator [mineral
rights holders]and the surface owner shall attempt good faith negotiations to reach a
surface use agreement to reasonably accommodate surface uses and to provide for
reclamation activities,timely completion of reclamation of the disturbed areas,and
payment for damages caused by the oil and gas operations.
Respondents:Richard Goff,Erik Carlson
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.22
Anadarko Data Request 5.22
Chad Teplyin his Rebuttal Testimony,page 7 lines 12-14,of March 14,2018 states:
"The Company is not aware of any identified coal deposits proceeding to development
directlyunder the proposed wind turbine locations on the Wind Projects,but will
continue its due diligence in this regard."
(a)Please identify all existing split-estate development within the wind power project
boundaries?
Response to Anadarko Data Request 5.22
(a)The active split-estate development that the Company is familiar with is reported
below:
TB Flats I and II:There is no active development that the Company is aware of.
Ekola Flats:There is an active natural gas facility in NE4SE4 3-23-79,at the end of
Oil Springs Road.Our developer's records show the minerals on this parcel are
owned by Anadarko.Project infrastructure at this time is not predicted to be sited in
any areas that would interfere with this site.
Uinta:Based on our developer's preliminarymineral research there are several
existing split-estate developmentsat Uinta.Sections 7 and 19,T17N R119W have
producing sour gas wells.In Section 19,Tl7N R118W there are injectionwells for
gas storage and future use.Lastly,there is a gas processing plant in Section 13,T17N
R119W that is currentlyin use.
Cedar Springs:Please refer to Confidential Exhibit CONF CAT-3SS-12 from Chad
Teply's Second SupplementalDirect Testimony for a spreadsheet listing active and
recent split-estate development within the Cedar Spring project boundaries is
attached.The split-estate development consists of oil,gas,and in-situ uranium
activity.Regarding the split estates at Cedar Springs,here's a breakdown of where
the developer is at now,along with anticipated next steps:
All existing mineral rights holders have been identified throughout the project
area down to the quarter section level.
The project is currentlyengaged in the process of examining title as well as
recorded and unrecorded leases to further confirm the status of mineral rights in
the project area.
As the project advances,and consistent with the developmenttimeline,mineral rights
holders will be contacted to ensure the parties are working cooperatively towards the
development of the wind project in a manner consistent with the interests of all
stakeholders.
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.22
Confidential information is subject to the protective agreement in this case.
Respondents:Richard Goff /Ken Clark
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.23
Anadarko Data Request 5.23
Chad Teply in his Rebuttal Testimony,page 8 lines 1-3,of March 14,
2018 states:
"The Company recognizes that the future mining of coal would likelybe more intensive
and would require geological and geotechnical studies to establish appropriate solutions."
(a)When will Rocky Mountain Power undertake these studies?
(b)What does Rocky Mountain Power mean by intensive?
Response to Anadarko Data Request 5.23
(a)Please refer to the Company's response to Anadarko Data Request 5.22.PacifiCorp is
not currentlyplanning any geological,geotechnical,or geophysical studies as the
Company is not aware of ongoing coal mining development activities requiring such
information.
(b)In this reference,the use of the word "intensive"was intended to reflect the amount
of surface and sub-surface disturbance that can result from active coal mining as
compared to oil and gas development and operations,as an example.
Respondents:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.24
Anadarko Data Request 5.24
Invenergyhas proceeded to secure a permit from Carbon County to build the TB Flats
wind power project and indicates that it will soon file its application before the Wyoming
Industrial Siting Council.Please explain the legal relationship between Invenergyand
Rocky Mountain Power.
(a)If Invenergyis acting independently before Carbon County and the Industrial Siting
Council,then how does Rocky Mountain Power reconcile this fact with its position to
the Commission that the testimony filed by Anadarko will be resolved when Rocky
Mountain Power secures approval from the Industrial Siting Council?
Response to Anadarko Data Request 5.24
On June 30,2017,Invenergyand Rocky Mountain Power (RMP)entered into a
Development Transfer Agreement (DTA)that includes terms and conditions for the
ongoing development and the contingent development assets transfer for the TB Flats
wind project.In accordance with the agreement,RMP is supporting Invenergy's
development activities,includingpursuit of the Carbon County conditional use and the
Wyoming Industrial Siting Council (ISC)permits for TB Flats.The parties are
collaborating on these critical development assets.
Respondents:Richard Goff
Witness:Chad Teply
20000-520-EA-17 /Rocky Mountain Power
March 22,2018
Anadarko Data Request 5.25
Anadarko Data Request 5.25
Who has the authority to enter into surface use or accommodation agreements for the
wind projects with the individual landowners,both surface and mineral estate owners?
Confidential Response to Anadarko Data Request 5.25
For the TB Flats and Ekola Flats projects,Invenergyhas the authorityand obligation to
enter into the required land use agreements up to the "Closing"of the Development
Transfer Agreement (DTA)between Invenergyand Rocky MountainPower (RMP).
RMP and Invenergyare coordinating on the terms and conditions of those agreements.
For the Cedar Springs build transfer and power purchase agreements,NextEra currently
For the Uinta build transfer agreement,Invenergycurrentlyhas the authority and
obligation to enter into re uired land use agreements
Confidential information is subject to the protective agreement in this case.
Respondents:Richard Goff
Witness:Chad Teply