This filing contains the rebuttal testimonies of Michael Palmer and Art Haskins.

Transcription

1 Document ID: This is the rebuttal testimony of John Glanzer and Robert Steede. The purpose of Mr. Glanzer s testimony is to: 1) provide NDPC s analysis regarding the additional costs, facilities, power usage and emissions that would result from the System Alternatives; 2) respond to DOC-DER witness Mr. Adam Heinen s assertions that SA-03 and SA- 03, as modified, are reasonable alternatives; and 3) provide evidence as to why moving the Clearbrook West Terminal to Crookston creates less reliable service to Minnesota refineries. The purpose of Mr. Steede s testimony is to provide additional analysis and information regarding the reliability and operational benefits of the proposed Sandpiper Pipeline Project (the Project ) as compared to System Alternative 03 ( SA-03 ) or SA-03, as modified, as those alternatives are described by Mr. Heinen. Specifically, I address the need for redundant service to serve the Minnesota Pipe Line Company and the operational costs and risks associated with pressure cycling that would result from moving the Clearbrook West Terminal to Crookston. Included in his testimony is the Line 81 Operational History Data. Document ID: This filing contains the rebuttal testimonies of Michael Palmer and Art Haskins. The purpose of Mr. Palmer s testimony is to respond to DOC-DER witness Adam Heinen s statements and conclusions regarding the incremental cost impact to Marathon, and to crude oil shippers and refiners in general, if either SA-03 or SA-03, as modified, is approved. The purpose of Mr. Haskins testimony is to The purpose of my testimony is to respond to issues raised by Minnesota Department of Commerce, Division of Energy Resources ( DOC- DER ) witness Mr. Adam Heinen related to emergency response, to discuss Enbridge s development of an emergency response plan, and to describe Enbridge s emergency response

2 protocols, resources, training and coordination with local first responders within each of the regions that the Project operates. In addition, my testimony responds to certain recommendations and requests for additional information by Mr. Heinen in his testimony. Also included are two schedules: Schedule 1 Excerpt from Enbridge Emergency Response Action Plan, Section 6.3.2a The Classification of the Incident chart Schedule 2 Table of Number of Fire Department Personnel on County-by-County Basis Document ID: This filing contains the testimonies of Allan Baumgartner, Sara Ploetz, and William Rennicke. Mr. Baumgartner is Director, Control Center Operations, Enbridge Pipelines, Inc., an affiliate of Enbridge Energy Partners, L.P. The purpose of Mr. Baumgartner s testimony is to respond to Minnesota Department of Commerce, Division of Energy Resources ( DOC-DER ) witness Adam Heinen s questions regarding the Control Center which monitors NDPC s pipeline system; describe the Control Center s operational processes; explain what the Control Center s role will be in monitoring real time pipeline operations for the Project after it is actively in service; clarify the Control Center s roles and responsibilities in emergency response situations; and respond to Mr. Heinen s questions regarding NDPC s approach to cyber security. He is also responding to the testimony submitted by Winona LaDuke for Honor the Earth and the testimony submitted by Mr. Smith and Mr. Stolen for Friends of the Headwater. His testimony includes his statement of qualifications. Ms. Ploetz has two purposes to her testimony. One is to update the list of environmental permits required for the Project to reflect activities completed since my direct testimony was submitted in August 2014 and the other is to sponsor the human and environment analysis sections of NDPC s System Alternatives Analysis Report (the SA Report ), which is attached to Mr. Paul Eberth s rebuttal testimony as Schedule 1. The above-referenced sections identify human and environmental features contained within a two-mile-wide study area of each System Alternative as well as SA-03 as Modified. It also identifies human and environmental features contained within a two-mile wide study area of NDPC s Preferred Route, as well as

3 the human and environmental features directly crossed by the Project route ( Sandpiper Route ) as filed with the Minnesota Public Utilities Commission in August NDPC s SA Report presents conclusions regarding these features. In addition, I respond to the environmental review of the Project and System Alternatives prepared by the Minnesota Department of Commerce, Energy Environmental Review and Analysis ( DOC-EERA ) Staff. I also respond to (i) Friends of the Headwaters ( FOH ) Witness Mr. Paul Stolen s comments regarding use of independent environmental monitors and the impact of Enbridge s proposed Line 3 Replacement Project; and (ii) certain of FOH Witness Mr. Richard Smith s maps showing Minnesota natural resources and his reliance on the Minnesota Pollution Control Agency s ( MPCA ) August 2014 analysis of the System Alternatives. The purpose of Mr. Rennicke s testimony is to respond to the Heinen, LaDuke, Blazar, and Younggren testimony and the DOC-EERA analysis. His testimony includes two schedules: Schedule 1 is a map that shows the rail lines that would likely handle additional crude oil movements in a No Action scenario, as well as alternative rail lines outside of Minnesota that could be used to move Bakken crude oil to refineries in the Central Midwest and East. To help illustrate the longer distances crude oil trains would have to travel to utilize these alternative routes, mileages between specified towns and railroad junctions are provided. Schedule 2 is a chart that shows projected annual tank car fleet capacity loss and tank car retrofit costs on an annual basis through 2024 as a result of proposed new regulations. The numbers used to create the chart were obtained from the Brattle Group s response on behalf of the Railway Supply Institute to the Pipeline and Hazardous Materials Safety Administration s ( PHMSA ) Notice of Proposed Rulemaking. Document ID: This filing contains the testimony of Bruce MacPhail, Director, Bakken Asset Performance and Development, and includes two associated schedules: Schedule 1 MacPhail Statement of Qualifications Schedule 2 Petition for Declaratory Order of North Dakota Pipeline Company LLC, filed on February 12, 2014, in FERC Docket OR

4 The purpose of Mr. MacPhail s testimony is to: discuss the cost implications of approving SA-03 or SA-03, as modified, to shippers and NDPC; respond to Minnesota Department of Commerce, Division of Energy Resources ( DOC- DER ) witness Adam Heinen s discussion of the role of the Federal Energy Regulatory Commission (the FERC ) and the procedural history of the Petition for Declaratory Order ( PDO ) and its predecessor, the Settlement Offer; respond to Mr. Heinen s assertion that if the Project does not go through Clearbrook it is unclear whether any material change in the Transportation Service Agreements ( TSAs ) would have to be made; and respond to other witnesses characterization of the positions of North Dakota shippers in the FERC proceedings. Document ID: This filing contains the testimony of Ray Wuolo, the Principal Hydrogeologist and a Vice President of Barr Engineering, and three associated schedules: Schedule 1 Statement of Qualifications of Ray Wuolo Schedule 2 Potential Effects of the Operation of the Sandpiper Pipeline Project on Lakes Schedule 3 Potential Effects of the Operation of the Sandpiper Pipeline Project on Groundwater The purpose of Mr. Wuolo s testimony is to present analyses Barr performed at North Dakota Pipeline Company s ( NDPC ) request related to the Sandpiper Pipeline Project (the Project ) and the System Alternatives under consideration in this proceeding. His testimony will discuss the analyses and results of these reports and respond to certain maps and accompanying statements made by other parties in this proceeding regarding potential impacts to certain environmental features, such as lakes and groundwater, which could result from operation of the Project or an alternative to the Project.

5 Document ID: This filing contains the testimony, schedules, and appendices of Paul Eberth. The purpose of Mr. Eberth s testimony is to summarize NDPC s response to the DOC-DER s conclusions, recommendations and requests for additional information. In response to DOC- DER Witness Mr. Adam Heinen, I also provide a detailed discussion of the current status of regulatory approvals for the Southern Access Extension project ( SAX ), address concerns regarding NDPC s commitments and obligations in the event of a crude oil release, respond to the recommendation that NDPC purchase power from a Minnesota utility s green pricing program, discuss relevant issues raised regarding Enbridge s proposed Line 3 Replacement Project, and provide NDPC s safety report, responding to specific safety-related questions the Commission requested be addressed as part of the Project s route proceeding. Finally, I summarize NDPC s analysis of the various System Alternatives analyzed in this docket, including SA-03 and SA-03, as modified. Page 2 of his testimony contains a good summary of the other witnesses providing rebuttal testimony for NDPC. The schedules included are: Schedule 1 NDPC System Alternatives Analysis Report Schedule 2 Safety Report Schedule Enbridge Corporate Social Responsibility Report The appendices included are: Appendix 1 Human and Environmental Resources Summary Table Appendix 2 Permit Table Appendix 3 Human and Environmental Features Comparison Document ID: This filing contains more information from the testimony of Mr. Eberth. Included are:

6 Schedule 2 Sandpiper Project Pipeline Safety Report o Appendix A Federal Regulations o Appendix B North Dakota Region Emergency Response Action Plan o Appendix C Superior Region Emergency Response Action Plan o Appendix D Example Control Point Map Schedule 3 Enbridge Corporate Social Responsibility Report Document ID: This filing contains the testimony of Neil Earnest for the purpose of responding to certain statements made by Mr. Adam J. Heinen and Ms. Winona LaDuke. Included are the following schedules: Schedule 1: Northern Tier Energy Third Quarter 2014 Earnings Conference Call and Webcast; Schedule 2: Northern Tier Energy 2013 Form 10-K; Schedule 3: Northern Tier Energy Form 8-K, February 27, 2014; Schedule 4: Enterprise Products Partners L.P. New Release December 12, 2014; Schedule 5: EOG Resources Third Quarter Earnings Presentation, November 18, 2014; and Schedule 6: EOG Resources Third Quarter Earnings Call Transcript, November 5, Document ID: This filing contains the testimony of Barry Simonson and includes Schedules 1 through 12, although the first three are protected as Trade Secret. The purpose of Mr. Simonson s testimony is to discuss the engineering analysis NDPC performed on each of the six System Alternatives ( SA ) (SA-03 SA-08) that the Commission requested be reviewed in this docket as well as SA-03, as modified, which was discussed by DOC-DER witness Mr. Adam Heinen. In addition, I respond to Mr. Heinen s requests for additional information regarding valve

7 placement, pipe wall thickness, and certain cost details related to SA-03 and SA-03, as modified. Finally, I respond to issues raised by Friends of the Headwaters witness Mr. Paul Stolen concerning risk assessments and construction-related impacts. Schedule 1 SA-03 IVP Analysis Schedule 2 SA-03, as modified, (RA-55) IVP Analysis Schedule 3 IVP Report for Sandpiper Pipeline Project Schedule 4 Valve Placement Illustrations Schedule 5 Final Report Sandpiper Pipeline Project Mainline 24 Diameter Internal Pressure Design Calculation & Diameter to Wall Thickness Ratio Schedule 6 Final Report Sandpiper Pipeline Project Mainline 30 Diameter Internal Pressure Design Calculation & Diameter to Wall Thickness Ratio Schedule 7 Final Report Sandpiper Pipeline Project Mainline 24 Diameter Pipe Stress Analysis Pipe Lowering and Boom Spacing Schedule 8 Final Report Sandpiper Pipeline Project Mainline 30 Diameter Pipe Stress Analysis Pipe Lowering and Boom Spacing Schedule 9 Final Report Sandpiper Pipeline Project 24 Mainline Diameter Pipe Stress Analysis Road and Highway Crossings Schedule 10 Final Report Sandpiper Pipeline Project 30 Mainline Diameter Pipe Stress Analysis Road and Highway Crossings Schedule 11 Final Report Sandpiper Pipeline Project 24 Mainline Diameter Pipe Stress Analysis Horizontal Directional Drilling Installation and Operating Stress Analysis Schedule 12 Final Report Sandpiper Pipeline Project 30 Mainline Diameter Pipe Stress Analysis Horizontal Directional Drilling Installation and Operating Stress Analysis Received Date: 1/6/15 Document ID: On Behalf Of: DOC DER This filing contains the testimony of Adam Heinen and several attachments. The purpose of Mr. Heinen s testimony is to 1) clarify the role of the Department of Commerce, Division of Energy Resources, Energy Regulation and Planning (DOC-DER) regarding CNs versus the role of the Department of Commerce, Energy Environmental Review and Analysis (DOC-EERA) regarding the Environmental Review, and 2) respond to DOC-EERA s Comparison of Environmental Effects of Reasonable Alternatives (Environmental Review) filed on December 18, 2014.

8 The Attachments included are: DOC Response to NDPC Information Request NO. 3 CNN.Com Article, Oil prices crash below $70, November 28, 2014 WTI Spot Price 2014 from the Energy Information Administration WIliston Basin Rig Counts from Baker Hughes NDPC Response to DOC Information Request Nos. 44 and 45. Received Date: 1/7/15 Document ID: On Behalf Of: CCLS This filing contains the testimony of Kim Chapman and includes several attachments. The purpose of Mr. Chapman s testimony is to explain why it is imperative that all parties have access to the same GIS data in order to be certain that their analyses of the various route possibilities consider the same factual data. The attachments include: Appendix A Chronology of Requests for GIS Data And Sandpiper System Alternatives: Upland Forest Block Size Analysis Sandpiper System Alternatives: Lowland Forest Block Size Analysis Received Date: 1/7/15 Document ID: On Behalf Of: Honor the Earth This filing contains the testimony of Winona LaDuke. The purpose of Ms. LaDuke s testimony is to reiterate there is no need for this Sandpiper pipeline today or in Included is an from Donald Rosenberry to Vern Peterson dated August 11, 2014.

9 Received Date: 1/8/15 Document ID: On Behalf Of: PUC Document Type: Notice January 8, 2015 Hearing rescheduled due to inclement weather. Hearing will now be held on Monday, January 12 at 2pm, location will remain at Crookston Inn & Convention Center Received Date: 1/8/15 Document ID: On Behalf Of: Carlton County Document Type: Public Comment This filing is the same document as the 11/6/14 filing of the 9/9/14 resolution by the Carlton County Board of Commissioners in support of the Sandpiper Pipeline. Received Date: 1/8/15 Document ID: On Behalf Of: PUC Document Type: Other This is the press release regarding the rescheduling of the Crookston public hearing.