BY ELECTRONIC FILING - centralpt.comcentralpt.com/upload/461/7455_RequesttoUsePre-filingProcedures.pdf · energy from the salt gradient evaporation ponds to be ... development of

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Dewey & LeBoeuf LLP 1101 New York Avenue, NW Suite 1100 Washington, DC 20005-4213 tel +1 202 346 7999 fax +1 202 299 1399 [email protected]

October 28, 2008

BY ELECTRONIC FILING

Kimberly D. Bose, Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, DC 20426

Re: Magnum Gas Storage, LLC, Docket No. PF09-__-000 Request for Approval to Use the Pre-filing Procedures and to Establish a Pre-filing Docket

Dear Secretary Bose:

Pursuant to Section 157.21(b) of the Commission’s regulations, 18 C.F.R. § 157.21(b) (2008), Magnum Gas Storage, LLC (“MGS”) hereby requests that Commission Staff authorize the use of the Commission’s natural gas project pre-filing procedures and initiate a pre-filing review of the proposed Western Energy Hub project (the “Project”). Upon completion of the pre-filing process, MGS plans to file an application with the Commission for a certificate of public convenience and necessity under Section 7(c) of the Natural Gas Act, 15 U.S.C. § 717f(c) (2000), authorizing MGS to construct, own and operate the natural gas storage and natural gas lateral pipeline components of the Project. On September 23, 2008, in accordance with Section 157.21(c), representatives of MGS met with Commission Staff to discuss the Project and use of the pre-filing process.

Project Overview

MGS is a single member, limited liability company wholly owned by Magnum Development, LLC (“Magnum Development”). MGS was formed for the special purposes of developing, constructing, owning and, potentially, operating an interstate natural gas storage facility and natural gas lateral pipeline connection that will make use of up to six (6) salt caverns to be created at an approximately 80-acre site in Millard County, Utah (the “Storage Site”). This facility will provide high-deliverability natural gas storage to markets in the Rocky Mountain

Kimberly D. Bose October 28, 2008 Page 2

area and the Western U.S. to support the rapid expansion of both natural gas production and pipeline “take-away” capacity, and to meet a well-documented need for additional natural gas storage capacity and deliverability in the West.

Affiliates of MGS (“MGS Affiliates”) will conduct solution mining of the salt structure (the “Magnum Salt Structure”) underlying the broader 12,000 acre Western Energy Hub Project area in central Utah (the “Project Area”) for the production and potential processing and marketing of brines and commercial salt products. Up to six caverns may be created by MGS Affiliates in the salt under the Storage Site, under development, lease or purchase agreements with MGS for natural gas storage. Additional caverns which MGS Affiliates could develop in the Project Area during the solution mining process could be used for purposes other than storage of natural gas, including, without limitation, storage of refined petroleum products, compressed air energy storage, pumped hydro storage or carbon dioxide sequestration. MGS Affiliates also propose using organic Rankin cycle (“ORC”) generators to recover thermal energy from the salt gradient evaporation ponds to be constructed to store and process the saturated brine created by the solution mining process. These solar ponds may also be used as “heat sinks” by MGS for residual thermal energy recovered from compressors and other heat sources at the Storage Site. MGS Affiliates may use additional ORC generators to recover higher temperature thermal energy directly from compressors and other industrial heat sources at or adjacent to the Storage Site. The availability of natural gas supply and storage may also support the construction by MGS Affiliates of new gas-fired generation in the Project Area.

These multiple use elements of the Western Energy Hub Project will add flexibility and opportunity to the nearby 1,900 megawatt (MW) coal-fired electric generation facility, the nearby 300 MW wind energy generation project (currently under construction, with plans to expand to 1,000 MW), a nearby 12-inch diameter refined products pipeline (currently under construction), and the regional electric power grid. MGS has confirmed the need for such services in the region through informal, ongoing discussions with potential customers and infrastructure providers.

In accordance with Section 157.21(d) of the Commission’s regulations, MGS submits the following information in support of this request:

1. A description of the schedule desired for the project including the expected application filing date and the desired date for Commission approval (Section 157.21(d)(1)).

MGS plans to begin the pre-filing process as soon as possible and will work with Commission Staff to develop complete drafts of the Resource Reports to be included in the Project’s certificate application. As indicated below, MGS plans to request that the Commission issue a final order granting the requested certificate authorizations on or before October 27, 2009. This will allow MGS to perform tasks that must be completed before the onset of seasonal wet and cold weather, which may adversely impact certain construction activities.


Proposed Project Schedule

September 23, 2008 Initial Consultation with Commission Staff

October 28, 2008 Submission of Request to Institute the Pre-Filing Process

April 28, 2009 Submission of Certificate Application

August 28, 2009 Issuance of Environmental Assessment

October 28, 2009 Commission Approval of Certificate Application

2. An explanation of why the prospective applicant is requesting to use the pre-filing

process under this section (Section 157.21(d)(3)).

MGS submits this request in order to facilitate timely environmental review of the Project and to maximize coordination among MGS, Commission Staff, interested federal and state permitting agencies, landowners and other stakeholders. MGS has created an aggressive Project schedule in an effort to meet the growing demand for the types of services the Project will provide as promptly as possible, and to position itself to take advantage of efficiencies that should result from coordination with other infrastructure projects (including a planned electric transmission line traversing the Project Area and a refined petroleum products pipeline to be constructed adjacent to, if not traversing the Project Area). The pre-filing process will provide Commission Staff, interested federal and state permitting agencies, landowners, other infrastructure developers and other stakeholders an opportunity to review draft Resource Reports and identify environmental or other issues related to the Project that may require further study and/or resolution prior to the completion of Project design and the filing of the certificate application. This will facilitate the development of a complete record for environmental review and should eliminate or reduce the need for environmental information requests once the certificate application has been submitted. Further, the pre-filing process will facilitate the development of a complete NEPA document and strengthen the conclusion that the Project will be compatible with protection of the environment and will serve the public interest.

3. A detailed description of the project, including location maps and plot plans to scale showing all major components, that will serve as the initial discussion point for stakeholder review (Section 157.21(d)(4)).

The Western Energy Hub will entail the construction and operation of a multi-faceted salt solution mining, energy storage and electric power generation project in the Project Area, which occupies approximately 12,000 acres overlying the Magnum Salt Structure. MGS proposes to use up to six (6) of the salt caverns to be created at the Storage Site for natural gas storage.


Beyond these caverns, MGS Affiliates may create additional caverns adjacent to the natural gas storage caverns for refined products storage and compressed air energy storage. MGS Affiliates will also investigate the feasibility and desirability of developing still other caverns for additional uses, including, without limitation, pumped hydro storage and potential sequestration of greenhouse gases captured from the adjacent coal-fired generation facility.

The MGS Storage Site will include a central compression facility and associated lateral pipelines required to transport natural gas to and from nearby interstate natural gas transmission systems, including a gas pipeline lateral to transmission pipeline facilities owned by Kern River Gas Transmission Company (“Kern River”) and, potentially, Questar Pipeline Company (“Questar”). A location map of the Project Area and a preliminary plot plan showing the Storage Site and all major Project components to be located in the Project Area are attached as Exhibits A and B, respectively. MGS will supplement and update these figures as additional information becomes available.

4. A list of the relevant federal and state agencies in the project area with permitting requirements (Section 157.21(d)(5)).

A table listing the federal and state agencies in the Project Area having permitting jurisdiction over elements of the Project is attached as Exhibit C. The table includes addresses and contact information for each of the interested agencies. MGS will supplement and update this list as additional information becomes available.

5. A statement indicating that those agencies are aware of the prospective applicant’s intention to use the pre-filing process (Section 157.21(d)(5)(i)).

MGS is notifying the agencies listing in Exhibit C that it has submitted to the Commission a request to use the pre-filing process by providing them with a copy of this letter.

6. A statement indicating whether the agencies have agreed to participate in the process (Section 157.21(d)(5)(ii)).

Exhibit C includes a column listing those agencies that have agreed to participate in the pre-filing process to date. MGS will update this information as additional agencies agree to participate in the pre-filing process.

7. A statement indicating how the applicant has accounted for agency schedules for issuance of federal authorizations (Section 157.21(d)(5)(iii)).

MGS does not believe that any federal authorizations (e.g., Bureau of Land Management (“BLM”) rights-of-way) are governed by specific, statutorily-imposed deadlines for action. MGS will discuss with the involved agencies the establishment of target dates for the issuance of


any required federal authorizations, and will strive to ensure that these targets are consistent with the target dates for issuance of a draft Environmental Assessment and the Project certificate.

8. A statement indicating when the applicant proposes to file with these agencies for their respective permits or other authorizations (Section 157.21(d)(5)(iv)).

Exhibit C includes a column indicating the dates by which MGS proposes to file with the federal and state agencies in the Project Area for their respective permits or other authorizations. MGS will supplement and update Exhibit C as the permitting processes go forward and permit schedules are refined.

9. A list and description of the interest of other persons and organizations who have been contacted about the project (including contact names and telephone numbers) (Section 157.21(d)(6)).

MGS has contacted landowners and agencies that manage lands on which the Storage Site will be located, including the BLM for federal lands and the State of Utah School and Institutional Trust Lands Administration (“SITLA”) for state lands, to negotiate surface and subsurface rights required for development and operation of the Project. MGS has also discussed the Project with representatives of the Intermountain Power Agency (“IPA”), owner of the 1,900 MW coal-fired generating facility adjacent to the Storage Site; with representatives of Delta Egg Farm, LLC (“Delta Egg Farm”), owner and operator of an egg production facility adjacent to the Storage Site; and with representatives of all persons holding grazing leases on the SITLA lands included within the area proposed for the Storage Site. As part of its Public Participation Plan described in its response to Item 13, MGS is also identifying and preparing project briefing packages for interested non-governmental organizations (“NGOs”), potentially including the Utah chapter of the Sierra Club and the Southern Utah Wilderness Alliance. A list of stakeholders MGS has identified in the area proposed for the Storage Site is attached as Exhibit D.

MGS is evaluating alternative routes for the lateral pipelines that will connect the Storage Site to transmission pipeline facilities owned by Kern River and/or Questar. Exhibit A shows the region’s major corridors currently in use for natural gas, electricity, and refined product transmission. MGS is in the process of identifying the potentially affected landowners along each of the pipeline routes being considered, although all of the options being considered would make use of significant lengths of existing rights-of-way. MGS will submit additional information showing the alternative routes under consideration and the potentially affected landowners as it becomes available.


10. A description of what work has already been done, e.g. , contacting stakeholders, agency consultations, project engineering, route planning, environmental and engineering contractor engagement, environmental surveys/studies, and open houses. This description shall also include the identification of the environmental and engineering firms and sub-contractors under contract to develop the project (Section 157.21(d)(7)).

MGS Affiliates have filed first priority applications for sodium prospecting permits with BLM covering all federal reserved minerals underlying the Project Area, have obtained necessary exploration rights from SITLA covering all state surface and subsurface interests in the Project Area and have acquired 100% of the surface and mineral rights in all private lands within the Storage Site. MGS and its affiliates have also retained a number of consultants and contractors in areas of expertise that the Project will require to complete the various application processes and to design and develop the Project, including legal and environmental consultants, water and civil engineering firms, a drilling contractor, and a seismic survey contractor. A list of the principal contractors and consultants retained to develop the Project is attached as Exhibit E. MGS will supplement and update this list as additional information becomes available.

11. Proposals for at least three prospective third-party contractors from which Commission staff may make a selection to assist in the preparation of the requisite NEPA document, or a proposal for the submission of an applicant-prepared draft Environmental Assessment as determined during the initial consultation described in paragraph (c) of this section (Section 157.21(d)(9)).

MGS proposes to submit an applicant-prepared Environmental Assessment, as discussed with Commission Staff during the initial consultation. The Project is relatively limited in size and located in a sparsely populated, generally undeveloped area of central Utah. All of the Project facilities proposed at the Storage Site will be located on property leased or owned by MGS. MGS has identified only two owners of surface interests in private lands within the broader Project Area likely to retain their ownership interests -- IPA and Delta Egg Farm. Initial environmental surveys of the Project Area have revealed no federal or state protected species or habitats, no significant cultural resources and no waterbodies or wetlands.

Given the small number of affected landowners and MGS’ expectation that the Project will have only minimal impacts on sensitive environmental resources in the Project Area, MGS believes that it can prepare a high quality and complete draft Environmental Assessment of the Project. However, in the event that unforeseen concerns are raised about the Project and/or the Commission Staff identifies issues that require additional review and environmental document preparation, MGS commits to cooperating fully with any third party contractor the Commission Staff may select to assist in the preparation of the Environmental Assessment.


12. Acknowledgement that a complete Environmental Report and complete application are required at the time of filing (Section 157.21(d)(10)).

MGS acknowledges that a complete Environmental Report and a complete certificate application under Section 7(c) of the NGA are required at the time of its filing for a Section 7(c) certificate.

13. A description of a Public Participation Plan which identifies specific tools and actions to facilitate stakeholder communications and public information, including a project website and a single point of contact. This plan shall also describe how the applicant intends to respond to requests for information from federal and state permitting agencies (Section 157.21(d)(11)).

MGS is committed to effective stakeholder communication and public outreach and is developing a Public Participation Plan (the “Plan”) designed to meet this commitment. MGS is currently developing a Project website at www.westernenergyhub.com, and designates Craig A. Broussard, one of the four managers of MGS, as the single point of contact for public information. Mr. Broussard can be contacted at:

Magnum Gas Storage, LLC 2150 South 1300 East, Suite 500 Salt Lake City, UT 84106 Attn: Craig Broussard [email protected] The Plan will include procedures for handling public requests for information from

landowners and other stakeholders and for appropriately responding to requests for information from interested federal and state permitting agencies. The Plan will be designed to ensure that interested agencies and other stakeholders will have an opportunity to identify potential issues relating to the Project and to assist MGS in developing solutions.

MGS commits to holding an open house for stakeholders, interested federal and state permitting agencies and Commission Staff within 60 days of this request. In accordance with the requirements of Section 157.21(f)(1) of the Commission’s regulations, MGS will establish the date and location for the open house in consultation with Commission Staff within 7 days of the Commission’s issuance of the notice commencing the pre-filing process.

Conclusion

MGS sincerely appreciates the guidance provided by Commission Staff in the initial consultation meeting and looks forward to working with Commission Staff, interested federal


and state permitting agencies and stakeholders in the pre-filing process. MGS is committed to identifying and resolving issues and concerns as early in the process as possible, to coordinating the preparation of Resource Reports and to filing a high quality and complete certificate application and applicant-prepared Environmental Assessment.

Thank you for your timely consideration of this request.

Respectfully submitted,

/s/ James F. Bowe, Jr. Attorney for Magnum Gas Storage, LLC

Enclosures

cc: Berne L. Mosley, Division Director, Pipeline Certificates, Office of Energy Projects Michael J. McGehee, Chief, Certificate Branch 1, Office of Energy Projects Alisa M. Lykens, Chief, Gas Branch 2, Office of Energy Projects Kandilarya Jacaman, Environmental Project Manager, Office of Energy Projects Stan Perkes, United State Bureau of Land Management, Utah State Office Cornell Christensen, Field Manager, United States Bureau of Land Management, Richfield District Office LaVonne Garrison, Assistant Director, State of Utah School and Institutional Trust Lands Administration John Baza, Director, Utah Department of Natural Resources, Division of Oil, Gas and Mining Kirk Forbush, Utah Department of Natural Resources, Division of Water Rights Utah Department of Natural Resources, Division of Wildlife Resources United States Fish and Wildlife Service, Utah Field Office Utah Department of Environmental Quality, Division of Water Quality Utah Department of Environmental Quality, Division of Air Quality State Historical Preservation Office Diane Nielson, Energy Advisor, Utah Governor’s Office Kathy Walker, Millard County Commissioner

DC2253327.8

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Millard County, UtahT 15 S, R 6&7 W

ProjectLocation:

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10/2008

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Natural GasQuestar Natural Gas PipelineKern River Natural Gas PipelinesStorage SiteCounty Boundary

Source: AGRC, ESRI, Questar Natural Gas, andWest-wide Energy Corridor Programmatic

EIS Information Center

136 E. South Temple, Suite 910Salt Lake City, Utah 84111

801.361.1064 801.364.2021 fax

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N:\PROJECTS\Magnum Energy LLC\WESTERN ENERGY HUB\GIS\Maps\Exhibit B Major Components WEH.mxd\ 10282008 Tt Kevin.Hively

Magnum Gas Storage, LLC Docket No. PF09-__-000

1

EXHIBIT C

RELEVANT FEDERAL AND STATE AGENCIES WITH PERMITTING REQUIREMENTS IN THE WESTERN ENERGY HUB PROJECT AREA

(as of October 28, 2008)

Permit Agency Address and Contact

Information Aware of Use of the Pre-filing Process

Agreement to Participate

Proposed Permit Submittal Date

FEDERAL

Certificate of Public Convenience and Necessity – Section 7(c) of the Natural Gas Act

Federal Energy Regulatory Commission

888 First Street, NE Washington, DC 20426

Yes Pending 4/1/09

Sodium Prospecting Permit United States Department of the Interior, Bureau of Land Management (BLM) Utah State Office

440 West 200 South, Suite 500 Salt Lake City, Utah 84101 Phone: (801) 539-4001 Stan Perkes

No None Submitted 2/07/07

Amended 10/1/07

Crossing Federal Lands by ROW Corridors

BLM, Branch Offices

Richfield Field Office 150 East 900 North Richfield, UT 84701 Cornell Christensen, Field Manager Phone: (435) 896-1500 Fillmore Field Office 35 East 500 North Fillmore, UT 84631 Nancy Allen, Field Manager Phone: (435) 743-3100

No

No

None

None

Not Determined

Not Determined


2

EXHIBIT C







Individual Permit or Nationwide Permit (if required)

United States Army Corps of Engineers (USACE) Sacramento District

1325 J Street Sacramento, CA 95814 Phone: (916) 557-7490

No None Anticipated

No Jurisdictional Waters

Threatened and Endangered Species Consultation and Clearances

United States Fish and Wildlife Service (USFWS) Utah Field Office

2369 West Orton Circle, Suite 50 West Valley City, Utah 84119 Phone: (801) 975-3330

No None Anticipated

Pending Further Field Review

STATE

Lease and Easement Agreements

Seismic Exploration (ROE)

State of Utah School and Institutional Trust Lands Administration (SITLA)

675 East 500 South, Suite 500 Salt Lake City, UT 84102 Phone: (801) 538-5100 LaVonne Garrison, Assistant Director Oil & Gas

Yes Yes Submitted 2/12/07

Final Lease October 2008

Approved 10/23/2008

Class II Permit for Solution Mining for Gas Storage

Seismic Exploration

Core Drilling

Utah Department of Natural Resources (UDNR), Division of Oil, Gas and

Mining (DOGM)

1594 West North Temple, Suite 1210 Salt Lake City, UT 84114-6480 Phone: (801) 538-5340 John Baza, Director

No

No

No

No

No

No

Not Determined

Approved 6/23/2008

Submitted 10/28/2008


3

EXHIBIT C







Class III Permit for Solution Mining to Mine Salt

Utah Pollution Discharge Eliminations Systems (UPDES) Construction Activity Storm Water Permit and Pollution Prevention Plan

UPDES Industrial Discharge Permit

Groundwater Discharge Permit

Wastewater Treatment System Construction Permit

Wastewater Treatment System Operating Permit

Utah Department of Environmental Quality (UDEQ), Division of Water Quality (DWQ)

288 North 1460 West Salt Lake City, Utah 84116 Phone: (801) 538-6146

No

No

No

No

No

No

Not at this time

Not at this time

Not at this time

Not at this time

Not at this time

Not at this time

Not Determined

Not Determined

Not Determined

Not Determined

Not Determined

Not Determined

Non-Production Well Permit

Application to Appropriate Water and Follow on Proof and/or Change Application (as required)

Dam Impoundment Construction Permit

UDNR, Division of Water Rights (DWR)

1594 West North Temple Suite 310 Salt Lake City, UT 84114-6480 Phone: (801) 538-7230 Kirk Forbush, Regional Engineer 130 North Main Street Richfield, Utah 84701-0563 Phone: (435) 896-4429

No

No

No

Not at this time

Not at this time

Not at this time

Approved 10/15/2008

Not Determined

Not Determined


4

EXHIBIT C







Small Source Exemption Permit; Utah Approval Order; or Title V Major Source Permit (as required)

UDEQ, Division of Air Quality

150 North 1950 West Salt Lake City, Utah 84116 Phone: (801) 536-4000

No Not at this time Not Determined

National Historic Preservation Act Cultural Resource Consultations/Clearance

State Historical Preservation Office (SHPO)

300 S. Rio Grande Street Salt Lake City, UT 84101 Phone: (801) 533-3500

No

(Seismic work clearance sought)

Not at this time Not Determined

(October 2008)

Threatened and Endangered Species Consultation and Clearances

UDNR, Division of Wildlife Resources (DWR)

1594 West North Temple Suite 2110 Salt Lake City, UT 84114-6480 Phone: (801) 538-4700

No Not at this time Pending Further Field Review

DC2253382.4


1

EXHIBIT D

STAKEHOLDERS IN THE WESTERN ENERGY HUB PROJECT AREA (as of October 28, 2008)

Area of Interest Stakeholders Address and Contact Information Contacted

LANDOWNERS

United States Reserved Minerals; Potential ROW’s

United States Department of the Interior, Bureau of Land Management (BLM)

Utah State Office

Fillmore Field Office

440 West 200 South, Suite 500 Salt Lake City, Utah 84101 (801) 539-4001 Stan Perkes Solid Minerals Leasing 35 East 500 North Fillmore, Utah 84631 (435) 743-3100 Jerry Mansfield, Geologist

Yes

State of Utah

Surface & Minerals; Potential ROW’s

School and Institutional Trust Lands Administration (SITLA)

675 East 500 South, Suite 500 Salt Lake City, UT 84102 801-538-5100 Lavonne Garrison Assistant Director – Oil & Gas

Yes

Privately Owned Surface

Intermountain Power Agency (IPA)

10653 S. River Front Parkway, Suite 120 South Jordan, UT 84095 (801) 938-1333 James A. Hewlett General Manager

Yes


2

EXHIBIT D



Privately Owned Surface (Cont’d)

Delta Egg Farm, LLC Cal-Maine Foods, Inc. 3320 Woodrow Wilson Ave. Jackson, MS 39209 (601) 948-6813 Adolphus B. Baker President and COO

Yes

LOCAL GOVERNMENT

State Government

State of Utah Governor’s Office

324 South State Street, Suite 500 Salt Lake City, UT 84111 801-538-8802 Dianne Nielson, Energy Advisor

Yes

County Government

Millard County Commission 71 South 200 West Delta, Utah 84624 (435) 864-1414 Kathy Y. Walker Millard County Commissioner

Yes


3

EXHIBIT D



INFRA-STRUCTURE

Kern River Gas Transmission Company 2755 E. Cottonwood Pkwy., Ste 300 Salt Lake City, Utah 84121 (801) 937-6273

Todd Kremer Director – Business Development

Yes

Questar Pipeline Company Questar Pipeline Company P.O. Box 45360 180 East 100 South Salt Lake City, UT 84145-0360 (801) 324-2938

Gary Schmitt General Manager, Marketing & Business Development

Yes

Intermountain Power Agency (IPA) (Same as above) Yes

NON-GOVERNMENTAL ORGANIZATIONS (NGO’s)

Sierra Club (Utah Chapter) Southern Utah Wilderness Alliance

(Interest to be Determined) (Interest to be Determined)

No

No

DC2253441.1


1

EXHIBIT E

PRINCIPAL CONTRACTORS ASSISTING WITH WESTERN ENERGY HUB PROJECT


Contractor/Consultant Principal Contact Area of Focus

Dewey & LeBoeuf LLP

Tetra Tech, Inc.

Clyde Snow & Sessions

Jones, Waldo, Holbrook & McDonough

Lear & Lear

Hatch, James & Dodge

Jim Bowe

David Babcock

Steve Clyde

Lucy Jenkins

Phil Lear

Gary Dodge

Project Counsel/FERC

Environmental Permitting

Local Counsel/Water & Land Rights

Local Counsel/State Permitting

Local Counsel/Land Title

Local Counsel/Transmission Regulation

Black & Veatch Lee Van Atta Market Analysis/Project Economics

Energy Strategies

Patricia Eckert Associates

Kohler Consulting

Scott Gutting

Patricia Eckert

Jim Kohler

Electric Markets/Transmission Regulation

CA Electric Markets/Regulation

Public Lands Regulation/ROW’s

Subsurface Technology, Inc.

Sandia National Laboratories

TJ Energy

Serra GeoConsulting, LLC

Interactive Earth Sciences

Lone Star Surveys

Boart – Longyear

Century Wireline Services

Joe Sheldon

Steve Bauer

Tom Siguaw

Sandro Serra

Mark Kramer

Heath Harris

Jason Lamb

Bob Sipes

Cavern Engineering/Leaching Facility

Cavern Design/Rock Mechanics

Salt Drilling/Core Sampling

Geologic Interpretation

Geophysical/Seismic Interpretation

3D Seismic Data Acquisition

Drilling Services and Equipment

Geophysical Logging


2

EXHIBIT E

PRINCIPAL CONTRACTORS ASSISTING WITH WESTERN ENERGY HUB PROJECT


Contractor/Consultant Principal Contact Area of Focus

G. W. Stewart Corp.

Stewart Consulting

Gary Stewart

Blaine Stewart

Construction Management

Electrical Engineering

Hansen, Allen & Luce

Desert Rock Products

Loughlin & Associates

Bullock Realty

Clear Water Realty

Backman Title

David Hansen

Jake Smith

Bill Loughlin

Andrea Bullock

Jeff Anderson

Paul Newton

Water Supply/Civil Engineering

Access Road/Drill Pad Construction

Hydrogeology

Land/Water Rights Brokerage

Land/Water Rights Brokerage

Land & Mineral Title Insurance

Wells Fargo National Bank, N.A.

ShadowCast Partners

Savas Greene & Associates

Beth Stauffer

Brad Berrett

Richard Greene

Banking Services

Accounting/Controller Services

Tax Accounting

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BY ELECTRONIC FILING - centralpt.comcentralpt.com/upload/461/7455_RequesttoUsePre-filingProcedures.pdf · energy from the salt gradient evaporation ponds to be ... development of