Office of Energy Policy and Systems Analysis (EPSA-60)

October 10, 2014

Office of Energy Policy and Systems Analysis (EPSA-60)

QER Meeting Comments

U.S. Department of Energy

1000 Independence Avenue, SW

Washington, D.C. 20585-0121

Submitted electronically via email to:

Berkshire Hathaway Energy hereby respectfully submits these comments on behalf of its indirect subsidiary PacifiCorp, a vertically-integrated electric utility headquartered in Portland, Oregon, which serves approximately 1.8 million electric customers in six western states and operates one of the largest high-voltage transmission systems in the west. These comments are, in part, in response to federal transmission permitting improvement efforts underway at the Department of Energy (“DOE”) in parallel or in conjunction with the Quadrennial Energy Review (“QER”).

By virtue of theconsiderable siting and permitting challenges it has faced developing its Energy Gateway transmission expansion project, PacifiCorp has a long-standing and strong interest in seeing federal agencies act to substantially improve the existing federal transmission siting and permitting process. Toward that end, Pat Reiten, President and Chief Executive Officer of Pacific Power, a division of PacifiCorp, actively participated in the regional QER meeting held in Portland, Oregon on July 11, 2014. In particular, Reiten recounted the company’s experience with delays obtaining federal permits for its Gateway West segment in calling for the federal government to dramatically improve the overall quality and timeliness of the existing federal process for siting and permitting electric transmission projects on federal lands. Simply put, to meet national policy goals, the efficiency and effectiveness of multiple agency reviews and decisions on major transmission projects must be improved, and the uncertainty with federal agency reviews must be reduced so that needed transmission expansion can keep pace with the nation’s revolving resource mix that is being driven by a rapidly changing policy landscape. As Reiten stated, above all federal agencies need to truly work together to assure consistent application of permitting requirements and clear communication of requirements between field/state/federal agency headquarters levels prior to the start of the permitting process and throughout the process is essential.

As DOE develops action items out of the QER process, Berkshire Hathaway Energy urges DOE to put further federal coordination around transmission siting on the list as a priority, with the goal of assuring consistent and expedited treatment of permit applications. In particular, as DOE explores opportunities for further improvement, Berkshire Hathaway Energy encourages DOE to consider the attached policy recommendations for refining DOE’s proposed Integrated Interagency Pre-Application (“IPP”) process for siting transmission projects requiring interagency and intergovernmental coordination, which PacifiCorp previously submitted in response to a DOE Request for Information. In particular, drawing on its successful experience permitting five Energy Gateway segments outside of an IIP-like process, PacifiCorp believes there are greater efficiencies to be gained through better National Environmental Policy Act execution and recommends that DOE focus on improving the post-application, pre-scoping process part of the overall federal permitting and siting process before implementing a prescriptive voluntary IIP process.

Berkshire Hathaway Energy appreciates the opportunity to provide these comments and recommendations in the interest of improving the federal siting and permitting of electric transmission on federal lands. If you have any questions or need further information, please contact the undersigned.

Respectfully submitted,

/s/ Jay Carriere

Jay Carriere

Director, Federal Government Affairs

Berkshire Hathaway Energy

1800 M Street, NW, Suite 330N

Washington, DC 20026

(202) 828-4590

Email: