20120424Staff 1-6 to Grand View.pdf

KRIST1NE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
... .
Street Address for Express Mail:
472 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AMENDMENTS TO THE )
FIRM ENERGY SALES AGREEMENT )
BETWEEN IDAHO POWER COMPANY AND )
GRAND VIEW SOLAR ONE PV, LLC. )
)
)
)
)
CASE NO. IPC-E-10-19
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
GRAND VIEW SOLAR ONE PV,
LLC
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Grand View Solar One PV, LLC
(Grand View Solar) provide the following documents and information as soon as possible, but no
later than TUESDAY, MAY 15, 2012.
This Production Request is to be considered as continuing, and Grand View Solar is
requested to provide, by way of supplementary responses, additional documents that it or any
person acting on its behalf may later obtain that will augment the documents produced.
For each item, please indicate the name of the person(s) preparing the answers, along
with the job title of such person(s) and the witness who can sponsor the answer at hearing.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Grand View Solar is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
FIRST PRODUCTION REQUEST
TO GRAND VIEW SOLAR 1 APRIL 24, 2012
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please explain why Grand View Solar One believes that an
extension until no later than January 12, 2013 is a fair and commercially reasonably time period
for Grand View Solar One to achieve its operation date. In your explanation, please discuss
specifically how Grand View Solar One defines the phrase "commercially reasonable."
REQUEST NO. 2: Please explain Grand View Solar One's reasons for not meeting the
Scheduled Operation Date as specified in ¶ B.-3 of Appendix B of the FESA. Describe all
reasons for delays and discuss any actions taken by Grand View Solar One to remedy those
delays.
REQUEST NO. 3: Please explain how Grand View Solar One intends to determine
when its facility has met its revised Scheduled Operation Date. For example, this project will
consist of approximately 75,000 PV panels. How many panels have to be operational before
Grand View Solar One believes the facility should be deemed to have met its Scheduled
Operation Date?
REQUEST NO. 4: Please explain why Grand View Solar One disputes Idaho Power's
interpretation of the FESA that the Scheduled Operation Date was January 30, 2012, and instead
asserts that the FESA has a "rolling" scheduled operation date as stated in Idaho Power's April 3,
2012 Letter of Understanding and Agreement with Grand View.
REQUEST NO. 5: Please state whether Grand View Solar One has commenced
construction activities at the project site. If construction has commenced, please describe those
activities.
FIRST PRODUCTION REQUEST
TO GRAND VIEW SOLAR 2 APRIL 24, 2012
REQUEST NO. 6: Please provide a schedule showing the expected completion date of
key activities necessary for the facility to achieve a Scheduled Operation Date of January 12,
2013. List all key activities completed to date as well as those yet to be completed.
DATED at Boise, Idaho, this ,'day of April 2012.
Kristine A. Sasser
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipeel 0.1 9ksrps gvs 1
FIRST PRODUCTION REQUEST
TO GRAND VIEW SOLAR 3 APRIL 24, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF APRIL 2010,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GRAND VIEW SOLAR PV ONE, LLC, IN CASE NO.
IPC-E-10-19, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
DONOVAN E WALKER
LISA D NORDSTROM
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
1nordstromäidahopower.com
RANDY C ALLPHIN
ENERGY CONTRACT ADMINISTRATOR
IDAHO POWER COMPANY
P0 BOX 70
BOISE ID 83707-0070
E-MAIL: [e-mail]
PETER RICHARDSON SEAN STOCKER
RICHARDSON & O'LEARY, PLLC 5 WHITNEY LANE
515 N. 27TH STREET NEW ULM, MN 56073
BOISE, IDAHO 83702
E-MAIL: [e-mail]
SECRETARY
CERTIFICATE OF SERVICE