20120424Staff 10-17 to IPC.pdf

KRISTINE A. SASSER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
P0 BOX 83720
BOISE, IDAHO 83720-0074
[phone]
BAR NO. 6618
RECEIVED
IDAHO PU8L IJTUJT ES COiSSION
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 ) CASE NO. IPC-E-10-19
BETWEEN IDAHO POWER COMPANY AND )
GRAND VIEW SOLAR ONE PV, LLC. ) THIRD PRODUCTION
) REQUEST OF THE
) COMMISSION STAFF TO
) IDAHO POWER COMPANY
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Kristine A. Sasser, Deputy Attorney General, requests that Idaho Power Company (Company;
IPC) 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 Idaho Power Company 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. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 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. 10: Please explain why Idaho Power 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
Idaho Power defines the phrase "commercially reasonable."
REQUEST NO. 11: Please explain Idaho Power's understanding of the reasons given by
Grand View Solar One for not meeting the Scheduled Operation Date as specified in ¶ B-3 of
Appendix B of the FESA.
REQUEST NO. 12: Please submit an amendment to Article VII in the FESA (rates
portion) to accommodate a full 20 year contract term (unless Idaho Power and Grand View are
now proposing less than a 20-year contract term).
REQUEST NO. 13: Please identify any interconnection and/or transmission studies that
are required for the project and state the status of each (i.e., completed, in-progress, etc.). Please
also indicate whether Grand View Solar One is current on any required payments for the studies.
REQUEST NO. 14: Please discuss whether any interconnection and transmission
facilities have been constructed or upgraded to date in order to accommodate the Grand View
Solar One facility. Please list any amounts paid by either Idaho Power or Grand View for
construction of these facilities.
REQUEST NO. 15: Please explain how Idaho Power intends to determine when the
Grand View Solar One facility has met its revised Scheduled Operation Date. For example, this
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 2 APRIL 24, 2012
project will consist of approximately 75,000 PV panels. How many panels have to be
operational before the facility will be deemed to have met its Scheduled Operation Date?
REQUEST NO. 16: 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. Does Idaho Power believe that
there is ambiguous language in the FESA that needs to be revised for use in future contracts?
REQUEST NO. 17: Please confirm whether Grand View Solar One posted security in
the amount of $810,000 no later than April 6, 2012 by 5:00 pm as required by the April 3, 2012
letter Agreement between the parties.
DATED at Boise, Idaho, this '1 —*1Zlay of April 2012.
MAMIF, - W. WN W!
Deputy Attorney General
Technical Staff: Rick Sterling
i:umisc:prodreq/ipce 10. 19ksrps ipc3
THIRD PRODUCTION REQUEST
TO IDAHO POWER COMPANY 3 APRIL 24, 2012
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 24TH DAY OF APRIL 2010,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO IDAHO POWER COMPANY, 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]
lnordstrom(idahopower.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]
SECRETAR
CERTIFICATE OF SERVICE