20110815Grand View PV Solar Two 1-7 to IPC.pdf

Peter J. Richardson ISB # 3195
Gregory Adams ISB # 7454
RICHARDSON & O'LEARY PLLC
515 N. 27th Street
Boise, Idaho 83702
Telephone: [phone]
Fax: [phone]
peter~richardsonandolear .com
Attorneys for Grand View PV Solar Two
RECEIVED
ZUII AUG /5 PM 3: 32
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR A DETERMINATION
REGARDING THE FIRM ENERGY
SALES AGREEMENT WITH
INTERCONNECT SOLAR
DEVELOPMENT, LLC, FOR THE SALE
AND PURCHASE OF ELECTRIC
ENERGY
) CASE NO. IPC-E-ll-IO
)
) FIRST PRODUCTION REQUEST OF
) GRAND VIEW PV SOLAR TWO,
) LLC TO IDAHO POWER COMPANY
)
)
)
)
Pursuant to Rule 225 of the Riles of Procedure of the Idaho Public Utilities Commission
(the "Commission"), Grand View PV Solar, Two, by and through its attorney of record, Peter J.
Richardson, hereby requests that Idaho Power Company ("Company") provide the following
documents.
This production request is to be considered as continuing, and the Company is requested
to provide by way of supplementa responses additional documents that it or any person acting
on its behalf may later obtain that will augment the documents produced.
Please provide one physical copy and one electronic copy, if available, of your answer to
Mr. Richardson at the address noted above. Please provide an additional electronic copy, or if
1 -FIRST PRODUCTION REQUEST OF GRAND VIEW PV SOLAR TWO - IPC-E-ll-l 0
unavailable a physical copy, to Dr. Don Reading at: 6070 Hil Road, Boise, Idaho 83703, Tel:
[phone]; Fax: [phone]; dreading~mindspring.com
For each item, please indicate the name of the person(s) preparng the answers, along
with the job title of such person(s) and the witness at hearing who can sponsor the answer.
REQUEST FOR PRODUCTION NO.1:
Please provide copies of Idaho Power's responses to all production requests from Staff in
this docket.
REQUEST FOR PRODUCTION NO.2:
Please provide detailed historic generation data for Idaho Power's solar panels located on
the rooftop of its headquarers building at 1221 West Idaho Street, Boise, Idaho ("Idaho Power
Solar Project"). Please provide said data broken out on an hourly basis as well as any other
information the Company has with regard to the performance of the Idaho Power Solar Project.
REQUEST FOR PRODUCTION NO.3:
Please identify the manufactuer, name plate rating and design and operation
specifications for the Idaho Power Solar Project.
REQUEST FOR PRODUCTION NO.4:
Please provide a copy of the data referred to in the Company's response to Staf Request
NO.4 which provides, in par, "data was collected from Idaho Power's rooftop solar facility that
has been installed for 17 years."
2 -FIRST PRODUCTION REQUEST OF GRAND VIEW PV SOLAR TWO - IPC-E-ll-lO
REQUEST FOR PRODUCTION NO.5:
Please provide a copy of the maintenance records for the Idaho Power Solar Facilty.
REQUEST FOR PRODUCTION NO.6:
Please identify by order number, or if not contained in an order, provide a copy of all
Idaho PUC directives, requirements, or guidelines that Idaho Power understads instructs how it
calculates avoided cost rates for PURP A QF projects larger than 100 kw.
REQUEST FOR PRODUCTION NO.7:
Please provide a copy of all communications between Idaho Power and the Idaho PUC
Staff regarding the proper calculation of avoided cost rates for PURP A QFs larger than 100 kw
DATED this 15th day of August, 2011.
RICHARDSON & O'LEARY PLLC
3 -FIRST PRODUCTION REQUEST OF GRAND VIEW PV SOLAR TWO - IPC-E-ll-l 0
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the15th day of August, 2011, a true and correct
copy of the within and foregoing FIRST PRODUCTION REQUEST OF GRAND
VIEW PV SOLAR TWO was served in the maner shown to:
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington (83702)
PO Box 83720
Boise, ID 83720-0074
X. Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
lL Electronic Mail
Lisa Nordstrom
Donovan Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707-0070
1nordstrom(ßidahopower.com
dwa1ker(ßidahopower.com
X. Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
lL Electronic Mail
Ron Wiliams
Wiliams Bradbur
1015 West Hays St
Boise, Idaho 83702
ron~williamsbradbur.com
X. Hand Delivery
_U.S. Mail, postage pre-paid
Facsimile
lL Electronic Mail
ÜiWA\b
Nina Curis
Administrative Assistat
4 -FIRST PRODUCTION REQUEST OF GRAND VIEW PV SOLAR TWO - IPC-E-II-IO