20120306IPC Objections to Production Requests 1,5,9B.pdf

DONOVAN E. WALKER
Lead Counsel
dwalker~idahopower.com
*5
IDA~POR(I
An IDACORP Company
March 6, 2012
VIA HAND DELIVERY
Jean D. Jewell, Secretary
Idaho Public Utilties Commission
472 West Washington Street
Boise, Idaho 83702
Re: Case No. IPC-E-12-01
GRAND VIEW PV SOLAR THREE, LLC, COMPLAINANT, GRAND VIEW PV
SOLAR FOUR, LLC, COMPLAINANT VS. IDAHO POWER COMPANY,
RESPONDENT
Dear Ms. Jewell:
Enclosed for filng please find an original and three (3) copies of Idaho Power
Company's Objections to Requests for Production Nos. 1, 5, and 9B of Grand View PV
Solar Three, LLC, and Grand View PV Solar Four, LLC's First Production Request to
Idaho Power Company in the above matter.
DEW:csb
Enclosures
1221 W. Idaho St. (83702)
P.O. Box 70
Boise, ID 83707
DONOVAN E. WALKER (ISB No. 5921)
JASON B. WILLIAMS (ISB No. 8718)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
dwalkercmidahopower.com
jwilliamscmidahopower.com
Attorneys for Idaho Power Company
RECEIVED
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UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
GRAND VIEW PV SOLAR THREE, LLC, )
)Complainant, )
)
GRAND VIEW PV SOLAR FOUR, LLC, )
)Complainant, )
)vs. )
)IDAHO POWER COMPANY, )
)Respondent. )
)
CASE NO. IPC-E-12-01
IDAHO POWER COMPANY'S
OBJECTIONS TO REQUESTS FOR
PRODUCTION NOS. 1, 5, AND 9B
OF GRAND VIEW PV SOLAR
THREE, LLC, AND GRAND VIEW
PV SOLAR FOUR, LLC'S FIRST
PRODUCTION REQUEST TO
IDAHO POWER COMPANY
COMES NOW, Idaho Power Company ("Idaho Powet') and objects to Requests
for Production Nos. 1, 5, and 9B of Grand View PV Solar Three, LLC, and Grand View
PV Solar Four, LLC's ("Grand View") First Production Request to Idaho Power
Company dated February 21, 2012, as follows:
IDAHO POWER COMPANY'S OBJECTIONS TO REQUESTS FOR PRODUCTION
NOS. 1, 5, AND 9B OF GRAND VIEW PV SOLAR THREE, LLC, AND GRAND VIEW
PV SOLAR FOUR, LLC'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 1
REQUEST FOR PRODUCTION NO.1: Please provide copies of all Documents
and communications Idaho Power has had (both internal and external) regarding Grand
View PV Solar Three, LLC and Grand View PV Solar Four, LLC.
OBJECTION TO REQUEST FOR PRODUCTION NO.1: Idaho Power objects to
this Request as the information sought is overly broad and would be unduly
burdensome to produce.
Idaho Power objects on the grounds that some of the information sought is
prohibited from disclosure by the attorney-client privilege. Specifically, communications
between Idaho Powets attorneys and other Idaho Power employees, agents, and
consultants is protected by the attorney-client privilege and wil not be disclosed.
Additionally, external communications with Grand View PV Solar Three, LLC,
and Grand View PV Solar Four, LLC, as well as their counsel are within the possession
and control of those parties.
The response to this Request was prepared by Jason Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S OBJECTIONS TO REQUESTS FOR PRODUCTION
NOS. 1, 5, AND 9B OF GRAND VIEW PV SOLAR THREE, LLC, AND GRAND VIEW
PV SOLAR FOUR, LLC'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO.5: Please provide copies of all
correspondence, Documents, notes and all other material related to Idaho Powets
PURPA contract with Interconnect Solar. Said information should include the avoided
cost pricing models and inputs in both hard copy and usable electronic format.
OBJECTION TO REQUEST FOR PRODUCTION NO.5: Idaho Power objects to
this Request on the grounds of relevancy and that it is beyond the scope of the issues
raised in this case.
Idaho Power also objects on the grounds that the information sought is
confidential, proprietary, and trade secret information that belongs to Interconnect Solar
Development, LLC. Idaho Power will not disclose such materiaL.
The response to this Request was prepared by Jason B. Wiliams, Corporate
Counsel, Idaho Power Company.
IDAHO POWER COMPANY'S OBJECTIONS TO REQUESTS FOR PRODUCTION
NOS. 1, 5, AND 9B OF GRAND VIEW PV SOLAR THREE, LLC, AND GRAND VIEW
PV SOLAR FOUR, LLC'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO.9: Please provide all Documents, notes,
correspondence and inputs and calculations related to the calculation of the rates
contained in:
A. The PPA Idaho Power provided to Grand View on December 2, 2011;
and,
B. The PPA Idaho Power provided to Interconnect Solar in October 2011.
OBJECTION TO REQUEST FOR PRODUCTION NO. 9B: See Idaho Power's
response to Grand View's Request for Production No.5.
The response to this Request was prepared by Randy Allphin, Senior Energy
Contracts Coordinator, Idaho Power Company, and Jason B. Wiliams, Corporate
Counsel, in consultation with Donovan E. Walker, Lead Counsel, Idaho Power
Company.
Respectfully submitted this 6th day of March 2012.
~.....
DONOVAN E. WALKER
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S OBJECTIONS TO REQUESTS FOR PRODUCTION
NOS. 1, 5, AND 9B OF GRAND VIEW PV SOLAR THREE, LLC, AND GRAND VIEW
PV SOLAR FOUR, LLC'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 6th day of March 2012 I served a true and
correct copy of IDAHO POWER COMPANY'S OBJECTIONS TO REQUESTS FOR
PRODUCTION NOS. 1, 5, AND 9B OF GRAND VIEW PV SOLAR THREE, LLC, AND
GRAND VIEW PV SOLAR FOUR, LLC'S FIRST PRODUCTION REQUEST TO IDAHO
POWER COMPANY upon the following named parties by the method indicated below,
and addressed to the following:
Commission Staff
Kristine Sasser
Deputy Attorney General
Idaho Public Utilities Commission
472 West Washington
P.O. Box 83720
Boise, Idaho 83720-0074
-- Hand Delivered
U.S. Mail
_ Overnight Mail
FAX
-- Email Kris.Sassercmpuc.idaho.gov
Grand View PV Solar Three, LLC, and
Grand View PV Solar Four, LLC
Peter J. Richardson
Gregory M. Adams
RICHARDSON & O'LEARY, PLLC
515 North 2th Street (83702) .
P.O. Box 7218
Boise, Idaho 83707
Hand Delivered
-- U.S. Mail
_ Overnight Mail
FAX
-- Email petercmrichardsonandoleary.com
gregcmrichardsonandoleary.com.~
Donovan E. Walker
IDAHO POWER COMPANY'S OBJECTIONS TO REQUESTS FOR PRODUCTION
NOS. 1, 5, AND 9B OF GRAND VIEW PV SOLAR THREE, LLC, AND GRAND VIEW
PV SOLAR FOUR, LLC'S FIRST PRODUCTION REQUEST TO IDAHO POWER COMPANY - 5