20140910Sierra Club 1-14 to IPC.pdf

(208) 343-7s00
(208) 336-69n (Fax)
McDevitt & Miller LLP
Lawyers
420 West Bannock Steet
P.O. Box 2564-83701
Boiser ldaho 83702
Chas. F. McDevitt
DeanJ. (oe) Millet
Celeste I(. Millet
Yia Ifaad Delivery
JeanJewell, Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,Idaho 83720
September 10,2074
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Deat Ms. Jewell:
Enclosed for filing in the above rnattet please 6nd an odginaf aod thtee (3) copies of Sietra Club's
Fitst Discovery Requests to Idaho Power Company.
An additional copy of the document and this lettet is included fot rctutn to me with yout file stamp
theteon.
Very Truly Youts,
McDevitt & Miller LLP
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DeanJ. Mllet
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Enclosures
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f\)Re: Siera Chfi/ IPC-E-14-18
Dean J. Miller (ISB No. 1968)
MoDEWIT & MILLER LLP
420 West Bannock Street
P.O. Box 2564-83701
Boise, D 83702
Tel: [phone]
Fax: [phone]
j oe@mcdevitt-miller. com
Matt Vespa
CA Bar #222265 (Pro Hac Vice pending)
Sierra Club
85 Second St., 2nd Fl.
San Francisco, CA 94105
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Siena Club
IN THE MATTER OF IDAHO POWER
COMPAI{Y'S APPLICATION TO
IMPLEMENT SOLAR INTEGRATION
RATES AND CIIARGES.
ORIGINAL
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BEF'ORE THE IDAHO PUBLIC UTILITIES COMMISSION
Pursuant to RP 221.02 afi,221.03, Sierra Club ("Sierra Club") propounds the following
Discovery Requests to Idaho Power Company ("Company'').
Sierra Club requests that the Company make best efforts to provide responses as soon as
possible but not later than September 24,2014.
These Discovery Requests are to be considered as continuing, and the Company is
requested to provide, by way of supplernentary responses, additional documents or information
that it or any person acting on its behalf may later obtain.
CASE NO.IPC-E-14.18
FrRST DTSCOVERY REQUESTS OF
SIERRA CLUB TO IDAHO POWER
COMPANY
FIRST DISCOVERY REQUESTS OF SIERRA CLUB TO IDAHO POWER COMPAI\IY:I
Pursuant to Commission Rules of Procedure a response to a request for production of
documents must include the name and phone number of the 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. See IDAPA 31.01.01.228.
The term as used in these requests, TRC, means the Technical Review Committee
described in the Direct Testimony of P. DeVol.
DISCOVERY REOUESTS
For Requests Numbers 1-12, please reference Exhibit No. L to the Direct
Testimony of P. DeVol.
REOUEST NO 1: Please provide copies of presentations (power point or the like) and
other materials provided by Idaho Power to the TRC at or in advance of the TRC meeting of
August 15,2013.
REOUEST NO 2: Please provide copies of minutes or similar summaries of the TRC
meeting of August 15,2013.
REOUEST NO 3: Please orovide copies of presentations (power point or the like) and
other materials provided by Idaho Power to the TRC at or in advance of the TRC meeting of
September 19,2013.
REQUEST NO 4: Please provide copies of minutes or similar summaries of the TRC
meeting of September 19, 2013.
REQUEST NO 5: Please provide copies of presentations (power point or the like) and
other materials provided by Idaho Power to the TRC at or in advance of the TRC meeting of
January 6,2014.
FIRST DISCOVERY REQUESTS OF SIERRA CLLIB TO IDATTO POWER COMPANY -2
REOUEST NO 6: Please provide copies of minutes or similar summaries of the TRC
meeting of January 6,2014.
REOUEST NO 7: Please provide copies of presentations (power point or the like) and
other materials provided by Idaho Power to the TRC at or in advance of the TRC meeting of
May 16,2014.
REOUEST NO 8: Please provide copies of minutes or similar summaries of the TRC
meeting of May 16,2014.
REOUEST NO 9: Please provide copies of presentations (power point or the like) and
other materials provided by Idaho Power to the TRC at or in advance of the TRC meeting of
May 29,2014.
REOUEST NO 10: Please provide copies of minutes or similar summaries of the TRC
meeting of May 29,2014.
REOUEST NO 11: To the extent not covered by the preceding requests please provide
copies of all communications (memorandums, letters, email transmittals and the like) from
company representatives to any member of the TRC between the sunmer of 2013 and the filing
of the present Application.
REOUEST NO 12: To the extent not covered by the preceding requests please provide
copies of all communications (memorandums, letters email transmittals and the like) from any
member of the TRC to the Company relating to the Solar Integration Study between the summer
of 2013 and the filing of the present Application.
FrRST DTSCOVERY REQUESTS OF STERRA CLUB TO rDAHO POWER COMPAT{Y -3
For requests Numbers 13-14, please refer to page 6 of the Direct Testimony of P.
DeVol and the document entitled Principles for technical Review Involvement in
Studies of Variable Generation into Electrical Power Systems.
REOUEST NO 13: Did Idaho Power provide to the TRC an assurance that project
sponsors will describe the project as having the benefit of expert review by a TRC only if the
TRC has clearly expressed its acceptance of and agreement with the results of the stud/
A. If your answer is yes, please provide a copy of said assurance.
B. If your answer is no, please explain why not.
REOUEST NO 14: Did Idaho Power provide to the TRC an assurance that in the event
agreement is not reached by the TRC and other project participants, ffiy reference to the TRC
will be removed from the final report and any associated documents or publicity?
A. If your answer is yes, please provide a copy of said assurance.
B. If your answer is no, please explain why not.
Dated this {I} day if September, 2014
J. Miller (ISB No. 1968)
MoDEVITT & MILLER LLP
Matt Vespa (CA Bar #222265)
(Pro Hac Yice pending)
SmnneCrun
Attorneys for Sierua Club
FIRST DISCOVERY REQUESTS OT SIERRA CLTJB TO IDAEO POWER COMPAI\TY.4
CERTIFICATE OF' SERVICE
I hereby certify that on ,t. 1ffary of Septemb er,20l4,I caused to be served, via the
method(s) indicated below, true and correct copies of the foregoing document, upon:
Jean Jewell, Secretary
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise, D 83720-0074
ij ewell@ouc. state.id.us
Kristine Sasser, Deputy Attorney General
Idaho Public Utilities Commission
47 2 W est Washington Street
P.O. Box 83720
Boise, D 83720-0074
[e-mail]. eov
Donovan E. Walker
Greg Said
Michael f. Youngblood
Regulatory Dockets
Idaho Power Company
1221 West Idaho Street
P.O. Box 70
Boise,ID 83707
dwalker@ i dalrooower. com
[e-mail]
m]rouneblood@ idahopower. com
dockets@ i dahopower. com
Idaho Conservation League
c/o Beqjamin J. Otto
710 N. 6th St.
Boise,Idaho 83702
botto@i dahoconsenrution.ot*
KenMiller
Snake River Alliance
Boise,ID
kmiller@ snakeriveralliance.ore
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FIRST DTSCOVERY REQTTESTS OF SIERRA CLUB TO rDAHO POWER COMPAT{Y -s