20141103Grand View 1-8 to Staff.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@richardsonando leary. com
Attorneys for Grand View PV Solar Two, LLC
IN THE MATTER OF THE
APPLICATION OF IDAHO POWER
COMPANY FOR APPROVAL OR
REJECTION OF AN ENERGY SALES
AGREEMENT WITH GRAND VIEW PV
SOLAR TWO, LLC, FOR THE SALE AND
PURCHASE OF ELECTRIC ENERGY
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E.14.19
FIRST PRODUCTION REQUEST OF
GRAND VIEW PV SOLAR TWO,
LLC TO THE IDAHO PUBLIC
UTILITIES COMMISSION
Pursuant to Rule 225 of the Rules of Procedure of the tdaho Public Utilities Commission
(the "Commission"), Grand View PV Solar Two, LLC by and through their attorney of record,
Peter J. Richardson, hereby requests that the Idaho Public Utilities Commission provide the
following documents and respond to the following interrogatories.
This production request is to be considered as continuing, and the Commission is
requested to provide by way of supplementary responses to provide 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
I -FTRST PRODUCTTON REQUEST OF GRAND VrEW PV SOLAR TWO AND IPC-E-14-19
unavailable a physical copy, to Dr. Don Reading at: 6070 Hill Road, Boise, Idaho 83703, Tel:
(208\ 342-1700; Fax: (208) 3 84- I 5 I I ; [e-mail]
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 at hearing who can sponsor the answer.
REOUEST FOR PRODUCTION NO. I:
Please provide copies of Idaho Power's responses to all production requests from Staff in
this docket.
REOUEST FOR PRODUCTION NO. 2:
Please provide copies of all of the Commission's workpapers and notes used in preparing
Staff s Comments in this docket.
REQUEST FOR PRODUCTION NO. 3:
Please provide a copy of all documents referred to by the Commission in the preparation
of Staff s Comments in this docket.
REOUEST FOR PRODUCTION NO. 4:
Please provide the information from Table I of Staff s Comments for every hour of the
term of the contract.
REOUEST FOR PRODUCTION NO. 5:
Please provide documentation supporting Figure One on pageT of Staff s Comments and
for Figure Two on page 8.
REQUEST FOR PRODUCTION NO. 6:
Please provide data for all hours for the term of the contract with data for the l5 columns
displayed in Table I along with the calculations for the avoided cost of energy for each hour as
displayed in the formula on page 6 below Table l.
2 -FIRST PRODUCTION REQUEST OF GRAND VrEW PV SOLAR TWO AND IPC-E-14-19
REOUEST FOR PRODUCTION NO. 7
Was 80 MW used for Grand View in each hour for the calculations in the formula found
on page 6?
REOUEST FOR PRODUCTION NO. 8:
Was 80 MW used for Grand View for each hour of the 20 year contract period in the
AURORA calculations of avoided energy cost rather than the output profile provided by Grand
View to Idaho Power in the calculations of avoided costs? Please explain why or why not.
DATED this 3rd day of November, 2014.
Grand View PV Solar Two
3 -FTRST PRODUCTTON REQUEST OF GRAND VIEW PV SOLAR TWO AND rPC-E-14-r9
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 3rd day of November, 2014, a true and correct copy of
the within and foregoing FIRST PRODUCTION REQUEST OF GRAND VIEW PV
SOLAR TWO was served in the manner shown to:
Kris Sasser
Ms. Jean Jewell
Idaho Public Utilities Commission
472 W . Washington (83702)
PO Box 83720
Boise, ID 83720-0074
Kris. sasser@ftuc. idaho. gov
Donovan Walker
Idaho Power Company
PO Box 70
Boise, Idaho 83707 -0070
dwalker@idahopower. com
X Hand Delivery
_U.S. Mail, postage pre-paid
_ Facsimile
Electronic Mail
X Hand Delivery
_U.S. Mail, postage pre-paid
_ Facsimile
_ Electronic Mail
Administrative Assistant
4 -FIRST PRODUCTTON REQUEST OF GRAND VIEW PV SOLAR TWO AND IPC-E-14-19