attorney sam randazzo's response to protective order by wind developer

7/25/2019 Attorney Sam Randazzo's Response to Protective Order by Wind Developer

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{C49379:2 }

BEFORETHE OHIO POWER SITING BOARD

In the Matter of the Application of )6011 Greenwich Windpark, LLC for an )

Amendment to its Certificate to Install ) Case No. 15-1921-EL-BGNand Operate a Wind-Powered Electric )Generation Facility in Huron County, Ohio. )

GREENWICH NEIGHBORS UNITEDSMEMORANDUM CONTRA TO

6011GREENWICH WINDPARK,LLCSMOTION FOR A PROTECTIVE ORDER

Samuel C. Randazzo (Reg. No. 0016386)(Counsel of Record)

Scott E. Elisar (Reg. No. 0081877)MCNEES WALLACE &NURICK LLC21 East State Street, 17THFloor

Columbus, OH 43215Telephone: (614) 469-8000Telecopier: (614) [email protected](willing to accept service by e-mail)[email protected](willing to accept service by e-mail)

FEBRUARY 12,2016 ATTORNEYS FOR GREENWICH NEIGHBORS UNITED


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{C49379:2 }

BEFORETHE OHIO POWER SITING BOARD

In the Matter of the Application of )

6011 Greenwich Windpark, LLC for an )Amendment to its Certificate to Install ) Case No. 15-1921-EL-BGNand Operate a Wind-Powered Electric )Generation Facility in Huron County, Ohio. )

GREENWICH NEIGHBORS UNITEDS MEMORANDUM CONTRA TO6011GREENWICH WINDPARK,LLCS MOTION FOR A PROTECTIVE ORDER

On November 16, 2015, 6011 Greenwich Windpark, LLC (Wind Farm) filed an

Application to Amend its Certificate of Environmental Compatibility (Application). The

Application requests the Ohio Power Siting Board (Board) to authorize an amendment

to its certificate to allow the Wind Farm to add three new models of turbines to the menu

from which it may select the turbines that will become part of its project if the Wind Farm

proceeds with development. Greenwich Neighbors United (GNU) has a direct, real, and

substantial interest in this proceeding and moved to intervene on November 25, 2015.

Subsequent to its intervention, GNU properly invoked the Boards discovery procedures

to gather information needed to assess the potential consequences of granting the

amendment proposed by the Wind Farm. More specifically, GNU served its first set of

interrogatories and requests for production of documents on the Wind Farm on

January 21, 2016. Pursuant to the Boards rules, the Wind Farm was obligated to provide

responses to GNUs discovery on February 10, 2016.


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{C49379:2 } 2

In response to GNUs proper discovery and instead of providing full and complete

substantive responses,1the Wind Farm filed a Motion for a Protective Order seeking a

ruling that prohibit[s] discovery on subjects not within the scope of this proceeding, i.e.,

subjects not related to the proposed additional [sic] of new turbine technology presented

in the amendment application.2 The Wind Farm waited until the last day on which it was

required to provide such full and complete discovery responses to file its Motion for a

Protective Order. The Wind Farm also seeks, without following the Boards rules, an

expedited ruling on its Motion for a Protective Order.3

As discussed below, the Wind Farm has presented the Board with a defective

Motion for a Protective Order that also fails, in any event, to demonstrate that the Wind

Farm is entitled to the requested relief. GNUs discovery requests seek information that

GNU may rightfully seek and obtain from the Wind Farm to identify the potential effects

of the Wind Farms proposed amendment. Accordingly, GNUs discovery requests are

proper and the Board should deny the last-minute Motion for a Protective Order.

I. THE WIND FARMS MOTION FOR A PROTECTIVE ORDER IS DEFECTIVE

A. Requirements for a Protective Order and Expedited Rulings

Under the Boards rules, a party may seek to prohibit discovery where the party

demonstrates that such prohibition is necessary to protect a party or person from

annoyance, embarrassment, oppression, or undue burden or expense.4 If a party seeks

to prohibit or limit discovery through a motion for a protective order, certain requirements

1The Wind Farms responses (mostly objections) to GNUs first set of interrogatories and requests forproduction of documents are attached hereto as Appendix A.

2Motion for Protective Order at 1.

3Id.

4Rule 4906-2-21(A), Ohio Administrative Code (O.A.C.).


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{C49379:2 } 3

must be met. The movant must have exhausted all other reasonable means of resolving

any differences with the party seeking discovery.5 The movant must attach to its motion

[c]opies of any specific discovery request which are the subject of the request for a

protective order.6 The movant must also attach to its motion [a]n affidavit of

counsel setting forth the efforts which have been made to resolve any differences with

the party seeking discovery.7

Additionally, the Board requires any party seeking expedited treatment of a motion

to first contact all other parties to determine whether any party objects to the issuance of

such a ruling without the filing of memoranda.

8

If the moving party fails to certify that no

party has any objections, any party may file a memorandum contra within seven days

after the service of the motion.9

B. The Motion for a Protective Order Fails to Comply with the BoardsRules

The Wind Farm has filed a defective motion for protective order, which should be

denied. Initially, the Wind Farm requests the issuance of a protective order pursuant to

Rule 4906-7-07(H)(1), O.A.C., and rule on an expedited basis pursuant to Rule

4906-7-12(F), O.A.C. These two rules were rescinded and are no longer in effect and

cannot be relied upon by the Board to provide the Wind Farm the relief it requests.

5Rule 4906-2-21(B), O.A.C.6Rule 4906-2-21(B)(2), O.A.C.

7Rule 4906-2-21(B)(3), O.A.C.

8Rule 4906-2-27(C), O.A.C.

9Id. The Wind Farms Motion for a Protective Order suggests that the Board subvert this process by issuingan expedited ruling on its own initiative under Rule 4906-2-27(F), O.A.C., instead of requiring the WindFarm to follow the process set forth in Rule 4906-2-27(C), O.A.C., applicable to a movant requestingexpedited treatment.


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The Wind Farms Motion for a Protective Order, however, also fails to comply with

the Boards current rules applicable to requests for the issuance of a protective order and

requests for expedited rulings.10 The Wind Farm has not attached to its Motion for a

Protective Order the discovery requests that are the subject of its Motion for a Protective

Order or attached the required Affidavit of Counsel. The Wind Farm has also failed to

allege or demonstrate that issuing the protective order is necessary to protect a party or

person from annoyance, embarrassment, oppression, or undue burden or expense.11 Its

only argument in support of its request for the protective order is that GNUs discovery

falls outside the proper scope of this proceeding. As demonstrated below, that is

incorrect. Accordingly, the Wind Farm has failed to comply with the requirements to

obtain a protective order.

After waiting until the last day on which it was required to fully and completely

respond to GNUs discovery, the Wind Farm is also asking the Board for an expedited

ruling without providing the requisite seven days for interested parties to file a

memorandum contra.12 The request for an expedited ruling is also defective; the Wind

Farm does not allege or demonstrate that it contacted counsel for GNU to determine if

GNU would object to a request for an expedited ruling as required by Rule 4906-2-27(C),

O.A.C.

For these reasons, the Board should find that the Motion for a Protective Order

and the accompanying request for an expedited ruling is defective and should be denied.

Even if the Board overlooks these defects, GNUs discovery requests are within the

10Rules 4906-2-21 and 4906-2-27(C), O.A.C.

11Rule 4906-2-21(A), O.A.C.



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proper scope of discovery in this matter and therefore the issuance of a protective order

is not necessary or warranted.

II. GNUS DISCOVERY IS PROPER

A. Standard of Review for Applications to Amend Certificates

Rule 4906-3-11, O.A.C., governs applications to amend certificates to construct

and operate proposed electric generating plants, such as the Wind Farms, and requires

such an application to satisfy the completeness requirements contained in Rule

4906-3-06, O.A.C. Rule 4906-3-06, O.A.C., further requires the application to comply

with the content requirements of R.C. 4906.06 and Chapters 4906-1 to 4906-7, O.A.C.

These substantive content requirements are quite extensive.13

Upon the filing of an application to amend an existing certificate, the Boards Staff

is required to review the application pursuant to rule 4906-3-06 of the Administrative

Code and make appropriate recommendations to the board and the administrative law

judge.14 The Board is then required to determine if the proposed change in the certified

13R.C. 4906.06 requires the application to contain, at a minimum, a description of the major utility facility,a summary of any studies that have been made by or for the application of the environmental impact of thefacility, a statement explaining the need for the facility, a statement of the reasons why the proposed locationis best suited for the facility, [a] statement of how the facility fits into the applicant's forecast contained inthe report submitted under section 4935.04 of the Revised Code, and such other information as the Boardmay require.

Pursuant to Chapters 4906-1 to 4906-7, the Board further requires the application to contain additionaldetail. Included in the additional detail required by the Board is the [wind] turbine hub height, tip height,rotor diameter, and blade length for each model under consideration (Rule 4906-4-03(B)(1)(b), O.A.C.),

information related to [s]ubstations, switching substations, and transformers

(Rule 4906-4-03(B)(2)(g),O.A.C.), a brief description of the need for new electric transmission line(s) (Rule 4906-4-03(B)(3),O.A.C.), [w]ildlife and environmental surveys/studies (Rule 4906-4-03(C)(1)(b), O.A.C.), and [r]eceipt ofgrid interconnection studies and other critical path milestones for project construction (Rule4906-4-03(C)(1)(c), O.A.C.). The application must also include a description of how the facility will beconnected to the regional electric grid (Rule 4906-4-05(A), O.A.C.), including information relating to theirgeneration interconnection request, including interconnection queue name, number, date, and website(Rule 4905-4-05(B)(1), O.A.C.) and studies on their generation interconnection request (Rule4906-4-05(B)(2), O.A.C.).

14Rule 4906-3-11(B)(1), O.A.C.


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{C49379:2 } 6

facility would result in any significant adverse environmental impact of the certified facility

or a substantial change in the location of all or a portion of such certified facility other than

as provided in the alternates set forth in the application.15 If the Board finds affirmatively,

it shallset the matter for a hearing. Even without an affirmative finding that the proposed

change would result in significant adverse environmental impact or a substantial change

in the location of all or a portion of the certified facility, the Board retains discretion to

require a hearing.

B. Applicable Discovery Standards

The Board encourages the prompt and expeditious use of prehearing discovery

in order to facilitate thorough and adequate preparation for participation in board

proceedings.16 The Board also permits discovery on any matter that is relevant to the

subject matter of the proceeding and any matter that appears reasonably calculated to

lead to the discovery of admissible evidence.17 Discovery may be sought in Board

proceedings through interrogatories and requests for production of documents.18

C. GNUs Discovery Requests are Reasonably Calculated to Lead to theDiscovery of Admissible Evidence

In support of its Motion for a Protective Order, the Wind Farm requests that the

Board limit discovery to prohibit discovery on matters not within the subject of this

proceeding.19 The Wind Farm asserts that the proper scope is limited to issues related

to the proposed additional [sic] of new turbine technology presented in the amendment

15Rule 4906-3-11(B)(1)(a), O.A.C.

16Rule 4906-2-14(A), O.A.C.

17Rule 4906-2-14(B), O.A.C.

18Rules 4906-2-17 and 4906-2-19, O.A.C.



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application.20 The Wind Farm also asserts that it does not seek to modify any of the

conditions and requirements established by the Board in the original Certificate case

(Case No. 13-990-EL-BGN).21 Finally, the Wind Farm cites a prior Board decision for

the proposition that an amendment application proceeding must be limited to the issues

raised in the amendment application.22

The Wind Farm has asked the Board to amend a construction and operation

certificate to add three new turbine models to the one turbine model that is presently

certificated subject to numerous conditions. The Wind Farm has not identified which

turbine model or combination of models it will actually construct and operate if the Board

approves the proposed amendment.

GNUs discovery seeks information related to the legal and real world ramifications

of the construction and operation of the turbine models (previously certified and previously

not certified) that the Wind Farm proposes to place on the menu from which it may elect

to feed its project development appetite. Any issues lawfully resolved in Case No.

13-990-EL-BGN, dealing with one turbine model, could not and did not reach the issues

raised by the Application in this proceeding that seeks the Boards authorization to

integrate, in ways unidentified by the Wind Farm, three additional turbine models within

the Wind Farms project area. The certificate conditions established in Case No.

13-990-EL-BGN are uniquely related to the facts and circumstances associated with the

one turbine model addressed in that case including, among other things, the

20Id.

21Id.

22Id.at 4 (citing In the Matter of the Application of Black Fork Wind Energy, LLC Regarding its Certificateof Environmental Compatibility and Public Need issued in Case No. 10-2865-EL-BGN , Case No.14-1591-EL-BGA, Opinion and Order at 2 (Aug. 27, 2015)).


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comprehensive violation of Ohios minimum setback requirements, the operating

characteristics of that one turbine model, the noise of that one turbine model, the ice throw

of that one turbine model, the shadow flicker of that one turbine model, the blade sheer

of that one turbine model, and all other factors that the Board must lawfully address to

issue a certificate. The three new turbine models, with different physical and operational

characteristics than the one turbine model previously reviewed and approved, and the

unknown combination of turbine models that the Wind Farm might ultimately select to

construct and operate if it decides to move forward with its project, raise issues that the

Board must lawfully address in this proceeding.

23

Accordingly, nothing resolved in Case

No. 13-990-EL-BGN can be, as a matter of law, dispositive of issues raised by the

Application that is pending in this proceeding.

While the Wind Farm may prefer otherwise, GNU is entitled to seek and obtain

information on the potential implications of the construction and operation of an

unspecified deployment and potential combination of four turbine models, each having

different dimensions and operating characteristics in a context where 62% of the wind

23For example, the Board is required to determine if the application to amend will result in a substantialchange in the location of all or a portion of such certified facility. As the Wind Farm details in its Application,the three new models differ in height from the one model that has been certified, and thus the new modelsmust be reviewed to determine if they could be installed at the locations previously certified by the Boardand comply with the minimum setback requirements. Furthermore, R.C. 4906.201 requires any certificate

that is amended after September 15, 2014 to comply with the current minimum setback requirements. Thecurrent minimum setbacks provide [t]hat minimum shall be equal to a horizontal distance, from the turbine'sbase to the property line of the wind farm property, equal to one and one-tenth times the total height of theturbine structure as measured from its base to the tip of its highest blade and be at least one thousand onehundred twenty-five feet in horizontal distance from the tip of the turbine's nearest blade at ninety degreesto property line of the nearest adjacent property at the time of the certification application. R.C.4906.20(B)(2)(a). In conjunction, the differences in heights between the certified model and the three newmodels which are the subject of the Wind Farms Application in this matter, and the application of the currentminimum setback requirements demonstrate that the Board must complete more than the cursory reviewthat the Wind Farm urges the Board to undertake.


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turbines certified in Case No. 13-990-EL-BGN violate Ohios minimum setback

requirements.

Additionally, the Wind Farm has failed to present, for the Boards consideration,

any showing that GNUs discovery is impermissible relative to the potential construction,

operation, and integration of some combination of the three new turbine models with the

one turbine model that was before the Board in Case No. 13-990-EL-BGN. The Wind

Farm did not attach GNUs discovery requests as required by the Boards rules. It did not

specifically address any of GNUs discovery requests and explain how they warrant the

issuance of a protective order. Under such circumstances, the issuance of a protective

order is not warranted.

The appropriateness of GNUs discovery requests is further confirmed by the Wind

Farms Application. The Wind Farms Application shows that some of the new turbine

models that the Wind Farm wants to add, in some unspecified way, to its development

menu are bigger, noisier, generate more shadow flicker,24and will operate more often

than the one turbine model addressed in Case No. 13-990-EL-BGN.25 Thus, discovery

related to the impact of the deployment of some unspecified combination of the four

turbine models is reasonably calculated to lead to the discovery of admissible evidence.

Accordingly, GNUs discovery is proper and the Motion for a Protective Order

should be denied.

24Application at 1-2.

25Id.at 1.


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III. CONCLUSION

The Wind Farm has presented the Board with a Motion for a Protective Order that

is procedurally and substantively unwarranted. The Wind Farm has failed to demonstrate

that GNUs discovery is not reasonably calculated to lead to the discovery of admissible

evidence. The Wind Farm has failed to allege or demonstrate that GNUs discovery is

designed to annoy, embarrass, oppress, or cause the Wind Farm any undue burden or

expense. The Wind Farm failed to attach to its Motion for a Protective Order copies of

the discovery requests that are the subject for its Motion for a Protective Order. The Wind

Farm failed to attach to its Motion for a Protective Order the required Affidavit of Counsel.

The Wind Farm failed to follow the process required by the Board to request the Board

issue an expedited ruling. The failure to satisfy any one of these items is cause enough

for the Board to deny the Motion for a Protective Order. The cumulative failure to meet

any of these requirements demonstrates the complete lack of merit upon which the Motion

for a Protective Order is founded.

For these reasons, the Board should deny the Wind Farms request for an issuance

of a protective order.

Respectfully submitted,

/s/ Samuel C. RandazzoSamuel C. Randazzo(Counsel of Record) (Reg. No. 0016386)Scott E. Elisar (Reg. No. 0081877)

MCNEES WALLACE &NURICK LLC21 East State Street, 17THFloorColumbus, OH 43215Telephone: (614) 469-8000Telecopier: (614) [email protected]@mwncmh.com


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9886874v3 1

BEFORE

THE OHIO POWER SITING BOARD

In the Matter of the Application of 6011 Greenwich

Windpark, LLC for an Amendment to its Certificate toInstall and Operate a Wind-Powered Electric

Generation Facility in Huron County, Ohio

)

))

)

Case No. 15-1921-EL-BGA

6011 GREENWICH WINDPARK, LLC REPLY TO

GREENWICH NEIGHBORS UNITEDS FIRST SET OF INTERROGATORIES AND

REQUESTS FOR PRODUCTION OF DOCUMENTS

Pursuant to Ohio Administrative Code (OAC) Rules 4906-2-17 and 4906-2-19, 6011

Greenwich Windpark, LLC (Greenwich) by and through its counsel, hereby responds to the

First Set of Interrogatories and Requests for Production of Documents of (the Discovery

Requests) of Greenwich Neighbors United (GNU) in the above-captioned proceeding.

GENERAL OBJECTIONS

Greenwichs responses to the Discovery Requests are being provided subject to, and

without waiver of, the general objections stated below, any specific objections posed in response

to an individual interrogatory, document request, or request for admission, and any general

objections not expressly set forth herein. The general objections listed below are hereby

incorporated by reference into the individual response to the Discovery Requests. Greenwich

hereby fully preserves all of its objections as well as the use of its responses to the Discovery

Requests for any purpose whatsoever.

1. Greenwich objects to and declines to respond to each and every interrogatory or request

for the production of documents by GNU to the extent that the requests seek information that

violates the rules of evidentiary simplicity and reasonable intelligence. See Penn Cent. Transp.

Co. v. Armco Steel Corp., 27 Ohio Misc. 76, 77 (Montgomery County Ct. C.P. 1971). The

APPENDIX A


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function of interrogatories is to pose simple questions relating to a particular subject that may be

answered by a brief categorical statement. See Stai v. The Kroger Co., Case No. 82AP-816, 1983

Ohio App. LEXIS 15659 (Ohio Ct. App. June 30, 1985).

2. Greenwich objects to each and every interrogatory or request for the production of

documents to the extent the requests are outside the scope of this proceeding and not reasonably

calculated to lead to the discovery of admissible evidence. OAC Rule 4906-2-14(B).

3. Greenwich objects to any and all Discovery Requests that are vague, ambiguous, overly

broad, and otherwise not susceptible to meaningful response. OAC Rule 4906-2-14(B).

4. Greenwich objects to any and all Discovery Requests to the extent that such requests

purport to or impose upon Greenwich any obligations broader than those set forth in the rules of

the Ohio Power Siting Board (OPSB or Board) or otherwise permitted by law.

5. Greenwich objects to any and all Discovery Requests to the extent that such requests seek

or purport to require the disclosure of information or documents protected by the attorney-client

privilege, attorney work product doctrine, joint defense privilege, or any other applicable privilege

or doctrine. Such responses as may hereafter be given shall not include any information protected

by such privileges or doctrines, and the inadvertent disclosure of such information shall not be

deemed to be a waiver of any such privilege or doctrine. OAC Rule 4906-2-14(B).

6. Greenwich objects to any and all Discovery Requests to the extent that they improperly

seek or purport to require access to confidential, competitively sensitive, and/or proprietary

business information and trade secrets belonging to Greenwich. The furnishing of responses to

these Discovery Requests is not intended, nor should it be construed, to waive Greenwichs right

to protect from disclosure certain documents and information containing confidential or

proprietary trade secrets or business information. Greenwich reserves the right to redact from the


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documents it produces or information it provides any confidential or proprietary business

information or trade secrets not relevant to the subject matter of this proceeding.

7. Greenwich objects to any and all Discovery Requests to the extent that they improperly

seek or purport to require Greenwich to provide documents and information not in Greenwich's

possession, custody, or control.

8. Greenwich objects to any and all Discovery Requests that either individually or

collectively are oppressive, or would require an undue burden or expense to respond.

9. Greenwich objects to any and all Discovery Requests to the extent that such requests are

not limited to any stated time period, or such requests identify a stated period of time that is longer

than is relevant for purposes of this docket, as such discovery is unduly broad and overly

burdensome.

10. Greenwich objects to any interrogatories, which are duplicative of others, or overlapping,

the result of which is that information covered by one interrogatory is also covered by another

interrogatory, thereby causing an oppressive and undue burden on Greenwich to respond.

11. Greenwich reserves its right to challenge the relevancy, materiality, and admissibility at

trial, or in any subsequent proceeding, of any information it produces in response to the Discovery

Requests.

12. Greenwich's responses will be based on information known to it at the time it responds.

Greenwich reserves its right to amend and/or supplement its responses if it learns of new

documents or information relevant hereto, through discovery or otherwise.

13. All responses of Greenwich to the Discovery Requests are made subject to and without

waiving these objections.


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INTERROGATORIES

1-1 Has Greenwich signed an Interconnection Service Agreement (ISA) with PJM

Interconnection, LLC (PJM)?

RESPONSE: No, Greenwich has not signed an Interconnection Service Agreement

(ISA) with PJM Interconnection, LLC (PJM).

Response prepared by Counsel.

1-2 If the answer to interrogatory 1-1 is no, when does Greenwich expect to sign the ISA?

RESPONSE: The Project expects to sign the ISA within the next 90 days.


1-3 Has Greenwich signed a Wholesale Market Participation Agreement (WMPA) with PJM?

RESPONSE: Greenwich objects that this interrogatory seeks information that is

irrelevant to the subject matter of this proceeding and not reasonably calculated to

lead to the discovery of admissible evidence; turbine technology changes will make no

difference whatsoever on this subject-matter.


1-4 If the answer to interrogatory 1-3 is no, when does Greenwich expect to sign a WMPA?

RESPONSE: See Response to Interrogatory No. 1-3.


1-5 Does Greenwich agree that PJMs interconnection analysis evaluated adherence with

applicable reliability criteria for summer peak conditions in 2015?



1-6 Has Greenwich submitted an interconnection request to PJM that would cause PJM toevaluate interconnection and reliability implications based on the additional turbine types

identified in the application submitted in this proceeding?

RESPONSE: No, the Project has not submitted such an interconnection request.



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1-7 If the answer to interrogatory 1-6 is no, explain why no such request has been submitted toPJM.

RESPONSE: Project submitted a notice of a scope change to review a change in

turbine technology to PJM.


1-8 With regard to pages 1 and 2 of the report issued by PJM in response to Greenwichs

interconnection request (PJM X3-023, http://www.pjm.com/pub/planning/project-

queues/feas_docs/x3023_fea.pdf#search=%22X3-023%22), what is Greenwichs method ofresolving the potential overload on the Boughtonville (Firelands COOP) line?

RESPONSE: RESPONSE: See Response to Interrogatory No. 1-3.


1-9 With regard to pages 1 and 2 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), will Greenwich install the SCADA system

recommended by American Electric Power (AEP) and regarding the potential overload

on the Boughtonville (Firelands CO-OP) line?



1-10 With regard to page 2 of the report issued by PJM in response to Greenwichs

interconnection request (PJM X3-023), by what method will Greenwich eliminate thepotential overload of the Brookside - Howard 138 kV FE-AEP tie line?

RESPONSE: RESPONSE: See Response to Interrogatory No. 1-3.



interconnection request (PJM X3-023), has AEP and FirstEnergy (FE) provided

Greenwich with a solution for resolving the potential overload of the Brookside - Howard138 kV FE-AEP tie line?




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1-12 With regard to page 2 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), by what method will Greenwich resolve the

potential overload of the Bridgeville-Chandlersville 138 kV line?




interconnection request (PJM X3-023), by what method will Greenwich resolve the

potential overload of the Bethel Church West Dover 138 kV line?



1-14 With regard to page 2 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Chandlersville Philo 138 kV line?





potential overload of the Hillview - Newcomerstown 138 kV line?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Newcomerstown South Coshocton 138 kV line?





potential overload of the Broken Sword Nevada (North Central CO-OP) 69 kV line?



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interconnection request (PJM X3-023), will Greenwich install the SCADA system

recommended by AEP and regarding the potential overload on the Broken Sword Nevada(North Central CO-OP) 69 kV line?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Sycamore Tap East Tiffin 69 kV line?



1-20 With regard to page 3 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023) and the potential overload of the Sycamore Tap

East Tiffin 69 kV line, will Greenwich install the SCADA system recommended by AEP?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Carrothers St. Stephen (North Central CO-OP) 69 kV line?




interconnection request (PJM X3-023), and the potential overload of the Carrothers St.Stephen (North Central CO-OP) 69 kV line, will Greenwich install the SCADA system

recommended by PJM?




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potential overload of the Crestline Howard 69 kV line?




interconnection request (PJM X3-023), and the potential overload of the Crestline

Howard 69 kV line, will Greenwich install the SCADA system recommended by PJM?



1-26 With regard to page 4 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Crestline North Robinson 69 kV line?





potential overload of the North Robinson West Galion Tap 69 kV line?




interconnection request (PJM X3-023) and the potential overload of the North Robinson West Galion Tap 69 kV line, will Greenwich install the SCADA system recommended by

PJM?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Academia Apple Valley 138 kV line?


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interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Apple Valley North Lexington 138 kV line?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Fostoria Central Melmore 138 kV line?




potential overload of the Greenlawn Tiffin 138 kV line?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Howard North Lexington 138 kV line?




interconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Brookside Howard 138 kV line?




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potential overload of the Millwood North Bellville 138 kV line?





potential overload of the Chatfield South Tiffin 138 kV line?



1-37 With regard to page 6 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), by what method will Greenwich resolve thepotential overload of the Howard North Bellville 138 kV line?





potential overload of the General Electric Tiffin Tiffin Tap 69 kV line?




interconnection request (PJM X3-023) and the potential overload of the General ElectricTiffin Tiffin Tap 69 kV line, will Greenwich install the SCADA system suggested by

PJM?




interconnection request (PJM X3-023) and the potential overload of the General ElectricTiffin Tiffin Tap 69 kV line, does the General Electric Tiffin 69 kV station serve a

specific customer or customers?


22/46

9886874v3 11



1-41 If the answer to interrogatory 1-40 is yes, has Greenwich notified the specific customer orcustomers of the potential overload?




interconnection request (PJM X3-023), by which method will Greenwich resolve thepotential overload of the General Electric Tiffin Maule Road 69 kV line?



1-43 With regard to page 7 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), by which method will Greenwich resolve the

potential overload of the Greely Tiffin Center 69 kV line?




interconnection request (PJM X3-023) and the potential overload of the Greely TiffinCenter 69 kV line, will Greenwich install the SCADA system suggested by PJM?




interconnection request (PJM X3-023), by which method will Greenwich resolve thepotential overload of the Riverview - Tiffin Tap 69 kV line?




23/46

9886874v3 12


potential overload of the Tiffin Center Maule Road 69 kV line?




interconnection request (PJM X3-023), by which method will Greenwich resolve the

potential overload of the Bucyrus Center Broken Sword 69 kV line?



1-48 With regard to page 7 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023), by which method will Greenwich resolve thepotential overload of the Broken Sword Nevada (North Central CO-OP) 69 kV line?



1-49 With regard to pages 7 and 8 of the report issued by PJM in response to Greenwichs

interconnection request (PJM X3-023) and the potential overload of the Broken Sword

Nevada (North Central CO-OP) 69 kV line, will Greenwich install the SCADA system

suggested by PJM?




potential overload of the Nevada (North Central CO-OP) Upper Sandusky 69 kV line?




interconnection request (PJM X3-023) and the sag check associated with the Academia-Apple Valley 138 kV line, has the sag check been performed?


24/46

9886874v3 13



1-52 If the answer to interrogatory 1-51 is yes, by what method will Greenwich resolve the

problem regarding the Academia Apple Valley 138 kV line?




interconnection request (PJM X3-023) and the sag check associated with the Apple Valley

North Lexington 138 kV line, has the sag check been performed?



1-54 If the answer to interrogatory 1-53 is yes, by what method will Greenwich resolve the

problem regarding the Apple Valley North Lexington 138 kV line?



1-55 With regard to page 19 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023) and the potential thermal violation associated with

the CARROTHR-ST STPH8 69 kV line, by what method will Greenwich resolve the

potential thermal violation?




interconnection request (PJM X3-023) and the potential thermal violation associated with

the TIFFIN T-RIVERVIE 69 kV line, by what method will Greenwich resolve the potentialthermal violation?




25/46

9886874v3 14

1-57 With regard to page 20 of the report issued by PJM in response to Greenwichsinterconnection request (PJM X3-023) and the potential thermal violation associated with

the ST STPH8-BLOOMVL 69 kV line, by what method will Greenwich resolve the





interconnection request (PJM X3-023) and the potential thermal violation associated withthe NEVADA8-U SANDSK 69 kV line, by what method will Greenwich resolve the





interconnection request (PJM X3-023) and the potential thermal violation associated with

the South Tiffin-Airco (North Central Co-Op) 138 kV line, by what method will Greenwichresolve the potential thermal violation?



1-60 With regard to the Greenlawn relay thermal limit engineering study identified in page 27 ofthe report issued by PJM in response to Greenwichs interconnection request (PJM X3-

023), has the engineering study been completed?



1-61 Is the PJM report available via the Internet at http://www.pjm.com/pub/planning/project-

queues/feas_docs/x3023_fea.pdf#search=%22X3-023%22 a true and accurate copy of thereport that PJM issued in response to Greenwichs request?

RESPONSE: Yes.


1-62 Has Greenwich obtained any waivers from the minimum setback requirements pursuant to a

procedure which the Ohio Power Siting Board (OPSB) has specified by rule?


26/46

9886874v3 15



1-63 Have all owners of property adjacent to the wind farm property waived application of theminimum setback requirements?



1-64 Has Greenwich finalized a Phase 1 cultural resources survey program for archeological

work at the turbine locations, access roads, substations, collection lines and laydown areas(see certificate condition 12)?



1-65 Has Greenwich performed any studies to identify ambient nighttime noise levels other thanthe study submitted in OPSB Case No. 13-990-EL-BGN?

RESPONSE: Greenwich did not perform an additional study to identify ambient

nighttime noise levels. The noise level requirements were established by the Ohio

Power Siting Board in Case No. 13-990-EL-BGN, and the Project will continue to

adhere to those requirements.


1-66 Has Greenwich obtained the land or land rights that may be needed to expand the AEP

Willard substation?




27/46

9886874v3 16

REQUESTS FOR PRODUCTION

1-67 Provide a copy of all discovery requests and OPSB Staff data requests received by

Greenwich in the above-captioned proceeding and Greenwichs responses to the discovery

requests and OPSB Staff data requests.

RESPONSE: Greenwichs response to this interrogatory is attached.


1-68 Provide a copy of any studies that identify ambient nighttime noise levels other than thestudy submitted to the OPSB in Case No. 13-990-EL-BGN.

RESPONSE: Greenwich objects that this Request for Production because it seeks

information that is irrelevant to the subject matter of this proceeding and not

reasonably calculated to lead to the discovery of admissible evidence; turbine

technology changes will make no difference whatsoever on this subject-matter.


1-69 Provide a copy of each setback waiver that Greenwich has obtained from each propertyowner adjoining the wind farm property.






1-70 Provide a copy of each communication between Greenwich and the Ohio Farm BureauFederation (OFBF) that is related to OPSB Case No. 13-990-EL-BGN or Case No. 15-

1921-EL-BGA.






1-71 For each turbine type identified in the application filed in this proceeding, provide the

manufacturers most current safety manual.

RESPONSE: This document is publicly available in the amendment application

submitted in this proceeding.


28/46

9886874v3 17


1-72 Provide a copy of each communication between Greenwich and the OPSB Staff (other than

data requests provided in response to request 1-67).

RESPONSE: In the above-captioned proceeding, there are no additional

communications between Greenwich and OPSB Staff.


1-73 Provide a copy of each communication Greenwich has received from PJM.

RESPONSE: Greenwichs response to this interrogatory is attached.


1-74 Provide a copy of each communication Greenwich has received from AEP regarding the

proposed wind farm identified in OPSB Case No. 13-990-EL-BGN or OPSB Case No. 15-

1921-EL-BGA.

RESPONSE: Greenwich has not received any communications from AEP.


1-75 Provide a copy of each communication Greenwich has received from FE regarding the

proposed wind farm identified in OPSB Case No. 13-990-EL-BGN or OPSB Case No. 15-1921-EL-BGA.

RESPONSE: Greenwich has not received from any communications from

FirstEnergy.



29/46

9886874v3 18

Respectfully submitted on behalf of6011 GREENWICH WINDPARK, LLC

Sally W. Bloomfield (Reg. No. 0022038)

Dylan F. Borchers (Reg. No. 0090690)BRICKER & ECKLER LLP

100 South Third Street

Columbus, OH 43215-4291

Telephone: (614) 227-2368; 227-4914Facsimile: (614) 227-2390

E-Mail: [email protected]

[email protected]


30/46

9886874v3 19

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of the foregoing Response been served upon

the following parties listed below by electronic mail, this 10th

day of February 2016.

Sally W. Bloomfield

Samuel RandazzoScott Elisar

McNees, Wallace & Nurick LLC

21 East State Street, 17th

FloorColumbus, OH 43215

[email protected]

[email protected]


31/46

1

Monica Jensen

From: Monica JensenSent: Thursday, January 28, 2016 1:13 PMTo: 'Conway, Andrew'Subject: FW: follow up

Andrew

second

original

e

mail

forwarded

please

confirm

receipt

and

use

of

document

Best,

Monica

From:Calvin Cooper [mailto:[email protected]]Sent:Wednesday, May 13, 2015 10:25 AM

To:Monica JensenSubject:RE: follow up

Monica, TheywereawareofthesituationsoIsurehopeso!

From:[email protected]

Date:Wed,13May201508:23:000400

Subject:RE:followup

To:[email protected]

IamassumingtheyincludedtheOPSBsetbacksfromoursites

From:Calvin Cooper [mailto:[email protected]]

Sent:Tuesday, May 12, 2015 3:19 PMTo:Monica Jensen

Subject:RE: follow up

HiMonica, Wehavesurveyedcenterline. Ihavenotgotresultsyet. Ishouldhaveanideainthenext2or3

weeks.Iwillletyouknowassoonastheytellme.


Date:Tue,12May201513:15:590400

Subject:RE:followup


HiCalvin,

ThoughtIwould

check

in

and

see

what

is

up

on

your

route,

timing,

OPSB

application

etc.

Best,

Monica

From:[email protected][mailto:[email protected]] On Behalf OfCalvin CooperSent:Monday, April 06, 2015 1:26 PMTo:Monica JensenSubject:RE: follow up

Response to Interrogatory 1-67


32/46

2

HiMonica,IgaveinformationtomySupervisortoday. Theymaycallyouintime. Thanksforyourhelp.


Date:Mon,6Apr201508:19:400400

Subject:followup


Dylan F. BorchersBricker & Eckler LLP | 100 South Third Street | Columbus, OH 43215Direct Dial 614.227.4914 | [email protected] | v-card | www.bricker.comThink green please print only if necessary.

Calvin Thanks for meeting last Thursday Hopefully your GIS/Map guy can send me your shape files of thecurrent proposed route. Not sure how we should continue to interface on the route? Especially through theturbine/ substation area?

Above is the contact info for the best OPSB attorney firm. If your permitting department has not contactedthem, I encourage them to do so - asap. As I shared before 2 years to get through the process for me from myfirst meeting with the OPSB. Bricker & Eckler will make it as painless as possible. $$ well spent.

Hope you had a fine Easter !

Best,Monica

Monica Jensen

Vice President, Development | Windlab Developments USA Ltd927 Wing Street | Plymouth, Michigan 48170 | United StatesOffice: +1-734-335-6219 | Mobile: +1-734-787-9396 | [email protected] | www.windlab.com

CONFIDENTIALITY : This e-mail and any attachments are confidential and may be privileged. If you are not a named recipient,please notify the sender immediately and do not disclose the contents to another person, use it for any purpose or store or copy theinformation in any medium.




33/46

1

Monica Jensen

From: Monica JensenSent: Thursday, January 28, 2016 1:11 PMTo: 'Conway, Andrew'Subject: FW: maps of Greenwich

Attachments: 20140305 Greenwich__Lease_Tracker MJ.xlsx

Andrew

Ihave

just

forwarded

the

original

email

to

you

please

let

me

know

ifthis

works.

Best,

Monica

From:Monica Jensen [mailto:[email protected]]Sent:Tuesday, March 31, 2015 9:32 AMTo:Calvin CooperSubject:RE: maps of Greenwich

Hereyougosorryforthedelay

From:[email protected][mailto:[email protected]] On Behalf OfCalvin CooperSent:Monday, March 30, 2015 6:15 PMTo:Monica JensenSubject:RE: maps of Greenwich

HiMonica, DidYousendthelistoflandowners?IfyoudidIcannotfindit. Pleaseletmeknow.


Date:

Tue,

24

Mar

2015

11:03:08

0400

Subject:RE:mapsofGreenwich


Resending,pleaseseebelow.

From:Monica Jensen [mailto:[email protected]]Sent:Monday, March 23, 2015 1:27 PMTo:'[email protected]'Subject:maps of Greenwich

Calvin

AttachedisagroupofmapsthatweresubmittedtotheOhioPowerSitingBoard.

Alsoshapefilesoftheproject.

NotethesubstationonSeidelsisdepictedontheattachedmapaswell.

IwillbeinNorwalk/Greenwich/Willardtomorrowwouldyouhavetimetomeet?


35/46

1

Monica Jensen

From: Monica JensenSent: Wednesday, December 23, 2015 8:23 AMTo: [email protected]; [email protected]: Erin WiedowerSubject: RE: Manufacturer Contact information

Grant,Andrew

&

Erin,

IwouldliketointroduceErinWiedower,GoldwindUSA. Shewillbeabletoprovideinformationandanswerany

questionsyoumayhaveinregardstotheGoldwindturbine. Herdirectphoneis9794929547,GoldwindUSAis

locatedinChicago(centraltime).

Pleaseletmeknowifyouneedanyfurtherassistance.

Best,

Monica Jensen

Vice President, Development | Windlab Developments USA Ltd927 Wing Street | Plymouth, Michigan 48170 | United States

Office: +1-734-335-6219 | Mobile: +1-734-787-9396 | [email protected] | www.windlab.com

From:[email protected][mailto:[email protected]]

Sent:Wednesday, December 23, 2015 8:05 AM

To:Monica JensenSubject:FW: Manufacturer Contact information

HiMonica,

Couldyoupleaseprovidetheinformationrequestedbelow?HappyHolidays!

ThankYou,

Grant

GrantZeto

OhioPower

Siting

Board

UtilitySpecialist

(614)6447743

OPSB.ohio.gov

_

From:Conway, AndrewSent:Tuesday, December 22, 2015 4:22 PMTo:Zeto, GrantSubject:Manufacturer Contact information


36/46

2

WouldGreenwichWindpark,pleaseprovidecontactinformationfortheGoldwindturbinemanufacturer?

Thanks.

Sincerely,

AndrewConway,P.E.

PublicUtilities

Commission

of

Ohio

RatesandAnalysisDepartment

Siting,Efficiency,andRenewableEnergyDivision

EngineeringSpecialist,Siting

(614)4665732

Email:[email protected]

PUCO.ohio.gov

_

Thismessageandanyresponsetoitmayconstituteapublicrecordandthusmaybepubliclyavailabletoanyonewho

requestsit.


37/46

1

Monica Jensen

From: [email protected]: Monday, January 25, 2016 10:40 AMTo: Monica JensenCc: [email protected]: RE: Greenwich Windpark / Kinder Morgan Utopia pipeline

Yes,

that

works.

From:Monica Jensen [mailto:[email protected]]Sent:Monday, January 25, 2016 10:23 AMTo:Conway, AndrewCc:Zeto, GrantSubject:Re: Greenwich Windpark / Kinder Morgan Utopia pipeline

3:00 pm today - will that work for you?

On Monday, January 25, 2016, [email protected] wrote:

Monica -

What time today can you call us to briefly discuss this issue?

My phone number is (614) 466-5732

-Andrew Conway

From:Conway, AndrewSent:Friday, January 22, 2016 1:27 PMTo:'Monica Jensen';[email protected]:Zeto, GrantSubject:RE: Greenwich Windpark / Kinder Morgan Utopia pipeline

Thanks. We can wait to discuss on Monday.

-Andrew Conway


38/46

2

From:Monica Jensen [mailto:[email protected]]Sent:Friday, January 22, 2016 12:26 PMTo:Conway, Andrew;[email protected]:Zeto, GrantSubject:RE: Greenwich Windpark / Kinder Morgan Utopia pipeline

Andrew,

My apologies for the delayed reply I am currently on vacation through the end of the week, also John is nolonger with Windlab.

Back in March of this year I met with the land acquisition person (his name escapes me right now), at the timeof our meeting, we discussed where all the Greenwich towers and infrastructure would be located, as well as the

OPSB guidelines and requirements. Where the pipeline was located it did not conflict with any tower locations. After the meeting I provided shape files as well for their use in planning. Also, I gave the setback guidelinesrequired for our project as well as contact information for the OPSB, as I surmised they would need to gothrough the OPSB process as well for permitting. I as much said to him, this project is permitted and he isrequired to work around our permitted project and abide by the OPSB requirements.

I left a VM for you this morning as well and we can speak on Monday.

Best,

Monica

Monica Jensen

Vice President, Development | Windlab Developments USA Ltd

927 Wing Street | Plymouth, Michigan 48170 | United States

Office: +1-734-335-6219 | Mobile: +1-734-787-9396 | [email protected] | www.windlab.com


39/46

3

From:[email protected][mailto:[email protected]]Sent:Friday, January 22, 2016 9:58 AMTo:[email protected]:[email protected]; [email protected]:Greenwich Windpark / Kinder Morgan Utopia pipelineImportance:High

John (or Monica)

Left you a voicemail message. My name is Andrew Conway, and I am an engineer with the Ohio Power SitingBoard. Our duties include reviewing the location of proposed energy infrastructure (including wind farms) inour State. Our website is: http://www.opsb.ohio.gov/

As you know we are investigating the proposed Greenwich Windpark amendment (Windlab Developments)which is in the vicinity of the proposed Kinder Morgan Utopia pipeline project.

From earlier conversations with Monica Jensen, it is my understanding that Greenwich Windpark has met withKinder Morgan, that no conflicts with the pipeline are anticipated, and that the pipeline is at least 543 feet fromthe nearest turbine which is 1.1 times the tip height of the tallest model.

Would you please confirm?

Thanks.

Sincerely,

Andrew Conway, P.E.

Ohio Power Siting Board

Engineering Specialist, Siting

(614) 466-5732


40/46

4

Email: [email protected]

OPSB.ohio.gov

_

This message and any response to it may constitute a public record and thus may be publicly available to anyone who

requests it.


--*Monica Jensen* | North AmericaVice President, Development3692 W. Liberty RoadAnn Arbor, MI 48103

Mobile: 734-787-9396Office: 734-222-9463 X2Fax: 734-761-8133www.windlab.com



41/46

1

Monica Jensen

From: Monica JensenSent: Tuesday, February 02, 2016 2:10 PMTo: '[email protected]'Subject: RE: follow up

Attachments: Greenwich 2.pdf; greenwich1.pdf

Andrew,

Sorryforthedelayingettingbacktoyou. UnfortunatelyIfoundmyselfwithstrepanda102feveryesterday.

AttachedaretwomapsIacquiredfromKinderMorgan. Theyhavechangedtheroutetoextendthesetbacksfrom

turbines#18,#17and#16. Whiletheydidnotsupplymewithgisdatapointsaccordingtotheirkeyitlookslikeboth

infrastructurescancoexsistwiththesetbackrequirements. Therouteinred,withdottedlinesistheoriginalroute

therouteinpinkisthenewroute.

Ihaveaskedfortheshapefilesforourconstructionplanningaswell. OnceIreceiveIwillshare.

Best,

Monica

From:[email protected][mailto:[email protected]]

Sent:Wednesday, January 27, 2016 5:21 PMTo:Monica Jensen

Cc:[email protected]:RE: follow up

Monica

Unfortunately,Iamunabletoviewtheseemailchains. Wouldyoupleasesendthroughanotherformat(e.g.copyinto

MSWord,scan,orfax)?

Thanks.

Sincerely,

AndrewConway,P.E.PublicUtilitiesCommissionofOhio

RatesandAnalysisDepartment

Siting,Efficiency,andRenewableEnergyDivision

EngineeringSpecialist,

Siting

(614)4665732

Fax:(614)7528353

Email:[email protected]

PUCO.ohio.gov

_

Thismessageandanyresponsetoitmayconstituteapublicrecordandthusmaybepubliclyavailabletoanyonewho

requestsit.


42/46

2

From:Monica Jensen [mailto:[email protected]]

Sent:Tuesday, January 26, 2016 4:09 PM

To:Conway, AndrewCc:Zeto, GrantSubject:FW: follow up

Andrew/

Grant,

AttachedaretwoemailchainsthatchroniclesmycorrespondencewithCalvinCooper,representativeoftheUtopia

Pipeline. IneverheardbackfromMr.Cooper,howeverasfollowup,tomorrowIammeetingwithAlPowersattheir

officetoactuallylookattheirmapsinperson. Willkeepyouposted.

Best,

Monica

Monica Jensen

Vice President, Development | Windlab Developments USA Ltd927 Wing Street | Plymouth, Michigan 48170 | United StatesOffice: +1-734-335-6219 | Mobile: +1-734-787-9396 | [email protected]|www.windlab.com

, use it for any purpose or store or copy the information in any medium.



43/46

GNU interrogatory1-73.txtFrom: Hay, Joseph S.Sent: Thursday, January 14, 2016 5:07 PMTo: Monica JensenSubject: RE: 2015GVTFV8PC22BG - Impact Study Submission - X3-023 - ModelCheck - deficienciesAttachments: X3-023 (DRAFT) South Greenwich-Willard 69 kV Facilities Study Report

011416 .pdf

Follow Up Flag: Follow upFlag Status: Flagged

Hi Monica,

Attached is a Draft of the final X3-023 Facilities Study Report. I have drafted theInterconnection ServiceAgreement (ISA) and Interconnection Construction Service Agreement (ICSA), andforwarded to our legaldepartment for their review. I calculated a security of $2,768,684 which will berequired with theexecuted ISA. You will have 60 days to execute the ISA and 90 days to execute theICSA. The

instructions for executing the agreements will be in the cover letter. I expect toissue these before theend of the month.

The turbine swap will need to be handled as a scope change during the constructionphase. I need youto confirm that the Windlab is definitely switching to the Goldwind Turbines beforethe analysis teamswill determine the mitigations, if any, that will be required to accommodate theturbine change.

Please feel free to contact me with any questions or comments regarding this report.

Regards,

JoeJoseph HaySenior Engineer, Interconnection Projects

(610) 666-4265 | C: (610)635-6571 | [email protected] Interconnection | 2750 Monroe Blvd. | Audubon, PA 19403

From: Monica Jensen [mailto:[email protected]]Sent: Thursday, October 08, 2015 2:25 PMTo: Hay, Joseph S.Subject: RE: 2015GVTFV8PC22BG - Impact Study Submission - X3-023 - Model Check -deficiencies

External Email! Think before clicking links or attachments.

Joe,

Thanks for the update, greatly appreciate. We are trying to COD this by Dec 2016.Is there any way wecould see a draft ISA my thought is the selection of turbine is not critical tothat? Obviously we wouldlike get the CSA executed as well. I believe the draft Facility Study had 11 monthsto completion forconstruction.

Page 1

Response to Interrogatory 1-73


44/46

GNU interrogatory1-73.txtIt would be great to see any draft type for pre-cursory review.

Hope you can help?

Monica

Page 2


45/46

{C49379:2 }

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing Greenwich Neighbors Uniteds

Memorandum Contra to 6011 Greenwich Windpark, LLCs Motion for a Protective Order

has been served via electronic mail upon the following parties of record this 12 thday of

February 2016.

/s/ Samuel C. RandazzoSamuel C. Randazzo

Sally W. BloomfieldDylan BorchersBricker & Eckler LLP100 South Third StreetColumbus OH [email protected]@bricker.com

ATTORNEYS FOR 6011GREENWICHWINDPARK,LLC

Chad A. Endsley (0080648)Chief Legal CounselLeah F. Curtis (0086257)

Amy M. Milam (0082375)Ohio Farm Bureau Federation280 North High Street, P.O. Box 182383Columbus, OH [email protected]@[email protected]

ATTORNEYS FOR THE OHIO FARM BUREAUFEDERATION

William L. WrightAssistant Attorney GeneralChief, Public Utilities SectionOffice of the Attorney General180 East Broad Street, 6thFloorColumbus, OH [email protected]

ATTORNEY FOR THE STAFF OF THE OHIOPOWER SITING BOARD

Bryce McKenneyAttorney ExaminerOhio Power Siting Board180 East Broad StreetColumbus, OH [email protected]

ATTORNEY EXAMINER


46/46

This foregoing document was electronically filed with the Public Utilities

Commission of Ohio Docketing Information System on

2/12/2016 3:13:36 PM

in

Case No(s). 15-1921-EL-BGA

Summary: Memorandum Contra to 6011 Greenwich Windpark, LLCs Motion for a ProtectiveOrder electronically filed by Mr. Samuel C. Randazzo on behalf of Greenwich NeighborsUnited