20240514Petition to Intervene.pdf

RECEIVED
2024 May 14, 1:21 PM
IDAHO PUBLIC
UTILITIES COMMISSION
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
HOLLAND&HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-24-16
COMPANY'S APPLICATION FOR A )
CERTIFICATE OF PUBLIC CONVENIENCE ) PETITION TO INTERVENE
AND NECESSITY FOR THE BOISE BENCH ) OF MICRON TECHNOLOGY, INC.
BATTERY STORAGE FACILITY )
Micron Technology, Inc. ("Micron"or"Intervenor"),pursuant to the Commission's Rules
of Procedure 71 through 74,1 hereby petitions the Commission for leave to intervene and to appear
and participate in this proceeding as a party, and as grounds therefore states:
1. The name and address of this Intervenor is:
Micron Technology, Inc.
c/o Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland&Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
Idaho Admin.Code 31.01.01.071—.074.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
IPC-E-24-16

Copies of all pleadings, production requests, production responses, Commission orders,
and other documents should be provided to:
Jim Swier Austin Rueschhoff
Micron Technology, Inc. Thorvald A. Nelson
8000 South Federal Way Austin W. Jensen
Boise, ID 83707 Holland&Hart, LLP
[e-mail] 555 17th Street, Suite 3200
Denver, CO 80202
[phone]
Fax: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
2. Micron receives electric utility services from Idaho Power Company ("Idaho
Power")as a Special Contract customer. Micron is Idaho Power's single largest customer. Micron
also participates in the Idaho Power Integrated Resource Plan Advisory Council ("IRPAC"). In
this proceeding, Idaho Power seeks a Certificate of Public Convenience and Necessity ("CPCN")
to acquire the Idaho Power-owned Boise Bench battery storage facility,providing 150 MW of new
dispatchable energy storage and operating capacity. Idaho Power asserts that the battery storage
project is necessary to continue to provide reliable and adequate electric service to Idaho Power
Customers starting in the summer of 2026 and into the future.
3. As a large customer, Micron has an interest in ensuring Idaho Power's electric
service is reliable and rates are just and reasonable. Additionally, as a member of IRPAC,Micron
has an interest in Idaho Power's resource planning and selection and the types of electric resources
that are used to serve Micron. The Boise Bench battery storage facility may have a significant
impact on Idaho Power's future rates for electric service and service reliability. Therefore, Micron
has a direct and substantial interest in this proceeding.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
IPC-E-24-16

4. Micron intends to participate herein as a party, and if necessary, to introduce
evidence, cross-examine witnesses, call and examine witnesses, and be heard in argument. The
nature and quality of evidence Micron will introduce is dependent upon the nature and effect of
other evidence in this proceeding.
5. Granting Micron's Petition to Intervene will not unduly broaden the issues,nor will
it prejudice any party to this case.
6. Without the opportunity to intervene, Micron would be without adequate means to
participate in this proceeding that may have a material impact on its electric service rates.
WHEREFORE,Micron Technology,Inc.respectfully requests that the Commission grant
its Petition to Intervene in this proceeding and to appear and participate in all matters as may be
necessary and appropriate; and to present evidence, call and examine witnesses,present argument
and to otherwise fully participate in this proceeding.
Respectfully submitted May 14, 2024.
HOLLAND & HART, LLP
By:
Austin Rueschhoff, ISB No. 1059
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
IPC-E-24-16

CERTIFICATE OF SERVICE
I hereby certify that on May 14, 2024, a true and correct copy of the within and foregoing
PETITION TO INTERVENE OF MICRON TECHNOLOGY, INC. IN CASE NO. IPC-E-24-16
was served in the manner shown to:
Electronic Mail
Idaho Power Company
Donovan E. Walker Timothy E. Tatum
Idaho Power Company Idaho Power Company
1221 W. Idaho Street(83702) 1221 West Idaho Street(83702)
PO Box 70 P.O. Box 70
Boise, ID 83707-0070 Boise, Idaho 83707
dwalkeraidahopower.com Telephone: [phone]
docketsgidahopower.com Facsimile: [phone]
ttatum(a�idahopower.com
Commission Staff
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A
Boise, ID 83714
secretarygpuc.idaho.gov
Micron Technology, Inc.
Jim Swier Austin Rueschhoff
Micron Technology, Inc. Thorvald A. Nelson
8000 South Federal Way Austin W. Jensen
Boise, ID 83707 Holland& Hart, LLP
jswiergmicron.com 555 17th Street, Suite 3200
Denver, CO 80202
darueschhoff khollandhart.com
tnelson(a,hollandhart.com
awj ens enghollandhart.c om
aclee(a,hollandhart.com
mamcmillen(a,hollandhart.com
s/Adele Lee
32004259_v1
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
IPC-E-24-16