20240816Micron 1-11 to IPC.pdf

RECEIVED
Friday, August 16, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
HOLLAND&HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. IPC-E-24-07
OF IDAHO POWER COMPANY TO )
INCREASE RATES FOR ELECTRIC ) MICRON TECHNOLOGY, INC.'S
SERVICE TO RECOVER COSTS ) FIRST PRODUCTION REQUESTS
ASSOCIATED WITH INCREMENTAL ) TO IDAHO POWER COMPANY
CAPITAL INVESTMENTS AND CERTAIN )
ONGOING OPERATIONS AND )
MAINTENANCE EXPENSES. )
Micron Technology, Inc. ("Micron" or"Intervenor"), by and through its counsel, Holland
& Hart LLP, submits the attached interrogatories and requests for the production of documents to
Idaho Power Company ("Idaho Power"). The following response date, definitions, and
instructions apply to the enclosed interrogatories and requests for production of documents.
In addition to the written copies provided as responses to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
RESPONSE DATE, DEFINITIONS AND INSTRUCTIONS
Please respond to these interrogatories and requests for production of documents by
September 6, 2024.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -1- August 16, 2024

DEFINITIONS
1. "Idaho Power Company," "Idaho Power," "IPC," "the Company," or "you" means Idaho
Power Company and the employees, officers, directors, agents, consultants, attorneys and
all persons acting under contractual arrangement with or acting or purporting to act on
behalf of Idaho Power.
2. "Agreement"means any contract, written or oral, or any non-contractual understanding.
3. "And/Or" will be construed disjunctively or conjunctively as necessary so that the scope
of these interrogatories is as broad as possible and includes any information which might
be constructed to be outside their scope.
4. "Communication" should be interpreted as broadly as possible to include, but not be
limited to, all forms of communication, whether written,printed, oral, pictorial, electronic
or otherwise and by any means or type whatsoever.
5. "Date" shall mean the exact day, month, and year if ascertainable, or if not the best
approximation thereof in relation to other events.
6. "Document" and "documentation" should be interpreted as broadly as possible, including
the original or any copy,regardless of origin or location, of any book,pamphlet,periodical
publication, letter, scrapbook, diary, calendar, canceled check, photograph, form,
memorandum, schedule, tax return, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other written, recorded,
transcribed, punched, taped, filmed, graphic or retrievable matter or data of any kind,
however produced or reproduced, to which you have or have had access. This definition
includes all documents which have been created and/or which reside in any type of
electronic format.
Any document that is not exactly identical to another document for any reason (such as
marginal notations or deletions) should be considered a separate document.
As to any document related to the matters addressed herein that is not currently in your
possession but that you know or believe such a document exists, you are requested to
identify and indicate to the best of your ability its present or last known location or
custodian.
7. To "describe, "detail," or "state" shall mean to relate as completely as possible each and
every act, omission, incident, event, condition, circumstance, decision, and/or thing
relating directly or indirectly to the subject of the explanation including all pertinent dates.
8. To "explain" means to make known in detail, to make clear the cause or reason of any
account for each act, omission, incident, event, condition, circumstance, decision, and/or
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -2- August 16, 2024

thing relating directly or indirectly to the subject of the explanation including all pertinent
dates.
9. Any request to "identify" or "provide" should be interpreted to mean:
a. With respect to a natural person, that person's full name, title,job description, and
business and home address. Where the identification pertains to a past period, as
to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided,
in addition,that person's title and job description as of the time of such past period.
Where the person is no longer in your employ or the employment of the group with
which such person is identified in response to any request, provide that person's
affiliate, position, home and business address, if known, or if not known, such
person's last known affiliation, position, home and business address, or portions
thereof as may be known.
b. With respect to an entity other than a natural person, that entity's name, business,
type of entity,present status and present or last known address.
C. With respect to a document,that document's title,date,author(and,if different,the
signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto,present location and
custodian,whether or not such document is in the respondent's possession,custody
or control and whether or not the document is claimed to be privileged. The final
version and each draft of each document should be identified and produced
separately. Each original and each non-identical copy (bearing marks or notations
not found on the original) of each final version and draft of each document should
be identified and produced separately.
d. With respect to a physical facility, the location of the facility, the intended purpose
of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if
applicable, and whether the facility is subject to the jurisdiction of the Idaho Public
Utilities Commission, the Federal Energy Regulatory Commission, or any other
regulatory body.
10. "Person or Entity" should be interpreted to denote, unless otherwise specified, any natural
person, firm, corporation, association, group, individual or organization of any type
whatsoever.
11. "PUC" or"Commission"means the Idaho Public Utilities Commission.
12. "Record" or "Records" includes any regulation, formal or informal, official or unofficial
memorandum, document or written preservation of any events, actions taken or rejects,
decisions and details thereof relating to the subject matter of the question and your response
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -3- August 16, 2024

including electronic data and e-mail. A copy of the original "record" is preferred; stating
the substance thereof will suffice where a copy cannot be made and is not available.
13. "Relating To" or "Related To" means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.
GENERAL INSTRUCTIONS
1. Interrogatories and requests for production must be answered with particularity and in
detail.
2. Interrogatories and requests for production must be answered separately and fully in
writing under oath within twenty-one (21) days after service in accordance with IDAPA
31.01.01.225.
3. Interrogatories and requests for production must be signed by the person upon whose
personal knowledge responses are based or who helped in any way in answering these
interrogatories and requests for production.
4. You must provide the names of any other persons upon whose personal knowledge
responses are based or who helped in any way in answering these interrogatories and
requests for production.
5. In making your answers, you must produce all relevant documents and data by attachment
or by identifying the documents which relate to your answers. You must also clearly
identify each interrogatory to which the document relates.
6. These interrogatories and requests for production are continuing in nature and in the event
any information provided in an answer is changed or supplemented by future developments
or other factors, you must file appropriate supplemental answers.
7. In answering these interrogatories and requests for production you should furnish all
information which is in your possession, custody or control including, but not limited to,
information from any files, records, or documents in the possession of your attorneys,
consultants, staff, accountants, experts, employees, former employees, and other agents.
8. These interrogatories and requests for production should be answered based on your
personal knowledge, the personal knowledge of your attorneys, consultants, staff,
accountants, experts,employees, former employees, and any other agents as appropriate or
available and with reference to the sources described above.
9. If the respondent is not a witness who has filed written direct testimony, please indicate
which of the company's witnesses will be prepared to answer these questions on the stand.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -4- August 16, 2024

10. In addition to a hard copy,please provide an electronic copy of your responses in Microsoft
Word. Where responses are prepared using spreadsheet software, please provide an
electronic copy in Microsoft Excel format.
11. If after exercising due diligence you are unable to answer any interrogatory or to produce
any document requested, you must explain your inability in detail.
12. If you object to any interrogatory or request for production, you may serve written
objections on Micron as provided in IDAPA 31.01.01.225, identifying the subject matter
objected to and stating with particularity the reasons for the objections. In addition, the
objections and the answers must be contained in separate pleadings with each clearly
identified as an objection or answer. The service of an objection will not excuse you from
answering the remaining interrogatories or responding to the remaining requests for
production for which no objection is stated.
13. If any responses to these interrogatories or requests for production have already been
provided in prior discovery in this matter, please direct Micron to the specific discovery
request and response where such response can be found.
14. Copies of the responses and any and all documents produced should be provided to:
Thorvald A. Nelson
Austin Rueschhoff
Austin W. Jensen
Kristine A.K. Rocah
Holland& Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: tnelson(d,hollandhart.com
darueschhoff khollandhart.com
aw'e� nsen(&,hollandhart.com
karoachkhollandhart.com
aclee(&,hollandhart.com
mamcmillenghollandhart.com
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: The Direct Testimony of the Company Witness Mr. Larkin at page 10,
lines 18-21 states that the final step in determining the sufficiency of existing rates is to layer on
increased costs and revenues associated with capital and Operation and Maintenance ("O&M")
Labor in 2024.
a. Please explain whether the Company is aware of any costs that are expected to
decrease in 2024.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -5- August 16, 2024

b. Please identify each O&M expense item the Company expects to decrease in 2024.
C. For each item identified in subpart (b), please provide the amount of the expected
cost reduction. Please provide this information in electronic spreadsheet format
with all formulas and links intact.
REQUEST NO. 2: Please indicate whether there are any regulatory asset amortizations
that were complete by year end 2023, or that will be complete in 2024. If the response is
affirmative,please identify the regulatory asset, and provide the annual amortization expense.
REQUEST NO. 3: Please provide IPC's actual 2024 employee headcount.
REQUEST NO. 4: Please identify the employee headcount assumed in the Company's
proposed revenue requirement.
REQUEST NO. 5: Please explain whether the headcount identified in response to
Question 4 includes any open/vacant positions. If the response is affirmative, please identify the
number of open/vacant positions included in the proposed revenue requirement.
REQUEST NO. 6: Please indicate whether the Company has reflected annualized
increased revenues associated with load growth as an offset to the proposed revenue requirement
in this case. If not,please explain why not. If so,please provide the calculations of the additional
revenue expected from load growth, and show how it was applied as an offset to the requested
revenue requirement in this case. Please provide all calculations in electronic spreadsheet format
with all formulas and links intact.
REQUEST NO. 7: Please refer to page 16, lines 5-6 of Direct Testimony of Company
Witness Mr.Larkin where he states accumulated depreciation was determined based on a mid-year
convention. Please provide the amount of accumulated depreciation at the beginning of the year,
the end of the year, and the mid-year average calculated by the Company. Please provide
workpapers, in an electronic format with all formulas and links intact, to support the accumulated
depreciation amounts.
REQUEST NO. 8: Please refer to page 11, lines 1-2 of Direct Testimony of Company
Witness Mr. Larkin where he states plant balances were estimated at year end. Please provide the
plant balances at the beginning of the year, the end of the year, and a mid-year average. Please
provide workpapers, in an electronic format with all formulas and links intact,to support the plant
balances.
REQUEST NO. 9: Please explain why the Company is forecasting plant balances at
year-end but calculating accumulated depreciation using a mid-year convention. Please provide
workpapers calculating the Company's revenue requirement if plant balances were also forecasted
using a mid-year approach as the Company has proposed for accumulated depreciation. Please
also provide workpapers calculating the Company's revenue requirement if accumulated
depreciation is forecasted at year-end as the Company has proposed for plant balances.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -6- August 16, 2024

REQUEST NO. 10: Please provide electronic versions of Mr. Larkin's exhibits, with all
formulas and links intact.
REQUEST NO. 11: Please refer to page 20, lines 17-24 of Direct Testimony of Company
Witness Larkin where he states,that to"determine the appropriate level of revenue growth to apply
as an offset...[fJirst, Idaho Power determined an estimated cents-per-kilowatt-hour ("kWh") rate
of cost recovery for capital-related items and O&M Labor that is currently embedded in retail rates
as a result of the 2023 GRC." Please provide workpapers supporting this estimated kWh rate.
Respectfully submitted August 16, 2024.
HOLLAND &HART, LLP
By: zj4l�
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -7- August 16, 2024

CERTIFICATE OF SERVICE
I hereby certify that on August 16,2024,a true and correct copy of the within and foregoing
FIRST PRODUCTION REQUESTS OF MICRON TECHNOLOGY, INC. TO IDAHO POWER
COMPANY was served in the manner shown to:
Idaho Power Company
Lisa D.Nordstrom Timothy E. Tatum
Donovan E. Walker Connie Aschenbrenner
Megan Goicoecha Allen Matt Larkin
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
lnordstrom(d),idahopower.com Telephone: [phone]
dwalker(a,idahopower.com Facsimile: [phone]
mgoicoecheaallen(a-),idahopower.com ttatum(didahopower.com
docketskidahopower.com caschenbrennergidahopower.com
mlarkin(a),idahopower.com
Commission Staff Federal Executive Agencies
Monica Barrios-Sanchez Peter Meier
Commission Secretary Emily W. Medlyn
Idaho Public Utilities Commission U.S. Department of Energy
11331 W. Chinden Blvd., Building 8, 1000 Independence Ave., S.W.
Suite 201-A Washington, D.C. 20585
Boise, ID 83714 peter.meier(&,hq.doe.gov
secretarykpuc.idaho.gov emily.medly&hq.doe. og_v
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen Lance Kaufman, Ph.D.
Echo Hawk& Olsen, PLLC 2623 NW Bluebell Place
505 Pershing Ave., Suite 100 Corvallis, OR 97330
P.O. Box 6119 lance(a,ae isi�nsi hg t.com
Pocatello, ID 83205
elo&echohawk.com
Industrial Customers of Idaho Power
Peter J. Richardson Dr. Don Reading
Richardson Adams, PLLC 280 S. Silverwood Way
515 N. 27th Street Eagle, ID 83616
P.O. Box 7218 dreadingkmindspring.com
Boise, ID 83702
peter(krichardsonadams.com
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -8- August 16, 2024

Idaho Conservation League
Matthew A.Nykel Brad Heusinkveld
710 N. 6th Street Idaho Conservation League
Boise, ID 83702 Regulatory Counsel
matthwe.pykelggmail.com 710 N. 6th Street
Boise, ID 83702
bheusinkveldgidahoconservation.org
Micron Technology, Inc.
Jim Swier Austin Rueschhoff
Micron Technology, Inc. Thorvald A. Nelson
8000 South Federal Way Austin W. Jensen
Boise, ID 83707 Kristine A.K. Roach
jswier(d),micron.com Holland& Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
darueschho f okhollandhart.com
tnelson(a,ho llandhart.com
awj ensenghollandhart.com
karoach(d,hollandhart.com
acleekhollandhart.com
mamcmillen(ahollandhart.com
City of Boise City Kevin Dickey
Ed Jewell Kevin Dickey
Steven Hubble PO Box 337
Boise City Attorney's Office Emmett, ID 83617
150 N. Capitol Blvd. bfe&safelink.net
P.O. Box 500
Boise, ID 83701-0500
Bois eCityAttorneykcityof boise.org
ei ewell(d),cityofboise.org
shubblekcityofboise.org
s/Adele Lee
32631416_Q
MICRON TECHNOLOGY, INC.'S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -9- August 16, 2024