20240906IPC to Micron 1-10.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
September 6, 2024
VIA ELECTRONIC FILING
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-24-07
Application of Idaho Power Company for Authority to Increase Rates for
Electric Service to Recover Costs Associated with Incremental Capital
Investments and Certain Ongoing Operations and Maintenance Expenses
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company’s Response to
Micron Technology, Inc.’s First Production Request to Idaho Power Company.
Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.
The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site will be provided to the parties that execute the
Protective Agreement in this matter.
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
' a1DA11> POWER .
RECEIVED
Friday, September 06, 2024
IDAHO PUBLIC
UTILITIES COMMISSION

CERTIFICATE OF ATTORNEY

ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION

Case No. IPC-E-24-07

Idaho Power Company’s Application for Authority to Increase Rates for Electric
Service to Recover Costs Associated with Incremental Capital Investments and
Certain Ongoing Operations and Maintenance Expenses

The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that the Attachment to Request No. 1 to Idaho Power Company’s Response to
Micron Technology, Inc.’s First Production Request to Idaho Power Company dated
September 6, 2024, contains information that Idaho Power Company and/or a third party
claim are trade secrets or business records of a private enterprise required by law to be
submitted to or inspected by a public agency, and/or public records exempt from
disclosure by state or federal law (material nonpublic information under U.S. Securities
and Exchange Commission Regulation FD) as described in Idaho Code § 74-101, et seq.,
and/or § 48-801, et seq. As such, it is protected from public disclosure and exempt from
public inspection, examination, or copying.

DATED this 6th day of September 2024.

LISA D. NORDSTROM
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Attorneys for Idaho Power Company

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY TO
INCREASE RATES FOR ELECTRIC
SERVICE TO RECOVER COSTS
ASSOCIATED WITH INCREMENTAL
CAPITAL INVESTMENTS AND CERTAIN
ONGOING OPERATIONS AND
MAINTENANCE EXPENSES.

)
)
)
)
)
)
)
)
)

CASE NO. IPC-E-24-07

IDAHO POWER COMPANY’S
RESPONSE TO MICRON
TECHNOLOGY, INC.’S FIRST
PRODUCTION REQUESTS TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Micron Technology, Inc.’s (“Micron”) First Production Requests to Idaho
Power Company dated August 12, 2024, here with submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 2
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.
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.
RESPONSE TO REQUEST NO. 1: Idaho Power does not possess and has not
prepared the requested analysis. However, it is important to note that 2023 Operations &
Maintenance (“O&M”) actuals were $346,812,692 compared to the 2024 O&M budget of
$400,876,505. Please see Confidential Attachment - Response to Micron Request No. 1
for a comparison of 2023 actual and 2024 budget O&M labor, which is a component of
the 2024 Limited Issue Rate Case (“2024 Rate Case”), and non-labor O&M, which is not
a component of the 2024 Rate Case.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 3
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.
RESPONSE TO REQUEST NO. 2: Please see the table below, showing three
Regulatory Asset amortizations that were either complete in 2023 or will be completed in
2024. It should be noted that none of these Oregon regulatory asset amortizations are
included in Idaho rates.
Regulatory Asset Amortization
Completion
Annual Amortization
Expense
182304 - Oregon Arrearage Management Plan 5/31/2023
348,448.20
182305 - Oregon COVID Deferral 5/31/2023
152,965.80
182398 - Oregon Langley Deferral 10/31/2024
369,171.36

The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 4
REQUEST NO. 3: Please provide IPC’s actual 2024 employee headcount.
RESPONSE TO REQUEST NO. 3: Employee headcount varies throughout the
year. Below is Idaho Power’s 2024 employee headcount by month.
1/29/2024 2/29/2024 3/31/2024 4/30/2024 5/31/2024 6/30/2024 7/31/2024 8/31/2024
Regular Full Time 2057 2055 2057 2057 2063 2068 2068 2068
Regular Part Time 9 10 10 9 9 9 9 8
Temporary Full Time 41 40 36 33 38 36 41 37
Temporary Part Time 0 0 0 0 0 0 0 0
Seasonal Full Time 0 0 0 11 16 18 18 12
Seasonal Part Time 1 1 1 1 0 0 0 0
Total 2108 2106 2104 2111 2126 2131 2136 2125

The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 5

REQUEST NO. 4: Please identify the employee headcount assumed in the
Company’s proposed revenue requirement.
RESPONSE TO REQUEST NO. 4: The Company’s 2024 O&M labor forecast
methodology was not based on an assumed employee headcount. As described in the
direct testimony of Matthew Larkin (Larkin, DI 18), the Company developed the 2024
O&M labor forecast by first calculating a three-year history of the ratio between February
year-to-date O&M labor expenses and full year O&M labor expenses. This ratio was then
applied to month-end February 2024 year-to-date O&M labor to determine the
expectation of full year 2024 O&M labor expenses.
As noted in Response to Request No. 3 above, the employee headcount was
2,106 as of the end of February 2024.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 6
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.
RESPONSE TO REQUEST NO. 5: The headcount identified in response to
Question No. 4 does not include any open/vacant positions.
The response to this Request is sponsored by Matthew Larkin, Revenue
Requirement Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 7
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.
RESPONSE TO REQUEST NO. 6: Yes, as described in pages 20-21 of the direct
testimony of Mr. Larkin, the Company included the increased revenue collection due to
sales growth between the 2023 General Rate Case (“GRC”) Stipulation and 2024 for the
capital and O&M labor components embedded in retail rates as a result of the 2023 GRC.
The calculation of the revenue offset was provided in Idaho Power Company’s Response
to the First Production Request of the Commission Staff to Idaho Power Company dated
July 5, 2024, labeled “Attachment 7 – Response to Staff Request No. 3 – Larkin
Workpaper 7 – Revenue Growth Offset.” The revenue offset was included in Table 4, row
357 in Larkin Exhibit 10 and is an offset to the total revenue requirement.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 8
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.
RESPONSE TO REQUEST NO. 7: The requested information is provided in the
following table -
Accumulated Depreciation
12/31/2023 (A) 12/31/2024 (B) Mid-Year ((A+B)/2)
2,146,074,331 2,202,464,827 2,174,269,579

The accumulated depreciation workpaper was provided in Idaho Power
Company’s Response to the First Production Request of the Commission Staff to Idaho
Power Company dated July 5, 2024, labeled “Attachment 1 – Response to Staff Request
No. 3 - Larkin Workpaper 1 – Accumulated Reserve.”
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 9
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.
RESPONSE TO REQUEST NO. 8: The requested information is provided in the
following table -
Plant Balances
12/31/2023 (A) 12/31/2024 (B) Mid-Year ((A+B)/2)
6,571,067,568 7,184,190,289 6,877,628,928

The plant workpaper was provided in Idaho Power Company’s Response to the
First Production Request of the Commission Staff to Idaho Power Company dated July
5, 2024, labeled “Attachment 3 – Response to Staff Request No. 3 - Larkin Workpaper 3
– Incremental Plant Determination.”
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 10
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.
RESPONSE TO REQUEST NO. 9: The Company used the mid-year convention
for accumulated depreciation because it assumes that assets are acquired and placed
into service evenly throughout the year, rather than assuming all assets are placed in
service at the beginning of the test year.
The Excel workpaper labeled “Attachment 1 – Response to Micron’s Request No.
9_2024 JSS Scenarios” contains two tabs labeled “2024 – Year-End Accum Depr,” and
“2024 – Mid Year Plant” which contains the requested revenue requirement scenarios.
Attachments 2 and 3 are the accompanying workpapers calculating the incremental year-
end Accumulated Depreciation and the incremental 2024 mid-year plant values used in
the revenue requirement scenarios.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 11
REQUEST NO. 10: Please provide electronic versions of Mr. Larkin’s exhibits,
with all formulas and links intact.
RESPONSE TO REQUEST NO. 10: Please see the following attachments to
Idaho Power Company’s Response to the First Production Request of the Commission
Staff to Idaho Power Company dated July 5, 2024.
 Attachment No. 11 – Response to Staff Request No. 3 – Larkin Exhibit No. 6 –
Results of Operations;
 Attachment No. 12 – Response to Staff Request No. 3 – Larkin Exhibit No. 7 –
Incremental Plant Determination;
 Attachment No. 13 – Response to Staff Request No. 3 – Larkin Exhibit No. 8 –
Incremental Labor Determination;
 Attachment No. 14 – Response to Staff Request No. 3 – Larkin Exhibit No. 9 –
Revenue Growth Offset; and
 Attachment No. 15 – Response to Staff Request No. 3 – Larkin Exhibit No. 10 –
2024 JSS.
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 12
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…[f]irst, 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.
RESPONSE TO REQUEST NO. 11: The calculation of the estimated kWh rate
was provided in Idaho Power Company’s Response to the First Production Request of
the Commission Staff to Idaho Power Company dated July 5, 2024, labeled ‘Attachment
No. 14 – Response to Staff Request No. 3 – Larkin Exhibit No. 9 – Revenue Growth
Offset.”
The response to this Request is sponsored by Matt Larkin, Revenue Requirement
Senior Manager, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 13
DATED at Boise, Idaho, this 6th day of September 2024.

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 14
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 6th day of September 2024, I served a true and
correct copy of Idaho Power Company’s Response to Micron Technology, Inc.’s First
Production Requests to Idaho Power upon the following named parties by the method
indicated below, and addressed to the following:

Commission Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 15
Idaho Conservation League
Brad Heusinkveld
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
[e-mail]

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S FIRST PRODUCTION
REQUESTS TO IDAHO POWER - 16
Steven Hubble
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]

Federal Executive Agencies
Peter Meier
Emily W. Medlyn
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585

Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
[e-mail]

Stacy Gust
Regulatory Administrative Assistant

~ ~