20241106Direct Jessica York.pdf

RECEIVED
Wednesday, November 6, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
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 ) CASE NO. IPC-E-24-07
INCREMENTAL CAPITAL INVESTMENTS )
AND CERTAIN ONGOING OPERATIONS )
AND MAINTENANCE EXPENSES )
Direct Testimony of
Jessica A. York
On behalf of
Micron Technology, Inc.
November 6, 2024

Table of Contents
I. SUMMARY............................................................................................................2
II. PROPOSED REVENUE APPORTIONMENT .......................................................2
III. RATE DESIGN ......................................................................................................6
Qualifications of Jessica A. York.......................................................................Appendix A
York, Di i
Micron Technology, Inc.

1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A Jessica A. York. My business address is 16690 Swingley Ridge Road, Suite 140,
3 Chesterfield, MO 63017.
4 Q WHAT IS YOUR OCCUPATION?
5 A I am a consultant in the field of public utility regulation and a Principal with the firm
6 of Brubaker & Associates, Inc. ("BAI"), energy, economic and regulatory
7 consultants.
8 Q PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
9 EXPERIENCE.
10 A This information is included in Appendix A to my testimony.
11 Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
12 A I am appearing on behalf of Micron Technology, Inc. ("Micron"), a large customer
13 of Idaho Power Company ("IPC" or the "Company").
14 Q WHAT IS THE PURPOSE OF YOUR TESTIMONY?
15 A The purpose of my testimony is to address IPC's proposed revenue apportionment
16 and rate design.
York, Di 1
Micron Technology, Inc.

1 Q DOES THE FACT THAT YOU DO NOT ADDRESS EVERY ISSUE RAISED IN
2 THE COMPANY'S TESTIMONY MEAN THAT YOU AGREE WITH ITS
3 TESTIMONY ON THOSE ISSUES?
4 A No, it merely reflects that I chose not to address all those issues in my testimony.
5 My silence on any issue should not be construed as an endorsement of, or
6 agreement with, IPC's position on such issues.
7 I. SUMMARY
8 Q PLEASE SUMMARIZE YOUR CONCLUSIONS AND RECOMMENDATIONS.
9 A I conclude that IPC's proposed spread of its requested revenue requirement
10 increase across customer classes is reasonable and should be approved. The
11 Company's proposed revenue apportionment is consistent with the stipulated
12 revenue spread from the 2023 General Rate Case ("GRC"), which reflected a
13 gradual movement toward cost of service based on the class cost of service study
14 provided in that case. Continuing the revenue spread from the 2023 GRC is
15 particularly appropriate here given the recency of the 2023 case, the "limited issue"
16 nature of this rate case, and because IPC has not performed or presented a new
17 class cost of service study in this case.
18 II. PROPOSED REVENUE APPORTIONMENT
19 Q HAVE YOU REVIEWED THE COMPANY'S PROPOSED SPREAD OF ITS
20 CLAIMED REVENUE DEFICIENCY IN THIS CASE?
21 A Yes. The Company's proposed spread of its claimed revenue deficiency is shown
22 in Table JAY-1.
York, Di 2
Micron Technology, Inc.

TABLE JAY-1
Idaho Power Company's Proposed Revenue Apportionment
Increase
Current IPC Proposed Relative to
Base Rate Increase/(Decrease) System
Line Description Revenue Amount Percent Average
(1) (2) (3) (4)
1 Combined Residential $ 629,812,087 $45,673,283 7.25% 0.99
2 Combined Small General Service 18,712,518 1,366,156 7.30% 1.00
3 Large General Service 320,493,527 21,935,191 6.84% 0.94
4 Dusk/Dawn Lighting 1,327,007 48,479 3.65% 0.50
5 Large Power Service 135,863,467 9,648,571 7.10% 0.97
6 Irrigation Service 166,865,446 15,849,613 9.50% 1.30
7 Unmetered Service 1,350,464 100,681 7.46% 1.02
8 Municipal Street Lighting 3,660,667 218,214 5.96% 0.82
9 Traffic Control Lighting 219,167 20,817 9.50% 1.30
10 Special Contracts 80,668,200 4,432,215 5.49% 0.75
11 Total Idaho Retail $1,358,972,550 $99,293,220 7.31% 1.00
Source:Attachment 3 to IPC's Application.
1 As shown in the table, the Company proposes to limit the increase for any
2 class to no more than 1.30x the system average increase, and no less than 0.5x
3 the system average increase.' The Company's claimed revenue deficiency, if
4 approved, would result in a 7.31% system average increase. That would, in turn,
5 result in the Irrigation Service and Traffic Control Lighting classes being capped at
6 an increase of 9.50%. The remaining classes would receive increases
7 approximately at the system average, or below the system average, but no less
8 than 3.65%, or 50% of 7.31%.2
' Direct Testimony of Timothy Tatum at 29:19-23.
2 Id. at 29:21-25.
York, Di 3
Micron Technology, Inc.

1 Q IS THE COMPANY'S PROPOSED REVENUE APPORTIONMENT
2 REASONABLE?
3 A Yes. As discussed in the Direct Testimony of IPC witness Mr.Tatum,the Company
4 proposes to spread the incremental revenue requirement of approximately
5 $99.3 million across customer classes in a manner that relies on agreed upon
6 methods from the 2023 Stipulation.3 This includes relying on the class cost of
7 service methods filed in the 2023 GRC to allocate the incremental rate base and
8 expenses to customer classes, and then applying the cap and spread parameters
9 agreed to in the 2023 Stipulation.4
10 As particularly applicable to Micron, the Company's proposed revenue
11 apportionment provides for an increase of approximately 5.53% for Micron's
12 Special Contract Rate Schedule 26.5 This outcome is directionally consistent with
13 IPC's cost of service study in the 2023 GRC, which concluded that Micron
14 warranted a cost-based rate increase below the system average increase.6
15 With regard to the other customer classes, I reviewed IPC's class cost of
16 service study in the 2023 GRC and found that study to be reasonable. I believe
17 that study remains reasonable today and can be used to develop a reasonable
18 revenue allocation in this case. Since the Company's proposed revenue allocation
19 moves all classes toward cost of service-based rates, Micron supports the
20 Company's revenue allocation proposal in this case. I would note that the
21 Company's approach makes a meaningful movement toward cost of service based
22 on the Company's class cost of service study while also recognizing the
23 ratemaking principal of gradualism in a manner consistent with the prior settlement.
3 Id. at 29:9-14.
4 Id. at 29:15-20.
5 Id. at 30:1.
6 See Case No. IPC-E-23-11, Direct Testimony of Pawel Goralski at 14:1-15.
York, Di 4
Micron Technology, Inc.

1 Q PLEASE EXPLAIN WHAT YOU MEAN BY "GRADUALISM."
2 A The ratemaking principal of gradualism is often applied by utility regulators in
3 revenue allocation decisions to balance the importance of moving customer
4 classes to rates that reflect their full cost of service while also recognizing that
5 movements towards cost of service may need to be made gradually to avoid
6 dramatic rate changes and resulting rate shock. This Commission has
7 acknowledged the ratemaking principal of gradualism in prior decisions.'
8 Q DID IPC CONSIDER ALTERNATIVE REVENUE APPORTIONMENT
9 PROPOSALS?
10 A Yes. The Company considered: 1) allocating the requested increase to the
11 customer classes based on a pro-rata share of the revenue increase from the
12 Commission-approved Settlement Stipulation in the 2023 GRC, and 2) an
13 across-the-board increase.$
14 Q WHY DID THE COMPANY DECIDE NOT TO APPLY ONE OF THE TWO
15 ALTERNATIVE REVENUE APPORTIONMENT METHODS THAT IT
16 CONSIDERED?
17 A The Company stated that it decided against the two alternative revenue
18 apportionment approaches because neither recognizes the cost drivers specific
19 and unique to this case, and would result in additional inter-class subsidization.9
20 Absent an updated class cost of service study in this case, the Company believes
' See, e.g., Case No. INT-G-16-02, Order No. 33757, at 28 & 35.
8 Direct Testimony of Tatum at 30:12-18.
9 Id. at 31:1-4.
York, Di 5
Micron Technology, Inc.

1 it is equitable to the various customer classes to maintain the stipulated approach
2 from the 2023 GRC.
3 Q DO YOU AGREE WITH THE COMPANY'S DECISION NOT TO USE ONE OF
4 THE ALTERNATIVE REVENUE SPREAD PROPOSALS?
5 A Yes. I agree that the alternative revenue apportionment approaches considered
6 by the Company would not continue to make meaningful movement toward cost of
7 service, as measured by the Company's class cost of service study in the last case.
8 Absent a new class cost of service study, maintaining the agreed upon revenue
9 allocation method from the Stipulation in the 2023 GRC is reasonable. It narrows
10 the wide range of rate impacts that would occur (both increases and decreases) if
11 all classes were moved to cost of service. Further, it mitigates the significant
12 increases that would be required for the Traffic Control Lighting, Irrigation Service,
13 and Residential classes to reach cost of service by ensuring that no class receives
14 an increase less than 0.5x the system average, and no class receives an increase
15 greater than 1.3x the system average.
16 III. RATE DESIGN
17 Q PLEASE DISCUSS IPC'S PROPOSED RATE DESIGN APPROACH FOR
18 SCHEDULE 26.
19 A For Schedule 26, Idaho Power's Micron Special Contract Schedule, the Company
20 proposes to collect the increased revenue requirement through the
21 demand-related charges, in recognition of Micron's Renewable Resource
22 Agreement.10
10 Id. at 32:16-19.
York, Di 6
Micron Technology, Inc.

1 Q DO YOU AGREE WITH IPC'S PROPOSED RATE DESIGN FOR
2 SCHEDULE 26?
3 A Yes. I believe the Company's proposed rate design for Schedule 26 is reasonable.
4 Q DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
5 A Yes, it does.
York, Di 7
Micron Technology, Inc.

1 Qualifications of Jessica A. York
2 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3 A Jessica York. My business address is 16690 Swingley Ridge Road, Suite 140,
4 Chesterfield, MO 63017.
5 Q PLEASE STATE YOUR OCCUPATION.
6 A I am a consultant in the field of public utility regulation and a Principal with the firm of
7 Brubaker&Associates, Inc. ("BAI"), energy, economic and regulatory consultants.
8 Q PLEASE IDENTIFY THE JURISDICTIONS IN WHICH YOU HAVE PREVIOUSLY
9 SPONSORED TESTIMONY.
10 A I have sponsored expert testimony in front of the Idaho Public Utilities Commission, the
11 Illinois Commerce Commission, Indiana Utility Regulatory Commission, the Iowa
12 Utilities Commission, the Kansas Corporation Commission, the Michigan Public
13 Service Commission, the Minnesota Public Utilities Commission, the Missouri Public
14 Service Commission, the Public Utilities Commission of Nevada, the Oklahoma
15 Corporation Commission, the Virginia State Corporation Commission, and the Public
16 Service Commission of Wisconsin.
17 Q PLEASE STATE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL
18 EMPLOYMENT EXPERIENCE.
19 A I graduated from Truman State University in 2008 where I received my Bachelor of
20 Science Degree in Mathematics with minors in Statistics and Actuarial Science. I
21 earned my Master of Business Administration Degree with a concentration in Finance
22 from the University of Missouri-St. Louis in 2014.
Appendix A
York, Di 1
Micron Technology, Inc.

1 1 joined BAI in 2011 as an analyst. Then, in March 2015, 1 joined the consulting
2 team of BAI.
3 1 have worked in various electric, natural gas, and water and wastewater
4 regulatory proceedings addressing cost of capital, sales revenue forecasts, revenue
5 requirement assessments, class cost of service studies, rate design, and various policy
6 issues. I have also conducted competitive power and natural gas solicitations on behalf
7 of large electric and natural gas users, have assisted those large power and natural
8 gas users in developing procurement plans and strategies, assisted in competitive
9 contract negotiations, and power and natural gas contract supply administration. In the
10 regulated arena, I have evaluated cost of service studies and rate designs proffered by
11 other parties in cases for various utilities, including in Idaho, Illinois, Indiana, Kansas,
12 Wisconsin and others. I have conducted bill audits, rate forecasts, and tariff rate
13 optimization studies.
14 1 have also provided support to clients with facilities in deregulated markets,
15 including drafting supply requests for proposals, evaluating supply bids, and auditing
16 competitive supply bills. I have also prepared and presented to clients reports that
17 monitor the electric market and recommend strategic hedging transactions.
18 BAI was formed in April 1995. BAI and its predecessor firm have participated
19 in more than 700 regulatory proceedings in forty states and Canada.
20 BAI provides consulting services in the economic, technical, accounting, and
21 financial aspects of public utility rates and in the acquisition of utility and energy
22 services through RFPs and negotiations, in both regulated and unregulated markets.
23 Our clients include large industrial and institutional customers, some utilities and, on
24 occasion, state regulatory agencies. We also prepare special studies and reports,
25 forecasts, surveys and siting studies, and present seminars on utility-related issues.
Appendix A
York, Di 2
Micron Technology, Inc.

1 In general, we are engaged in energy and regulatory consulting, economic
2 analysis and contract negotiation.
3 In addition to our main office in St. Louis, the firm also has branch offices in
4 Corpus Christi, Texas; Louisville, Kentucky and Phoenix, Arizona.
Appendix A
York, Di 3
Micron Technology, Inc.

1 DECLARATION OF JESSICA A. YORK
2 I, Jessica A. York, declare under penalty of perjury under the laws of the state of Idaho:
3 1. My name is Jessica A. York. I am employed by Brubaker & Associates, Inc.
4 ("BAI") as a Principal and consultant in the field of public utility regulation.
5 2. On behalf of Micron Technology, Inc., I present this pre-filed direct testimony in
6 this matter.
7 3. To the best of my knowledge, my pre-filed direct testimony is true and accurate.
8 I hereby declare that the above statement is true to the best of my knowledge and
9 belief, and that I understand it is made for use as evidence before the Idaho Public Utilities
10 Commission and is subject to penalty for perjury.
11 SIGNED this 611 day of November 2024, at Chesterfield, Missouri.
12 Signed:
13
14 Q. �L-
1 5 33417525_v7
Declaration
York, Di 1
Micron Technology, Inc.

CERTIFICATE OF SERVICE
I hereby certify that on November 6, 2024, a true and correct copy of the within and
foregoing DIRECT TESTIMONY OF JESSICA A. YORK ON BEHALF OF MICRON
TECHNOLOGY, INC. IN CASE NO. IPC-E-24-07 was served in the manner shown to:
Electronic Mail
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
Inordstrom(d),idahopower.com Telephone: [phone]
dwalker&idahopower.com Facsimile: [phone]
mgoicoecheaallen(didahopower.com ttatum(d),idahopower.com
docketskidahopower.com caschenbrenner&idahopower.com
mlarkin(aidahopower.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(ahq.doe.gov
secretaryhpuc.idaho.gov emily.medlynkhq.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 lancegae ism 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 dreadinagmindsprina.com
Boise, ID 83702
peter@.richardsonadams.com
Idaho Conservation League City of Boise City
Brad Heusinkveld Ed Jewell
Idaho Conservation League Steven Hubble
Regulatory Counsel Boise City Attorney's Office
710 N. 6th Street 150 N. Capitol Blvd.
Boise, ID 83702 P.O. Box 500
bheusinkveldgidahoconservation.org Boise, ID 83701-0500
BoiseCityAttomey(a,cityofboise.org
ejewell(a,cityofboise.org
shubble(acityofboise.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
jswierkmicron.com John W. Sherry
Holland&Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
darueschhoff(ahollandhart.com
tnelson(ahollandhart.com
awj ensen(a,hollandhart.c om
karoach(ahollandhart.com
aclee(ahollandhart.com
mamcmillen(aho llandhart.com
s/Adele Lee
324015040
2