Loading...
HomeMy WebLinkAbout20241112Micron to FEA 1.pdf RECEIVED Tuesday, November 12, 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: (303) 295-8000 Email: darueschhoff@hollandhart.com tnelson@hollandhart.com a@ ensen@hollandhart.com karoach@hollandhart.com 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 THE FEDERAL EXECUTIVE CAPITAL INVESTMENTS AND CERTAIN ) AGENCIES 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 the Federal Executive Agencies ("FEA"). 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 via email with formulas intact and enabled. RESPONSE DATE,DEFINITIONS AND INSTRUCTIONS Please respond to these interrogatories and requests for production of documents by November 22, 2024. MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-1- November 12, 2024 DEFINITIONS 1. "The Federal Executive Agencies," "FEA," or "you" means the Federal Executive Agencies 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 FEA. 2. "Idaho Power Company," "Idaho Power," "IPC," or "the Company" 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. 3. "Agreement"means any contract,written or oral, or any non-contractual understanding. 4. "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. 5. "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. 6. "Date" shall mean the exact day, month, and year if ascertainable, or if not the best approximation thereof in relation to other events. 7. "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. MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-2- November 12, 2024 8. 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. 9. 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 thing relating directly or indirectly to the subject of the explanation including all pertinent dates. 10. 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. 11. "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. MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-3- November 12, 2024 12. "PUC" or"Commission"means the Idaho Public Utilities Commission. 13. "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 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. 14. "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 ten(10) days after service as agreed to by the parties in this case. 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. MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-4- November 12, 2024 9. If the respondent is not a witness who has filed written direct testimony, please indicate which of the FEA's witnesses will be prepared to answer these questions on the stand. 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: (303)295-8000 Email: tnelsonghollandhart.com darueschhoff(c hollandhart.com awj ensenghollandhart.com karoachghollandhart.com acleekhollandhart.com mamcmillen(a,hollandhart.com INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST NO. 1: Please provide a copy of FEA's class cost of service study reflecting the Average and Excess Demand ("AED") — Four Coincident Peak ("4CP") method used to produce the results shown in Table 2 of Mr. Blank's Direct Testimony at 17. Please provide the class cost of service study model in Excel format with all formulas and links intact. MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-5- November 12, 2024 Respectfully submitted November 12, 2024. HOLLAND & HART, LLr By: n- a,'t'- zt.,� 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: (303) 295-8000 Email: darueschhoff@hollandhart.com tnelson@hollandhart.com awjensen@hollandhart.com karoach@hollandhart.com Attorneys for Micron Technology, Inc. MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-6- November 12, 2024 CERTIFICATE OF SERVICE I hereby certify that on November 12, 2024, a true and correct copy of the within and foregoing FIRST PRODUCTION REQUESTS OF MICRON TECHNOLOGY, INC. TO THE FEDERAL EXECUTIVE AGENCIES 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&idahopower.com Telephone: (208) 388-5515 dwalkergidahopower.com Facsimile: (208) 388-6449 mgoicoecheaallengidahopower.com ttatumkidahopower.com dockets(kidahopower.com caschenbrenner&idahopower.com mlarkinkidahopower.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 secretga(kpuc.idaho.gov emily.medlyn(khq.doe.gov 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 isg insi hg t.com Pocatello, ID 83205 elo(a,echohawk.com MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-7- November 12, 2024 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 dreading(a,mindspring.com Boise, ID 83702 petergrichardsonadams.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 bheusinkveld(abidahoconservation.org Boise, ID 83701-0500 BoiseCityAttorneygcityofboise.org ejewell(&cityofboise.org shubblegcityofboise.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(a)micron.com Holland& Hart, LLP 555 17th Street, Suite 3200 Denver, CO 80202 darueschhoff(a hollandhart.com tnelson(a,hollandhart.com awj ens ennhollandhart.com karoachkhollandhart.com aclee(ab,hollandhart.com mamcmillen(a,hollandhart.com s/Adele Lee 33654819_v1 MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST TO THE FEDERAL EXECUTIVE AGENCIES-8- November 12, 2024