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HomeMy WebLinkAbout20241122FEA to Micron 1.pdf RECEIVED Friday, November 22, 2024 IDAHO PUBLIC UTILITIES COMMISSION Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 Phone: 240-578-3364 peter.meier@hq.doe.gov emily.medlyn@hq.doe.gov Attorneys for the Federal Executive Agencies 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 ) SERVICE TO RECOVER COSTS ) THE FEDERAL EXECUTIVE ASSOCIATED WITH INCREMENTAL ) AGENCIES' RESPONSES TO CAPITAL INVESTMENTS AND CERTAIN ) MICRON TECHNOLOGY, ONGOING OPERATIONS AND ) INC.'S FIRST PRODUCTION MAINTENANCE EXPENSES ) REQUEST The Federal Executive Agencies ("FEA") hereby provides its responses and objections to Micron Technology, Inc.'s ("Micron") First Production Request to FEA. FEA objects to the instructions and directions in Micron's First Production Request insofar as they seek: (A) to impose more burdensome requirements for discovery than the applicable requirements of Rules 225 and 228 of the Rules of Procedure of the Idaho Public Utilities Commission, or Commission precedent; or (B) require disclosure of privileged communications and information pursuant to the attorney-client privilege or disclosure of communications and information protected from discovery under the attorney work product doctrine. Subject to and without waiving these general objections, FEA responds to Micron's First Production Request, FEDERAL EXECUTIVE AGENCIES' RESPONSES TO MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST 1 expressly reserving all evidentiary and other objections concerning FEA's responses and any related documents that Micron may seek to offer into evidence in this case. FEA's responses are made in the spirit of cooperation without waiving FEA's right to contest the admissibility of any of these matters at hearing. MICRON 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. RESPONSE: Please see attached Excel workbooks `Micron-FEA-1 WP LB-1 AED-4CP CCOS' and `Micron-FEA-1 WP LB-2 AED-4CP'. This response is sponsored by Dr. Larry Blank. Respectfully submitted, this 22nd day of November 2024. FEDERAL EXECUTIVE AGENCIES BY THE U.S. DEPARTMENT OF ENERGY uc w R Emily W. Medlyn Attorney-Adviser Peter Meier Emily W. Medlyn U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 Phone: 240-578-3364 Fax: 202-586-4116 peter.meierghq.doe.gov emily.medlyn@hg.doe.gov FEDERAL EXECUTIVE AGENCIES' RESPONSES TO MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST 2 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 ) SERVICE TO RECOVER COSTS ) CERTIFICATE OF SERVICE ASSOCIATED WITH INCREMENTAL ) CAPITAL INVESTMENTS AND CERTAIN ) ONGOING OPERATIONS AND ) MAINTENANCE EXPENSES ) I CERTIFY that on this date I sent by email a true and correct copy of THE FEDERAL EXECUTIVE AGENCIES' RESPONSES TO MICRON TECHNOLOGY,INC.'S FIRST PRODUCTION REQUEST on the parties of record to this proceeding. DATED November 22, 2024. 6L A- Emily W. Medlyn Attorney-Adviser U.S. Department of Energy 1000 Independence Ave., S.W. Washington, D.C. 20585 Phone: 240-578-3364 emily.medlyn@hq.doe.gov FEDERAL EXECUTIVE AGENCIES' RESPONSES TO MICRON TECHNOLOGY, INC.'S FIRST PRODUCTION REQUEST 3