20241122FEA 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: [phone]
[e-mail]
[e-mail]
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: [phone]
Fax: [phone]
peter.meierghq.doe.gov
[e-mail]
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: [phone]
[e-mail]
FEDERAL EXECUTIVE AGENCIES' RESPONSES TO
MICRON TECHNOLOGY, INC.'S FIRST
PRODUCTION REQUEST 3