20241127Jessica York Rebuttal.pdf

RECEIVED
Wednesday, November 27, 2024
IDAHO PUBLIC
BEFORE THE UTILITIES COMMISSION
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 )
Rebuttal Testimony of
Jessica A. York
On behalf of
Micron Technology, Inc.
November 27, 2024

Table of Contents
I. RESPONSE TO IIPA WITNESS KAUFMAN.........................................................1
II. RESPONSE TO ICIP WITNESS READING..........................................................4
York, Di-Reb 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 ARE YOU THE SAME JESSICA A. YORK WHO PREVIOUSLY FILED DIRECT
5 TESTIMONY ON NOVEMBER 6, 2024 IN THIS CASE?
6 A Yes, I am.
7 Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
8 A I am appearing on behalf of Micron Technology, Inc. ("Micron"), a large customer of
9 Idaho Power Company ("IPC" or the "Company").
10 Q WHAT IS THE PURPOSE OF YOUR REBUTTAL TESTIMONY?
11 A The purpose of my rebuttal testimony is to respond to the revenue allocation proposals
12 made by the Idaho Irrigation Pumpers Association, Inc. ("IIPA") witness Dr. Lance
13 Kaufman, and the Industrial Customers of Idaho Power ("ICIP") witness Dr. Don
14 Reading.
15 My silence with regard to any position taken by IPC or any other party in any
16 testimony in this proceeding does not indicate my endorsement of that position.
17 I. RESPONSE TO IIPA WITNESS KAUFMAN
18 Q PLEASE DESCRIBE DR. KAUFMAN'S REVENUE ALLOCATION PROPOSAL.
19 A Dr. Kaufman recommends an equal percent increase for all rate schedules.'
' Direct Testimony of Lance Kaufman at 5:21.
York, Di-Reb 1
Micron Technology, Inc.

1 Q WHAT IS THE BASIS FOR DR. KAUFMAN'S REVENUE ALLOCATION
2 PROPOSAL?
3 A Dr. Kaufman accepts IPC's class cost of service study ("CCOSS") model as a model of
4 the approximate cost of providing service to customers,2 and notes that alternative
5 methods such as an hourly CCOSS are being considered separately from this docket.3
6 Dr. Kaufman proceeds to compare the revenue-to-cost ratio based on IPC's CCOSS
7 result to the revenue-to-cost ratio based on an equal percent increase across classes.4
8 He claims that since an equal percent increase would bring each class within 3 percent
9 of the CCOSS result, an equal percent increase is reasonable.5
10 Q DO YOU HAVE CONCERNS WITH DR. KAUFMAN'S REVENUE ALLOCATION
11 PROPOSAL?
12 A Yes. First, Dr. Kaufman's proposal does not make any progress moving customer
13 classes toward their actual cost of service. Second, Dr. Kaufman recommends that
14 IPC's CCOSS be accepted, but then makes several unsubstantiated claims discrediting
15 IPC's CCOSS, including vague assertions that the CCOSS only provides "generic
16 representations of the cost of providing service,16 that "it may be more appropriate to
17 place greater weight on winter demand peaks because winter demand is more costly
18 to serve,"' and referring to the "approximate nature"8 of IPC's cost of service study.
19 Dr. Kaufman also overstates that parties are in the process of"fundamentally revising
20 IPC's cost of service study" while in fact parties have only agreed to participate in
2 Id. at 2:14-15.
3 Id. at 3:3-7.
41d. at4-5.
5 Id.
6 Id. at 2:16.
Id. at 2:18-20.
$ Id. at 3:1.
s Id. at 3:3-5.
York, Di-Reb 2
Micron Technology, Inc.

1 informal workshops to study alternative cost of service methodologies, and no decision
2 has been made regarding the use of alternative methodologies.10 While Dr. Kaufman
3 attempts to cast doubt on IPC's CCOSS, he does not recommend an alternative
4 CCOSS in this case.
5 Q DOES DR. KAUFMAN'S PROPOSED REVENUE ALLOCATION MAKE PROGRESS
6 IN MOVING RATE CLASSES CLOSER TO COST OF SERVICE?
7 A No. Dr. Kaufman accepted IPC's CCOSS, as noted above, but his proposed class
8 revenue spread reflecting an equal percentage increase does not follow the IPC's
9 CCOSS or move rate classes closer to cost of service.
10 Q DO OTHER PARTIES TAKE ISSUE WITH IPC'S CCOSS?
11 A With the exception of ICIP witness Dr. Reading, whom I respond to below, no. Further,
12 while the parties in the 2023 General Rate Case ("GRC") agreed to explore alternative
13 CCOSS methods through workshops, those workshops are ongoing, and no alternative
14 hourly CCOSS model has been presented to any party or the Commission for
15 consideration at this point in time.
16 The only alternative CCOSS presented in this case is an Average and Excess
17 Demand ("AED") Four Coincident Peak ("4CP") CCOSS presented by the Federal
18 Executive Agencies' ("FEA") witness Mr. Blank. FEA's model shows that an even
19 greater increase could be justified for the Irrigation class than IPC's CCOSS.11 That is,
20 the FEA CCOSS also does not support Dr. Kaufman's proposal using an equal
21 percentage increase as a means of moving classes closer to cost of service. However,
22 despite offering the AED-4CP CCOSS, FEA ultimately recommends that IPC's CCOSS
10 IPC-E-23-11, Stipulation at¶ 13(a).
11 Direct Testimony of Larry Blank at 17, Table 2.
York, Di-Reb 3
Micron Technology, Inc.

1 be used as the basis for revenue allocation in this case.12 In addition, the City of Boise13
2 and Idaho Public Service Commission Staff 14 also support the Company's proposed
3 revenue spread in this case.
4 Q DO YOU CONTINUE TO SUPPORT THE COMPANY'S PROPOSED REVENUE
5 ALLOCATION?
6 A Yes. Given that IPC's CCOSS is the one that was used as the basis for revenue
7 allocation in the 2023 GRC settlement, which was approved by the Commission, and
8 no party recommends a different CCOSS be relied on in this case, it is reasonable to
9 continue moving toward cost of service based on the Company's CCOSS in this case.
10 Dr. Kaufman's proposal to use an equal percent increase across customer classes
11 does not make a meaningful movement toward cost of service and should not be
12 approved by the Commission.
13 II. RESPONSE TO ICIP WITNESS READING
14 Q PLEASE DESCRIBE DR. READING'S REVENUE ALLOCATION PROPOSAL.
15 A Dr. Reading recommends that "the percentage difference between the overall rate
16 increase and each individual rate class's rate increase be the same percentage
17 difference that was used and approved by the Commission in the last rate case."15 The
18 percentage increases by customer class resulting from his recommendation at the
19 Company's claimed revenue deficiency are shown in the table on page 14 of
20 Dr. Reading's direct testimony.
12 Id. at 21:1-3.
13 Direct Testimony of Steve Hubble at 3:9-21.
14 Direct Testimony of Michael Eldred at 8:17-25.
15 Direct Testimony of Dr. Don Reading at 13:8-10.
York, Di-Reb 4
Micron Technology, Inc.

1 Q WHAT IS THE BASIS FOR DR. READING'S PROPOSAL?
2 A Dr. Reading observes that the Schedule 19 class received a stipulated increase of
3 0.65x16 the system average increase in the 2023 GRC, but that the same rate spread
4 parameters in this case produce an increase of 0.96x17 system average. Dr. Reading
5 takes issue with this result and asserts that, since the 2023 GRC, there have been
6 changes both in the relationship among customer classes as well as the Company's
7 resource mix that impact the CCOSS results in an unknown fashion.18 He also raises
8 a concern that IPC included three new special contract customers, who were previously
9 part of the Schedule 19 class, in Schedule 19 for purposes of developing rate spread.19
10 Q HAS DR. READING PROVIDED ANY EVIDENCE THAT THE RELATIONSHIP
11 BETWEEN CUSTOMER CLASSES HAS CHANGED SINCE THE LAST CASE?
12 A No. Dr. Reading has not provided any analysis or evidence to support this assertion.
13 Q WHAT IS YOUR RESPONSE TO DR. READING'S CONCERN ABOUT THE
14 INCLUSION OF THE THREE NEW SPECIAL CONTRACT CUSTOMERS IN
15 SCHEDULE 19 FOR PURPOSES OF RATE SPREAD?
16 A Dr. Reading has not provided evidence to show that the three special contract
17 customers who were previously included in Schedule 19 have changed their load
18 characteristics such that it is unreasonable to include them with the Schedule 19 class
19 in this case. Similarly, he has not provided any evidence to show that the consequence
20 of including those customers with Schedule 19 in the 2023 CCOSS model updated to
16 Id. at 10:25-26 and 11:1 (2.78% /4.25% = 0.65).
17 Id. at 11:8-9. (7.10% /7.31% = 0.96).
1s Id. at 12:2-7.
19 Id. at 12:19-26.
York, Di-Reb 5
Micron Technology, Inc.

1 reflect the incremental revenue requirement in this case does not produce a reliable
2 result.
3 Q DOES A CHANGED RESOURCE MIX MAKE THE COMPANY'S CCOSS RESULTS
4 UNRELIABLE IN THIS CASE?
5 A No. I believe the nature of the incremental investment in production plant is a significant
6 driver of the result identified by Dr. Reading for Schedule 19. However, changes in
7 resource mix do not make the Company's CCOSS unreliable, particularly in light of the
8 fact that no party has shown that customer class load characteristics have changed
9 materially from the 2023 GRC.
10 In the Company's CCOSS, production resources are distinguished between
11 baseload and peaking resources. Baseload resources are allocated on the basis of 12
12 Coincident Peak (12CF) demand, and peaking resources are allocated on the basis
13 of 4CP demand.20 In this case, as shown below in Table JAY-1, growth in baseload
14 production plant has significantly outpaced the growth in peaking plant. All else equal,
15 customer classes like Schedule 19, who receive a larger percentage allocation of
16 baseload generation costs than peaking generation costs, could expect their share of
17 production rate base to increase in this case relative to the last case.
21 Docket No. IPC-23-11. Direct Testimony of Pawel Goralski at 15, Table 2.
York, Di-Reb 6
Micron Technology, Inc.

TABLE JAY-1
Growth in Rate Base Since 2023 GRC
2024 Case
Incremental Percent
Line Description 2023 GRC' Amount2 Increase
(1) (2) (3)
Production Capacity
1 Baseload $ 1,226,986,067 $ 372,671,415 30.4%
2 Peaking 126,207,603 6,227,723 4.9%
3 Total $ 1,353,193,670 $ 378,899,138 28.0%
4 Transmission $ 936,643,287 $ 129,847,647 13.9%
Distribution
5 Substations $ 338,804,962 $ 38,102,436 11.2%
6 Primary Voltage 648,561,230 106,831,512 16.5%
7 Secondary Voltage 465,661,410 64,765,215 13.9%
8 Other 116,114,651 12,346,570 10.6%
9 Total $ 1,569,142,253 $ 222,045,733 14.2%
10 Total $ 3,858,979,210 $ 730,792,519 18.9%
Sources and Notes:
'Docket No. IPC-E-23-11, Exhibit No. 38.
2Docket No. IPC-E-24-07. IPC's response to ICIP Data Request No. 2.
3Includes services, metres, streelights, and installations on customer
premises.
1 In addition, there has been significant investment in transmission and distribution plant.
2 Transmission plant is also allocated on 12CP demand. Further, Schedule 19 receives
3 an allocation of both primary and secondary voltage distribution plant. Given the growth
4 in all of these categories of plant, and the load characteristics of the Schedule 19 class,
5 1 believe the resulting increase of 0.96x system average for Schedule 19 in this case is
6 justified by the data and reasonable.
York, Di-Reb 7
Micron Technology, Inc.

1 Q PLEASE SUMMARIZE YOUR CONCLUSIONS REGARDING DR. READING'S
2 REVENUE ALLOCATION PROPOSAL.
3 A For the reasons described above, I believe it is reasonable to continue relying on the
4 Company's CCOSS as the basis for revenue apportionment in this case, and Dr.
5 Reading's alternative revenue allocation proposal should be rejected.
6 Q DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY?
7 A Yes, it does.
York, Di-Reb 8
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 rebuttal testimony in this
6 matter.
7 3. To the best of my knowledge, my pre-filed rebuttal testimony is true and
8 accurate.
9 1 hereby declare that the above statement is true to the best of my knowledge and
10 belief, and that I understand it is made for use as evidence before the Idaho Public Utilities
11 Commission and is subject to penalty for perjury.
12 SIGNED this 27th day of November, 2024, at Chesterfield, Missouri.
13 Signed:
14
15
16 33742571_A
Declaration
York, Di-Reb 1
Micron Technology, Inc.

CERTIFICATE OF SERVICE
I hereby certify that on November 27, 2024, a true and correct copy of the within and
foregoing REBUTTAL 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
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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
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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
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City of Boise City
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ei ewell(a,cilyofboise.orfz
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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
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