20250218IPC Supplemental No. 1 to Staff.pdf

"4%6h-0IQAHO POWER.
RECEIVED
MEGAN GOICOECHEA ALLEN 2025 February 18, 2:02PM
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallenC&_idahopower.com UTILITIES COMMISSION
February 18, 2025
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Boulevard
Building 8, Suite 201-A
Boise, Idaho 83714
Re: Case No. IPC-E-24-44
Idaho Power Company's Application for Approval of a Special Contract and
Tariff Schedule 28 to Provide Electric Service to Micron Idaho Semiconductor
Manufacturing (Triton) LLC
Dear Commission Secretary:
Attached for electronic filing, please find Idaho Power Company's Supplemental
Response to the First Production Request of the Commission Staff to Idaho Power in the
above-entitled matter.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely, n��^
Awrl
I fACC41.P.a
Megan Goicoechea Allen
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Attachments
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707

MEGAN GOICOECHEA ALLEN (ISB No. 7623)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
mgoicoecheaallenCo)idahopower.com
Attorney for Idaho Power Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR ) CASE NO. IPC-E-24-44
APPROVAL OF SPECIAL CONTRACT AND )
TARIFF SCHEDULE 28 TO PROVIDE ) IDAHO POWER COMPANY'S
ELECTRIC SERVICE TO MICRON IDAHO ) SUPPLEMENTAL RESPONSE TO
SEMICONDUCTOR MANUFACTURING ) THE FIRST PRODUCTION
(TRITON) LLC. ) REQUEST OF THE COMMISSION
STAFF TO IDAHO POWER
COMES NOW, Idaho Power Company ("Idaho Power" or "Company"), and in
response to the First Production Request of the Commission ("Commission" or "IPUC")
Staff to Idaho Power Company dated January 8, 2025, herewith supplements the
following information:
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER- 1

REQUEST FOR PRODUCTION NO. 1: In reference to the proposed Demand and
Energy Charges discussed on pages 7-9 of the Application, please respond to the
following:
a. Please provide all workpapers used to determine the Demand Charges. Please
provide all workpapers in electronic format with formulas enabled.
b. Please provide all model runs and workpapers used to determine the Energy
Charge. For the model runs, please provide the assumptions used for each model
run. Please provide all files in electronic format with formulas enabled.
c. Please explain if the Company considered any other methods to determine the
Energy Charge for Schedule 28 besides the marginal cost method discussed in
the Application. If other methods were considered, please explain the method(s)
considered and why these method(s)were not selected. If no other method(s)were
considered, please explain why no other methods were considered.
d. Please explain if the Company evaluated the proposed Energy Charge
differentiated by season and by On, Mid, and Off-peak hour pricing similar to
Demand-Side Management Avoided Cost Averages. If the Company did evaluate
the time periods, please explain why the time periods were not used and provide
the Company's workpapers from the evaluation. If the Company did not evaluate
these time periods, please explain why these time periods were not evaluated.
e. Please provide a proposal for Energy Charges differentiated by season and by On,
Mid, and Off-peak hours with electronic workpapers documenting the method.
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER- 2

SUPPLEMENTAL RESPONSE TO REQUEST FOR PRODUCTION NO. 1: Per
discussions with Staff, Idaho Power submits this supplemental response to Request No.
1(a). Please refer to the file labeled "Attachment 8 — Supplemental Response to Staff
Request No. 1 — Pricing" for the workpaper illustrating Idaho Power's proposed
adjustments to the Contract Demand Charge and Billing Demand Charge. Paragraph 19
of the Application outlines the Company's proposal to modify these charges in Schedule
28 to align with any changes based on the aggregate Special Contract percentage
revenue increase authorized by the Commission in Case No. IPC-E-24-07. This proposal
acknowledges that the rates presented in the Application could not have accounted for
such an increase at the time of filing.
The response to the Request is sponsored by Grant T. Anderson, Regulatory
Consultant, Idaho Power Company.
Respectfully submitted this 18th day of February 2025.
n I fit
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER- 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 18th day of February 2025, 1 served a true and
correct copy of Idaho Power Company's Supplemental Response to the First Production
Request of the Commission Staff to Idaho Power upon the following named parties by the
method indicated below, and addressed to the following:
Commission Staff Hand Delivered
Chris Burdin U.S. Mail
Deputy Attorney General Overnight Mail
Idaho Public Utilities Commission FAX
11331 W. Chinden Blvd., Bldg No. 8 FTP Site
Suite 201-A (83714) X Email chris.burdin(a-),puc.idaho.gov
PO Box 83720
Boise, ID 83720-0074
Micron Technology, Inc. Hand Delivered
Austin Rueschhoff U.S. Mail
Thorvald A. Nelson Overnight Mail
Austin W. Jensen FAX
Kristine A.K. Roach FTP Site
Holland & Hart LLP X Email
555 17t" Street, Suite 3200 darueschhoff(abhol land hart.com
Denver, CO 80202 tnelson((2-)hol land hart.com
awjensen hol land hart.corn
karoach(a)hol land hart.com
aclee hollandhart.com
Stacy Gust
Regulatory Administrative Assistant
IDAHO POWER COMPANY'S SUPPLEMENTAL RESPONSE TO THE FIRST PRODUCTION REQUEST
OF THE COMMISSION STAFF TO IDAHO POWER-4

BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-44
IDAHO POWER COMPANY
SUPPLEMENTAL RESPONSE TO
REQUEST NO. 1
ATTACHMENT NO. 8

SEE ATTACHED SPREADSHEET