HomeMy WebLinkAbout20250430Supplemental and Errata Application.pdf "4%6h-0IQAHO POWER.
RECEIVED
MEGAN GOICOECHEA ALLEN April 30, 2025
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallenC�idahopower.com UTILITIES COMMISSION
April 30, 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 Supplement and
Errata Application in the above-entitled matter. Also attached for filing is the Direct
Testimony of Connie G. Aschenbrenner, Direct Testimony of Grant T. Anderson, and the
Direct Testimony of Jared L. Ellsworth.
The Exhibit to the Direct Testimony of Grant T. Anderson is confidential and
will be provided in a separate email to the parties who sign the Protective Agreement.
If you have any questions about the attached documents, please do not
hesitate to contact me.
Sincerely,
I lam'NL
Megan Goicoechea Allen
MGA:sg
Attachments
1221 W. Idaho St(83702)
P.O. Box 70
Boise, ID 83707
CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Idaho Power Company's Application for Approval of Special Contract and Tariff
Schedule 28 to Provide Electric Service to Micron Idaho Semiconductor
Manufacturing (Triton) LLC
Case No. IPC-E-24-44
The undersigned attorney, in accordance with Commission Rules of Procedure
67, believes that Exhibit No. 1 to the Direct Testimony of Grant T. Anderson, dated April
30, 2025, contains information that Idaho Power and a third party claim constitutes trade
secrets, confidential business records, and/or other non-public records exempt from
disclosure under state or federal law including but not limited to Idaho Code § 48-801, et
seq.; Idaho Code § 74-101, et seq.; and/or U.S. Code of Federal Regulations Title 17.
As such, it is protected from public disclosure, inspection, examination, or copying.
DATED this 30th day of April 2025.
Megan Goicoechea Allen
Counsel for Idaho Power Company
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
DONOVAN WALKER (ISB No. 5921)
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: (208) 388-5317
Facsimile: (208) 388-6936
mgoicoecheaallen(c-).idahopower.com
dwalker(a-)idahopower.com
Attorneys 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 ) SUPPLEMENT AND ERRATA TO
ELECTRIC SERVICE TO MICRON IDAHO ) APPLICATION
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC. )
Idaho Power Company ("Idaho Power" or"Company") hereby respectfully submits
to the Idaho Public Utilities Commission ("Commission") this Supplement and Errata to
the Company's Application seeking an order approving the Special Contract for electric
service between Idaho Power and Micron Idaho Semiconductor Manufacturing (Triton)
LLC ("Micron") for Micron's new memory manufacturing fabrication complex ("Micron
FAB"), as follows:
I. SUPPLEMENT TO APPLICATION
1. On December 6, 2024, Idaho Power filed an application requesting an order
approving the Micron FAB Special Contract and the rates proposed in tariff Schedule 28.
The Commission issued a Notice of Application and Notice of Modified Procedure in
SUPPLEMENT AND ERRATA TO APPLICATION - 1
Order No. 36446 on January 27, 2025, indicating, in part, that it intended to proceed under
Modified Procedure pursuant to the Commission's Rules of Procedure 201-204, IDAPA
31.01.01.201-204.
2. Petitions to Intervene were filed by Micron on January 27, 2025, by IIPA on
February 12, 2025, and by ICIP on February 17, 2025.The Commission granted Micron's
intervention in Order No. 36460 issued on February 10, 2025, the IIPA's intervention in
Order No. 36479 issued on February 24, 2025, and ICIP's intervention in Order No. 36483
issued on March 3, 2024.
3. On February 20, 2025, the IIPA filed its Objection to Modified Procedure,
Demand for Hearing, and Motion to Consolidate for Hearing with Interrelated Cases
("Objection and Motion"), which ICIP concurred with in a filing dated February 27, 2025.
4. Following a hearing on IIPA's Objection and Motion held on March 25, 2025,
the Commission issued Order No. 36547 denying IIPA's motion to consolidate but
sustaining its objection to the processing of the case by Modified Procedure, ordering
instead that the issues in this case be resolved through a technical hearing.
5. As a result of Order No. 36547 issued by the Commission on April 15, 2025,
Idaho Power confirms that it is prepared to present its case in support of the relief
requested in its Application at a technical hearing, including the following testimony filed
contemporaneously herewith: the Direct Testimony of Connie G. Aschenbrenner, Direct
Testimony of Grant T. Anderson, and the Direct Testimony of Jared L. Ellsworth.
II. ERRATA TO APPLICATION
6. The Company recently became aware that its Application in this matter
includes an error in the request for relief section on page 11. More specifically, paragraph
31 states that the Company requests approval of the Energy Charge set forth in Schedule
SUPPLEMENT AND ERRATA TO APPLICATION - 2
28 through May 31, 2024, which had already passed at the time the Application was filed.
7. Accordingly, the Company provides the following correction to page 11 of
the Application to ensure accuracy, consistency, and clarity of the record:
31. Accordingly, as set forth more fully above, Idaho Power respectfully
requests the Commission issue an order approving: (1) the Micron FAB ESA,
included as Attachment 1; (2) the Contract Demand and Billing Demand charges
set forth in Schedule 28, included as Attachment 2, adjusted to reflect the
composite rate change authorized for special contract customers in Case No. IPC-
E-24-07; (3) the Energy Charge set forth in Schedule 28 through May 31, 2024
2025; and (4) authorizing the requested accounting treatment of energy sales
under the ESA.
This errata does not change anything else about the Application.
III. UPDATED COMMUNICATIONS AND SERVICE OF PLEADINGS
8. Communications and service of pleadings with reference to this Application
should be sent to the following:
Megan Goicoechea Allen Connie Aschenbrenner
Donovan Walker Grant Anderson
Regulatory Dockets Timothy E. Tatum
Idaho Power Company Idaho Power Company
1221 West Idaho Street (83702) 1221 West Idaho Street (83702)
P.O. Box 70 P.O. Box 70
Boise, Idaho 83707 Boise, Idaho 83707
mgoicoecheaallenCa-),idahopower.com caschenbrenner(a�idahopower.com
dwalker(oDidahopower.com ganderson(oDidahopower.com
dockets idahopower.com ttatumCcbidahopower.com
Respectfully submitted this 30t" day of April 2025.
4ur
I fACC�P.aI
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
SUPPLEMENT AND ERRATA TO APPLICATION - 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 30th day of April 2025, 1 served a true and correct
copy of Idaho Power Company's Supplement and Errata to Application 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(apuc.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 17' Street, Suite 3200 darueschhoff(a)hol land hart.com
Denver, CO 80202 tnelson hol land hart.com
awiensen(cDhol land hart.corn
karoach hollandhart.com
aclee(aDhollandhart.com
Idaho Irrigation Pumpers Association, Hand Delivered
Inc. U.S. Mail
Eric L. Olsen Overnight Mail
ECHO HAWK & OLSEN, PLLC FAX
505 Pershing Avenue, Suite 100 FTP Site
P.O. Box 6119 X Email
Pocatello, Idaho 83205 elo echohawk.com
Lance Kaufman, Ph.D. Hand Delivered
2623 NW Bluebell Place U.S. Mail
Corvallis, OR 97330 Overnight Mail
FAX
FTP Site
X Email Iance(a)aegisinsight.com
SUPPLEMENT AND ERRATA TO APPLICATION -4
Industrial Customers of Idaho Power Hand Delivered
Peter J. Richardson U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27t" Street FAX
Boise, Idaho 83702 FTP Site
X Email peter(a�richardsonanadams.com
Dr. Don Reading Hand Delivered
280 S. Silverwood Way U.S. Mail
Eagle, Idaho 83716 Overnight Mail
FAX
FTP Site
X Email dread ing(�D_mindspring.com
Clean Energy Opportunities of Idaho Hand Delivered
Kelsey Jae U.S. Mail
Law for Conscious Leadership Overnight Mail
920 N. Clover Dr. FAX
Boise, ID 83703 FTP Site
X Email kelsey(a-)kelseyjae.com
Courtney White Hand Delivered
Mike Heckler U.S. Mail
Clean Energy Opportunities for Idaho Overnight Mail
3778 Plantation River Drive, Suite 102 FAX
Boise, Idaho 83703 FTP Site
X Email
courtneV(a-)_cleanenergyopportunities.com
mike@cleanenergyopportunities.com
Stacy Gust
Regulatory Administrative Assistant
SUPPLEMENT AND ERRATA TO APPLICATION - 5