20250523Petition to Intervene.pdf

RECEIVED
May 23, 2025
IDAHO PUBLIC
Austin Rueschhoff, ISB No. 10592 UTILITIES COMMISSION
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
HOLLAND&HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF COMMISSION ) CASE NO. GNR-E-25-01
STAFF'S APPLICATION FOR APPROVAL )
OF AN OVERSIGHT PROCESS FOR THE ) PETITION TO INTERVENE OF
ACQUISITION OF LARGE SUPPLY-SIDE ) MICRON TECHNOLOGY, INC.
ELECTRICAL RESOURCES )
Micron Technology, Inc. ("Micron"or"Intervenor"),pursuant to the Commission's Rules
of Procedure 71 through 74,1 hereby petitions the Commission for leave to intervene and to appear
and participate in this proceeding as a party and as grounds therefore states:
1. The name and address of this Intervenor is:
Micron Technology, Inc.
c/o Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland&Hart LLP
555 17th Street, Suite 3200
Denver, CO 80202
' Idaho Admin.Code 31.01.01.071—.074.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
GNR-E-25-01

Telephone: [phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Copies of all pleadings, production requests, production responses, Commission orders,
and other documents should be provided to:
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland&Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
[phone]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
2. Micron receives electric utility services from Idaho Power Company ("Idaho
Power") as a Special Contract customer, taking service under Schedule 26. Micron is Idaho
Power's single largest customer. In this proceeding, Staff requests the Commission open a
rulemaking to modify the Request for Proposal ("RFP") oversight process. Specifically, Staff
states its objective to create a process which ensures generation resources are least-cost and least-
risk based on the specific circumstances and needs of a utility's system. Staff also states that Idaho
should develop its own RFP procedures and not rely on other states' processes because other states
may not share the same policy priorities as Idaho.
3. As a large customer, Micron has a direct and substantial interest in ensuring that
Idaho Power's electric service is reliable and rates are just and reasonable. The type,mix, and cost
of generation resources a utility chooses to build and purchase directly correlate to the reliability
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
GNR-E-25-01

and rates of their utility service. Additionally,as a member of the Idaho Power Integrated Resource
Plan Advisory Council("IRPAC"),Micron has an interest in Idaho Power's resource planning and
selection of the types of resources that are used to serve Micron. These are all issues that will be
affected by the outcome of this proceeding and the Commission's RFP rules. Without the
opportunity to intervene, Micron would be without adequate means to participate in this
proceeding that will have a material impact on its electric service.
4. Micron recognizes that this Petition to Intervene is being filed after the deadline
established in the Commission's Notice of Application and Notice of Intervention Deadline Order
No. 36549. However, the Commission's Rule of Procedure 732 permits the Commission to grant
untimely petitions to intervene for good cause shown. Good cause exists here. Micron is a party
to Idaho Power's Jackalope Wind Certificate of Public Convenience and Necessity ("CPCN")
proceeding, Case No. IPC-E-24-46, and has a substantial and direct interest in the outcome of that
proceeding. On May 13, 2025, after the intervention deadline in this case, Commission Staff
submitted its comments in the Jackalope Wind CPCN proceeding. In such comments,Commission
Staff noted concerns about the types of resources that Idaho Power accepted in its RFP that resulted
in the Jackalope Wind Project. However, Staff further stated that it is addressing that issue in a
separate case, referring to this case, GNR-E-25-01. Because the outcome of this case may impact
Idaho Power's Jackalope Wind CPCN proceeding and will certainly impact future Idaho Power
RFP's, Micron has a direct and substantial interest in this proceeding that justifies granting this
Petition to Intervene.
2 Idaho Admin.Code 31.01.01.073.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
GNR-E-25-01

5. Granting Micron's Petition to Intervene will not disrupt this proceeding, prejudice
existing parties, or unduly broaden the issues in this proceeding. Micron understands that a
Procedural Order in this case has not yet been set,but Micron agrees to be bound by all prior orders
and notices in this proceeding as required by Rule of Procedure 73. Additionally, Micron
conferred with all current parties in this proceeding and no party opposes Micron's intervention.
6. Micron intends to participate herein as a party, and if necessary, to introduce
evidence, cross-examine witnesses, call and examine witnesses, and be heard in argument. The
nature and quality of evidence Micron will introduce is dependent upon the nature and effect of
other evidence in this proceeding.
WHEREFORE,Micron Technology,Inc.respectfully requests that the Commission grant
its Petition to Intervene in this proceeding and to appear and participate in all matters as may be
necessary and appropriate; and, if necessary, to present evidence, call and examine witnesses,
present argument and to otherwise fully participate in this proceeding.
3 The current parties are Commission Staff,Avista Corporation,Idaho Power Company,Industrial Customers of
Idaho Power,Northwest Intermountain Power Producers Coalition,and Rocky Mountain Power.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
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Respectfully submitted May 23, 2025.
HOLLAND & HART, LLP
By:
Austin Rueschhoff, ISB No. 105
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
GNR-E-25-01

CERTIFICATE OF SERVICE
I hereby certify that on May 23, 2025, a true and correct copy of the within and foregoing
PETITION TO INTERVENE OF MICRON TECHNOLOGY,INC. IN CASE NO. GNR-E-25-01
was served in the manner shown to:
Electronic Mail
Commission Staff Industrial Customers of Idaho Power
Chris Burdin Peter J. Richardson
Mike Louis Richardson Adams, PLLC
Monica Barrios-Sanchez 515 N. 27th Street
Commission Secretary Boise, ID 83702
Idaho Public Utilities Commission petergrichardsonadams.com
11331 W. Chinden Blvd., Building 8, -
Suite 201-A
Boise, ID 83714
Chris.burdinkpuc.Idaho.gov
mike.louis(&puc.idaho.gov
secretgakpuc.idaho.gov
Northwest&Intermountain Power Producers
Coalition
Gregory M. Adams Irion Sanger
Richardson Adams, PLLC Sanger Law, PC
515 N. 27th Street 4031 SE Hawthorne Blvd.
Boise, ID 83702 Portland, OR 97214
greg(a,richardsonadams.com irion(asanger-law.com
Spenser Gray
Northwest&Intermountain Power Producers
Coalition
P.O. Box 504
Mercer Island, WA 98040
sgray&nippc.org
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
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Idaho Power Company Avista Utilities
Donovan E. Walker David J. Meyer
Matt Larkin Shawn Bonfield
Idaho Power Company Avista Utilities
1221 W. Idaho Street(83702) P.O. Box 3727
PO Box 70 1411 E. Mission Avenue, MSC 13
Boise, ID 83707-0070 Spokane, WA 99220-3727
dwalkeraidahopower.com david.me er0)avistacorp.com
docketskidahopower.com shawn.bonfield&avistacorp.com
mlarkin0idahopower.com AvistaDocketskavistacorp.com
Rocky Mountain Power
Mark Alder Joe Dallas
Rocky Mountain Power Rocky Mountain Power
1407 West North Temple, Suite 330 825 NE Multnomah, Suite 2000
Salt Lake City, UT 84116 Portland, OR 97232
mark.alder(a,pacificorp.com joseph.dallas(kpacificorp.com
datarequestkpacificorp.com
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland& Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
darueschhoff(a hollandhart.com
tnelson(a,hollandhart.com
awj ens ennhollandhart.com
karoachkhollandhart.com
aclee(d,hollandhart.com
s/Adele Lee
34886976_v2
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MICRON TECHNOLOGY, INC. PETITION TO INTERVENE
GNR-E-25-01