20250730Rebuttal Testimony.pdf

RECEIVED
July 30, 2025
IDAHO PUBLIC
Kelsey Jae (ISB No. 7899) UTILITIES COMMISSION
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Phone: [phone]
[e-mail]
Attorney for Clean Energy Opportunities for Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO
POWER COMPANY'S
APPLICATION FOR APPROVAL
OF SPECIAL CONTRACT AND CASE NO. IPC-E-24-44
TARIFF SCHEDULE 28 TO
PROVIDE ELECTRIC SERVICE TO
MICRON IDAHO
SEMICONDUCTOR
MANUFACTURING(TRITON) LLC.
REBUTTAL TESTIMONY OF MICHAEL HECKLER
On Behalf Of
CLEAN ENERGY OPPORTUNITIES FOR IDAHO

I Q: Please state your name, business affiliation, and address.
2 A: Michael Heckler, Policy Director, Clean Energy Opportunities for Idaho, 3778 N
3 Plantation River Dr Suite 102, Boise, ID 83714.
4
5 Q: On whose behalf are you testifying in this proceeding?
6 A: I am testifying on behalf of Clean Energy Opportunities for Idaho (CEO). The mission
7 of our nonprofit is to bring problem-solving rigor and solution-focused approaches to
8 advance clean energy and better serve the long-term interests of Idahoans and future
9 generations.
10
11 Q: Please describe your experience and qualifications.
12 A: I have a Bachelor's degree in Accounting from Seattle University and MBA and JD
13 degrees from the University of Washington. I have been employed in various business
14 fields, including banking, aerospace and renewable electric energy generation with
15 analytical and managerial assignments both within the United States and internationally.
16
17 I have actively participated in Idaho Power's resource planning processes since 2002 and
18 have been engaged in regulatory matters impacting Idaho's transition to clean energy since
19 then. I have served as the Policy Director of Clean Energy Opportunities for Idaho since its
20 founding in 2021.
21
22 Q: What is the purpose of your testimony?
23 A: The purpose of my testimony is to address issues inherent in the treatment of the costs
24 caused by the enormous new"megaload"that Triton represents. It is my contention that
25 the proposed Energy Services Agreement(ESA) and its associated rate features merit more
26 extensive review and modifications in order to adequately serve the public's interest.
27
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 2
July 30, 2025 CEO

I I will support these assertions by rebutting and synthesizing portions of the testimony
2 provided in this case by Grant Anderson, Michael Eldred, Lance Kaufman, Representatives
3 Stephanie Jo Mickelson and Dan Garner. The purpose of my testimony is thus in the
4 context of CEO's goal to serve the long-term interests of Idahoans.
5
6 Q: What topics should be covered in the "extensive review and modification" of the
7 proposed ESA you referenced?
8 A: At least the following topical areas warrant review:
9 1. Do traditional analytical methods adequately apply to the unique megaload that
10 Triton represents?
11 2. Is the No-harm analysis adequate, as presented, to justify treatment of
12 incremental Triton resource requirements on an embedded capacity basis?
13 3. When does Triton transfer from a new"incremental" customer to an
14 "embedded" customer?
15 4. Given concerning provisions in the ESA, the potential for upcoming Legislation
16 and an already full platter of issues in the GRC dockets,would it be contrary to
17 public interest to leave these open matters unresolved in this case docket?
18 My testimony is organized into four sections below which speak to the four topics above.
19
20 Section 1: Implications of Triton load size on analytical methods
21
22 Q: Do you have concerns about how the parties' testimony addresses the question of
23 whether the Company's application of traditional "known and measurable" analysis
24 is sufficient to ensure fair and accurate treatment?
25
26 A: Yes. I have found multiple instances within the testimony provided by both Company
27 witnesses and other parry witnesses where the use of analytical methods from other cases
28 produces questionable results in light of Triton's unique size. In addition to concerns
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 3
July 30, 2025 CEO

I related to the magnitude of the Triton load requiring a careful review of proposed analysis
2 there are instances where the Company has relied upon outdated data sources to reach
3 conclusions that potentially harm non-Micron customers.
4
5 Q: Can you provide examples where parties have raised concerns on the use of outdated
6 data sources affecting the appropriateness of analyses provided to support the
7 proposed ESA?
8 A: Yes. On page 14 of his testimony Mr. Eldred suggests the proposed demand charges be
9 updated to reflect any changes in the 2024 limited rate case IPC-E-24-07. Additionally, on
10 page 12 he suggests that the proposed marginal energy charges should be updated to align
11 with the timeframe used for calculating marginal energy rates in case IPC-E-25-17.
12
13 A more substantive example of outdated data sources affecting analyses may be related to
14 comments from Mr. Kaufman on page 3 of his direct testimony where he points out the use
15 of 2023 IRP data inputs in the No-harm analysis. This matter is addressed more fully in
16 section 2 below.
17
18 Q: Does the proposed treatment of interconnection costs provide one example of an
19 inappropriate analysis?
20 A: Yes, Triton load is so large it can be compared to a series of traditionally sized new
21 special contract loads arriving every few months. There is no traditional special contract
22 load growth to use as a model for treatment here.
23
24 As an example, the traditional method for addressing customer specific incremental
25 interconnection costs may be inadequate to cover all incremental transmission costs the
26 Triton load will cause. On pages 4 and 5 of his testimony Mr. Eldred references section
27 6.1 of the ESA in the context of the appropriate upfront infrastructure costs necessary to
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 4
July 30, 2025 CEO

I "connect the Micron FAB to the system" are being collected. I am concerned that such
2 treatment is inadequate.
3
4 Section 6.1 of the ESA asserts that the existing construction and procurement agreements
5 cover necessary Interconnection Facilities to interconnect up to 416.2MW. Additionally,
6 Exhibit 3 to the Application shows contract demand on February 1, 2029 as being 396MW,
7 well under the 416.2MW threshold.
8
9 Yet by November of 2028 the 2025 IRP shows the need for:
10 "a new Mayfield substation, located southeast of Boise, will be required to
11 integrate the 500-kV line into the Treasure Valley 230-kV system. " (2025 IRP p.
12 75)
13
14 Exhibit 202 of Kaufman direct also notes:
15 "The (Mayfield) station is also required to improve transmission import capability
16 into the Treasure Valley."
17
18 The massive new Triton load southeast of Boise is so large that its effects on the
19 transmission system are not limited to those traditionally associated with physical
20 interconnection to the transmission or distribution system. Triton load will cause some
21 portion of requirement and associated costs of building a new Mayfield substation and
22 using that facility to serve rising loads "southeast of Boise" (2025 IRP p. 75). Kaufman
23 direct page 3 raises concerns that some portion of incremental transmission upgrades are
24 not being adequately charged to Triton.
25
26 The Company suggests that incremental transmission costs not be allocated to Triton
27 because the added transmission capacity offers opportunities, such as energy price
28 arbitration, that are hard to quantify and would need to be offset against the cost of adding
29 those transmission resources. Difficulty in quantifying the split of benefits between Triton
30 and other customers notwithstanding, some portion of the costs should accrue to Triton.
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 5
July 30, 2025 CEO

1
2 Similarly, building a new substation at Mayfield and connecting it to the 500kV system via
3 a Hemingway link would potentially provide benefits to more customers than just Triton.
4 But building that link two years earlier than the Midpoint-Mayfield 2030 connection adds
5 new market access and other system level benefits carries a present value cost, some
6 portion of which should be allocated directly to Triton.
7
8 Q: Can you suggest possible modifications to improve the proposed treatment of
9 interconnection costs?
10 A: Yes. Section 6.1 and any other relevant portions of the ESA should be amended to
11 make clear that any"additional transmission" costs not be limited to those needed as
12 traditional "Interconnection Facilities" and those costs should be covered by Triton making
13 additional upfront Contributions in Aid of Construction (CIAC).
14
15 Triton CIAC contributions to assets that provide benefits to both Triton and other
16 customers raise issues related to the characterization of incremental and embedded costs.
17 These issues are discussed in more detail below.
18
19 Q: Does the testimony include any other examples of the use of a traditional analytical
20 method in a fashion insufficient to ensure fair and accurate treatment?
21 A: Yes. Mr. Eldred acknowledges that the amount of additional capacity required to serve
22 the Micron FAB raises concern. His belief regarding the reasonableness of Energy and
23 Demand Charges is qualified by the assumption that the method applied to far smaller
24 contracts (Schedules 33 and 34) is a fair and reasonable method to apply to Triton's
25 megaload. See Eldred Direct, page 14:
26 "7 believe both the proposed Energy and Demand Charges are reasonable when
27 compared to recently approved special contracts (Schedules 33 and 34). However,
28 the amount of additional capacity required to serve the Micron FAB does create
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 6
July 30, 2025 CEO

I concerns whether Micron will pay their fair share of costs with the proposed
2 contract rates and if it will impact other customers as discussed earlier. "
3
4 I share the concern Mr. Eldred expressed because Schedules 33 and 34 are not appropriate
5 bases for analyzing Triton costs. Just because the Company may have accurately employed
6 methods used in Schedules 33 and 34 when calculating Triton rates does not ensure that
7 the Triton rates so calculated are fair or reasonable.
8
9 Regarding Schedule 33, Brisbie has a Clean Energy Your Way structure where Brisbie
10 procures its own power and as such is inherently different from Triton.
11
12 Regarding Schedule 34 for Lamb-Weston, that schedule basically involves about 14 or
13 15MWs of incremental load(its first 20 MW are addressed under Schedule 19). Lamb-
14 Weston's 14 or15MWs of incremental load is hardly an appropriate analogy for the
15 enormous incremental load Triton represents. Lamb-Weston's incremental load is a
16 fraction of 1% of the 2,102 average MW system load the 2025 IRP projects for 2026. By
17 comparison, the 507MW Triton summer load is 25 times larger portion of total system load
18 in 2030 (507MW divided by the 2807MW IRP projected 2030 average load).
19
20 For example, a decision on whether to directly track the incremental capacity costs for a
21 Lamb-Weston load that represents a .7% increase in requirements is not analogous to
22 Triton. The expected 18% of the system load at full Triton build-out is dramatically
23 different from the load change addressed in Schedule 34 treatment.
24
25 The rationale for justifying the use of embedded capacity costs in the Triton rate design is
26 deserving of a more rigorous review than has been provided by the Company to date.
27
28
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 7
July 30, 2025 CEO

I Section 2: The No-harm analysis and embedded capacity cost treatment
2
3 Q: Does testimony present sufficient evidence that treating Triton-caused incremental
4 capacity costs on an average embedded cost allocation method is insufficient and that
5 a comprehensive review of the proposed No-harm analysis is warranted?
6 A: Yes. The testimony in this docket provides sufficient evidence to call for a more
7 extensive review of the No-harm analysis. In my experience in regulatory matters before
8 the Idaho PUC, the Commission's interest in ensuring everyone pays their fair share has
9 prompted more thorough reviews over matters with far less financial impact to the average
10 customer, such as on-site generation. The potential for cost shifting in this docket is orders
11 of magnitude larger than any potential cost-shifting from residents and businesses with
12 self-generation to other customers. An updated No-harm analysis is warranted.
13
14 Mr. Kaufman's testimony contests the suggestion that 500MWs of new Triton load would
15 not cause substantial incremental capacity costs. I also observed during CEO's
16 participation in the IRPAC that a portfolio run in the 2025 IRP (Portfolio w I I I(d)
17 500MW, see 2025 IRP Appendix C p 47) shows a new 500MW load causes an increased
18 cost of more than $2.3 billion over the 20 year IRP analysis timeframe.
19
20 Mr. Kaufman uses data from this 500MW portfolio analysis to support his assertion that
21 the 2025 IRP shows 500MWs of new generation imposes an incremental revenue
22 requirement of$186/MWh (p. 22). While there are differences between the incremental
23 load Triton represents and the load assumptions in portfolio w I I I(d) 500MW, the
24 $186/MW is dramatically higher than the $62.79/MWh annual average charge he
25 calculates the proposed ESA would charge to Triton in 2026 for both energy and capacity.
26
27 Mr. Eldred also expresses concern about how uncertainty in underlying cost assumptions
28 could change the No-harm analysis conclusions, noting (Eldred Direct, p 20):
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 8
July 30, 2025 CEO

I "Changing resource costs are a strong possibility, especially given uncertainty in
2 the cost of resources that have occurred over the past five years and conditions that
3 continue to persist given the uncertainty in current federal economic policies. "
4
5 Q: Does the use of outdated data inputs and a reduced review duration call into question
6 the results of the Company's No-harm analysis?
7 A: Yes. In addition to the changing resource costs Mr. Eldred refers to on page 20 of his
8 testimony as potentially affecting the outcome of a No-harm analysis, Mr. Kaufman notes
9 that the proposed No-harm analysis assumed a smaller increase in system load attributable
10 to Triton than the load amounts in the ESA. Notwithstanding an assertion that Mr.
11 Anderson's comment (p 16) that an informal review by the Company's planning team
12 refuted Mr. Kaufman's concern, given the public's awareness of magnitude of cost issues
13 inherent in this docket such an informal review may not be adequate to provide an
14 appearance of fairness in this process.
15
16 The 10 year duration of the No-harm review is tied to a planning timeframe in Mr.
17 Ellsworth's testimony. Unlike most Aurora based test runs that calculate a net present
18 value based on 20 years of forecast costs, the No-harm analysis only covered 10 years
19 (2024-2033), two of which(2024 and 2025)had marginal Triton participation. The No-
20 harm portion of the analysis also was run as a decrement from the 2023 preferred portfolio
21 rather than the full 20-year based review of Portfolio w 111(d) 500MW in the 2025 IRP.
22 Each of these issues raises questions about the accuracy and sufficiency of the Company's
23 No-harm analysis
24
25 Q: Could the potential for cost shifting be avoided in a manner that would eliminate the
26 need to resolve factual disputes such as the validity of the proposed No-harm
27 analysis?
28 A: Yes. Mr. Kaufman notes that if Triton procured its energy on a competitive basis and
29 not through IPC's rate regulated entity, the issue of cost shifting and contract risk would be
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 9
July 30, 2025 CEO

I fully resolved. The testimony of Representatives Mickelsen and Garner implicitly presents
2 self-generation by large new customers rather than service through IPC's rate regulated
3 service as solution to some of these issues. Kaufman also notes (p 16) that Triton
4 procuring its energy directly would remove risk to other customers from the proposed
5 treatment of energy supplied to Triton as an energy sale in the PCA. Further he notes (p
6 17)that any ESA build-out schedule risk,proposed for mitigation via termination
7 payments, would be obviated by Triton procuring its energy requirements.
8
9 A similar set of risk reductions could be affected by expanding the use of up-front CIAC
10 payments beyond the scope envisioned in section 6.1 of the ESA. CIAC payments based
11 in amount on an estimate of the IPC capital expenditures that the incremental Triton load
12 causes and made "up-front" of those expenditures could reduce some of the concerns the
13 Company has expressed in general rate cases over regulatory lag. Under a process
14 somewhat analogous to the 30MW per year reduction in minimum billings, all incremental
15 capital costs could be covered by CIAC payments made by Triton and then credited back
16 to Triton over some measure of years to align with asset depreciation rates and affect a
17 gradual transition of Triton from an"incremental" customer status to an"embedded"
18 customer status.
19
20 Section 3: Transferring from a new "incremental" customer to an "embedded"
21 customer
22
23 Q: Does the testimony include any references to problems that arise from the proposal to
24 treat the incremental energy costs the Triton load imposes on the system on a
25 marginal basis and its incremental capacity costs on an embedded cost basis?
26 A: Yes. Both the Eldred and Kaufman testimonies address these matters as collectively
27 raising problems including when Triton would transition from a status as a"new customer"
28 charged marginal rates to an"existing" customer charged embedded rates. These matters
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 10
July 30, 2025 CEO

I are further complicated by the fact that the proposed ESA treats Triton energy costs on a
2 marginal cost basis while proposing an average "embedded" cost basis for capacity
3 (demand) charges.
4
5 Q: What types of issues are raised regarding when Triton would transition from a "new
6 customer"warranting marginal cost treatment to an "existing embedded" customer
7 status?
8 A: One example of such issues arises in Mr. Eldred's testimony(p 10)where he notes that
9 in section 7.2 of the proposed ESA Idaho Power agrees to reevaluate energy charges "after
10 the scheduled ramp period ends on September 30, 2030." Mr. Eldred expresses a concern
11 related to this option (p 11)because the
12 "Marginal Cost-Based Energy Charge is one of the major components of the
13 Special Contract that is mitigating the risk of higher costs caused by Micron's
14 incremental load from being passed to other customers."
15
16 Mr. Eldred suggests that the Company be required to show that shifting Triton energy costs
17 from marginal to embedded"will not harm other customers" (Eldred Direct,p 11).
18
19 The ESA seems to imply that for purposes of computing energy charges, Triton transitions
20 to an embedded customer status after September 30, 2030 or at least grants Triton the
21 option to do so. For matters related to demand charges, a gradual transition begins in 2030
22 and extends through 2047. Mr. Kaufman has concerns even with that 2047 transition date.
23
24 On p 20 of his testimony Mr. Kaufman raises a different type of concern about whether
25 even in 2047 the size of this one customer presents unique liquidity risks to IPC.
26 Effectively he argues that enormous customers like Triton can inherently never become
27 like other customers—and by implication, there never can be a transition of Triton to be
28 like other customers absent some treatment to reduce this liquidity risk.
29
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 11
July 30, 2025 CEO

I Both Eldred and Kaufman refer to 5-year period adjustments in their proposals, Eldred for
2 an extension beyond when Triton reaches 507MW of load to ensure Triton load reaches a
3 "steady state", Kaufman proposes that termination payments be adequate to cover 5-years
4 of lost revenue (p 20).
5
6 Q: Are the concerns about whether,when and how Triton load would eventually
7 transition from an "incremental" to an "embedded" status adequately resolved?
8 A: No. The existence of"take or pay provisions" inherently acknowledges that there are
9 risks of the cost of serving Triton's huge incremental load that persist after the ramp up
10 period. While Mr. Eldred's testimony (p 15)notes that take or pay provisions mitigate a
11 particular risk(stranded asset risk) related to "the incremental cost to serve the Micron
12 FAB"being imposed upon other customers, such ESA provisions do not address how
13 those Triton's incremental capacity costs are allocated among customers.
14
15 Similarly, Mr. Eldred's suggestion that a five-year extension be added to the potential
16 ramp period acknowledges that there are issues related to the timing of any Triton
17 transition from incremental to embedded customer status but does not resolve all of them.
18 Does the transition occur at the end of the period when the Triton load is "ramping"up and
19 at that time warrant changing the basis for Triton energy charges from a marginal to an
20 embedded rate? Does the transition occur on a specific date? Should a transition from
21 "new marginal"to "existing" customer affect both energy and demand charges?
22
23 There remains an open question concerning how long the Company's other customers
24 should be shielded from higher marginal cost Triton's new load introduces. Further
25 complicating matters is the fact that in the 2025 IRP marginal energy costs shift lower than
26 embedded in out years. Should Triton get lower than embedded energy rates?
27
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 12
July 30, 2025 CEO

I Questions related to the best policy for transitioning new large load customers like Triton
2 to full"embedded" customer status should be resolved before the ESA is approved.
3
4 Section 4: Open issues merit resolution in this case docket
5
6 Q: Should the Commission grant Final Regulatory Approval to the proposed ESA at this
7 time?
8 A: No. The proposed ESA (section 14) appears to condition the ESA becoming effective
9 upon the Commission granting"Final Regulatory Approval". There are many significant
10 open issues that should be resolved before ESA approval is granted.
11
12 One such example relates to a comment Mr. Eldred makes on page 23 of his testimony
13 regarding risk mitigation where he notes Commission jurisdiction regarding rate changes
14 as a third risk mitigation element. Specifically, that section 13.1 of the ESA notes:
15 "These terms are important to ensure the rates in the Special Contract can change
16 if the rates are not collecting a reasonable amount from the Micron FAB".
17
18 I am concerned that the contents of the following ESA section, 13.2, appear to constrain
19 the Commission's opportunities to change rates by requiring"substantial competent
20 evidence" showing such rate change is "just, fair, reasonable, sufficient, non-preferential,
21 and nondiscriminatory" and made under"the same standards that are applicable to Idaho
22 intrastate tariff rates". The concept of nondiscriminatory is inherently difficult to apply to
23 a load that is of a scale unlike any other.
24
25 The potential impact of this language needs to be addressed before approval of this ESA as
26 well as before setting any precedent that could constrain appropriate treatment of the next
27 megaload customer.
28
29 Another concern arises from page 24 of his testimony where Mr. Eldred recommends:
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 13
July 30, 2025 CEO

I "First, I recommend that the Company isolates the effect of new special contract
2 customers when cost allocation and rates need to be set for these customers in
3 future general rate cases, and develop methods to ensure other customers are not
4 harmed. "
5
6 I see two sources of concern. One is based on my belief that the very significant issues
7 related to the cost allocation proposed for Triton should be resolved before proceeding to
8 any future general rate case. The second is based on my observation during the two most
9 recent rate cases that the number of open issues presented in such cases is so large that
10 fundamental issues of cost allocation treatment for specific customers are unlikely to get
11 the attention that their significance warrants.
12
13 Another reason to resolve the concerns listed above before approving the proposed Triton
14 ESA comes from the testimony of Representatives Mickelsen and Garner. In Exhibit 205
15 they present proposed draft legislation including a proposed new section 61-335 to the
16 Idaho Code, (6) (a) of which, allows the Commission to:
17 "promulgate rules, subject to legislative approval, to implement provisions of this
18 section and to provide reasonable assurance that the new large loads will not
19 cause the rates charged to the public utility's other customers to increase. "
20
21 Delaying the resolution of these open issues by deferring their consideration until some
22 future general rate case or expecting a comprehensive solution to arise from a crowded
23 future Legislative session would, in my opinion,be sub-optimal.
24
25 Q: How should these matters be addressed?
26 A: These matters should receive a comprehensive review at the October 28 technical
27 hearing. If all issues cannot be resolved in that forum additional sessions should be
28 undertaken. The public interest would be harmed if the Commission were to delay
29 reviewing matters which are clearly within its existing jurisdiction to review.
30
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 14
July 30, 2025 CEO

I Triton deserves to know what rate it will face as it begins operations of the new FAB even
2 if that beginning may be delayed. But the public's interest will not be served without
3 resolution of questions surrounding whether and how Triton should pay for both the
4 incremental energy and capacity costs its new load causes. Guidelines on how and when
5 new large customers transition from an"incremental" customer status to an"embedded"
6 customer status should be developed.
7
8 Perhaps the Commission should establish a presumption that new large loads above some
9 size cause incremental capacity costs directly assignable to the new customer, and allow
10 that presumption to be rebutted by a No-harm analysis that is based on"substantial
11 competent evidence" and that shows the result is "just, fair, reasonable, sufficient, non-
12 preferential, and nondiscriminatory" in its impact upon existing customers.
13
14 As it was submitted, the proposed ESA should not be approved. I propose that the
15 Commission implement a process in this docket which provides Triton temporary rate
16 guidance now, and which directs a process for further review of open matters as
17 highlighted in testimony. Such a review should also include development of a time-varying
18 rate structure as requested in White Direct testimony on behalf of CEO.
19
20 Q: Does this conclude your rebuttal testimony in this proceeding?
21 A: Yes, it does.
Case No. IPC-E-24-44 Heckler, M. (Rebuttal) 15
July 30, 2025 CEO

CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of July, I delivered true and correct copies of the
foregoing REBUTTAL TESTIMONY to the following persons via the method of service noted:
Electronic Mail Delivery (See Order No. 34602)
Idaho Public Utilities Commission
Monica Barrios-Sanchez
Commission Secretary
secretaryPpuc.idaho.gov
Idaho PUC Staff
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
chris.burdin(a puc.idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Connie Aschenbrenner
Grant Anderson
mg,oicoecheaallenOidahopower.com
dwalkerPidahopower.com
[e-mail]
gandersonOidahopower.com
dockets(cDidahopower.com
Industrial Customers of Idaho Power, Inc.
Peter J. Richardson
Dr. Don Reading
peterPrichardsonadams.com
dreadin @mindsprin .com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
eloPechohawk.com
lance anaepisinsight.com
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - HECKLER REBUTTAL - IPC-E-24-44

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart, LLP
darues chhoff0hollandhart.com
tnelson0hollandhart.com
awj ensen(a)hollandhart.com
aclee hollandhart.com
karoach0hollandhart.com
'U
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - HECKLER REBUTTAL - IPC-E-24-44