20250815Surrebuttal Testimony CEO - M. Heckler.pdf

RECEIVED
August 15, 2025
Kelsey Jae (ISB No. 7899) IDAHO PUBLIC
Law for Conscious Leadership UTILITIES COMMISSION
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.
SURREBUTTAL TESTIMONY OF MICHAEL HECKLER
On Behalf Of
CLEAN ENERGY OPPORTUNITIES FOR IDAHO

1 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: Are you the same Michael Heckler who submitted Rebuttal testimony on behalf of
12 Clean Energy Opportunities for Idaho on July 30t" in this case?
13 A: Yes I am.
14
15 Q: What is the purpose of this testimony?
16 A: The purpose of this testimony is to reply to certain matters raised in the rebuttal
17 testimony of Mr. Anderson, Mr. Ellsworth and Mr. Gorman with some references to the
18 direct testimony of Mr. Eldred and Dr. Kaufman. Silence on my part related to other
19 matters presented in theirs or other testimony in this case should not be taken to signify
20 my acceptance of any assertions related to those other matters.
21
22 Q: How is your testimony organized?
23 A: My testimony has been divided into the following topical areas:
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 2
August 15, 2025 CEO

1 1. The no-harm analysis as presented is structurally flawed and grossly inadequate to
2 support a conclusion that the use of an embedded demand cost approach will not
3 significantly harm non-Micron Fab customers.
4 2. There is a substantial difference between showing that a cost allocation
5 methodology will not harm other customers and the setting of specific prices
6 under that methodology.
7 3. Resolution of whether the use of an embedded demand cost approach should be
8 applied in calculating the revenue required from Micron Fab should be resolved in
9 proceedings initiated under this docket and before Micron Fab pricing is reviewed
10 in any general rate case.
11
12 Section 1 —Flaws and inadequacies in the no-harm analysis and their implications
13
14 Q: Does the no-harm analysis provide a unique form of review as related to protecting
15 non-Micron Fab customers from shifting incremental costs caused by Micron Fab?
16 A: Yes it does. Mr. Eldred, in his direct testimony', lists multiple terms in the ESA that
17 provide protection to the Company and indirectly to its customers including what have
18 been referred to as "take or pay"minimum billing provisions, termination payment
19 provisions and creditworthiness features.
20 I agree that these provisions provide the Company, and indirectly its customers,
21 with protections from Micron Fab incremental resources becoming stranded assets. What
22 those provisions do not do, and only the no-harm analysis addresses, is to protect non-
Eldred Direct page 22.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 3
August 15, 2025 CEO

1 Micron Fab customers from paying too large a share of the cost for the incremental
2 resources that the Micron Fab load will require.
3
4 Q: Did Commission staff, as reflected in Mr. Eldred's testimony, recognize the
5 possibility of future load shifting arising from customers whose share of total system
6 load is rising exceptionally rapidly?
7 A: Yes, Mr. Eldred recognized that unequal growth rates between classes will "continue
8 to be important as the number of large-load customers, who drive in a large amount of
9 `system' resources and seek electric service through special contracts are projected to
10 increase in the near future."'
11 To address this matter Mr. Eldred further commented:
12 `1 recommend that the Company isolate the effect of this dynamic when cost
13 allocation and rates need to be set for these customers in future general rate
14 cases and develop methods to ensure other customers are not harmed.
15
16 Exhibit 102, attached to Mr. Eldred's testimony, displays that in response to a
17 query regarding how Micron Fab Schedule 28 issues would be addressed in future rate
18 cases, the Company replied in part:
19 While the Company has not yet identified the exact method, it anticipates
20 proposing a "known and measurable"adjustment be applied to the test year to
21 account for the Micron Fab billing determinants during the scheduled ramp
22 period.'
23
24
25 Q: Do you find the implications of those comments concerning?
26 A: These comments leave me with several sources of concern including:
2 Eldred Direct page 9.
3 Eldred Direct Exhibit 102, Response to Staff Production Request No. 4.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 4
August 15, 2025 CEO

1 • Given the fact that the Company does not have a method for incorporating Schedule
2 28 in future rate cases, use of a"known"method implies the use of a historical
3 method which may not apply to the unique, new issues the magnitude of the Micron
4 Fab load imposes;
5 • The proposed term states that adjustments to Schedule 28 would only apply"during
6 the scheduled ramp period,"has implications for how and when Micron Fab would
7 transfer from a uniquely massive new customer to an existing customer; and
8 • Mr. Eldred focuses on new large-load customers projected"in the near future' rather
9 than addressing the potential for harm to other customers from the current Micron
10 Fab "large-load customer".
11
12 Q: Why do you question whether the Company has used appropriate methods to
13 ensure other customers are not harmed when conducting its no-harm analysis in
14 this case?
15 A: I believe the no-harm analysis performed in this case is grossly inadequate to ensure
16 other customers are not harmed for two reasons: 1) outdated or inappropriate data values
17 were input to the Aurora based model and 2)the analysis assumptions used in reviewing
18 the outputs from the Aurora model warrant careful review for inherent bias.
19
20 Q: What specifically do you see as outdated or inappropriate data values used as inputs
21 to Aurora for modeling the no-harm calculations?
22 A: Several statements made within previously submitted testimony mention that the
23 2024 through 2033 timeframe used in the no-harm analysis may no longer be appropriate,
24 that estimates of the timing and magnitude of Micron Fab load growth are now different
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 5
August 15, 2025 CEO

1 from those used in the no-harm analysis, and that resource cost estimates from taken from
2 the 2023 IRP and used in the no-harm analysis are also now different.
3 But the most substantive of those resource cost changes has not been specifically pointed
4 out.
5 As Mr. Ellsworth pointed out in his testimony regarding the no-harm analysis,
6 when compared to the "without Micron"run the "with Micron"Aurora run moved the
7 timing of some solar and wind resource acquisitions but it also added more batteries,
8 demand response and 261MWs of new gas-fired capacity via an upgrade of the existing
9 Valmy generation facility from coal-fired to gas-fired.
10 Conceptually the Aurora model can add multiple increments of the same type of
11 resource and it often does add solar or batteries year after year. The Valmy upgrade was
12 a unique type of resource addition—available only one time. The Valmy upgrade also
13 had another exceptional characteristic—it was cheap.
14 The table below shows how inexpensive (from a capital expenditure perspective)
15 the Valmy upgrade was when compared to other gas-fired generation alternatives'.
16
'NV Energy has reported the cost to upgrade their half of the cost to upgrade the North Valmy
Generating Station to gas-fired at $83 million.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 6
August 15, 2025 CEO

Incremental gas-fired generation resource alternatives
Number of
Nameplate units Total capital Additonal
Resource Captial cost cost for
per unit required to outlay above
type ($/Kw) equivalent
(MWs) substitute Valmy baseline
for Valmy required units
Valmygas $ 320 261 1 $ 83,520,000 $ -
upgrade
CCCT $ 1,841 300 1 $552,300,000 $468,780,000
SCCT $ 1,391 150 2 $417,300,000 $333,780,000
1 Recip $ 2,587 50 6 $776,100,000 $692,580,000
2
3 If the no-harm analysis were to be re-run using updated load values and resource
4 costs as included in the more recent 2025 IRP iteration, a dramatically higher cost
5 difference could occur between the "with Micron Fab" and"without Micron Fab"runs.
6 Assuming that the updated no-harm Aurora run were subject to the same restriction as
7 used in 2025 portfolio development(that certain procurements - including the Valmy
8 upgrade - were already committed and not selectable during either run) a dramatically
9 higher"with Micron Fab" cost would result if its 500MW load required an incremental
10 gas fired resource.
11 Allocating the "one-time-only" low-cost Valmy upgrade to Micron Fab when the
12 Company ran the no-harm analysis in 2023 could well have understated the true
13 incremental resource costs the Micron Fab load will impose on the system by several
14 hundred million dollars. A careful review of an updated no-harm analysis is warranted.
15
16 Q: What concerns do you have regarding the analysis assumptions the Company used
17 when reviewing the outputs calculated by Aurora for the no-harm analysis?
18 A: At least two aspects of the analysis methods the Company used in its no-harm
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 7
August 15, 2025 CEO

I analysis concern me: 1)the value the Company used for weighting the portion of
2 embedded costs assigned to Micron Fab and 2)the characterization of costs for new
3 resource as embedded rather than incremental.
4
5 Q: Can you explain first your concerns with how the Company chose to allocate
6 portions of the costs it characterized as embedded between Micron Fab and non-
7 Micron Fab customers?
8 A: At its core the no-harm analysis broke demand resource costs into three categories
9 and then proposed to allocate those costs between Micron Fab and non-Micron Fab
10 customers. Those three categories were: 1) exiting embedded resource costs, 2)the costs
11 for newly acquired transmission resources and 3) comparable costs for newly acquired
12 generation resources.
13 I ask that we keep in mind that the Company presents the new Micron Fab load as
14 being at a very high load factor—essentially flat all year long. But when the no-harm
15 analysis was conducted all three categories of costs were allocated to Micron Fab based
16 not on its average use throughout the year but on Micron Fab's usage during the one hour
17 of the year when Micron Fab's share of system load is the smallest portion.
18 Note that the Company characterizes all three categories of costs as if they were
19 "embedded" and not"incremental". Now if the new resources were considered to be
20 "incremental" one could make an argument that they should be allocated based on load
21 conditions during the peak load hour in which the requirement for such incremental
22 resources arose. But the Company doesn't do that. They treat all three categories of
23 resources as if they are already embedded.
24 By allocating embedded costs based on the Micron Fab's average annual usage
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 8
August 15, 2025 CEO

1 rate of embedded resources rather than the much lower ratio based on its use during the
2 single peak hour of the year, the estimated demand cost imposed by the Micron Fab load
3 over the period 2024-2033 increases by %.
4 Mr. Gorman says (page 8)that Micron Fab will pay a"proportional share" of
5 capacity resource costs. The question is what proportion is fairly allocated to Micron
6 Fab. Using the estimate Dr. Kaufinan calculated for the annual price per MW implied in
7 Schedule 28 at$62.79/MWh and subtracting out the proposed flat energy charge of
8 $34.86/MWh, leaves us with an implied annual average demand charge of$28/MWh. If
9 that $28 estimate were to be increased by.% it would raise the $62.79/MWh annual
10 Schedule 28 price Dr. Kaufman calculated to $MMWh.
11 In sum, the magnitude of potential inaccuracy resulting from subjective choices
12 made in the no-harm analysis to support the proportional allocation of embedded costs
13 between Micron Fab and Non-Micron Fab customers is sufficient to merit review.
14
15 Q: What concerns you with the characterization of costs for new resource as embedded
16 rather than incremental in the no-harm analysis?
17 A: In explaining my concerns about how the no-harm analysis handled incremental
18 resource costs, I ask the Commission take notice of two other cases currently open- the
19 2025 IRP and Idaho Power's 2025 general rate case.
20 The image below was taken from the 2025 IRP. It is presented to call attention to
21 the overwhelming portion of increased electricity sales characterized as "additional firm
22 sales" in the 2026 to 2032 period.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 9
August 15, 2025 CEO

30,000
25,000
20,000
15,000
10,000
5,000
0
2004 2009 2014 2019 2024 2029 2034 2039 2044
■Residential ■Commercial ■Ind ustrial Irrigation ■Additional Firm Sales
Figure 3.Composition of system company electricity sales (thousands of MWh)
1
2 Notice is also requested of the 17%rate increases requested for residents and
3 irrigators in the Company's current rate case. One might reasonably expect that families
4 and farmers who face a very large rate increase would wonder if the new megaload that
5 Micron Fab represents is not somehow behind that cost growth. But the way the
6 Company modeled Micron Fab caused incremental resource cost growth in its no-harm
7 analysis was to spread almost all of those incremental costs to all customers rather than
8 assigning them directly to the Micron Fab.
9 The ESA already contemplates some incremental transmission charges being
10 assigned directly to Micron Fab. These traditional interconnection costs are covered by
11 the Micron Fab making contributions in aid of construction(CIAC)payments. The
12 Company argues that all other transmission resource additions during the relevant period
13 provide benefits to all customers and thus treats those costs the same way it treats
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 10
August 15, 2025 CEO

1 existing embedded asset costs.
2 Other parties have viewed incremental transmission costs in a different fashion,
3 with Dr. Kaufman suggesting that substantial portions of such costs warrant a direct
4 assignment to Micron Fab while my rebuttal testimony asserted that some portion of the
5 costs associated with the Mayfield substation and its early installation should accrue to
6 Micron Fab.
7 But, in its no-harm analysis, not only did the Company not directly assign any
8 incremental transmission costs to Micron Fab, it treated all incremental transmission
9 costs as if they were embedded costs and allocated those costs between Micron Fab and
10 non-Micron Fab customers via the peak share of load ratio described above.
11 More concerning is the fact that while the no-harm analysis does identify a significant
12 amount of generation expenses as being Micron Fab caused incremental procurements, it
13 also allocates those incremental costs between Micron Fab and non-Micron Fab
14 customers as if these incremental generation resources were embedded assets.
15 If, for purposes of simplicity at this time,we just allocate directly to Micron Fab
16 the incremental costs associated with the new generation resources it required and treat
17 all incremental transmission expenditures as if they are embedded assets,the effect is to
18 increase the estimated demand charge by■% over the baseline value the company
19 used in its no-harm analysis.
20 Using the same methodology listed above based on Dr. Kaufman's estimate of
21 Schedule 28 average annual costs per MWh of$62.79 and netting out the $34.86 energy
22 charge for an implied demand charge of$28/MWh, raising that$28 by■%produces an
23 estimate that Schedule 28 should reflect an annual average charge of$ItMWh.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 11
August 15, 2025 CEO

I Section 2 —Cost Allocation vs. the Setting of Prices
2
3 Q: Are there significant differences in the way Company witness Grant Anderson
4 presents the characteristics of the no-harm analysis in his direct and his rebuttal
5 testimony?
6 A: Yes, there are. In his direct testimony submitted on April 30th Mr. Anderson stated
7 that the no-harm analysis showed that the cost to serve all other customers was lower in
8 the scenario that included Micron Fab than in the scenario without the new Micron Fab
9 load and concluded that a methodology which allocated Micron Fab a"load ration share
10 of both embedded and future system resources""is not expected to cause rates to increase
11 for"all other customers".
12 In his July 301 rebuttal testimony Mr. Anderson's comments were more
13 restrained, saying:
14 "The no-harm analysis was provided as a directional tool to help evaluate
15 whether the proposed initial pricing structure could reasonably mitigate cost
16 shiftings".
17
18 Q: Do the Company's rebuttal comments reflect an inconsistency in how it values
19 "directional" signals?
20 Yes, the Company does not appear to be consistent with regard to how"directional"
21 signals should be interpreted. I do not disagree with the inappropriateness of using Dr
22 Kaufman's analysis for setting pricing but Dr. Kaufman's analysis does provide a
23 valuable check on the accuracy of the proposed no-harm analysis.
24 Even if one accepts the contention of Mr. Ellsworth and Mr. Gorman that the
" Anderson Direct page 15.
6 Anderson Di-Reb page 21.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 12
August 15, 2025 CEO

1 Kaufinan analysis double-counts some costs, both of their rebuttal comments ignore the
2 fact that even after"correction" from $186/MWh to $95/MWh that hourly cost estimate
3 is still 50%higher than the $62/MWh Dr. Kaufman saw as implied by the proposed
4 Schedule 28 pricing.
5 Fifty percent higher is certainly a directional signal.
6
7 Q: Would it be unduly discriminatory to charge Micron Fab demand related costs
8 calculated on an incremental rather than an embedded cost basis?
9 No, the Commission is precluded from discriminating between customers within a given
10 class but the use of special contracts inherently involves a differentiation between very
11 large customers. Mr. Gorman's suggests that Micron Fab should not be subjected to:
12 discriminatory treatment by subjecting Micron to terms and conditions that the
13 Commission did not require for other recent special contracts
14
15 This comment is inconsistent with the inclusion of terms in the ESA covering
16 creditworthiness, termination payments and"take or pay"provisions that are not found in
17 all "other recent special contracts". Micron Fab's unique load size differentiates it from
18 other special contract customers and those differences warrants different cost treatment.
19
20 Q: Does Mr. Gorman acknowledge that the Micron Fab load is of an unprecedented
21 size among all of Idaho Power's customers?
22 A: Yes, Mr. Gorman affirms that the Micron Fab load is atypical,
23 Micron is certainly an atypical Idaho Power customer'
24
7 Gorman Di-Reb page 10.
8 Gorman Di-Reb page 3.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 13
August 15, 2025 CEO

I But the Micron Fab load is not only atypical, it is of an unparalleled size. As
2 CEO noted in comments submitted in this docket on March 21, 2025:
3 If the Micron Fab load increases at the rates presented for Contract Demand in
4 Exhibit 3 of the IPC/Micron Fab contract, then Micron Fab annual load will
5 exceed the entire annual load for whole Idaho jurisdiction customer classes,
6 including:
7
8 •By June 2026 Micron Fab load exceeds all 4 existing Special Contracts
9 •By October 2027 Micron Fab load exceeds all 27,000 Irrigation customers
10 •By February 2028 Micron Fab load exceeds all 120 Large Industrial customers
11 •By June 2030 Micron Fab load exceeds all 38,000 Commercial customers
12
13 The magnitude of the Micron Fab loads makes Micron Fab unlike any other
14 customer. As a unique level of load Micron Fab has no analogous customer against
15 which it would receive a discriminatory treatment. But magnitude of the new Micron
16 Fab load certainly does warrant treatment separate from that employed in recent special
17 contracts.
18
19 Q: How do you respond to Mr. Gorman's concerns about setting Micron Fab revenue
20 requirements over the "next 20 years" based on marginal rates projected in the
21 2025 IRP99
22 A: I agree with Mr. Gorman's concern that it's unreasonable to set a rate for 20 years at
23 this time. Actual costs will likely vary from the projections used in the IRP and general
24 rate cases are an appropriate forum for addressing how actual costs should be reflected
25 when updating rate levels.
26 But I think that Mr. Gorman does not speak directly to the matter Dr. Kaufman
27 was addressing. The issue is not whether rates are flexible enough to ensure that the
9 Gorman Di-Reb page 21.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 14
August 15, 2025 CEO

1 Company collects adequate revenue to meet its requirements. The more fundamental
2 matter that I see when reading Dr. Kaufman's testimony is from which customers those
3 collections will be made.
4 We should periodically reset rate amounts to reflect the actual way costs and
5 loads play out. But any such adjustments should use cost allocation methods that are not
6 unfair to other customers.
7 We should not conflate issues related to accurate price levels with matters related
8 to how much of the revenue requirement Micron Fab's incremental resource
9 requirements are causing.
10
11 Section 3 —Resolve these issues in this docket, do not defer resolution to an
12 upcoming general rate case
13
14 Q: Do you have concerns related to both aspects of Mr. Eldred's proposal that future
15 rate cases be the forum for resolution and that the Company bring the proposal for
16 "methods to ensure other customers are not harmed" by large-load special
17 customers?
18 A: Yes, I have two separate, substantive concerns: 1) as detailed above, I do not believe
19 the Company has used appropriate "methods to ensure other customers are not harmed"
20 when reviewing whether other customers are harmed by the unprecedented large load
21 special customer in this docket and 2) general rate cases have not proven to be an
22 effective forum for resolving basic issues related to cost allocation methodologies.
23
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 15
August 15, 2025 CEO

1 Q: Please explain the nature of the concern you expressed related to using future rate
2 cases for resolving basic issues related to cost allocation methodologies
3 A: While I believe that within a future rate case we could successfully make a
4 determination of the actual costs Micron Fab causes in the rate case's test year that forum
5 is not appropriate to determine whether Micron Fab costs should be allocated on an
6 embedded cost or an incremental cost basis. Mr. Anderson appropriately argues that
7 actual costs caused by Micron Fab will be addressed in future general rate cases. But
8 determining actual cost quantities is not the same as deciding cost allocation
9 methodologies.
10 We all know that class allocation in general rate cases is a zero-sum matter and
11 thus each class attempts to shift costs from their customers onto other customer classes.
12 Some have characterized the process as a"food fight". Having a new"500MW gorilla"
13 customer class sitting at the table in future "food fights"will make it unlikely to get a full
14 review of whether embedded or incremental cost allocations should be employed. The
15 baseline condition coming into the rate case will prove too hard to change. Further, given
16 the finite timeline and resources associated with deliberating matters within a rate case, a
17 decision to allocate significant time to Micron Fab allocation matters is a decision to take
18 time away from other matters of interest to the public or other parties.
19 For that reason, with regard to costs classified as Demand, I believe it is essential
20 to public interest that the method for allocating those costs to Micron Fab must be
21 addressed in this docket. My concern is that failure to do so could result in gross
22 unfairness to non-Micron Fab customers.
23
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 16
August 15, 2025 CEO

1 Q: Why do you use such a potentially inflammatory term as "gross unfairness" in
2 describing the potential impacts to non-Micron Fab customers?
3 A: Because a combination of out-of-date inputs, non-repeatable opportunities and a
4 highly questionable analytical method combine to produce a no-harm analysis that is
5 fatally flawed. As I described above, the no-harm analysis is, effectively, the justification
6 the Company provided for the prices in the proposed Schedule 28. The use of a more
7 supportable no-harm analysis would reduce the costs allocated to non-Micron Fab
8 customers.
9
10 Q: Do you acknowledge that there are difficulties presented if the Commission were not
11 to approved the proposed ESA?
12 A: Yes, I acknowledge that the ESA was designed with demand costs being treated as
13 embedded and modifications to that agreement would likely be needed if the application
14 of cost causation principles required that some of the incremental costs Micron Fab will
15 cause were to be directly assigned to Micron Fab.
16 I also note the pressure implicit on the Commission in a comment from Mr.
17 Gorman who notes a need not to harm other customers but adds:
18 However, the Commission must also ensure that Micron is charged just and
19 reasonable rates that allow it to continue to operate its business as a major
20 economic engine for the City of Boise and the State of Idaho.l o
21
22 CEO doesn't want to endanger Micron Fab's continued operation, rather we
23 advocate for the long-term interests of Idahoans within the scope of matters before the
24 Commission. My understanding is that giving favorable treatment to a customer for
io Gorman Di-Reb page 3.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 17
August 15, 2025 CEO

1 purposes of economic development is inappropriate in this regulatory process and thus
2 should be excluded from consideration when reviewing the facts presented in this docket.
3
4 Q: Should other funding approaches be considered in assessing how to resolve the
5 issues presented in this docket?
6 A: Yes. Mr. Gorman's testimony appears to acknowledge that the transition period
7 associated with the take or pay provisions (the period in which load growth from other
8 customers gradually reduces stranded asset exposure) is a way for Micron Fab to
9 transition from new to embedded customer status. I agree with Mr. Gorman in
10 recognizing that load growth from non-Micron Fab customers will eventually reduce
11 stranded asset risk from Micron Fab caused incremental resource procurements.
12 But other customer growth resulting in the eventual elimination of Micron Fab
13 caused stranded asset risk does not preclude looking at other ways to preclude such risks.
14 One such method would involve addressing those incremental Micron Fab resources via
15 expanding the scope CIAC payments made by Micron Fab.
16 The application already reflects using CIAC payments to address site specific
17 interconnection costs. In my rebuttal testimony I question whether some portion of the
18 Mayfield substation and interconnection costs should be assigned to Micron Fab and
19 resolved via CIAC payments.
20 We should review whether Micron Fab-caused incremental generation costs could
21 also be covered by Micron Fab CIAC contributions. The value of those contributions for
22 system level generation and transmission assets could be credited back to Micron Fab
23 over a period like that implied in the take or pay provisions to account for asset
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 18
August 15, 2025 CEO

I depreciation and load growth from non-Micron Fab customers.
2
3 Q: Can you summarize your comments and suggestions regarding resolution of open
4 issues you have addressed in this docket?
5 A: A high level summary could be made using three points:
6 1. The no-harm analysis was the analytical basis for protecting non-Micron Fab
7 customers. The analysis as presented is insufficient to meet that requirement.
8 The no-harm analysis should be updated to provide protection to non-Micron Fab
9 customers from inappropriate cost allocations.
10 2. The next GRC is an inappropriate forum for resolving Micron Fab specific issues.
11 GRC's can be used to determine how much revenue should be collected from
12 Micron Fab based on test year data but they should not be relied upon to
13 determine the Micron Fab-specific method for calculating the amount of revenue
14 that should be collected from Micron Fab.
15 3. Questions related to Micron Fab's share of future revenue requirements should be
16 resolved within a follow-on process set up within this docket. Micron Fab should
17 be provided some temporary pricing structure for use until those questions are
18 resolved and implemented.
19
20 Q: Does this conclude your testimony?
21 A: Yes, it does.
Case No. IPC-E-24-44 HECKLER, M. Surrebuttal 19
August 15, 2025 CEO

CERTIFICATE OF SERVICE
I hereby certify that on this 15th day of August, I delivered true and correct copies of the
foregoing SURREBUTTAL 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
secretary(ilpuc.idaho.gov
Idaho PUC Staff
f
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
chris.burdin(@puc.idaho.gov
Idaho Power Company
Megan Goicoechea Allen
Donovan Walker
Connie Aschenbrenner
Grant Anderson
mgoicoecheaallenOidahopower.com
[e-mail]
caschenbrennerna idahopower.com
ganderson(@idahopower.com
dockets idahopower.com
Industrial Customers of Idaho Power, Inc.
Peter J. Richardson
Dr. Don Reading
[e-mail]
dreadingna mindspring.com
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Lance Kaufman, Ph.D.
elo(a)echohawk.com
lance(a�aegisinsight.com
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - HECKLER SURREBUTTAL -
IPC-E-24-44

Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Kristine A.K. Roach
Holland & Hart, LLP
darueschhoff0hollandhart.com
tnelson aphollandhart.com
awj [e-mail]
aclee(a)hollandhart.com
karoach(a)hollandhart.com
'U
Kelsey Jae
Attorney for CEO
CLEAN ENERGY OPPORTUNITIES FOR IDAHO - HECKLER SURREBUTTAL -
IPC-E-24-44