HomeMy WebLinkAbout20250829Surrebuttal Testimony IPC.pdf "4%611—NIQAHO m Re
RECEIVED
MEGAN GOICOECHEA ALLEN August 29, 2025
Corporate Counsel IDAHO PUBLIC
mgoicoecheaallenC�idahopower.com UTILITIES COMMISSION
August 29, 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 Surrebuttal
Testimonies and exhibit of Connie Aschenbrenner, Grant T. Anderson and Jared L.
Ellsworth in regard to the above matter.
Confidential Exhibit No. 3 to the Surrebuttal Testimony of Grant T.Anderson will be
sent in a separate email to the parties who have signed the Protective Agreement.
If you have any questions about the attached documents, please do not hesitate
to contact me.
Sincerely,
ukr I f��Cfi�1.PA
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. 3 to the Surrebuttal Testimony of Grant T. Anderson, dated
August 29, 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 29th day of August 2025.
ivl
Megan Goicoechea Allen
Counsel for Idaho Power Company
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29t" day of August 2025, 1 served a true and
correct copy of Idaho Power Company's Surrebuttal Testimonies of Connie G.
Aschenbrenner, Grant T. Anderson and Jared L. Ellsworth 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
PO Box 83720 Chris.Burdin(a)-puc.idaho.gov
Boise, ID 83720-0074
Industrial Customers of Idaho Power Hand Delivered
c/o Peter J. Richardson U.S. Mail
Richardson Adams, PLLC Overnight Mail
515 N. 27' Street FAX
Boise, Idaho 83702 FTP Site
X Email
peter richardsonadams.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�mindsprinq.com
Idaho Irrigation Pumpers Association, Hand Delivered
Inc. U.S. Mail
Eric L. Olsen Overnight Mail
Echo Hawk & Olsen, PLLC FAX
505 Pershing Ave., Ste. 100 FTP Site
P.O. Box 6119 X Email
Pocatello, Idaho 83205 elo(a-)echohawk.com
CERTIFICATE OF SERVICE - 1
Lance Kaufman, Ph.D. Hand Delivered
2623 NW Bluebell Place U.S. Mail
Corvallis, OR 97330 Overnight Mail
FAX
FTP Site
X Email lance(a)aegisinsight.com
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(a)hol land hart.com
karoach hollandhart.com
acleeC@hollandhart.com
Clean Energy Opportunities for 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)kelseyiae.com
Courtney White Hand Delivered
Mike Heckler U.S. Mail
3778 Plantation River Drive, Suite 102 Overnight Mail
Boise, ID 83703 FAX
FTP Site
X Email
courtney(a cleanenergyopportunities.com
mike(a-)-cleanenergyopportunities.com
Stacy Gust
Regulatory Administrative Assistant
CERTIFICATE OF SERVICE - 2
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 )
ELECTRIC SERVICE TO MICRON IDAHO )
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC. )
IDAHO POWER COMPANY
SURREBUTTAL TESTIMONY
OF
CONNIE G. ASCHENBRENNER
1 Q. Please state your name, business address, and
2 present position with Idaho Power Company ("Idaho Power" or
3 "Company") .
4 A. My name is Connie G. Aschenbrenner. My
5 business address is 1221 West Idaho Street, Boise, Idaho
6 83702 . I am employed by Idaho Power as the Director of
7 Regulatory Affairs in the Regulatory Affairs Department.
8 Q. Are you the same Connie Aschenbrenner who
9 submitted direct testimony in this proceeding on behalf of
10 Idaho Power ?
11 A. Yes .
12 Q. Have you had the opportunity to review the
13 pre-filed rebuttal and surrebuttal testimonies filed by the
14 intervenors to this proceeding?
15 A. Yes, I have .
16 Q. What is the scope of your surrebuttal
17 testimony?
18 A. My surrebuttal testimony addresses issues
19 raised by intervenors regarding the Commission' s authority
20 under the Energy Service Agreement ("ESA") , the timing of
21 ESA approval, including the appropriate forum for resolving
22 cost allocation and price design issues, the impact of the
23 ESA on other customer rates, and the impact of Micron' s
24 future development plans on the current proceeding.
ASCHENBRENNER, SURR REB 2
Idaho Power Company
1 Q. Does the fact that you do not address every
2 issue raised in the testimonies of other parties mean that
3 you agree with other parties' testimony on those issues?
4 A. No. It merely reflects that I chose not to
5 address all those issues . It should not be read as an
6 endorsement of, or agreement with, any unaddressed issues .
7 Q. For ease of reference, can you provide a table
8 of contents for your surrebuttal?
9 A. Please see the below table of contents for my
10 surrebuttal testimony:
Table of Contents Page
I . Commission Authority and ESA Oversight 3
II . ESA Review and Ripeness for Approval 5
III . Rate Impact of Micron FAB 11
IV. Future Load Growth and Second Fab 15
V. Conclusion 16
11 I . COMMISSION AUTHORITY AND ESA OVERSIGHT
12 Q. Please summarize your understanding of the
13 intervenor positions regarding the Commission' s
14 jurisdiction and oversight under the ESA.
15 A. Clean Energy Opportunities for Idaho ("CEO") ,
16 through its consultant Mr. Michael Heckler, raises concerns
17 that the ESA may limit the Commission' s ability to exercise
18 its ratemaking authority. More specifically, he points to
19 Section 13 .2, which requires that any rate revisions be
ASCHENBRENNER, SURR REB 3
Idaho Power Company
1 supported by "substantial competent evidence, " language
2 that he suggests could constrain the Commission' s ability
3 to adjust rates .
4 Q. Do you agree with his interpretation?
5 A. No. The Micron FAB ESA expressly affirms the
6 Commission' s full ratemaking jurisdiction. Section 13 . 1
7 subjects the agreement to the Commission' s General Rules
8 and Regulations and Idaho law, while Section 13 . 2 confirms
9 that all rates under the ESA remain subject to change and
10 revision by Commission order. These revisions may be made
11 upon a finding that such changes are just, fair,
12 reasonable, sufficient, non-preferential, and
13 nondiscriminatory; that such finding should be supported by
14 "substantial competent evidence" is not, as Mr. Heckler
15 suggests, a constraint on the Commission' s ability to
16 adjust rates but a reference to the legal standard of
17 appellate review of Commission decisions . '
18 Additionally, Section 7 . 2 provides for annual
19 updates to the marginal cost-based Energy Charges, subject
20 to Commission review and approval, while Section 14 . 1 makes
21 the ESA "expressly conditioned upon" Final Regulatory
1 See, e.g. , Washington Water Power Co. v. Idaho Pub. Utilities Comm'n,
101 Idaho 567, 575-76, 617 P.2d 1242 (1980) (though appellate review of
Commission decisions is limited, the Idaho Supreme Court has cautioned
that the Commission must enter adequate findings of fact based upon
competent and substantial evidence and set forth its reasoning in a
rational manner to ensure there is meaningful opportunity for judicial
review) .
ASCHENBRENNER, SURR REB 4
Idaho Power Company
1 Approval, meaning the Commission retains the authority to
2 approve, reject, or modify any provision before the ESA
3 becomes effective. These ESA provisions ensure that the
4 rates applied to the Micron FAB usage remain responsive to
5 regulatory oversight and evolving system conditions .
6 II . ESA REVIEW AND RIPENESS FOR APPROVAL
7 Q. What concerns did the Idaho Irrigation Pumpers
8 Association, Inc. ("IIPA") consultant Dr. Lance Kaufman
9 raise regarding the timing of regulatory approval of the
10 proposed ESA?
11 A. Dr. Kaufman believes that there are
12 outstanding issues that should prevent the Commission from
13 approving the ESA, focusing primarily on the potential
14 impact of possible future large load legislation.
15 Q. What is your understanding of the legislation
16 that has been referenced by Dr. Kaufman?
17 A. IIPA refers to House Bill No . 395 ("HB 395") ,
18 presented as Exhibit No. 204 to the testimony of
19 Representative Stephanie Jo Mickelson and Representative
20 Dan Garner, members of the Idaho State Legislature . My
21 understanding of HB 395, introduced during the Idaho
22 Regular Legislative Session in 2025, is that it would have
23 prohibited an electric utility from providing electric
ASCHENBRENNER, SURR REB 5
Idaho Power Company
1 service to any customer with power requirements of tent
2 megawatts ("MW") or greater with its existing or planned
3 generation resources for a period of ten (10) years from
4 the initial date of service. Instead, the large load
5 customer would have been responsible for securing their own
6 energy, either by purchasing through the utility or by
7 contracting directly with a third-party provider. This is
8 often referred to as direct access, a form of deregulation.
9 Q. You equated direct access to a form of
10 deregulation. Are you aware of any deregulated markets that
11 have lower electric rates than Idaho Power' s rates?
12 A. No. As shown in Table 1, based on a recent
13 review of electric prices in states with deregulated or
14 "retail choice" structures, I have found that the rates,
15 specifically residential rates, are higher than those in
16 the State of Idaho. For reference, Idaho Power' s mill rate
17 for Idaho residential customers was 11 . 68G for the 12-month
18 period ending June 2025 .
19
20
21
22
23
2 The engrossed bill amended this from ten to thirty (30) megawatts. See
House Amendment to HB 395.
ASCHENBRENNER, SURR REB 6
Idaho Power Company
1 Table 1 - EIA June 2025 - Residential Sector3
2Residential Residential
Rank State Rate (cents) Rank State Rate (cents)
1 Nevada 11.42 26 West Virginia 15.82
3 27 Missouri 15.84
3 Louisiana 12.64 28 Alabama 16.00
4 4 Washington 12.98 29 Georgia 16.00
5 Utah 13.12 30 Colorado 16.16
5 6 Nebraska 13.17 31 Indiana 16.60
7 Arkansas 13.33 32 Minnesota 17.14
6 8 North Carolina 13.33 33 Ohio 17.52
9 Kentucky 13.62 34 Delaware 18.15
7 10 Oklahoma 13.62 35 Illinois 18.33
11 North Dakota 13.68 36 Wisconsin 18.57
12 Mississippi 13.94 37 Maryland 19.33
8 13 Tennessee 13.98 38 Pennsylvania 19.70
14 South Dakota 14.23 39 Michigan 20.85
9 15 South Carolina 14.71 40 District of Columbia 22.70
16 New Mexico 14.77 41 Vermont 23.21
10 17 Montana 14.85 42 New Hampshire 23.51
18 Wyoming 14.89 43 New Jersey 24.88
11 19 Kansas 15.00 44 New York 26.53
20 Texas 15.23 45 Rhode Island 26.84
21 Arizona 15.28 46 Alaska 26.88
12 22 Florida 15.36 47 Connecticut 27.24
23 Iowa 15.39 48 Maine 28.14
13 24 Virginia 15.41 49 Massachusetts 30.37
25 Oregon 15.77 50 California 33.52
14 51 Hawaii 40.96
15 Q. What is the status of HB 395?
16 A. HB 395 did not become law during the 2025
17 legislative session; it is my understanding that the bill
18 died in the Senate State Affairs Committee. While IIPA
19 contends that there continues to be support for large load
20 legislation and that alternative draft legislation is being
21 refined to be taken up again in a future legislative
22 session, at this stage it would be entirely speculative to
3 EIA June 2025,
https://www.eia.gov/electricity/monthly/epm table grapher.php?t=epmt 5
6 a;
https://www.rstreet.org/wp-content/uploads/2025/05/Final-Study-No.-324-
1.pdf; blue = deregulated
ASCHENBRENNER, SURR REB 7
Idaho Power Company
1 predict the existence or impact of hypothetical future
2 legislation.
3 Q. Does the Company agree with the claim
4 legislation is necessary to mitigate the impact of new
5 large load energy use by companies like Micron?
6 A. No. While the Company does not disagree that
7 existing customers should be protected from potential cost
8 shifting caused by large load, and other types of
9 customers, legislation is not necessary to accomplish this
10 objective. The Commission already has the authority to
11 approve special contracts which balance meeting large load
12 customers' operational needs with adequate regulatory
13 oversight and customer protection.
14 Q. What concerns did CEO raise regarding the
15 timing of regulatory approval of the ESA?
16 A. In his rebuttal testimony, Mr. Heckler
17 contends that it would suboptimal to delay resolution of
18 cost allocation issues to a future general rate case
19 ("GRC") , noting his belief that there are significant open
20 issues related to the Company' s proposal for the Micron FAB
21 that should be addressed before proceeding to a GRC, based
22 on concerns that the scope of a GRC proceeding would
23 prevent a full and comprehensive review of matters specific
24 to the Micron FAB. Instead, he recommends that these issues
25 be reviewed and considered as part of the upcoming
ASCHENBRENNER, SURR REB 8
Idaho Power Company
1 technical hearing, with the potential to schedule
2 additional sessions if any issues are unresolved at that
3 stage . While recognizing the need for timely resolution,
4 Mr. Heckler believes that that there are additional
5 questions regarding the treatment of "megaload" customers
6 that must be resolved in this docket before the ESA is
7 approved.
8 Q. How to you respond to Mr. Heckler' s claims in
9 his rebuttal and surrebuttal testimonies that the number of
10 open issues presented in a general rate case docket "is so
11 large that fundamental issues of cost allocation treatment
12 for specific customers are unlikely to get the attention
13 that their significance warrants" and that "general rate
14 cases have not proven to be an effective forum for
15 resolving basic issues related to cost allocation
16 methodologies"?
17 A. Mr. Heckler' s statements are without basis .
18 Assigning shared costs outside of general rate cases would
19 reduce transparency and limit stakeholder input, weakening
20 oversight and increasing the potential for disputes . A GRC
21 is unequivocally the appropriate venue for evaluating cost
22 allocation methodologies and incorporating the Micron FAB' s
23 treatment into broader system frameworks with full
24 stakeholder input. For context, in the Company' s 2008 GRC,
25 class cost-of-service issues were fully litigated and
ASCHENBRENNER, SURR REB 9
Idaho Power Company
1 resolved by Commission order within the legislatively
2 mandated time of review.
3 Q. Is delay of ESA approval warranted to allow
4 for legislative action or additional regulatory process in
5 this case?
6 A. No. The possibility of future legislation is
7 influenced by various factors and the likelihood of a bill
8 being passed, its final wording, and how it will be
9 interpreted are all too uncertain for it to be treated as a
10 present fact . The Commission is empowered to act
11 independently and proactively to protect the public
12 interest, and there is no legal basis for delaying review
13 of the ESA for potential future legislation.
14 Moreover, it is not necessary for the Commission to
15 implement further regulatory process; the ESA provides a
16 timely and targeted framework for recovering costs
17 associated with serving the Micron FAB, using a pricing
18 model that reflects both marginal and embedded cost
19 impacts . The Company' s proposed approach ensures that
20 pricing for the Micron FAB stays aligned with Commission-
21 authorized revenue changes over time . Demand Charges will
22 be updated through general rate cases and marginal Energy
23 Charges will be updated annually.
24 The Commission has the authority and procedural
25 framework to issue a decision within this docket. The
ASCHENBRENNER, SURR REB 10
Idaho Power Company
1 docket is proceeding on a robust schedule, with discovery,
2 three (3) rounds of pre-filed testimony and a technical
3 hearing forthcoming. Delaying a decision will not better
4 serve the interests of existing customers . Further review
5 beyond what is already scheduled as part of the Micron FAB
6 case proceedings would only postpone resolution of issues
7 that are already being thoroughly vetted.
8 III . RATE IMPACT OF MICRON FAB
9 Q. Both Dr. Kaufman and Mr. Heckler imply that
10 the Micron FAB incremental load is a driver of the base
11 rate increase requested in the Company' s 2025 GRC, Case No .
12 IPC-E-25-16 ("2025 GRC") . Is this correct?
13 A. No. The requested revenue increase in that
14 docket does not include impacts of the planned Micron FAB
15 load. All incremental investments included for recovery in
16 the 2025 GRC are necessary to provide safe, reliable
17 service to other existing customers . The Micron FAB load is
18 not a driver or contributor to any of the proposed revenue
19 requirements in the 2025 GRC. Any recovery of incremental
20 plant associated with serving the Micron FAB load
21 requirements would be addressed in a future general rate
22 case when such facilities are in service, and the
23 associated costs and revenues are in the test year.
24 In a future general rate case - when the Micron
25 FAB' s load and associated share of costs are included in
ASCHENBRENNER, SURR REB 11
Idaho Power Company
1 the test year - the Company would propose updated pricing
2 and will apply approved allocators so that Micron FAB bears
3 its allocated share of both existing and incremental demand
4 related generation and transmission revenue requirement. As
5 a result, a portion of costs that would otherwise be
6 recovered from other customers would be recovered from
7 Micron FAB, which is consistent with historic cost
8 causation principles for large special contract customers .
9 Q. How do you respond to Dr. Kaufman' s claim in
10 his surrebuttal testimony that the Micron FAB ESA is not
11 reflective of Idaho Power' s stated "growth pays for growth"
12 policy?
13 A. Dr. Kaufman' s contention in this regard is
14 unsupported and based on flawed and cyclical reasoning.
15 More specifically, Dr. Kaufman explains that the fact that
16 Idaho Power' s General Rate Case is clearly driven by load
17 growth, noting that the word "growth" appeared 193 times in
18 the Company' s GRC testimony, demonstrates that the growth
19 pays for growth policy is not being followed, because rate
20 changes would not be driven by growth if it were . He then
21 goes on to assert that there is "clear evidence" that
22 Micron is driving costs up, though he fails to offer any
23 support for this claim, and implies that irrigation
24 customers are unfairly subsidizing large load customers; in
25 this regard he states, "the irrigation class is repeatedly
ASCHENBRENNER, SURR REB 12
Idaho Power Company
1 asked to pay the largest percentage rate increases of any
2 rate class for growth driven rate increases despite being
3 one of the only customer classes that has not grown over
4 the last 20 years . "
5 As an initial point of clarification, recent
6 proposed rate increases for the irrigation class in GRCs is
7 the result of seeking to align the irrigation class with
8 their cost of service. That is, recent class cost of
9 service studies have shown the irrigation class is being
10 subsidized by other classes, not the other way around.
11 Additionally, Dr. Kaufman' s statement that the
12 irrigation class has not grown over the last 20 years is
13 untrue across multiple metrics . Between 2005 and 2024,
14 irrigation class customers experienced compound annual
15 growth rates of 1 . 2 percent in customer counts, 1 . 6 percent
16 in actual sales, and 0 . 4 percent in weather-adjusted sales .
17 These figures directly refute the claim that the class has
18 remained stagnant over the last 20 years as suggested by
19 IIPA.
20 Despite Dr. Kaufman' s assertions, neither the
21 requested rate change for irrigation customers in the
22 pending GRC nor presence of the word "growth" in testimony
23 demonstrate cost causation or rate impact. He also
24 overlooks the fact that the Micron FAB is not the only load
25 that is growing on the Company' s system and fails to
ASCHENBRENNER, SURR REB 13
Idaho Power Company
1 account for how the Company' s "growth pays for growth"
2 policies are implemented uniquely for each customer class .
3 Q. Do you agree with intervenors' suggestions
4 that residential and irrigation customers are
5 disproportionately and unfairly impacted by growth driven
6 rate increases?
7 A. No. Over the ten-year period ending June 1,
8 2025, the compound annual growth rate in average prices was
9 less than 2 percent for residential customers and less than
10 3 percent for irrigation customers . These outcomes are
11 consistent with the Company' s cost-causation approach to
12 cost allocation.
13 The observed price trends reflect measured, modest
14 movement - not the rampant increases Dr. Kaufman' s
15 narrative implies - and they demonstrate that costs
16 associated with large incremental loads are addressed
17 through Commission-approved pricing and allocations
18 designed to assign costs to cost-causers . In short, the
19 data does not align with Dr. Kaufman' s premise, and in
20 fact, demonstrates that the Company' s practices have
21 maintained affordability for residential and irrigation
22 customers despite the unprecedented growth being
23 experienced by the Company.
24
25
ASCHENBRENNER, SURR REB 14
Idaho Power Company
1 IV. FUTURE LOAD GROWTH AND SECOND FAB
2 Q. Do you agree with the concern noted by Dr.
3 Kaufman in his rebuttal testimony that Micron' s recent
4 announcement of a planned second FAB plant changes the
5 context of this case?
6 A. No. Dr. Kaufman' s reference to Micron' s June
7 2025 public announcement regarding a planned second Idaho
8 fabrication facility is a red herring; Micron' s plans for a
9 potential second memory fabrication facility are inapposite
10 in this case . The maximum Contract Demand under the
11 existing ESA is 507 MW and any request to serve load beyond
12 this limit would be subject to Commission review and at a
13 minimum, approval of an amended contract. If a second
14 memory fabrication facility where to be served through
15 unique interconnection facilities, a separate special
16 contract would need to be executed and filed for Commission
17 approval .
18 Idaho Power has an obligation to provide service to
19 all customers, including requests for service of greater
20 than 20 MW, and it agrees that large loads warrant careful
21 evaluation - this is exactly what the special contract
22 mechanism is designed to ensure. The Commission' s objective
23 in this docket is to consider the terms of the proposed
24 Micron FAB ESA - terms that are being thoroughly vetted
25 through this proceeding. Micron' s future development plans
ASCHENBRENNER, SURR REB 15
Idaho Power Company
1 are not within the scope of this docket, nor do they
2 justify delaying approval of the ESA.
3 V. CONCLUSION
4 Q. Please summarize your recommendations .
5 A. I recommend that the Commission:
6 (i) Affirm the ESA does not interfere with its
7 jurisdictional authority, recognizing that Sections 13 . 1,
8 13 . 2, and 14 . 1 collectively preserve full regulatory
9 oversight and condition the agreement' s effectiveness on
10 Final Regulatory Approval;
11 (ii) Reject intervenor proposals to delay ESA
12 approval pending legislative action or additional process;
13 (iii) Confirm that general rate cases are the
14 appropriate forum to evaluate and address allocation and
15 pricing updates; and
16 (vi) Disregard speculative concerns related to
17 Micron' s second FAB announcement.
18 Q. Please summarize the Company' s request in this
19 case .
20 A. Idaho Power respectfully requests the
21 Commission issue an order approving: (1) the Micron FAB ESA
22 (included as Attachment 1 to the Application) , (2) the
23 Contract Demand and Billing Demand Charges set forth in
24 Schedule 28 (included as Attachment 2 to the Application) ,
25 adjusted to reflect the composite rate change authorized
ASCHENBRENNER, SURR REB 16
Idaho Power Company
1 for special contract customers in Case No. IPC-E-24-07, (3)
2 the Energy Charge set forth in Schedule 28, adjusted to
3 reflect the Commission-approved marginal cost-based pricing
4 in Case No . IPC-E-25-17, and (4) authorizing the requested
5 accounting treatment of energy sales under the ESA.
6 Q. Does this conclude your surrebuttal testimony
7 in this case?
8 A. Yes, it does .
9
10
ASCHENBRENNER, SURR REB 17
Idaho Power Company
1 DECLARATION OF CONNIE G. ASCHENBRENNER
2 I, Connie G. Aschenbrenner, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Connie G. Aschenbrenner. I am employed
5 by Idaho Power Company as the Director of Regulatory
6 Affairs in the Regulatory Affairs Department.
7 2 . On behalf of Idaho Power, I present this pre-
8 filed surrebuttal testimony in this matter.
9 3 . To the best of my knowledge, my pre-filed
10 surrebuttal testimony is true and accurate.
11 I hereby declare that the above statement is true to
12 the best of my knowledge and belief, and that I understand
13 it is made for use as evidence before the Idaho Public
14 Utilities Commission and is subject to penalty for perjury.
15 SIGNED this 29th day of August 2025, at Boise, Idaho.
16
17 Signed:
18 CONNIE G. ASCHENBRENNER
19
20
21
22
23
24
25
26
ASCHENBRENNER, SURR REB 18
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 )
ELECTRIC SERVICE TO MICRON IDAHO )
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC. )
IDAHO POWER COMPANY
SURREBUTTAL TESTIMONY
OF
GRANT T. ANDERSON
1 Q. Please state your name.
2 A. My name is Grant T. Anderson.
3 Q. Are you the same Grant T. Anderson who
4 submitted direct and rebuttal testimony in this proceeding
5 on behalf of Idaho Power Company ("Idaho Power" or
6 "Company") ?
7 A. Yes .
8 Q. Have you had the opportunity to review the
9 pre-filed rebuttal and surrebuttal testimonies filed by the
10 intervenors to this proceeding?
11 A. Yes, I have .
12 Q. What is the scope of your surrebuttal
13 testimony?
14 A. I address three topics related to the Micron
15 Idaho Semiconductor Manufacturing (Triton) LLC ("Micron
16 FAB") Energy Services Agreement ("ESA") and Schedule 28 :
17 (1) Pricing framework and allocation boundary. I confirm
18 the Schedule 28 structure - marginal cost-based Energy
19 Charges updated annually using Commission-approved
20 marginal cost data, and embedded cost-based Demand
21 Charges set and updated in general rate cases - and
22 clarify that class allocators and direct assignment
23 belong in a future general rate case when Micron FAB is
24 in the test year.
ANDERSON, SURR REB 2
Idaho Power Company
1 (2) Energy pricing and market risk. I explain why 20-year
2 Integrated Resource Plan ("IRP") portfolio averages are
3 not customer prices, consider how time-of-use Energy
4 Charges based on the same approved marginal cost data
5 could be implemented, and recommend addressing long-run
6 energy cost and marginal cost market risk in a separate
7 docket .
8 (3) No-harm framework. I describe the purpose and limits of
9 the no-harm check and present an update using 2025 IRP
10 inputs and updated Micron FAB forecast that reaches the
11 same conclusion: under the proposed structure, other
12 customers are not harmed.
13 Q. Does the fact that you do not address every
14 issue raised in the testimonies of other parties mean that
15 you agree with other parties' testimony on those issues?
16 A. No . It merely reflects that I chose not to
17 address all those issues . It should not be read as an
18 endorsement of, or agreement with, any unaddressed issues .
19 Q. For ease of reference, can you provide a table
20 of contents for your surrebuttal?
21 A. Please see the below table of contents for my
22 surrebuttal testimony:
23
24
25
ANDERSON, SURR REB 3
Idaho Power Company
Table of Contents Page
I . Pricing Framework & Cost Allocation Boundary 4
II . Energy Charge Pricing & Market Risks 12
III . No-Harm Framework & Responses 17
IV. Conclusion 23
1 I . PRICING FRAMEWORK & COST ALLOCATION BOUNDARY
2 Pricing Structure (Overview)
3 Q. What pricing structure has the Company
4 proposed for the Micron FAB facility under Schedule 28?
5 A. The Company has proposed embedded cost-based
6 Demand Charges and marginal cost-based Energy Charges for
7 Micron FAB under Schedule 28 .
8 Q. How will pricing under Schedule 28 stay
9 aligned with Commission-authorized revenue changes over
10 time?
11 A. Demand Charges for Micron FAB as proposed
12 would be updated through general rate cases; once the
13 Micron FAB is in the test year its revenue allocation and
14 resulting pricing structure would be addressed similar to
15 other special contract customers . For Energy Charges, the
16 Company proposes to update the marginal cost-based price
17 annually based on the Commission-approved updated marginal
18 energy cost components used in certain tariff schedules .
19 See, e .g. , Case No . IPC-E-25-17 .
20
ANDERSON, SURR REB 4
Idaho Power Company
1 ESA Protects Against Cost Shifts
2 Q. Does the Micron FAB ESA protect existing
3 customers from cost shifts?
4 A. Yes . The Micron FAB ESA pricing structure
5 ensures that Micron FAB pays a marginal cost-based energy
6 price, updated annually, and that demand-related generation
7 and transmission revenue requirement is assigned to Micron
8 FAB based on its load-ratio share . As demonstrated by the
9 no-harm analysis developed from the 2023 IRP and the
10 updated analysis using 2025 IRP inputs, this structure
11 prevents cross-subsidization and maintains fairness for
12 Micron FAB and all other customers . The annual marginal
13 cost-based energy revenue - as described by Ms .
14 Aschenbrenner in her direct testimony - flows through as an
15 offset to net power supply expense, benefiting other
16 customers . Allocation of embedded demand costs to Micron
17 FAB would be determined in general rate cases, ensuring
18 that as Micron FAB' s load ramps over time and new
19 generation and transmission revenue requirement enter
20 rates, Micron FAB bears its proportionate share . Taken
21 together, these mechanisms allow for a pricing structure
22 which mitigates cost shifts to other customers .
23
24
25
ANDERSON, SURR REB 5
Idaho Power Company
1 Embedded vs . Incremental Cost Allocation
2 Q. Is the proposed pricing structure under the
3 Micron FAB ESA - including demand-related pricing -
4 intended to recover future incremental generation and
5 transmission costs or embedded system costs?
6 A. Both. The pricing structure is intended to
7 recover Micron FAB' s proportional share of embedded system
8 costs reflected in a respective test-year revenue
9 requirement in a general rate case . This includes a share
10 of those generation resources in-service prior to the
11 Micron FAB coming online as well as a share of those
12 generation resources that come online in years 2026 and
13 after . This approach does not directly assign the full cost
14 of future incremental generation or transmission to Micron
15 FAB, as is recommended by Mr. Michael Heckler and Dr. Lance
16 Kaufman, consultants for Clean Energy Opportunities for
17 Idaho ("CEO") and Idaho Irrigation Pumpers Association,
18 Inc. ("IIPA") , respectively, because these capital
19 investments are system resources used by all customers .
20 Cost allocation on an embedded-cost basis avoids
21 over-assigning incremental costs solely to Micron FAB, but
22 it also ensures Micron is assigned a portion of the
23 existing system costs they will rely on as well .
24 Intervenors appear to focus only on Micron' s contribution
25 to incremental resources, suggesting the proposed pricing
ANDERSON, SURR REB 6
Idaho Power Company
1 method is insufficient. This narrow view ignores the fact
2 that assigning Micron a portion of existing resources
3 offsets costs that are currently entirely borne by other
4 customers . This is a significant driver of the "no harm"
5 result-absent Micron taking its share of existing costs in
6 addition to its share of incremental costs, the result
7 would likely be different.
8 For example, as Company witness Mr. Jared Ellsworth
9 explains, the planned transmission projects are not solely
10 necessitated by Micron FAB; recognizing Micron FAB' s system
11 impact means Micron FAB will bear its allocated share,
12 which also alleviates some of the burden from other
13 customers . These are system resources - not facilities
14 dedicated solely to Micron FAB. System generation and
15 transmission are planned, procured, and operated to
16 optimize service for all customers . Assigning costs by
17 vintage rather than by cost causation is not an approach
18 the Company supports . And while the no-harm scenarios can
19 inform planning, actual resource decisions are not made in
20 isolation for Micron FAB versus Idaho Power' s entire
21 customer base; resource decisions are made for the system
22 as a whole .
23
24
25
ANDERSON, SURR REB 7
Idaho Power Company
1 Alignment and Fairness
2 Q. How does this pricing structure ensure
3 alignment and fairness?
4 A. By anchoring demand-related generation and
5 transmission revenue requirement - and the resulting Demand
6 Charges - to outcomes in a general rate case, Micron FAB' s
7 pricing stays synchronized with the broader cost structure
8 and cost allocation framework applied to all customers .
9 This ensures consistent treatment across classes and fairly
10 reflects Micron FAB' s contribution to system load.
11 Response to "Outlier" Claim
12 Q. How do you respond to Mr. Heckler' s suggestion
13 that traditional analytical methods are not suitable for
14 Micron FAB given the magnitude of its load?
15 A. I acknowledge that Micron FAB represents a
16 substantial and unique load but disagree with the
17 implication that the structured pricing approach proposed
18 by the Company does not adequately address the customer' s
19 unique characteristics . The Micron FAB ESA does not rely
20 exclusively on traditional frameworks but instead applies a
21 tailored pricing structure informed by - but not bound to -
22 past Commission-approved special contracts . While
23 agreements approved for Schedules 33 and 34 provided useful
24 precedent, the Micron FAB ESA was specifically adapted to
25 reflect the Micron FAB facility' s distinct load
ANDERSON, SURR REB 8
Idaho Power Company
1 requirements, timing, and cost profile. This approach
2 ensures that pricing is responsive to this customer' s
3 facility' s unique system impacts, while maintaining
4 consistency with cost-causation principles .
5 IRP 20-Year Average vs. Embedded Pricing Misalignment
6 Q. While Mr. Heckler generally agrees with the
7 inappropriateness of using Dr. Kaufman' s analysis for
8 setting prices, do you agree with his assertion that it
9 provides a valuable check on the accuracy of the proposed
10 no-harm analysis?
11 A. No . Mr. Heckler incorrectly characterizes the
12 corrected IRP figure of approximately $95 per megawatt-hour
13 ("MWh") as an "hourly" cost estimate, which he contends is
14 still 50 percent higher than embedded pricing included in
15 Schedule 28 as filed. However, the IRP figure is not an
16 hourly price and not a customer tariff price; it is a
17 twenty-year average incremental portfolio cost between two
18 (2) planning scenarios . Comparing that incremental cost
19 between planning portfolios to the average of the proposed
20 Schedule 28 current embedded pricing - which would be
21 updated in general rate cases and other ratemaking
22 proceedings - is not a like-for-like comparison and not
23 informative for the establishment of pricing for Micron
24 FAB. Suggesting that initial pricing is 50 percent below
ANDERSON, SURR REB 9
Idaho Power Company
1 the IRP derived figure does not provide a reasonable
2 comparison and is misleading.
3 Cost Allocation Boundary
4 Q. From a pricing perspective, what is the
5 "allocation boundary" you' re drawing in this case?
6 A. This proceeding sets Schedule 28 pricing
7 structure and initial levels of cost allocation for
8 pricing. It does not decide future class-level allocators,
9 nor does it directly assign system generation or
10 transmission to Micron FAB. Those class-allocation methods
11 - such as an incremental-growth weighting approach as
12 contemplated by Commission Staff ("Staff") Witness Mr.
13 Michael Eldred' s Surrebuttal - belong in a general rate
14 case.
15 The Company has proposed to update Micron FAB' s
16 initial Schedule 28 charges by the same overall percentage
17 change approved through general rate cases via compliance
18 filings in order to maintain parity with other Idaho Power
19 customers . The intent of this approach is to keep Micron
20 FAB' s initial pricing in sync.
21 In a future general rate case - when the Micron
22 FAB' s load and associated share of costs are included in
23 the test year - the Company would propose updated pricing
24 and apply approved allocators so that Micron FAB bears its
25 allocated share of both demand-related generation and
ANDERSON, SURR REB 10
Idaho Power Company
1 transmission revenue requirement in the test year. As a
2 result, a portion of costs that would otherwise be
3 recovered from other customers would be recovered from
4 Micron FAB, which is consistent with historic
5 cost-causation principles for large special contract
6 customers .
7 Q. How does Idaho Power respond to Staff' s
8 example of weighting each class' s load share by its
9 incremental growth when allocating embedded capacity costs?
10 A. Idaho Power agrees with Mr. Eldred' s
11 recommendation that allocation of future generation and
12 transmission revenue requirement should be addressed in a
13 future general rate case. Staff' s example of weighting
14 class load shares by incremental growth is consistent with
15 cost-causation principles . This approach is similar to the
16 Company' s current methodology in its class cost-of-service
17 study, which reflects a marginal cost weighting element. In
18 a future general rate case, Idaho Power, Staff and other
19 stakeholders will have the opportunity to assess and, if
20 appropriate, recommend streamlining and improving the
21 allocation methodology used to allocate embedded capacity
22 costs, so the outcome reflects how incremental load drives
23 new investment . Ultimately, the decision to rely on
24 existing class cost-of-service methods or to implement new
25 or modified methods will be decided by the Commission.
ANDERSON, SURR REB 11
Idaho Power Company
1 II . ENERGY CHARGE PRICING & MARKET RISKS
2 Long-Run Energy Costs and Market-Based Cost Exposure
3 Q. How do you respond to Dr. Kaufman' s concern
4 regarding the treatment of Power Purchase Agreement ("PPA")
5 costs under the proposed pricing framework?
6 A. Idaho Power disagrees that there is a hole in
7 the pricing framework by which existing customers bear a
8 disproportionate share of energy costs . However, it
9 acknowledges Dr. Kaufman' s argument that the current
10 proposed pricing framework does not explicitly recover the
11 cost of incremental PPAs . As noted in his testimony, PPA
12 costs are currently recovered through embedded energy
13 rates . Because the proposed energy pricing under the Micron
14 FAB ESA is a marginal cost-based price, those embedded
15 costs are not directly recovered. Dr. Kaufman points out
16 that Idaho Power currently classifies purchased power,
17 which includes PPAs, as embedded energy costs . Because the
18 proposed pricing structure for Micron includes assessing a
19 marginal cost-based Energy Charge, Micron will not directly
20 contribute to embedded energy costs, rather those costs
21 will be covered by the Company' s remaining customers .
22 Q. How does IIPA suggest resolving this issue?
23 A. Dr. Kaufman suggests IIPA would not be opposed
24 to identifying the difference between what he refers to as
ANDERSON, SURR REB 12
Idaho Power Company
1 long-run energy costs and short-run energy costs and
2 wrapping that amount into a customer charge or demand
3 charge.
4 Q. How did IIPA respond to Idaho Power' s
5 recommendation that issues related to long-run cost issues
6 and a true-up related to forecasting error should be
7 addressed in a separate docket?
8 A. Dr. Kaufman notes that IIPA is open to
9 addressing these issues in a separate docket, provided
10 there is sufficient time to scope and resolve them. In
11 looking at the timing of the Company' s most recent annual
12 marginal cost update docket, Dr. Kaufman highlighted the
13 streamlined nature of that docket, which was resolved
14 within 60-days, and questioned whether it would have
15 sufficient depth to fully develop a new method of
16 calculating long run marginal energy costs or developing a
17 true-up mechanism.
18 Q. What is Idaho Power' s response to Dr.
19 Kaufman' s concerns?
20 A. Idaho Power agrees that it will be important
21 to ensure there is adequate time to fully consider the
22 issue of long run energy costs and the assessment of a
23 marginal cost true-up mechanism. Accordingly, Idaho Power
24 revises its recommendation that those issues could be
25 addressed through the annual update process and instead
ANDERSON, SURR REB 13
Idaho Power Company
1 recommends if the Commission directs an evaluation, that it
2 occur in a marginal cost docket to be filed independent of
3 the annual update . This approach would allow for a more
4 comprehensive and transparent evaluation of the marginal
5 cost-based pricing framework and ensure that any
6 modifications are appropriately scoped and vetted.
7 Time-of-Use Energy Prices (TOU)
8 Q. What is the Company' s position on adopting
9 time-of-use ("TOU") energy pricing for Schedule 28?
10 A. As noted in my rebuttal testimony, the Company
11 is not opposed, in concept, to implementing a TOU energy
12 pricing structure so long as it leverages the same
13 underlying marginal cost data that informs the proposed
14 Energy Charge . I also suggested that the time periods set
15 forth in Schedule 19 would be a reasonable starting point.
16 Q. Do you support the alternative time periods
17 proposed by Ms . Courtney White, witness for CEO?
18 A. I do not take a position on the alternatives
19 suggested by Ms . White.
20 Q. Have you considered what the pricing would
21 look like under each of the alternative time periods
22 proposed by Ms . White?
23 A. Yes . Using the marginal-cost data approved by
24 the Commission in Case No. IPC-E-25-17, I calculated Energy
25 Charges for each alternative . The table below summarizes
ANDERSON, SURR REB 14
Idaho Power Company
1 the resulting price per MWh for each time period. Under
2 Option A, Schedule 19 hours are modified to add a "Super
3 Off-Peak" period from 10 : 00 a.m. to 2 : 00 p.m. , Monday -
4 Friday, in both Summer (S) and Non-Summer (NS) seasons; all
5 remaining hours - except for On-Peak - are considered
6 "Base . " Under Option B, the existing Schedule 19 time
7 periods are modified by adding a year-round "Super Off-
8 Peak" from 10 : 00 a.m. to 2 : 00 p.m. , which splits the
9 current Off-Peak window into Off-Peak and Super Off-Peak.
10 Option C reflects current Schedule 19 time periods without
11 modification. The calculated Energy Charges for each time
12 period under each option are shown in Table 1 below.
13 Table 1. Derivation of Marginal Energy Charges for Scenarios Proposed by CEO
Marginal Energy Price Option A Option B Option C
($/MWh) White SUR REB Modified Sch 19 Current Sch 19
Season (S/NS) S NS S NS S NS
On-Peak $52.67 $48.69 $52.67 $48.69 $52.67 $48.69
Mid-Peak/"Base" $39.28 $40.31 $48.68 $45.62 $48.68 $41.51
Off-Peak N/A N/A $36.28 $38.83 $35.85 $38.06
Super Off-Peak $34.14 $32.94 $34.14 $32.94 N/A N/A
14 Capacity Cost Recovery (Demand vs . Volumetric)
15 Q. Does the Company agree with Ms . White that a
16 portion of capacity costs should be collected
17 volumetrically during higher risk hours?
18 A. No. The Company disagrees with recovering
19 capacity costs volumetrically as proposed by Ms . White .
20 Demand Charges most accurately reflect capacity cost
ANDERSON, SURR REB 15
Idaho Power Company
1 drivers and provide price stability. In my opinion, Ms .
2 White' s recommendation to shift capacity related fixed
3 costs into the volumetric Energy Charge would move pricing
4 further away from pricing reflective of cost; as I
5 explained in rebuttal, it would also place a larger share
6 of fixed costs at risk of recovery due to usage and weather
7 variability, while weakening peak management signals .
8 Additionally, in my opinion, Ms . White' s proposal
9 appears to depart from commonly accepted regulatory
10 practices . Across most jurisdictions, regulators have
11 approved demand-based pricing components to align recovery
12 with cost causation, promote efficient use of system
13 capacity, and help avoid cross-subsidies among customer
14 classes . Tariff designs often include minimum or
15 reservation demand provisions that require customers to
16 commit a baseline level of capacity. Those commitments
17 provide credible planning signals, reduce resource
18 redundancy and financial risk, and help ensure customers
19 pay in proportion to the demand they place on the system.
20 In short, demand-based structures discourage inefficient
21 consumption and support equitable cost recovery across
22 customer classes .
23 The Company' s position remains that capacity costs
24 should be recovered through Demand Charges, not
ANDERSON, SURR REB 16
Idaho Power Company
1 volumetrically, to reflect cost causation principles and
2 maintain fairness across customer classes .
3 III . NO-HARM FRAMEWORK & RESPONSES
4 No-Harm Analysis : Purpose & Limits
5 Q. How should the no-harm analysis inform the
6 Commission' s decision?
7 A. The no-harm analysis was designed to evaluate
8 whether the proposed pricing structure provides the
9 opportunity to mitigate cost shifting under defined
10 assumptions . It should not be used to develop pricing and
11 does not determine class allocation given that the costs
12 reflected are estimates or forecasts under the respective
13 scenarios for load assumptions and generation and
14 transmission resources available to be procured.
15 Q. How does the Company respond to criticisms of
16 intervenors regarding the inputs relied on by the Company
17 in the original no-harm analysis?
18 A. The Company relied on the most current
19 planning assumptions then available — the 2023 IRP — to
20 develop the no-harm analysis . The Company intended for the
21 analysis to support the initial development of pricing but
22 understood that ultimately future resource investments
23 would drive the need for a general rate case which is where
24 cost allocation to Micron FAB and other customers would be
ANDERSON, SURR REB 17
Idaho Power Company
1 effectuated. At the time the application in this case was
2 prepared and filed, the 2025 IRP had not yet been filed.
3 Q. Has the Company conducted an updated no-harm
4 analysis in response to intervenor concerns?
5 A. Yes . While the Company maintains that using
6 contemporaneous planning inputs was appropriate - its
7 evaluation was necessarily based on the information
8 available at the time and the reasonableness of its
9 analysis should not be assessed from the perspective of
10 hindsight - in order to address intervenor concerns of
11 staleness the Company has completed a revised no-harm
12 analysis using the 2025 IRP and the updated Micron FAB load
13 forecast. This update addresses the recency issues raised
14 by some intervenors and reinforces the conclusion that the
15 proposed pricing structure for the Micron FAB is equitable
16 and can mitigate upward pressure on prices for other
17 customers .
18 Updated No-Harm Analysis (2025 IRP Inputs)
19 Q. Was the methodology used to update the no-harm
20 analysis generally consistent with the original version?
21 A. Yes . As described by Company witness Mr.
22 Ellsworth, the Company used AURORA' S long-term capacity
23 expansion model to compare a base case that includes the
24 Micron FAB ("With Micron") to a counterfactual that removes
25 this load and re-optimizes the system to meet remaining
ANDERSON, SURR REB 18
Idaho Power Company
1 customer needs ("Without Micron") . This approach provides a
2 like-for-like comparison of total system costs and the
3 relative impacts to other customers under both scenarios .
4 Q. What timeframe and assumptions were used in
5 the 2025 no-harm analysis?
6 A. As more fully described in Mr. Ellsworth' s
7 surrebuttal testimony, the analysis was conducted using
8 inputs and planning assumptions from the 2025 IRP and
9 relied on an updated forecast of the Micron FAB' s expected
10 load profile, which Micron most recently updated in
11 December 2024 consistent with the terms of the ESA.
12 Q. Does the updated no-harm analysis using 2025
13 IRP inputs change the conclusion for other customers?
14 A. No. Using updated planning inputs confirms the
15 original conclusion: including Micron FAB does not increase
16 costs for other customers under the no-harm framework.
17 Similar to the original no-harm check, the updated analysis
18 remains a directional planning check, not a pricing
19 mechanism; allocation and price updates as contemplated in
20 the Micron FAB ESA would be addressed in future general
21 rate case proceedings . Both the original (2023 IRP) and
22 refreshed (2025 IRP) no-harm runs allocate embedded
23 demand-related costs using a full-year load-ratio share .
24
25
ANDERSON, SURR REB 19
Idaho Power Company
1 Consistency of No-Harm Statements
2 Q. How do you respond to Mr. Heckler' s assertion
3 that your testimony has been inconsistent in its
4 presentation of the no-harm analysis?
5 A. I do not agree with Mr. Heckler' s
6 characterization. In my direct testimony I explained that
7 the no-harm analysis was intended to evaluate whether
8 Micron FAB was sufficiently allocated its share of both
9 embedded and incremental system costs under the proposed
10 pricing structure and to confirm that it would not result
11 in inappropriate cost-shifting or subsidization by other
12 customers . Similarly, my rebuttal testimony reiterates that
13 the no-harm analysis was conducted to evaluate whether the
14 proposed initial pricing structure could reasonably
15 mitigate cost shifting. I have repeatedly described the
16 nature of the no-harm counterfactual analysis as being
17 based on a particular point in time in order to confirm at
18 the outset that the proposed pricing approach would not
19 result in inappropriate cost-shifting to existing
20 customers, which is consistent with my characterization of
21 the no-harm analysis as a directional tool in my rebuttal
22 testimony. Contrary to Mr. Heckler' s suggestion that the
23 term reflected a more "restrained" position, the discussion
24 was intended to emphasize that the no-harm analysis is a
25 directional planning comparison, not a pricing mechanism in
ANDERSON, SURR REB 20
Idaho Power Company
1 response to the flawed recommendation from Dr. Kaufman to
2 set initial pricing based on the difference in IRP
3 portfolio costs .
4 Load-Ratio Share Allocation Used in No-Harm
5 Q. Do you agree with Mr. Heckler' s concerns
6 regarding how the Company allocated the Micron FAB load in
7 the no-harm analysis and recommendation to use average load
8 instead?
9 A. No. Mr. Heckler incorrectly indicates that the
10 no-harm analysis assigned costs using a single-hour
11 coincident peak. The no-harm analysis uses a full-year
12 load-ratio share that is akin to a 12-month coincident peak
13 ("12CP") allocator. For each month, the Micron FAB' s
14 monthly load is divided by the system peak for that month
15 to produce a monthly load ratio share; those allocations
16 are applied across the year. This is not a single-hour
17 assignment and is appropriate for a planning check because
18 demand-related generation and transmission costs are driven
19 by peak or net peak demand criteria, not average load.
20 Using an average-load allocator would under-collect from
21 peak-driving conditions, over-collect from high-load-factor
22 customers, and weaken peak-management incentives . This
23 approach is consistent with common coincident peak-based
24 conventions used to reflect planning drivers .
25
ANDERSON, SURR REB 21
Idaho Power Company
1 Methods Used to Ensure "No Harm" Are Appropriate
2 Q. How does the Company respond to Mr . Heckler' s
3 contention that the methods used by the Company to ensure
4 other customers are not harmed were not adequate?
5 A. Idaho Power disagrees with Mr. Heckler' s
6 suggestion that the Company has not taken appropriate steps
7 to prevent harm to other customers . To the contrary, the
8 Company' s approach is multi-layered and robust including:
9 (1) a pricing framework that uses marginal-based energy and
10 embedded-based demand aligned with cost drivers; (2) a
11 no-harm planning comparison that was refreshed with 2025
12 IRP inputs and continues to show that including the Micron
13 FAB does not increase costs to other customers; (3) use of
14 a full-year load-ratio share for embedded demand-related
15 costs; and (4) governance safeguards - including Commission
16 review before any post-ramp shift from marginal to embedded
17 energy - to ensure ongoing protection of other customers .
18 Allocation mechanics, if revised, will be addressed in a
19 GRC for system-wide consistency.
20
21
22
23
24
25
ANDERSON, SURR REB 22
Idaho Power Company
1 IV. CONCLUSION
2 Q. Please summarize your recommendations .
3 A. I recommend the following:
4 (1) Approve ESA & Schedule 28 ; Compliance Update . Approve
5 the Contract Demand and Billing Demand Charges set
6 forth in Schedule 28, adjusted to reflect the composite
7 rate change authorized for special contract customers
8 in Case No. IPC-E-24-07, the Energy Charge set forth in
9 Schedule 28 adjusted to reflect the Commission-approved
10 marginal cost-based pricing in Case No. IPC-E-25-17,
11 with subsequent annual marginal cost-based updates as
12 approved by the Commission.
13 (2) Capacity Recovery via Demand Charges. Retain Demand
14 Charges for capacity cost recovery and reject
15 volumetric recovery of capacity-related fixed costs .
16 (3) Allocation Boundary to GRC. Defer future class-
17 allocation and direct-assignment questions to a general
18 rate case that includes Micron FAB in the test year.
19 Q. Does this conclude your surrebuttal testimony
20 in this case?
21 A. Yes, it does .
22
ANDERSON, SURR REB 23
Idaho Power Company
1 DECLARATION OF GRANT T. ANDERSON
2 I, Grant T . Anderson, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Grant T . Anderson. I am employed
5 by Idaho Power Company as the Pricing & Tariff Manager in
6 the Regulatory Affairs Department .
7 2 . On behalf of Idaho Power, I present this
8 pre-filed surrebuttal testimony and confidential exhibit in
9 this matter.
10 3 . To the best of my knowledge, my pre-filed
11 surrebuttal testimony and confidential exhibit are true and
12 accurate.
13 I hereby declare that the above statement is true to
14 the best of my knowledge and belief, and that I understand
15 it is made for use as evidence before the Idaho Public
16 Utilities Commission and is subject to penalty for perjury.
17 SIGNED this 29th day of August 2025, at Boise,
18 Idaho .
19
20 Signed:
21 (10
RANT T. ANDERSON
22
23
24
25
26
ANDERSON, SURR REB 24
Idaho Power Company
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. IPC-E-24-44
IDAHO POWER COMPANY
CONFIDENTIAL
ANDERSON , SURREBUTTAL
TESTIMONY
EXHIBIT NO. 3
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 )
ELECTRIC SERVICE TO MICRON IDAHO )
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC . )
IDAHO POWER COMPANY
SURREBUTTAL TESTIMONY
OF
JARED L. ELLSWORTH
1 Q. Please state your name .
2 A. My name is Jared L. Ellsworth.
3 Q. Are you the same Jared L. Ellsworth who
4 submitted direct and rebuttal testimony in this proceeding
5 on behalf of Idaho Power Company ("Idaho Power" or
6 "Company") ?
7 A. Yes .
8 Q. Have you had the opportunity to review the
9 pre-filed rebuttal and surrebuttal testimonies filed by the
10 intervenors to this proceeding?
11 A. Yes, I have .
12 Q. What is the scope of your surrebuttal
13 testimony?
14 A. My surrebuttal testimony addresses
15 intervenor positions related to transmission cost treatment
16 and system planning impacts . It also addresses criticisms
17 of the Company' s no-harm analysis by presenting updated
18 modeling based on Idaho Power' s 2025 Integrated Resource
19 Plan ("IRP") preferred portfolio.
20 Q. Does the fact that you do not address every
21 issue raised in the testimonies of other parties mean that
22 you agree with other parties' testimony on those issues?
23 A. No. It merely reflects that I chose not to
24 address all those issues . It should not be read as an
25 endorsement of, or agreement with, any unaddressed issues .
ELLSWORTH, SURR REB 2
Idaho Power Company
1 Q. For ease of reference, can you provide a table
2 of contents for your surrebuttal?
3 A. Please see the below table of contents for my
4 surrebuttal testimony:
Table of Contents Page
I . Transmission Expansion and Cost Responsibility 3
II . Updated IRP and No-Harm Modelling 5
III . Conclusion 9
5 I . TRANSMISSION EXPANSION AND COST RESPONSIBILITY
6 Q. Please summarize your understanding of the
7 intervenor rebuttal and surrebuttal positions regarding
8 Idaho Power' s treatment of interconnection costs under the
9 Micron FAB Special Contract or Energy Services Agreement
10 ("MESA") .
11 A. Similar to the concern raised by Dr. Lance
12 Kaufman, the consultant for the Idaho Irrigation Pumpers
13 Association, Inc. ("IIPA") , that some portion of
14 incremental transmission upgrades are not being adequately
15 charged to Micron, Clean Energy Opportunities for Idaho
16 ("CEO") , through its Policy Director, Mr. Michael Heckler,
17 suggests that the Company' s traditional method for
18 addressing customer specific incremental interconnection
19 costs is inadequate for the Micron FAB because the size of
20 the expected load is so large that its effects on the
21 transmission system are not limited to those traditionally
ELLSWORTH, SURR REB 3
Idaho Power Company
1 associated with physical interconnection to the
2 transmission or distribution system.
3 Q. What modifications to the ESA does Mr. Heckler
4 suggest to improve the proposed treatment of
5 interconnection costs?
6 A. Mr. Heckler recommends amending the ESA to
7 ensure that Micron covers additional transmission costs
8 beyond those needed as traditional Interconnection
9 Facilities, including some portion of the costs associated
10 with the Mayfield substation.
11 Q. Is the Mayfield substation solely
12 attributable to Micron FAB' s load, such that Micron should
13 bear additional upfront cost responsibility to offset the
14 project cost?
15 A. No . The Mayfield substation supports broader
16 system reliability and capacity. It serves multiple
17 customers and is part of Idaho Power' s long-term planning
18 for regional growth, grid reliability, and resource
19 interconnection needs .
20 Q. Should Section 6 . 1 of the ESA be amended to
21 include broader transmission costs?
22 A. No . Section 6 . 1 of the ESA already
23 establishes a clear and appropriate framework for
24 addressing additional infrastructure needs . It confirms
25 that Micron FAB is responsible for funding the
ELLSWORTH, SURR REB 4
Idaho Power Company
I interconnection facilities necessary to meet its Scheduled
2 Ramp Contract Demand and acknowledges that any further
3 transmission or substation upgrades required to reach the
4 full 507 megawatts will be addressed through a separate
5 construction agreement .
6 II . UPDATED IRP NO-HARM MODELLING
7 Q. How do you respond to those parties that have
8 called for the Company to update its no-harm analysis to
9 reflect changes in underlying assumptions that have
10 occurred since it was originally completed?
11 A. The Company' s original no-harm analysis was
12 necessarily based on the information available at the time
13 and grounded in the most current planning assumptions then
14 available -- the 2023 IRP -- and using contemporaneous
15 planning inputs was reasonable and appropriate . However, as
16 more fully explained in Mr. Anderson' s surrebuttal
17 testimony, the Company has conducted an updated no-harm
18 analysis in response to intervenor concerns in this case .
19 Q. Did the Company use the same modeling platform
20 to evaluate long-term system planning scenarios in the
21 updated no-harm analysis as it did in the original no-harm
22 analysis?
23 A. Yes . Idaho Power used the AURORA modeling
24 platform developed by Energy Exemplar as described in my
25 direct testimony. Specifically, Idaho Power relied on the
ELLSWORTH, SURR REB 5
Idaho Power Company
1 LTCE functionality to evaluate system buildouts over a
2 multi-year planning horizon.
3 Q. Has Idaho Power' s use of the Long-Term
4 Capacity Expansion ("LTCE") model and supporting tools—such
5 as Reliability and Capacity Assessment Tool ("RCAT") and
6 AURORA—remained consistent in the updated no-harm analysis?
7 A. Yes . The updated no-harm analysis continues to
8 rely on the same LTCE modeling framework and supporting
9 tools described in my direct testimony.
10 Q. How did Idaho Power develop the "With Micron"
11 and "Without Micron" scenarios relied upon for the updated
12 no-harm analysis?
13 A. To address concerns raised by intervenors
14 regarding the staleness of the assumptions relied on in the
15 original no-harm analysis, the Company relied on its 2025
16 IRP Preferred Portfolio for the "With Micron" scenario in
17 the updated analysis .
18 To evaluate the "Without Micron" scenario, a
19 counterfactual analysis was run that excluded Micron FAB' s
20 load and any proxy resources that were included to ensure
21 sufficiency in the early years of the portfolio. This
22 allowed the LTCE model to re-optimize the resource
23 portfolio accordingly. Other assumptions, such as system
24 load absent Micron FAB, anticipated market and fuel
ELLSWORTH, SURR REB 6
Idaho Power Company
1 conditions, and resource cost assumptions, remained
2 consistent with those relied upon in the 2025 IRP.
3 Q. What outputs did the LTCE model provide in the
4 two scenarios Idaho Power analyzed?
5 A. The LTCE model produced optimized resource
6 portfolios for each scenario — one that included Micron
7 FAB' s forecasted load and one that did not . For each case,
8 the model identified the type and quantity of new resource
9 additions required per year.
10 Q. What differences were observed in the
11 portfolios with and without Micron FAB?
12 A. The "With Micron" portfolio results in
13 additional natural gas, wind, solar, battery storage, and
14 demand response being selected throughout the planning
15 timeframe of 2026 to 2035 .
16 Q. Can you provide more detail on the resource
17 selections by year in the "With Micron" scenario?
18 A. Yes . Table 1 illustrates the modeled resource
19 selections for the "With Micron" portfolio by resource
20 type . The column labeled "DR" represents the amount of
21 Demand Response selected and the column labeled "EE"
22 represents energy efficiency.
23
24
25
ELLSWORTH, SURR REB 7
Idaho Power Company
1 Table 1 . LTCE Resource Selection "With Micron"
With Micron Scenario-Total Megawatts (MW)
Geothermal
Nuclear
Year Coal Gas/1-12 Wind Solar Storage DR EE Biomass
2026 (134) 261 - 125 250 - - -
2027 - - 600 420 100 - - -
2028 - - - 100 200 - - -
2029 - 150 100 - 155 10 - -
2030 (350) 650 - 100 - - - -
2031 - - - 400 - - 8 -
2032 - - - 200 - - - -
2033 - - - 100 50 - 21 -
2034 - - - - - - 6 -
2035 - - - - - - 5 -
2 Sub Total (484) 1,061 700 1,445 755 10 41 -
3 Q. How does this compare to the resource
4 selections by year in the "Without Micron" scenario?
5 A. Table 2 similarly illustrates the modeled
6 resource selections for the "Without Micron" portfolio.
7 Table 2 . LTCE Resource Selection "Without Micron"
Without Micron Scenario-Total Megawatts(MW)
Geothermal
Nuclear
Year Coal Gas/1-12 Wind Solar Storage DR EE Biomass
2026 (134) 261 - 125 250 - - -
2027 - - - 320 - - - -
2028 - - - - - - - -
2029 - 50 - - - - - -
2030 (350) 400 - 100 - - - -
2031 - - - 400 - - - -
2032 - 50 - 200 - - - -
2033 - 50 - - 5 - - -
2034 - - - - 5 - - -
2035 - - - - - - - -
8 Sub Total (484) 811 - 1,145 260 - - -
ELLSWORTH, SURR REB 8
Idaho Power Company
1 Last, Table 3 represents the difference between the
2 "With Micron" and "Without Micron" resource selection by
3 resource type and year.
4 Table 3 . LTCE Resource Selection "With vs . Without Micron"
With Micron vs.Without Micron
Geothermal
Nuclear
Year Coal Gas/H2 Wind Solar Storage DR EE Biomass
2026 - - - - - - - -
2027 - 600 100 100 - - -
2028 - - - 100 200 - - -
2029 - 100 100 - 155 10 - -
2030 - 250 - - - - - -
2031 - - - - - - 8 -
2032 - (50) - - - - - -
2033 - (50) - 100 45 - 21 -
2034 - - - - (5) - 6 -
2035 - - - - - - 5 -
5 Sub Total - 250 700 300 495 10 41 -
6 In summary, these tables demonstrate how the
7 system' s projected resources change over time and how
8 Micron FAB' s load affects the timing and scale of resource
9 needs .
10 III . CONCLUSION
11 Q. Please summarize your recommendations .
12 A. First, I recommend the Commission reject
13 proposals to expand Micron' s up-front cost responsibilities
14 beyond direct interconnection facilities .
15 Second, I recommend the Commission recognize the no-
16 harm analysis as initially filed and updated to reflect the
ELLSWORTH, SURR REB 9
Idaho Power Company
1 2025 IRP is based on best information available and uses
2 consistent modeling tools and assumptions .
3 Q. Does this conclude your surrebuttal testimony
4 in this case?
5 A. Yes, it does .
6
ELLSWORTH, SURR REB 10
Idaho Power Company
1 DECLARATION OF JARED L. ELLSWORTH
2 I, Jared L. Ellsworth, declare under penalty of
3 perjury under the laws of the state of Idaho:
4 1 . My name is Jared L. Ellsworth. I am employed
5 by Idaho Power Company as the Transmission, Distribution
6 and Resource Planning Director for the Planning,
7 Engineering and Construction Department.
8 2 . On behalf of Idaho Power, I present this
9 pre-filed surrebuttal testimony in this matter.
10 3 . To the best of my knowledge, my pre-filed
11 surrebuttal testimony is true and accurate.
12 I hereby declare that the above statement is true to
13 the best of my knowledge and belief, and that I understand
14 it is made for use as evidence before the Idaho Public
15 Utilities Commission and is subject to penalty for perjury.
16 SIGNED this 29th day of August 2025, at Boise,
17 Idaho .
18
19
20
21 Signed: `
22 JARED L. ELLSWORTH
23
24
25
26
ELLSWORTH, SURR REB 11
Idaho Power Company