20250902Rebuttal Testimony - Revised.pdf

RECEIVED
September 2, 2025
IDAHO PUBLIC
Austin Rueschhoff, ISB No. 10592 UTILITIES COMMISSION
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
HOLLAND&HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-24-44
COMPANY'S APPLICATION FOR )
APPROVAL OF SPECIAL CONTRACT AND ) MICRON TECHNOLOGY, INC.'S
TARIFF SCHEDULE 28 TO PROVIDE ) NOTICE OF REVISED DIRECT
ELECTRIC SERVICE TO MICRON IDAHO ) REBUTTAL TESTIMONY OF
SEMICONDUCTOR MANUFACTURING ) MICHAEL P. GORMAN
(TRITON) LLC. )
Micron Technology, Inc. ("Micron"), hereby files with the Commission:
1. Revised Direct Rebuttal Testimony of Michael P. Gorman (Confidential)
2. Revised Direct Rebuttal Testimony of Michael P. Gorman (Public)
3. Revised Errata Confidential Exhibit MPG-2
Mr. Gorman is revising his Direct Rebuttal Testimony and Confidential Exhibit MPG-2 to
correct calculations presented in his Direct Rebuttal Testimony. The revisions are presented on
page 17 lines 18-20 and Revised Errata Confidential Exhibit MPG-2, these revisions affect lines
14-17, 19, and 26.
1
MICRON TECHNOLOGY, INC.'S NOTICE OF FILING REVISED DIRECT REBUTTAL
TESTIMONY OF MICHAEL P. GORMAN
IPC-E-24-44

Respectfully submitted September 2, 2025.
HOLLAND & HART, LLr
By: 7�)- a,"y-'- 2 6��"
Austin Rueschhoff, ISB No. 1059
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
Kristine A.K. Roach
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
2
MICRON TECHNOLOGY, INC.'S NOTICE OF FILING REVISED DIRECT REBUTTAL
TESTIMONY OF MICHAEL P. GORMAN
IPC-E-24-44

CERTIFICATE OF SERVICE
I hereby certify that on September 2, 2025, a true and correct copy of the within and
foregoing MICRON TECHNOLOGY, INC.'S NOTICE OF FILING REVISED DIRECT
REBUTTAL TESTIMONY OF MICHAEL P. GORMAN was served in the manner shown to:
Electronic Mail
Idaho Power Company
Megan Goicoecha Allen Connie Aschenbrenner
Donovan E. Walker Grant T. Anderson
Idaho Power Company Idaho Power Company
1221 W. Idaho Street(83702) 1221 West Idaho Street(83702)
PO Box 70 P.O. Box 70
Boise, ID 83707-0070 Boise, Idaho 83707
mgoicoecheaallengidahopower.com Telephone: [phone]
dwalker(abidahopowencom Facsimile: [phone]
docketskidahopower.com caschenbrennergidahopower.com
ganderson(ab idahopower.com
Commission Staff Micron Technology, Inc.
Monica Barrios-Sanchez *Austin Rueschhoff
Commission Secretary *Thorvald A. Nelson
Idaho Public Utilities Commission Austin W. Jensen
11331 W. Chinden Blvd., Building 8, *Kristine A.K. Roach
Suite 201-A Holland& Hart, LLP
Boise, ID 83714 555 17th Street, Suite 3200
secretary(apuc.idaho.gov Denver, CO 80202
darueschhoff khollandhart.com
tnelson(a,hollandhart.com
awj ens enkhollandhart.com
karoach(a,hollandhart.com
*aclee(a,hollandhart.com
Idaho Irrigation Pumpers Association, Inc.
*Eric L. Olsen *Lance Kaufman, Ph.D.
ECHO HAWK& OLSEN, PLLC 2623 NW Bluebell Place
505 Pershing Avenue, Suite 100 Corvallis, OR 97330
P.O. Box 6119 lancegae isi�nsi hg t.com
Pocatello, ID 83205
elo(a,echohawk.com
3
MICRON TECHNOLOGY, INC.'S NOTICE OF FILING REVISED DIRECT REBUTTAL
TESTIMONY OF MICHAEL P. GORMAN
IPC-E-24-44

Industrial Customers of Idaho Power
*Peter J. Rickardson *Dr. Don Reading
Richardson Adams, PLLC 280 S. Silverwood Way
515 N. 27th Street Eagle, ID 83716
Boise, ID 83702 dreadingkmindspring com
peterkrichardsonadams.com
Clean Energy Opportunities for Idaho
*Kelsey Jae *Courtney White
920 N. Clover Drive *Mike Heckler
Boise, ID 83703 3778 Plantation River Drive, Suite 102
kelsey(kkelseyjae.com Boise, ID 83703
courtney�kcleanenergyopportunities.com
mike(&cleanenergyopportunities.corn
s/Adele Lee
35681415_v2
4
MICRON TECHNOLOGY, INC.'S NOTICE OF FILING REVISED DIRECT REBUTTAL
TESTIMONY OF MICHAEL P. GORMAN
IPC-E-24-44

NON-CONFIDENTIAL
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S
APPLICATION FOR APPROVAL OF A
SPECIAL CONTRACT AND TARIFF
SCHEDULE 28 TO PROVIDE ELECTRIC CASE NO. IPC-E-24-44
SERVICE TO MICRON IDAHO
SEMICONDUCTOR MANUFACTURING
(TRITON) LLC.
Revised Direct Rebuttal Testimony
and Exhibits of
Michael P. Gorman
On behalf of
Micron Technology, Inc.
July 30, 2025
ftum ER&ASSOCIATES,INC.
ENERGY.ECONOMIC AND REGULATORY CONSULTANTS
1215 FERN RIDGE PARKWAY.SUITE 208
POST OFFICES Box 412�j000
STPrS�§�Y4$2�40y0
FAxT314.275.7036
E-MAIL lYi­

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S
APPLICATION FOR APPROVAL OF A
SPECIAL CONTRACT AND TARIFF
SCHEDULE 28 TO PROVIDE ELECTRIC CASE NO. IPC-E-24-44
SERVICE TO MICRON IDAHO
SEMICONDUCTOR MANUFACTURING
(TRITON) LLC.
Table of Contents to the Direct
Rebuttal Testimony of Michael P. Gorman
Paqe
I. INTRODUCTION..................................................................................................... 1
II. SUMMARY..............................................................................................................2
III. RESPONSE TO STAFF WITNESS ELDRED .........................................................4
IV. RESPONSE TO IIPA WITNESS DR. KAUFMAN.................................................. 13
Qualifications of Michael P. Gorman ...............................................................Appendix A
Exhibit MPG-1: Confidential - IPC — Kaufman Marginal Cost Analysis
Exhibit MPG-2: Confidential — IPC — Revised Errata Cost of CCCT at 2026, 2030 and
2035
Gorman, Di-Reb, Rev. i
Micron Technology, Inc.

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IDAHO POWER COMPANY'S
APPLICATION FOR APPROVAL OF A
SPECIAL CONTRACT AND TARIFF
SCHEDULE 28 TO PROVIDE ELECTRIC CASE NO. IPC-E-24-44
SERVICE TO MICRON IDAHO
SEMICONDUCTOR MANUFACTURING
(TRITON) LLC.
Direct Rebuttal Testimony of Michael P. Gorman
1 I. INTRODUCTION
2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3 A. Michael P. Gorman. My business address is 16690 Swingley Ridge Road,
4 Suite 140, Chesterfield, Missouri 63017.
5 Q. WHAT IS YOUR OCCUPATION?
6 A. I am a consultant in the field of public utility regulation and a Managing Principal
7 with the firm of Brubaker & Associates, Inc. ("BAI"), energy, economic and
8 regulatory consultants.
9 Q. PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND
10 EXPERIENCE.
11 A. This information is included in Appendix A to my testimony.
12 Q. HAVE YOU PREVIOUSLY TESTIFIED BEFORE THE IDAHO PUBLIC
13 UTILITIES COMMISSION ("COMMISSION")?
14 A. Yes, I have previously testified before this Commission.
Gorman, Di-Reb, Rev. 1
Micron Technology, Inc.

1 Q. ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
2 A. I am appearing in this proceeding on behalf of Micron Technology, Inc.
3 ("Micron").
4 Q. WHAT IS THE PURPOSE OF YOUR DIRECT REBUTTAL TESTIMONY?
5 A. My testimony will address the Commission Staff's recommendations regarding
6 the proposed Electric Service Agreement ("ESA") between Micron and Idaho
7 Power Company ("IPC" or the "Company"). In addition, I respond to several
8 issues raised by Idaho Irrigation Pumper's Association ("IIPA") witness Dr.
9 Kaufman.
10 Q. DOES THE FACT THAT YOU DO NOT ADDRESS EVERY ISSUE RAISED IN
11 THE DIRECT TESTIMONY OF OTHER PARTIES MEAN THAT YOU AGREE
12 WITH OTHER PARTIES' TESTIMONY ON THOSE ISSUES?
13 A. No. It merely reflects that I did not choose to address all those issues. It should
14 not be read as an endorsement of, or agreement with, any unaddressed issues.
15 Q. ARE YOU SPONSORING ANY EXHIBITS IN CONNECTION WITH YOUR
16 REBUTTAL TESTIMONY?
17 A. Yes, Exhibits MPG-1 through MPG-2.
18 II. SUMMARY
19 Q. DO YOU HAVE ANY HIGH-LEVEL CONCERNS REGARDING IIPA AND
20 COMMISSION STAFF'S RECOMMENDATIONS?
21 A. Yes, I have significant concerns regarding Dr. Kaufman's recommendations,
22 and to a lesser extent, the recommendations of Commission Staff witness Mr.
23 Eldred. Idaho Power has an obligation to serve all customers within its
Gorman, Di-Reb, Rev. 2
Micron Technology, Inc.

1 certificated service territory by charging just and reasonable and
2 nondiscriminatory rates. The Commission has the responsibility to approve
3 such just and reasonable and nondiscriminatory rates. I am concerned that if
4 IIPA's and some of the Commission Staff's recommendations are approved, it
5 will result in Micron being forced to pay rates that are far higher than the cost to
6 serve Micron and operate under discriminatory terms and conditions. Micron is
7 certainly an atypical Idaho Power customer, but the Commission must approve
8 just and reasonable rates for Micron just as it does for all other customers.
9 Micron understands that the Commission has an obligation to approve rates and
10 terms of service that will ensure other customers do not subsidize Micron and
11 are not otherwise harmed by the Micron Triton Special Contract. However, the
12 Commission must also ensure that Micron is charged just and reasonable rates
13 that allow it to continue to operate its business as a major economic engine for
14 the City of Boise and the State of Idaho.
15 Q. DID IDAHO POWER DEVELOP A MICRON FAB ESA AND SCHEDULE 28
16 THAT ENSURES THE PRICES CHARGED TO MICRON WILL BE FAIR AND
17 REASONABLE TO ALL CUSTOMERS ON THE SYSTEM?
18 A. Yes. In his direct testimony, Company witness Mr. Anderson states that the
19 ESA and the related pricing elements were structured to be cost-based,
20 transparent, and reflective of the impact on the Company's load.' The Company
21 performed a "No-Harm" analysis to ensure that the ESA pricing would not shift
22 cost burdens onto other IPC customers.2
' Direct Testimony of IPC Witness Anderson at pages 4:8-18.
2 Id. at 14:14— 15:25.
Gorman, Di-Reb, Rev. 3
Micron Technology, Inc.

1 Staff largely supported the Company's ESA objectives stating that the
2 pricing under the contract should isolate the Company's cost of providing
3 service to the Micron Fab, and the contract cost of service should be allocated
4 and used to design contract rates in future general rate cases. Staff witness
5 Eldred opines that this methodology would ensure that other customers are not
6 harmed by the implementation of the ESA.3
7 Q. SHOULD THE COMMISSION APPROVE THE MICRON FAB ESA?
8 A. Yes, the Commission should approve the Micron Fab ESA as presented in IPC's
9 Application. IPC's analysis shows that the ESA will result in just and reasonable
10 rates for Micron and protect other IPC customers.
11 III. RESPONSE TO STAFF WITNESS ELDRED
12 Q. DOES STAFF RECOMMEND ANY MODIFICATIONS TO THE SPECIAL
13 CONTRACT?
14 A. Yes. Staff witness Eldred proposes changes in contract pricing terms related
15 to:
16 • Modifications for Marginal Cost-Based Energy Charges; and,
17 • Minimum monthly billing demand.4
18 Q. WHAT ARE STAFF WITNESS ELDRED'S RECOMMENDATIONS
19 REGARDING MARGINAL COST-BASED ENERGY PRICING?
20 A. Mr. Eldred recommends revising the Section 7.2 of the ESA to
21 1) Allow the ability to update the method used to determine the
22 Marginal Cost-Based Energy Charges; and
3 Direct Testimony of Staff witness Michael Eldred at 9:5-10.
4 Id. at 4:3-7.
Gorman, Di-Reb, Rev. 4
Micron Technology, Inc.

1 2) Require the Commission's approval to change from Marginal
2 Cost-Based Energy Charges to Energy Charges based on an
3 embedded rate or another basis. The Commission must find that
4 the change will not shift costs to other customers after the
5 scheduled ramp period.115
6 Mr. Eldred opines that the accurate measurement of marginal cost-
7 based energy rates is one of the major components of the ESA that will
8 mitigate the risk of higher costs caused by Micron's incremental load from
9 being passed on to other customers. He maintains that the Company should
10 be required to show that changing from a marginal cost basis to an
11 embedded cost basis will not harm other customers.6
12 Mr. Eldred is also proposing an update of the monthly energy charge
13 determination to be based on the period from April 2025 through March
14 2026, rather than March 2024 through March 2025. He states this updated
15 time period is more similar to the marginal energy rate approved in Case No.
16 IPC-E-25-17.'
17 Q. WHAT ARE YOUR RECOMMENDATIONS REGARDING STAFFS
18 PROPOSED MARGINAL COST- BASED ENERGY PRICING UNDER THE
19 ESA?
20 A. I agree with the Company's and Staff's positions that the ESA rates should
21 not shift costs to other customers. I also agree that any change to the way
22 that energy costs are reflected in the ESA's energy prices should be subject
23 to the Commission's review and approval. However, in determining the
5 Id. at 10:15-23.
6 Id. at 11:8- 12:3.
Id. at 12:4-20.
Gorman, Di-Reb, Rev. 5
Micron Technology, Inc.

1 appropriate contract demand and energy prices for the Micron Fab in any
2 future review of the contract energy prices or pricing structure, it is critical
3 that the Commission consider both the benefits and the costs that the ESA
4 will bring to the Company's system.
5 Q. WHY IS IT REASONABLE TO ALLOW THE ESA TO UPDATE THE
6 METHOD USED TO DETERMINE THE MICRON FAB'S ENERGY
7 CHARGES?
8 A. Under the ESA pricing terms, Micron will pay its allocated share of the
9 Company's system resource capacity costs in demand charges based on
10 the Commission-approved allocation process used in general rate cases.
11 Both the Company and the Staff support this approach.$ However, as the
12 Company adds generation resources that serve Micron, the cost of demand
13 and energy will likely shift.
14 Q. PLEASE EXPLAIN THE ANTICIPATED SHIFT CAUSED BY CHANGING
15 GENERATION RESOURCES.
16 A. The Company's planned resource additions include efficient Combined
17 Cycle Combustion Turbine ("CCCT") generation, battery storage and
18 wind/solar resources that have no fuel costs.9 All of these new capacity
19 resource additions will help to reduce the Company's average embedded
20 energy cost, but may not alter its marginal energy costs. Hence, as long as
21 Micron pays marginal energy rates rather than a portion of embedded
8 Direct Testimony of Staff witness Eldred at 14:4-10 and Direct Testimony of IPC witness Anderson at
7:1 9 8:2.
9 Direct Testimony of IPC witness Ellsworth at 10-11.
Gorman, Di-Reb, Rev. 6
Micron Technology, Inc.

1 system energy rates, Micron will pay the fixed capacity cost for these
2 resources but will not receive the benefit of the lower energy costs
3 associated them. This pricing structure will result in energy pricing benefits
4 to non-special contract customers. This can result in a reduction in costs to
5 the non-special contract customers, while Micron overpays. This outcome
6 exceeds the stated objective of ensuring "No Harm" to existing customers.
7 Q. HOW COULD THE COMPANY'S EXPECTED RESOURCE ADDITIONS
8 SHIFT THE MARGINAL ENERGY COSTS AND AVERAGE EMBEDDED
9 ENERGY COST TO SERVE THE MICRON LOAD?
10 A. Mr. Ellsworth's resource planning studies project marginal generation
11 resource additions that are needed to serve Micron to include: a large
12 gas/hydrogen ("H2") resource installed in 2026 (261 MW), wind resources
13 with delayed installation to 2030 (100 MW), solar resources with accelerated
14 installation in 2026 (100 MW) and 2030 (200 MW), several storage resource
15 additions in 2026 through 2033 totaling 275 MW, and demand response
16 resources of 100 MW.10
17 For gas resources. the Company's 2025 Integrated Resource Plan
18 ("IRP") estimates the cost of new large gas turbines using a proxy CCCT
19 resource with a very efficient heat rate of —/KWh.11 A CCCT
20 installed in 2026 may be dispatched ahead of the Company's existing
21 resources because it will be a very efficient conversion of fuel consumed to
22 electric energy generated. Hence, this resource will very likely reduce
10 Id. at 10.
" Case No. IPC-E-25-23, IPC 2025 Integrated Resource Plan—Appendix C: Technical Report, at 22.
Gorman, Di-Reb, Rev. 7
Micron Technology, Inc.

1 embedded energy costs. However, a CCCT may not meaningfully impact
2 marginal energy costs under economic dispatch because a highly efficient
3 low-cost generator like a CCCT will not frequently operate on the margin.
4 Similarly, the Company estimated that additional new wind and solar
5 resources will have zero fuel/energy cost. Solar/wind resources also will
6 likely reduce average embedded energy cost but will not likely impact the
7 Company's marginal cost of energy. Storage resources consume energy
8 during low-cost periods and discharge energy during higher-cost periods.
9 These resources also will likely produce reductions to IPC's average
10 embedded energy cost but will not likely produce reductions in IPC's
11 marginal energy costs.
12 Under the ESA pricing structure, Micron will pay a proportional share
13 of the system capacity portfolio resource costs via the ESA demand charges.
14 However, Micron will not receive the expected resource portfolio energy cost
15 savings from the new resources as long as the ESA energy price is based
16 on the Company's Marginal Cost-Based Energy Charge. Hence, allowing
17 for the conversion of the energy pricing charge after the expansion is
18 complete strikes a reasonable balance between establishing just and
19 reasonable rates for Micron and protecting other customers.
20 Q. WHAT ARE MR ELDRED'S CONCERNS REGARDING THE ESA
21 MINIMUM BILLING DEMAND CHARGES?
22 A. Mr. Eldred also states concerns related to the duration of the ESA minimum
23 monthly demand charge. Mr. Eldred states:
Gorman, Di-Reb, Rev. 8
Micron Technology, Inc.

1 1 recommend that the Minimum Monthly Billing Demand should not
2 be reduced per the schedule as stipulated in Section 5.5(b) of the
3 Special Contract, until it can be shown that the Micron FAB has
4 reached steady state. I recommend that reductions in the Minimum
5 Monthly Billing Demand should be revisited 5 years after the effective
6 date of the Embedded Contract Demand. This modification would
7 extend the take-or-pay provisions by 5 years. If at that time, Micron
8 can show stable loads and stability of revenue, the reductions in the
9 Minimum Monthly Billing Demand can begin at that time based on the
10 schedule in the proposed Special Contract.1112
11 Q. DO YOU HAVE COMMENTS CONCERNING THE EXTENSION OF
12 MINIMUM MONTHLY BILL PROVISIONS OF THE SPECIAL CONTRACT
13 RATE?
14 A. Yes. Both the Company and Staff state that the ESA should contain "take
15 or pay" provisions that require Micron to pay minimum monthly demand
16 charges for a certain period of time to ensure that Micron pays for the
17 expansion of Idaho Power's system even if Micron's projected load does not
18 materialize on the schedule anticipated.
19 Q. DO YOU AGREE WITH MR. ELDRED THAT THE COMMISSION SHOULD
20 EXTEND THE ESA TAKE OR PAY PROVISIONS FOR FIVE YEARS?
21 A. No. The ESA as proposed in the Company's Application provides robust
22 customer protections including the take or pay minimum monthly billing
23 demand requirement. IPC states that the ESA includes "stringent terms
24 intended to limit Micron's ability to request changes to [contract demand]
25 levels"13 and "robust customer protections" including "the strongest
26 customer protections the Company has ever implemented for a special
12 Direct Testimony of Staff Witness Mr. Eldred at 17:19— 18:5.
13 Direct Testimony of IPC Witness Aschenbrenner at 15:17-25.
Gorman, Di-Reb, Rev. 9
Micron Technology, Inc.

1 contract.1114 Extending the take or pay provisions by five years as proposed
2 by Mr. Eldred is unnecessary to protect other customers and could result in
3 discriminatory treatment by subjecting Micron to terms and conditions that
4 the Commission did not require for other recent special contracts. The
5 Commission should approve the take or pay provision in the proposed
6 contract.
7 Q. BEYOND THE CONTRACT'S EXISTING "TAKE OR PAY" PROVISIONS,
8 WHAT OTHER FACTORS REDUCE ANY RISKS ASSOCIATED WITH
9 MICRON'S LOAD NOT MATERIALIZING AS ANTICIPATED?
10 A. In addition to the take or pay provisions, two other factors mitigate any
11 remaining risks to customers. First, IPC is projecting load growth in several
12 of its customer classes and other large load additions in the coming years in
13 addition to the Micron Fab.15 If IPC load growth results in retail customer
14 demands that require the capacity in its resource portfolio to reliably serve
15 its customers, then the loss of the Micron load will not result in stranded
16 production investment.
17 Second, if IPC has production capacity in excess of the amount
18 needed to serve its retail customers, it can seek wholesale customers that
19 need additional production capacity. IPC can then enter a wholesale
20 contract for the sale of production capacity in excess of the amount needed
21 to reliably serve its retail customers.
14 Id. at 16:10-13.
15 See Table 1 below.
Gorman, Di-Reb, Rev. 10
Micron Technology, Inc.

1 Q. DOES THE MARKET REGION IN WHICH IPC OPERATES PROVIDE A
2 VIBRANT OPPORTUNITY TO SELL UNNEEDED PRODUCTION
3 CAPACITY INTO THE WHOLESALE MARKET?
4 A. Yes. IPC operates within Western Electricity Coordinating Council
5 ("WECC") and has opportunities to transact with entities through bilateral
6 wholesale energy markets in the Pacific Northwest, Intermountain West, and
7 the Desert Southwest. In addition, Idaho Power is a participant in the
8 Western Resource Adequacy Program ("WRAP"), which is an effort by a
9 group of load-serving entities in the West to provide increased reliability of
10 the regional power system through additional reporting and planning, and
11 the facilitation of energy and capacity sharing during critical hours. WRAP
12 is designed to allow for bilateral capacity contracts and capacity sharing
13 across members in order to ensure their ability to provide reliable service to
14 customers. Through its participation in the regional bilateral wholesale
15 energy markets and through its participation in WRAP, IPC may have
16 opportunities to sell generation capacity that is not needed to serve retail
17 customers across a larger wholesale market footprint.
18 Indeed, there appears to be a demand for capacity in the WECC. In
19 a July 2025 report, The North American Electric Reliability Corporation,
20 projected that the WECC region (which includes Colorado, Idaho, Montana,
Gorman, Di-Reb, Rev. 11
Micron Technology, Inc.

1 Oregon, Utah, Washington, Wyoming, parts of California, Nebraska, and
2 Nevada), may become capacity deficient in the period 2030 to 2035.16
3 Q. WHAT WILL HAPPEN IF THE MICRON TAKE OR PAY OBLIGATIONS
4 ARE EXTENDED, MICRON'S LOAD DOES NOT MATERIALIZE AS
5 EXPECTED, AND IPC IS ABLE TO MARKET ADDED GENERATION TO
6 ITS OWN CUSTOMERS OR CUSTOMERS IN THE WEST GENERALLY?
7 A. In that instance, IPC will be paid twice for the same capacity — once from
8 Micron through the demand rate take or pay provisions and then again from
9 IPC's own customers or wholesale market customers. From my perspective,
10 the negotiated ESA reasonably balances those considerations by including
11 a demand rate take or pay obligation for a time but then transitioning from
12 that approach to an approach where Micron simply pays for the capacity it
13 actually uses like all other customers in recognition of the value of those
14 generation resources to IPC and its other customers over time, even if
15 Micron's load does not materialize as anticipated. To avoid this
16 unreasonable result, the Commission should reject Staff's recommendation
17 to extend the take or pay provision of the ESA.
16 NERC, 2024 Long-Term Reliability Assessment, December 2024, Updated July 15, 2025, at 127.
(Available at
https://www.nerc.com/pa/RAPA/ra/Reliability°/o20Assessments%20DL/NERC_Long%20Term%20Reli
ability%20Assessment_2024.pdf).
Gorman, Di-Reb, Rev. 12
Micron Technology, Inc.

1 IV. RESPONSE TO IIPA WITNESS DR. KAUFMAN
2 Q. HAVE YOU REVIEWED DR. KAUFMAN'S ANALYSIS REGARDING THE
3 GENERATION REVENUE REQUIREMENT OF A NEW 500 MW HIGH LOAD
4 FACTOR CUSTOMER?
5 A. Yes. I have reviewed Dr. Kaufman's analysis in detail. He erroneously
6 recommends a generation revenue requirement for Micron of $186 per
7 megawatt-hour ("MWh"). A close inspection of his analysis and calculations
8 demonstrates that he did not accurately capture the difference in revenue
9 requirements between the two portfolios he studied and relied upon to estimate
10 the incremental cost of serving a new 500 MW high load factor customer.
11 Q. HOW DID DR. KAUFMAN DERIVE HIS $186 PER MWH INCREMENTAL
12 COST PRICING FOR THE MICRON EXPANSION?
13 A. Dr. Kaufman describes the rationale for his estimated incremental cost as
14 follows:
15 "IPC's 2025 Draft IRP estimates that the incremental cost of an
16 incremental 500 MW industrial load increases portfolio costs by
17 $186 per MWh. This represents the difference in annual revenue
18 requirement across the two portfolios divided by the difference in
19 retail load across the two portfolios. In other words, the cost of
20 serving each incremental MWh of energy in the 500 MW load
21 addition scenario costs $186 per MWh. If the new load pays
22 anything less than $186 per MWh, the excess costs to serve
23 Micron will be paid by existing customers.""
24 In his workpapers, Dr. Kaufman compared the incremental revenue
25 requirement and the incremental load between two of the Company's IRP
26 resource portfolios: 1) Preferred Portfolio, and 2) 500 MW Portfolio. Dr.
" Direct Testimony of IIPA Witness Kaufman at 4:19—5:4.
Gorman, Di-Reb, Rev. 13
Micron Technology, Inc.

1 Kaufman concludes that the 500 MW Portfolio adds a 500 MW Industrial
2 customer to the Preferred Portfolio.
3 The data used in Dr. Kaufman's methodology show that the average
4 portfolio cost over the period 2026 through 2045 in the Preferred Portfolio was
5 $82.50/MWh. His conclusion opines that if the new industrial customer in the
6 500 MW Portfolio is charged an incremental price of $186/MWh, then the other
7 customers in the 500 MW portfolio can be charged $82.50/MWh, the same as
8 the Preferred Portfolio. I have included Dr. Kaufman's workpaper for these
9 calculations as my Exhibit MPG-1 .
10 Q. IS DR. KAUFMAN'S INCREMENTAL COST ANALYSIS REASONABLE?
11 A. No. His marginal cost analysis is flawed for several reasons. First, the new
12 Micron load is already included in the Preferred Portfolio. The 500 MW Portfolio
13 includes the projected cost of an additional hypothetical new high load factor
14 customer that comes online around 2034, based on the difference in annual
15 energy load. Hence, his estimate for the additional 500 MW load reflects a new
16 load that takes service sometime around the year 2034 (in addition to the Micron
17 Fab at issue in this case). Dr. Kaufman's analysis does not directly measure
18 IPC's incremental cost of serving the Micron Fab load that would be subject to
19 pricing under the special contract proposed in this proceeding.
20 Second, Dr. Kaufman's analysis erroneously double counts certain costs
21 in each portfolio such that his marginal cost estimate of $186/MWh is
22 significantly overstated.
Gorman, Di-Reb, Rev. 14
Micron Technology, Inc.

1 Third, I disagree with Dr. Kaufman's suggestion that the ESA pricing
2 should be based on the 20-year average per unit cost of resource portfolio
3 projections based on IPC's IRP. Rather, the Company's proposed cost-based
4 pricing approach provides rate setting protection to all of its customers, including
5 Micron.
6 Lastly, the correct analysis to determine the impact of serving Micron's
7 load is to look at the total system costs under the Preferred Portfolio with and
8 without Micron's new load and associated contract revenues. The Company
9 has performed this analysis and determined that the embedded system cost
10 would actually decrease as a result of the inclusion of Micron's new load and
11 associated contract revenues.$
12 Q HOW DOES DR. KAUFMAN'S PROPOSED MARGINAL COST FOR
13 GENERATION FOR MICRON COMPARE TO THE COST OF GENERATION
14 FOR OTHER IPC CUSTOMERS?
15 A. Dr. Kaufman's estimated marginal generation price for Micron of $186/MWh
16 compares to the average cost for production resource capacity paid by other
17 customers generally of $37.57/MWh.19 Dr Kaufman's estimated marginal
18 production resource cost for Micron is about 5 times more expensive than the
19 average cost to other IPC customers.
20 Further, at $186/MWh, a 500 MW 90% load factor customer would incur
21 generation costs of about $733 million per year. This represents about 75% of
18 Direct Testimony of IPC Witnesses Ellsworth at 8-12 and Anderson at pages 14-16.
19 The $37.57 average cost is based on a 20-year average IRP resource cost corrected to remove the
double counting of resources cost included in Dr. Kaufman's workpapers for the Company's Preferred
Portfolio, as developed on my Exhibit MPG-1, page 2.
Gorman, Di-Reb, Rev. 15
Micron Technology, Inc.

1 the corrected average annual generation revenue requirement for the Preferred
2 Portfolio identified in IPC's 2025 IRP, and presented on my Exhibit MPG-1 , page
3 2, despite the load associated with the Triton facility being only about 15% of
4 the total system load when it has reached full operations.20
5 Q. DID DR. KAUFMAN OFFER OTHER SUPPORT FOR HIS INCREMENTAL
6 COST ESTIMATE FOR A NEW 500 MW CUSTOMER?
7 A. Yes. Dr. Kaufman outlined some incremental production resource costs in the
8 500 MW Portfolio which he claims support his conclusion that IPC's incremental
9 cost of serving a new 500 MW high load factor customer is approximately
10 $186/MWh. Dr. Kaufman references a battery storage facility and the Jackalope
11 Wind project with a levelized cost of capacity of
12 respectively.21 Without explanation, Dr. Kaufman asserts that these Ievelized
13 energy costs equate to a cost to serve a 90% load factor customer to be about
14 22 1 note that it is not reasonable nor even credible to
15 assume a battery facility and/or a wind facility can operate at a 90% capacity
16 factor to serve a high load factor industrial customer. The expected operation
17 for these resources would be a fraction of 90% and it is unreasonable to
18 compare such resources to a utility's portfolio of diverse resource types used to
19 reliably serve customers.
20 Estimated based on 500 MW load at 90% load factor relative to average annual MWh sales in the IRP
Preferred Portfolio.
21 Confidential Direct Testimony of IIPA Witness Kaufman at 5:11-13
22 Id. at 5:13-14.
Gorman, Di-Reb, Rev. 16
Micron Technology, Inc.

1 Q. DO THE RESOURCE OPTIONS INCLUDED IN THE 500 MW PORTFOLIO
2 SUPPORT AN INCREMENTAL COST OF $186/MWH TO SERVE A NEW 500
3 MW HIGH LOAD FACTOR INDUSTRIAL CUSTOMER?
4 A. No. Dr. Kaufman's suggestion that variable resources such as a battery and
5 wind resource would be the incremental resources needed to serve a high load
6 factor industrial customer is not reasonable. A portfolio of battery and wind
7 resources simply cannot provide IPC the operating flexibility needed to reliably
8 serve a large high load factor customer. IPC's 2025 IRP also includes capacity
9 resources that are more appropriate for serving high load factor customers,
10 such as a CCCT. A CCCT is projected to be able to convert fuel to electric
11 energy very efficiently, its heat rate conversion of fuel ("BTU") to electric energy
12 (KWh) is far better than the other resources included in the resource plan.23
13 Also, a CCCT can be ramped up and down and dispatched to serve variable
14 demands — making it useful as a backup to intermittent resources like wind/solar
15 — and used to manage power quality.
16 Q. WHAT DOES IPC'S IRP INDICATE IS THE INSTALLED COST OF A NEW
17 CCCT?
18 A. As shown on my CONF Exhibit MPG-2 Errata, the installed cost for a new
19 CCCT, assuming a S4.0/Dth delivered gas price and including 20% reliability
20 reserve adder, is around /MWh and /MWh in 2030,
21 and 2035, respectively.24 Thus the cost of a system that could actually reliably
23 Case No. IPC-E-25, IPC 2025 Integrated Resource Plan, Appendix C: Technical Report at 21.
24 This assumes a 90% load factor operation.
Gorman, Di-Reb, Rev. 17
Micron Technology, Inc.

1 serve a 500 MW high load factor customer is a fraction of the cost estimated by
2 Dr. Kaufman.
3 Q. PLEASE DESCRIBE THE DOUBLE COUNTING ERROR IN DR. KAUFMAN'S
4 ANALYSIS.
5 A. As shown in Exhibit 203 to Dr. Kaufman's testimony, he summed the difference
6 in annual revenue requirements between the Preferred Portfolio and the 500
7 MW Portfolio over the 20-year period, and then divided by the incremental
8 energy sales between the two portfolios over the same period. On my Exhibit
9 MPG-2, page 1, 1 show the data Dr. Kaufman used to develop his $186/MWh
10 incremental cost estimate.
11 Upon reviewing Dr. Kaufman's workpaper, it became evident that the
12 annual revenue requirements stated in Dr. Kaufman's Exhibit 203 for each
13 portfolio are overstated. Specifically, the annual revenue requirement consists
14 of resource costs, and the net cost of market purchases and market sales. Dr.
15 Kaufman's analysis erroneously double counts the resource costs in each year.
16 When corrected, the result of using Dr. Kaufman's methodology (which I do not
17 agree with)would be about$95/MWh, instead of the $186/MWh. The correction
18 to Dr. Kaufman's incremental cost analysis is shown on Exhibit MPG-1 , page 2.
Gorman, Di-Reb, Rev. 18
Micron Technology, Inc.

1 Q. WHY DO YOU DISAGREE WITH DR. KAUFMAN'S RECOMMENDATION TO
2 CALCULATE THE MARGINAL GENERATION COST OVER THE 20-YEAR
3 IRP PERIOD?
4 A. There are several reasons. First, the IRP represents the state of IPC's system,
5 projected load conditions, and projected costs based on a snapshot in time. The
6 actual costs incurred will depend on the result of various resource procurement
7 efforts that happen over time. It would be unreasonable to lock an ESA
8 customer into a marginal generation rate tied to projections that may or may not
9 materialize.
10 Second, Dr. Kaufman seems to overlook the fact that IPC's projected
11 system load growth beyond 2033 is not driven by large high load factor ESA
12 customers and is instead driven by other rate classes.25 This is shown below in
13 Table 1.
25 Case No. IPC-E-25, IPC 2025 Integrated Resource Plan, Appendix A: Sales and Load Forecast, at
8, Figure 2; at 33-34, Appendix Al.
Gorman, Di-Reb, Rev. 19
Micron Technology, Inc.

TABLE 1
2025 IRP Energy Sales Growth
Special Contract' Other Total IPC3
Thousands Annual Thousands Annual Thousands Annual
Year of MWh Increase of MWh Increase of MWh Increase
(1) (2) (3) (4) (5) (6)
2026 2,257 54.2% 14,733 - 16,990 5.8%
2027 4,279 89.6% 14,796 0.4% 19,075 12.3%
2028 5,795 35.4% 14,951 1.0% 20,746 8.8%
2029 7,016 21.1% 15,098 1.0% 22,114 6.6%
2030 7,663 9.2% 15,279 1.2% 22,942 3.7%
2031 8,748 14.2% 15,424 0.9% 24,172 5.4%
2032 9,309 6.4% 15,575 1.0% 24,884 2.9%
2033 9,307 0.0% 15,718 0.9% 25,025 0.6%
2034 9,329 0.2% 15,891 1.1% 25,220 0.8%
2035 9,332 0.0% 16,069 1.1% 25,401 0.7%
2036 9,346 0.2% 16,247 1.1% 25,593 0.8%
2037 9,333 -0.1% 16,400 0.9% 25,733 0.5%
2038 9,332 0.0% 16,518 0.7% 25,850 0.5%
2039 9,332 0.0% 16,642 0.8% 25,974 0.5%
2040 9,346 0.2% 16,778 0.8% 26,124 0.6%
2041 9,389 0.5% 16,869 0.5% 26,258 0.5%
2042 9,390 0.0% 16,970 0.6% 26,360 0.4%
2043 9,390 0.0% 17,097 0.7% 26,487 0.5%
2044 9,403 0.1% 17,224 0.7% 26,627 0.5%
2045 9,388 -0.2% 17,336 0.7% 26,724 0.4%
Sources & Notes:
' 2025 IRP, Appendix A1, page 44.
Includes Brisbie, LLC, INL, Lamb Weston, Micron Idaho Semiconductor
Manufacturing, Micron Technology, Simplot Caldwell, and Simplot Pocatello
Don Plant and other committed large load customers who have entered into
procurement or construction agreements with IPC but have not yet executed an
ESA.
2 2025 IRP, Appendix A1, pages 36-42.
Data not available to calculate the value for 2026.
3 2025 IRP, Appendix Al, page 34.
Gorman, Di-Reb, Rev. 20
Micron Technology, Inc.

1 As shown in the table, beginning in 2033 and continuing through 2045,
2 energy sales to special contract customers are expected to remain relatively
3 flat, while non-ESA customer sales are projected to continue increasing.
4 Further, as the cost of resource additions (used to support overall system
5 load growth) is included in rates in future general rate cases, Micron's contract
6 rates will be updated to reflect an allocation of those resource costs. Thus, Dr.
7 Kaufman's proposal to set the Micron Fab's generation revenue requirement at
8 the marginal rate based on 2025 IRP projections over the next 20 years is
9 unreasonable because it does not reflect the Company's cost of providing
10 service to the Micron Fab.
11 Q. DID DR. KAUFMAN ALSO SUGGEST THAT THE ESA ENERGY PRICE
12 SHOULD BE SET BASED ON LONG-RUN MARGINAL PRICE RATHER
13 THAN SHORT RUN MARGINAL PRICE?
14 A. Yes. Dr. Kaufman maintains that the hourly marginal prices during the
15 forecasted year are impacted by several factors. He says short run marginal
16 energy cost is an estimate of the market hourly price of energy. He states that
17 energy procurement over long periods of time will reflect costs that are not
18 considered in the short run marginal cost.26
26 Direct Testimony of IIPA Witness Kaufman at 9:4— 10:17.
Gorman, Di-Reb, Rev. 21
Micron Technology, Inc.

1 Q. PLEASE RESPOND TO DR KAUFMAN'S RECOMMENDATION THAT THE
2 ESA ENERGY CHARGE SHOULD BE BASED ON LONG RUN MARGINAL
3 COSTS.
4 A. I disagree. Dr. Kaufman's rationale confuses the IRP with rate setting. An IRP
5 study relies on various assumptions and projections in order to make a prudent
6 and informed investment decision to select infrastructure asset options that are
7 needed to provide reliable service at economic costs to customers.
8 Rate setting methodology on the other hand attempts to identify how
9 much revenue the utility needs to recover from customers in setting prices to
10 allow it to recover its cost of providing service based on the investment decisions
11 that have actually been made and form the infrastructure assets investments
12 that are being used to provide service to customers.
13 Contrary to Dr. Kaufman's representations, resource planning and rate
14 setting methodologies are different analyses. Planning studies help the utility
15 make prudent investment decisions and identify the best and lowest cost
16 resources needed to provide reliable utility service. Hence, planning studies
17 drive the utilities cost of providing service. In contrast, rate setting studies
18 establish the revenue requirement needed to allow the utility to recover its cost
19 of service including maintaining its financial integrity and access to external
20 capital markets. Setting rates to maintain a utility's financial integrity allows the
21 utility to access external capital markets to fund the asset investments identified
22 in the planning studies that are needed to provide service.
Gorman, Di-Reb, Rev. 22
Micron Technology, Inc.

1 Q. IF DR. KAUFMAN'S ANALYSIS IS CORRECTED, WOULD IT PRODUCE A
2 RELIABLE COST ESTIMATE FOR SERVING THE MICRON FAB
3 CONTRACT?
4 A. No. Dr. Kaufman's analysis simply is not reliable to produce a reasonable
5 estimate of IPC's incremental cost of serving the Micron Fab load. Specifically,
6 the Micron Fab load is already included in the Preferred Portfolio, it is not
7 included as an incremental cost in the 500 MW Portfolio. Hence, Dr. Kaufman's
8 suggestion that IPC's incremental cost of serving the Micron Fab load should
9 be based on the difference between the Preferred Portfolio and the 500 MW
10 Portfolio is not accurate.
11 Q HOW SHOULD IPC'S INCREMENTAL COST OF SERVING THE NEW
12 MICRON FAB LOAD BE MEASURED?
13 A. The most accurate way to measure IPC's ESA contract cost and to ensure other
14 customers are not harmed by the special contract is to accept IPC's
15 methodology for pricing the ESA contract. As described by IPC witness Mr.
16 Anderson, the ESA and the related pricing elements were structured to be cost-
17 based, transparent, and reflective of the impact on the Company's load.27
18 Q. WHAT IS THE OVERALL CONCLUSION OF YOUR REBUTTAL
19 TESTIMONY?
20 A. I recommend that the Commission approve the Micron Fab ESA as presented
21 in Idaho Power's Application.
27 Direct Testimony of IPC Witness Anderson at 4:10-13.
Gorman, Di-Reb, Rev. 23
Micron Technology, Inc.

1 Q. DOES THIS CONCLUDE YOUR REBUTTAL TESTIMONY?
2 A. Yes, it does.
Gorman, Di-Reb, Rev. 24
Micron Technology, Inc.

1 Qualifications of Michael P. Gorman
2 Q. PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3 A. Michael P. Gorman. My business address is 16690 Swingley Ridge Road,
4 Suite 140, Chesterfield, MO 63017.
5 Q. PLEASE STATE YOUR OCCUPATION.
6 A. I am a consultant in the field of public utility regulation and a Managing Principal
7 with the firm of Brubaker & Associates, Inc. ("BAI"), energy, economic and
8 regulatory consultants.
9 Q. PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND WORK
10 EXPERIENCE.
11 A. In 1983 1 received a Bachelor of Science Degree in Electrical Engineering from
12 Southern Illinois University, and in 1986, 1 received a Master's Degree in
13 Business Administration with a concentration in Finance from the University of
14 Illinois at Springfield. I have also completed several graduate level economics
15 courses.
16 In August of 1983, 1 accepted an analyst position with the Illinois
17 Commerce Commission ("ICC"). In this position, I performed a variety of
18 analyses for both formal and informal investigations before the ICC, including:
19 marginal cost of energy, central dispatch, avoided cost of energy, annual
20 system production costs, and working capital. In October of 1986, 1 was
21 promoted to the position of Senior Analyst. In this position, I assumed the
Appendix A
Gorman, Di-Reb, Rev. 1
Micron Technology, Inc.

1 additional responsibilities of technical leader on projects, and my areas of
2 responsibility were expanded to include utility financial modeling and financial
3 analyses.
4 In 1987, 1 was promoted to Director of the Financial Analysis Department.
5 In this position, I was responsible for all financial analyses conducted by the
6 Staff. Among other things, I conducted analyses and sponsored testimony
7 before the ICC on rate of return, financial integrity, financial modeling and
8 related issues. I also supervised the development of all Staff analyses and
9 testimony on these same issues. In addition, I supervised the Staff's review and
10 recommendations to the Commission concerning utility plans to issue debt and
11 equity securities.
12 In August of 1989, 1 accepted a position with Merrill-Lynch as a financial
13 consultant. After receiving all required securities licenses, I worked with
14 individual investors and small businesses in evaluating and selecting
15 investments suitable to their requirements.
16 In September of 1990, 1 accepted a position with Drazen-Brubaker &
17 Associates, Inc. ("DBA"). In April 1995, the firm of Brubaker & Associates, Inc.
18 was formed. It includes most of the former DBA principals and Staff. Since
19 1990, 1 have performed various analyses and sponsored testimony on cost of
20 capital, cost/benefits of utility mergers and acquisitions, utility reorganizations,
21 level of operating expenses and rate base, cost of service studies, and analyses
22 relating to industrial jobs and economic development. I also participated in a
Appendix A
Gorman, Di-Reb, Rev. 2
Micron Technology, Inc.

1 study used to revise the financial policy for the municipal utility in Kansas City,
2 Kansas.
3 At BAI, I also have extensive experience working with large energy users
4 to distribute and critically evaluate responses to requests for proposals ("RFPs")
5 for electric, steam, and gas energy supply from competitive energy suppliers.
6 These analyses include the evaluation of gas supply and delivery charges,
7 cogeneration and/or combined cycle unit feasibility studies, and the evaluation
8 of third-party asset/supply management agreements. I have participated in rate
9 cases on rate design and class cost of service for electric, natural gas, water
10 and wastewater utilities. I have also analyzed commodity pricing indices and
11 forward pricing methods for third party supply agreements, and have also
12 conducted regional electric market price forecasts.
13 In addition to our main office in St. Louis, the firm also has branch offices
14 in Corpus Christi, Texas; Detroit, Michigan; Louisville, Kentucky and Phoenix,
15 Arizona.
16 Q. HAVE YOU EVER TESTIFIED BEFORE A REGULATORY BODY?
17 A. Yes. I have sponsored testimony on cost of capital, revenue requirements, cost
18 of service and other issues before the Federal Energy Regulatory Commission
19 and numerous state regulatory commissions including: Alaska, Arkansas,
20 Arizona, California, Colorado, Delaware, the District of Columbia, Florida,
21 Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maryland,
22 Massachusetts, Michigan, Minnesota, Mississippi, Missouri, Montana, Nevada,
Appendix A
Gorman, Di-Reb, Rev. 3
Micron Technology, Inc.

1 New Hampshire, New Jersey, New Mexico, New York, North Carolina, North
2 Dakota, Ohio, Oklahoma, Oregon, South Carolina, South Dakota, Tennessee,
3 Texas, Utah, Vermont, Virginia, Washington, West Virginia, Wisconsin,
4 Wyoming, and before the provincial regulatory boards in Alberta, Nova Scotia,
5 and Quebec, Canada. I have also sponsored testimony before the Board of
6 Public Utilities in Kansas City, Kansas; presented rate setting position reports
7 to the regulatory board of the municipal utility in Austin, Texas, and Salt River
8 Project, Arizona, on behalf of industrial customers; and negotiated rate disputes
9 for industrial customers of the Municipal Electric Authority of Georgia in the
10 LaGrange, Georgia district.
11 Q. PLEASE DESCRIBE ANY PROFESSIONAL REGISTRATIONS OR
12 ORGANIZATIONS TO WHICH YOU BELONG.
13 A. I earned the designation of Chartered Financial Analyst ("CFA") from the CFA
14 Institute. The CFA charter was awarded after successfully completing three
15 examinations which covered the subject areas of financial accounting,
16 economics, fixed income and equity valuation and professional and ethical
17 conduct. I am a member of the CFA Institute's Financial Analyst Society.
18 35681350_v1
Appendix A
Gorman, Di-Reb, Rev. 4
Micron Technology, Inc.

I DECLARATION OF MICHAEL P. GORMAN
2 I, Michael P. Gorman, declare under penalty of perjury under the laws of the state
3 of Idaho:
4 1. My name is Michael P. Gorman. I am employed by Brubaker &
5 Associates, Inc. (`BAI") a consultant in the field of public utility regulation.
6 2. On behalf of Micron Technology, Inc., I present this pre-filed
7 revised direct rebuttal testimony and exhibit in this matter.
8 3. To the best of my knowledge, my pre-filed revised direct rebuttal
9 testimony and exhibit are true and accurate.
10 I hereby declare that the above statement is true to the best of my knowledge
11 and belief, and that I understand it is made for use as evidence before the Idaho
12 Public Utilities Commission and is subject to penalty for perjury.
13 SIGNED this 2nd day of September 2025, at Chesterfield, Missouri.
14 Signed:
15
16 s/Michael P. Gorman
17 35694304_v1