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Home My WebLink About20251024Errata to Exhibit No. 3.pdf MAN FuwER., MEGAN GOICOECHEA ALLEN RECEIVED Corporate Counsel OCTOBER 24, 2025 mgoicoecheaallen(@idahopower.com IDAHO PUBLIC UTILITIES COMMISSION October 24, 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 Errata to Exhibit No. 3 of the Surrebuttal Testimony of Grant T. Anderson 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, n I f9CC� IJI�J(�ivl. Megan Goicoechea Allen MGA:cd Attachments 1221 W. Idaho St(83702) P.O.Box 70 Boise, ID 83707 MEGAN GOICOECHEA ALLEN (ISB No. 7623) DONOVAN WALKER (ISB No. 5921) Idaho Power Company 1221 West Idaho Street (83702) P.O. Box 70 Boise, Idaho 83707 Telephone: (208) 388-5317 Facsimile: (208) 388-6936 mgoicoecheaallenCa�,idahopower.com dwalkerCa-)_idahopower.com Attorneys for 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 ) IDAHO POWER COMPANY'S ELECTRIC SERVICE TO MICRON IDAHO ) ERRATA TO EXHIBIT NO. 3 OF SEMICONDUCTOR MANUFACTURING ) THE SURREBUTTAL (TRITON) LLC. ) TESTIMONY OF GRANT T. ANDERSON Idaho Power Company ("Idaho Power" or "Company") hereby respectfully submits to the Idaho Public Utilities Commission ("Commission") this Errata to Exhibit No. 3 accompanying the Surrebuttal Testimony of Grant T. Anderson ("Anderson Surrebuttal Testimony")filed on August 29, 2025, in this matter, to ensure accuracy, consistency, and clarity of the record as follows: 1. While preparing its response to the Second Production Request of the Industrial Customers of Idaho Power ("ICIP") issued on October 9, 2025, the Company identified the need to revise and update Exhibit No. 3 accompanying the Anderson Surrebuttal Testimony as more fully explained below. IDAHO POWER COMPANY'S ERRATA TO EXHIBIT NO. 3 OF THE SURREBUTTAL TESTIMONY OF GRANT T. ANDERSON - 1 2. As described on pages 18 and 19 of the Anderson Surrebuttal Testimony, Exhibit No. 3 presented an updated no-harm analysis using the 2025 Integrated Resource Plan ("IRP") and Micron FAB's most recent load forecast for a ten-year period (2026- 2035). In preparing a version of Exhibit No. 3 expanded over the twenty-year time frame as requested in ICIP's Second Production Request, the Company determined that certain portfolio costs were inadvertently omitted in both the With Micron and Without Micron scenarios and that the total revenue requirement was understated in both portfolios due to a discrepancy in the timing of certain revenue requirement. 3. Once it identified these issues, the Company prepared a revised Exhibit No. 3 adjusted as follows and confirmed that the adjustments did not result in a change to Company's conclusion that the Micron FAB does not increase costs for other customers: (1) incorporating the associated revenue requirement for 250 MW of battery energy storage systems and 261 MW of natural gas generation resources that had been inadvertently omitted from both the With Micron and Without Micron portfolios and (2) correcting a formulaic error affecting the timing of certain revenue requirement that had previously understated the total revenue requirement in both portfolios. 4. In addition to the adjustments described above, the Company incorporated two further updates. First, the embedded demand-classified revenue requirement was updated to more accurately reflect expected 2026 levels based on pending open dockets. Second, the load ratio share was revised to rely on Micron FAB's Contract Demand rather than its load forecast, which more appropriately reflects cost allocation. 5. As a result of these modifications and updates, the Company is providing a revised version of Exhibit No. 3 with this Errata to replace Exhibit No. 3 filed with the Anderson Surrebuttal Testimony on August 29, 2025. Revised Exhibit No. 3 does not IDAHO POWER COMPANY'S ERRATA TO EXHIBIT NO. 3 OF THE SURREBUTTAL TESTIMONY OF GRANT T. ANDERSON -2 change the conclusions of the no-harm analysis or necessitate any changes to the testimony itself and is being provided to ensure accuracy, transparency, and clarity of the record. Respectfully submitted this 24t" day of October 2025. Awrt, I MEGAN GOICOECHEA ALLEN Attorney for Idaho Power Company IDAHO POWER COMPANY'S ERRATA TO EXHIBIT NO. 3 OF THE SURREBUTTAL TESTIMONY OF GRANT T. ANDERSON - 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 24t" day of October 2025, 1 served a true and correct copy of Idaho Power Company's Errata to Exhibit No. 3 of the Surrebuttal Testimony of Grant T. Anderson 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. 27t" 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 dreading6a mindspring.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 el�echohawk.com Pocatello, Idaho 83205 Lance Kaufman, Ph.D. Hand Delivered 2623 NW Bluebell Place U.S. Mail Corvallis, OR 97330 Overnight Mail FAX FTP Site X Email lance aegisinsight.com IDAHO POWER COMPANY'S ERRATA TO EXHIBIT NO. 3 OF THE SURREBUTTAL TESTIMONY OF GRANT T. ANDERSON -4 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 17th Street, Suite 3200 darueschhoff(a-).hollandhart.com Denver, CO 80202 tnelson(o)_hol land hart.corn awjensen hollandhart.com karoach(a)_hol land hart.com aclee 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(o)_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(o-)_cleanenergyopportunities.com mike ,cleanenergyopportunities.com Christy Davenport Legal Administrative Assistant IDAHO POWER COMPANY'S ERRATA TO EXHIBIT NO. 3 OF THE SURREBUTTAL TESTIMONY OF GRANT T. ANDERSON - 5