20251118Direct Leyko.pdf

RECEIVE
November 18, 202
IDAHO PUBLIC
BEFORE THE UTILITIES COMMISSIO
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF IDAHO POWER )
COMPANY'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES ) CASE NO. IPC-E-25-16
AND CHARGES FOR ELECTRIC SERVICE )
IN THE STATE OF IDAHO )
Direct Testimony of
James A. Leyko
in Support of the Stipulation and Settlement
On behalf of
Micron Technology, Inc.
November 18, 2025

Table of Contents
I. SUMMARY ..........................................................................................................1
II. RECOMMENDATIONS........................................................................................2
Qualifications of James A Leyko
Leyko, DI (Stip) i
Micron Technology, Inc.

1 I. SUMMARY
2 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
3 A James A. Leyko. My business address is 16690 Swingley Ridge Road, Suite 140,
4 Chesterfield, MO 63017.
5 Q WHAT IS YOUR OCCUPATION?
6 A I am a consultant in the field of public utility regulation and a Senior Consultant with the
7 firm of Brubaker & Associates, Inc. ("BAI"), energy, economic and regulatory
8 consultants.
9 Q PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND EXPERIENCE.
10 A This information is included in Appendix A to my testimony.
11 Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING?
12 A I am appearing on behalf of Micron Technology, Inc. ("Micron"), a large customer of
13 Idaho Power Company ("IPC" or the "Company").
14 Q WHAT IS THE PURPOSE OF YOUR TESTIMONY?
15 A The purpose of my testimony is to support the unanimous Stipulation and Settlement
16 ("Stipulation")filed by the Company and the other parties to this proceeding on October
17 24, 2025. The Stipulation resolves all revenue requirement, class cost of service, and
18 rate design issues in this proceeding.
Leyko, DI (Stip) 1
Micron Technology, Inc.

1 II. RECOMMENDATIONS
2 Q DO YOU RECOMMEND APPROVAL OF THE STIPULATION?
3 A Yes. I recommend approval of the Stipulation. The Stipulation is a comprehensive
4 agreement that represents give and take among the parties and resolves the revenue
5 requirement, cost allocation, and rate design issues that would have likely been raised
6 by the parties in this proceeding. The Stipulation is a result of extensive arms-length
7 negotiations between the settling parties in order to reach a comprehensive settlement.
8 Notably, the Stipulation is within the range of outcomes that would have resulted from
9 a litigated case.
10 In sum, the Stipulation should be approved for the following reasons:
11 1. The stipulated overall revenue requirement will result in an overall level
12 of revenue for IPC that is just and reasonable and will allow the utility a
13 reasonable opportunity to earn a fair return on its investments. The
14 revenue requirement adjustments contained in the Stipulation represent
15 a compromise on the issues that would have been contested in this
16 case.
17 2. The stipulated revenue allocation reflects a compromise between the
18 parties to resolve the issues that would have been contested in this case
19 and is reasonably based on cost-of-service principles. The compromise
20 revenue allocation in the Stipulation is within the range of what would
21 have likely been the parties' litigated positions in this case.
22 3. The stipulated rate design for the various customer rates is fair,
23 reasonable, and in the public interest.
24 4. The Stipulation requires IPC to file a single-issue class cost of service
25 study case in advance of filing its next general rate case to allow the
26 parties and Commission to consider potential class cost of service
27 methodologies to be used in future rate cases.
28 5. The Stipulation provides for Commission Staff to initiate a workshop with
29 IPC and interested parties to discuss appropriate test-year
30 methodologies for future rate case.
31 6. The Stipulation is likely to reduce the Commission's administrative
32 burden and save rate case expenses for all parties.
Leyko, DI (Stip) 2
Micron Technology, Inc.

1 Q PLEASE DESCRIBE THE STIPULATION'S RESOLUTION OF THE COMPANY'S
2 REVENUE REQUIREMENT IN THIS PROCEEDING.
3 A The Stipulation resolves the revenue requirement issues that would have been raised
4 by parties in this rate case.
5 The Company's original filing in this docket proposed to increase base rate
6 revenues by$199.1 million, or a system average increase of 13.09 percent. Under the
7 Stipulation, the increase in total revenue was reduced to $110.0 million, or a system
8 average increase of 7.48 percent.'
9 The Stipulation reflects several adjustments to the Company's originally filed
10 revenue requirement, which are summarized in the table on page 5 of the Stipulation.
11 The Commission Staff ("Staff') and intervenors, including Micron, conducted robust
12 discovery prior to settlement discussions and provided a thorough and detailed
13 assessment of the Company's cost of service in these negotiations. Staff's and the
14 other intervenors' review and input was very useful in identifying and reaching an
15 agreement on the revenue requirement adjustments included in the Stipulation.
16 Q DID MICRON HAVE CONCERNS ABOUT ANY SPECIFIC COMPONENTS OF THE
17 COMPANY'S PROPOSED REVENUE REQUIREMENT?
18 A Yes. Micron had several concerns with IPC's originally proposed revenue requirement,
19 which are resolved by the compromise represented in the Stipulation. First, Micron
20 was concerned that the Company's proposed Return on Equity("ROE")of 10.4 percent
21 was excessive based on current market conditions. Micron conducted an independent
22 analysis of IPC's proposed ROE and concluded that we would, in the context of a
23 litigated case, likely advocate for an ROE in the range of 9.20 percent to 9.80 percent.
' Stipulation at 9.
Leyko, DI (Stip) 3
Micron Technology, Inc.

1 The Stipulation provides for a reasonable compromise between these positions and
2 recommends the Commission approve a 9.60 percent ROE.2
3 In addition, Micron had several other concerns with the Company's proposed
4 revenue requirement including the Company's measurement of rate base, the inclusion
5 of 2026 salary increases (which were outside the test year), and the need to update
6 revenues to account for actual results. In total, Micron estimated that its adjustments
7 related to these issues would have reduced the Company's claimed revenue deficiency
8 by at least the amount agreed to in the Stipulation. The adjustments are the same or
9 incremental to other adjustments that Micron understands that the Staff and other
10 intervenors would have raised. The Stipulation addresses several of Micron's various
11 revenue requirement adjustments and reflects a reasonable compromise of the various
12 issues presented in this proceeding and the parties' positions in those issues.
13 Q DID THE SETTLING PARTIES REACH AN AGREEMENT ON THE REVENUE
14 ALLOCATION?
15 A Yes. Stipulation Exhibit No. 1 provides the parties' agreement regarding revenue
16 allocation. Stipulation Exhibit No. 2 identifies the settlement rates agreed to by all
17 settling parties.
18 As particularly applicable to Micron, the Stipulation provides for an increase of
19 approximately 3.69 percent for Micron's Special Contract Rate Schedule 26.3 This
20 outcome generally follows the results of IPC's cost of service study, with adjustments
21 to recognize the need for gradualism for certain rate classes. However, the stipulated
22 revenue spread still recognizes that IPC's cost of service study concluded that Micron
23 warranted a cost-based rate change less than the system average rate increase. In
2 Stipulation at 13.
3 Stipulation Exhibit 2 at.26.
Leyko, DI (Stip)4
Micron Technology, Inc.

1 addition, Micron is satisfied with the rate design for Rate Schedule 26, as it generally
2 reflects cost-based rates based on Micron's preferred class cost of service study
3 methodology.
4 With regard to the other customer classes, Micron analyzed IPC's class cost of
5 service study and finds the revenue allocation reasonable based on the class cost of
6 service study proposed by IPC, including any adjustments to that study that Micron
7 would have proposed had this case been fully litigated.
8 Q DID THE SETTLING PARTIES AGREE UPON A PARTICULAR COST OF SERVICE
9 STUDY?
10 A No. The parties did not agree on any particular class cost of service methodology.
11 Instead, the settling parties negotiated a modified revenue allocation to adjust rates
12 and charges for each customer class. Further, the Stipulation provides for IPC to file a
13 single issue proceeding for the Commission to address IPC's class cost of service
14 methodology and associated policy issues. 4 The single-issue class cost of service
15 methodology case will provide a focused forum for robust consideration of various class
16 cost of service methodologies for the Company to use in future rate cases.
17 Q IN YOUR OPINION, IS THE STIPULATION REASONABLE AND IN THE PUBLIC
18 INTEREST?
19 A Yes. The settling parties compromised on their various positions to reach a Stipulation
20 that economically and efficiently resolves issues that would have been contested in this
21 case. The Stipulation provides the Company with the ability to update its rates to better
22 reflect current costs and a reasonable opportunity under current conditions to finance
4 Stipulation at 11-12.
Leyko, DI (Stip) 5
Micron Technology, Inc.

1 new investments while maintaining just and reasonable rates for its customers.5
2 Furthermore, approving the Stipulation will result in administrative efficiencies for the
3 Commission, Staff, and parties, and reduced rate case expenses to the benefit of all
4 PC customers.
5 Q DOES THIS CONCLUDE YOUR DIRECT TESTIMONY?
6 A Yes, it does.
5 Settlement Testimony of Timothy Tatum at 2:16-23.
Leyko, DI (Stip) 6
Micron Technology, Inc.

Qualifications of James Leyko
1 Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS.
2 A James Leyko. My business address is 16690 Swingley Ridge Road, Suite 140,
3 Chesterfield, MO 63017.
4 Q PLEASE STATE YOUR OCCUPATION.
5 A I am a Senior Consultant in the field of public utility regulation with the firm of Brubaker
6 &Associates, Inc. ("BAI"), energy, economic and regulatory consultants.
7 Q PLEASE SUMMARIZE YOUR EDUCATIONAL BACKGROUND AND EXPERIENCE.
8 A I received a Bachelor of Arts Degree in History from Tulane University in 2007. 1
9 attended Saint Louis University and received a Master of Business Administration
10 Degree in 2011. 1 joined BAI and served in the analyst department until 2012. Prior to
11 rejoining BAI as a Consultant in 2018, 1 worked as a Regulatory Economist for the
12 Maryland Public Service Commission and as the Regulatory Affairs Manager for the
13 Efficiency Maine Trust.
14 1 have written testimony and appeared as an expert witness before the Illinois
15 Commerce Commission, the Maine Public Utilities Commission, the Maryland Public
16 Service Commission, and the Oklahoma Corporation Commission, and have supported
17 filings for several regulated utility matters as a Consultant for BAI. These assignments
18 included revenue requirement issues such as incentive compensation and vegetation
19 management, income taxes, the impact of the Tax Cuts and Jobs Act of 2017, and
20 resource planning.
21 BAI was formed in April 1995. BAI and its predecessor firm have participated
22 in more than 700 regulatory proceedings in 40 states and Canada.
Appendix A
Leyko, DI (Stip) 1
Micron Technology, Inc.

1 BAI provides consulting services in the economic, technical, accounting, and
2 financial aspects of public utility rates and in the acquisition of utility and energy
3 services through RFPs and negotiations, in both regulated and unregulated markets.
4 Our clients include large industrial and institutional customers, state regulatory
5 agencies, and some utilities. We also prepare special studies and reports, forecasts,
6 surveys and siting studies, and present seminars on utility-related issues.
7 In general, we are engaged in energy and regulatory consulting, economic
8 analysis, and contract negotiation. In addition to our main office in St. Louis, the firm
9 also has branch offices in Corpus Christi, Texas; Louisville, Kentucky; and Phoenix,
10 Arizona.
11 36184240_v5
Appendix A
Leyko, DI (Stip) 2
Micron Technology, Inc.

I DECLARATION OF JAMES A. LEYKO
2 I, James A. Leyko, declare under penalty of perjury under the laws of the state of
3 Idaho:
4 1. My name is James A. Leyko. 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 testimony in support of the settlement stipulation in this matter.
8 3. To the best of my knowledge, my pre-filed testimony in support of
9 the settlement stipulation is 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 18th day of November 2025, Chesterfield, Missouri.
14 Signed: /
15
16 lames A. Leyko

CERTIFICATE OF SERVICE
I hereby certify that on November 18, 2025, a true and correct copy of the within and
foregoing DIRECT TESTIMONY OF JAMES L. LEYKO IN SUPPORT OF THE
STIPULATION AND SETTLEMENT ON BEHALF OF MICRON TECHNOLOGY, INC. IN
CASE NO. IPC-E-25-16 was served in the manner shown to:
Electronic Mail
Idaho Power Company Idaho Public Utilities Commission
Megan Goicoechea Allen Erika Melanson
Donovan E. Walker Monica Barrios-Sanchez
Timothy Tatum Idaho Public Utilities Commission
Connie Aschenbrenner 11331 W. Chinden Blvd., Building 8,
Matt Larkin Suite 201-A(83714)
Idaho Power Company PO Box 83720
1221 W. Idaho Street(83702) Boise, ID 83714
PO Box 70 Erika.melanson(&puc.idaho.gov
Boise, ID 83707-0070 secretgakpuc.idaho.gov
mgoicoecheaallennidahopower.com
dwalkerkidahopower.com
ttatum(a,idahopower.com
cas chenbrennerkidahopower.com
mlarkin(ab idahopower.com
docketskidahopower.com
Clean Energy Opportunities for Idaho
Courtney White Kelsey Jae
Mike Heckler 920 N. Clover Dr.
3778 Plantation River Drive, Suite 102 Boise, ID 83703
Boise, ID 83703 kelsey(a),kelseyjae.com
courtneykcleanenerg_yopportunities.com
mike(&,cleanenergyopportunities.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 lanceAae ism hg t.com
Pocatello, ID 83205
elo(aechohawk.com

City of Boise City Industrial Customers of Idaho Power
Ed Jewell Peter J. Richardson
Katie O'Neil Richardson Adams, PLLC
150 N. Capitol Blvd. 515 N. 27th Street
P.O. Box 500 Boise, ID 83702
Boise, ID 83701-0500 petergrichardsonadams.com
boisecityattorneygcityofboise.org
ei ewell&cityofboise.org
koneilkcityofboise.org
Federal Executive Agencies'
Emily W. Medlyn Dwight Ethridge
Jelani A. Freeman Exeter Associates, Inc.
U.S. Department of Energy 10480 Little Patuxent Parkway
1000 Independence Avenue, S.W. Suite 300
Washington, D.C. 20585 Columbia, MD 21044
emily.medlyn(khq.doe.gov detheridgegexeterassociates.com
j elani.freemankhq.doe.gov
Micron Technology, Inc. The Kroger Co.
Austin Rueschhoff Kurt J. Boehm
Thorvald A. Nelson Jody Kyler Cohn
Austin W. Jensen Boehm, Kurtz &Lawry
Kristine A.K. Roach 425 Walnut Street, Suite 2400
Holland& Hart, LLP Cincinnati, OH 45202
555 17th Street, Suite 3200 kboehm&bkllawfirm.com
Denver, CO 80202 jkylercohn(c bkllawfirm.com
darueschhoff khollandhart.com
tnelson(a,hollandhart.com
awj ens enkhollandhart.com
karoach(a,hollandhart.com
aclee&hollandhart.com
tlfrielAhollandhart.com
2

IdaHydro John Gannon, Deborah Fease, Amy
C. Tom Arkoosh Lorrance, Randy Morris
Nicholas J. Erekson John L. Gannon
Arkoosh Law Offices Deborah Fease
913 W. River Street, Suite 450 Amy Lorrance
P.O. Box 2900 Randy Morris
Boise, ID 83701 1104 Johnson Street
tom.arkooshkarkoosh.com Boise, ID 83705
nick.erekson ci,arkoosh.com iohngannon200(agmail.com
erin.cecilgarkoosh.com occidentalpacific&hotmail.com
feased854a,amail.com
Northwest Energy Coalition
Benjamin J. Otto
Lauren McCloy
Derek Goldman
1407 W Cottonwood Court
Boise, ID 83702
ben(&nwenergy.org
lauren&nwenergy org
derek cr,nwenergy.org
s/Tracy Friel
35290344_vl
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