20251202Post Hearing Brief.pdf

RECEIVED
DECEMBER 2, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Austin Rueschhoff, ISB No. 10592
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]
Facsimile: [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 28 TO PROVIDE ) MICRON TECHNOLOGY, INC.'S
ELECTRIC SERVICE TO MICRON IDAHO ) POST-HEARING BRIEF
SEMICONDUCTOR MANUFACTURING )
(TRITON) LLC. )
December 2, 2025
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Table of Contents
I. INTRODUCTION...............................................................................................................4
II. LEGAL STANDARD.........................................................................................................6
III. ARGUMENT........................................................................................................................6
1. The ESA contains robust customer protection mechanisms and will result
in just and reasonable rates for all Idaho Power customers. ...................................6
a. The Construction and Procurement Agreements require Micron to pay
the initial cost for transmission and distribution facilities necessary to
interconnect and serve the Micron Fab. ............................................................7
b. The ESA requires Micron to pay Marginal Energy Charges Consistent
with other recent Special Contracts...................................................................9
c. The ESA allocates Micron's share of embedded demand charges and
imposes 21-year"take or pay"provisions to protect other customers............ 10
d. Idaho Power's no-harm analysis supports the reasonableness of the
ESAand proposed rates. ................................................................................. 13
c. The ESA Termination Payment protects other customers in the event
that Micron terminates the ESA...................................................................... 14
f. ESA Credit Support Requirements protect Other Customers from a
Microndefault. ................................................................................................ 15
g. Idaho Power's proposed Power Cost Adjustment("PCA") Accounting
isreasonable. ................................................................................................... 15
h. Even in the event of a Micron default, another entity could operate the
MicronFab. ..................................................................................................... 16
i. The Commission retains jurisdiction over the ESA........................................ 16
2. Micron's Response to the Idaho Irrigation Pumpers Association......................... 17
a. Idaho Power is not developing any generation or transmission
resources to exclusively serve Micron. ........................................................... 17
b. Dr. Kaufman's proposed pricing methodology is flawed, inconsistent
with Commission precedent, and should be rejected. ..................................... 18
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c. Dr. Kaufinan's proposal to use "long-run" marginal energy pricing is
undeveloped and flawed..................................................................................20
d. The Commission should give no weight to Dr. Kaufman's alternative
no harm analyses that were presented for the first time at hearing and
were not subject to rebuttal evidence. .............................................................21
e. Dr. Kaufman's proposed Termination Payment is an unreasonable
penalty against Micron. ...................................................................................23
3. Micron's proposed Alternative ESA Language to Address Staff Witness
Eldred's Recommendations...................................................................................23
a. ESA Section 5.5(b) Minimum Monthly Billing Demand...............................24
b. 7.2 Marginal Cost-Based Energy Charges......................................................26
4. Response to Clean Energy Opportunities of Idaho's Cost Allocation and
RateDesign proposals...........................................................................................27
5. The Commission should not withhold approval of the ESA based on the
potential for future legislative changes. ................................................................28
IV. CONCLUSION.................................................................................................................29
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I. INTRODUCTION
Micron Technology, Inc. ("Micron") urges the Idaho Public Utilities Commission
("Commission" or "IPUC")) to approve Idaho Power Company's ("Idaho Power" or the
"Company") proposed Special Contract for electric service between Idaho Power and Micron
Idaho Semiconductor Manufacturing (Triton) LLC for Micron's new memory manufacturing
fabrication complex ("Micron Fab") and rates proposed in tariff Schedule 28. The Micron Fab
Special Contract is also referred to herein as the Energy Services Agreement("ESA").
The Micron Fab is a new large load on the Idaho Power system. Accordingly, Micron and
Idaho Power carefully negotiated an ESA and Idaho Power carefully designed tariff rates to meet
two core goals—serve Micron's load at just and reasonable rates,terms, and conditions that reflect
the complexities of serving Micron and, equally importantly, protect all other Idaho Power
customers from harm, consistent with Idaho Power's obligation to serve all customers within its
service territory at just and reasonable rates. While this specific ESA is unique, the methods and
principles used by Idaho Power are consistent with several other special contracts for large
customers approved by the Commission in the past,including the existing Micron Special Contract
and Schedule 26 that was originally approved in 1995.
The record shows that Idaho Power negotiated robust customer protections and the Micron
ESA includes the"strongest customer protections the Company has ever implemented for a special
contract."' These robust customer protections include:
• Micron's upfront payment of construction and procurement costs necessary to
connect the Micron Fab to Idaho Power's system,
• Charging Micron marginal energy charges to recover incremental and variable
energy costs,
' Tr.at 329:10-12(IPC-Aschenbrenner Direct at 16).
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• Minimum Billing Demand "take or pay" charges that commit Micron to pay for
capacity whether or not Micron uses it,
• An ESA Termination Payment methodology that compensates Idaho Power for up
to 21 years if Micron terminates the ESA,
• Credit support requirements that cover Micron's obligations including the full
amount of the termination payment if Micron's credit rating decreases,
• Continued Commission jurisdiction over the ESA and setting demand and marginal
energy charges pursuant to an approved cost of service allocation, and
• Commission jurisdiction over the annual updates to the marginal cost of energy
charges.
Idaho Power has provided substantial evidence showing that these measures will protect
current customers from harm. Commission Staff("Staff') generally agrees and recommends only
a few changes that will be discussed later in this brief.
Another critical point is that the rates proposed by Idaho Power are not being set for the
life of the contract. On the contrary, the rates are specifically designed such that the level of the
rate and the methodology used to calculate the rate can and will be periodically revisited through
rate filings. As such, the Commission retains the power to make adjustments as necessary and
appropriate going forward and need not attempt to speculate at this time about every possible future
possibility in order to make sure all customers are protected through the life of the contract.
While the Commission must ensure that the ESA does not cause rates to other Idaho Power
customers to become unjust or unreasonable, the Commission must equally ensure that the ESA
results in just and reasonable and not unduly discriminatory rates for Micron. The Commission
must view this question against the backdrop of the existing special contracts under which Idaho
Power serves other large customers and the evidence presented in this proceeding. Some parties
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to this proceeding recommend the Commission order changes to the ESA that would result in
discriminatory and unreasonable rates for Micron. These recommendations should be rejected.
Micron asks the Commission to approve the ESA as proposed by Idaho Power using the
rates proposed by Idaho Power to allow Micron to continue to invest in and operate its business as
a major economic engine for the City of Boise and the State of Idaho.
II. LEGAL STANDARD
Idaho Power has an obligation to serve all customers in its service territory.2 Pursuant to
its tariffs approved by the Commission, any customer with demand greater than 20 MW requires
a special contract.3 All customers, including those under a special contract, are entitled to just and
reasonable rates that are not unduly discriminatory.4 When the Commission reviews a special
contract it must evaluate whether the proposed rates and methodology to reset rates in the future
violate the public interests The Commission should review this application for whether the ESA
is just and reasonable and not unduly discriminatory. If the ESA meets these requirements the
Commission should find that it is in the public interest and approve the ESA.
III. ARGUMENT
1. The ESA contains robust customer protection mechanisms and will result in
just and reasonable rates for all Idaho Power customers.
Idaho Power tariffs require special contracts for service requests greater than 20 MW.
Idaho Power witness Ms. Aschenbrenner testified that the use of special contracts:
• Allow for the unique characteristics of a customer of[Micron's] size to be captured
within the terms of a Commission-approved ESA;
2 Idaho Code§ 61-507;Tr.at 319:9-11 (IPC-Aschenbrenner Direct at 9).
s Idaho Power Tariff Schedule 19.
a Idaho Code§ 61-502;Tr.at 620:10-13.
5 Bunker Hill Co. v. Wash. Water Power Co.,98 Idaho 249,254,561 P.2d 391,396(1977);Tr.at 319:22-321:2(IPC-
Aschenbrenner Direct at 9-10).
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• Allow for specific cost-of-service information for each ESA customer to be
reviewed during rate proceedings; and
• Can include provisions intended to protect the Company and its other retail
customers from the impacts that some large loads could impose because of their
sheer size and operating characteristics.6
The record contains extensive evidence of the risk mitigation protections in the ESA that
are supported by both Idaho Power and Staff. These risk mitigation measures protect Idaho
Power's existing customers from negative rate impacts associated with serving the Micron Fab.
Idaho Power and Staff also testify that the customer protections are the strongest the Company has
ever implemented for a special contract.' A discussion of each provision and how it specifically
protects non-special contract customers is below.
a. The Construction and Procurement Agreements require Micron to pay the
initial cost for transmission and distribution facilities necessary to
interconnect and serve the Micron Fab.
The Construction and Procurement Agreements$ensure that Micron will cover the entirety
of Idaho Power's costs to construct the transmission and distribution facilities required to connect
the Micron Fab to Idaho Power's system.9 These facilities include a new substation, distribution
equipment, new transmission line segments to serve the substation, and relocation of certain
existing transmission and distribution lines.10 Importantly, Ms. Aschenbrenner testifies that the
scope of work covered under the Construction Agreement is limited to facilities that would not be
constructed by Idaho Power but for Micron's request. 11 She further confirmed that"Idaho Power
6 Tr.at 315:4-14(IPC-Aschenbrenner Direct at 6).
Tr.at 329:10-12(IPC-Aschenbrenner Direct at 16);Tr. at 835:2—836:2(Staff-Eldred Direct at 21-22).
s Idaho Power's Application for Approval of Special Contract and Tariff Schedule 28, Confidential Attachments 3
and 4.
9 Tr.at 322:21 —323:2(IPC-Aschenbrenner Direct at 11).
10 Tr. at 76:7-11 (IPC-Ellsworth Direct at 13).
" Tr. at 318:22—319:5(IPC-Aschenbrenner Direct at 8-9).
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does not procure generation or transmission resources that are solely dedicated to an individual
customer."12 Consistent with other primary-service level customers, Idaho Power will retain
ownership of the newly constructed distribution substation and the transmission that feeds into that
substation up to the point of delivery. Micron is required to install, own, and maintain all
distribution facilities downstream from the point of delivery.13 Micron will fund the full cost of
all upgrades through a Contribution in Aid of Construction ("CIAC").14 Micron has already paid
tens of millions in CIAC funds based on the initial estimate of the costs." After upgrade
completion, Idaho Power will reconcile project costs and ensure Micron directly funds all
incremental upgrades.16 Under the principles of cost causation, assigning these costs to Micron is
just and reasonable because these upgrades are used exclusively by Micron.17
Staff also testified that it supports the terms included in the Procurement and Construction
Agreements and the costs included in those Agreements.18 Staff testified that "the terms will
ensure the Company recovers the appropriate upfront infrastructure costs necessary to connect the
Micron Fab to the system" and that the "terms included in the Agreements are consistent with
other large load customer requests."19 Staff witness Mr. Eldred also points out that"[i]f additional
facilities are required to meet the Micron FAB demand, the Special Contract in Section 6.1
includes a term that requires a separate construction agreement to be created that will ensure
Micron pays for these costs."20
12Id.
"Tr. at 324:3-11 (IPC-Aschenbrenner Direct at 12).
14 Idaho Power's Application for Approval of Special Contract and Tariff Schedule 28, Confidential Attachments 3
and 4(describing the specific cost estimates).
is Id.;Tr.at 76:17-26(IPC-Ellsworth Direct at 13).
16 Tr. at 76:17—77:9(IPC-Ellsworth Direct at 13-14).
17 Tr. at 318:9-18(IPC-Aschenbrenner Direct at 8).
18 Tr. at 813:13 (Staff-Eldred Direct at 5).
19 Tr. at 813:14-18(Staff-Eldred Direct at 5).
20 Tr. at 813:18-22(Staff-Eldred Direct at 5).
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b. The ESA requires Micron to pay Marginal Enemy Charles Consistent
with other recent Special Contracts.
The ESA protects existing customers by charging Micron Marginal Energy Charges,
(rather than embedded energy charges21) based on the marginal cost of serving the Micron Fab's
energy needs.22 The marginal energy charge structure is important because it "recognize[s] that
the variable costs associated with serving a new large load of this magnitude will be met with
marginal resources, and therefore a marginal cost-based energy price is appropriate."23 This is
consistent with how Idaho Power has treated other recent special contracts that have been approved
by the Commission.24 Idaho Power witness Mr. Anderson explained how the Company has
worked closely with Staff to refine the methodology it uses to develop marginal energy prices.
Additionally, the ESA provides for "annual filing updates to the Energy Charge based on the
proposed marginal cost methodology ...[which] allows the pricing to reflect changes in fuel prices,
market dynamics, hydro conditions, and other planning variables that affect the Company's cost
to serve the incremental energy needs."25 Mr.Anderson also explained that the company evaluated
the feasibility and rationale of applying a time-of-use ("TOU")-based marginal cost pricing
structure for the Micron Fab, but ultimately concluded that "TOU pricing was not appropriate or
necessary under the circumstances."26 Additionally, the ESA provides continued Commission
oversight over the ESA charges by requiring Commission approval for changes to the methodology
to charging marginal energy prices or to switch to charging embedded energy changes.27
21 Existing customers pay embedded energy costs which reflect the historic costs of operating the utility and providing
service.
22 Tr. at 165:3-4(IPC-Anderson Direct at 10);ESA Section 7.2.
2s Tr. at 325:3-7(IPC-Aschenbrenner Direct at 13).
24 Tr. at 175:19-22(IPC-Anderson Direct at 18).
25 Tr.at 167:15-20(IPC-Anderson Direct at 12);ESA Section 7.2.
26 Tr. at 169:6-11 (IPC-Anderson Direct at 13).
27 Tr. at 336:5—338:5 (IPC-Aschenbrenner Direct at 4-5);ESA Sections 7.2, 13.2,and 14.1.
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Mr. Gorman, Micron's expert witness, also explained how charging Micron marginal
energy rates will benefit non-special contract customers. Mr. Gorman explains that Idaho Power's
"planned resource additions include efficient Combined Cycle Combustion Turbine generation,
battery storage and wind and solar resources that have no fuel costs."28 These new capacity
resources will help to reduce the Company's average embedded energy costs but may not alter its
marginal energy costs.29 Therefore, as long as Micron pays marginal energy rates rather than
embedded energy rates, Micron's energy rate payments will be higher than Idaho Power's average
energy cost thus creating extra revenue to offset the energy costs that need to be recovered from
Idaho Power's other customers.
Staff supports the ESA's proposed method and annual update for determining the marginal
energy charges. Mr. Eldred recommends an amendment to Section 7.2 to clarify that the
Commission has jurisdiction to update the method used to determine the energy charges.30 Micron
does not oppose such clarification.
c. The ESA allocates Micron's share of embedded demand charges and
imposes 21-year "take or pay" provisions to protect other customers.
The ESA contains embedded contract demand charges and aggressive "take or pay"
Minimum Monthly Billing Demand charges to recover Micron's share of system capacity costs.31
Prices associated with the ESA demand charges are based on embedded system capacity costs
following the cost-of-service allocation methodology consistent with Idaho Power's 2023 General
Rate Case.32 The demand charges will be updated to reflect the final outcome of the currently
2'Tr. at 435:19-22(Micron-Gorman Rebuttal,Rev.at 6).
29 Tr. at 435:22-25(Micron-Gorman Rebuttal,Rev.at 6).
so Tr. at 817:15-25(Staff-Eldred Direct at 9).
"ESA Section 5.5.
32 Tr. at 161:1-6(IPC-Anderson Direct at 7).
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pending 2025 General Rate Case.33 As Mr. Anderson testifies, using cost allocation from the last
approved general rate case is "aligned with the Commission-reviewed approaches used in other
recent special contract agreements."34 Additionally, consistent with the method reviewed by the
Commission in other special contracts, the ESA Contract Demand rate is based on Idaho Power's
Open Access Transmission Tariff ("OATT") which "provides a consistent, transparent, and
equitable benchmark for setting capacity-related charges in the ESA. ,35 The demand-related
charges will be consistently updated throughout the ESA to reflect the cost to serve Micron within
Idaho Power's General Rate Cases.
The aggressive "take or pay" provisions lock-in Contract Demand and Minimum Billing
Demand during the ESA to protect existing customers from potential cost shifting if the Micron
load does not materialize on the expected schedule. Between now and 2030, during the "ramp
period," the ESA requires Micron to adhere to its forecasted load ramp and pay for the forecasted
capacity whether it uses it or not.36 These charges specifically align the Micron Fab's projected
load during expansion with the costs that Idaho Power will incur to procure the necessary resources
in advance to serve that load. Whether the load materializes or not,Micron is still obligated to pay
the Minimum Monthly Billing Demand charge on the predetermined schedule.37 Micron can only
minimally adjust its forecasted load ramp and must do so well in advance of expected changes.38
This protects existing ratepayers by ensuring that when Idaho Power procures the resources to
s3 Tr. at 236:18-25.
sa Tr. at 161:6-9(IPC-Anderson Direct at 7).
ss Tr. at 163:12-21 (IPC-Anderson Direct at 8).
36 Tr. at 327:18-23 (IPC-Aschenbrenner Direct at 15);ESA Section 5.2 and 5.5(a).
37 See ESA Exhibit 3 (showing the increasing minimum billing demand dates).
38 Tr. at 327:23—329:6(IPC-Aschenbrenner Direct at 15-16);ESA Section 5.2(a)and 5.5(a).
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serve the Micron Fab, Micron will pay for those resources as planned, even if it is behind
schedule.39
After the ramp up period,the ESA's"take or pay"provisions continue to protect customers
for 16 years into the future. The ESA provides that after 2030, the Micron Fab minimum demand
payments will reduce 30 MW annually until reaching a floor of 20 MW.40 Thus, after the Micron
Fab reaches its peak demand of 507 MW in 2030, Micron will still be on the hook for significant
Minimum Billing Demand charges for 16 years until the minimum demand reaches 20 MW.41
Thus,taking the five year ramp up and 16 years thereafter together, Micron will remain subject to
"take or pay"charges for a total of 21 years. This provision ensures meaningful protection of other
customers if the Micron load does not develop as quickly as planned.
Finally, the "take or pay" provisions not only protect existing customers from harm but
could also provide significant benefit to existing customers if the Micron load does not arrive as
projected. Idaho Power is projecting load growth in several of its customer classes and other large
load additions in the coming years in addition to the Micron Fab.42 If the Micron load does not
arrive as projected, Idaho Power can allocate that capacity— that Micron is paying for—to serve
other customers and resulting in lower costs to other customers at Micron's expense. Additionally,
if Idaho Power procures capacity for Micron that Micron does not need or use, Micron will still
pay for that capacity while Idaho Power may be able to sell excess capacity on the wholesale
market. This ability to reallocate unused contract resources or resell those resources in the
s9 Tr. at 329:23—330:2(IPC-Aschenbrenner Direct at 16-17).
ao ESA Section 5.5(a).
ai Tr. at 858:18-21; ESA, Exhibit 2 Part B (507 MW minus the 20 MW demand floor equals 487 MW. 487 MW
divided by 30 MW annual reduction equals 16.23 years.).
42 Tr. at 443:15-17,460:1 (Micron-Gorman Rebuttal,Rev.at 10,20)(citing Idaho Power's 2025 Integrated Resource
Plan,Appendix Al at 34-44).
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wholesale market provides additional contract economic protection for other Idaho Power
customers.
d. Idaho Power's no-harm analysis supports the reasonableness of the ESA
and proposed rates.
Idaho Power prepared and presented a "no-harm analysis" to demonstrate that the ESA
pricing structure and underlying methodology does not result in inappropriate cost-shifting to
existing customers. The analysis quantifies whether the Micron Fab is sufficiently allocated its
share of both embedded and incremental system costs and to confirm that other customers are not
subsidizing the Micron Fab load. To prepare the no-harm analysis,Idaho Power used AURORA'S
Long-Term Capacity Expansion model to compare two scenarios: one that includes the Micron
Fab load and a counterfactual case where the Micron Fab load is removed, and the model re-
optimizes the system resource additions to meet remaining customers' resource needs without
Micron.43 This approach provides a comparison of the system costs and rate impacts to existing
customers with and without the Micron Fab on the system.44 In response to discovery, Idaho
Power provided an updated version of the no-harm analysis on October 24, 2025, which
demonstrated that other Idaho Power customers are better off with the Micron Fab load than they
are without. Specifically, between 2026 and 2035, the Idaho Power rates are projected to be
$44.17/MWh on a total basis and $44.13/MWh on a net present value basis with Micron and
$44.77/MWh on a total basis and $44.80/MWh on a net present value basis without Micron.45
While Staff witness Mr. Eldred stated that he did not rely specifically on the no-harm
analysis in his recommendation to approve the ESA, Mr. Eldred stated that he believed "the
43 Tr. at 77:12-25(IPC-Ellsworth Direct at 14).
as Id.
45 IPC-Anderson Surrebuttal,Confidential Revised Exhibit 3.
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Company's input assumptions and evaluation of risk variables used in the no-harm analysis were
reasonable based on the information known at the time the analysis was performed.',46
Mr. Eldred's conclusion not to over-emphasize the no-harm analysis is perfectly logical
because the Commission retains the ability to adjust both (a) the demand and energy rates in the
Micron ESA and(b)the methodology used to calculate those rates in future rate filings. That fact
makes it wholly unnecessary to attempt to speculatively address every possible future scenario in
this case. Rather than having to speculate, the Commission retains the power and the tools to
adjust rates in the future as necessary and appropriate to ensure that the ESA does not cause harm
to customers over time. Furthermore, all parties will have the opportunity in those future cases to
present evidence and arguments to the Commission to aid in that analysis.
e. The ESA Termination Payment protects other customers in the event that
Micron terminates the ESA.
The ESA includes a substantial Termination Payment that compensates Idaho Power and
its remaining customers if Micron terminates the ESA before 2046. To terminate the ESA,Micron
must provide a minimum of 12 months' notice and pay the net present value of the estimated
monthly charges for contract demand and billing demand over a set period.47 The significant scope
of the Termination Payment is provided in the illustrative demonstration in ESA Exhibit 2.
Additionally, the figures in the illustrative ESA Exhibit 2 are almost certainly too low as they are
based on a monthly billing demand rate that is lower than the Micron Fab will be charged following
the conclusion of the 2025 Idaho Power electric rate case. Because the ESA provides for a
Termination Payment for 16 years after the Micron Fab reaches a steady state, the Termination
"Tr. at 832:10-13 (Staff-Eldred Direct at 19).
47 ESA Sections 3.1,3.3;Tr.at 858:5-24(discussing the practical implications of the Termination Payment being tied
to contract demand ramp-down).
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Payment ensures that Idaho Power has time and opportunity to adjust its capacity needs in the
event of an early termination and that Micron will compensate Idaho Power for early termination
stranded contract costs. The Termination Payment provides Idaho Power sufficient time to adjust
resource plans to balance its resource capacity with its ongoing customer demands.
f. ESA Credit Support Requirements protect Other Customers from a
Micron default.
The ESA requires Micron to provide credit support that Idaho Power can draw on, if
necessary, to recover the Termination Payment or any other event of default.48 Micron already
provided its initial credit support'49 but in the event Micron's credit is downgraded the ESA
requires additional credit support equivalent to the total Termination Payment.50 The ESA entitles
Idaho Power to draw on the Credit Support for any damages or obligations to which Idaho Power
is entitled.51 Thus, Micron's credit support further protects existing customers by ensuring that
the Termination Payment, or any other obligations owed to Idaho Power, will be paid if required.
g. Idaho Power's proposed Power Cost Adjustment ("PCA") Accounting is
reasonable.
Idaho Power proposes to flow the costs of supplying energy to the Micron FAB through
the PCA and treat the energy related revenues under the ESA as a surplus sale and an offset to
power supply costs.52 Accordingly, Idaho retail sales would not include the Micron FAB energy
sales in the sales-based adjustment in the PCA and the annual PCA rates would not be applicable
to Micron FAB energy sales.53 Idaho Power and Staff agree this is a prudent allocation of costs
as ESA Section 10.
a9 ESA Section 10.1
'0 ESA Section 10.2;ESA Exhibit 2.
"ESA Section 10.3.
12 Tr. at 331:24—332:1 (IPC-Aschenbrenner Direct at 18-19).
13 Tr. at 332:2-5 (IPC-Aschenbrenner Direct at 19).
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between Micron and other schedules and is consistent with other special contracts.54 This protects
existing customers.
h. Even in the event of a Micron default, another entity could operate the
Micron Fab.
Termination payments and credit support protect Idaho Power and existing customers in
the event that Micron defaults on its obligations. Importantly, even if Micron did default on its
obligation and was unable to continue under the ESA, the Micron Fab is a valuable and cutting-
edge facility in a critical supply chain and could be acquired and operated by another company.
Given the billions of dollars invested in semiconductor fabs, companies often sell or repurpose
facilities as that is far more economical than shutting down and dismantling them. While it is
unlikely that Micron would become unable to fulfill its obligations under the ESA, even in that
event it is certainly possible that the Micron Fab would attract another company to acquire the
Micron Fab and continue to take service from Idaho Power, thereby reducing the risk of stranded
assets.
i. The Commission retains jurisdiction over the ESA.
The ESA builds in Commission oversight of future pricing adjustments. Schedule 28's
contract demand charge and billing demand charges"are based on embedded system capacity costs
following the cost-of-service allocation methodology consistent with the Idaho Power 2023
General Rate Case ("GRC") Settlement Stipulation in Case No. IPC-E-23-11.,,55 In the next rate
case, the Commission can review the cost allocation modeling and revise the marginal cost of
energy.56 Further, the Marginal Cost of Energy is subject to an annual update and Commission
sa Tr. at 837:19-24(Staff-Eldred Direct at 23);Tr.at 332:6-8(IPC-Aschenbrenner Direct at 19).
ss Tr. at 161:1-6(IPC-Anderson Direct at 7).
16 Tr. at 654:11-22.
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approval.' Thus,as Idaho Power's system evolves and costs and benefits change,the Commission
will still control the ultimate cost allocation within the ESA and, therefore, the rates charged to
Micron.
2. Micron's Response to the Idaho Irrigation Pumpers Association
Idaho Irrigation Pumpers Association's ("IIPA") witness Dr. Kaufman recommends
adjustments to the ESA that would result in unjust and unreasonable rates and would be unduly
discriminatory to Micron. The Commission should reject Dr. Kaufman's recommendations as
discussed below.
a. Idaho Power is not developing any generation or transmission resources to
exclusively serve Micron.
Dr. Kaufman's testimony incorrectly implies that Idaho Power is acquiring new generation
and transmission resources exclusively to serve Micron and that Micron should therefore pay the
incremental cost of such generation rather than an allocated share of Idaho Power's embedded
system costs. However, at hearing, Dr. Kaufman could not identify a single generation or
transmission resource that is being acquired exclusively to serve Micron.58 The record is clear that
Idaho Power is experiencing load growth in several of its customer classes and that while Micron
is a unique example of load growth, Idaho Power is expanding its system for several customer
classes.59 Mr. Anderson states directly that:
[P]lanned transmission projects are not solely necessitated by Micron Fab;
recognizing Micron Fab's system impact means Micron Fab will bear its allocated
share, which also alleviates some of the burden from other customers. These are
system resources—not facilities dedicated solely to Micron Fab. System generation
and transmission are planned, procured, and operated to optimize service for all
57 ESA Section 7.2.
58 Tr. 619:14—620:3.
59 Tr. at 443:15-17,460:1 (Micron-Gorman Rebuttal,Rev. at 10,20) (citing Idaho Power's 2025 IRP, Appendix Al
at 34-44);Tr.at 269:11-13.
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customers. Assigning costs by vintage rather than by cost causation is not an
approach the Company supports.60
b. Dr. Kaufman's proposed pricing methodology is flawed, inconsistent with
Commission precedent, and should be reiected.
Dr. Kaufman recommends the Commission reject Idaho Power's proposed ESA pricing
structure and instead base pricing on Idaho Power's Integrated Resource Plan ("IRP") and
forecasted incremental costs of new generation. Dr. Kaufman originally estimated the cost of
doing so to be $186/MWh but later corrected an error in his initial analysis and reduced the
estimated price to $95/MWh.61 Even after correcting his error Dr. Kaufinan's recommendation is
inconsistent with the cost to serve Micron and how Idaho Power will actually serve Micron's load.
Dr. Kaufinan's proposed $95/MWh price should be rejected for several reasons.
First, as Idaho Power explains,Dr. Kaufman's methodology of comparing two forecasts in
the IRP as a definitive cost to serve a specific customer is "misleading and misrepresents the
function and purpose of the IRP."62 Dr. Kaufinan's proposed cost using the 20-year IRP portfolio
includes "forecasted long-term resource costs —many of which Idaho Power does not have
certainty will occur at the time or cost forecasted. ,63 This is problematic because:
[B]asing prices on modeled portfolio costs intended to inform long-term planning
decisions would bypass the regulatory process that ensures fair and equitable cost
allocation. Additionally, a 20-year average ignores the timing of both resource
investment and load development, which are critical to aligning costs with cost
causation.64
The Commission should reject Dr. Kaufinan's analysis because Idaho Power has shown
that it"disregards actual test year costs and relies on long-term planning assumptions that do not
6'Tr. at 211:9-18(IPC-Anderson Surrebuttal at 7).
61 Tr. at 469:3-8.
62 Tr. at 186:3-5 (IPC-Anderson Rebuttal at 7).
63 Tr. at 188:20-24(IPC-Anderson Rebuttal at 9).
64 Tr. at 190:5-11 (IPC-Anderson Rebuttal at 10).
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determine future rates or reflect used-and-useful principles. This methodology is inconsistent with
standard ratemaking practices and should not be used to establish pricing for Micron."65
Furthermore, Dr. Kaufman's argument that Idaho Power's proposed pricing is too low, is
incorrectly"based on the initial pricing for the special contract... [and] assum[es] that the pricing
for the special contract would not change in any future rate case over the next 20 years and all
future increases would be fully borne by other customers. This is not what has been proposed in
the special contract and the application in this docket. ,66
Mr. Gorman also discusses the flaws with Dr. Kaufman's generation revenue requirement
analysis. Mr. Gorman points out that Dr.Kaufman's proposed pricing uses specific battery storage
and wind projects and uses them to price the cost to serve Micron.67However, again, Idaho Power
will serve Micron, like all Idaho Power customers, using a portfolio of diverse resources and a
limited subset of specific resources. Additionally, Mr. Gorman shares Mr. Anderson's views that
the IRP presents projections and that the"actual costs incurred will depend on the result of various
resource procurement efforts that happen over time."68 "It would be unreasonable to lock an ESA
customer into a marginal generation rate tied to projections that may or may not materialize."69
Indeed, because these future resource costs are not yet known, adopting Mr. Kaufman's proposal
to lock in the ESA pricing now will erode the pricing protection contemplated in the proposed
ESA. The ESA pricing structure proposed by Idaho Power and Micron includes pricing protection
to non-special contract customers for the resource cost uncertainty. This protection comes in the
form of ESA pricing adjustments in future rate cases. As the cost of resource additions used to
6s Tr. at 186:14-19(IPC-Anderson Rebuttal at 7).
66 Tr. at 190:17-24(IPC-Anderson Rebuttal at 10).
67 Tr. at 455:13—456:20(Micron-Gorman,Rev. at 16-17).
68 Tr. at 459:7-9(Micron-Gorman Rebuttal,Rev. at 19).
69 Tr. at 459:9-11 (Micron-Gorman Rebuttal,Rev.at 19).
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support overall system load growth is included in rates in future general rate cases, Micron's
contract rates will be updated to reflect an allocation of those actual resource costs.70 Thus, Dr.
Kaufman's proposal to set the Micron Fab's generation revenue requirement at the marginal rate
based on 2025 IRP projections over the next 20 years is unreasonable because it does not reflect
the Company's cost of providing service to the Micron Fab.71
c. Dr. Kaufman's proposal to use "long-run" marginal enemy pricing is
undeveloped and flawed.
The Commission should also reject Dr. Kaufman's recommendation to charge Micron's
ESA energy rates using a"long-run marginal price"rather than short-run marginal pricing. As an
initial matter, nowhere in Dr. Kaufman's testimony does he explain what he means by "long-run
marginal pricing," provide an estimate of long-run energy costs, or even explain how the
Commission would calculate long-run energy costs.72 Dr. Kaufman also admits that calculating
energy costs based on long-run marginal pricing would require Idaho Power to develop pricing
based on several forecasts, including the costs of natural gas and coal required to run thermal
generation as well as the cost of future Power Purchase Agreement resources.73
Additionally, Dr. Kaufman argues in support of using a long-run marginal price concept
that "a long run marginal price is a better price signal because it provides better information for
customers making long run energy decisions."74 However, he does not recommend the use of
long-run marginal pricing to charge Irrigation customers, the class he represents, energy costs.75
70 Tr. at 461:6-10(Micron-Gorman Rebuttal,Rev. at 21).
77 Tr. at 461:10-14(Micron-Gorman Rebuttal,Rev. at 21).
72 Tr. at 632:14-19;633:8-12.
73 Tr. at 635:18—636:23.
74 Tr. at 586:4-6(IIPA-Kaufman Surrebuttal at 19).
75 Tr. at 638:23—639:22.
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Finally,Dr. Kaufman did not cite any examples in Idaho or elsewhere in the country where energy
rates have been set using long-run marginal costs.76
Idaho Power witness Mr. Anderson also disagrees with Dr. Kaufman's recommendation to
use long-run energy prices. Mr. Anderson explains that the short-run energy prices are reasonable
becausethey:
[P]rovide[] actionable, time-sensitive price signals based on near-term market
conditions, system operations,and updated expectations for hydro,fuel,and system
dispatch. In contrast, long-run marginal costs are based on projected future
investments—such as those associated with power purchase agreements or utility-
owned resource additions—and are not directly tied to short-term operational
realities. Because of this disconnect, long-run marginal cost estimates are more
speculative, less transparent to customers and regulators, and difficult to validate.77
d. The Commission should give no weight to Dr. Kaufman's alternative no
harm analyses that were presented for the first time at hearing and were
not subiect to rebuttal evidence.
Dr. Kaufman presented new alternative no harm analyses for the first time live at the
evidentiary hearing, well after the multiple opportunities to file written testimony in this case, to
support his alternative rates and rate methodologies.78 Dr. Kauftnan's hearing exhibits were also
only produced at the hearing in hard copy printed documents despite the fact that the exhibits are
dense and voluminous spreadsheets that require executable versions of the spreadsheets to
reasonably analyze. In fact, the accompanying executable workpapers for the exhibit were not
made available to the parties until eight days after the hearing on November 5,2025. Commission
Rule 267.02 requires that "A party who offers an unusually bulky or voluminous exhibits should
allow the parties to inspect it before offering it at the hearing. Copies must be of good quality."
76 Tr. at 639:23—640:14.
77 Tr. at 193:13-25(IPC-Anderson Rebuttal at 13).
78 Hearing Exhibits 211—218.
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IIPA's strategy left Micron and Idaho Power without opportunity to adequately question
Dr. Kaufman regarding those exhibits or present responsive evidence on the record. Micron and
Idaho Power objected to admission of Hearing Exhibits 211 through 218 on the record and,while
the Commission ultimately admitted the hearing exhibits, the Commission noted it would give
them"appropriate weight. ,79 After reviewing the information provided,given how it was provided
and the fact that parties had no opportunity to present a response on the record or effectively cross-
examine Dr. Kaufman, those exhibits should be given no weight. But that does not leave Dr.
Kaufman and the entities he represents without opportunities to raise these issues going forward.
Indeed, Dr. Kaufman will be able to raise the issues and concerns they have with the specific rates
and rate methodologies in Idaho Power rate filings in the future. Idaho Power and Micron are not
asking the Commission to set rates for the entire duration of the contract —just until the next rate
filing. And, importantly, if the Commission were to agree to increase the demand charges Micron
pays as proposed by Dr. Kaufman, between now and the next rate case there is no methodology to
lower anyone else's rates in response. Therefore, those higher demand revenues would simply be
retained by Idaho Power and provide no benefit to Idaho Power's other customers. Unlike energy
revenues which flow through the PCA, any demand revenues created by increasing rates to Micron
can only be translated into lower rates for other customers in a future rate filing. For all these
reasons, there is no need or basis to adopt Dr. Kaufinan's recommendations at this time.
79 Tr. at 484:3-7.
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e. Dr.Kaufman's proposed Termination Pavment is an unreasonable penalty
against Micron.
IIPA recommends that the ESA "Termination Payment should be subjected to a floor
amount equal to five times the annual difference between revenue and net energy value."80 This
floor is arbitrary. IIPA merely reasons that if Micron went unexpectedly bankrupt in 2047 when
minimum billing demand will have reduced to 20 MW, the Termination Payment will cover only
seven months of lost revenue.81 IIPA also speculates that the unexpected loss of Micron Fab's
revenue will cause liquidity issues for Idaho Power.
Idaho Power disagrees with IIPA's assumptions about Idaho Power's financial exposure.82
As a seasonal importer, Idaho Power is confident that if it lost the Micron Fab load it could reduce
imports and repurpose the capacity.83 IIPA provides no compelling evidence why Idaho Power's
assessment of its own business needs is incorrect. As demonstrated above, the ESA Termination
Payment is sufficient to protect Idaho Power customers in the event of contract termination.
3. Micron's proposed Alternative ESA Language to Address Staff Witness
Eldred's Recommendations
Micron maintains that the ESA as proposed by Idaho Power protects other customers, is in
the public interest, and should be approved. Specifically, as discussed above, the ESA provides
for 21 years of protection for other customers in the event that Micron's loads do not materialize
as scheduled. Also as discussed above,those protections are greater than those in any other special
contract ever approved by the Commission.
80 Tr. at 497:20-23 (IIPA-Kaufman Direct at 4).
81 Tr. at 527:8-14(IIPA-Kaufman Direct at 20).
82 Tr. at 92:1-2(IPC-Ellsworth Rebuttal at 12).
83 Tr. at 92:4-6(IPGEllsworth Rebuttal at 12).
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However, at hearing Micron discussed potential amendments to the ESA the Commission
could order if it supports Mr. Eldred's two recommendations. Staff witness Mr. Eldred testifies
that he generally supports the ESA but recommends the Commission modify the ESA contract
terms related to (1) the Marginal Cost-Based Energy Charges and (2) the Minimum Monthly
Billing Demand. At hearing, Micron proposed two potential contractual terms that the
Commission could adopt to address Mr. Eldred's recommendations and Mr. Eldred agreed that
those amendments address his concern. Micron discusses each of the two potential changes in
turn below.
a. ESA Section 5.5(b) Minimum Monthly Billing Demand
Staff supports the ESA Minimum Monthly Billing Demand terms.84 However, Staff
opposes the automatic reduction to the Minimum Monthly Billing Demand that begins after
2030.85 Specifically, Staff suggested extending the take-or-pay period by five years before
automatically reducing the Minimum Monthly Billing Demand.86 At hearing, Micron discussed
the following amendment to the ESA to address Mr. Eldred's concerns:
5.5 Minimum Monthly Billing Demand
b.Minimum Monthly Billing Demand After Expansion. Starting on9n the effective
date of the Embedded Contract Demand, the Minimum Monthly Billing Demand
shall remain fixed a the then-effective Minimum
Monthly Billing Demand unless either Party seeks and obtains approval from the
IPUC to reduce the Minimum Monthly Billing Demand based upon an affirmative
showing that such reduction is consistent with the public interest. Upon the IPUC's
provision of such approval, the.. Tccr, Minimum Monthly Billing Demand
will decrease from the then-effective Minimum Monthly Billing Demand in
accordance with the schedule provided in the IPUC's approval. Notwithstanding
the foregoing, the Minimum Monthly Billing Demand will decrease e-by 30
MW on June 1, 2036, and will continue to automatically reduce by 30 MW on June
84 Tr. at 827:21-23 (Staff-Eldred Direct at 15).
85 Tr. at 827:23-24(Staff-Eldred Direct at 15).
86 Tr. at 829:25—831:2(Staff-Eldred Direct at 17-18).
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I of each year thereafter down to a minimum of 20 MW unless otherwise ordered
by the IPUC.
This language addresses Mr. Eldred's concerns by not automatically reducing the
Minimum Monthly Billing Demand on the effective date of the Embedded Contract Demand.
Instead, it states the Minimum Monthly Billing Demand shall remain fixed unless either party
seeks and the Commission approves a reduction to the Minimum Monthly Billing Demand based
on a showing that doing so is in the public interest. If the Commission accepts Staffs
recommendation, this change is important because it provides flexibility to address the Minimum
Monthly Billing Demand in the future based on the facts and circumstances at that time while
ensuring the Minimum Monthly Billing Demand continues to protect other customers. For
example, one could imagine a hypothetical scenario in 2032 where Micron's actual demand is
lower than the Embedded Contract Demand and a new large load customer approaches Idaho
Power for new capacity. If the "take or pay" provisions were locked in for five additional years
under this hypothetical, Micron would be paying for unneeded capacity in the Minimum Monthly
Billing Demand charges. At the same time, Idaho Power would be contractually required to
provide that capacity to Micron even though it could potentially reallocate that capacity to the new
large load customer. Such a result is not in the public interest. In such a hypothetical, the revised
language in Hearing Exhibit 304 would allow Micron and Idaho Power to propose a reduction to
the Minimum Monthly Billing Demand at that time to address those facts.
At hearing, Staff Witness Eldred confirmed that the revisions to ESA Section 5.5(b)
contained in Hearing Exhibit 304 addressed his concerns.'
87 Tr. at 862:12-19.
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b. 7.2 Marginal Cost-Based Energy Charges
Staff supports Idaho Power's proposal to charge Micron Marginal Energy Charges and the
method and annual update process for determining the Marginal Energy Charges. However, Mr.
Eldred expressed concerns "about the ability to change the method if the Commission adopts a
different method in the future and the [ESA's] language related to reevaluating the basis for the
Energy Charges after the scheduled ramp period ends."88 Mr. Eldred recommends modifying
Section 7.2 to (1) address potential changes in the method used to determine the Energy Charges
and (2) address requirements for changing the basis for the Energy Charges, and (3) clarify that
changes require Commission approval.89 Micron and Idaho Power do not oppose Mr. Eldred's
recommendation and at hearing Micron proposed the following change to clarify the ESA to
address Mr. Eldred's concerns:
7.2 Marginal Cost-Based Energy Charges. Schedule 28 shall include the
marginal cost-based energy charges (the "Energy Charges") unless otherwise
ordered by the IPUC to be set on a different basis. Either party may request that
the IPUC reevaluate the basis for the Energy Charges after the scheduled ramp
period ends on September 30, 2030; provided, however, that any changes to the
basis for the Energy Charges will be subject to IPUC approval. The Energy
Charges will be subject to IPUC approval and Idaho Power shall provide IPUC with
updated Energy Charges annually. The methods used to calculate marginal cost-
based energy charges are subject to change and may be updated from time to time
as directed by the IPUC.At t Mier-.n's Fe quest, Wake Power-agrees to ry aluate the
basis for- the Enefgy Cha ges after- the sehedttled ramp period ends on September-
3 n�n0.
Mr. Eldred confirmed that the proposed changes to Section 7.2 in Exhibit 305 implement
his recommendation regarding Marginal Energy Charges.90
88 Tr. at 817:15-23 (Staff-Eldred Direct at 9).
89 Tr. at 818:19—819:1 (Staff-Eldred Direct at 10).
90 Tr. at 865:24—866:3.
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4. Response to Clean Energy Opportunities of Idaho's Cost Allocation and Rate
Design proposals.
Clean Energy Opportunities of Idaho ("CEO") presents arguments in this case regarding
cost allocation and rate design issues that are best reserved for future general rate cases. First,
CEO witness Ms.White recommends that the ESA contain a different billing paradigm that reflects
the "hourly, time varying nature of cost causation" and shifts generation and transmission cost
recovery into volumetric energy charges.91 However, Idaho Power does not support Ms. White's
recommendations and explains that a TOU rate could actually risk harm to existing customers and
disincentivize stable loads.92 The Commission should approve the ESA with its proposed pricing
because it is consistent with the accepted regulatory practice to require customers to commit to a
baseline level of capacity through demand based pricing.93 Ms.White does not provide persuasive
evidence to rebut Idaho Power's explanation that TOU rates risk harm to existing ratepayers.
Additionally, this proceeding is ill-suited to address and consider the rate design and cost
allocation proposals raised by CEO. Such issues are best considered in rate case proceeding where
rate design and cost allocation can be considered within the context of all of Idaho Power's
customer classes, costs, and revenues. Specifically, CEO is a party to the currently pending Idaho
Power General Rate Case. CEO and Micron are parties to the settlement in that case that provides
for Idaho Power to file a"Single Issue [Class Cost of Service] CCOS Case" in the first quarter of
2026.94 This Single Issue CCOS Case will"address the CCOS methodology and associated policy
issues in a separate proceeding in which alternatives to the Company's filed CCOS methodology
in[the GRC], including a CCOS study with an hourly-informed class allocation of Production and
"Tr. at 692:2-7(CEO-White Direct at 16).
92 Tr. at 223:1-8 (IPC-Anderson Surrebuttal at 16).
91 Tr. at 223:9-23 (IPC-Anderson Surrebuttal at 16).
94 Case No.IPC-E-25-16,Stipulation and Settlement at¶10.
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Transmission revenue requirement,will be presented for the Commission's consideration."" That
future Single Issue CCOS case is a suitable forum to consider future changes to Idaho Power's rate
design and cost allocation proposals.
Further, CEO witness Mr. Heckler's argument that Micron Fab cost allocation and rate
design issues should not be determined in a general rate case is contrary to the very purpose of
General Rate Cases as provided in Commission rules. Commission Rule 124 specifically states
that in General Rate Cases "the rates and charges of all Idaho retail customers, both recurring and
non-recurring, including those of special contract customers, are at issue, and every component of
every existing and proposed rate and charge is at issue." Additionally, Rule 124 provides "the
Commission may approve,reject or modify existing or proposed relationships between and among
rates and charges within, between or among customer classes or rate groupings and may approve,
reject or modify existing or proposed relationships among and between customer classes or rate
groupings."
General rate cases are the appropriate forum to allocate costs to the Micron Fab because
they consider actual test year data including all of Idaho Power's costs and revenues from its
various customer classes,rather than the forecasts being used in this proceeding. The Commission
will have the opportunity to consider the costs allocated to and recovered from the Micron Fab in
every future General Rate Case and should reserve such questions for those cases.
5. The Commission should not withhold approval of the ESA based on the
potential for future legislative changes.
Evidence was presented in this proceeding regarding past proposed, but not enacted,
legislation and the potential for future legislative changes that could impact the treatment of new
95 Id.
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large loads in the future.96 While Micron does not take a position on such potential legislation, it
urges the Commission to approve the ESA based on the law as it stands today. The Commission
must apply existing law, regulation, and Commission precedent to determine whether the ESA is
just and reasonable and in the public interest.
IV. CONCLUSION
Micron respectfully requests the Commission approve the Micron Fab ESA. The ESA
contains the strongest customer protections of any Idaho Power ESA to date. Not only does the
ESA protect existing customers, Micron's longevity as an economic engine in the Boise area
should encourage the Commission to find that the ESA is in the public interest.
Respectfully submitted December 2, 2025.
HOLLAND &HART, LLP
By: -L---) - 266�L
ustin Rueschhoff, ISB No. 1059
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Micron Technology, Inc.
96 Tr. at 278:4-8 (IIPA-Mickelson,Garner Joint Direct at 1).
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MICRON TECHNOLOGY, INC.'S POST-HEARING BRIEF
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CERTIFICATE OF SERVICE
I hereby certify that on December 2, 2025 a true and correct copy of the within and
foregoing MICRON TECHNOLOGY, INC.'S POST-HEARING BRIEF IN CASE NO. IPC-E-
24-44 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(aNdahopower.com Facsimile: [phone]
docketskidahopower.com caschenbrennergidahopower.com
ganderson(ae,idahoRower.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
secretgUkpuc.idaho.gov Denver, CO 80202
darueschhoff(a,hollandhart.com
tnelsonghollandhart.com
awj ensen(ahollandhart.com
karoach(cr�,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 lance(d),ae isg insi hg t.com
Pocatello, ID 83205
elo(aechohawk.com
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MICRON TECHNOLOGY, INC.'S POST-HEARING BRIEF
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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 dreadinggmindspring com
peter(&richardsonadams.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(a,kelseyjae.com Boise, ID 83703
courtneygcleanenergyol2]2ortunities.com
mike(iD cleanenergyol2portunities.com
s/Adele Lee
36137963_v12
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