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Home My WebLink About20260514Petition to Intervene.pdf RECEIVED May 14, 2026 IDAHO PUBLIC Austin Rueschhoff, ISB No. 10592 UTILITIES COMMISSION Thorvald A. Nelson Richard A. Arnett HOLLAND&HART LLP 555 17th Street, Suite 3200 Denver, CO 80202 Telephone: (303) 295-8000 Email: darueschhoff@hollandhart.com tnelson@hollandhart.com raamett@hollandhart.com Attorneys for Micron Technology, Inc. BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF IDAHO POWER ) CASE NO. IPC-E-26-08 COMPANY'S APPLICATION FOR ITS ) ANNUAL UPDATE TO MARGINAL ) PETITION TO INTERVENE PRICING USED IN CERTAIN SCHEDULES ) OF MICRON TECHNOLOGY, INC. Micron Technology, Inc. ("Micron"or"Intervenor"),pursuant to the Commission's Rules of Procedure 71 through 74,1 hereby petitions the Commission for leave to intervene and to appear and participate in this proceeding as a party. Because this Petition is filed after the intervention deadline set forth in the Notice of Application and Notice of Intervention Deadline,2 Micron further requests that the Commission grant Micron leave to intervene for good cause shown pursuant to Rule 73. In support of this Petition, Micron states: 1. The name and address of this Intervenor is: Micron Technology, Inc. c/o Austin Rueschhoff Thorvald A. Nelson Richard A. Arnett ' Idaho Admin. Code 31.01.01.071—.074. 2 Order No.37007. 1 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08 Holland&Hart LLP 555 17th Street, Suite 3200 Denver, CO 80202 Telephone: (303) 295-8000 darueschhoff@hollandhart.com tnelson@hollandhart.com raamett@hollandhart.com Copies of all pleadings, production requests, production responses, Commission orders, and other documents should be provided to: Austin Rueschhoff Thorvald A. Nelson Richard A. Arnett Holland&Hart, LLP 555 17th Street, Suite 3200 Denver, CO 80202 (303) 295-8000 darueschhoff@hollandhart.com tnelson@hollandhart.com raamett@hollandhart.com And, for documents served electronically,please also add: aclee@hollandhart.com tlfriel@hollandhart.com 2. Micron receives electric utility services from Idaho Power Company ("Idaho Power" of"Company") as a Special Contract customer, taking service under Schedule 26 and, in the future, Schedule 28. Micron is one of Idaho Power's largest customers. In this case, Idaho Power seeks Commission approval of its annual review and adjustment of the marginal cost-based energy prices contained in Schedule 20, Speculative High-Density Load and Schedule 34, Lamb Weston Special Contract. 2 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08 3. On May 8, 2026, the same day as the intervention deadline in this case, the Commission issued its Final Order in Case No. IPC-E-24-44, Idaho Power's Application for Approval of a Special Contract between Idaho Power and Micron's affiliate Micron Idaho Semiconductor Manufacturing (Triton) LLC and Approval of Tariff Schedule 28 ("Schedule 28 Special Contract"). Pursuant to that Final Order, Micron will be subject to marginal cost-based energy charges under Schedule 28. Although Idaho Power does not propose to adjust the Schedule 28 marginal cost-based energy charges in this proceeding, the outcome of this proceeding could impact Micron's marginal cost-based energy charges in the future. Micron,therefore,has a"direct and substantial interest" in this proceeding.4 4. Pursuant to Commission Rule 73, good cause exists for Micron's untimely filing of this Petition to Intervene. First, the Commission's Notice of Application and Notice of Intervention Deadline issued in this proceeding stated Idaho Power's request for authorization to maintain the currently in-effect marginal energy price components of Schedule 20 and Schedule 34.5 Second, Micron's Schedule 28 Special Contract was not approved by the Commission until May 8, 2026, the same date as the intervention deadline in this proceeding. As Idaho Power describes in its Application in this proceeding, during the pendency of the Schedule 28 Special Contract case, parties raised concerns regarding Idaho Power's methodology for determining marginal energy costs. In that case, Idaho Power proposed that the Commission direct an evaluation of these issues in a separate marginal cost docket,filed independent of the annual update, to allow for a more transparent and more appropriate scoped review of potential 3 Order No. 37039. 'Idaho Admin. Code 31.01.01.071. s Order No.370007,p. 1. 3 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08 modifications.6 In its Schedule 28 Special Contract Case Final Order, the Commission declined to address Idaho Power's recommendation that the marginal energy cost methodology be examined in a separate docket. Therefore, the Schedule 28 Special Contract Case Final Order results in some uncertainty regarding the scope of this proceeding that could not have been known before the intervention deadline established in this case. 5. Further pursuant to Rule 73, Micron's intervention in this case will not result in disruption, prejudice to existing parties, or unduly broadening the issues. Micron is filing this Petition only four business days after the May 8, 2026 intervention deadline in this case. A Procedural Order has not yet been set in this case. Therefore, it is still early in this proceeding and Micron's intervention will not disrupt the established case procedure. Micron's intervention will not unduly broaden the issues presented in this case as Micron agrees with Idaho Power that a more transparent and more appropriate scoped review of potential modifications to Idaho Power's methodology to determine marginal energy costs is better reserved for a future case and not in this annual update case. However, Micron has a direct and substantial interest in participating in this case to the extent alternative methodologies are proposed beyond the scope of the case that could impact Micron's future rates for service. 6. Micron has conferred with the parties to this case,Idaho Power, Commission Staff, and the Idaho Irrigation Pumpers Association regarding Micron's Petition to Intervene and no party opposes Micron's intervention. 7. Micron agrees to be bound by the prior orders and notices in this case. 6 Idaho Power Application,Para.22,citing IPC-E-24-44 Anderson Surrebuttal Testimony at 12-14. 4 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08 8. Micron intends to participate herein as a party and, if necessary, to file comments, introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in argument. The nature and quantity of evidence Micron will introduce is dependent upon the nature and effect of other evidence in this case. 9. Without the opportunity to intervene, Micron would be without adequate means to participate in this case that will have a material impact on its electric service. WHEREFORE,Micron Technology,Inc.respectfully requests that the Commission grant its Petition to Intervene in this case and to appear and participate in all matters as may be necessary and appropriate; and, if necessary, to present evidence, call and examine witnesses, present arguments and to otherwise fully participate in this case. Respectfully submitted May 14, 2026. HOLLAND &HART, LLP By: 0400'� Austin Rueschhoff, ISB No. 10592 Thorvald A. Nelson Richard A. Arnett 555 17th Street, Suite 3200 Denver, CO 80202 Telephone: (303) 295-8000 Email: darueschhoff@hollandhart.com tnelson@hollandhart.com raamett@hollandhart.com Attorneys for Micron Technology, Inc. 5 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08 CERTIFICATE OF SERVICE I hereby certify that on May 14, 2026, a true and correct copy of the within and foregoing PETITION TO INTERVENE OF MICRON TECHNOLOGY, INC. IN CASE NO. IPC-E-26-08 was served in the manner shown to: Electronic Mail Idaho Power Company Commission Staff Megan Goicoechea Allen Erika Melanson Donovan Walker Monica Barrios-Sanchez Grant T. Anderson Deputy Attorney General Austen Apperson Idaho Public Utilities Commission Jessi Brady P.O. Box 83720 1221 West Idaho Street (83702) Boise, ID 83720-0074 PO Box 70 erika.melanson(d)puc.idaho.gov Boise, ID 83707-0070 secretgak]2uc.idaho.gov mgoicoecheaallen(k idahopower.com dwalker@idahopower.com dockets(&idahopower.com gandersonkidahopower.com aapperson(a,idahopower.com j brady(kidahopower.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 lancegaeginsi h Pocatello, ID 83205 deborah. log sser(a),gmail.com elogechohawk.com taysha(a,ecohawk.com Micron Technology, Inc. Austin Rueschhoff Thorvald A. Nelson Richard A. Arnett Holland& Hart, LLP 555 17th Street, Suite 3200 Denver, CO 80202 darueschhoff(a,hollandhart.com tnelson(a,hollandhart.com awj ensen(khollandhart.com raarnett(a,hollandhart.com acleekhollandhart.com tlfrielnhollandhart.com 6 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08 s/Tracy Friel 37909912_vl 7 MICRON TECHNOLOGY, INC. PETITION TO INTERVENE IPC-E-26-08