Attch41_IPCE0113_Comments_Micron.pdf

Richard E. Malmgren ISB 5730
Micron Technology, Inc.
8000 South Federal Way, MS 507
P.O. Box 6
Boise, Idaho 83707-0006
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorney for Micron Technology, Inc.
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATIONOF INCREASED DEMAND-SIDEMANAGEMENT PROGRAMS AND THEFUNDING OF THOSE PROGRAMS FORIDAHO POWER COMPANY
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CASE NO. IPC-E-01-13
COMMENTS OF MICRONTECHNOLOGY, INC.
Micron Technology, Inc. (“Micron”) respectfully submits its comments in the above
captioned matter pursuant to the Notice of Application and Notice of Modified Procedure issued
by the Secretary of the Idaho Public Utilities Commission (“Commission”).
Micron supports aggressive and effective conservation measures. However, Micron
opposes disproportionate reliance on conservation programs that seek primarily long-term
“market transformation” such as many programs funded by Northwest Energy Efficiency
Alliance (“NEEA”). Micron supports Idaho Power Company’s (“Idaho Power” or the
“Company”) proposal to create separate accounts for large customers from which self-directed
conservation programs can be funded. Finally, Micron believes that demand-side conservation
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programs provide only a partial solution. Micron believes that in connection with proposed
demand-side measures, Idaho Power should pursue efficiency enhancing system improvements.
I.THE COMMISSION SHOULD REQUIRE IDAHO POWER TO SHIFT ITS
CONSERVATION FOCUS AWAY FROM LONG-TERM MARKET
TRANSFORMATION PROGRAMS AND TOWARD IMMEDIATE AND
SHORT-TERM CONSERVATION MEASURES.
Micron believes that effective conservation efforts require an approach that is
appropriately balanced between long-term and short-term measures and between demand-side
and supply-side improvements. For this reason, Micron disagrees with Idaho Power’s current
disproportionate focus on long-term conservation measures. According to Idaho Power’s recent
filing, nearly $1.2 million or almost 80 percent of Idaho Power’s total conservation programs in
2001 are used to fund NEEA. NEEA has stated that one of its primary goals is to transform
markets for energy consuming appliances. Indeed, according to NEEA’s own annual report, they
cannot even identify savings for 17 out of their 32 projects because it is simply “too difficult.” 1
While Micron is not opposed to long-term market transformation programs, Micron believes that
allocating 80 percent of its conservation resources to such transformation programs is not a
prudent use of ratepayers’ money. Because NEEA admits that it cannot identify any savings for
over half of its projects, Idaho Power funding for NEEA should be immediately curtailed and
redirected to Idaho Power to operate Idaho-based conservation efforts.
In the current economic and energy environment, demand-side programs that will result
in immediate conservation should take priority over long-term market transformation measures.
Examples of immediate conservation programs are described briefly in Idaho Power’s filing.
Extensive conservation studies at Micron have identified similar and additional opportunities for

1 2000 Alliance Annual Report, Northwest Energy Efficiency Alliance, p.2, www.alliance.org.
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immediate power conservation at Micron. Micron believes the Commission should require
Idaho Power to shift funding away from NEEA’s market transformation activities in favor of
programs that can be shown to result in immediate power savings.
In addition to immediate demand-side conservation measures, Idaho Power should
implement supply-side conservation measures by improving the efficiency of the transmission
system. System improvements that would eliminate transmission bottlenecks and replace aging
components with new, low-resistant wires, switches, transformers, insulators and other
components may be the most cost effective way to prevent energy loss. Such supply-side
measures may provide greater conservation that any demand-side programs industrial customers
might implement. Micron believes the public interest is best served by shifting conservation
efforts away from long-term market transformation and toward immediate demand- and supply-
side programs.
II.SELF-DIRECTED CONSERVATION PROGRAMS FOR THE INDUSTRIAL
CUSTOMERS AS PROPOSED BY IDAHO POWER WILL RESULT IN
SIGNIFICANT IMMEDIATE CONSERVATION.
Because of the prominent role of power in Micron’s manufacturing process, Micron is
continuously engaged in efforts to conserve power. These efforts have intensified during the
past year in response to the development of the current energy environment. The result of such
efforts has been the identification of numerous opportunities for immediate power conservation
at Micron. Some of these opportunities involve the acquisition of more energy efficient
equipment, upgrades to existing equipment or the installation of energy saving devices. Creation
of a separate account that would allow Micron to fund qualified energy efficiency projects would
result in proven and immediate power conservation. Micron supports—and asks the
Commission to approve—Idaho Power’s proposal to structure programs “for maximum customer
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flexibility and participation where customers may propose and manage all efficiency efforts”
with utility approval.
If self-directed programs are implemented, the governing approval procedures must be
efficient and streamlined. The most effective conservation measures are weakened to the degree
that implementation is delayed by sluggish approval processes. Idaho Power should be required
to act upon conservation measures proposed by customers within thirty days. If Idaho Power
fails to approve or reject a conservation proposal within the thirty-day period, the proposal
should be deemed approved. Finally, Micron agrees with Idaho Power that “the recovery of
expenses on an ongoing basis is the appropriate mechanism for program funding.”
RESPECTFULLY SUBMITTED this _____ day of September, 2001.
Micron Technology, Inc.
By
Richard E. Malmgren
Assistant General Counsel