20170103Micron 1-22 to IPC.pdf

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

Brian T. Hansen, ISB No. 6087
HOLLAND & HART LLP
800 W. Main Street, Suite 1750
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

Thorvald A. Nelson
Frederick J. Schmidt
Emanuel T. Cocian
HOLLAND & HART LLP
6380 South Fiddlers Green Circle, Ste. 500
Greenwood Village, CO 80111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

Attorneys for Micron Technology, Inc.

BEFORE THE IDAHO
PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY
FOR AUTHORITY TO INCREASE ITS
RATES DUE TO REVISED DEPRECIATION
RATES FOR ELECTRIC PLANT-IN-
SERVICE
)
)
)
)
)
)
CASE NO. IPC-E-16-23

FIRST DATA REQUEST OF
MICRON TECHNOLOGY, INC.
TO IDAHO POWER COMPANY

Micron Technology, Inc. (“Micron”), by and through its undersigned counsel, pursuant to
applicable rules of procedure, hereby submits the below First Data Requests to Idaho Power
Company (“IPC”). The following definitions and instructions apply to all Data Requests to be
submitted by Micron in the above-captioned docket.

RESPONSE DATE, DEFINITIONS, AND INSTRUCTIONS

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

Please respond to these Data Requests by January 24, 2017 or as soon as responses can
be provided, whichever is sooner.

DEFINITIONS

“Applicant” or “you” shall mean IPC; any merged or consolidated predecessor or
predecessors in interest; parent(s), subsidiaries and affiliates, past and present; and the
employees, officers, directors, agents, consultants, attorneys and all persons acting under
contractual arrangement with or acting or purporting to act on behalf of Applicants. If the data
request only applies to one of the Applicants, please respond on behalf of that Applicant.
“Document” and “documentation” should be interpreted as broadly as possible to include,
but not be limited to, the original or any copy, regardless of origin or location, of any book,
pamphlet, periodical publication, letter, scrapbook, diary, calendar, canceled check, photograph,
form, memorandum, schedule, tax return, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal operating
manual, data sheet or data processing card, or any other written, recorded, transcribed, punched,
taped, filmed, graphic or retrievable matter or data of any kind, however produced or reproduced,
to which you have or have had access. This definition is intended to include, but not be limited
to, all documents which have been created and/or which reside in any type of electronic format.
Any document that is not exactly identical to another document for any reason, including,
but not limited to, marginal notations or deletions, should be considered to be a separate
document.
As to any document related to the matters addressed herein that is not currently in your
possession but that you know or believe such a document exists, you are requested to identify
and indicate to the best of your ability its present or last known location or custodian.
“Person or Entity” should be interpreted to denote, unless otherwise specified, any natural
person, firm, corporation, association, group, individual or organization of an type whatsoever.
Any request to “identify” or “provide” should be interpreted to mean:
With respect to a natural person, that person’s full name, title, job description, and
business and home address. Where the identification pertains to a past period, as to each person
identified who is still in your employ, or the employment of the group with which such person is
identified in response to any requests, provided, in addition, that person’s title and job
description as of the time of such past period. Where the person is no longer in your employ or
the employment of the group with which such person is identified in response to any request,
provide that person’s affiliate, position, home and business address, if known, or if not known,
such person’s last known affiliation, position, home and business address, or portions thereof as
may be known.

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

With respect to an entity other than a natural person, that entity’s name, business,
type of entity, present status and present or last known address.
With respect to a document, that document’s title, date, author (and, if different,
the signer), addresses, recipients, or other persons who assisted in the preparation, subject matter
or general nature, and any amendments thereto, present location and custodian, whether or not
such document is in the respondent’s possession, custody or control and whether or not the
document is claimed to be privileged. The final version and each draft of each document should
be identified and produced separately. Each original and each non-identical copy (bearing marks
or notations not found on the original) of each final version and draft of each document should
be identified and produced separately.
With respect to a physical facility, the location of the facility, the intended
purpose of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if applicable, and
whether the facility is subject to the jurisdiction of the Federal Energy Regulatory Commission,
the Colorado Public Utilities Commission, or any other regulatory body.
“Communication” should be interpreted to include, but not be limited to, all forms of
communication, whether written, printed, oral, pictorial, electronic or otherwise, including
testimony or worn statement, or any means or type whatsoever.
“Relating To” or “Related To” means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.
GENERAL INSTRUCTIONS
Where a request can be answered in whole or in part by reference to the response to a
preceding or subsequent request, it is sufficient to so indicate by specifying the response to the
preceding or subsequent request by number and specifying whether it is claimed that the
response to the preceding or subsequent request is a full or partial response. If the latter, the
response to the balance of the request shall be completed.

If various individuals are the authors of different responses to the Data Requests, please
indicate the name of the author and his/her position within Applicants, or if he/she is an expert or
a consultant, please provide a current curriculum vitae for each such expert of consultant.
As to any requests consisting of a number of separate subdivisions, or related parts or
portions, a complete response is required to each part or portion with the same effect as if it were
propounded as a separate request. Should objection to a request be interposed it should clearly
indicate to which part or portion of the request it is directed.
For each document identified in a response which is computer generated, state separately
(a) what types of data files or tapes are included in the input and the source thereof, (b) the form
of the data which constitutes machine input (punch cards, tapes, etc.), (c) a description of the
recordation system employed (including program descriptions, flow charts, etc.), and (d) the

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

identity of the person or persons, during the designed period, who was in charge of the collection
of input materials, the processing of input materials, the data bases utilized, and/or the
programming to obtain such output.
Responses to requests referring to documents shall include all documents relating to the
time period specified in each request or in these instructions, whether prepared before, during or
after that period.
Individual response of more than one page should be stapled or bound, and each page
consecutively numbered.
If any document covered by this request is withheld for whatever reason, please furnish a
list identifying all withheld documents in the following manner:
the reasons for withholding;
date of the document;
name of each author or preparer;
name of each person who received the document; and
statement of facts constituting the basis for withholding the document.
If you assert that documents, records, or information responsive to any requests have
been destroyed and are thus not available, state when and explain why any such document,
record or information was destroyed, identify the person directing the destruction and identify all
documents relevant to such destruction or explanation. If a claim is made that the destruction
occurred pursuant to your document destruction program, identify and produce a copy of the
guideline, policy, or company manual describing such document destruction program, and any
correspondence or communication relating to the destruction of responsive documents, records
or information.
If any of these requests are not answered on the ground that the material or information
requested is confidential, privileged or otherwise immune to discovery, set forth in detail the
factual and legal basis which support your decision to withhold production. Please also state
whether a protective order or protective conditions regarding disclosure would satisfy or resolve
your concern.
Each document or written response shall designate the respective question (and subpart of
the question) under which it is being produced.
Each document produced shall be an authentic original document or a true duplicate of an
authentic original document.
Each of these requests shall be considered to be continuing and to require supplemental
or amended answers as readily as information and knowledge is acquired.

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

If, in answering a request, you encounter any ambiguity in interpreting either the request
or a definition or instruction applicable thereto, please secure a clarification by contacting
undersigned counsel as soon as the ambiguity is known.
The term “and” and “or” should be construed either disjunctively or conjunctively
whenever appropriate in order to bring within the scope of each request any information or
document which might otherwise be considered to be beyond its scope.
The singular form of a word should be interpreted as plural, and the plural form of a word
should be interpreted as singular, whenever appropriate in order to bring within the scope of each
request any information or document which might otherwise be considered to be beyond its
scope.
FIRST DATA REQUESTS

MICRON 1-1: Provide all data requests and responses received from or sent to other
parties in this proceeding. This is an ongoing request.

MICRON 1-2: Please provide all property data utilized in the depreciation study,
including additions, retirements, cost of removal, and salvage data. Please provide this data by
account, placement, and experience year since the date of inception. Please include all
transaction codes and a description of each transaction code. This data should allow for the
reconstruction of the analysis and calculations performed as part of the depreciation study. Please
provide this information in Excel format with formulae intact.

MICRON 1-3: Please provide all workpapers, schedules, tables, and exhibits used in the
depreciation study or relied upon in conducting the depreciation study in Excel format with
formulae intact where applicable.
MICRON 1-4: Please provide all final observed life tables generated for each account in
Excel format.

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

MICRON 1-5: Please provide all remaining life calculations in Excel format.
MICRON 1-6: Please provide the average age of survivors as of the study date for each
production plant by account.
MICRON 1-7: Please identify and describe any changes in the depreciation system /
methodology between the previous depreciation study and the depreciation study filed in this
case.
MICRON 1-8: Please provide a copy of the most recent, previously-filed depreciation
study.
MICRON 1-9: Please provide a copy of the most recent Commission order(s) regarding
currently-approved depreciation rates and probable retirement dates of any production units.
MICRON 1-10: Please provide a copy of the Company’s most recently-filed integrated
resource plan; please also provide a copy of the most recently prepared integrated resource plan.
MICRON 1-11: Please provide all notes taken during any meetings with Company
personnel regarding the depreciation study. Identify by name and title, all Company personnel
who provided the information, and explain the extent of their participation and the information
they provided. Please explain how this information affected the depreciation study.
MICRON 1-12: Please identify all plant tours taken in relation to the depreciation study.
For each such tour:

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

a. Identify those in attendance and their titles and job descriptions.
b. Provide all conversation notes taken during the tour.
c. Provide all photographs and images taken during the tour.
d. Provide all written materials obtained during the tour.
MICRON 1-13: Please provide all external sources relied upon in conducting the
depreciation study, including industry surveys, statistics, and reports.

MICRON 1-14: Please provide a copy of the most recent industry surveys associated
with depreciation statistics in the Company’s possession.

MICRON 1-15: Please identify and provide a copy of the Company's accounting policies
and procedures for plant retirements and cost of removal.

MICRON 1-16: Please identify and provide copies of Company programs and plans that
might substantially affect the remaining lives of any plant assets.

MICRON 1-17: Regarding the placement and experience bands chosen for the analysis of
each account, please explain why such bands were chosen and if any other bands were
considered for conducting depreciation analysis.

MICRON 1-18: Please provide copies of any internal memos, policies, studies, etc.,
identifying the appropriate allocation or treatment of costs between cost of removal and the
installation of new investment when a retirement occurs and a replacement investment is

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

installed at the same location. Further, provide all support, justification and related documents
associated with establishing the allocation levels.

MICRON 1-19: Please identify and provide copies of all Board of Director’s minutes and
internal management meeting minutes in which the subject of the Company’s depreciation rates
or the probable retirement dates of the Company’s production units were discussed during the
last three calendar years.

MICRON 1-20: Please provide the following information regarding each of the
Company’s generating units:
a. Date of installation;
b. MW capacity;
c. primary fuel source;
d. Detailed narrative identifying all significant improvements performed during the
past 10 years;
e. Detailed narrative identifying all anticipated significant improvements over the
next 10 years.
f. The estimated / proposed probable retirement dates throughout the history of the
units, from the units’ inception to present day.

MICRON 1-21: Please identify any proposed changes in the probable retirement dates of
any production units and provide justification and support for such proposed changes.

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

MICRON 1-22: Please provide all decommissioning studies relied upon for support of
any terminal net salvage requested in this case.
DATED this 3rd day of January, 2017.
Respectfully submitted,

HOLLAND & HART LLP

_________________________
Thorvald A. Nelson, #24715
Emanuel T. Cocian, #36562
Holland & Hart LLP
6380 South Fiddlers Green Circle, Suite 500
Greenwood Village, CO 80111
Telephone: [phone] and x1639, respectively
Facsimile: [phone]
[e-mail]
[e-mail]

Frederick J. Schmidt, NV Bar No. 002090
HOLLAND & HART LLP
377 South Nevada Street
Carson City, NV 89703
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

ATTORNEYS FOR MICRON
TECHNOLOGY, INC.

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-23

CERTIFICATE OF SERVICE
I hereby certify that on this 3rd day of January, 2017, a true and correct copy of the
within and foregoing FIRST DATA REQUEST OF MICRON TECHNOLOGY, INC. TO
IDAHO POWER COMPANY in CASE NO. IPC-E-16-23 was served in the manner shown to:

Jean D. Jewell [e-mail] Idaho Public Utilities
Commission

Lisa D. Nordstrom [e-mail] Idaho Power Co.
[e-mail] Idaho Power Co.
Matt Larkin [e-mail] Idaho Power Co.

Thorvald Nelson [e-mail] Micron Technology
Frederick J. Schmidt [e-mail] Micron Technology
Emanuel T. Cocian [e-mail] Micron Technology
Brian Hansen [e-mail] Micron Technology
Kayla Hall [e-mail] Micron Technology
Kelly Trease [e-mail] Micron Technology
Therese Wolf [e-mail] Micron Technology
Pete Bennett [e-mail] Micron Technology
Therese Wolf [e-mail] Micron Technology
Clancy Kelley [e-mail] Micron Technology
Heather Baldwin [e-mail] Micron Technology

Steven Porter [e-mail] The United States
Department of Energy

Eric L. Olsen [e-mail] Idaho Irrigation
Pumpers Association,
Inc.
Anthony Yankel [e-mail] Idaho Irrigation
Pumpers Association,
Inc.

Peter J. Richardson [e-mail] Industrial Customers
of Idaho Power
Dr. Don Reading [e-mail] Industrial Customers
of Idaho Power
s/ Kayla L. Hall