20170303Micron 24-26 to IPC.pdf

1
Micron Technology, Inc.’s Fourth 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

’S FOURTH SET OF DATA

Micron Technology, Inc. (“Micron”), by and through its undersigned counsel, pursuant to
applicable rules of procedure, hereby submits the below Fourth Set of Data Requests to Idaho
Power Company (“IPC”). The following response date, definitions, and instructions apply to this
set of data requests:

2
Micron Technology, Inc.’s Fourth Set of Data Requests to Idaho Power Company
IPC-E-16-23

RESPONSE DATE

Please respond to these Data Requests as soon as responses can be provided, but not later
than March 22, 2017.

DEFINITIONS AND INSTRUCTIONS

Please refer to the Definitions and Instructions included in the First Data Requests of
Micron to Idaho Power Company in the above-captioned docket.

FOURTH SET OF DATA REQUESTS

Micron Request No. 24: Re: IPC’s Response to Micron Request No. 3-1

Has Mr. John Spanos ever proposed an amortization period greater than five years for Account
303 (Software)? If so, please provide (a) the amortization period proposed; (b) the state and docket
number in which the proposal was made; and (c) a copy of the testimony or study supporting the
proposal.

Micron Request No. 25: Re: IPC’s Response to Micron Request No. 3-1

Has any other expert or consultant with Gannett Fleming Valuation and Rate Consultants ever
proposed an amortization period greater than five years for Account 303 (software)? If so, please
provide (a) the name of the expert or consultant; (b) the amortization period proposed; (c) the state
and docket number in which the proposal was made; and (d) a copy of the testimony or study
supporting the proposal.

Micron Request No. 26: Re: IPC’s Response to Micron Request No. 3-1

Please provide a copy of all studies, reports, and/or analyses supporting “the Company’s
understanding of standard industry practice” with respect to the amortization period for Account
303 (software).

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

Respectfully submitted this 1st day of March, 2017.

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 Fourth Set of Data Requests to Idaho Power Company
IPC-E-16-23

CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of March, 2017, a true and correct copy of the within
and foregoing FOURTH PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC.
TO IDAHO POWER COMPANY in Case No. IPC-E-16-23 was served in the manner shown
to:

Daphne Huang [e-mail] Idaho Public Utilities
Commission
Camille Christen [e-mail] Idaho Public Utilities
Commission
[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

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

Benjamin J. Otto [e-mail] Idaho Conservation
League and Sierra
Club
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Micron Technology, Inc.’s Fourth Set of Data Requests to Idaho Power Company
IPC-E-16-23

Travis Ritchie [e-mail] Idaho Conservation
League and Sierra
Club

s/ Kayla L. Hall

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