20170201Micron 1-6 to IPC.PDF

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-24

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 FOR ELECTRIC SERVICE TO
RECOVER COSTS ASSOCIATED WITH
NORTH VALMY PLANT
)
)
)
)
)
)
CASE NO. IPC-E-16-24

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-16-24

Please respond to these Data Requests by February 22, 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.
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.
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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-24

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
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.
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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-24

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.
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.
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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-24

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: Please quantify the annual increase in the proposed revenue
requirement attributable to the proposed accelerated depreciation of Valmy 1 and Valmy 2.

MICRON 1-2: Referring to Exhibit No. 3 of Mr. Larkin’s testimony, please
provide a similar revenue requirement summary for the current test year for the Valmy units.

MICRON 1-3: Referring to Mr. Larkin’s testimony at p. 16, lines 3-12,
specifically: “Idaho Power has filed its updated depreciation study in Case No. IPC-E-16-23 that
incorporates Valmy’s 2025 end-of-life date and adjusts depreciation rates accordingly. . . .”
Please provide the following information as of December 31, 2016 (i.e., the type of information
presented in a depreciation study):
a. Plant balances for Valmy 1 and Valmy 2 by account (i.e., Accounts 310.20, 311,
312.10, 312.30, 314, 315, 316, etc.);
b. Book reserve balances for Valmy 1 and Valmy 2 by account;
c. Current net salvage rates for Valmy 1 and Valmy 2 by account;
d. Current remaining life calculations for Valmy 1 and Valmy 2 by account;
e. Current depreciation rates for Valmy 1 and Valmy 2 by account;
f. Proposed depreciation rates for Valmy 1 and Valmy 2 by account;
g. Depreciation expense under existing depreciation rates; and
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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-24

h. Depreciation expense under proposed depreciation rates.

MICRON 1-4: Please quantify the dollar revenue requirement difference between
the Company’s proposal to accelerate Valmy depreciation rates, and leaving the currently-
approved depreciation rates in place (i.e., no acceleration), regardless of the actual retirement
dates for Valmy 1 and Valmy 2 under each of the following scenarios:
a. Including full recovery of the forecasted capital additions and decommissioning
costs described in Exhibit 2 of Mr. Larkin’s testimony; and
b. Without including recovery of the forecasted capital additions and
decommissioning costs. (In other words, including only the plant investment
through 12-31-16).

MICRON 1-5: Referring to Exhibit No. 2 of Mr. Larkin’s testimony, please
explain in detail how the “Existing Accelerated” amounts from 2017-2025 were calculated (at
the top left-hand side of the exhibit).

MICRON 1-6: Referring to the levelized revenue requirement of $41,787,659 in
Exhibit No. 2 in Mr. Larkin’s testimony, how much of this amount is attributable to depreciation
expense.

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Micron Technology, Inc.’s First Set of Data Requests to Idaho Power Company
IPC-E-16-24

DATED this 1st day of February, 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-16-24

CERTIFICATE OF SERVICE
I hereby certify that on this 1st day of February, 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-16-24 was served in the manner shown to:

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
s/ Kayla L. Hall

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