20170308Micron 7-10 to IPC.pdf

1
Micron Technology, Inc.’s Second 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

’S SECOND SET OF DATA

Micron Technology, Inc. (“Micron”), by and through its undersigned counsel, pursuant to
applicable rules of procedure, hereby submits the below Second Set of 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.

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

RESPONSE DATE
Please respond to these Data Requests as soon as responses can be provided, but not later
than March 28, 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.
SECOND SET OF DATA REQUESTS

Micron Request No. 7: Referring to IPC’s response to the Excel Attachment to
Corrected Supplemental Response to Micron’s Request No. 1-4, at the worksheet called “Valmy
Forecast,” please provide a detailed explanation of the $5,000,000 forecasted expense in 2024 for
Valmy Capital Plan – 2024 (see cell J59), including all justification and support for the prudence
of this forecasted investment.

Micron Request No. 8: Please confirm whether any investment in the Valmy V2
Low Nox Burner replacement project is included in the proposed net change in levelized revenue
requirement, and if there is, please quantify such investment and provide all justification and
support for the prudence of such investment.

Micron Request No. 9: Please confirm whether any investment in Valmy Wells 21,
23, and 27 are included in the proposed net change in levelized revenue requirement, and if there
is, please quantify such investment and provide all justification and support for the prudence of
such investment.

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

Micron Request No. 10: Regarding the proposed decommissioning costs stated in
Exhibit No. 2 of Mr. Larkin’s testimony:
a. Please provide all justification and support for such proposed costs, including, but
not limited to the most recently-conducted, site-specific decommissioning study for
the Valmy Plant.
b. Please tie any cost estimates stated in the decommissioning study to the proposed
decommissioning costs in Exhibit No. 2 of Mr. Larkin’s testimony.
c. Please confirm whether any contingency cost factors were included in the
decommissioning study.
d. Please verify the escalation rate used to escalate the present value of the proposed
decommissioning costs to the “2025 Costs” stated in Exhibit No. 2.
e. Please provide a detailed explanation any plans that Company management has
considered as an alternative to complete dismantlement of the Valmy plant,
including, but not limited to the sale of the plant, the repowering or conversion of
the plant, or the use of the site for future generating assets. Please include all
documentation and any cost estimates associated with such alternative plans.

DATED this 7th day of March, 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
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Micron Technology, Inc.’s Second Set of Data Requests to Idaho Power Company
IPC-E-16-24

Carson City, NV 89703
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

ATTORNEYS FOR MICRON
TECHNOLOGY, INC.

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

CERTIFICATE OF SERVICE
I hereby certify that on this 7th day of March, 2017, a true and correct copy of the within
and foregoing MICRON TECHNOLOGY, INC.’S SECOND SET OF DATA REQUESTS
TO IDAHO POWER COMPANY in CASE NO. IPC-E-16-24 was served in the manner shown
to:
Daphne Huang [e-mail] Idaho Public Utilities
Commission
Camille Christen [e-mail] Idaho Public Utilities
Commission
Diane Holt [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
Pete Bennett [e-mail] Micron Technology
Therese Wolf [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.

Benjamin J. Otto [e-mail] Idaho Conservation
League and Sierra
Club
Travis Ritchie [e-mail] Idaho Conservation
League and Sierra
Club
s/ Kayla L. Hall
9623416_1