20230808Micron 4-20 to IPC.pdf

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -1- AUGUST 8, 2023
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
HOLLAND & HART LLP
555 17th Street, Suite 3200
Denver, CO 80202
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
AND CHARGES FOR ELECTRIC SERVICE
IN THE STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY
ACCOUNTING TREATMENT.

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CASE NO. IPC-E-23-11

MICRON’S SECOND SET OF
DISCOVERY REQUESTS TO
IDAHO POWER COMPANY

Micron Technology, Inc. (“Micron” or “Intervenor”), by and through its counsel, Holland
& Hart LLP, submits the attached interrogatories and requests for the production of documents to
Idaho Power Company (“Idaho Power”). The following response date, definitions, and
instructions apply to the enclosed interrogatories and requests for production of documents.
In addition to the written copies provided as responses to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
RESPONSE DATE, DEFINITIONS AND INSTRUCTIONS

Please respond to these interrogatories and requests for production of documents by August
29, 2023. Please refer to the Definitions and Instructions included in Micron’s First Set of Data
Requests to Idaho Power in Case No. IPC-E-23-11, which are incorporated by reference.
RECEIVED
2023 AUGUST 8, 2023 4:36PM
IDAHO PUBLIC
UTILITIES COMMISSION

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -2- AUGUST 8, 2023

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 4: Please provide all exhibits, schedules, and workpapers utilized and/or
filed by Mr. McKenzie in this case in Excel format.

REQUEST NO. 5: Please provide all source documents relied upon and/or cited by Mr.
McKenzie in this case.

REQUEST NO. 6: Please provide a list of all proceedings in which Mr. McKenzie has
filed testimony.

REQUEST NO. 7: Please state the Company’s current authorized return on equity and cite the
commission order approving such authorized return.

REQUEST NO. 8: Please provide the most current reports from the major rating agencies for
IDACORP (“IDA”) and Idaho Power (including Moody’s, Standard and Poor’s, and Fitch).

REQUEST NO. 9: Please provide a copy of the most recent reports prepared by security analysts
that describe IDA.

REQUEST NO. 10: Please provide a copy of the most recent presentations of IDA and Idaho
Power given to security analysts and rating agencies.

REQUEST NO. 11: Please provide the Idaho Power’s forecasted growth rates for the following
factors over the longest reasonable period available, and provide the source for such forecasts, as
well as the time period for such forecasts, and the source of the information:

a. Total load
b. Total customers
c. Total revenue
d. Net income
e. Rate base
REQUEST NO. 12: Please provide Idaho Power’s annual figures for the following items over the
past 10 years and the source of such information:

a. Total load
b. Total customers
c. Total revenue

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -3- AUGUST 8, 2023
d. Operating income
e. Net income
f. Rate base
REQUEST NO. 13: Please provide the following financial information for the Company for the
most recent annual reporting period:

a. Earnings before interest and taxes
b. Interest expense
c. Amount of book debt capital
d. Amount of book equity capital
e. Cost of debt
REQUEST NO. 14: Please provide the year-end capital structures of Idaho Power and IDA over
the past five years.

REQUEST NO. 15: Please describe the source of Idaho Power’s common equity on its balance
sheet.

REQUEST NO. 16: Please provide a list of each equity issuance by IDA during the past five
years, including the number of shares issued, the offered price per share, the net proceeds per share,
and the total flotation cost for each issuance.

REQUEST NO. 17: Please refer to the Direct Testimony of Adrien McKenzie at page 80, lines
21-22. Please provide IDA’s and Idaho Power’s records pertaining to flotation costs and other
relevant information pertaining to these costs “recorded on the books of a utility.”

REQUEST NO. 18: Please refer to the Direct Testimony of Adrien McKenzie at pages 80-87
regarding flotation costs.

a. Please provide a schedule showing how the additional basis points added to Mr.
McKenzie’s proposed ROE relate to flotation costs incurred by IDA and Idaho
Power.
b. Is it Mr. McKenzie’s opinion that there should be a permanent upward adjustment
to the authorized ROE to account for flotation cost regardless of how long ago that
equity shares were issued?
REQUEST NO. 19: Is it Mr. McKenzie’s opinion that an authorized ROE of 10.6% represents
the Company’s lowest reasonable cost of equity?

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -4- AUGUST 8, 2023
REQUEST NO. 20: In Mr. McKenzie’s opinion, will the Company still be able to remain
financially healthy and attract capital if it is awarded a lower authorized ROE than 10.0% (the
lower end of his cost of equity range)? If the answer is no, please explain in detail.

Respectfully submitted August 8, 2023.
HOLLAND & HART, LLP

By:
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]

Attorneys for Micron Technology, Inc.

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -5- AUGUST 8, 2023
CERTIFICATE OF SERVICE
I hereby certify that on August 8, 2023, a true and correct copy of the within and foregoing
SECOND PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO
POWER COMPANY was served in the manner shown to:

Idaho Power Company
Lisa D. Nordstrom
Donovan E. Walker
Megan Goicoechea Allen
Idaho Power Company
1221 W. Idaho Street (83702)
PO Box 70
Boise, ID 83707-0070
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Timothy E. Tatum
Connie Aschenbrenner
Matt Larkin
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

Commission Staff
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A
Boise, ID 83714
[e-mail]
[e-mail]

Idaho Conservation League
Marie Callaway Kellner
Brad Heusinkveld
710 N. 6th Street
Boise, ID 83702
[e-mail]
[e-mail]

Clean Energy Opportunities
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Drive
Boise, ID 83703
[e-mail]

Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
[e-mail]
[e-mail]

Idaho Irrigation Pumpers Association, Inc.
Eric L. Olsen
Echo Hawk & Olsen, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ID 83205
elo echohawk.com

Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
[e-mail]

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -6- AUGUST 8, 2023
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, ID 83702
[e-mail]

Dr. Don Reading
280 Silverwood Way
Eagle, ID 83616
[e-mail]

Micron Technology, Inc.
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, ID 83707
[e-mail]

Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 17th Street, Suite 3200
Denver, CO 80202
[e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]

City of Boise City
Ed Jewell
Darrell Early
Wil Gehl
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]
[e-mail]

NW Energy Coalition
F. Diego Rivas
1101 8th Avenue
Helena, MT 59601
[e-mail]

Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
[e-mail]
[e-mail]
[e-mail]

Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
[e-mail]

MICRON TECHNOLOGY, INC.’S
SECOND SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -7- AUGUST 8, 2023
Walmart
Norman M. Semanko
Justina A. Caviglia
Parsons Behle & Latimer
800 West Mian Street, Suite 1300
Boise, ID 83702
[e-mail]
[e-mail]

Steve W. Chriss
Walmart Inc.
2608 Southeast J Street
Bentonville, AR 72716
[e-mail]

s/ Chelsey Moser
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