20230825Micron 21-24 to IPC.pdf

MICRON TECHNOLOGY, INC.’S
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -1- AUGUST 25, 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 THIRD 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
September 15, 2023. Please refer to the Definitions and Instructions included in Micron’s First
RECEIVED
2023 AUGUST 25, 2023 3:42PM
IDAHO PUBLIC
UTILITIES COMMISSION

MICRON TECHNOLOGY, INC.’S
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -2- AUGUST 25, 2023
Set of Data Requests to Idaho Power in Case No. IPC-E-23-11, which are incorporated by
reference.
INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 21: Please provide a proof of revenue showing how annual billing units applied
to current and proposed rates produce the current and proposed revenues for each class, and the
total requested revenue requirement. Please provide the proof of revenue in electronic spreadsheet
format with all formulas and links intact.

REQUEST NO. 22: Please refer to the Direct Testimony of Pawel P. Goralski at pages 8 and 9.
In electronic spreadsheet format, with all formulas and links intact, please provide the following:

a. The workpapers used to produce the demand and energy allocation factors by
jurisdiction and by tariff rate class used in the Company’s filing in this case, in
electronic spreadsheet format with all formula intact, including all supporting
schedules and/or workbooks.
b. The system (retail and total company) peak demands for each month of the test
year.
c. The monthly retail coincident peak demands for the system and by each customer
class for the test year.
d. The calculation of Idaho Power Company’s 12 coincident peak (“12CP”) demands
by customer class used to allocate demand-related base-load generation plant costs
in the CCOSS.
e. The calculation of Idaho Power Company’s four coincident peak (“4CP”) demands
by customer class used to allocate peak-load serving generation capacity costs in
the CCOSS.
f. The calculation of Idaho Power Company’s 12 CP demands by customer class used
to allocate transmission capacity costs in the CCOSS.
g. The calculation of Idaho Power Company’s energy-related cost allocators inclusive
of marginal-cost weighting.
h. The three-year load duration curve used to classify distribution plant between
demand and customer.

MICRON TECHNOLOGY, INC.’S
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -3- AUGUST 25, 2023
REQUEST NO. 23: Please refer to Mr. Goralski’s Direct Testimony at page 11, lines 6-8.

a. Please indicate whether Account 555.0 Purchased Power Agreements are used to
meet the Company’s production resource adequacy requirements or planning
reserve requirements. If affirmative:
i. Please identify the capacity provided by the PPA and describe how the
capacity is reflected in the PPA price.
ii. Please identify the annual PPA capacity commitment and energy
commitment, by year over the contract agreement.
iii. If the response to part a. is affirmative, please explain why Idaho Power
Company proposes to allocate the capacity-related benefits of the PPA on
an energy basis.
b. Please indicate whether Account 555.1 – PURPA provides production capacity that
the Company relies on to meet its production resource adequacy or planning reserve
requirement. If the response is affirmative:
i. Please identify the amount of qualifying capacity.
ii. Please identify the annual qualifying capacity and energy entitlement under
the PPA.
iii. Please explain why Idaho Power Company proposes to allocate the
capacity-related benefits of the PURPA resource on an energy basis.
REQUEST NO. 24: Regarding the Company’s proposal to transfer Demand-Side Management
(“DSM”) labor-related cost collection from the Energy Efficiency Rider into base rates, please
respond to the following:

a. Please identify the amount of DSM labor-related cost being transferred to base
rates.
b. Please explain how the DSM labor-related cost is currently allocated across
customer classes for collection through the Energy Efficiency Rider.
c. Please explain how the DSM labor-related cost will be allocated to customer classes
once it is rolled into base rates.

MICRON TECHNOLOGY, INC.’S
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -4- AUGUST 25, 2023
Respectfully submitted August 25, 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
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -5- AUGUST 25, 2023
CERTIFICATE OF SERVICE
I hereby certify that on August 25, 2023, a true and correct copy of the within and foregoing
THIRD 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
[e-mail]

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

MICRON TECHNOLOGY, INC.’S
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -6- AUGUST 25, 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
THIRD SET OF DISCOVERY REQUESTS
TO IDAHO POWER COMPANY -7- AUGUST 25, 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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