20230829IPC to Micron 4-20.pdf

LISA D. NORDSTROM
Lead Counsel
[e-mail]
August 29, 2023
VIA ELECTRONIC FILING
Jan Noriyuki, Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg 8,
Suite 201-A (83714)
PO Box 83720
Boise, Idaho 83720-0074
Re: Case No. IPC-E-23-11
Idaho Power Company’s General Rate Case
Dear Ms. Noriyuki:
Enclosed for electronic filing, please find Idaho Power Company’s Response to
Micron Technology, Inc.’s Second Set of Discovery Requests to Idaho Power Company.
Due to the collectively voluminous confidential and non-confidential information
provided in response to data requests in this case, the Company is posting the
attachments to these requests to the secure FTP site to allow parties to view the
requested information remotely unless otherwise noted in the response. Because certain
attachments contain confidential information, the FTP site is divided between confidential
and non-confidential information.
The login information for the non-confidential portion of the FTP site has been
provided to all parties that have intervened to date. The login information for the
confidential portion of the FTP site has been provided the parties that have executed the
Protective Agreement in this matter.
If you have any questions about the attached filing, please do not hesitate to
contact me.
Very truly yours,
Lisa D. Nordstrom
LDN:sg
Enclosures
RECEIVED
Tuesday, August 29, 2023 4:41:03 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CERTIFICATE OF ATTORNEY
ASSERTION THAT INFORMATION CONTAINED IN AN IDAHO PUBLIC UTILITIES
COMMISSION FILING IS PROTECTED FROM PUBLIC INSPECTION
Case No. IPC-E-23-11
In the Matter of the Application of Idaho Power Company for Authority to Increase
Its Rates and Charges for Electric Service to Its Customers In the State of Idaho
and For Associated Regulatory Accounting Treatment
The undersigned attorney, in accordance with Commission Rules of Procedure 67,
believes that attachments in Response to Requests Nos. 8, 9, 10 and 11 to Idaho Power
Company’s Response to the Micron Technology, Inc.’s Second Set of Discovery
Requests dated August 29, 2023, contain information that Idaho Power Company and a
third party claim are trade secrets, public records exempt from disclosure by state or
federal law (material nonpublic information under U.S. Securities and Exchange
Commission Regulation FD), and/or business records of a private enterprise required by
law to be submitted to or inspected by a public agency, as described in Idaho Code § 74-
101, et seq., and/or § 48-801, et seq. As such, it is protected from public disclosure and
exempt from public inspection, examination, or copying.
DATED this 29th day of August, 2023.
LISA D. NORDSTROM
Counsel for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 1
LISA D. NORDSTROM (ISB No. 5733)
DONOVAN E. WALKER (ISB No. 5921)
MEGAN GOICOECHEA ALLEN (ISB No. 7623)
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]
Attorneys for Idaho Power Company
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
IDAHO POWER COMPANY’S
RESPONSE TO MICRON
TECHNOLOGY INC.’S SECOND
SET OF DISCOVERY TO IDAHO
POWER COMPANY
COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Micron Technology, Inc.’s (“Micron”) Second Set of Discovery Requests to
Idaho Power Company dated August 8, 2023, herewith submits the following information:
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION NO. 4: Please provide all exhibits, schedules,
and workpapers utilized and/or filed by Mr. McKenzie in this case in Excel format.
RESPONSE TO REQUEST FOR PRODUCTION NO. 4: Please see the attached
Excel file “McKenzie Idaho Power Exhibit File.xlsm.”
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION NO. 5: Please provide all source documents
relied upon and/or cited by Mr. McKenzie in this case.
RESPONSE TO REQUEST FOR PRODUCTION NO. 5: The requested
information was provided as workpapers via the Company’s File Transfer (“FTP”) Site on
June 7, 2023.
The response to this Request is sponsored by Stacy Gust, Regulatory
Administrative Assistant, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4
REQUEST FOR PRODUCTION NO. 6: Please provide a list of all proceedings in
which Mr. McKenzie has filed testimony.
RESPONSE TO REQUEST FOR PRODUCTION NO. 6: A list of all prior
proceedings in which Mr. McKenzie has prepared and sponsored pre-filed testimony is
provided as Attachment – Response to Micron’s Request No. 6.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION NO. 7: Please state the Company’s current
authorized return on equity and cite the commission order approving such authorized
return.
RESPONSE TO REQUEST FOR PRODUCTION NO. 7: In the Company's last
general rate case, IPC-E-11-08,1 the Commission did not authorize a stated return on
equity. Rather, the Commission approved the settlement stipulation that provided for an
overall rate of return of 7.86 percent.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
1 Order No. 32426 at 3.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6
REQUEST FOR PRODUCTION 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).
RESPONSE TO REQUEST FOR PRODUCTION NO. 8: The most recent Moody’s
report for Idaho Power and IDACORP are each dated July 26, 2022. The Idaho Power
report was provided as Confidential Attachment 1 to the Company’s Response to ICIP
Request for Production No. 13. The IDACORP report is provided as Confidential
Attachment 1 to this request.
The most recent Standard and Poor’s report for Idaho Power is dated June 16,
2023, and is included as Confidential Attachment 2 to this request. Additionally, Standard
and Poor’s downgraded IDACORP, Inc. and Idaho Power’s liquidity in a report dated
February 7, 2023, which was provided as Confidential Attachment 1 to the Company’s
Response to ICIP Request for Production No. 14.
IDACORP, Inc. and Idaho Power have not received ratings from Fitch in many
years.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 7
REQUEST FOR PRODUCTION NO. 9: Please provide a copy of the most recent
reports prepared by security analysts that describe IDA.
RESPONSE TO REQUEST FOR PRODUCTION NO. 9: The most recent copy of
the quarterly reaction reports prepared by the five analysts that cover IDACORP are
included as Confidential Attachments 1 through 5 to this request. Please note reports
prepared by analysts are proprietary research and should be treated as confidential.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8
REQUEST FOR PRODUCTION NO. 10: Please provide a copy of the most recent
presentations of IDA and Idaho Power given to security analysts and rating agencies.
RESPONSE TO REQUEST FOR PRODUCTION NO. 10: The most recent
presentation to security analysts is available on IDACORP’s website at
(https://www.idacorpinc.com/investor-relations/events-and-presentations/default.aspx).
The most recent presentations to ratings agencies were made available in the
Company’s Confidential Response to ICIP Requests for Production Nos. 13 and 14. The
requested information is highly confidential. It will be made available at Idaho Power's
corporate headquarters. Please contact Tami White at [phone] or David Fewkes
at [phone] to arrange a time to review the requested material.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 9
REQUEST FOR PRODUCTION 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
RESPONSE TO REQUEST FOR PRODUCTION NO. 11:
a. Idaho Power’s forecasted load growth for the period of 2024-2043 is a 2.2 percent
Compound Annual Growth Rate (“CAGR”). The source of the sales forecast is the
long-term forecast model specifications that the Company used to estimate its
2023 load requirements included in this case.
b. Idaho Power’s forecasted customer growth for the period of 2024-2043 is a 1.5
percent CAGR. The source of the customer forecast is the long-term forecast
model specifications that the Company used to estimate its 2023 load
requirements included in this case.
c. The requested information is highly confidential. It will be made available at Idaho
Power's corporate headquarters. Please contact Tami White at [phone] or
David Fewkes at [phone] to arrange a time to review the requested
material.
d. The requested information is highly confidential. It will be made available at Idaho
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 10
Power's corporate headquarters. Please contact Tami White at [phone] or
David Fewkes at [phone] to arrange a time to review the requested
material.
e. The forecasted growth rates for Idaho Power’s rate base for the period of 2023-
2027 is a 11.1 percent CAGR. The source of the forecasted growth rate is shown
on Slide 11 of IDACORP’s 4th quarter earnings conference call presentation dated
February 16, 2023, which is publicly available on the IDACORP website at
https://s26.q4cdn.com/720254477/files/doc_financials/2022/q4/4Qtr_2022_Confe
rence_Call.pdf.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 11
REQUEST FOR PRODUCTION 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
d. Operating income
e. Net income
f. Rate base
RESPONSE TO REQUEST FOR PRODUCTION NO. 12: The requested
information is provided in the attached Excel spreadsheet labeled “Attachment –
Response to Micron Request No. 12.” The information was compiled from amounts
reported in Forms 10-K as filed with the Securities and Exchange Commission, except as
noted in the attachment. For total load, total retail megawatt-hours sold is provided for
each year. All amounts are annual, except total retail customers and total rate base, which
are as of December 31 for each respective year.
The response to this Request is sponsored by Paula Jeppsen, Forecasting and
Planning Director, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 12
REQUEST FOR PRODUCTION 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
RESPONSE TO REQUEST FOR PRODUCTION NO. 13: The following Idaho
Power financial information is for the most recent annual reporting period (2022), in
thousands (except for cost of debt). Interest expense relates to long-term debt and
includes amortization of premium/discount, debt issuance costs, and losses on re-
acquired debt. Interest expense excludes carrying charges on customer deposits and
regulatory liabilities and also excludes bank commitment fees related to Idaho Power’s
credit facility. Idaho Power’s book debt capital excludes unamortized premium/discount,
losses on reacquired debt, and debt issuance costs, and also excludes Idaho Power’s
guarantee of American Falls variable rate bonds. No adjustments have been made to
remove Allowance for Funds Used During Construction from the numbers below.
a. Earnings before interest and taxes - $385,136
b. Interest expense - $90,361
c. Amount of book debt capital - $2,164,100
d. Amount of book equity capital - $2,631,663
e. Cost of debt – 4.60 percent
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 13
REQUEST FOR PRODUCTION NO. 14: Please provide the year-end capital
structures of Idaho Power and IDA over the past five years.
RESPONSE TO REQUEST FOR PRODUCTION NO. 14: Please see the table
below:
Year Ending December 31, 2022
Idaho Power IDACORP
Capitalization Structure Capitalization Structure
Amount Percent Amount Percent
Long-term Debt 2,164,100 45.1%2,164,100 43.5%
Common Equity 2,631,662 54.9%2,814,615 56.5%
Total Capitalization $4,795,762 100.0%$4,978,715 100.0%
Year Ending December 31, 2021
Idaho Power IDACORP
Capitalization Structure Capitalization Structure
Amount Percent Amount Percent
Long-term Debt 1,970,460 44.4%1,970,460 42.4%
Common Equity 2,464,302 55.6%2,675,234 57.6%
Total Capitalization $4,434,762 100.0%$4,645,694 100.0%
Year Ending December 31, 2020
Idaho Power IDACORP
Capitalization Structure Capitalization Structure
Amount Percent Amount Percent
Long-term Debt 1,970,460 45.5%1,970,460 43.4%
Common Equity 2,363,834 54.5%2,566,456 56.6%
Total Capitalization $4,334,294 100.0%$4,536,916 100.0%
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 14
Year Ending December 31, 2019
Idaho Power IDACORP
Capitalization Structure Capitalization Structure
Amount Percent Amount Percent
Long-term Debt 1,835,460 44.6%1,835,460 42.6%
Common Equity 2,275,558 55.4%2,470,553 57.4%
Total Capitalization $4,111,018 100.0%$4,306,013 100.0%
Year Ending December 31, 2018
Idaho Power IDACORP
Capitalization Structure Capitalization Structure
Amount Percent Amount Percent
Long-term Debt 1,835,460 45.5%1,835,460 43.6%
Common Equity 2,194,439 54.5%2,375,811 56.4%
Total Capitalization $4,029,899 100.0%$4,211,271 100.0%
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 15
REQUEST FOR PRODUCTION NO. 15: Please describe the source of Idaho
Power’s common equity on its balance sheet.
RESPONSE TO REQUEST FOR PRODUCTION NO. 15: Idaho Power's common
equity is made up of common stock, premium on common stock, common stock expense,
retained earnings, and accumulated other comprehensive loss. The amounts below are
from Idaho Power’s December 31, 2022, balance sheet, as reported in Idaho Power's
2022 Annual Report on Form 10-K.
As of December 31, 2022 (in thousands):
Common stock, $2.50 par value $ 97,877
Premium on capital stock 712,258
Capital stock expense (2,097)
Retained earnings 1,836,547
Accumulated other comprehensive loss (12,922)
Total equity $ 2,631,663
The common stock value was derived from Idaho Power's 39,150,812 shares
outstanding at the $2.50 par value. The most recent issuance of common shares was in
December 2003. The premium on common stock value was derived from amounts in
excess of par value received from share issuances and from contributions received from
IDACORP. The most recent contribution received from IDACORP was in 2012. The
capital stock expense value was derived from costs related to issuance of Idaho Power
common shares and has not changed since 2004. The retained earnings value was
derived primarily from an accumulation of all net income of Idaho Power since inception,
reduced by cumulative dividends to shareholders. The accumulated other comprehensive
loss value was derived from changes in actuarial valuations of liabilities related to the
security plans for senior management employees.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 16
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 17
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 16: IDACORP has issued
no equity to outside markets in the last five years. There has been a nominal amount of
equity issued as compensation through the Company’s long-term incentive plans.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President & Chief Financial Officer, Idaho Power Company.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 18
REQUEST FOR PRODUCTION 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.”
RESPONSE TO REQUEST FOR PRODUCTION NO. 17: Mr. McKenzie states in
his Direct Testimony that debt flotation costs are recorded on the books of the utility and
amortized over the life of the issue, and thus increase the effective cost of debt capital.
The Direct Testimony of Mr. Brian Buckham shows these debt discount and issuance
costs and their impact on the effective cost of debt capital (see Buckham Exhibit 21, page
2, columns 8 and 9).As Mr. McKenzie indicated in his Direct Testimony, unlike the cost
associated with issuing long-term bonds, common equity flotation costs are not recorded
on books of the utility. Equity flotation costs are not amortized as an expense; nor are they
included in a utility’s rate base because neither that portion of the gross proceeds from the
sale of common stock used to pay flotation costs is available to invest in plant and
equipment, nor are flotation costs capitalized as an intangible asset. Because there is no
accounting convention to accumulate the flotation costs associated with equity issues, they
must be accounted for indirectly, with an upward adjustment to the cost of equity being
the most appropriate mechanism.
The response to this Request is sponsored by Brian Buckham, Senior Vice
President and Chief Financial Officer and Adrien McKenzie, CFA, President, FINCAP,
Inc.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 19
REQUEST FOR PRODUCTION 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?
RESPONSE TO REQUEST FOR PRODUCTION NO. 18:
a. As explained in Mr. McKenzie’s Direct Testimony, equity flotation costs are not
accounted for in the books and records of the Company. Mr. McKenzie adopted
an approach to estimating flotation costs by applying an industry-wide flotation cost
factor to the average dividend yield for the firms in his proxy group.
b. Idaho Power objects on the grounds that the request calls for a statement of
opinion proscribed by RP 225.01(a). Notwithstanding the above objection, yes.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 20
REQUEST FOR PRODUCTION NO. 19: Is it Mr. McKenzie’s opinion that an
authorized ROE of 10.6% represents the Company’s lowest reasonable cost of equity?
RESPONSE TO REQUEST FOR PRODUCTION NO. 19: Idaho Power objects on
the grounds that the request calls for a statement of opinion proscribed by RP 225.01(a).
Notwithstanding the above objection, Mr. McKenzie concludes that a fair ROE for
Idaho Power falls in a range of 10.1 percent to 11.1 percent, with his 10.6 percent
recommendation being the midpoint of this range. Mr. McKenzie’s opinion is that an ROE
of 10.6 percent represents a just and reasonable ROE that is adequate to compensate
Idaho Power’s investors, while maintaining the Company’s financial integrity and ability
to attract capital on reasonable terms.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 21
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 20: Idaho Power objects on
the grounds that the request calls for a statement of opinion proscribed by RP 225.01(a).
Notwithstanding the above objection, please refer to the response to Request for
Production No. 19. Mr. McKenzie’s recommended ROE range for Idaho Power is 10.1
percent to 11.1 percent. It is his opinion that an ROE below the bottom end of his
recommended range would adversely affect Idaho Power’s financial standing under
current capital market conditions.
The response to this Request is sponsored by Adrien McKenzie, CFA, President,
FINCAP, Inc.
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 22
DATED at Boise, Idaho, this 29th day of August 2023.
LISA D. NORDSTROM
Attorney for Idaho Power Company
DONOVAN E. WALKER
Attorney for Idaho Power Company
MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 23
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 29th day of August 2023, I served a true and
correct copy of Idaho Power Company’s Response to Micron Technology Inc.’s Second
Set of Discovery Request to Idaho Power Company upon the following named parties by
the method indicated below, and addressed to the following:
Commission Staff
Dayn Hardie
Chris Burdin
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg No. 8
Suite 201-A (83714)
PO Box 83720
Boise, ID 83720-0074
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
[e-mail]
Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 24
Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]
[e-mail]
[e-mail]
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
[e-mail]
[e-mail]
IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 25
Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email [e-mail]
Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
Hand Delivered
U.S. Mail
Overnight Mail
FAX
FTP Site
X Email
[e-mail]
IdaHydro
C. Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, Idaho 83701
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Federal Executive Agencies
Peter Meier
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, DC 20585
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Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY INC.’S SECOND SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 26
NW Energy Coalition
F. Diego Rivas
1101 8th Ave
Helena, MT 59601
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Walmart Inc.
Norman M. Semanko
Parsons Behle & Latimer
800 West Main Street, Suite 1300
Boise, Idaho 83702
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Steve W. Chriss
Director, Energy Services
Walmart Inc.
2608 Southeast J Street
Bentonville, Arkansas 72716
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Walmart Inc.
Justina A. Caviglia
Parsons Behle & Latimer
50 West Liberty Street, Suite 750
Reno, NV 89502
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Stacy Gust, Regulatory Administrative
Assistant