20230915IPC to Micron 21-24.pdf

MEGAN GOICOECHEA ALLEN
Corporate Counsel
[e-mail]

September 15, 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 Third 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,

Megan Goicoechea Allen
MGA:sg
Enclosures

RECEIVED
Friday, September 15, 2023 1:44:07 PM
IDAHO PUBLIC
UTILITIES COMMISSION

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD 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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)
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CASE NO. IPC-E-23-11

IDAHO POWER COMPANY’S
RESPONSE TO MICRON
TECHNOLOGY, INC.’S THIRD SET
OF DISCOVERY REQUESTS TO
IDAHO POWER COMPANY

COMES NOW, Idaho Power Company (“Idaho Power” or “Company”), and in
response to Micron Technology, Inc.’s (“Micron”) Third Set of Discovery Requests dated
August 25, 2023, herewith submits the following information:

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 2
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 21: Please see the
attachment provided for this request, Attachment – Response to Micron’s Request No.
21.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 3
REQUEST FOR PRODUCTION 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.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 4
RESPONSE TO REQUEST FOR PRODUCTION NO. 22:
a.-g. Please see previously provided Confidential Attachment 6 to Supplemental
Response to Staff’s Request No. 75, Goralski Exhibit No. 44, and Goralski Exhibit
No. 45.
h. Please see the attachment provided for this request, Attachment – Response to
Micron’s Request No. 22.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 5
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 23:
a. Idaho Power has Power Purchase Agreements (“PPAs”) or Energy Sales
Agreements (“ESAs”) with several different resource types. These PPAs and ESAs

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 6
are assumed to count toward the Company’s production resource adequacy
requirements and planning reserve requirements. In resource planning, the
methodology by which the projects are assigned capacity contribution depends on
the resource type, not on the agreement type (i.e., PURPA or non-PURPA). For
PPAs or ESAs of various resources (wind, solar, run of river hydro, thermal,
biomass, etc.), Idaho Power currently assumes the resource provides capacity
based on a total calculated Effective Load Carrying Capability (“ELCC”). Idaho
Power resource planning does not assign a particular ELCC value to each PPA or
ESA resource, but instead utilizes historical hourly data in its internally developed
Reliability and Capacity Assessment Tool (“RCAT”) to account for the capacity
contribution of those resource types to system reliability. For example, wind
projects are combined to determine a total wind contribution, independent of
whether a project is in Account 555.0 or Account 555.1. Idaho Power provides the
capacity contribution by resource type in the biannually published Integrated
Resource Plan (“IRP”); the ELCC values of existing and future resources as
published in the 2021 IRP are provided below for informational purposes.
However, the PPAs and ESAs do not identify a capacity value the project is
required to provide.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 7
ELCC of Existing Resources ELCC of Future Resources 
Resource Average Resource Average 
PURPA Solar 62.3% Solar PV  10.2% 
Oregon Solar 62.3% Jackpot Solar 34.0% 
PURPA Wind 15.0% Wind 11.2% 
Elkhorn Wind 15.0% 4‐Hour Storage 87.5% 
Current Demand Response 17.3% 8‐Hour Storage 97.0% 
  Solar PV + 4‐Hour Storage 97.0% 
  Proposed Demand Response 58.5% 
  Incremental Demand Response 36.0% 

i. Capacity provided by a PPA is not tracked by project. The Company
highlights the difference between the cost of PPAs versus how they impact
resource adequacy and planning reserve requirements. Specifically, PPA
cost is negotiated for a fully bundled product Idaho Power receives, which
may include capacity value, energy value, and environmental attributes,
among others. The “value layers” of a PPA are not individual components
which are enumerated and combined into a final PPA rate.
ii. Individual PPA capacity commitment is not tracked over the contract
agreement. The energy entitlement under the PPA is provided in a monthly
forecast.
iii. As noted in response to part a(i), capacity is not tracked by project, and
each PPA price is negotiated as a bundled product with a single price which
is identified in the PPA and paid to the project as compensation based on
variable output of the project. The price is paid to the project based on actual
generation, which is variable and not dispatchable. For these reasons and
the reasons described above regarding how the project’s capacity is

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 8
counted in resource planning, allocation on an energy basis is appropriate.
b. Please see the response to part a. For PURPA resources, Idaho Power includes
below a portion of the response provided to the Industrial Customers of Idaho
Power Request No. 9(2):
Prior classification of purchased power in the Company’s 2011 general
rate case, including PURPA energy and capacity cost did not classify
costs in a manner matching the respective component of PURPA
payment, that is PURPA capacity costs were not classified as 100
percent demand-related, nor were PURPA energy costs classified as
100 percent energy-related, instead they followed classification of
production plant.
Further, the capacity-related expense listed in the 2011 general rate
case test year, $2,815,214 out of $86,772,920 of account 555.1
Cogeneration & Small Power Production cost, represented capacity
payments for contracts which had a levelized capacity payment
independent of energy generation for generators such as hydro and
biomass, and were contracts executed in the 1980s which utilized a
different Commission-approved methodology for capacity payment
structure. As contracts have expired since the 2011 general rate case,
upon their renewal all contracts were transitioned to current,
Commission-approved methodology to include the capacity payment on
a combined basis with the energy rate and are expressed on single,
dollars per megawatt-hour values differentiated between heavy-load
and light-load hours, which is the single contract cost value for any
specific hour entered into the Company’s accounting system. The last
year Idaho Power recorded separate capacity payments was 2019.

Payments made for PURPA contracts for both energy and capacity are
variable based on the variable output of the project, thus the Company
has classified all PURPA expense as 100 percent energy related.

i. The qualifying capacity of an ESA project is not tracked.
ii. Please see the response to part a(ii).
iii. Please see the response to part a(iii). Prices in ESAs are determined either
under the avoided cost methodologies approved by the Commission, and

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 9
the prices identified in the ESAs, and as described in part a(iii), the
compensation to the project is based on the prices as applied to the variable
output of the project.
The response to this Request is sponsored by Jared Ellsworth, Transmission,
Distribution, and Resource Planning Director and Paul Goralski, Regulatory Consultant,
Idaho Power Company.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 10
REQUEST FOR PRODUCTION 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.
RESPONSE TO REQUEST FOR PRODUCTION NO. 24:
a. $3,474,5551
b. All energy efficiency-related costs recovered through the Energy Efficiency
Rider are collected from customers at the percentage identified in Schedule 91
– Energy Efficiency Rider, multiplied by the customer’s monthly billed charges
for the base rate components.
c. The $3.5 million in DSM labor-related expense transferred into base rates is
recorded in FERC account 908, Customer Assistance, which is allocated to
customer classes based on customer count.
The response to this Request is sponsored by Paul Goralski, Regulatory
Consultant, Idaho Power Company.

1 Noe Exhibit No. 34; Noe Exhibit No. 35; Goralski Exhibit No. 41.

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 11
DATED at Boise, Idaho, this 15th day of September 2023.

MEGAN GOICOECHEA ALLEN
Attorney for Idaho Power Company

LISA D. NORDSTROM
Attorney for Idaho Power Company

DONOVAN E. WALKER
Attorney for Idaho Power Company

IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 12
CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on the 15th day of September 2023, I served a true and
correct copy of Idaho Power Company’s Response to Micron Technology, Inc.’s Third Set
of Discovery Requests 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

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Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
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Courtney White
Mike Heckler
Clean Energy Opportunities for Idaho
3778 Plantation River Drive, Suite 102
Boise, ID 83703

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Industrial Customers of Idaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
Boise, Idaho 83702

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IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 13
Dr. Don Reading
280 Silverwood Way
Eagle, Idaho 83616

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Idaho Irrigation Pumpers Association,
Inc.
Eric L. Olsen
ECHO HAWK & OLSEN, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, Idaho 83205

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Lance Kaufman, Ph.D.
2623 NW Bluebell Place
Corvallis, OR 97330
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Micron Technology, Inc.
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 Seventeenth Street, Suite 3200
Denver, Colorado 80202

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Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise, Idaho 83707
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IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 14
City of Boise
Ed Jewell
Darrell Early
Boise City Attorney’s Office
150 N. Capitol Blvd.
Boise, ID 83701
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Wil Gehl
Boise City Dept. of Public Works
150 N. Capitol Blvd.
P.O. Box 500
Boise, Idaho 83701-0500

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Idaho Conservation League
Marie Callaway Kellner
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702

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Brad Heusinkveld
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83702
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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
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washin ton, DC 20585
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IDAHO POWER COMPANY’S RESPONSE TO MICRON TECHNOLOGY, INC.’S THIRD SET OF
DISCOVERY REQUESTS TO IDAHO POWER COMPANY - 15

Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
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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