20230707Micron 1-3 to IPC.pdf

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -1- July 7, 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 IDAHO POWER
COMPANY’S APPLICATION FOR
AUTHORITY TO IMPLEMENT CHANGES
TO THE COMPENSATION STRUCTURE
APPLICABLE TO CUSTOMER ON-SITE
GENERATION UNDER SCHEDULES 6, 8,
AND 84 AND TO ESTABLISH AN EXPORT
CREDIT METHODOLOGY

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CASE NO. IPC-E-23-14

MICRON’S FIRST 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 on CD with formulas intact and enabled.
RESPONSE DATE, DEFINITIONS AND INSTRUCTIONS

Please respond to these interrogatories and requests for production of documents by July
28, 2022.

RECEIVED
Friday, July 7, 2023 2:56:39 PM
IDAHO PUBLIC
UTILITIES COMMISSION

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -2- July 7, 2023
DEFINITIONS

1. “Idaho Power Company,” “Idaho Power,” “IPC,” “the Company,” or “you” means Idaho
Power Company and the employees, officers, directors, agents, consultants, attorneys and
all persons acting under contractual arrangement with or acting or purporting to act on
behalf of Idaho Power.

2. “Agreement” means any contract, written or oral, or any non-contractual understanding.

3. “And/Or” will be construed disjunctively or conjunctively as necessary so that the scope
of these interrogatories is as broad as possible and includes any information which might
be constructed to be outside their scope.

4. “Communication” should be interpreted as broadly as possible to include, but not be
limited to, all forms of communication, whether written, printed, oral, pictorial, electronic
or otherwise and by any means or type whatsoever.

5. “Date” shall mean the exact day, month, and year if ascertainable, or if not the best
approximation thereof in relation to other events.

6. “Document” and “documentation” should be interpreted as broadly as possible, including
the original or any copy, regardless of origin or location, of any book, pamphlet, periodical
publication, letter, scrapbook, diary, calendar, canceled check, photograph, form,
memorandum, schedule, tax return, telegram, telex, report, record, order or notice of
governmental action of any kind, study, minutes, logs, graph, index, tape, disc, internal
operating manual, data sheet or data processing card, or any other written, recorded,
transcribed, punched, taped, filmed, graphic or retrievable matter or data of any kind,
however produced or reproduced, to which you have or have had access. This definition
includes all documents which have been created and/or which reside in any type of
electronic format.

Any document that is not exactly identical to another document for any reason (such as
marginal notations or deletions) should be considered a separate document.

As to any document related to the matters addressed herein that is not currently in your
possession but that you know or believe such a document exists, you are requested to
identify and indicate to the best of your ability its present or last known location or
custodian.

7. To “describe, “detail,” or “state” shall mean to relate as completely as possible each and
every act, omission, incident, event, condition, circumstance, decision, and/or thing
relating directly or indirectly to the subject of the explanation including all pertinent dates.

8. To “explain” means to make known in detail, to make clear the cause or reason of any
account for each act, omission, incident, event, condition, circumstance, decision, and/or

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -3- July 7, 2023
thing relating directly or indirectly to the subject of the explanation including all pertinent
dates.

9. Any request to “identify” or “provide” should be interpreted to mean:

a. With respect to a natural person, that person’s full name, title, job description, and
business and home address. Where the identification pertains to a past period, as
to each person identified who is still in your employ, or the employment of the
group with which such person is identified in response to any requests, provided,
in addition, that person’s title and job description as of the time of such past period.
Where the person is no longer in your employ or the employment of the group with
which such person is identified in response to any request, provide that person’s
affiliate, position, home and business address, if known, or if not known, such
person’s last known affiliation, position, home and business address, or portions
thereof as may be known.

b. With respect to an entity other than a natural person, that entity’s name, business,
type of entity, present status and present or last known address.

c. With respect to a document, that document’s title, date, author (and, if different, the
signer), addresses, recipients, or other persons who assisted in the preparation,
subject matter or general nature, and any amendments thereto, present location and
custodian, whether or not such document is in the respondent’s possession, custody
or control and whether or not the document is claimed to be privileged. The final
version and each draft of each document should be identified and produced
separately. Each original and each non-identical copy (bearing marks or notations
not found on the original) of each final version and draft of each document should
be identified and produced separately.

d. With respect to a physical facility, the location of the facility, the intended purpose
of the facility, the actual use of such facility, the operating dates of the facility, the
installation date of the facility, the date utilization of the facility terminated if
applicable, and whether the facility is subject to the jurisdiction of the Idaho Public
Utilities Commission, the Federal Energy Regulatory Commission, or any other
regulatory body.

10. “Person or Entity” should be interpreted to denote, unless otherwise specified, any natural
person, firm, corporation, association, group, individual or organization of any type
whatsoever.

11. “PUC” or “Commission” means the Idaho Public Utilities Commission.

12. “Record” or “Records” includes any regulation, formal or informal, official or unofficial
memorandum, document or written preservation of any events, actions taken or rejects,
decisions and details thereof relating to the subject matter of the question and your response

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -4- July 7, 2023
including electronic data and e-mail. A copy of the original “record” is preferred; stating
the substance thereof will suffice where a copy cannot be made and is not available.

13. “Relating To” or “Related To” means pertaining to, presenting, discussing, commenting
on, analyzing, or mentioning in any way.

GENERAL INSTRUCTIONS

1. Interrogatories and requests for production must be answered with particularity and in
detail.

2. Interrogatories and requests for production must be answered separately and fully in
writing under oath within twenty-one (21) days after service in accordance with IDAPA
31.01.01.225.

3. Interrogatories and requests for production must be signed by the person upon whose
personal knowledge responses are based or who helped in any way in answering these
interrogatories and requests for production.

4. You must provide the names of any other persons upon whose personal knowledge
responses are based or who helped in any way in answering these interrogatories and
requests for production.

5. In making your answers, you must produce all relevant documents and data by attachment
or by identifying the documents which relate to your answers. You must also clearly
identify each interrogatory to which the document relates.

6. These interrogatories and requests for production are continuing in nature and in the event
any information provided in an answer is changed or supplemented by future developments
or other factors, you must file appropriate supplemental answers.

7. In answering these interrogatories and requests for production you should furnish all
information which is in your possession, custody or control including, but not limited to,
information from any files, records, or documents in the possession of your attorneys,
consultants, staff, accountants, experts, employees, former employees, and other agents.

8. These interrogatories and requests for production should be answered based on your
personal knowledge, the personal knowledge of your attorneys, consultants, staff,
accountants, experts, employees, former employees, and any other agents as appropriate or
available and with reference to the sources described above.

9. If the respondent is not a witness who has filed written direct testimony, please indicate
which of the company's witnesses will be prepared to answer these questions on the stand.

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -5- July 7, 2023
10. In addition to a hard copy, please provide an electronic copy of your responses in Microsoft
Word. Where responses are prepared using spreadsheet software, please provide an
electronic copy in Microsoft Excel format.

11. If after exercising due diligence you are unable to answer any interrogatory or to produce
any document requested, you must explain your inability in detail.

12. If you object to any interrogatory or request for production, you may serve written
objections on Micron as provided in IDAPA 31.01.01.225, identifying the subject matter
objected to and stating with particularity the reasons for the objections. In addition, the
objections and the answers must be contained in separate pleadings with each clearly
identified as an objection or answer. The service of an objection will not excuse you from
answering the remaining interrogatories or responding to the remaining requests for
production for which no objection is stated.

13. If any responses to these interrogatories or requests for production have already been
provided in prior discovery in this matter, please direct Micron to the specific discovery
request and response where such response can be found.

14. Copies of the responses and any and all documents produced should be provided to:

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

INTERROGATORIES AND REQUESTS FOR PRODUCTION OF DOCUMENTS
REQUEST NO. 1: Please provide copies of all data requests and responses issued to Idaho
Power Company (“Idaho Power”) by all parties in this case. This is an ongoing request.

REQUEST NO. 2: Please provide the exhibits of all witnesses who filed direct testimony
on behalf of Idaho Power in electronic spreadsheet format with all formulas and links intact.

REQUEST NO. 3: Please provide the workpapers of all witnesses who filed direct
testimony on behalf of Idaho Power in electronic spreadsheet format with all formulas and links
intact.

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -6- July 7, 2023

Respectfully submitted July 7, 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
FIRST PRODUCTION REQUEST
TO IDAHO POWER -7- July 7, 2023
CERTIFICATE OF SERVICE
I hereby certify that on July 7, 2023, a true and correct copy of the within and foregoing
FIRST PRODUCTION REQUEST OF MICRON TECHNOLOGY, INC. TO IDAHO POWER
COMPANY was served in the manner shown to:

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

Timothy E. Tatum
Connie Aschenbrenner
Grant Anderson
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
Idaho Conservation League, Energy Associate
710 N. 6th Street
Boise, ID 83702
[e-mail]
[e-mail]

Idaho Irrigation Pumpers Association
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.
4801 W Yale Avenue
Denver, CO 80219
[e-mail]

MICRON TECHNOLOGY, INC.’S
FIRST PRODUCTION REQUEST
TO IDAHO POWER -8- July 7, 2023
Idaho Hydroelectric Power Producers Trust
C. Tom Arkoosh
ARKOOSH LAW OFFICES
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
[e-mail]
[e-mail]

Boise City:
Darrell Early
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]

Clean Energy Opportunities for Idaho
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
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]

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]

Vote Solar
Abigail R. Germaine
Elam & Burke, P.A.
251 E. Front Street, Suite 300
P.O. Box 1539
Boise, ID 83701
[e-mail]

Vote Solar
c/o Kate Bowman
Regulatory Director, Interior West
299 S. Main Street, Suite 1300, PMB 93601
Salt Lake City, UT 84111
[e-mail]

s/ Adele Lee
30015267_v1