20220513Reply Comments.pdf

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REPLY COMMENTS OF MICRON TECHNOLOGY, INC.
IPC-E-21-17
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen
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 INCREASE ITS RATES
FOR ELECTRIC SERVICE TO RECOVER
COSTS ASSOCIATED WITH THE JIM
BRIDGER POWER PLANT

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CASE NO. IPC-E-21-17

REPLY COMMENTS OF MICRON
TECHNOLOGY, INC.

Micron Technology, Inc. (“Micron”), pursuant to the Commission’s Notice of Amended
Application dated March 10, 2022, submits its reply comments regarding Idaho Power Company’s
(“Idaho Power”) Amended Application in this proceeding.
I. Micron agrees with initial comments that the Commission should not approve a rate
increase at this time and should direct Idaho Power to further analyze potential rate
mitigation options.

Micron appreciates the thoughtful initial comments filed in this proceeding by Commission
Staff and a diverse group of interested parties. In general, Micron agrees with parties’ comments
that a rate increase is inappropriate and unnecessary at this time and that Idaho Power should
further analyze and present to the Commission options to mitigate potential rate increases due to
the anticipated early retirement of Jim Bridger coal-related facilities (“Bridger”).
RECEIVED
2022 May 13, PM 1:29
IDAHO PUBLIC
UTILITIES COMMISSION

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REPLY COMMENTS OF MICRON TECHNOLOGY, INC.
IPC-E-21-17
First, Micron agrees with parties’ comments that Idaho Power has not established that a
rate increase is necessary or appropriate at this time. As discussed by Commission Staff, there is
still substantial uncertainty regarding the terms of a potential exit agreement between Idaho Power
and PacifiCorp, the co-owner of the Bridger plant, PacifiCorp.1 The contractual terms of such exit
agreement, once determined, may impact the closure costs and may shift the economics of Idaho
Power’s planned Bridger closure date.2 This is especially true as the Bridger exit dates presented
in Idaho Power’s 2021 Integrated Resource Plan vary significantly from PacifiCorp’s planned exit
dates.3 It would be unreasonable to burden customers with increased rates at this time given such
uncertainty.
Second, Micron agrees with Commission Staff’s analysis that Idaho Power will not be
harmed financially by deferring to a future rate case recovering accelerated depreciation rates.4
Based on Idaho Power’s filed financial reports, Idaho Power is currently earning a healthy return
on equity and Commission Staff’s analysis shows that denying Idaho Power’s proposed rate
increase will not materially impact the Company’s financial position.5 Should Idaho Power feel
differently, the utility has the right to file a general rate case at any time to allow a comprehensive
review of its costs and revenues. Such a comprehensive review would be more appropriate than
piecemeal rate increases with no review of the Company’s overall financial results.
Finally, Micron agrees with other initial comments that Idaho Power has not adequately
analyzed potential options to mitigate rate increases resulting from an early Bridger retirement.
As a large consumer, Micron relies on Idaho Power providing service at just and reasonable rates

1 Comments of the Commission Staff (April 27, 2022), pp. 9-10.
2 Id.
3 Id.
4 Id. at p. 11.
5 Id.

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REPLY COMMENTS OF MICRON TECHNOLOGY, INC.
IPC-E-21-17
to effectively operate and remain competitive in the global marketplace. As noted in the
comments, the proposed Bridger rate increase would be “pancaked” with another impending large
rate increase due to the Power Cost Adjustment (“PCA”) the Company filed on April 15, 2022.6
Micron agrees with initial comments that, to the extent the Commission determines a Bridger
depreciation rate increase is appropriate now or in the near future, that the Commission should
require Idaho Power to first analyze and present options to mitigate the rate increase, such as
securitization. In initial comments, parties present persuasive arguments that securitization may
be a useful tool to prevent rate shock, and that authority exists in Idaho law to support such an
approach.7 Micron supports Idaho Power’s reasonable transition away from coal-fired generation
and toward more sustainable generation options, and securitization can be a useful approach to
such a transition without unduly burdening customers. While securitization presents pros and cons
that must be weighed by the Commission, and Micron does not assert that it is necessarily the best
approach for Bridger, the Commission should at least require Idaho Power to analyze and present
all options before approving an accelerated depreciation rate increase.
II. Conclusion
Micron appreciates various initial comments presented by Commission Staff and the other
parties in this proceeding and the opportunity to provide these reply comments. Micron looks
forward to reviewing Idaho Power’s reply comments and continuing to engage with Idaho Power,
other stakeholders, and the Commission in this proceeding.

6 Comments of the Industrial Customers of Idaho Power (April 27, 2022), pp. 1-2.
7 See Id. at pp. 2-5; Joint Comments of Idaho Conservation League and Sierra Club (April 27, 2022), pp. 27-36.

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REPLY COMMENTS OF MICRON TECHNOLOGY, INC.
IPC-E-21-17

Respectfully submitted May 13, 2022.
HOLLAND & HART, LLP

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

Attorneys for Micron Technology, Inc.

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REPLY COMMENTS OF MICRON TECHNOLOGY, INC.
IPC-E-21-17
CERTIFICATE OF SERVICE
I hereby certify that on May 13, 2022, a true and correct copy of the within and foregoing REPLY
COMMENTS OF MICRON TECHNOLOGY, INC. was served in the manner shown to:

Electronic Mail

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

Matthew Larkin
Idaho Power Company
1221 W. Idaho Street (83702)
PO Box 70
Boise, ID 83707-0070
[e-mail]

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

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

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
6070 Hill Road
Boise, ID 83703
[e-mail]

Idaho Conservation League
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, ID 83702
[e-mail]

Sierra Club
Rose Monahan
Ana Boyd
Sierra Club
211 Webster St., Suite 1300
Oakland, CA 94612
[e-mail]
[e-mail]

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REPLY COMMENTS OF MICRON TECHNOLOGY, INC.
IPC-E-21-17
Clean Energy Opportunities for Idaho
Michael Heckler
Courtney White
3778 Plantation River Drive, Suite 102
Boise, ID 83703
[e-mail]
[e-mail]
Kelsey Jae
Law for Conscious Leadership
920 N. Clover Dr.
Boise, ID 83703
[e-mail]
City of Boise
Ed Jewell
Deputy City Attorney
Boise City Attorney’s Office
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
[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]
s/ Gina Gargano-Amari