20211116Final Comments.pdf

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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
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 TO INITIATE
A MULTI-PHASE COLLABORATIVE
PROCESS FOR THE STUDY OF COSTS,
BENEFITS, AND COMPENSATION OF NET
EXCESS ENERGY ASSOCIATED WITH
CUSTOMER ON-SITE GENERATION
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CASE NO. IPC-E-21-21
MICRON TECHNOLOGY, INC.’S
FINAL COMMENTS
Micron Technology, Inc. (“Micron” or “Intervenor”), pursuant to the Commission’s Notice
issued October 7, 2021, submits its Final Comments regarding the proposed Study Framework
Idaho Power will utilize to comprehensively evaluate the cost and benefits of on-site generation.
Micron’s comments focus on the “Cost-of-Service & Rate Design” section of the proposed Study
Framework. Micron encourages the Commission to approve a Study Framework that includes the
important issues described in that section.
Cost-of-Service & Rate Design
Micron is an Idaho Power Special Contract customer and is Idaho Power’s single largest
customer. Micron is supportive of Idaho Power’s net metering offerings and recognizes that, when
implemented properly, net metering programs can provide benefits to customer-generators, Idaho
RECEIVED
2021 NOV 16 PM 4:00
IDAHO PUBLIC
UTILITIES COMMISSION

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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
Power, and all Idaho Power customers. However, as a large electricity consumer, Micron is also
particularly susceptible to cross-subsidies between customer-generators and customers who have
not installed on-site generation and do not take advantage of net metering programs. Micron is
interested in participating in this and other Idaho Power net metering proceedings to ensure that
net metering programs are just and reasonable for all Idaho Power customers and that
compensation paid to customer-generators does not create inappropriate cost shifts to non-
customer-generators. It is not Micron’s intention in this proceeding to allege or assert that such
cost shifts currently exist. Rather, Micron believes that this proceeding presents an opportunity to
further investigate the issue.
To that end, Micron proposed, and Commission Staff incorporated, the following section
to the Study Framework under the “Cost-of-Service & Rate Design” section:
14. Evaluate how various cost of service methodologies and potential rate designs
impact non-customer-generators in each rate class (including Special Contract
customers) including the potential for cross-subsidies between customer-generators
and non-customer-generators.

Micron believes that incorporating this language into the Study Framework is crucial to ensure
that Idaho Power, the Commission, and all interested stakeholders have the necessary information
to consider and propose potential changes to Idaho Power’s net metering compensation rates and
methodology. Indeed, Idaho Power’s Application in this proceeding states:
Ultimately, the Company anticipates proposals to implement changes to the on-site
generation offering will be informed by the studies and should seek to eliminate or
minimize potential cross-subsidies that exist between participants and non-
participants of on-site generation through rate design and compensation structures
for on-site generation customers.1

1 Application, p. 6

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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
However, at this point Micron is unaware of data that would indicate if and to what extent subsidies
currently exist in Idaho Power’s net metering programs and how to best address such subsidies if
they do exist. Micron has reviewed Staff and Idaho Power’s Initial Comments filed in this
proceeding and is encouraged that both parties seem to share Micron’s view that cost-of-service,
rate design, and potential subsidies are important items to include in the Study Framework.2
However, Micron is concerned that some parties’ comments support excluding cost-of-
service, rate design, and potential subsidy issues from the Study Framework. For example, Clean
Energy Opportunities states that “any additional attempt to calculate intra or inter class subsidies
caused by some customers reducing their purchases from the Company via self-generation should
not be reviewed outside of a comprehensive rate case.”3 Additionally, Idaho Clean Energy
Association states that “in terms of minimizing subsidies across classes, this study is not the place
to presume that reducing one’s usage via on-site generation creates ‘subsidies’ any different than
other customers who reduce their usage.”4 Finally, the Idaho Conversation League states that
Idaho Power’s Application “continues the long trend of making unsubstantiated assertions about
subsidization, cost shifts, and customer-generators not paying their fair share.”5
It is clear by these comments that there is considerable disagreement and a lack of
information regarding whether and to what extent subsidies result from Idaho Power’s current net
metering policies. This disagreement and lack of information underscores the need to include
these issues in the Study Framework and should not serve as a basis to exclude them from the
Study Framework. Indeed, the Commission has ordered Idaho Power to:

2 See Commission Staff’s October 13 Comments p. 13-14; Idaho Power’s Initial Comments, p. 11.
3 Initial Comments of Clean Energy Opportunities, p. 4.
4 Idaho Clean Energy Association Initial Comments on Study Framework, p. 1.
5 Idaho Conservation League Initial Comments on Study Framework, p. 4.

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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
Initiate a docket to comprehensively study the costs and benefits of on-site
generation on Idaho Power’s system, as well as proper rates and rate design,
transitional rates, and related issues of compensation for net excess energy provided
as resource to the Company.6

Idaho Power has committed in this proceeding to undertake a comprehensive multi-year study
process with robust input from the public and interested stakeholders, after which all parties will
have access to in-depth data. This data will be invaluable in proposing and debating modifications
to Idaho Power’s net metering offerings. Limiting the scope of the comprehensive study would
be a missed opportunity that would ultimately hinder Idaho Power’s, the Commission’s, and the
parties’ ability to make constructive changes to its net metering programs that are grounded in
accurate data and are in the public interest.
It is of the utmost importance to ensure that Idaho Power’s comprehensive study produces
the data necessary to inform future changes to its net metering programs and to have confidence
that such programs result in just and reasonable rates for all customers whether they install on-site
generation or not. Therefore, Micron encourages the Commission to include cost-of-service and
rate design issues in the study framework, including Micron’s proposed study framework item
number fourteen regarding potential subsidies.

6 IPC-E-17-13, Order No. 34046, p. 31.

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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
Respectfully submitted November 16, 2021.

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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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
CERTIFICATE OF SERVICE
I hereby certify that on November 16, 2021, a true and correct copy of the within and
foregoing MICRON TECHNOLOGY, INC.’s FINAL COMMENTS 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]

Connie Aschenbrenner
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]

Idaho Clean Energy Association
Kevin King
P.O. Box 2264
Boise, ID 83702
[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]

Idaho Hydroelectric Power Producers Trust
Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 450
P.O. Box 2900
Boise, ID 83701
[e-mail]
[e-mail]
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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
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]
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 Drive
Boise, ID 83703
[e-mail]
Idaho Solar Owners Network
Joshua Hill
Idaho Solar Owners Network
1625 S. Latah
Boise, ID 83705
[e-mail]
[e-mail]
Idaho Irrigation Pumpers Association, Inc.
Eric L. Olson
Echo Hawk & Olson, PLLC
505 Pershing Avenue, Suite 100
P.O. Box 6119
Pocatello, ID 83205
[e-mail]
Boise City
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]
Kiki Tidwell
Kiki Leslie A. Tidwell, pro se
704 N. River Street #1
Hailey, ID 83333
[e-mail]
ABC Power Co. LLC
Ryan Bushland
184 W. Chrisfield Drive
Meridian, ID 83646
[e-mail]
Comet Energy LLC
George Stanton
13601 W. McMillan Road, Suite 102
Boise, ID 83713
[e-mail]
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MICRON TECHNOLOGY, INC. FINAL COMMENTS
IPC-E-21-21
Richard E. Kluckhohn
Wesley A. Kluckhohn
2564 W. Parkstone Drive
Meridian, ID 83646
[e-mail]
Idahome Solar, LLC
Tyler Grange
2484 Stokesberry Place, #100
Meridian, ID 83646
[e-mail]
s/ Gina Gargano-Amari