HomeMy WebLinkAbout20220602Comments.pdfAustin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jense,n
HolLaNo & HnRtrrr
555 17th Street, Suite 3200
Denver, CO 80202
Telephone: (303) 295-8000
Email: darueschhoff@hollandhart.com
tnel son@hollandhart. com
awj ensen@hollandhan. com
' l'ri .,',; -f Plt ir: l0
Attorneys for Micron Technology, Inc.
BEFORE THE IDAIIO PTIBLIC UTILITIES COMI\{ISSION
IN TI{E MATTER OF IDAHO POWER
COMPANY' S 2O2I INTEGRATED
RESOURCE PLAN
CASE NO. IPC-E-21-43
MICRON TECHNOLOGY INC.'S
COMMENTS
Micron Technology, Inc. ("Micron"), pursuant to the Commission's Notice of Modified
Procedure dated March 10, 2022, provides the following comments regarding Idaho Power
Company's ("Idaho Power" or the "Company")2021Integrated Resource Plan ("IRP").
I. Introduction
Micron is Idaho Power's largest customer and relies on Idaho Power's provision ofreliable
electic service at just and reasonable rates in order to effectively operate its business and remain
competitive in the global marketplace. Therefore, Micron is keenly interested in all aspects of
Idaho Power's cost of service and service reliability, including ldaho Power's resource planning
processes. Indeed, Micron actively serves on Idaho Power's IRP Advisory Council where Micron
provides its perspective as a large customer on resource issues such as availability, reliability, cost,
and sustainability.
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MICRON TECHNOLOGY, INC.'S COMMENTS
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II. Micron's Comments regarding ldaho Power's Planned Resource Procurement.
While reliable service at reasonable rates is a critical component of Idaho Power's electric
service, Micron is also interested in the types of resources used to serve its electric load. Micron
supports Idaho Power's continued transition to clean energy, energy efficiency and demand
response programs as outlined in its IRP. Indeed, as Micron commented in Idaho Power's 2019
IRP proceeding, Micron has established its own sustainability goals, including aggressive efforts
to reduce emissions and power its operations with renewable energy. I In the 201 9 IRP proceeding
Micron also commented on its interest in partnering with Idaho Power on cost-competitive
renewable energy strategies that would allow both parties to meet clean energy goals.
Since the 2019 IRP, Micron and Idaho Power have successfully worked together to
advance their mutual goals culminating in a revised Micron Special Contract which contemplates
Idaho Power procuring a renewable resource on Micron's behalf to serve Micron's load.2 Micron
applauds Idaho Power's efforts to collaborate with Micron and other large customers to acquire
renewable resources and encourages Idaho Power to continue these efforts as the Company
transitions away from coal-fired generation. Specifically, Micron supports Idaho Power's
commitment in the 2021 IRP Action Plan to "work with large-load customers to support their
energy needs with solar resources."3 However, Micron cautions the Commission to ensure Idaho
Power plans future resource procurement with an eye toward other large loads that may transition
to customer-specific resources to ensure it does not procure excess resources.
I See Micron's 2021 Sustainability Report, available at https://media-www.micron.com/-
/media/client/slobal/documents/eeneraliabout/micron sustainabilitv-report-fy21-
fi nal.pdf.rla:en&rev:e794e4d2 f94 1 464f84e9290d5f9864c8.
2 See Case No.rcC-E-22-06.
3 2o2l RP, p.7.
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MICRON TECHNOLOGY, INC.'S COMMENTS
[PC-E-ZI-43
III. Idaho Power's Clean Energy Transition and Customer Rates.
While Micron supports Idaho Power's clean energy transition, Micron is also sensitive to
the rate impacts that can arise from early retirement of existing thermal generating units and
investment in new renewable resources and energy efficiency measures. Idaho Power must ensure
that its clean energy transition does not result in excessive rate impacts. Micron encourages Idaho
Power to continually investigate strategies to mitigate energy transition rate impacts and
implement such strategies where appropriate. For example, in Idaho Power's pending case
regarding the early retirement of the coal-fired Jim Bridger power plant and related depreciation
rates, Micron and other parties requested that Idaho Power investigate securitization of the
remaining plant balance to mitigate customer rate impacts.a Securitization can allow utilities to
pay retiring facilities' remaining plant balances at a lower interest rate, both reducing utility risk
and rate shock, resulting in a "win-win." While securitization and other rate mitigation strategies
may not be possible or appropriate in all circumstances, it is crucial that the Commission require
Idaho Power to include rate mitigation efforts in its resource plaruring to ensure a clean energy
transition that achieves sustainability goals at just and reasonable customer rates.
IV. Conclusion
Micron has long enjoyed a productive working relationship with Idaho Power and is
interested in the potential for further partnerships as both work toward meeting their respective
clean energy goals. Micron appreciates the opportunity to provide these comments and will
continue to engage with Idaho Power, the Commission, and other stakeholders in this and other
resource planning proceedings as its interests appeil.
4 SeeIP.C-E-21-17.
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MICRON TECHNOLOGY, [NC.'S COMMENTS
LPC-E-2I-43
Respectfrrlly submittd Jrme 2, 2A22.
HOLLAIID & HART, r.l,r
By:D O-^^L lLil,,l,l-
[ustin Rueschhofr, ISB No. l$gl
ThorvaldA.Nglson
AustinW. Je,nsen
555 lTth Sfreet, Suite 3200
Denver, CO 80202
Telephone (303) 295-8000
Email: darueschhoff@hollandhart.com
trelson@oollandbartcom
awjensen@hollandhart com
Attorneys for Micron Technology, Inc.
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MICRON TECHNOLOGY, INC.'S COMMENTS
rPc-E-zt43
CERTIFICATE OF SERVICE
I hereby certiff that on June 2, 2022 a true and correct copy of the within and foregoing
MICRON TECHNOLOGY INC.'s COMMENTS was served in the manner shown to:
Electronic Mail
Idaho Power Company
Lisa D. Nordstrom
Idaho Power Company
I22I W. Idaho Street (83702)
PO Box 70
Boise,ID 83707-0070
lnordstrom@ idahopower. com
dockets@ idahopower. com
Commission Staff
JanNoriyuki
Commission Secretary
Dayn Hardie
Deputy Attorney General
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A
Boise,lD 83714
Jan.noriyuki@puc. idaho. gov
secretary@puc. idaho. eov
dayn.hardie@ouc. idaho. eov
Industrial Customers of ldaho Power
Peter J. Richardson
Richardson Adams, PLLC
515 N. 27th Street
P.O. Box 7218
Boise, D 83702
oeter@richardsonadams. com
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MICRON TECHNOLOGY, [NC.'S COMMENTS
[PC-E-zI-43
Timothy E. Tatum
Alison Williams
Idaho Power Company
l22l West Idaho Street (83702\
P.O. Box 70
Boise,Idaho 83707
Telephone: (208) 388-55 l5
Facsimile: (208) 388-6449
ttatum@idahopower.com
awilliams@idahopower. com
Idaho Conservation League
Benjamin J. Otto
Emma E. Sperry
710 N. 6th Sneet
Boise, lD 83702
botto@ idahoconservation. ore
esperry@idahoconservation. ore
Dr. Don Reading
6070 Hill Road
Boise,ID 83703
dreading@mindsprins. com
Micron Technologt, Inc.
Jim Swier
Micron Technology, Inc.
8000 South Federal Way
Boise,ID 83707
jswier@micron.com
Clean Energt Opportunities for ldaho
Courtney White
Mike Heckler
3TTSPlantation River Drive, Suite 102
Boise,ID 83703
courhrey@ cl eanenere.vopportunities. com
mike@ cleane,nere.vopportunities. com
Stop B2H Coalition
Jim Kreider
60366 Marvin Road
LaGrande, OR 97850
iim@stopb2h.org
Kiki Leslie A. Tidwell
704 N. River Sfteet, #1
Hailey,ID 83333
Ktidwell2022@ email.com
Austin Rueschhoff
Thorvald A. Nelson
Austin W. Jensen
Holland & Hart, LLP
555 lTth Street, Suite 3200
Denver, CO 80202
darueschho ff@ hollandhart. com
trelson@hollandhart.com
awj ensen@hollandhart. com
aclee@hollandhart.com
gl garganoamari@hollandhart. com
Kelsey Jae
Law for Conscious Leadership
920 No. Clover Drive
Boise,ID 83703
kelsey@kelsevjae.com
Jack Van Valkenburgh
Van Valkenburgh Law, PLLC
P.O. Box 531
Boise,ID 83701
i ack@ vanvalkenburehlaw. com
s/ Gina Garsano-Amari
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MICRON TECHNOLOGY, INC.'S COMMENTS
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