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Home My WebLink About20220602Comments.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. 1 MICRON TECHNOLOGY, INC.'S COMMENTS rPc-E-2t-43 ) ) ) ) ) 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. 2 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. 3 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. 4 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 5 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 6 MICRON TECHNOLOGY, INC.'S COMMENTS IPC-E-zt-43