20231115Direct Jessica York in Support of Stipulation and Settlement.pdf

BEFORE THE

IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR ELECTRIC SERVICE
IN THE STATE OF IDAHO AND FOR
ASSOCIATED REGULATORY ACCOUNT
TREATMENT
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CASE NO. IPC-E-23-11

Testimony in Support of Settlement Stipulation

Jessica A. York

On behalf of

Micron Technology, Inc.

November 15, 2023

RECEIVED
Wednesday, November 15, 2023 3:23:37 PM
IDAHO PUBLIC
UTILITIES COMMISSION

York, Di 1
Micron Technology, Inc.
Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 1
A Jessica A. York. My business address is 16690 Swingley Ridge Road, 2
Suite 140, Chesterfield, Missouri 63017. 3

Q WHAT IS YOUR OCCUPATION? 4
A I am a consultant in the field of public utility regulation and an Associate with the 5
firm of Brubaker & Associates, Inc. (“BAI”), energy, economic and regulatory 6
consultants. 7

Q PLEASE DESCRIBE YOUR EDUCATIONAL BACKGROUND AND 8
EXPERIENCE. 9
A This information is included in Appendix A to my testimony. 10

Q ON WHOSE BEHALF ARE YOU APPEARING IN THIS PROCEEDING? 11
A I am appearing on behalf of Micron Technology, Inc. (“Micron”). 12

Q WHAT IS THE PURPOSE OF YOUR TESTIMONY IN THIS PROCEEDING? 13
A The purpose of my testimony is to support the unanimous Stipulation and 14
Settlement (“Stipulation”) filed by Idaho Power Company (“IPC” or “Company”) 15
and the other parties to this proceeding on October 27, 2023. The Stipulation 16
resolves all revenue requirement, class cost of service, and rate design issues in 17
this proceeding. 18

Q DO YOU RECOMMEND APPROVAL OF THE STIPULATION? 19
A Yes. I recommend approval of the Stipulation. The Stipulation is a 20
comprehensive agreement that represents give and take among the parties and 21

York, Di 2
Micron Technology, Inc.
resolves the revenue requirement, cost allocation, and rate design issues that 1
would have likely been raised by the parties in this proceeding. The Stipulation is 2
a result of extensive arms-length negotiations between the settling parties in 3
order to reach a comprehensive settlement. Notably, the Stipulation is within the 4
range of outcomes that would have resulted from a litigated case. 5
In sum, the Stipulation should be approved for the following reasons: 6
1. The stipulated overall revenue requirement will result in an overall level of 7
revenues for IPC that is just and reasonable and will allow the utility a 8
reasonable opportunity to earn a fair return on its investments. The revenue 9
requirement adjustments contained in the Stipulation represent a compromise 10
on the issues that would have been contested in this case. 11
2. The stipulated revenue allocation reflects a compromise between the parties 12
to resolve the issues that would have been contested in this case and is 13
reasonably based on cost of service principles. The compromise revenue 14
allocation in the Stipulation is within the range of what would have likely been 15
the parties’ litigated positions in this case. 16
3. The stipulated rate design for the various customer rates is fair, reasonable, 17
and in the public interest. 18
4. The Stipulation is likely to reduce the Commission’s administrative burden 19
and save rate case expenses for all parties. 20

Q PLEASE DESCRIBE THE STIPULATION’S RESOLUTION OF THE 21
COMPANY’S REVENUE REQUIREMENT IN THIS PROCEEDING. 22
A The Stipulation resolves the revenue requirement issues that would have been 23
raised by parties in this rate case. 24
The Company’s original filing in this docket proposed to increase base 25
rate revenues by $111 million, or a system average increase of 8.61 percent. 26
Under the Stipulation, the increase in total revenue was reduced to $54.7 million, 27
or a system average increase of 4.25 percent. 28
The Stipulation reflects several adjustments to the Company’s originally 29
filed revenue requirement, which are summarized in the table on page 4 of the 30

York, Di 3
Micron Technology, Inc.
Stipulation. The Commission Staff (“Staff”) and intervenors, including Micron, 1
provided a thorough and detailed assessment of the Company’s cost of service 2
in these negotiations. Staff’s and the other intervenors’ review and input was 3
very useful in identifying and reaching an agreement on the revenue requirement 4
adjustments included in the Stipulation. 5

Q DID MICRON HAVE CONCERNS ABOUT ANY SPECIFIC COMPONENTS OF 6
THE COMPANY’S PROPOSED REVENUE REQUIREMENT? 7
A Yes. Micron had several concerns with IPC’s originally proposed revenue 8
requirement, which are resolved by the compromise represented in the 9
Stipulation. First, Micron was concerned that the Company’s proposed Return 10
on Equity (“ROE”) of 10.4 percent was excessive based on current market 11
conditions. Micron conducted an independent analysis of IPC’s proposed ROE 12
and concluded that we would, in the context of a litigated case, advocate for an 13
ROE in the range of 9.0 percent. The Stipulation provides for a reasonable 14
compromise between these positions and recommends the Commission approve 15
a 9.6 percent ROE. 16
In addition, Micron had several other concerns with the Company’s 17
proposed revenue requirement including the use of end-of-period rate base 18
instead of average rate base; the inclusion of 2024 salary increases, which were 19
outside the test year; an excessive projection of uncollectibles’ expense relative 20
to the three-year average of 2019, 2021, and 2022;1 the inclusion of incentive 21
compensation tied to financial performance, which benefits shareholders rather 22
than ratepayers; and a potentially understated residential sales forecast. In total, 23

1 2020 was excluded due to the COVID-19 pandemic, which contributed to an abnormally high
level of uncollectibles.

York, Di 4
Micron Technology, Inc.
Micron estimated that its adjustments related to these issues would have 1
reduced the Company’s claimed revenue deficiency by approximately 2
$45 million. The adjustments are, in many instances, incremental to other 3
adjustments that Micron understands that the Staff and other intervenors would 4
have raised. The Stipulation addresses several of Micron’s various revenue 5
requirement adjustments and reflects a reasonable compromise of the various 6
issues presented in this proceeding and the parties’ positions in those issues. 7

Q DID THE SETTLING PARTIES REACH AN AGREEMENT ON THE REVENUE 8
ALLOCATION? 9
A Yes. Stipulation Exhibit No. 1 provides the parties’ agreement regarding revenue 10
allocation. Stipulation Exhibit No. 2 identifies the settlement rates agreed to by 11
all settling parties. 12
As particularly applicable to Micron, the Stipulation provides for an 13
increase of approximately 3.65 percent for Micron’s Special Contract Rate 14
Schedule 26. This outcome is consistent with IPC’s cost of service study, which 15
concluded that Micron warranted a cost-based rate increase less than the system 16
average rate increase. In addition, Micron is satisfied with the rate design for 17
Rate Schedule 26, as it generally reflects cost-based rates based on its preferred 18
class cost of service study methodology. 19
With regard to the other customer classes, Micron analyzed IPC’s class 20
cost of service study and finds the revenue allocation reasonable based on the 21
class cost of service study proposed by IPC, including any adjustments to that 22
study that Micron would have proposed had this case been fully litigated. 23

York, Di 5
Micron Technology, Inc.
Q DID THE SETTLING PARTIES AGREE UPON A PARTICULAR COST OF 1
SERVICE STUDY? 2
A No. The parties did not agree on any particular class cost of service 3
methodology. Instead, the settling parties negotiated a modified revenue 4
allocation to adjust rates and charges for each customer class. 5

Q IN YOUR OPINION, IS THE STIPULATION REASONABLE AND IN THE 6
PUBLIC INTEREST? 7
A Yes. The settling parties compromised on their various positions in order to 8
reach a Stipulation that economically and efficiently resolves what would have 9
been contested issues in this case. The Stipulation provides the Company with 10
updated rates to better reflect current costs and the ability to economically 11
finance new investments in infrastructure while maintaining just and reasonable 12
rates for its customers.2 Furthermore, approving the Stipulation will result in 13
efficiencies for the Commission, Staff, and parties, and reduced rate case 14
expenses to the benefit of all IPC customers. 15

Q DOES THIS CONCLUDE YOUR TESTIMONY IN SUPPORT OF THE 16
SETTLEMENT STIPULATION? 17
A Yes, it does. 18

2 Settlement Testimony of Timothy Tatum at page 2, ll. 7-17.

Appendix A
York, Di 6
Micron Technology, Inc.
Appendix A - Qualifications of Jessica A. York

Q PLEASE STATE YOUR NAME AND BUSINESS ADDRESS. 1
A Jessica York. My business address is 16690 Swingley Ridge Road, Suite 140, 2
Chesterfield, Missouri 63017. 3

Q PLEASE STATE YOUR OCCUPATION. 4
A I am a consultant in the field of public utility regulation and an Associate with the firm 5
of Brubaker & Associates, Inc. (“BAI”), energy, economic and regulatory consultants. 6

Q PLEASE IDENTIFY THE JURISDICTIONS IN WHICH YOU HAVE PREVIOUSLY 7
SPONSORED TESTIMONY. 8
A I have sponsored expert testimony in front of the Idaho Public Utilities Commission, 9
the Illinois Commerce Commission, Indiana Utility Regulatory Commission, the 10
Kansas Corporation Commission, the Michigan Public Service Commission, the 11
Minnesota Public Utilities Commission, the Missouri Public Service Commission, the 12
Public Utilities Commission of Nevada, the Oklahoma Corporation Commission, and 13
the Public Service Commission of Wisconsin. 14

Q PLEASE STATE YOUR EDUCATIONAL BACKGROUND AND PROFESSIONAL 15
EMPLOYMENT EXPERIENCE. 16
A I graduated from Truman State University in 2008 where I received my Bachelor of 17
Science Degree in Mathematics with minors in Statistics and Actuarial Science. I 18
earned my Master of Business Administration Degree with a concentration in Finance 19
from the University of Missouri-St. Louis in 2014. 20

Appendix A
York, Di 7
Micron Technology, Inc.
I joined BAI in 2011 as an analyst. Then, in March 2015, I joined the 1
consulting team of BAI. 2
I have worked in various electric, natural gas and water and wastewater 3
regulatory proceedings addressing cost of capital, sales revenue forecasts, revenue 4
requirement assessments, class cost of service studies, rate design, and various 5
policy issues. I have also conducted competitive power and natural gas solicitations 6
on behalf of large electric and natural gas users, have assisted those large power and 7
natural gas users in developing procurement plans and strategies, assisted in 8
competitive contract negotiations, and power and natural gas contract supply 9
administration. In the regulated arena, I have evaluated cost of service studies and 10
rate designs proffered by other parties in cases for various utilities, including in Idaho, 11
Illinois, Indiana, Kansas, Wisconsin, and others. I have conducted bill audits, rate 12
forecasts and tariff rate optimization studies. 13
I have also provided support to clients with facilities in deregulated markets, 14
including drafting supply requests for proposals, evaluating supply bids, and auditing 15
competitive supply bills. I have also prepared and presented to clients reports that 16
monitor the electric market and recommend strategic hedging transactions. 17
BAI was formed in April 1995. BAI and its predecessor firm have participated 18
in more than 700 regulatory proceedings in forty states and Canada. 19
BAI provides consulting services in the economic, technical, accounting, and 20
financial aspects of public utility rates and in the acquisition of utility and energy 21
services through RFPs and negotiations, in both regulated and unregulated markets. 22
Our clients include large industrial and institutional customers, some utilities and, on 23
occasion, state regulatory agencies. We also prepare special studies and reports, 24
forecasts, surveys and siting studies, and present seminars on utility-related issues. 25

Appendix A
York, Di 8
Micron Technology, Inc.
In general, we are engaged in energy and regulatory consulting, economic 1
analysis and contract negotiation. 2
In addition to our main office in St. Louis, the firm also has branch offices in 3
Corpus Christi, Texas; Detroit, Michigan; Louisville, Kentucky and Phoenix, Arizona 4

30881116_v3
DECLARATION OF JESSICA A. YORK 1
I, Jessica A. York, declare under penalty of perjury under the laws of the state of 2
Idaho: 3
1.My name is Jessica A. York. I am employed by Brubaker &4
Associates, Inc. (“BAI”) as an Associate and consultant in the field of public utility 5
regulation. 6
2.On behalf of Micron Technology, Inc., I present this pre-filed7
testimony in support of the settlement stipulation in this matter. 8
3.To the best of my knowledge, my pre-filed testimony in support of9
the settlement stipulation is true and accurate. 10
I hereby declare that the above statement is true to the best of my knowledge 11
and belief, and that I understand it is made for use as evidence before the Idaho 12
Public Utilities Commission and is subject to penalty for perjury. 13
SIGNED this 14th day of November 2023, at Chesterfield, Missouri. 14
Signed: 15
16
17
30897075_v1
Declaration York, Di 9
Micron Technology, Inc.

CERTIFICATE OF SERVICE
I hereby certify that on November 15, 2023, a true and correct copy of the within and
foregoing TESTIMONY IN SUPPORT OF SETTLEMENT STIPULATION OF JESSICA A.
YORK ON BEHALF OF MICRON TECHNOLOGY, INC. was served in the manner shown to:

Electronic Mail

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

Timothy E. Tatum
Connie Aschenbrenner
Matt Larkin
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
Dayn Hardie
Chris Burdin
Jan Noriyuki
Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Building 8,
Suite 201-A
Boise, ID 83714
[e-mail]
[e-mail]
[e-mail]
[e-mail]

Idaho Conservation League
Matthew Nykiel
Brad Heusinkveld
710 N. 6th Street
Boise, ID 83702
[e-mail]
[e-mail]

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

2
Idaho Irrigation Pumpers Association, Inc.
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.
2623 NW Bluebell Place
Corvallis, OR 97330
[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
280 Silverwood Way
Eagle, ID 83616
[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]

City of Boise City
Ed Jewell
Darrell Early
Wil Gehl
150 N. Capitol Blvd.
P.O. Box 500
Boise, ID 83701-0500
[e-mail]
[e-mail]
[e-mail]
[e-mail]

NW Energy Coalition
F. Diego Rivas
Benjamin J. Otto
1101 8th Avenue
Helena, MT 59601
[e-mail]
[e-mail]

3
Federal Executive Agencies
Peter Meier
Paige Anderson
Tanner Crowther
U.S. Department of Energy
1000 Independence Ave., S.W.
Washington, D.C. 20585
[e-mail]
[e-mail]
[e-mail]

Dwight Etheridge
Exeter Associates
5565 Sterrett Place, Suite 310
Columbia, MD 21044
[e-mail]

Walmart
Norman M. Semanko
Justina A. Caviglia
Parsons Behle & Latimer
800 West Mian Street, Suite 1300
Boise, ID 83702
[e-mail]
[e-mail]

Steve W. Chriss
Walmart Inc.
2608 Southeast J Street
Bentonville, AR 72716
[e-mail]
IdaHydro
Tom Arkoosh
Arkoosh Law Offices
913 W. River Street, Suite 420
P.O. Box 83701
[e-mail]
[e-mail]

s/ Chelsey Moser
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