20240215Comments.pdf

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MICRON TECHNOLOGY, INC.’S COMMENTS
IPC-E-23-23
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
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 2023 INTEGRATED
RESOURCE PLAN

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CASE NO. IPC-E-23-23

COMMENTS
OF MICRON TECHNOLOGY, INC.

Micron Technology, Inc. (“Micron”), pursuant to the Commission’s Notice of Modified
Procedure dated December 15, 2023, provides the following comments regarding Idaho Power
Company’s (“Idaho Power” or the “Company”) 2023 Integrated Resource Plan (“IRP”).
I. Introduction

Micron is Idaho Power’s largest customer and is in the process of significantly expanding
its Idaho investment, operations, and electric load.1 Therefore, Micron relies on Idaho Power’s
provision of reliable electric service at just and reasonable rates in order to effectively operate its
business and remain competitive in the global marketplace. Micron is an Idaho Power Special
Contract customer and recently amended its Special Contract to incorporate Micron’s investment

1See Micron Press Release “Micron Breaks Ground on Leading-Edge Manufacturing Fab in Boise, Idaho”
(September 12, 2022). Available at https://investors.micron.com/news-releases/news-release-
details/micron-breaks-ground-leading-edge-manufacturing-fab-boise-idaho.
RECEIVED
Thursday February 15, 2024 3:21PM
IDAHO PUBLIC
UTILITIES COMMISSION

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MICRON TECHNOLOGY, INC.’S COMMENTS
IPC-E-23-23
in the Black Mesa Solar project through Idaho Power’s Clean Energy Your Way program. Micron
is keenly interested in all aspects of Idaho Power’s cost of service and service reliability, including
Idaho 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. Micron submits these comments to assist
the Commission consider Idaho Power’s IRP from the prospective of an Idaho Power large
customer.
II. Micron’s Sustainability and Clean Energy Goals

Micron applauds Idaho Power’s efforts presented in the IRP to meet its 100% clean energy
by 2045 goal. Idaho Power’s IRP is marked by significant investment in new renewable resources,
energy efficiency, generating facility conversions from coal to natural gas, and new transmission
investment to facilitate efficient use of renewable generation resources. 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. Sustainability and environmental efforts
are cornerstones of Micron’s business operations and Micron is working toward its own ambitious
greenhouse gas emission and renewable energy goals.2
In past Idaho Power IRP proceedings Micron has commented on its interest in partnering
with Idaho Power on cost-competitive renewable energy strategies that would assist both parties
to meet clean energy goals. In 2023, Micron and Idaho Power finalized its amended Special
Contract incorporating the Black Mesa solar project procured by Idaho Power on Micron’s behalf

2 See Micron’s 2023 Sustainability Report, available at https://media-www.micron.com/-
/media/client/global/documents/general/about/2023/2023_micron_sustainability_report.pdf?la=en&rev=3
65ecf23d3324430a3eb117e9fb3ffa1.

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MICRON TECHNOLOGY, INC.’S COMMENTS
IPC-E-23-23
as part of the Idaho Power Clean Energy Your Way program. The Black Mesa project entered
commercial operation in June 2023 and currently serves portions of Micron’s load. The amended
Special Contract also provides flexibility for Idaho Power and Micron to work together to
potentially develop additional renewable resources in the future to serve Micron’s growing load.
Additionally, in 2023 Micron worked collaboratively with the City of Boise to transfer some of
the Black Mesa renewable generation to the City to help meet its sustainability goals. The details
of that arrangement are being finalized and will be presented for Commission approval when
appropriate.
Micron is proud to have worked with Idaho Power and the City of Boise on these mutually
beneficial renewable energy arrangements. Idaho Power’s IRP demonstrates it will need to add
substantial resources to its generation portfolio in the coming years. Micron encourages Idaho
Power to continue working with Micron and other large customers to develop large-scale
customer-dedicated generation resources that meet Idaho Power’s and large customers’ mutual
sustainability goals.
III. Idaho Power’s Resource Needs and Customer Rates
While Micron supports Idaho Power’s clean energy transition and investment in renewable
generation to meet growing loads, Micron is also sensitive to the rate impacts that can arise from
investment in new resources and conversion or early retirement of existing thermal generating
units. Idaho Power’s IRP calls for significant capital investment in both generation and
transmission resources. Idaho Power must ensure that its clean energy transition does not result
in excessive rate impacts that harm businesses working to remain cost-competitive in the national
and global marketplace. Micron encourages Idaho Power to continually investigate strategies to
mitigate energy transition rate impacts and implement such strategies where appropriate. For

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MICRON TECHNOLOGY, INC.’S COMMENTS
IPC-E-23-23
example, Micron encourages Idaho Power to continue to conduct robust competitive solicitation
processes when acquiring new resources to ensure new investments are least-cost and least-risk
and to consider rate mitigation strategies such as securitization if Idaho Power retires thermal
generation plants early.
IV. Western Energy Markets and Regional Coordination
Idaho Power currently participates in the Western Energy Imbalance Market (“EIM”) and
the Western Power Pool (“WPP”) Western Resource Adequacy Program (“WRAP”). The EIM
allows participants to buy and sell power close to the time electricity is consumed and gives electric
system operators real-time visibility across neighboring grids, resulting in improved balancing of
electric supply and demand across the region, often resulting in lower costs. WRAP is a regional
planning and capacity program that allows utility participants to share available resources if a
participant experiences a short-term period of resource deficiency, thereby potentially reducing a
participants’ own capacity needs. Indeed, the IRP shows Idaho Power including 14 MW of
capacity associated with WRAP in its resource portfolio beginning in 2027. A recent WPP
assessment demonstrated the value of WRAP to support participant service reliability during the
January 2024 Northwest cold weather event, reinforcing the importance of Idaho Power’s
participation in the WRAP to provide customers with reliable power.3
In the IRP, Idaho Power acknowledges the importance of markets and identifies market
access as a “major qualitative risk” in its modeling analysis, stating that:
[w]ith many utilities including Idaho Power relying more on resources like wind
and solar, the ability to access markets like the EIM becomes increasingly
important. Lack of market access can cause considerable wholesale price

3 See https://www.westernpowerpool.org/private-
media/documents/WPP_Assessment_of_January_2024_Cold_Weather_Event_Final.pdf.

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MICRON TECHNOLOGY, INC.’S COMMENTS
IPC-E-23-23
fluctuations and high costs as well as present reliability concerns during times of
need.”4

Micron supports Idaho Power’ participation in the EIM to capture market efficiencies and deliver
electricity to Idaho Power customers at lower costs. Micron is also aware that many western
utilities, utility regulators, and other interested stakeholders are investigating new or expanded
regional markets in the west, including the California ISO Extended Day Ahead Market
(“EDAM”),5 the Southwest Power Pool Markets+,6 and the West-Wide Governance Pathways
Initiative.7 Micron understands that the western market landscape is evolving and that
participation in regional markets requires careful analysis of the potential pros and cons. However,
Micron encourages Idaho Power to continually investigate and analyze regional markets and
coordination efforts and seek opportunities to participate in such programs that will result in
increased reliability and lower costs to customers.
V. 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 appear.

4 IRP, p. 141.
5 See EDAM Fact Sheet available at https://www.caiso.com/Documents/extended-day-ahead-market-
edam-fact-sheet.pdf.
6 See https://www.spp.org/western-services/marketsplus/.
7 See https://www.westernenergyboard.org/wwgpi/.

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MICRON TECHNOLOGY, INC.’S COMMENTS
IPC-E-23-23
Respectfully submitted February 15, 2024.
HOLLAND & HART, LLP

By:
Austin Rueschhoff, ISB No. 10592
Thorvald A. Nelson
Austin W. Jensen, ISB No. 11947
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.’S COMMENTS
IPC-E-23-23
CERTIFICATE OF SERVICE
I hereby certify that on February 15, 2024, a true and correct copy of the within and
foregoing COMMENTS OF MICRON TECHNOLOGY, INC. IN CASE NO. IPC-E-23-23 was
served in the manner shown to:

Electronic Mail

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

Timothy E. Tatum
Alison Williams
Idaho Power Company
1221 West Idaho Street (83702)
P.O. Box 70
Boise, Idaho 83707
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

Commission Staff
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]

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]

s/ Adele Lee