20240412Petition to Intervene.pdf

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Thursday,Apri111,20241a4258 AM
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Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center St.
Pocatello, Idaho 83204-1391
[phone]
[e-mail]
Attorneys for P4 Production, L.L.C., an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO. PAC-E-24-05
OF ROCKY MOUNTAIN POWER
REQUESTING APPROVAL OF $62.4 BAYER PETITION FOR
MILLION ECAM DEFERRAL LEAVE TO INTERVENE
P4 Production, L.L.C., an affiliate of Bayer Corporation(referred to herein as "Bayer"),
hereby petitions the Idaho Public Utilities Commission for leave to intervene in this matter
pursuant to Rules 71 and 72 of the Rules of Procedure of the Commission. In support of this
petition, Bayer states as follows:
1. The name and address of Bayer is:
Mike Veile
P4 Production, L.L.C.
P.O. Box 816
Soda Springs, Idaho 83276
E-mail: [e-mail]
2. Bayer will be represented by:
Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
E-mail: [e-mail]
3. All pleadings and other documents should be served upon:
Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
E-mail: [e-mail]
BAYER PETITION FOR LEAVE TO INTERVENE 1

Brian C. Collins
Greg Meyer
Brubaker&Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-mail: [e-mail]
[e-mail]
4. Bayer has a direct and substantial interest in this proceeding and intends to
participate in all respects as a party to represent its interests.
5. Without the opportunity to intervene, Bayer would be without a manner or means of
participating in the lawful determination of issues which will affect its rates for electric service.
Therefore, Bayer respectfully requests that the Commission grant this petition for leave to
intervene and allow Bayer to appear and participate in all matters as may be necessary and
appropriate; to present evidence, call and examine witnesses, cross-examine witnesses, and
present argument; and to otherwise fully participate in this proceeding.
DATED this 1 lth day of April, 2024.
RACINE OLSON, PLLP
By: -3p:
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1 lth day of April, 2024, 1 served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Idaho Public Utilities Commission
Commission Secretary
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
PacifiCorp
Data Request Response Center
[e-mail]
Mark Alder
Idaho Regulatory Affairs Manager
[e-mail]
Joe Dallas
Senior Attorney
Rocky Mountain Power
[e-mail]
Idaho Irrigation Pumpers Association
Eric L. Olsen
ECHO HAWK& OLSEN, PLLC
[e-mail]
Lance Kaufman, Ph.D.
[e-mail]
PIIC
Ronald L. Williams
Williams Bradbury, P.C.
[e-mail]
PIIC Electronic Service Only:
Val Steiner: [e-mail]
Kyle Williams: [e-mail]
Adam Gardner: [e-mail]
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 3