20240613Petition to Intervene.pdf

RECEIVED
Thursday, June 13, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
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
OF ROCKY MOUNTAIN POWER FOR CASE NO. PAC-E-24-04
AUTHORITY TO INCREASE ITS RATES
AND CHARGES IN IDAHO AND BAYER PETITION FOR
APPROVAL OF PROPOSED ELECTRIC LEAVE TO INTERVENE
SERVICE SCHEDULES AND
REGULATIONS
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
BAYER PETITION FOR LEAVE TO INTERVENE I

Pocatello, Idaho 83204-1391
E-mail: [e-mail]
Brian C. Collins
Greg Meyer
Brubaker&Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-mail: [e-mail]
[e-mail]
Kevin Higgins
Neal Townsend
Energy Strategies LLC
I I I East Broadway, Suite 1200
Salt Lake City, UT, 84111
Email: [e-mail]
[e-mail]
4. Bayer has a direct and substantial interest in this proceeding and intends to
participate in all respects as a parry 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 131h day of June, 2024.
RACINE OLSON, PLLP
----------------
By:
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 131h day of June, 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 Kaufinan, Ph.D.
[e-mail]
PIIC
Ronald L. Williams
HAWLEY TROAELL
[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