20250929Petition to Intervene.pdf

RECEIVED
SEPTEMBER 29, 2025
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 CASE NO. PAC-E-25-14
FOR APPROVAL OF THE 2026 INTER-
JURIDICTIONAL COST ALLOCATION BAYER PETITION FOR LEAVE TO
PROTOCOL 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:
Ethan Waltermire
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:
Ethan Waltermire
P4 Production, L.L.C.
P.O. Box 816
Soda Springs, Idaho 83276
E-mail: [e-mail]
BAYER PETITION FOR LEAVE TO INTERVENE 1

Thomas J. Budge
Racine Olson, PLLP
P.O. Box 1391; 201 E. Center
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]
4. Bayer has a direct and substantial interest in this proceeding because it is the single-
largest consumer of electricity on PacifiCorp's six-state system, and the allocation of costs
among the states may directly and substantially affect Bayer's electricity costs.
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 291h day of September, 2025.
RACINE OLSON, PLLP
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 29th day of September, 2025, I 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]
Aj ay Kumar
Chief Regulatory Counsel
Rocky Mountain Power
[e-mail]
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 3