20260213Petition to Intervene.pdf

Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center St. RECEIVED
Pocatello, Idaho 83204-1391 FEBRUARY 13, 2026
[phone] IDAHO PUBLIC
[e-mail] UTILITIES COMMISSION
Attorneys for Ruveon LLC, an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN CASE NO. PAC-E-25-22
POWER'S APPLICATION FOR
APPROVAL OF THE 2026-2028 IDAHO BAYER PETITION FOR LEAVE TO
WILDFIRE MITIGATION PLAN INTERVENE
Ruveon LLC, 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
the Commission's Order No. 36912 and 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
Email: [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
Email: [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
Email: [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
Email: [e-mail], [e-mail]
Brian C. Collins
Greg Meyer
Brubaker&Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
Email: [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 Rocky Mountain Power's system, and costs incurred by Rocky
Mountain Power to implement its 2026-2028 Idaho Wildfire Mitigation Plan 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 13th day of February, 2026.
RACINE OLSON, PLLP
By
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 13th day of February, 2026, 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]
Joe Dallas
PacifiCorp, Senior Attorney
[e-mail]
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 3