20260318Comment_1.pdf

From:Tessa Sparrow<[e-mail]>
Sent:Wednesday, March 18, 2026 10:55 AM
To: secretary<[e-mail]>;[e-mail]; Dallas, Joseph
(PacifiCorp) <[e-mail]>; [e-mail]
Cc:TJ Budge <[e-mail]>; Ethan Waltermire <[e-mail]>;
Brock Sturm <[e-mail]>; bcollins <[e-mail]>; gmeyer
<[e-mail]>
Subject: PAC-E-25-20 - Bayer Comments
Dear Parties,
Attached for filing and service please find the Comments of Bayer regarding the above-
referenced matter.
Thankyou!
Sincerely,
Tessa Sparrow
Paralegal
L4RACINE OLSON
ATTORNEYS I PROBLEM SOLVED
201 E. Center Street/ P.O. Box 1391
Pocatello, Idaho 83204
[phone] - Phone
[phone]- Fax
racineolson.com

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 Ruveon LLC, an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION CASE NO. PAC-E-25-20
OF ROCKY MOUNTAIN POWER FOR A
WAIVER OF THE SOLICITATION COMMENTS OF BAYER
REQUIREMENTS PROPOSED IN CASE
NO. GNR-E-25-01
Ruveon LLC, an affiliate of Bayer Corporation (referred to herein as "Bayer"), respectfully
submits these comments in response to the Application filed by Rocky Mountain Power on
October 20, 2025f, seeking a waiver of the solicitation requirements proposed in Case No. GNR-
E-25-01.
Bayer does not object to the Commission granting a limited, one-time waiver of the
solicitation requirements in this proceeding, given the unique and time sensitive circumstances
associated with the KUl project. Bayer agrees that,under these specific facts, a traditional RFP
may not have produced meaningfully competitive alternatives within the required timeframe.
However, Bayer emphasizes that federal funding availability should not substitute for a
least-cost showing. Regardless of whether federal funding is available, PacifiCorp should remain
responsible for demonstrating that the KU1 resource is least-cost and least-risk for Idaho
customers. Approval of a waiver should not be construed as a finding that this resource satisfies
least-cost standards or as limiting the Commission's review in future proceedings.
Accordingly, Bayer urges the Commission to make clear that any waiver granted is
narrow, non-precedential, and does not relieve PacifiCorp of its ongoing obligation to
demonstrate the economic prudence of this resource in subsequent cost recovery,prudence, or
ratemaking proceedings.
COMMENTS OF BAYER 1

Respectfully submitted this 18th day of March, 2026.
RACINE OLSON, PLLP
By:
THOMAS J. BUDGE
COMMENTS OF BAYER 2

CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 18th day of March, 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 Email
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
PacifiCorp Email
Data Request Response Center
[e-mail]
Jana Saba
Rocky Mountain Power Email
[e-mail]
Joe Dallas
PacifiCorp, Senior Attorney Email
[e-mail]
THOMAS J. BUDGE
COMMENTS OF BAYER 3