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Home My WebLink About20260511Petition to Intervene.pdf RECEIVED May 11, 2026 Thomas J. Budge, ISB No. 7465 IDAHO PUBLIC RACINE OLSON, PLLP UTILITIES COMMISSION P.O. Box 1391; 201 E. Center St. Pocatello, Idaho 83204-1391 (208) 232-6101 tj@racineolson.com Attorneys for Ruveon LLC., an affiliate of Bayer Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF THE PETITION OF CASE NO. IPC-E-26-07 IDAHO POWER COMPANY TO EVALUATE CLASS COST-OF-SERVICE BAYER PETITION FOR LEAVE TO METHODOLOGY, CONSIDER INTERVENE ALTERNATIVE CLASS COST-OF- SERVICE STUDIES, AND DETERMINE COST OF SERVICE CONSIDERATIONS FOR NEW LARGE-LOAD CUSTOMERS Ruveon LLC, an affiliate of Bayer Corporation (referred to herein as "Bayer"), hereby petitions the Idaho Public Utilities Commission("Commission") for leave to intervene in this matter pursuant to the Commission's Rules of Procedure, including Rules 72 and 73, IDAPA 31.01.01.072 and .073, and Commission Order No. 36998. Because this Petition is filed after the intervention deadline set forth in the Notice of Petition, Bayer further requests that the Commission grant leave to intervene for good cause shown pursuant to Rule 73. In support of this Petition, Bayer states as follows: 1. The name and address of Bayer is: Ethan Waltermire Ruveon LLC P.O. Box 816 Soda Springs, Idaho 83276 Email: ethan.waltermire@bayer.com 2. Bayer will be represented by: Thomas J. Budge Racine Olson, PLLP P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 BAYER PETITION FOR LEAVE TO INTERVENE 1 Email: tj@racineolson.com 3. All pleadings and other documents should be served upon: Ethan Waltermire Ruveon LLC P.O. Box 816 Soda Springs, Idaho 83276 Email: ethan.waltermire@bayer.com Thomas J. Budge Racine Olson, PLLP P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Email: tj@racineolson.com, tessa@racineolson.com Brian C. Collins Greg Meyer Brubaker&Associates 16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017 Email: bcollins@consultbai.com, gmeyer@consultbai.com 4. Bayer has a direct and substantial interest in this proceeding. Bayer is a special contract electric customer of Rocky Mountain Power and is the single largest consumer of electricity on Rocky Mountain Power's Idaho system. Although Bayer is not a retail customer of Idaho Power Company, the subject matter of this proceeding—the development and evaluation of class cost-of-service ("CCOS") methodologies and related treatment of large-load customers—is not utility-specific in effect. Rather, the outcome of this case will address fundamental cost-allocation principles that the Commission may reasonably be expected to apply across utilities in the interest of regulatory consistency, avoidance of undue discrimination, and equal protection of the law. 5. This Petition is filed seven days after the intervention deadline set forth in Order No. 36998. Good cause exists for granting late intervention under Rule 73. Bayer is not an Idaho Power customer and does not routinely monitor or participate in Idaho Power-specific proceedings. Bayer desires to intervene because this case has broader policy implications, when it became apparent that the record developed in this docket could establish or inform Commission policy affecting CCOS methodologies and large-load treatment for other electric utilities serving Idaho, including Rocky Mountain Power. BAYER PETITION FOR LEAVE TO INTERVENE 2 6. Granting Bayer's late-filed Petition will not prejudice any party or disrupt the procedural posture of this case. No prehearing conference has been held, no hearing date has been set, and no procedural schedule has yet been established. Bayer's participation will not enlarge the issues presented by Idaho Power's Petition but will instead assist the Commission by providing the perspective of a large industrial customer subject to CCOS outcomes at another Idaho-regulated electric utility. Bayer intends to participate constructively and in coordination with existing parties to ensure an efficient and focused record. 7. The nature of this proceeding further supports Bayer's intervention. Idaho Power has expressly framed this case as a single-issue, non-rate-setting docket intended to develop a comprehensive evidentiary record on CCOS methodology and related policy considerations, rather than to approve specific rates or tariff changes. In that respect, the issues presented resemble matters often addressed in proceedings of more general applicability, rather than disputes limited to the unique circumstances of a single utility. Bayer's participation will help ensure that the Commission's evaluation of CCOS principles is informed by the potential implications for similarly situated customers served by other utilities, consistent with the Commission's obligation to administer Title 61 in a uniform and non-discriminatory manner. 8. Without leave to intervene, Bayer would lack any reasonable means of participating as a party in the development of a record that may materially affect how its electric rates are determined in future proceedings involving its serving utility. Written public comment would not provide Bayer with an adequate opportunity to protect its interests through discovery, evidentiary presentation, or cross-examination on technical cost-allocation matters. For these reasons, Bayer respectfully requests that the Commission grant this late-filed Petition for Leave to Intervene pursuant to IDAPA 31.01.01.073 and permit Bayer to appear and participate fully in this proceeding. DATED this 1 lth day of May, 2026. RACINE OLSON, PLLP By: THOMAS J. BUDGE BAYER PETITION FOR LEAVE TO INTERVENE 3 CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 1 Ph day of May, 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 secretary@puc.idaho.gov Idaho Power Company Megan Goicoechea Allen Lisa Lance mgoicoecheaallengidahopower.c om llance(c�r�,idahopower.com dockets gidahopower.com Timothy Tatum Grant T. Anderson ttatum[aiidahopower.com ganderson@idahopower.com City of Boise Ed Jewell Deputy City Attorney Boise City Attorney's Office boisecityattomeygcityofboise.org ei ewell(ccityofboise.org Katie O'Neil Energy Program Manager Boise City Department of Public Works koneilgciytof Boise.org Clean Energy Opportunities of Idaho Courtney White Mike Heckler Kelsey Jae courtney(aa,cleanenergyopportunities.com mikegcleanenerg_yopportunitie s.com kelsey@kelsey al e.com BAYER PETITION FOR LEAVE TO INTERVENE 4 The Federal Executive Agencies Emily W. Medlyn Jelani A. Freeman U.S. Department of Energy Emily.medlynghq.doe.gov Jelani.fre emankhq.doe.gov Dwight Etheridge Exeter Associates, Inc. detheridge(&,exeterassociates.com Idaho Irrigation Pumpers Association, Inc. Eric L. Olsen ECHO HAWK& OLSEN, PLLC elo(a,echohawk.com tayshagechohawk.com Lance Kaufman, Ph. D. Deborah Glosser, Ph.D. lancegae is�.hg t.com deborah. log sser(a),gmail.com Industrial Customers of Idaho Power Peter J. Richardson Richardson Adams, PLLC petergrichardsonanadams.com Micron Technology,Inc. Austin Rueschhoff Thorvald A. Nelson Richard A. Arnett Holland& Hart, LLP darue schhoff khollandhart.com tnelson(d,hollandhart.com raamett(&,hollandhart.com aclee(&,hollandhart.com tlfrielghollandhart.com Northwest Energy Coalition Benjamin J. Otto ben(cnwenergy.org BAYER PETITION FOR LEAVE TO INTERVENE 5 Lauren McCloy NWEC Utility and Regulatory Director laurengnwenergy.org Derek Goldman NWEC Policy Associate derekknwenergy.org THOMAS J. BUDGE BAYER PETITION FOR LEAVE TO INTERVENE 6