20260519Petition to Intervene.pdf

RECEIVED
May 19, 2026
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 Ruveon LLC, an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF ROCKY MOUNTAIN CASE NO. PAC-E-26-04
POWER'S APPLICATION FOR
APPROVAL OF THE SALE OF ITS BAYER PETITION FOR LEAVE TO
WASHINGTON SERVICE AREA AND INTERVENE
FOR AN ACCOUNTING ORDER
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. 37016 and rules 71 and 72 of the Rules of Procedure of the
Commission. This Petition is timely filed within twenty-one (21) days of Order No. 37016
establishing the intervention deadline. 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.
BAYER PETITION FOR LEAVE TO INTERVENE 1

P.O. Box 816
Soda Springs, Idaho 83276
Email: [e-mail]
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 one of the
largest retail customers on Rocky Mountain Power's Idaho system and is directly affected by the
Company's rates, cost allocation methodologies, and any accounting treatment of the proposed
transaction, including the disposition of the Idaho-allocated goodwill value and any resulting rate
credits or future rate impacts.
5. Bayer intends to participate in this proceeding on issues that may include,but are not
limited to, (a) the ratemaking treatment of the transaction, including allocation of costs and
benefits to Idaho customers; (b)the proposed accounting order and disposition of goodwill
value; (c)potential impacts on rates, resource adequacy, and cost allocation among jurisdictions;
and(d)whether the proposed transaction is consistent with the public interest as applied to Idaho
customers.
6. 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.
7. Bayer's participation will not unduly broaden the issues in this case and will assist
the Commission in developing a full and complete record regarding the impacts of the proposed
transaction on large Idaho customers.
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.
BAYER PETITION FOR LEAVE TO INTERVENE 2

DATED this I91h 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 19th 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
[e-mail]
PacifiCorp
Data Request Response Center
[e-mail]
Jana Saba
Director, Regulation and Regulatory Operations
[e-mail]
Adam Lowney
PacifiCorp, Attorney
[e-mail]
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 4