20220512Petition to Intervene.pdf

BAYER PETITION FOR LEAVE TO INTERVENE 1
Thomas J. Budge, ISB No. 7465 RACINE OLSON, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391 Telephone: [phone] Fax: [phone] [e-mail]
Attorney for P4 Production, L.L.C., an affiliate of Bayer Corporation BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

IN THE MATTER OF COMMISSION
STAFF’S APPLICATION TO UPDATE INPUTS TO THE “SURROGATE AVOIDED RESOURCE” METHOD AVOIDED COST
CASE NO. GNR-E-22-01
BAYER PETITION FOR LEAVE TO 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:
Bayer Corporation
P4 Production, L.L.C.
Mike Veile P.O. Box 816 Soda Springs, Idaho 83276 E-Mail: [e-mail]

2. Bayer will be represented by Racine Olson, PLLP. All pleadings and other documents should be served to the following:
Thomas J. Budge Racine Olson, PLLP P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391
E-mail: [e-mail] Brubaker & Associates Brian C. Collins Greg Meyer
RECEIVED
2022 May 12, PM 4:41
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER PETITION FOR LEAVE TO INTERVENE 2
16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017
E-Mail: [e-mail]
[e-mail]
3. Bayer is an Idaho electric utility ratepayer and a customer of PacifiCorp. Bayer has a direct and substantial interest in this proceeding because its electricity rates depend in part upon natural gas forecasts and avoided cost rates. While Bayer is not a qualifying facility (“QF”) under the Public Utility Regulatory Policies Act of 1978, Bayer is a special contract customer of Rocky Mountain Power, under which Bayer receives a credit for interruptibility whose value may be affected by the natural gas forecast used to calculate avoided cost rates. Furthermore, avoided costs paid to QFs are included in Rocky Mountain Power’s Net Power Costs (“NPC”). As a substantially large load in Idaho and the PacifiCorp system as a whole, any increases in NPC can materially affect Bayer’s total electricity costs paid to PacifiCorp. Without the opportunity to intervene herein, Bayer would be unable to effectively participate in the Commission’s determination of issues which may affect its rates for electric service.
4. Allowing Bayer to intervene in this matter will not unduly broaden the issues.
Based on the foregoing, Bayer respectfully requests that the Commission grant to Bayer
leave to intervene in this proceeding, with all rights afforded to a party under the Rules of
Procedure of the Commission.

DATED this 12th day of May, 2022.

RACINE OLSON, PLLP
By: ___________________________
THOMAS J. BUDGE
BAYER PETITION FOR LEAVE TO INTERVENE 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 12th day of May, 2022, I served a true, correct and
complete copy of the foregoing document by email to each of the following: Commission Secretary Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074 [e-mail] Donovan E. Walker Idaho Power Company 1121 W. Idaho Street 83702
P.O. Box 70 Boise, ID 83707-0070 [e-mail] [e-mail]
Ted Weston
Emily Wegener Rocky Mountain Power 1407 West North Temple, Ste. 330 Salt Lake City, UT 84116 [e-mail]
[e-mail]
David Meyer Michael Andrea
Avista Corporation P.O. Box 3727 1411 East Mission Avenue Spokane, WA 99220-3727
[e-mail] [e-mail]
IdaHydro
c/o C. Tom Arkoosh and Amber Dresslar Arkoosh Law Offices 913 W. River Street, Suite 450 P.O. Box 2900
Boise, ID 83701
[e-mail] [e-mail] [e-mail]
_________________________________
THOMAS J. BUDGE