20221031Petition to Intervene.pdf

Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1 39 I
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneyfor P4 Production, L.L.C., an ffiliate of Bayer Corporation
BEFORE TIIE IDAHO PUBLIC UTILITIES COMMISSION
;"i [ {.;i: IVED
tl:l OtI 3 I pH L: 32
::;i,i-iI-r ;,UBLiC-: . f-13.:ri COil{MlSSlON
TN THE MATTER OF TI{E APPLICATION
OF ROCKY MOUNTATN POWER FOR
AUTHORITY TO IMPLEMENT A
COMMERCIAL AND INDUSTRIAL
DEMAND RESPONSE PROGRAM
CASE NO. PAC.E.22.I3
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 7l and 72 of the Rules of Procedure of the Commission. In support of this
Petition, Bayer states as follows:
l. 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 : mike.vei [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 l39l;201E. Center
Pocatello, Idaho 83204-1391
E-mai I : tj @racineolson.com
IBAYER PETITION FOR LEAVE TO INTERVENE
Brubaker & Associates
Brian C. Collins
Greg Meyer
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-Mail: [e-mail]
[e-mail]
3. The Application proposes to propose financial incentives to customers who curtail load
during Company initiated events. Bayer has a direct and substantial interest in this
proceeding because it currently operates under a special contract that provides financial
incentives for curtailing its load during Company initiated events. The Commission's
disposition of the Application may directly or indirectly affect Bayer's special contract.
Therefore, Bayer intends to participate in all respects as a party to represent its interests.
4. Without the opportunity to intervene herein, Bayer would be without a manner or means
of participating in the lawful determination of issues which will affect its rates for electric
service.
Based on the foregoing, Bayer requests that this Commission confirm Bayer's leave to
intervene in this proceeding and to appear and participate in all matters as may be necessary and
appropriate; and to present evidence, call and examine witnesses, cross-examine witnesses,
present argument, and to otherwise fully participate in the proceeding.
DATED this 3l't day of Octobet2022.
RACTNE OLSON, PLLP
By:
THOMAS J. BUDGE
2BAYER PETITION FOR LEAVE TO INTERVENE
CERTIFICATE OF SERYICE
I HEREBY CERTIFY that on this 3l$ day of October,Z}Z2,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, lD 83720-0074
secretary@puc. idaho. gov
Ted Weston
Michael Snow
Emily Wegener
Rocky Mountain Power
1407 West North Temple, Ste. 330
Salt Lake City, UT 84116
ted.weston@pacifi corp.com
michae l. snow@pacifi corp.com
em ily.wege ner @pacifrcorp. com
THOMAS J. BI.JDGE
3BAYER PETITION FOR LEAVE TO INTERVENE