20230213Bayer Petition 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 St.
Pocatello, Idaho 83204-1391 [phone] [e-mail]
Attorneys for P4 Production, L.L.C., an affiliate of Bayer Corporation
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER FOR A
CERTIFICATE OF CONVENIENCE AND NECESSITY AUTHORIZING CONSTRUCTION OF THE BOARDMAN-TO-HEMINGWAY 500-KV TRANSMISSION
CASE NO. PAC-E-23-01
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:
Mike Veile P4 Production, L.L.C. P.O. Box 816 Soda Springs, Idaho 83276 E-mail: [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
E-mail: [e-mail]
3. All pleadings and other documents should be served upon:

RECEIVED
Monday, February 13, 2023 1:46:43 PM
IDAHO PUBLIC
UTILITIES COMMISSION
BAYER PETITION FOR LEAVE TO INTERVENE 2
Thomas J. Budge Racine Olson, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391 E-mail: [e-mail] Brian C. Collins
Greg Meyer
Brubaker & Associates 16690 Swingley Ridge Rd., #140 Chesterfield, MO 63017 E-mail: [e-mail]
[e-mail]
4. Bayer has a direct and substantial interest in this proceeding and intends to participate in
all respects as a party to represent its interests.
5. 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.
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.

DATED this 13th day of February, 2023.

RACINE OLSON, PLLP

By: ___________________________ THOMAS J. BUDGE

BAYER PETITION FOR LEAVE TO INTERVENE 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on this 13th day of February, 2023, I served a true, correct and
complete copy of the foregoing document by email to each of the following: Idaho Public Utilities Commission Commission Secretary
P.O. Box 83720
Boise, ID 83720-0074 [e-mail] Riley Newton, Deputy Attorney General
[e-mail]
PacifiCorp Data Request Response Center [e-mail]

Mark Alder Idaho Regulatory Affairs Manager [e-mail]
John Hutchings
Carla Scarsella [e-mail] [e-mail]
Katherine McDowell
Adam Lowney (ID #10456)
McDowell Rackner & Gibson PC [e-mail] [e-mail]

Idaho Irrigation Pumpers Association Eric L. Olsen ECHO HAWK & OLSEN, PLLC [e-mail]

Lance Kaufman, Ph.D. [e-mail]

_________________________________ THOMAS J. BUDGE