20020501Nuwest Petition to Intervene.pdf

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Conley Ward
GIVENS PURSLEY LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, ID 83701
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Attorneys for Nu -West Industries, Inc.
S:\MACS\CEW\Nu- West\petition to intervene.rtf
BEFORE THE IDAHO PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE APPLICATION OF : CASE NO.: PAC-02-
PACIFICORP DBA UTAH POWER & LIGHT
COMPANY FOR APPROVAL OF CHANGES : NU- WEST INDUSTRIES' PETITION
TO ITS ELECTRIC SERVICE SCHEDULES : TO INTERVENE
Nu-West Industries, Inc. ("Nu-West") petitions this Commission for leave to intervene in
the above entitled proceeding pursuant to Rules 72 and 73 of the Commission s Rules of Practice
and Procedure, IDAPA 31.01.01.072 and -073. In support ofthis Petition, Nu-West states as
follows:
1. Nu-West's facility near Soda Springs is PacifiCorp s second largest Idaho customer..
2. Potlatch has a direct and substantial interest in these proceedings because tIns
Commission s decision may, directly or indirectly, affect the rates paid by Nu- West
PacifiCorp.
3. Nu-West is unable to state its position at this stage of the proceedings, and therefore
seeks to intervene for the purpose of receiving documents, examining witnesses, and otherwise
participating as its interest may appear.
4. Nu- West's representatives for the purpose of service of pleadings and other written
materials are:
NU- WEST's PETITION TO INTERVENE - 1
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Conley Ward
GIVENS PURSLEY LLP
277 North 6th Street, Suite 200
O. Box 2720
Boise, ID 83701
[phone]
[phone] (fax)
cew(fYgi venspursley. com
Gary Thoms
Agrium U., Inc.
131 Lake Fraser Dr., S.
Calgary, Alberta
T2J7E8 Canada
[phone]
[phone] (fax)
gthoms(fYagrium.com
5. This Petition is late filed as a result of excusable neglect, but wi11not unjustifiably
broaden the issues or otherwise delay these proceedings.
WHEREFORE, Nu- West respectfully requests that the Commission grant this Petition to
Intervene and authorize Nu- West to participate in the above entitled proceedings with full rights
as a formal party.
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DATED this 30th day of April, 2002.
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Conley Ward
GIVENS PURSLEY LLP
Attorneys for Nu- West InduslTies Inc.
NU- WEST's PETJTJON TO INTERVENE - 2
CERTIFICATE OF SERVICE
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I HEREBY CERTIFY that on the day of May, 2002, I caused to be served a true
and correct copy of the foregoing by the method indicated below, and addressed to the following:
Jean Jewell
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 83720
Boise, ill 83720-0074
u.S. Mail - Fax -1L By Hand
Eric L. Olsen
Racine Olson Nye Budge & Bailey
O. Box 1391
Pocatello, ill 83204-1391
L U.S. Mail Fax ByHand
Doug Larson
PacifiCorp
201 S. Main, Suite 2300
Salt Lake City, UT 84140
1L u.S. Mail - Fax - By Hand
Randall C. Budge
Racine Olson Nye Budge & Bailey
O. Box 1391
Pocatello, ill 83204-1391
L U.S. Mail Fax - By Hand
James R. Smith
Monsanto Company
O. Box 816
Soda Springs, ill 83276
1L U.S. Mail - Fax - By Hand
Anthony J. Yankel
29814 Lake Road
Bay Vi11age, OH 44140
L U.S. Mail Fax - By Hand
Timothy Shurtz
411 S. Main
Firth, ill 83236
1L u.S. Mail - Fax - By Hand
John Eriksson
Stoel Rives LLP
201 S. Main, Suite 1100
Salt Lake City, UT 84111
1L u.S. Mail - Fax - By Hand
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Tina Smith
NU-WEST's PETITION TO INTERVENE - 3
The City of Firtl~
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o. Box 37 ,"-WI.-I.., LL'
Firth , Idaho 83236
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February 26, 2002
Idaho Public Utili ties Commission
O. Box 83720Boise, Idaho 83720-0074
Ref: Case Number PAC-02-
The Firth Ci ty Counci 1 held a meeting on February 25,
2002, in that meeting it was voted on not to intervenein the above case. We hope this will not be a problem
and are sorry for any inconvenience this may have caused.
Attes
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Robert Dial, City
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Mike Kress, Mayor
fhJClerk
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Timothy J. Shurtz
411 S. Main
Firth, 10 83236
Mr. Ron Law
Idaho Public UtilitieR Commission
412 W, Washington
PO Box 83720
Boise, m 83720-0074
R.e: CASE NO. P AC-02-
Honorable Commissioners:
1 requeRt the right to continue as an intervenor in ca!I~ Jlo.P AC-E-O2-1. The city of Firth
has chosen not to continue I fet=l that! have a strong personal interest this cllSe.
First,. I vutw lu I Guew the Utah Power franchise for the City of Firth so I feel personal
l(:apol1sibility to the people of Firth for that vote.
As CL oommunity leader, other people outside of l4irth have approached me and shown 1111
interest in this case, I teel they should aiM) be represemed as well.
I am also a power consumer of Utah Power.
I _1 for these IWSOnI that I should QOntinue u an intervoDor to represent these interests,
I do not plan to expand on the issues in thil case.
I appreciate your time and consideration.
Sincerely.
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MY c:mIMISSJON EXPIRES
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Randall C. Budge, ISB 1949
RACINE, OLSON, NYE, BUDGE & .
BAILEY, CHARTERED
O, Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: (208) ~32-61 01
Fax: [phone]
RECEIVED
FILED
ZllU2 JAN 14 Pt'1 3:
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uTILITIES COf'H'-HSSIO1'
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In the Matter of the Application of PacifiCorp,
dba Utah Power & Light Company, for
Approval of its Proposed Electric Service Schedules. Case No. PAC-O2-
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE
COMES NOW Monsanto Company, herein called "this Intervenor" and pursuant to Rule 72
of the rules of Procedure of the Idaho Public Utility Commission, by this Petition asks leave to
intervene herein and to appear and participate as a party herein, and as basis therefor states as
follows:
(1)The name and address of this Intervenor is:
Mark Boswell
Assistant General Counsel (E2NR)
Monsanto Company
800 N. Lindbergh Boulevard
81. Louis, Missouri 63167
This Intervenor will be represented by:
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391 tG : J 1...
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PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 1
and requests that copies of all pleadings and production requests and responses should be provided
to the following:
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
O, Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Richard Anderson
Energy Strategies, Inc.
39 Market Street, Suite 200
Salt Lake City, Utah 84101
Fax: [phone]
James R. Smith
Monsanto Company
O. Box 816
Highway 34 North
Soda Springs, Idaho 83276
Phone: [phone] x 207
Fax: [phone]
(2)This Intervenor is a special contract customer ofPacifiCorp and therefore has a direct
and substantial interest in this proceeding and intend to participate in all respects herein as a party
as may be required to represent its interests,
(3)Without the opportunity to intervene herein, this Intervenor would be without a
manner or means of participating in the lawful determination of issues which wi11 result in affecting
its rates for electric service,
WHEREFORE, this Intervenor requests that this Commission confirm this Intervenor s leave
to intervene in these proceedings 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 proceedings,
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 2
DATED this 10th day of January, 2002,
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By ~ Co'
RANDALL C. BUDGE
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 10th day of January, 2002, I served a true, correct and
complete copy of the foregoing document, to each of the following:
Jean D, Jewell, Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
John M, Eriksson
Stoel Rives LLP
201 S. Main St., Ste 1100
Salt Lake City, Utah 84111
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
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RANDALL C. BUDGE
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 3
Eric L. Olsen
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Attorneys for Intervenor
Idaho Irrigation Pumpers Association, Inc.
RECE\VEO 0F\LED -
20nZ JAN \ 4 PM 3:
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UTlllT IE':) Cor\iii1S~!Or
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP, DBA UTAH POWER &
LIGHT COMPANY FOR APPROVAL OF ITS
PROPOSED ELECTRIC SERVICE SCHEDULES)
Case No. PAC-O2-
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION. INc..
FOR LEAVE TO INTERVENE
COMES NOW Idaho Irrigation Pumpers Association, Inc., herein called "this Intervenor
and pursuant to Rule 72 of the rules of Procedure of the Idaho Public Utility Commission, by this
Petition asks leave to intervene herein and to appear and participate as a party herein, and as basis
therefor states as follows:
(1)The name and address of this Intervenor is:
Idaho Irrigation Pumpers Association, Inc.
c/o Lynn Tominaga
O. Box 2624
Boise, Idaho 83701-2624
This Intervenor will be represented by:
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
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PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC,
FOR LEAVE TO INTERVENE-
and requests that copies of all pleadings and production requests and responses should be provided
to the following:
Eric L. Olsen
Racine, Olson, Nye, Budge &
Bailey, Chartered
O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
Anthony Yankel
29814 Lake Road
Bay Village, Ohio 44140
Fax: [phone]
(2)This Intervenor and its members have a direct and substantial interest in this
proceeding and intend to participate in all respects herein as a party as may be required to represent
its interests,
(3)Without the opportunity to intervene herein, this Intervenor would be without a
manner or means of participating in the lawful determination of issues which will result in affecting
its rates for electric service.
WHEREFORE, this Intervenor requests that this Commission confirm this Intervenor s leave
to intervene in these proceedings 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 proceedings.
DATED this 10th day of January, 2002.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INe.
FOR LEAVE TO INTERVENE - 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 10th day of January, 2002, I served a true, correct and
complete copy of the foregoing document, to each of the following:
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
O, Box 83720
Boise, Idaho 83720-0074
John M, Eriksson
Stoel Rives, LLP
201 South Main Street, Suite 1100
Salt Lake City, Utah 84111-4904
Fax: [phone]
Doug Larson
PacifiCorp
201 South Main, Suite 2300
Salt Lake City, Utah 84140-0023
Fax: [phone]
PETITION OF IDAHO IRRIGATION PUMPERS ASSOCIATION, INC.
FOR LEAVE TO INTERVENE - 3