20140130Petition to Intervene.pdf

il RACI N E
OLSON
NYE
BUDGE
BAILEY
2O1 E. Center St.
P.O, Box 1391
Pocatello, lD 83204
o 208.232.6101
F 208.232.6109
racinelaw.net
RANDALL C. BUDGE
[e-mail] .r_-I,
:;1i !'rr.1+i.i,'; I . ,:._..r
. i ;i
January 28,2014
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise lD 8372O-OO74
IPUC Case No. PAC-E-14-01
Dear Ms. Jewell:
Enclosed you will find the original and eight (8) copies of Petition of Monsanto Company for
Leave to lntervene. Please file the same with the Commission's records and return a file-
stamped copy to me in the envelope provided. lf you have any questions, please don't
hesitate to call.
Thank you.
RCB:cr
PETITIONOFMONSANTOCOMPANYFORLEAVETOINTERVENE-l ?tr:. ,.,r.-ri-,r ^,,! r:i., /
lRandall C. Budge, ISB No. 1949 r r r ' ' '.'': ; ;1 i'';; i1fi
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE & i '
BAILEY, CHARTERED
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
ROCKY MOUNTAIN POWER FOR ) Case No. PAC-E-14-01
AUTHORITY TO INCREASE RATES BY )
$2.2MLLLrON TO RECOVER DEFERRED )
NET POWER COSTS THROUGH THE ENERGY )
COST ADruSTMENT MECHANISM )
)
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, and by this Petition asks leave to
intervene herein and to appear and participate as aparty herein, and as basis therefor states as
follows:
(1) The name and address of this Intervenor is:
Monsanto Company
c/o Steven D. Spinner, Manager, Energy Procurement
800 N. Lindburg Blvd., Mailzone C2NF
St. Louis, Missouri 63167
This Intervenor will be represented by:
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
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
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fa:r: [phone]
E -mail : r cb @r acinelaw. net
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-Mail: [e-mail]
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, Idaho 83276
Fax: [phone]
E-Mail : j im.r. [e-mail]
(2) This Intervenor has a direct and substantial interest in this proceeding as a special contract
customer of Applicant Rocky Mountain Power and intends to participate in all respects herein as
aparty 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 28t dayof January, 2014.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 286 day of January,z}l4,I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary (original and7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail: [e-mail] U.S. Mail + Email
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 84111
E-mail: [e-mail] E-l4c; I
Yvonne R. Hogle, Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 8411I
E-mail: [e-mail]
V (,u,.t fr"E&^
RANDALL C..BUDGE U
E-Mail