20150209Petition to Intervene.pdf

il RACI N E
OLSON
NYE
BUDGE
BAILEY
2O1 E. Center St.
P.O. Box 1391
Pocatello, lD A32O4
o 208.232.6101
F 208.232.6109
racinelaw.net
RANDALL C. BUDGE
[e-mail]
February 6, 2015
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
Re: IPUC Gase No. PAG-E-15-01
Dear Ms. Jewell:
Enclosed you willfind the original and seven (7) copies of Petition of
Monsanto Company for Leave to lnteruene. Please file the same with the
Commission's records and return a file-stamped PDF copy to me. lf you have
any questions, please don't hesitate to cal!.
Thank you.
RCB:tscc: Service List
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Randall C. Budge,ISB No. 1949 2flli f [8 -9 [g 9' 2L
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE & , ,,,,i,ri;lj,1i:1,. ,.llr,Iit,;rBAILEY,CHARTERED '''rrr-rrr:-"r '\/ri'r'=
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]t01
Fax: [phone]
[e-mail]
Attomeys 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-15-01
AUTHORITY TO INCREASE RATES BY )
$10.7 MILLTON TO RECOVER ) PETITION FOR MONSANTO
DEFERRED NET POWER COSTS ) COMPANY FOR LEAVE
THROUGH THE ENERGY COST ) TO INTERVENE
ADJUSTMENT 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 a party 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
Thomas J. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE . 1
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
and requests that copies ofall pleadings and production requests and responses should be
provided to the following:
Randall C. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail : [e-mail]
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 : i [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
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 [ntervenor 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
, ll4
DATED this (-9 day of February, 2015.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
PETITION OT MONSANTO COMPANY FOR LEAVE TO INTERYENE .3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on thi, LlJayof February ,2Ol5,I served atrue, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Jean D. Jewell, Secretary (original and 7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail : i eanj [e-mail]. gov
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, Utah 841l l
E-mail: [e-mail]
Yvonne R. Hogle, Senior Counsel
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake city, Utah 84111
E-mail: [e-mail]
E-Mail
E-Mail
U.S. Mail + Email
PETITION OF MONSANTO COMPANY F'OR LEAVE TO INTERVENE.4