20160212Petition to Intervene.pdf

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February 8, 2016
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
iean.jewell @ puc.idaho.gov
Re: IPUC Gase No. PAC-E-15-16
Dear Ms. Jewell:
Enclosed you wi!!find the original and seven (7) copies of Petition of
Monsanto Company for Leave to lnteruene. Please file the same with the
Commission's records. lf you have any questions, please don't hesitate to call.
Thank you.
RCB:tscc: Service List
RANDALL C. BUDGE
[e-mail]
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2O1 E. Center St. I
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P.O Box 1391 I Pocatello, lD 43204
F: (2O8) 232-6109 I racinelaw.net Offices in Boise, Pocatello, and ldaho Falls
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391;201E. Center
Pocatello,Idatro 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
IN THE MATTER OF PACIFICORP DBA
ROCI(Y MOUNTAIN POWER'S
APPLICATION FOR APPROVAL OF THE
20 1 7 INTER.JURISDICTIONAL COST
ALLOCATION PROTOCOL.
RECEIVED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-15.16
PETITION FOR MONSANTO
COMPANY FOR LEAVE TO
INTER\rENE
PETITION OF MONSANTO COMPA}IY
FOR LEAVE TO INTERYENE
COMES NOW Monsanto Company, herein called "this lntervenor" 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 lntervenor 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
P.O. Box l39l;201F,. Center
PETITION OF.MONSAT\TO COMPAI\IY FOR LEAVE TO INTERVENE - 1
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 l39l;201E. Center
Pocatello,Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail : r cb @r acinel aw. 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 : i im.r. smith@monsanto. com
(2) This lntervenor 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 lntervenor would be without a manner or
means of participating in the lawful determination of issues which will result in af[ecting its rates
for electric service.
WHEREFORE, this Intervenor requests that this Commission confirm this lntervenor'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 MONSAI\TO COMPAI\IY FOR LEAVE TO INTERVENE.2
DATED *. -d6", of Febnrary, 2016.
RACINE, OLSON, }IYE, BUDGE &
BAILEY, CHARTERED
PETITION OF MONSAI\iTO COMPANY FOR LEAVE TO INTERVENE .3
CERTJFICATE OF MAILING
I HEREBY CERTIFY that on ,^, throf February, 2016,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 and 7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail : j ean j [e-mail]. gov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
E-mail: [e-mail]
Daniel E. Solander
Senior Counsel
Rocky Mountain Power
1407 West North Tonple, Suite 320
Salt Lake City, UT 84116
E-mail : daniel. solander@oacifi corp. com
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PETITION OF'MONSANTO COMPAI\'Y FOR LEAVE TO INTERVENE.4