20160208Petition to Intervene.pdf

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February tl, 2016
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
iean.jewell @ puc. idaho.gov
Re: IPUC Case No. PAG-E-16-05
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. 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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Sincerely,
2O1 E. Center St. I
P: [phone] I
P.O Box 1391 I Pocatello, lD 83204
F: (2O8) 232-6109 I racinelaw.net Offices in Boise, Pocatello, and ldaho Falls
RECE'VED
t8l6 rEB -B At{ 9: 26Randall C. Budge,ISB No. 1949
Thomas J. Budge,ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTTNG APPROVAL OF THE $16.7
MILLION NET POWER COST DEFERRAL
AND AUTHORITY TO DECREASE RATES
BY $9.0 MILLION
uitl?#.{ocHr8n!|8u,o,
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CASE NO. PAC.E-16.05
PETITION FOR MONSANTO
COMPANY FOR LEAVE TO
INTERVENE
PETITION OF MONSANTO COMPAT\IY
FOR LEAVE TO INTERVENE
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 aparfi herein, and as basis therefor states as
follows:
(l) The name and address of this lntervenor is:
Monsanto Company
c/o Steven D. Spinner, Manager, Enerry 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 MONSAI\TO COMPANY FOR LEAVE TO INTERVENE - 1
P.O. Box l39l1,201E. Center
Pocatello, Idaho 83204-1391
and requests that copies ofall pleadings and production requests and responses should be
provided to the following:
RandallC. Budge
Racine, Olson, Nye, Budge & Bailey, Chartered
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1397
Telephone: [phone]
Fax: [phone]
E-mail : r cb @r acrnel 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 : j 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 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.
PETITION OF MONSANTO COMPAI\IY FOR LEAVE TO INTERVENE - 2
DATED ,fri, #uV of February, 2016.
RACINE, OLSON, NIYE, BUDGE &
BAILEY, CHARTERED
PETITION OF MONSAIITO COMPAIYY FOR LEAVE TO INTERVENE.3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on,*. flJu, of 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 : i ean j [e-mail]. gov
Ted Weston
Idaho Regulatory Af[airs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
E-mail: [e-mail]
Yvonne R. Hogle,
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
E-mail: [e-mail]
U.S. Mail + Email
E-Mail
E-Mail
PETITION OF MONSANTO COMPA}IY FOR LEAVE TO INTERVENE.4