20160908Petition to Intervene.pdf

September 6, 2016
Jean D. Jewell, Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise, Idaho 83720-0074
[e-mail]
Re: IPUC Case No. PAC-E-16-12
Dear Ms. Jewell:
RANDALL C. BUDGE
[e-mail]
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Enclosed you will find the original and seven (7) copies of Petition of
Monsanto Company for Leave to Intervene. Please file the same with the
Commission's records. If you have any questions, please don't hesitate to call.
Thank you.
Sincerely,
DL~GE
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201 E. Center St. I P.O Box 1391 I Pocatello, ID 83204
P: [phone] I F: [phone] I racinelaw.net Offices in Boise, Pocatello, and Idaho Falls
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone] l O 1
Fax: [phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
REC EIVED
20 ! 6 SC:P -8 A 8: 51
· .· : i :. i-LJLI C
: :1 '-, COV .~ISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER TO
UPDATE BASE NET POWER COSTS AND
IMPLEMENT A RA TE STABILITY PLAN
CASE NO. PAC-E-16-12
PETITION FOR MONSANTO
COMP ANY FOR LEA VE 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
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391
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
P.O. Box 1391; 201 E. 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: [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 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 LEA VE TO INTERVENE - 2
JIil
DATED this 12..__ day of September, 2016.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
PETITION OF MONSANTO COMP ANY FOR LEA VE TO INTERVENE -3
CERTIFICATE OF MAILING
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I HEREBY CERTIFY that on this 12_ day of September, 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: jean. j ewell@puc. idaho. gov
Daniel E. Solander
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Facsimile No. [phone]
E-mail: [e-mail]
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
E-mail: [e-mail]
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PETITION OF MONSANTO COMPANY FOR LEA VE TO INTERVENE - 4