20170405Petition to Intervene.pdf

R RACINE OLSON
ATTORNEYS RANDALL C. BUDGE
[e-mail]
April 3, 2017 t;r'.iii.,,..*,,,' . , 1,.)') ,'.-, i
Jean D. Jewell, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-0074
iean.jewell @ puc. idaho.gov
Re: IPUC Case No. PAC-E-17 -0L
Dear Ms. Jewell:
Enclosed you will find the original and seven (7) copies ol 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.
Sincerely,
RAN m
RCB:tsccr Service List
2O1 E. Center St. I P.O Box 1391 I Pocatello, lD 83204
P: [phone] I F: (2O8) 232-6109 I racinelaw.net Otfices in Boise, Pocatello, and ldaho Falls
Randall C. Budge, ISB No. 1949
Thomas J. Budge, ISB No. 7465
RACINE, OLSON, NYE & BUDGE, CHARTERED
P.O. Box l39l; 201E.. Center
Pocatello, Idaho 83204-139 I
Telephone: [phone]
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
REQUESTING APPROVAL OF THE $7.5
MILLION NET POWER COST DEFERRAL
AND AUTHORITY TO DECREASE RATES
BY $6.9 MILLION
CASE NO. PAC.E.I7-02
PETITION FOR MONSANTO
COMPANY FOR LEAYE TO
INTER\IENE
PETITION OF MONSANTO COMPANY
FOR LEAVE TO INTERyENE
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
James R. Smith
P.O. Box 816
Soda Springs, Idaho 83276
Fax: [phone]
E-Mail: [e-mail]
This Intervenor will be represented by:
Randall C. Budge
Thomas J. Budge
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE. 1
Racine, Olson, Nye & Budge, Chartered
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, Chartered
P.O. Box l39I;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]
(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 lntervenor 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 wifiresses, cross-examine
witnesses, present argument, and to otherwise fully participate in the proceedings.
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 2
DATED thiS of April, 2017.d*,
RACINE, OLSON, NYE, BUDGE &
BAILEY, CI{ARTERED
By:I
RA}IDALL C.
PETTION OF MONSAI\ITO COMPAI\IY FOR LEAVE TO INTERY, EIIE - 3
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this &u*of April, 2017,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 andT)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail : j ean j ewell@ouc. idaho. eov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: [phone]
Email : ted.weston@pacifi corp.com
U.S. Mail + Email
E-Mail
Yvonne R. Hogle,
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake Ciry, Utah 84116
Telephone: [phone]
Email: [e-mail] E-Mail
0
RANDALL C. BUDGE
PETITION OF MONSAI\TO COMPANY FOR LEAVE TO INTERVENE.4