20170821Petition to Intervene.pdf

R RACINE OLSON
ATTORNEYS RANDALL C. BUDGE
rcb@ racinelaw.net
August 16,2017
W,fi4
Diane Hanian, Commission Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
diane.holt@ puc. idaho.gov
Re: IPUC Case No. PAC-E-17-03
Dear Ms. Hanian:
Enclosed you will find the original and seven (7) copies of Petition of
Monsanto Company for Leave to lntervene. Please file the same with the
Commission's records. lf you have any questions, please don't hesitate to call.
Thank you.
Sincerely,
{1
RANDALL C. BUDGE
RCB:ts
2O1 E. Center St. I P.O Box 1391 I Pocatello, lD 83204
P: (2O8) 232-6101 I F: (2OB) 232-61O9 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, CHARTERED
P.O. Box 1391; 201E. Center
Pocatello, Idaho 83204-139 |
Telephone: [phone]
Fax: [phone]
[e-mail]
lilil Lri; I I fili I
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE FILING BY
PACIFICORP DBA ROCKY
MOUNTAIN POWER OF ITS 2017
INTEGRATED RESOURCE PLAN
CASE NO. PAC.E.17.O3
PETITION FOR MONSANTO
COMPANY FOR LEAVE TO
INTER\rENE
PETITION OF MONSANTO COMPANY
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 a party herein, and as basis therefor states as
follows:
(1) The name and address of this lntervenor is:
Monsanto Company
James R. Smith
P.O. Box 816
Soda Springs, Idaho 83276
Fax: [phone]
E-Mail : [e-mail]
This lntervenor will be represented by:
Randall C. Budge
Thomas J. Budge
Racine, Olson, Nye & Budge, Chartered
P.O. Box l39l:201E. Center
PETITION OF MONSANTO COMPANY 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
Thomas J. Budge
Racine, Olson, Nye & Budge, Chartered
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
E-mail : [e-mail]
[e-mail]
Brubaker & Associates
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017
E-Mail: [e-mail]
kiverson@consultbai. com
(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.
DATED this 16th day of August,Z}l7,
RACINE, OLSON, NYE
& BUDGE, CHARTERED
By:C,
C. BUDGE
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE .2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on this 1 6th day of Augu st, 2017 ,I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
Diane Hanian, Commission Secretary (original and 7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
E-mail : [e-mail]. qov U.S. Mail + Email
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake city, Utah 84116
Telephone: (80 I ) 220-2963
Email : ted.weston@pacifi corp.com E-Mail
Yvonne R. Hogle,
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 84116
Telephone: [phone]
Email : wonne.hogle@pacifi corp.com E-Mail
BUDGE
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE .3