20170712Petition to Intervene.pdf

RACINE OLSON
RANDALL C.BUDGE
[e-mail]
July 10,2017
Diane Hanian,Commission Secretary
Idaho Public Utilities Commission
PO Box 83720
Boise,Idaho 83720-0074
diane.holt @ puc.id aho.gov
Re:IPUC Case No.PAC-E-17-06
Dear Ms.Hanian:
Enclosed you will find the original and seven (7)copies of Petition of
Monsanto Companyfor 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,
RANDA C.BUDG
RCB:ts
cc:Service List
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,CHARTERED
P.O.Box 1391;201 E.Center
Pocatello,Idaho 83204-1391
Telephone:[phone]
Fax:[phone]
[e-mail]
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE CASE NO.PAC-E-17-06
APPLICATION OF ROCKY
MOUNTAIN POWER FOR BINDING PETITION FOR MONSANTO
RATEMAKING TREATMENT FOR COMPANY FOR LEAVE TO
WIND REPOWERING INTERVENE
PETITION OF MONSANTO COMPANY
FOR LEAVE 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:
(l)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
Racine,Olson,Nye &Budge,Chartered
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE -1
P.O.Box 1391;201 E.Center
Pocatello,Idaho 83204-1391
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,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:bcollins consultbai.com
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 opportunityto 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 y of July,2017.
RACINE,OLSON,NYE
&BUDGE,CHARTERED
'RANDALL C.BUD
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE -2
CERTIFICATE OF MAILING
I HEREBY CERTIFYthat on this &day of July,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] U.S.Mail +Email
Ted Weston
Idaho Regulatory Affairs Manager
Rocky MountainPower
1407 West North Temple,Suite 330
Salt Lake City,Utah 84116
Telephone:[phone]
Email:[e-mail] E-Mail
Yvonne R.Hogle,
Assistant General Counsel
Rocky MountainPower
1407 West North Temple,Suite 320
Salt Lake City,Utah 84116
Telephone:[phone]
Email:[e-mail] E-Mail
RAND L C.BUDGE
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE -3