20180416Petition to Intervene.pdf

R RACINE OLSON
ATTORNEYS RTCEIVED RANDALL C. BUDGE
[e-mail]
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April 12,2018
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Diane Hanian, Secretary
ldaho Public Utilities Commission
PO Box 83720
Boise, ldaho 83720-007 4
dia n e. h olt@ pu c. id ah o. qov
Re: IPUC Case No. PAC-E-le-01
Dear Ms. Hanian
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.
ince
C. BUDGE
RCB:tscc: Service List
2O1 E. Center St. I P.O Box 1391 I Pocatello, lD 83204
P: (2O8) 232-61O1 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 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
PETITION FOR MONSANTO
COMPANY FOR LEAVE TO
INTERVENE
R[CITIVED
I0lB &PR l6 At{ t0: 00
/\trt/tYSS
Attorneys for Intervenor Monsanto Company
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTTNG APPROVAL OF $7.8
MILLION NET POWER COST DEFERRAL
WITH NO CHANGE TO RATES
CASE NO. PAC.E.18.O1
COMES NOW Monsanto Company, herein called "this Intervenor" and pursuant to Rule
72 of the rules of Procedure of the ldaho Public Utility Commission, and by this Petition asks
leave to intervene herein and to appear and participate as aparty 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 : j im.r. smith@monsanto. com
This Intervenor will be represented by:
Randall C. Budge
Thomas J. Budge
Racine, Olson, Nye & Budge, Chartered
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1,39 I
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 1
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 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 flavof April,20l8.
RACINE, OLSON, NYE, BUDGE &
BAILEY, CHARTERED
By:
RAND C.
CERTIFICATE OF MAILING
C'
E
\
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 2
I HEREBY CERTIFY that on this of April, 2018,I served a true, correct and
complete copy of the foregoing document, to each of the following, via the method so indicated:
da,
Diane Hanian, Secretary (original andT)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail : [e-mail]. gov
Ted Weston
Idaho Regulatory Affairs Manager
Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: (80 1 ) 220-2963
Email: [e-mail]
U.S. Mail + Email
E-Mail
Yvonne R. Hogle,
Assistant General Counsel
Rocky Mountain Power
1407 West North Temple, Suite 320
Salt Lake City, Utah 841l6
Telephone: (80 I ) 220-4050
Email : yvonne.ho gle@pacifi com.com E-Mail
RANDALL C. B E
PETITION OF MONSANTO COMPANY T'OR LEAVE TO INTERVENE - 3