20180913Petition to Intervene.pdf

ldaho Public Utilities Commission
Otfice of the SecrelarvRECEIVED
sEP I 3 20t8
Randall C. Budge,ISB No. 1949
Thomas J. Budge,ISB No. 7465
RACINE OLSON, PLLP
P.O. Box l39l;201E, Center
Pocatello, Idaho 83204-1391
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Intervenor Monsanto Company
BETORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF ROCKY MOUNTAIN POWER
REQUESTING A PRUDENCY
DETERMINATION ON DEMAND-SIDE
MANAGDMENT EXPENDITURES
CASE NO. PAC.E-18-07
Boise,ldaho
PETITION F'OR MONSANTO
COMPAI\rY FOR LEAVE TO
INTERVENE
COMES NOW Monsanto Company, herein called "this Intervsnor" 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 : j [e-mail]
This lntervenor will be represented by:
Randall C. Budge
Thomas J. Budge
Racine Olson, PLLP
P.O. Box l39l;201E. Center
Pocatello, tdaho 8320 4-1391
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, PLLP
P.O. Box l39l;201E. Center
Pocatello, Idaho 83204-1391
Telephone: [phone] I
Fax: [phone]
E-mail: rcb@racinelaw.n.t
[[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 lawfi.rl 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 ar5ument, and to otherwise fully participate in the proceedings.
DATED this ilZ'diy of September,20l8.
RACINE OLSON, PLLP
By:0'
RANDALL C.
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 2
CERTIFICATE OF MAILING
I HEREBY CERTIFY that on thi, lz!(lyof Septemb er,2078, I served a true, correct
and complete copy of the foregoing document, to each of the following, via the method so
indicated:
Diane Hanian, Secretary (original and 7)
Idaho Public Utilities Commission
P.O. Box 83720
Boise,ID 83720-0074
E-mail : diane.holt@puo, idaho. gov
Ted Weston
Daniel E. Solander
Michael S. Snow
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116
Telephone: (80 l) 220 -29 63
Fax: [phone]
Email: ted.weston@pacifi corp.com
daniel.solander@f acifi corp. com
michael. snow@pacificorp. com
U.S, Mail + Email
Email
Email
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RANDALL C.
PETITION OF MONSANTO COMPANY F'OR LEAVE TO INTERVENE - 3