20200422Petition to Intervene.pdf

RANDALL C. BUDGE [e-mail] April 22, 2020

Sent Via Email Diane Hanian, Secretary
Idaho Public Utilities Commission
PO Box 83720 Boise, Idaho 83720-0074 [e-mail]
Re: IPUC Case No. PAC-E-20-04
Dear Ms. Hanian: Attached please find for electronic filing Monsanto’s Petition of Monsanto
Company for Leave to Intervene. Please file the same with the Commission’s
records. The original and seven (7) copies of the Petition will be following by U.S. Mail. If you have any questions, please do not hesitate to contact us. Thank you for your assistance.

Sincerely, RANDALL C. BUDGE
RCB:ts cc: Service List

RECEIVED
2020 April 22,AM8:22
IDAHO PUBLIC
UTILITIES COMMISSION
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 1
Randall C. Budge, ISB No. 1949 Thomas J. Budge, ISB No. 7465
RACINE OLSON, PLLP P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391 Telephone: [phone]
Fax: [phone]
[e-mail] [e-mail] Attorneys for Intervenor Monsanto Company, a member of the Bayer group of companies BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF ROCKY MOUNTAIN POWER FOR A DEFERRED ACCOUNTING ORDER REGARDING COSTS INCURRED DUE TO THE COVID-19 PUBLIC HEALTH EMERGENCY
CASE NO. PAC-E-20-04 PETITION FOR MONSANTO COMPANY FOR LEAVE TO INTERVENE

COMES NOW Monsanto Company, a member of the Bayer group of companies, 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
Racine Olson, PLLP
P.O. Box 1391; 201 E. Center Pocatello, Idaho 83204-1391
RECEIVED
2020 April 22,AM8:22
IDAHO PUBLIC
UTILITIES COMMISSION
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 2
and requests that copies of all pleadings and production requests and responses should be
provided to the following:
Randall C. Budge Thomas J. Budge Racine Olson, PLLP
P.O. Box 1391; 201 E. Center
Pocatello, Idaho 83204-1391 Telephone: [phone] Fax: [phone] E-mail: [e-mail] [e-mail]
Brubaker & Associates Brian C. Collins Maurice Brubaker
16690 Swingley Ridge Rd., #140
Chesterfield, MO 63017 E-Mail: [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 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 22nd day of April, 2020.

RACINE OLSON, PLLP
By: ___________________________ RANDALL C. BUDGE
PETITION OF MONSANTO COMPANY FOR LEAVE TO INTERVENE - 3
CERTIFICATE OF MAILING I HEREBY CERTIFY that on this 22nd day of April, 2020, 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 Email: [e-mail] Email + U.S. Mail
Ted Weston Idaho Regulatory Affairs Manager Rocky Mountain Power
1407 West North Temple, Suite 330
Salt Lake City, Utah 84116 Email: [e-mail] Email [e-mail] [e-mail]
Adam Lowney McDowell Rackner Gibson PC 419 SW 11th Avenue, Suite 400 Portland, OR 97205
Email: [e-mail] Email
Attorney for Rocky Mountain Power _________________________________
RANDALL C. BUDGE