Control Number : Item Number : 122. Addendum StartPage : 0

Transcription

1 Control Number : Item Number : 122 Addendum StartPage : 0

2 SOAH DOCKET NO PUC DOCKET NO APPLICATION OF SOUTHWSTERN PUBLIC SERVICE COMPANY FOR AUTHORITY TO CHANGE RATES AND TO RECONCILE FUEL AND PURCHASED POWER COSTS FOR THE PERIOD JANUARY 1, 2010 THROUGH JUNE 30, 2012 MOTION IN INTERVENTION OF PLAINS COTTON GROWERS, INC. i9izqrr 4,, /0; BEFORE THE STAT,FOFFICE OF ADMINISTRATIVE HEARINGS COMES NOW Plains Cotton Growers, Inc. (PCG), and moves to intervene in the abovecaptioned docket. In support of this Motion, PCG would show the following: The name, address, telephone number and address of PCG is as follows: PLAINS COTTON GROWERS, INC. Steve Verett 4517 West Loop 289 Lubbock, Texas Phone: FAX: H. The name, address, telephone number and address of PCG's authorized representative is as follows: ZS BRADY & Co. Zach Brady Amber Miller TH Street Lubbock, Texas (806) (Office) (806) (Fax) PUC DOCKET No ; PCG's MOTION IN INTERVENTION PAGE 1 OF 5 o"^

3 PCG requests that the Public Utility Commission of Texas ("the Commission") and all parties to this proceeding serve copies of all correspondence, pleadings, briefs, and other documents upon PCG's authorized representative at the Lubbock address shown above. III. PCG represents cotton growers throughout the High Plains of Texas. PCG is the USDA certified producer organization for cotton growers in the approximately 41-county region surrounding Lubbock, Texas; PCG has advocated for High Plains Cotton Growers since The members of PCG produce approximately 60% percent of the Texas cotton harvest, and include both irrigators and dryland producers. PCG membership is determined on a gin-by-gin basis; if a grower's chooses to have his or her cotton ginned at a PCG member gin, that grower is a member of, and pays dues to PCG. The PCG members who farm in the Applicants' service area will be affected by the Commission's decision in this case, as it will have an impact on production input costs. Therefore, PCG has a substantial and vital interest in the outcome of this hearing and requests the opportunity to be heard. The PCG member gins in the Applicants' service area affected in this proceeding are listed in Exhibit "A" attached hereto and incorporated herein by reference. PCG will accept and abide by any existing procedural schedule in this matter. NOW THEREFORE, for the above-mentioned reasons PCG respectfully requests that this, its Motion in Intervention in the above-captioned case be granted, and requests any other relief to which it may show itself entitled. PUC DOCKET No ; PCG's MOTION IN INTERVENTION PAGE 2 OF 5

4 Respectfully submitted, ZS BRADY & Co. l( Zachary S. Brady State Bar No Amber S. Miller State Bar No th Street Lubbock, Texas Telephone: (806) Facsimile: (806) ATTORNEYS FOR INTERVENOR PLAINS COTTON GROWERS, INC. CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing has been served on all parties known of record via facsimile, U.S. mail, or electronically on this ea/^ day of December, GG^^'^' ^Gt, X^. /(.(^^il ^. Amber S. Miller PUC DOCKET No ; PCG's MOTION IN INTERVENTION PAGE 3 OF 5

5 EXHIBIT A PCG MEMBER GINS COUNTY GINNA111E Gin Name Hale 1'Petersburg Co-op Gin Tetersburg Co-op Gin,Hale lunited Farm Industries- United Farm Industries Gin, nited Farm Industries Gin nited Farm Industries Gin, s erry oakum ynn :ockley bock bock y.orenzo Co-op Gin Assn. ) & J Gin, Inc. iloydada Co-op Gin, Inc.,ockney Co-op Gin 3Iarble Bros. Farm Gin cott Gin Co. 3arwise Gin ohnson's Gin Co. - R.J. Gin, Inc We Points Gin, Inc. 'ourway Ginning Association 'ri County - Loop,eminole Service Gin, Inc. 3Ieadow Farmers Co-op Gin un-cot Gin, Inc. lfarmers Co-op Assn. Tahoka Ropes Farmers Co-op Gin lalou Co-op Gin laton Co-op Gin laple Coop at Muleshoe Jillingham Gin armers Co-op Assn - Amherst armers Co-op Assn. of Sudan Lorenzo Co-op Gin, Inc. D & J Gin, Inc. Floydada Co-op Gin, Inc. Lockney Co-op Gin Marble Bros. Farm Gin Scott Gin Company Barwise Gin Johnson's Gin Co. Five Points Gin, Inc. Fourway Ginning Association TriCounty Producers Co-op Seminole Service Gin, Inc. Meadow Farmers Co-op Gin!Suncot Gin, L.L.C. 1Farmers Co-op Assn. No. 1 Ropes Farmers Co-op Gin yldalou Co-op Gin ISlaton Co-op Gin Maple Co-op Gin at Muleshoe Willingham Gin, Inc. Farmers Co-op Assn. lfarmers Co-op Assn. of ILamb 1Olton Co-op Gin 1Olton Co-op Gin Lamb ^Springlake/Earth Co-op Springlake-Earth Cotton rs Tuco Gin, Inc. Producers Co-op Gin h Gin of Dimmitt, Inc. af Smith lhereford Farmers Gin Assn Inc. armers Tuco Gin, Inc. :art Producers Co-op Gin orth Gin LTD. :ereford Farmers Gin Assn. PUC DOCKET NO ; PCG'S MOTION IN INTERVENTION PAGE 4 OF 5

6 EXHIBIT A PCG MEMBER GINS COUNTY GINNAME Gin Name Parmer jlariat Gin Co, Inc. 'Lariat Gin & Supply, Inc. Swisher Swisher Co-op Gin Inc. ISwisher Co-op Gin, Inc. Swisher Tule Creek Gin Inc. Tule Creek Gin --I Carson ^ Carson County Gin, LP Carson County Gin, L.P. FMoore Moore County Gin, LP Moore County Gin, L.P. I PUC DOCKET NO ; PCG's MOTION IN INTERVENTION PAGE 5 OF 5