20250610Petition to Intervene.pdf

RECEIVED
June 10, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Chad M. Stokes (OSB No. 004007)
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
[e-mail]
Attorneys for Alliance of Western Energy Consumers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CASE NO. INT-G-25-02
INTERMOUNTAIN GAS COMPANY
FOR THE AUTHORITY TO PETITION TO INTERVENE OF
CHANGE ITS RATES AND ALLIANCE OF WESTERN ENERGY
CHARGES FOR NATURAL GAS CONSUMERS
SERVICE IN THE STATE OF IDAHO
Pursuant to Rules of Procedure 71-75 of the Idaho Public Utilities Commission
("Commission") Rules of Procedure, IDAPA 31.01.01.071—.075, Alliance of Western Energy
Consumers ("AWEC")hereby submits this Petition to Intervene in the above-captioned
proceeding. As discussed below, AWEC has a direct and substantial interest in these
proceedings, and respectfully requests that the Commission grant its intervention.
The name and business address of AWEC as an intervenor in this proceeding is:
Alliance of Western Energy Consumers
818 SW Third Avenue#266
Portland, OR 97204
Chad M. Stokes from the law firm Cable Huston LLP will represent AWEC in this
proceeding. All notices, pleadings, production requests and responses, and other documents
related to this proceeding should be served on AWEC's attorneys at the following address:
ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE - 1

Chad M. Stokes
Cable Huston LLP
1455 SW Broadway Suite 1500
Portland, OR 97201
Telephone: [phone]
E-Mail: [e-mail]
AWEC respectfully requests that any communications to AWEC also include a courtesy
copy to AWEC's consultant, Brad Mullins; [e-mail].
AWEC is a non-profit association consisting of approximately 40 end users of natural
gas with major facilities in the States of Idaho, Oregon, and Washington. AWEC members
include diverse industrial and commercial interests, including food processing, pulp and paper,
wood products, electric generation, aluminum, steel, chemicals, electronics and aerospace. The
association provides an informational service to its members and participates in various
regulatory matters that affect member interests. AWEC member companies purchase sales and
transportation services from local distribution companies including Intermountain Gas Company
("Intermountain"or"the Company").
On May 30, 2025, Intermountain filed a request to increase the rates and charges for
natural gas distribution service in the state of Idaho effective on or after June 30, 2025.
Intermountain proposes to increase the revenue collected through natural gas rates by
approximately $26.5 million, which equates to a margin revenue increase of approximately 22%.
Because AWEC member companies purchase sales and transportation services from
Intermountain, AWEC and its members have a direct and substantial interest in Intermountain's
Application in this proceeding. AWEC intends to participate in all respects herein as a party, and
if necessary, to introduce evidence, cross-examine witnesses, call and examine witnesses, and be
heard in argument. Without the opportunity to intervene herein, AWEC would be without any
ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE - 2

means of participation in this proceeding which may have a material impact on the rates paid by
the industrial class of customers to the Company.
AWEC's participation in this proceeding will assist the Commission in resolving the
issues, and will not unduly broaden the issues, delay the proceeding, or prejudice any party to
this case.
WHEREFORE, for the reasons described above, AWEC respectfully requests leave to
intervene and fully participate with all rights as a formal party in this proceeding.
This Petition is accompanied by a Motion for Limited Admission Pro Hac Vice
requesting admission of Chad M. Stokes to serve as counsel to AWEC in this proceeding.
Dated this I Oth day of June 2025.
Respectfully submitted,
Chad M. Stokes
CABLE HUSTON LLP
Attorneys for Alliance of Western Energy
Consumers
ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE - 3

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 10th day of June 2025, 1 caused a true and correct copy
of the foregoing Petition to Intervene to be delivered to the following persons via the method of
service indicated below:
Electronic mail only (see Commission Order No. 35375)
Monica Barrios-Sanchez, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd
Building 8, Suite 201-A
Boise, ID 83714
[e-mail]
[e-mail]
Preston N. Carter, ISB No. 8462
Megann E. Meier, ISB No. 11948
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
[e-mail]
[e-mail]
Lori A. Blattner
Director, Regulatory Affairs
Intermountain Gas Company
P O Box 7608
Boise, ID 83707
[e-mail]
Chad M. Stokes
Cable Huston LLP
Attorneys for Alliance of Western Energy
Consumers
ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE - 4