Northwest Industrial Gas Users.pdf

f~ECEJVED
F!LED
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L,~Edward A. Finklea
Chad M. Stokes
Energy Advocates, LLP
526 NW 18th Avenue
Portland, OR 97209-0220
Tel: [phone]
Fax: [phone]
Counsel for Intervenor Northwest
Industrial Gas Users
e-mail: mail(j?)energyadvocates.com
2002 JUN 25 AM 9: 31
JO;\H:: PJ..'lL:
UTILITiES CQfcH11SSION
BEFORE THE IDAHO PUBLIC UTILITY COMMISSION
IN THE MATTER OF THE APPLICA nON OF )
INTERMOUNTAIN GAS COMPANY FOR
AUTHORITY TO DECREASE ITS RATESFOR SERVICE.
CASE NO. INT-02-
PETITION FOR LEA VE
TO INTERVENE AND
COMMENTS OF INTERVENOR
NORTHWEST INDUSTRIAL
GAS USERS
Pursuant to Rules 72 and 203 of the Idaho Public Utility Commission s ("IPUC'" or
Commission ) Rules of Procedure, the Northwest Industrial Gas Users ("NWIGU"
petitions the Commission for leave to intervene and submit comments in the above-captioned
proceeding. On May 23 2002, Intermountain Gas Company, ("Intermountain" or the
Company ) filed its annual Purchased Gas Adjustment ("PGA") Application ("Application
with the IPUC requesting that this matter be handled under Modified Procedure pursuant to
Rules 201-204 of the Commission s Rules of Procedure.
In support of its Petition, NWIGU states the following:
PAGE 1 - PETITION FOR LEAVE TO INTERVENE AND COMMENTS OF
INTERVENOR NORTHWEST INDUSTRIAL GAS USERS
INTRODUCTION AND PETITION FOR LEAVE TO INTERVENE
NWIGU is a nonprofit association comprised of thirty-two end users of natural
gas with major facilities in the states of Oregon, Washington, and Idaho. NWIGU members
encompass diverse industrial 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. NWIGU member companies purchase
transportation services from Williams Gas Pipeline- West, also known as Northwest Pipeline
Corporation ("NPC") and PG&E Gas Transmission, Northwest Corporation and purchase sales
and transportation services from local distribution companies, such as Intermountain.
The following persons will represent the NWIGU in this proceeding, and should
be included on the official service list:
Edward A. Finklea
Chad M. Stokes
Energy Advocates LLP
526 NW 18th Avenue
Portland, OR 97209-0220
Tel: [phone]
Fax: [phone]
Counsel for the Northwest
Industrial Gas Users
e-mail: mailal)energyadvocates.com
Paula Pyron
Executive Director
Northwest Industrial Gas Users
4113 Wolf Berry Court
Lake Oswego, OR 97035
Tel: [phone]
Fax: [phone]
e-mail: ppyron(Wnwigu.org
On May 23 , 2002, Intermountain filed its annual PGA Application requesting
the authority to place into effect new rate schedules that will decrease its annualized revenues
by $52.5 million. The PGA account is a deferral mechanism for over-and under-collections
and for realized savings on spot market gas purchases. If its Application is approved
PAGE 2 - PETITION FOR LEAVE TO INTERVENE AND COMMENTS OF
INTERVENOR NORTHWEST INDUSTRIAL GAS USERS
Intermountain states that customer rates will decrease on average by 24 percent. The
Application also proposes to promote rate stability by not altering Intermountain's weighted
average cost of gas (W ACOG) from its current level at this time. The Company requests an
effective date of July 1 , 2002.
NWIGU member companies that are customers of Intermountain will be
impacted by any outcome in this proceeding. These customers transport large quantities of
natural gas to serve their facilities. Therefore NWIGU has a direct and substantial interest in
the proceeding, and NWIGU's participation will not unduly broaden the issues.
II.
COMMENTS OF NWIGU
Intermountain seeks with this Application to pass through to each of its customer
classes a decrease in gas related costs resulting from: 1) a net decrease in costs for
Intermountain's natural gas interstate transportation; 2) an updated customer allocation of gas
related costs pursuant to the Company s Purchased Gas Cost Adjustment provision; and 3) the
inclusion of temporary surcharges and credits for one year relating to gas and interstate
transportation costs from Intermountains's deferred gas cost account. Application at 3-4. As
part of the Application, Intermountain also proposes to refund amounts generated from NPC
Case No. RP95-409 for the 13 month locked-in period from February 1 , 1996 to February 28
1997 and pass through additional surcharges incurred from NPC Case No. RP93-5 for the
locked-in period from April 1 , 1993 to October 31 , 1994 via individual industrial customer
direct billings of surcharges and credits.
NWIGU's concerns with the equitable resolution of these NPC refunds and surcharges
PAGE 3 - PETITION FOR LEAVE TO INTERVENE AND COMMENTS OF
INTERVENOR NORTHWEST INDUSTRIAL GAS USERS
from these historical time periods have been resolved with Intermountain as set forth in the
filing presented to the Commission. It is unfortunate that nearly a decade has passed before
customers know the fmal rate to be charged for pipeline transportation purchased so many
years before, but by tracking the refunds and surcharges in accordance with the individual
customer s usage and cost responsibility during these same time periods, Intermountain's filing
has reached an equitable and fair resolution of the issues, both with the 1993 surcharges and
the 1995 refunds.
NWIGU has reviewed the Company s filing and associated work papers and urges the
Commission to approve the permanent adjustments and temporary surcharges and credits for
the deferred gas costs as an appropriate and correct resolution of those accounts. NWIGU
supports the accuracy of the allocations to be made to individual industrial customer s bills for
Intermountain's LV-, T-, T-, T-3 and T-4 customers as representing the most equitable
resolution possible for the overpayments and surcharges stemming from each customer
historical use and cost responsibility during the relevant locked-in time periods.
WHEREFORE, NWIGU respectfully requests the Commission approve the proposed
permanent adjustment and proposed temporary surcharges and credits as filed, including the
direct billing and crediting of industrial accounts as proposed in the above-referenced docket.
PAGE 4 - PETITION FOR LEAVE TO INTERVENE AND COMMENTS OF
INTERVENOR NORTHWEST INDUSTRIAL GAS USERS
DA TED this 24th day of June , 2002.
Respectfully submitted,
(j4~
Edward A. Finklea
Chad M. Stokes
Counsel for the Northwest
Industrial Gas Users
Energy Advocates LLP
526 NW 18th Avenue
Portland, OR 97209-0220
Tel: [phone]
Fax: [phone]
PAGE 5 - PETITION FOR LEAVE TO INTERVENE AND COMMENTS OF
INTERVENOR NORTHWEST INDUSTRIAL GAS USERS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that I have this 24th day of June, 2002, served the foregoing
Intervention and Comments of the Northwest Industrial Gas Users upon all parties of record in
this proceeding, by mailing a copy thereof, properly addressed with postage prepaid, to:
Ms. Jean Jewell Michael E. Huntington
Commission Secretary Vice President
Idaho Public Utilities Commission Marketing & External Affairs
472 West Washington Street Intermountain Gas Company
PO Box 83720 PO Box 7608
Boise , ID 83702-5983 Boise, ID 83707
Mike McGrath Morgan W. Richards, Jr. ESQ.
Intermountain Gas Company Moffatt, Thomas, Barrett, Rock & Fields
555 S. Cole Road Chartered
PO Box 7608 PO Box 829
Boise, ID 83707 Boise, ID 83701
t!4~Chad M. Stokes
Edward A. Finklea
Counsel for the Northwest
Industrial Gas Users
Energy Advocates LLP
526 NW 18th Avenue
Portland, OR 97209-0220
Tel: [phone]
Fax: [phone]
e-mail: mail(j?)energyadvocates.com
PAGE 6 - PETITION FOR LEAVE TO INTERVENE AND COMMENTS OF
INTERVENOR NORTHWEST INDUSTRIAL GAS USERS