20030516Jeff Brooks Petition to Intervene.pdf

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JefITey C. Brooks
Advanced Energy Strategies, Inc.
1027 E. Cayman Drive
Meridian, ill 83642
[phone]
brooksjc1~aol.com
R~CEIVEO mFILED
2003 MA Y 15 PH 3: 25
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UTILITIES COt1MISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY
FOR AUTHORITY TO INCREASE ITS
RATES FOR SERVICE
CASE NO: INT-03-
JEFFREY C. BROOKS dba ADV ANCED
ENERGY STRATEGIES, INC.
PETITION TO INTERVENE
Advanced Energy Strategies Inc. (AES) petitions this Commission for leave to intervene
in the above entitled proceeding pursuant to Rules 72 and 73 of the Commission s Rules of
Practice and Procedure, IDAPA 31.01.01.072 and -073. In support ofthis Petition, AES states
as follows:
1. JefITey C. Brooks is private citizen and principal of Advanced Energy Strategies
Inc. (AES). AES is an independent business that specializes in energy efficiency, and energy
related issues. AES has provided comments to this Commission in previous cases on behalf of
public interest groups and as a concerned citizen, and in this matter represents the interests of
residential and small commercial customers oflntermountain Gas Company (IGC).2. AES has a direct and substantial interest in these proceedings because the
Commission s decision may, directly or indirectly, affect the cost of natural gas supplied to
residential and small commercial retail customers of Intermountain Gas Company, and it is
unknown, at this time, whether any other third party entity has entered into these proceedings to
participate on behalf of residential and small commercial retail customers of I GC, who typically
have no representation and are not organized or funded to provide alternative representation.3. AES is unable to state its position at this stage of the proceedings, and therefore
seeks to intervene for the purpose of receiving documents, examining witnesses, and otherwise
participating as its interest may appear.4. AES' s representative for the purpose of service of pleadings and other written
materials is:
JefITey C. Brooks
Advanced Energy Strategies, Inc.
1027 E. Cayman Drive
Meridian, ill 83642
[phone]
brooksic 1 ~aol. com (email)
AES'S PETITION TO INTERVENE -
WHEREFORE, AES respectfully requests that the Commission grant this Petition to
Intervene and authorize AES to participate in the above entitled proceedings with full rights as a
formal party.
Dated this I ~1fj day of May, 2003.
Strategies, Inc.
AES'PETITION TO INTERVENE--
CERTIFICATE OF SERVICE
7t-
I HEREBY CERTIFY that on the day of May 2003, I caused to be served a true and
correct copy of the forgoing by the method indicated below, and addressed to the following:
Jean Jewell ./
Idaho Public Utilities Commission
472 W. Washington Street
O. Box 8372
Boise, ID 83720-0074S. Mail Fax By Hand
Michael Huntington
Intermountain Gas Company
555 S. Cole Road
O. Box 7608
Boise, ID 83707
S. Mail Fax By Hand
M. W. Richards Jr.
Moffatt Thomas Barrett Rock & Fields CHTD
US Bank Plaza Bldg 10th Floor
101 S. Capitol Blvd.
Boise, ID 83702
S. Mail Fax By Hand
AES'S PETITION TO INTERVENE--
E mail
Email
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