20160922Petition to Intervene.pdf

Peter Richardson ISB #3195
Gregory M. Adams ISB #7454
RICHARDSON ADAMS, PLLC
515 N. 2J1h Street
Boise, Idaho 83 702
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for the Amalgamated Sugar Company LLC
RE CE IVED
BEFORE THE
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF INTERMOUNT AIN )
GAS COMPANY'S APPLICATION TO )
CHANGE ITS RA TES AND CHARGES FOR )
NATURAL GAS SERVICE IN THE STATE OF)
IDAHO )
)
) _________________ .)
CASE NO. INT-G-16-02
PETITION TO INTERVENE
OF THE AMALGAMATED SUGAR
COMPANYLLC
COMES NOW, The Amalgamated Sugar Company, LLC, hereinafter referred to as
"Intervenor," and pursuant to this Commission's Rules of Procedure, Rule 71 IDAPA
31.01.01.71 and pursuant to that Notice of Application and Notice oflntervention Deadline
issued by the Commission on September 9, 2016, and hereby petitions the Commission for leave
to intervene herein and to appear and participate herein as a party, and as grounds therefore states
as follows:
1. The name and address of this Intervenor is:
The Amalgamated Sugar Company LLC
Scott Dale Blickenstaff
1951 S. Saturn Way, Ste. 100
Boise, Idaho 83 702
Telephone: [phone]
[e-mail]
Copies of all pleadings, discovery and other documents should be served on Mr.
Blickenstaff and Richardson Adams, PLLC at the addresses noted above.
2. This Intervenor, The Amalgamated Sugar Company LLC is a Delaware
Corporation duly qualified to do business in the State of Idaho. Amalgamated Sugar Company
receives natural gas utility services from lntermountain Gas Company at all three of its Idaho
sugar refinery operations located in Nampa, Twin Falls and Mini Cassia. Amalgamated Sugar
claims a direct and substantial interest in this proceeding in that its costs for said natural gas
utility services will be affected by the outcome of this proceeding.
3. This Intervenor, intends to participate herein as a party, and if necessary, to
introduce evidence, cross-examine witnesses, call and examine witnesses, and be heard in
argument. The nature and quality of evidence which this Intervenor will introduce is dependent
upon the nature and effect of other evidence in this proceeding.
4. Without the opportunity to intervene herein, this Intervenor would be without any
means of participation in this proceeding which may have a material impact on its cost for
natural gas services.
5. Granting this Intervenor's petition to intervene will not unduly broaden the issues
nor will it prejudice any party to this case.
WHEREFORE, The Amalgamated Sugar Company LLC respectfully requests that this
Commission grant its Petition 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, present argument and to otherwise fully participate in these proceedings.
Amalgamated Sugar Intervention -INT-G-1 6-02 2
DATED this 22nd day of September, 2016.
P;JL Oi ~
PJ er J. Richardson
RICHARDSON ADAMS, PLLC
Attorneys for the Amalgamated Sugar
Company LLC
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of September, 2016, a true and correct copy of the
within and foregoing PETITION TO INTERVENE BY THE AMALGAMATED SUGAR
COMPANY LLC was served by Electronic and U.S. Mail:
Michael P. McGrath
Director, Regulatory Affairs
Intermountain Gas Company
555 S. Cole Road
PO Box 7608
Boise, ID 83 707
[e-mail]
Chad M. Stokes
Tommy A. Brooks
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1 136
[e-mail]
[e-mail]
Benjamin J. Otto
Idaho Conservation League
710 N. 6th Street
Boise, Idaho 83 702
[e-mail]
Amalgamated Sugar Intervention -INT-G-1 6-02 3
Ronald L. Williams
Attorney for Intermountain Gas Company
1015 West Hays Street
Boise, Idaho 83702
[e-mail]
Michael C. Creamer
Givens Pursley, LLP
601 West Bannock Street
Boise, Idaho 83 702
[e-mail]
Brad M. Purdy
2019 N. 17th Street
Boise, Idaho 83 702
[e-mail]
F. Diego Rivas
NW Energy Coalition
1101 8th Ave.
Helena, MT 59601
[e-mail]
Edward Finklea
Northwest Industrial Gas Users
545 Grandview Drive
Ashland, OR 97520
[e-mail]
I /? -·J tJ 1} By: t {,_ __ .{:I:__,,(__,,~
Kandi Walters, Administrative Assistant
Richardson Adams, PLLC
Amalgamated Sugar Intervention -INT-G-1 6-02 4