20161005Petition to Intervene.pdf

Ms. Jean Jewell
Secretary
Idaho Public Utilities Commission
4 72 W. Washington
Boise, ID 83 702
27 September, 2016
RE: Case INT-G-16-02 Intermountain Gas Company's 2016 General Rate Case
Dear Ms. Jewell,
Enclosed, pleas find an original and seven (7) copies of Federal Executive Agencies' Petition to
Intervene in the above reference proceeding.
Respectfully, ,/,?"~.a-­
ANDREW J. ~i ,{1aj, USAF
AFLOA/JACE-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
[phone]
Andrew. [e-mail]
Attorney for Federal Executive Agencies
BEFORE THE IDAHO PUBLIC UTITLITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF )
INTERMOUNTAIN GAS COMPANY'S )
APPLICATION TO CHANGE ITS RA TES AND )
CHARGES FOR NATURAL GAS SERVICE )
IN THE STATE OF IDAHO )
) _________________ )
Case Nos. INT-G-16-02
FEDERAL EXECUTIVE AGENCIES'
PETITION TO INTERVENE
Pursuant to Rules of Practice and Procedure of the Idaho Public Utilities Commission,
Federal Executive Agencies, ("FEA"), through its undersigned counsel, files its Petition to
Intervene in the above captioned case. In support thereof, FEA states as follows:
1. The FEA represents numerous federal entities within the area serviced by Intermountain
Gas Company ("the Company"). Mountain Home Air Force Base represents a major customer of
the Company.
2. The FEA notes that the filing of this Motion to Intervene is untimely, as the deadline to
file intervention in this case was 23 September, 2016, pursuant to The Notice of Application
Notice of Intervention Deadline, Order No. 33595, dated 9 September 2016. Pursuant to Rule
073 of the Commission's Rules of Practice and Procedure, FEA states that it has substantial
reasons for the delay and that our filing is still greater than 14 days before the hearing or pre­
hearing in this case. Additionally, FEA 's late filing will not cause disruption, prejudice to
existing parties, or undue broadening of the issues.
3. FEA was initially notified of the above-captioned case on 16 September 2016. The
attorney's for the FEA often intervene in various state jurisdictions to represent FEA's interests
across the country. Many times our attorneys are not licensed in those specific jurisdictions.
Therefore, we must reach out to other attorneys within the air force to sponsor us Pro Hae Vice.
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FEA was able to partner with the attorney in this case that sponsored us Pro Hae Vice on 22
September 2016. FEA had the Motion to Intervene drafted, as well as the Motion for Limited
Admission Pro Hae Vice 23 September 2016. However, we were unable to secure the funding
needed to cover the cost of the Pro Hae Vice motion on 23 September 2016. Obtaining necessary
funding from the federal government can take some time, especially during the fiscal year close
out, which is on 30 September 2016. Therefore, we wanted to ensure that the check had been
made and sent to the Idaho State Bar at the time that our sponsoring attorney signed the Motion
for Limited Admission Pro Hae Vice.
4. The FEA will be substantially affected by any order rendered by the Commission in this
case. The Department of Defense has been delegated authority by the U.S. General Services
Administration pursuant to section 205 (d) of the Federal Property and Administrative Services
Act of 1949, as amended (40 U.S.C. 485(d)) to represent consumer interests of the executive
agencies of the Federal Government.
5. Granting FEA intervention will not unduly broaden the issues presented by the
application in this matter, and therefore, FEA is entitled to intervention pursuant to Rules 071-076
of the Commission's Rules of Practice and Procedure, IDAPA 31.01.01.071-076
WHEREFORE, FEA respectfully request that it be granted intervention in the above-
referenced matter.
Please provide copies of all pleadings and address all communication with regard to this
matter to:
Federal Executive Agencies
Andrew J. Unsicker
Lanny L. Zieman
Natalie A.Cepak
Thomas A. Jernigan
Ebony M. Payton
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AFLONJA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
[phone]
[e-mail]
Lanny.Zieman. [e-mail]
Natalie. [e-mail]
[e-mail]1
[e-mail]
RESPECTFULLY SUBMITTED THIS 27th day of September, 2016.
drn J. Unsicker, Maj, USAF
AFLONJA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
[phone]
Andrew. [e-mail]
Counsel for FEA
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that a true and correct copy has been furnished by electronic mail
(e-mail) and/or U.S. Mail this 27th day of September, 2016 to the following:
Idaho Public Utilities Commission Clearwater Paper Corporation
Jean Jewell Clo Peter Richardson, Esq.
472 W. Washington Street Richardson Adams
P.O. Box 83720 PLLC 515 N. 27th Street
Boise, ID 83 720 P.O. Box 7218
J ean.J [e-mail] Boise, ID 83702
[e-mail]
Northwest Industrial Gas Users Givens Pursley LLP
Chad Stokes Michael Creamer
Tommy Brooks 601 W. Bannock Street
Cable Huston, LLP Boise, ID 83 702
1001 S. W. 5th, Suite 2000 [e-mail]
Portland, OR 97204
[e-mail]
[e-mail]
Federal Executive Agencies
Andrew J. Unsicker
Lanny L. Zieman
Natalie A.Cepak
Thomas A. Jernigan
Ebony M. Payton
AFLOA/JA-ULFSC
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
[phone]
Andrew. [e-mail]
Lanny.Zieman. [e-mail]
Natalie. [e-mail]
[e-mail]
[e-mail]
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