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Home My WebLink About20221209Petition to Intervene.pdfJiL C E IVED , :r:7 [[{j -9 Al{ ll: I 5Chad M. Stokes (OSB No. 004007) Cable Huston LLP 1455 SW Broadway Suite 1500 Portland, OR 97201 Telephone: (503) 224-3092 cstokes@cabl ehuston.com Attorneys for Alliance of lilestern Energy Consumers BEF'ORE THE IDAHO PUBLIC UTILITIES COMMISSION .i i'Ljit-l S SICN IN THE MATTER OF INTERMOUNTAIN GAS COMPANY FOR THE AUTHORITY TO CHANGE ITS RATES AND CHARGES FOR NATURAL GAS SERVICE IN THE STATE OF IDAHO CASE NO.INT.G.22.O7 PETITION TO INTERVENE OF ALLIANCE OF WESTERN ENERGY CONSUMERS Pursuant to Rules of ProcedureTl-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 35 l9 NE l5th Avenue #249 Portland, OR97212 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. I Chad M. Stokes Cable Huston LLP 1455 SW Broadway Suite 1500 Portland, OR 97201 Telephone: (503)224-3092 E-Mail: cstokes@cablehuston.com AWEC respectfully requests that any communications to AWEC also include a courtesy copy to Brad Mul I ins ; brmu I I ins @mw analytics.com. AWEC is a non-profit association consisting of approximately 40 end users of natural gas with major facilities in the States of ldaho, 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 maffers 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 December l,2022,lntermountain filed a request to increase the rates and charges for natural gas distribution service in the state of Idaho effective on or after January 1,2023. Intermountain proposes to increase the revenue collected through natural gas rates by approximately $l 1.3 million, which equates to a margin revenue increase of approximately 10.3%. 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, and AWEC intends to participate in all respects herein as a party as its interest may arise. ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE. 2 AWEC's participation in this proceeding will assist the Commission in resolving the issues, and will not unduly broaden the issues or delay the proceeding. 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 9n day of December 2022. Respectfully submitted, @ Chad M. Stokes CABLE HUSTON LLP Attorneysfor Alliance of Western Energt Consumers ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE. 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the fth day of December 2022I caused an original and seven (7) copies of the foregoing to be served upon: Jan Noriyuki Idaho Public Utilities Commission 11331 W. Chinden Blvd Building 8, Suite 201-A Boise,ID 83714 by mailing the same to the above-named at the last known address(s) as set forth above and mailing a copy to the addresses below. Preston N. Carter Givens Pursley LLP 601 W. Bannock St. Boise,ID 83702 prestoncarter@givenspursley.com stephaniew@given spursley.com Lori A. Blattner Director, Regulatory Affairs Intermountain Gas Company P O Box 7608 Boise,ID 83707 ffiM Chad M. Stokes Cable Huston, LLP Attorneysfor Alliance of Western Energt Consumers ALLIANCE OF WESTERN ENERGY CONSUMERS' PETITION TO INTERVENE.4