20180425Late-Filed Petition to Intervene - Intermountain Gas.pdf

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CABLE HUSTON,.,RECEIVTD
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JoNATHAN J. CaVeNnCII
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[e-mail]
www.cablehuston.com
April25,20l8
VrA FrosRAL EXPRESS
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise,lD 83702
Re: Case No. GNR-U-18-01
Dear Ms. Hanian:
Please find enclosed for filing with the Commission the original of the following
pleading (along with 7 copies):
I . Late-Filed Petition to Intervene of Alliance of Western Energy Consumers
Copies of the Petition are being transmitted to the service list via electronic mail. Should
you have any questions, please give me a call. Thank you.
Sincerely
It€-
J. Cavanagh
Suite 2000, I 001 5W tifih Avenue Fortland, Oegon 972&-t I 16 . Phone: [phone] " Fax: 503.224,31 76 . www.rablehuston.(om
JJC:lms
Enclosure(s)
Jonathan J. Cavanagh, ISB No. 8609
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: (503) 224-317 6
j cav anagh@c ab I ehuston. c o m
Attorneys for Alliance of Western Energy Consumers
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
ORIGINAL
IN THE MATTER OF THE
INVESTIGATION INTO THE
IMPACT OF FEDERAL TAX CODE
REVISIONS ON UTILITY COSTS
AND RATEMAKING
CASE NO. GNR.U.18-01
LATE.F'ILED PETITION TO
INTERVENE OF ALLIANCE OF
WESTERN ENERGY CONSUMERS
Pursuant to Rules 7l through 75 of the Idaho Public Utilities Commission
("Commission") Rules of Procedure, IDAPA 31.01.01 .071-.075 ("Rules"), Alliance of Westem
Energy Consumers ("AWEC") hereby submits this Petition to Intervene ("Petition") in the
above-captioned proceeding. This Petition is being filed after the March 6th deadline for filing
petitions to intervene set forth in Commission Order No. 33991. Pursuant to Rule 73, AWEC
sets forth below the substantial reason for the delay in this filing. AWEC has a direct and
substantial interest in these proceedings, and respectfully requests that the Commission grant its
intervention.
The name and address of AWEC as an intervenor in this proceeding is:
Edward A. Finklea
Director of Natural Gas
Alliance of Western Energy Consumers
545 Grandview Drive
Ashland, OR 97520Phone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
PAGE 1 - LATE-FILED PETITION TO INTERVENE OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
Jonathan J. Cavanagh from the law firm Cable Huston LLP will represent AWEC in this
proceeding. In addition to Mr. Finklea, 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:
Jonathan J. Cavanagh
Cable Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97204-1136
Telephone: [phone]
Facsimile: [phone]E-Mail: [e-mail]
l. AWEC is a non-profit association whose members are large energy consumers
with major facilities in the States of Idaho, 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, aerospace, and healthcare
providers. AWEC provides an informational service to its members and participates in various
regulatory matters that affect member interests. On March 31,2018, Northwest Industrial Gas
Users ("NWIGU") merged into the Industrial Customers of Northwest Utilities ("ICNU") and
ICNU changed its name to AWEC effective April 1, 2018. The advocacy and work previously
performed by NWIGU now occurs as part of AWEC. AWEC member companies purchase
sales and transportation services from local distribution companies, including Intermountain Gas
Company ("Intermountain").
2. On January I7,2018, the Commission opened this case to investigate whether it
should adjust utilities' rates and charges to reflect changes in the corporate income tax rate and
revenue requirement reductions caused by the 2017 federal Tax Cuts and Jobs Act, which
became effective January 1,2018.
PAGE 2 - LATE-FILED PETITION TO INTERVENE OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
3. Because AWEC member companies purchase sales and transportation services
from Intermountain, AWEC and its members will be impacted by any decision in this proceeding
and therefore have a direct and substantial interest in this investigation. AWEC requests
permission to participate in this proceeding as a party as its interest may arise.
4. 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.
5. AWEC's attorney became aware of this filing after the deadline to intervene had
passed. AWEC typically receives notice of the initiation of natural gas proceedings by
monitoring new dockets related to Intermountain. AWEC did not see the initial filing for this
docket because this case has been handled as a multi-utility generic proceeding instead of a case
with an Intermountain gas specific case number. AWEC therefore asserts there is good cause to
grant its late-filed Petition. AWEC's intervention and participation will not prejudice any of the
current parties in the proceeding.
6. Because this Petition to intervene is late, AWEC understands that it will be bound
by orders and notices earlier entered as a condition of granting the untimely petition.
7. AWEC contacted Intermountain about this late-filed intervention, and
Intermountain does not object.
PAGE 3 - LATE-FILED PETITION TO INTERVENE OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
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.
Dated ttis Suyof April2018.
Respectfully submitted,
J. Cavanagh, ISB No. 8609
Huston LLP
1001 SW Fifth Ave., Suite 2000
Portland, OR 97 20 4 - | 13 6
Telephone : [phone]
Facsimile: (503) 224-3 17 6
j cav anagh@c ab I ehu sto n. c om
Attorneys for Alliance of Western Energt
Consumers
PAGE 4 . LATE-FILED PETITION TO INTERVENE OF ALLIANCE OF WESTERN
ENERGY CONSUMERS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on ,n"E{{^rof April2018 I caused an original and seven (7)
copies of the foregoing to be served upon:
Diane M. Hanian, Secretary
Idaho Public Utilities Commission
472 W. Washington Street
Boise, ID 83702
by mailing via Federal Express the same to the above-named at the last known address(s) as set
forth above and sending a copy via electronic mail to the email addresses below.
Michael P. McGrath
Director, Re gulatory Affairs
Intermountain Gas Company
PO Box 7608
Boise, ID 83707
mike. mc [e-mail]
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
prestoncarter@sivenspursley. com
Edward A. Finklea
Director of Natural Gas
Alliance of Western Energy Consumers
545 Grandview Drive
Ashland, OR 97520
efi nklea@awec. solutio(rs
J J
PAGE 1 _ CERTIFICATE OF SERVICE