249717 ORI6INAL TO CITY CL6RK CI I 1 OF ST. PAUL COUNCIL 249���.�'�
OFF OF THE CITY CLERK FILE NO.
A�
N OLUTION-GENERAL FORM
.
PRESENTED BY
COMMISSIONE ATF
RESOLVED, The proper City officers are hereby
authorized to execute Petition of the City of Saint Paul
for Leave to Intervene in the matter of ATorthern Natural
Gas Company� Docket No. RP70-43, before the United States
Federal Power Commissiom for the purpose of opposing the
rate increased petitioned for by said Northern Natural Gas
Company and to present evidence looking toward a reduction
in the rates charged.
F PR0�6
Asst. Cor ration Counsel
� �� ��a
COUNCILMEN Adopted by the Co�ncil 19—
Yeas Nays
Butler `���� � � lg10
Carlson ved 19�
_..
Le�ine �,,,
�n Favor n
Meredith
, yor
Sprafka U ��,,
A gainat
Tedesco ���;
Mr. President, McCarty PUBLISHED ,,��L � $ ]97�
�
. , .
` ' . r 7 � �� ��
� �
UNITED SmATE� OF :�i�RICA
FEDERaL PUWER COrP'i1ISSI0N
Iii the Matter of
Docket Na . RP70-43
:Vorthern Natura"1 Gas Company
NOTICE OF' INTER�ENTION BY AND
PETITION OF CITY OF SAINT PAUL,
a Min.nesota rlixni.cipal Corporation,
FOR LEAVE TO INTERVENE
To sai_d Federal Power Commission:
Your Petitioner, City of Saint Paul , a Minnesota municipal
corporation, pursuant to Sec. 1.8 of the Rules of Practice and
Procedure of the Federal Power Commission and pursuant to 15 U.S.C.A. ,
� Ch. 15 B, Sec . 717 n (a) , respec�Li�tely, hereby intervenes in the
above entitled proceedin� and hereby petitions for leave to inter-
vene as a party intervener therein. Your Petitioner, at the out-
set, desires to iizform your Honorable Body that i�s desire to
participate herein would be on the basis that Petitioner could,
if desired, call witnesses , or retain the right of presentin�
independent evidenee therein, and heieby seeks the Order of your
Iionorable Body permitting intervention �or that purpose and �ar
the purpose of participating in the. hearings to the extent af
being presen�; i;hereat, being permitted to examine and cross-
examine witnesses therein and to pa�°ticipate generally tlierein
and i;o fiie brie�s with r.espect thereto to the extent that
Petiti.onEr deenis the same necessary or appropri_ate . Tha�; s�.id
I��iter. veizer-Pe titione�, City of' Sd�.nt P�.ul , hereby shows and
alleges in support o� sizch in�;ex�e:tition ai�d petition tYiere�or. :
I, I. .
That said Petitioner, City of Saint Paul, is a municipal
c orporation and a City of the ! �first class of the State of Minnesota,
organized and existing under and by virtue of the Constitution and
Laws of said State and go verned by a Home Rule Charter and the
Statutes of said State of Minnesota supplemental thereto , and is
substantially interested in and affected by the matters under
consideration in said proceed.ings .
II.
� That said Yetitioner, ;City of Saint Paul, is a Niinnesota
municipality, having and exercising jurisdiction to regulate
� rates and charges for the sale of natural gas to consumers
within its corporate limits, by virtue of its said Home Rule
Charter, Chapter 286, Session La�,�s of �iinnesota for 1y35,
5upplemental Laws of said State and ordinatices of said Petitioner,
City of Saint Paul , heretofore and now opera.tive as enacted pur--
suant to said Home Rule Charter and said State Laws.
III .
That Northern States Power Company, a Minnesota corporation,
during all the times material hereto has been and now is engaged
as a public utility in the business oF distributing natural gas
for domestic , commercial and industrial use to consumers in said
City of Saint Paul , Minnesota, subject to regulation by said City
of Saint Paul in re spect of the rates and charges therefor and the
services involved. .
_ -2-
IV.
Tha`t said Northern States Power Company is entirely
dependent upon said NortYiern Natural Gas Company for its supply
of natural gas in said City of Saint Paul for said public utility
purposes and has necessarily contracted. with said Northern Natural
Gas Company therefor to deliver a contract demand of approximately
131, 000 mcf per day of natural gas .
V.
The communications to be addressed to said Petitioner in
the above entitled matter should be addressed to the following :
Charl.es P. McCarty, Mayor of the City of Saint Paul ,
347 City Hall and Court House
Saint Paul , Minnesota 55102
Leonard Levine , Commissioner of Public Utilities ,
216 �ity Hall and Court House
Saint Paul, Minnesota 55102
Daniel A. Klas , Corporation Counsel
Thomas J. Stearns , Assistant Corporation Counsel
316 City Hall and Court House
5aint Paul , Minnesota 55102
VI.
, That said \Torthern States Power Company is a principal
re-sale customer of said Northern Natural Gas Company and regu-
larly purchases approximately ten percent of the gas sold by said
Northern Natural Gas Company to the latter' s jurisdictional
utility customers . That in the City of Saint Paul said Norther.n
Sta.tes Power Company has in excess of 90, 000 natural gas consumer
customers, of which more than 50 percent are space heating con-
sumer customers . That the price ch�rged by said 1�?orthern Natural
Gas Company therefore is a matter of vital and substantial interest
^�_
tu said Petitioner , City oi Saint Paul , and it�s residents who ,
together with said Petitioner, City of Saint Paul , are natural
gas consumer customers of said Northern States Power Compan3T.
That said Northern States Power Company, during all times material
hereto, has operated and does now operate as such utility, for
said purposes within said City of Saint Yaul , solely by virtue
of pertinent franchise permits granted unto said Company, by
ordinances of said City enacted by its Council and accepted by
said Company, pursuant to said Home Rule Charter and said State
Laws , whereunder and whereby, among other things , said City
;
has reserved the righ� therefor and has regulated and does now
reserve the right therefor and regulate the rates and charges
for natural gas supplied by said Company to natural gas consumer
customers within said City. That said rates and ch arges there-
under are based upon the cost of said natural gas �o said
Northern 5tates Power Company, and other expenses of said
Company, and are adjusted from time to time on the bases of
such cost of natural gas a.nd such other operation expenses of
s aid Company.
VII.
That Petitioner has been i.nformed by personnel of the
Northern States Power C�ompany that on June 26 , 1970, Northern
tendered for filing proposed changes in its FPC Gas Tariff,
Third Revised Volume No . 1, to become effective June 27 , 1970,
which changes, amor_g other things , reflect:
(a) Increased charges for jurisdictional sales and
_rf_
services by approximately �37, 950,�398 annually,
based on sales for the 12-mon�h period ending
February 28, 1970, as adjusted, which changes
would increase the annual town border costs of
gas to NSP (Minnesota) by about �4, 438,618 and
for NSP (Wisconsin) by about �253, 908 ;
(b) A new purchased gas cost adjustment clause ;
(c) A proposal to commence �a normalization method for
accounting and rate-ma,king purposes for the cal-
endar year 1971 ;
(d) Inclusion in the rate base of the investment in
,
� advance payments required to obtain a new gas
supply in Canada and Montana for the purpose of
meeting the growth requirements for Northern' s
customers ; and
(e ) Miscellaneous changes relatzng to procedure for
curtailment of service, procedure for requesting
additiona]_ gas service and sales , apportionment
of limited increases in contract demand , and
lateral line e�tension policy.
The principal reasons stated by Northern for the increase
in rate levels , among other things , are : increased revenues
needed to pravide a return of 8. '75�0 on rate base , increased
cost of gas supplies, increased taxes , and increased cost of
construction, wages , supplies , and expenses .
_�
.
VIII .
That because of the limit of inform ation available to
your Petitioner, Petitioner cannot determine at this time its
position with respect to the aforesaid docket. However, it is
apparent that your Petitioner has a direct and substantial
economic interest in these proceedings not adequately repre-
sented by existing parties and which may be adversely affected
by the Commission' s action herein. .
j�IEREFORE, your Petitioner City of Saint Paul requests
that your Honorable Body issue its Order permitting Petitioner
to intervene in the above entitled proceedings , with leave to
� call witnesses , present independent evidence , examine and cross-
examine witnesses , to participate generally therein and to file
briefs therein �to the extent that your Petitioner deems the
same necessary or appropriate with respect thereto .
Dated at Saint Paul , Minnesota, this 16th day of July,
� 1970. .
Respectfully submitted,
CITY OF SAINT PAUL
� �; s',
� �'� �� �� , , �,�~ �
B . �� �.�.-?��.�. �-�, �...� -_�
Y'
Daniel A, as Charles �P. McCar�y, r1�:yor
Corporati ounsel 347 City Hall and�`��,Co�,t� House
Sai Pau , M' ta 55102
r
Thomas J. ' earns
Assistant orporation Counsel Le nard Le ine
City of Saint Paul Commissioner of Public Utili�;ies
316 City Ha.11 and Court I�ouse 216 City Hall and Court House
Sain�t Paul , Minnesota 55102 Saint Paul , Minnesota 55102
A1;torneys for the City
of Saint Paul , Minnesota
-6-
, i
STATE OF MINNESOTA) �,
) ss . ,
COUNTY OF RAMSEY ) '�
LEONARD LEVINE, being Ifirst duly sworn, upon oath deposes
and says that he is the Commissioner of Public Utilities of the
City of Saint Paul , the Petitioner in the above entitled matter;
� that he has read said Petition and knows the contents thereof,
and that the same is true except as. to those matters therein
stated on information and belief, and to those matters , he
believes the same to be true . �
. ;!
;
, ;
,r
, r�
Le n r e� e
Subscribed and sworn to before me
this 16th day of July, 1970
� � n �-.
� �__ C_^i ����./
ALBERT B. OLSON.
Notary Pubiic, Ramsey County, Minn.
My Commission Expires Oct. 27, 1973.
(SEAL)
_7_
CERTIFICATE OF SERVICE
I hereby certify that I have this day served the fore-
going document upon the following named parties of record in
this proceeding by mailing a copy thereof properly addressed
to each of the parties named or, where indicated, to the attorney
of record of a party named:
PartY Attorneys Served
Northern Natural Gas Company 'F. Vinson Roach, General Counsel
Northern Natural Gas Company
2223 Dodge Street
Omaha, Nebraska 68102
Walter Gallagher
Gallagher, Connor & Boland
The Bowen Building
821 - 15th St. N.W.
, Washington, D. C. 20005
Northern States Power Company A. R. Renquist
Northern States Power Comapny
414 Nicollet Mall
Minneapolis , Minnesota 55401
. ��
• Thomas Stearns
Subscribed and sworn to before me
this 16th day of Ju1y, 19'70.
Betty J. L s en
Notary Public , Ramsey Co . , Minn.
My commission expires Apr. 8, 19'72.
(5EAL)