239932 ORIGIN'L TO CITY CLERK /�,����/ ,
CITY OF ST. PAUL couNCi� ^� ''•d
OFFICE OF THE CITY CLERK FILE NO. ,
' CO CIL RESOLUTION—GENERAL FORM
PRESENTED BY ! �j C� � '
COMMISSIONE H _/ -� DATF � � � � � `� i
RESOLVED, That the Coun.cil of the City of Saint Paul
hereby authorizes, ratifies and approves _the action of
the Corporation Counsel in filing a Notice and Petition �
of Intervention by the City of Saint Paul in the matter
of Northern Natural Gas Company, Docket No. RP69-1, _a
copy. of said Notice and Petition of Intervention of �
the City of Saint Paul being attached hereto. and incor-
, porated herein by reference.
' �
�
Fa 1�A—A PROVED �
� Asst. Corporation Co sel�
AUG 2 2 1968
COUNCILMEN Adopted by the Council 19—
Yeas Nays �qUG 2 � 196�
n ,
c�"aL auvu
Dalglish � Approvec� 19—
Meredith Tn Favor
Peterson �
Sprafku � Mayor
Tedesco A gainst
Mr. President, Byrne PUBLISHEr AUG 2 4 1968
�O
i
. _ _� . , - .. - � ���932 '
� UNITED STATES OI' A1�iERICA
FEDERAL POWER COMMISSION �
In the Matter of �
� Docket No. ftP69-1
Northern Natural Gas Company �
� .
� NOTICE OF INTEftVENTION BY AND
• PETITION OF CITY OF SAINT PAUL,
- a Minnesota Municipal Corporation,
� FOR INTERVENTION IN THE
ABOVE CAPTIONED PROCEEDING _
To said Federal Power Commission: �
Your Petitioner, City of Saint Paul ,• a Minnesota municipal
corporation, pursuant to Seco 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) , as amended, hereby inter-
venes in the above entitled proceeding. That said intervenor,
City of Saint Paul, hereinafter referred to as Petitioner herein,
hereby represents and shows to the Commission: -
� Ie
� That said Petitioner, City of Saint Paul, is a municipal
� corporation and a city of the first class of the State of Minne-
sota, organized and existing under and by virtue of the Consti-
tution and Laws of the State and governed 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 proceedings. "
. � • , - -
. IIe
. That said Petitioner, City of Saint Paul, is a Minnesota •
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 Laws of Minnesota for s935, Sup-
plemental Laws o�f said State and ordinances of said Petitioner,
City of Saint Paul , heretofore and now operative as enacted
pursuant to said Home Rule Charter and said State laws. .
. IIIe
That� Northern States Power Company, a Minnesota corpora-
tion, 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 .respect to the rates
and charges therefor and the services involved.
� Iv� -
. That said Northern States Power Company is entirely de-
pendent upon said Northern 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. -
• Vo
That�' the Northern States Power Company (Minnesota) and
the Northern States Power Company (Wisconsin) have heretofore
filed, in the above captioned proceedings, Petitions to Intervene
� herein. �
. . 2
VIa
- That the communications to be addressed to said Petitioner .
in the above entitled matter should be addressed to the follow-
ing:
. Thomas R. Byrne, riayor of the City of Saint Paul
34� Court House
. Saint Paul, riin.nesota 55102
Robert F. Sprafka, Commissioner of Public Utilities
. • 216 Court House
Saint Paul , Minnesota 55102
Joseph P. Summers, Corporation Counsel
Robert Ee 0' Connell , First Assistant Corporation Counsel
316 Court House �
Saint Paul, Minnesota 55102 �
� VIIo
That said Northern States Power Company is a principal
resale customer of said Northern Natural Gas Company and regu-
larly purchases approximately ten per cent of the gas sold by
said Northern Natural Gas Company to the latter' s j�urisdictional
utility customers. That in the City of Saint Paul said �Torthern.
States Power Company has in excess of 90,000 natural gas con-
sumer customers, of which a substantial portion are space heat�
ing consumer customers. That the price charged by said Northern
- Natural Gas Company therefore is a matter of vital and substan-
�ial interest to said Petitioner, City of Saint Paul, are natural
gas consumer customers of said Northern States Power Company.
� 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 Paul, �
solely by virtue of pertinent franchise permits granted unto
• � 3 . _
r ,
said Company by orclinances 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 right 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 charges
thereunder are based upon the cost of said natural gas to said
Northern States Power Company, and other expenses of said Com-
pany, and are adjusted from time to time on the bases of such
cost of natural gas and such other operation expenses of said
Company. �
� � ' VIII. �
Petitioner has been informed by personnel of the Northern
States Power Compan.y that on July 26, 1968 Northern tendered
for filing in this proceeding proposed changes in its FPC Gas
Tariff, Second Revised Volume No. 1, to become effective on
� , September 10, 1g68, which changes would increase charges for
jurisdictional sales by �17, 391, 473 per year, based upon sales
for the 12-month period ending March 31, 1968. Such proposed
changes would increase the annual town border cost of gas to
NSP (Minnesota) by about �2,044, 178 and for NSP (Wisconsin) by.
about �112, 802. . � � _
_ � IX.
� Petitioner in this proceedings is particularly interested,
' among other things, in the matter of Northern' s sales and
. revenue estimates, cost allocations including allocations
�
• 4
{
, ° c . - ; - '
� F
between jurisdictional and "nonjurisdictional customers, cost of
service, test year, and rate design. It is Petitioner' s position.
that Northern must sustain the burden of proof that its proposed
increased rates and charges are just, reasonable, and lawful.
. X. .
Petitioner has been informed by personnel of the Northern
States Power Company that the time for filing petitions in inter-
vention in the above captioned matter has been fixed by your
honorable body to be on or before August 22, �968. :
XI. �
The Petitioner requests that the Commission suspend the
operation of the proposed rate increases for the maximum period
of five months from September 10, 1g68, pursuant to the Natural
Gas Act, and that' it order an early hearing concerning the law-
fulness of the proposed increased rates. It is exceedingly im-
� portant that a decision on all issues be reached as soon as
possible in order to avoid or minimize the imposition of the -
burden of any unlawful price increases on consumers of gas. "'•
, WHEREFORE, the Petitioner requests that an order be
entered: • .
(1) Suspending the operation of Northern' s proposed
� rate increases as requested above;
(2) Noticing this matter for a formal hearing or hear- -
ings on all issues at the earliest practicable
date; and
(3) Permitting the Petitioner to intervene, with leave .
to� present evidence, examine and cross-examine .
witnesses, and to participate generally therein. .
: . � 5 � . .
r •
Dated at Saint Paul , Min�esota, on this 21st day of August ,
�g6s. .
, , Respectfully submitted,
CITY OF SAINT PAUL
� ' . , '
- ` - L�-� �l�Y/"�'� �L.
_, . �
� � ' Robert F. Peterson
. . Acting Mayor .
, 347 Court House
� Saint Paul , Minnesota 55102
"�� (�
, �_; .
� � � � ��,\_� ��_ �`�,�-�. '�'�'`� a--�
Robe"rt F. Sprafka,� Commissioner
� Department of Public Utilities
� 216 Court House `.)
Saint Paul , Minnesota 55102
i
JOSE P. S ERS
Corporatio Counsel ' � _
�I� J � / .
:��� � �''"`��
ROBERT E. 0'CONNELL
First �Assistant Corporation
Coun.sel � . ' _
� Attorneys for Petitioner ,
6
� •. Y . C
e �
d
STATE OF MINNESOTA .
ss.
COUNTY OF RA1�iSEY
_ROBERT F. SPRAFKA, being first duly sworn according to law,
. states that he is the Commissioner of the Department of Public
� Utilities of the City of Saint Paul, Minnesota; that he has
read the foregoing document and is �amiliar with the contents
thereof; that he has executed the same for and on behalf of said
City of Saint Paul with full power and authority so, to do; and
that the facts set forth therein are true and correct to the
best of his knowledge, information and belief.
�•
�.. �
�' � • ,
�� ,� �- � �-,� ` ��.����,
, ' `--�' Robert F. Sprafka�
� ,'
Subscribed and sworn to before me, J
a Notary Public, this 21 st day of
August , 1g68. � _
���a� • .
Notary Public, Ramsey County, Minnesota.
My commission expires �
BF�'7: CASSEN
• ' Hotary Pub�c,Ramse}�County, MMn.
' My Commisslon Exp�res Aprtl g, �972 '
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DIJrLICAT[TO PRINTER
23���2
` CITY OF ST. PAUL �o�Nci� NO
OFFICE OF THE CITY CLERK
° COUNCIL RESOLUTION—GENERAL FORM
PRESENTED BY
COMMISSIONER DATF
RESOLVED, That the Counoil o� the City o3 Saint Paul
hereby authorizes, ratifies and approvea the action of
the Corporation Counsel in �iling a Notice and Petition
of Interven�ion by the City of Saint Paul in the matter
of Nort;hern Naturnl Gas Company, Docket No. �P6g-1, a
copy o� eaid Notioe and Petit3on o� Tntervention of
the City of Saint Paul being attached horeto and incor—
porated herein by reference.
AUG 2 � 1968
COUNCILMEN Adopted by the Council 19—
Yeas Nays AUG 2 ?_ 196�
�..��_
Dalglish Approverl 19—
Meredith Tn Favor
Peterson
Sprafka 0 Mayor
Tedesco A gainst
Mr. President, Byrne
a��