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227685 . y - ORIGINAL TO CITY GLERK � '- CITY OF ST. PAUL couNCi� ���� OFFICE OF THE CITY CLERK FILE NO.� cZ� OUNC RESOLUTION—GENERAL FORM PRESENTED BY COMMISSIONE DATE __ RE�OLVED� that the Council of the City of Saint Paul hereby authorizes and directs the Corporation Counsel to file a Notice of Intervention and Fetition by the City of �aint Paul in the matters of: Northern Natural Gas Companp (Docket No. CP66-212) an.d ` Northern Natural Gas Transportation Company (Docket Nos. CP66-213, CP66-214, CP66-21 5) a copy of said Notiee of Intervention by and Petition of the City of Sain.t Paul being attached hereto and incorporated herein by reference. � FO APPROVED / A st. Corpbtatwn Cou �set NIAR 151966 COLTNCILMEN Adopted by the Council 19— Yeas Nays � 1519�6 Dalglish Holland /, proved 19— Loss � Tn Favor Meredith �� � Ma or �� Ag�'I'gt BLISHED MAR 19196b� pU ?��iden�,:;�?;�auTis� .�i::oo:�Yi0 B n ice President .` . . , , �, • y' ������ �- UNITED STATES OF AMERICA FEDERAL POWER COMMISSION In the Matters of ) ) � 1Vorthern Natural Gas Company ) Docket No. CP66-212 ) CP66-214 Northern Natural Gas ) Docket Nos. CP66-213, Transportation Company ) CP66-215 NOTICE OF INTERVENTION BY AND PETITION OF CITY OF SAINT PAUL , a Minnesota Municipal Corporation, FOR INTERVENTION IN THE ABOVE CAPTIONED PROCFEDING - - - - - - - - - - - - - - - - - - - To said Federal Power Commission: Your Petitioner� City of Saint Paul, a Minnesota ' munic�pal corporation, pursuant to Sec. 1.8 di the Rules of Pxactice 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 intervenes in the above entitled proceeding. That said intervener� City of Saint Paul� hereinafter referred to as Petitioner herein� hereby represents and shows to the Commission: ' 1 I. � -� � That said Petitioner, Ci�y of Saint Paul, is a� municipal corporation 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 the State and governed by a Home Rule Charter and the Statutes of said State of Minnesota supplemental thereto, and is substantially int�rested in and affected by the matters under con- � sideration in said proceedings. II. ' That said Petitioner , City of Saint Paul, is a Minnesota municipali.ty, 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 7.935, Supplemental Laws of said State and ordinances of said Petitioner, Czty of Saint Pau1, . heretofore and now operative as enacted pursuant �o said Home Rule Charter and said State Iaws. III. 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 sai.d City of Saint Paul, Minnesotar subject to regulation by said City of Saint Paul in respect of the rates and charges therefor and the services involved. � IV�. That said Northern States �Power Compa�ny is entirely dependent 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 to deliver a contract demand of approximately 191� 500 mcf per day of natural gas. V. That the Noxthern States Power Company (Minnesota) and the Northexn States Power Compar�y (Wisconsin) have heretofore filed, in the above captioned proceedings� Petitions to In�ervene therein. �I. That the communications to be addressed to said Petitioner in the above entitled matter should be addressed to the following: George J. Vavoulis� Mayor of the City of Saint Paul 347 Court House Saint Paul, Minnesota 55102 Bernard T. Holland� Commissioner of Public Utilities 216 Court House ' Saint Paul, Minnesota 55102 Stephen L. Maxwell, Corporation Counsel Robert E. 0' Connell Special Assistant Corporation Counsel 316 Court House Saint Paul, Minnesota 55102 VII. That said Northern States Power Company is a principal re-sale customer of said Northern Natural Gas Compar�y and regularly purchases approximately ten per cent. of the gas sold by said Northern Natural Gas Company to the latter' s �urisdictional utility customers� That in the City of Saint Paul said Northern 3 r, • States Power Company has in excess of 90,000 natural gas consumer c�stomers � of which more than 50 per cent. are space heating consumer customers. That the price charged by said Northern Natural Gas Company therefore is a matter of vital and substantial interest to said Petitioner� City of Saint Paul, and its re�idents who, together with said Petitioner, City of Saint Paul, are natural gas consumer customers of said Northern States Power Compa�y. 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 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 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 Company, and are adjusted from time to time on the bases of such cost of natural gas and such other operation expenses of said Company. r-� V�II That petitioner has been informed by personnel of Northern States Power Company that the above captioned docket numbers have been consolidated for hearing before your Honorable Body and that a hearing thereon is set for April 19� 1966. 4 That your Petitioner furth�r has been informed that the par ties designated in the attached notice of service are parties of record with respect to the aforesaid consolidated proceedings � � and that service thereon has been affected by your Petitioner on such parties. IX. On December 30, 1965 Northern filed in Docket No. CP66-212 an application for a certificate of public convenience and necessity authorizing it to operate and construct new facilities� costing approximately �14, 500,000, and to exchange natural gas with its wholly-owned subsidiary Northern Natural Gas Transportation Company (Transportation Company) . " Transportation Company also filed on December 30� 1965, in Docket No. CP66-213, a related application for authorization to operate and construct facilities, costing about �185,000,000, and to exchange and sell natural gas in interstate commerce. On the same date in Docket Nos . CP66-214 and CP66-2� 5 Transportation Company concurrently filed applications for authorization to import and export natural gas from and to Canada and for an original permit authorizing the construction, operation, maintenance, . and connection of facilities at three separate locations on the international border between the United States and Canada for such importation and exportation. The applications propose the plan of Northern and Transportation Company to construct facilities to deliver natural gas for Trans-Canada Pipe Lines � Limited (Trans-Canada) to Eastern Canadian markets. Under the plan Transportation Company will take 5 � gas from Trans-Canada at Fmerson, Manitoba, and delive� it into Northern' s system near Sandstone, Minnesota. Northern will provide an equivalent amount of gas to Transportation Company at Ogden� Iowa� and Republic� Michigan� for re-delivery to Trans-Canada near Detroit and Sault Ste. Marie � Michigan, Transportation Company also proposes to se11 and deliver to Michigan Consolidated Gas Company volumes of natural gas purchased from Trans-Canada. Tran�portation Company alleges that its proposals are competitive and mutually exclusive �ith the proposals of Great Lakes Gas Transmission Company cont�ined in the applications filed in Docket No�. CP66-110, CP66-111 , and CP66-112 and some of the proposals of Michigan Wisconsin Pipe Lirie Company filed .in Docket No. CP66-109. However, it alleges that its proposal is not mutually exclusive to and competitive with the facilities and service proposed by Midwestern Gas Transmission Company applica- tions in Docket Nos. CP66-119, CP66-120 and CP66-121 . X. The City of Saint Paul has reviewed the applications and plan of operation of NorthPrn and Transportation Company in the above dockPts and there appear to be several potential and .significant benefits to the customers of Northern, including the ' gas users in the City of Saint Paul, which should be carefully considered and which may be important in determining the public convenience and necessity, namely: . (a) Receipt of substantial volumes of Canadian gas into the northern part of Northern' s - system in exchange for redelivery to Trans- portation Company at Ogden, Iowa, would enable Northern more effectively to utilize existing 6 . � � f , pipeline and storage facilities and would release existing pipeline capacity for exten- sion of sales and service to NorthPrn' s present and future customers, thereby elimi- nating millions of dollars in future invest- ment in additional facilities that would be required in the absence of the exchange pro- posal. This would enable Northern to supply� the estimated increase in contract demand of 224,000 Mc�f during the next five years to its customers in the north end of its system at a net savings of approximately $15,000,000 in construction costs for additional main line facilities (see Exhibits Z-1 and Z-2 attached to Northern' s application in Docket No. CP66-212) . The related cost of service studies in Exhibit Z-3 of Northern' s applica- tion shows that the proposed exchange plan would save Northern more than $3�000,000 annually in cost of service to supply the additional contract demand. (b) The construction of facilities as proposed would provide Northern with access to a gas supply in WPstern Canada on an economical basis . (c) A supply of Canadian gas into the north end of Northern' s transmission line in quantities substantially adequate to supply St. Paul and Minneapolis , Minnesota, and other communities north thereof, would free up a large part of Northern' s pipeline capacity north of Ogden, Iowa, for expanded service to its customers on an economical basis� including peaking service from Northern' s storage field. (c) Construction of pipeline capacity from Canada, in addition to present facilities from the south, each capable of substantially serving . - requirements of St. Paul and Minneapolis and communities north thereof, would offer addi- tional protection against interruption of service to said communities. XI. In view of the alleged benefits set forth above � the City of Saint Pau1 and its natural gas consumers have a very definite interest in these proceedings and desire to intervene and support the respective applications of Northern and � 7 s „ Transportation Company. This statemPnt of position, however, is without prejudice to or waivercf the City of Sai.nt Paul' s right to test these potential benefits through cross-examination of witnes�es of either applicant and such other participation in hearing procedures as may be appropriate under the circumstances , as well as to take any alternate position therPin that may be deemed advisable to protect the City' s interest and that of the natural gas consumers located within its jurisdiction. XII. Because of all the foregoing facts , your Petitioner is vitally concerned with and in�erested in the proceedings in these dockets. This interest is not adequately represented by existing parties . The City of Saint Paul will be directly affected and bound by the Commission' s action herein. WHEREFORE, the City of Saint Paul prays that its right of intervention in the above entitled proceedings be granted and approved with leave to present evidence, examine and cross-examine witnesses� and participate generally therein. Dated at Saint Paul, Minnesota , this 15th day of March, 1966. Respectfully submitted, CITY OF SAINT PAUL Stephen L. Maxwell By; /s/ George J. Vavoulis Corporation Counsel George J. Vavoulis , Mayor /s/ Robert E. 0' Connell 34`7 Court House By: Saint Paul, Minnesota 55102 Robert E. 0' Connell Special Assistant /s/ Bernard T. Holland Corporation Counsel Bernard T. Holland City of Saint Paul Commissioner of Public IItilities 316 Court House 216 Court House Saint Paul� Minnesota 55102 Saint Pau1, Minnesota 55102 Attorneys for the City of . Saint Paul, Minnesota 8 , � . � STATE OF MINNESOTA) ' ) ss. COUNTY OF RAMSEY ) � Bernard T. Holland� being first duly sworn, upon oath deposes and says that he is the Commissioner of Public Utilities o�' the City of Saint Paul, the Petitioner in the above entitled matters ; that he has read sa�,d Petition and knows the contents ` thereof, and that the same is true except as to those matters therein stated on information and belief� and as to those matters he believes the same to be true. � � /s/ Bernard T. Holland Bernard T. Holland Commissioner of Public Utilities Subscribed and sworn to before me this 15th day of March, 1966. /s/ Betty J. Lassen Betty J. Lassen Notary Public, Ramsey Co. , Minn. My commission expires April 8, 1972 (Notarial Seal� Ramsey County, Minnesota)