UTAH RATEPAYERS ALLIANCE

Salt Lake Community Action Program

Crossroads Urban Center


764 South 200 West

Salt Lake City, Utah 84101



April 21, 2006



Julie Orchard, Commission Secretary

Public Service Commission

160 East 300 South, 4th Floor

Salt Lake City, Utah 84101


Re:      Docket No. 05-057-T01


Dear Ms. Orchard:


Enclosed is the Petition for Leave to Intervene of Salt Lake Community Action Program and Crossroads Urban Center (collectively referred to as the Utah Ratepayers Alliance) in the above-referenced docket. Please file as is your usual practice.


Thank you for your attention in this matter.


Sincerely,






_____________________________________

Betsy Wolf

Utility Ratepayer Advocate

Salt Lake Community Action Program


BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH

***

 

In the Matter of the Joint Application of                                ) 

Questar Gas Company, the Division of Public                       ) 

Utilities and Utah Clean Energy for the Approval                 )          Docket No. 05-057-T01

of the Conservation Enabling Tariff Adjustment                   )          

Option and Accounting Orders                                               )




PETITION FOR LEAVE TO INTERVENE


 

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Pursuant to the Rules of Practice and Procedure of the Utah Public Service Commission (Commission), Salt Lake Community Action Program and Crossroads Urban Center (collectively known as the Utah Ratepayers Alliance) hereby petition for leave to intervene in the above-captioned docket and, in support thereof, state as follows:


1.         The Salt Lake Community Action Program (CAP) is a private nonprofit community-based organization that addresses the needs of low-income people through service delivery and advocacy.


2.         Crossroads Urban Center (Crossroads) is a nonprofit community-based organization serving the needs of low-income people in the Salt Lake Metropolitan Area.


3.         CAP and Crossroads have a special interest in ensuring that the people they represent are charged fair and reasonable rates for natural gas service. The application filed by Questar Gas Company (Questar or QGC) for approval of its proposed Conservation Enabling Tariff (CET) is a significant change in the way that natural gas rates are determined and collected. Any change in the rates of Questar Gas may have an impact on residential natural gas customers and the price that residential natural gas customers will have to pay.


4.         Furthermore, since Salt Lake Community Action Program and Crossroads Urban Center represent low income people, those organizations have a particular interest in ensuring that rates for natural gas service remain as low as possible since people with limited incomes pay such a disproportionate share of their income for natural gas service.


5.         Accordingly, CAP and Crossroads possess a direct and substantial interest in the subject matter of this case, and seek via this intervention petition to protect that interest as it may appear. Participation in this docket will be in the public interest and may also be of particular assistance to the Commission in rendering informed decisions on the issues that will likely be raised.


6.         Intervention by CAP and Crossroads will not delay the proceeding or unduly burden the other parties in the proceeding.



7.         CAP and Crossroads request that all pleadings, correspondence, discovery, and other documents be served on:


Utah Ratepayers Alliance

c/o Betsy Wolf

Salt Lake Community Action Program

764 South 200 West

Salt Lake City, Utah 84101

            FAX:              (801) 355-1798

            VOICE:          (801) 582-2149

            E-mail             bwolf@slcap.org




Respectfully submitted this _______ day of April, 2006.




_____________________________________________

Betsy Wolf, Utility Ratepayer Advocate

Salt Lake Community Action Program



















CERTIFICATE OF SERVICE



            I hereby certify that a true and correct copy of the foregoing Petition for Intervention in Docket No. 05-057-T01, of Salt Lake Community Action Program and Crossroads Urban Center (collectively known as the Utah Ratepayers Alliance) was mailed electronically (e-mailed) this ______ day of April, 2006, to the following:




Michael Ginsberg

Patricia E. Schmid

Assistant Attorney Generals

160 East 300 South, 5th Floor

Salt Lake City, UT 84111

mginsberg@utah.gov

pschmid@utah.gov


Reed T. Warnick

Paul H. Proctor

Assistant Attorney Generals

160 East 300 South, 5th Floor

Salt Lake City, UT 84111

rwarnick@utah.gov

pproctor@utah.gov


C. Scott Brown

Colleen Larkin Bell

Questar Gas Company

180 East First South

P.O. Box 45360

Salt Lake City, UT 84145

scott.brown@questar.com

colleen.bell@questar.com


Gregory B. Monson

David L. Elmont

Stoel Rives LLP

201 South Main Street, Suite 1100

Salt Lake City, UT 84111

gbmonson@stoel.com

dlelmont@stoel.com





Gary A. Dodge

Hatch, James & Dodge

10 West Broadway, Suite 400

Salt Lake City, UT 84101

gdodge@hjdlaw.com


Roger J. Ball

1375 Vintry Lane

Salt Lake City, UT 84121

ball.roger@gmail.com


Sarah Wright

Executive Director

Utah Clean Energy

917 2nd Avenue

Salt Lake City, UT 84103

sarah@utahcleanenergy.org


Kevin Higgins

Neal Townsend

Energy Strategies

215 S. State Street, Suite 200

Salt Lake City, UT 84111

khiggins@energystrat.com

ntownsend@energystrat.com









F. Robert Reeder

William J. Evans

Parsons Behle & Latimer

201 South Main Street, Suite 1800

P.O. Box 45898

Salt Lake City, UT 84145-0898

rreeder@parsonsbehle.com

wevans@parsonsbehle.com



Respectfully submitted,




__________________________

Betsy Wolf

Salt Lake Community Action Program