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5.4 ERMUSR 02-10-2004 UNITED STATES OF AMERICA BEFORE THE FEDERAL ENERGY REGULATORY COMMISSION Connexus Energy Docket No. ER04-327-000 CONCURRENCE AND INTERVENTION OF ELK RIVER MUNICIPAL UTILITIES IN SUPPORT OF FILING Pursuant to Rule 214 of this Commission's Rules of Practice and Procedure, 18 C.F.R. §385.214, and in accordance with this Commission's Notice of Filing dated January 2, 2004, Elk River Municipal Utilities of Elk River, Minnesota("ERMU"), herewith moves to intervene in support of and concur in the filing made in this docket by Connexus Energy on December 23, 2003 of a revision to Schedule V of Connexus Energy's First Revised Electric Rate Schedule FERC No. 1. I. COMMUNICATIONS Communications regarding this matter should be addressed to: Bryan C.Adams, P.E. Robert C. McDiarmid General Manager Thomas C. Trauger Elk River Municipal Utilities SPIEGEL& MCDIARMID 322 King Avenue 1333 New Hampshire Ave.,NW Elk River, Minnesota 553301 Suite 200 Washington, D.C. 200362 H. ERMU SUPPORTS THE FILING ERMU, a municipal entity of the State of Minnesota. concurs with and supports the filing of the amendment to Schedule V. ERMU understands that the Revised Schedule V simply passes through rate changes to be implemented by Connexus 'E-mail:bryada@nsatel.net. 2 E-mail: robert.mcdiarmid @spiegelmcd.com;thomas.trauger@spiegelmcd.com. -2 - Energy's supplier, Great River Energy. Therefore, ERMU expects to continue to avail itself of the option, described at Original Sheet No. 2 of the Connexus Energy Revised Electric Rate Schedule FERC No. 1, to receive up to five percent of its greatest amount of measured demand in electric power and associated energy from another source or from Connexus under different terms. ERNIU plans to pay the changed rate as of January 1, 2003, and supports the request for a waiver. ERMU is the only other party to these agreements, no other party can protect its interest, and its intervention is clearly in the public interest. ERMU notes that the successive revisions to the GRE rate schedules which are incorporated as Connexus rate schedules to ERMU have now gotten to the point where they are potentially ambiguous because of the fact that they were originally designed to cover the relationship between GRE and its members, including Connexus. In this connection, several of the rate schedules refer to services provided to a"member," and at least one of the rate schedules now (e.g., Special Rate Rider 1)require that retail loads obtain their power from members("Customer's qualifying load must receive all power from a GRE Member cooperative"). The basic idea behind the agreement between ERMU and Connexus is that ERMU will be treated as if it were a GRE Member cooperative (with the single exception of Capital Credits dealt with in Schedule V, paragraph E) insofar as ERMU service from Connexus is concerned. ERMU and Connexus agree (and we are authorized to make this representation by counsel for Connexus)that the Large Load, High Load Factor Rate in Special Rate Rider T will be available to ERMU, such that Connexus will offer the benefits of that rate to - 3 - ERMU to pass along to ERMU's retail customers who receive all their power from ERMU. CONCLUSION For the foregoing reasons,the Commission should permit Elk River to intervene and permit the filing by Connexus to become effective as requested. Respectfully submitted, /s/Robert C. McDiarmid Robert C. McDiarmid Thomas C. Trauger Attorney for Elk River Municipal Utilities Law Offices of: Spiegel & McDiarmid 1333 New Hampshire Avenue,NW Washington, DC 20036 (202) 879-4000 January 12, 2004 CERTIFICATE OF SERVICE I hereby certify that I have on this 12th day of January, 2004, caused the foregoing document to be sent by first-class mail to all parties on the list compiled by the Secretary of the Commission in this proceeding. /s/Robert C. McDiarmid Robert C. McDiarmid Law Offices of: Spiegel & McDiannid 1333 New Hampshire Avenue,NW Washington, DC 20036 (202) 879-4000