ATTORNEYS AT LAW IOO PINE STREET P. O. BOX 1166 HARRISBURG, PA TELEPHONE ( FAX http ://www. m wn.

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1 MCNEES ATTORNEYS AT LAW PAMELA C. POLACEK DIRECT DIAL: (717) ADDRESS: Jaes J. McNulty, Secretary Pennsylvania Public Utility Coission Coonwealth Keystone Building 400 North Street, 2 nd Floor Harrisburg, PA IOO PINE STREET P. O. BOX 1166 HARRISBURG, PA TELEPHONE ( FAX http ://www. wn.co June 11,2001 ""OLDER n CD o TO >> -<." o CDd ZD at ro ro > - i ^3 rn o i * * VIA HAND DELIVERY Re: Pennsylvania Public Utility Coission v. UGI Utilities, Inc. - Gas Division; Docket No. R Dear Secretary McNulty: Enclosed for filing are the original and three (3) copies of the Petition to Intervene of the UGI Industrial Interveners ("UGIII") in the above-referenced atter. Copies of this docuent have been served upon all known parties of record as indicated on the enclosed Certificate of Service. Please date stap the extra copy of this transittal letter and kindly return for our filing purposes. Thank you. Very truly yours, PCP:kp Enclosures MCNEES WALLACE & NURICK LLC By C'.A-^^ Derrick P. Williason Paela C. Polacek Counsel to the UGI Industrial Interveners c: Honorable Ky Van Nguyen, Adinistrative Law Judge (w/enc.) (via Federal Express) Ms. Judy E. Weaver, Scheduling Officer (w/enc.) (via hand delivery) Certificate of Service op COLUMBUS, OH HAZLETON. PA WASHINGTON, D.C.

2 PENNSYLVA PENNSYLVANIA PUBLIC UTILITY COMMISSION 1 11 TC UTILITY COMMISSION OCHETI JUN < CD rn b= 1 " ^r* O v. UGI UTILITIES, INC. - GAS DIVISION PETITION TO INTERVENE Docket No. R TO THE HONORABLE, THE PENNSYLVANIA PUBLIC UTILITY COMMISSIO CD' _. r.i Pursuant to the provisions of 52 Pa. Code , the UGI Industrial Interveners ("UGIII") hereby file this Petition to Intervene in the above-captioned proceeding. In support thereof, UGIII states as follows: includes: 1. Petitioner is UGI Industrial Interveners. For purposes of this proceeding, UGIII TO ro ^CUMENT ALCOA Bethlehe Steel Corporation Carpenter Technology Corporation Lucent Technologies Mount Joy Wire Corporation R.R. Donnelley & Sons, Co. The coposition of UGIII at this point in tie is also attached hereto as Appendix "A." Appendix "A" will be updated as necessary. 2. The naes and address of Petitioner's attorneys are: Derrick P. Williason Paela C. Polacek Karen S. Miller-Oer McNEES WALLACE & NURICK LLC 100 Pine Street P.O. Box 1166 Harrisburg, PA (717) (717) (facsiile)

3 9 3. On May 1,2001, UGI Utilities, Inc. ("UGI") filed with the Coission its preliinary Section 1307(f) filing of the period Deceber 1, 2001, through Noveber 30, See 66 Pa. C.S. 1307(f). On June 1, 2001, UGI subitted its definitive Section 1307(f) filing, including PGC 2001 Tariff Addendu Gas-Pa. P.U.C. No. 5 and supporting testiony. Based on the definitive filing, UGI projects decreasing its PGC(l) rates by Sl.lOOO/Mcf to a charge of $8.1134/Mcf and decreasing its PGC(2) rates by $ per Mcf to a charge of $6.6999/Mcf. 4. UGIII is an ad hoc group of large volue custoers receiving transportation and related services fro UGI pursuant to transportation delivery service rate schedules and the general ters of delivery service set forth in Rule 17 of UGI's tariff. UGIII ebers purchase service fro UGI under Rate XD - Extended Large Volue Delivery Service and Rate LFD - Large Fir Delivery Service, as well as other rate schedules. UGIII ebers use substantial volues of natural gas in their anufacturing and operational processes, and natural gas costs are a significant eleent of their respective costs of production. The Coission's final disposition of UGI's 1307(f) filing ay have an ipact upon the rates UGIII ebers pay for natural gas transportation and other services. 1 Therefore, UGIII has a significant interest in this proceeding, and it is not represented by any other party of record. 1 Section 17.1 (g) of UGI's tariff provides that transportation-related storage and balancing costs ay be credited to the PGC; transportation-related storage and balancing costs and charges could be affected by the resolution of this proceeding. In addition, large transportation custoers ay have been affected by the Texas Eastern Operational Flow Order ("OFO") situation referenced in UGI's prepared testiony. -2-

4 WHEREFORE, the UGI Industrial Interveners respectfully request that the Coission grant this Petition to Intervene with active party status. Respectfully subitted, McNEES WALLACE & NURICK LLC By / CA^^- Derrick P. Williason Paela C. Polacek Karen S. Miller-Orner 100 Pine Street P.O. Box 1166 Harrisburg, PA (717) (717) (fax) Counsel to the UGI Industrial Interveners Dated: June 11, 2001 s S - w c= rn 3X> t -» -3-

5 0 Appendix A UGI Industrial Interveners ALCOA Bethlehe Steel Corporation Carpenter Technology Corporation Lucent Technologies Mount Joy Wire Corporation RR Donnelley & Sons Copany

6 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA COUNTY OF DAUPHIN ss: PAMELA C. POLACEK, being duly sworn according to law, deposes and says that she is counsel to the UGI Industrial Interveners, that in this capacity she is authorized to and does ake this affidavit for the UGI Industrial Interveners, and that the facts set forth in the foregoing Petition to Intervene are true and correct to the best of her knowledge, inforation and belief. SWORN TO and subscribed before e this // ^^day Paela C. Polacek, Esq. ofjune, Notfery Publi/ (SEAL) NOTARIAL 86AL ~" MARY A. SIPE, Notary Public Hasburg,PA Dauphin County My Coission Expires HWh w o o c "Tl >> o 5^ rvi c/^,^ if _ CDcr ro o TO ro o > j c

7 01 CERTIFICATE OF SERVICE I hereby certify that I a this day serving a true copy of the foregoing docuent upon the participants listed below in accordance with the requireents of Section 1.54 (relating to sendee by a participant): VIA FIRST-CLASS MAIL David B. MacGregor, Esquire Morgan, Lewis & Bockius 1701 Market Street Philadelphia, PA Mark C. Morrow, Esquire UGI Utilities, Inc. - Gas Division PO Box 858 Valley Forge, PA Stephen J. Keene, Esquire Office of Consuer Advocate 555 Walnut Street Foru Place - 5 Ih Floor Harrisburg, PA Angela T. Jones, Esquire Office of Sall Business Advocate Coerce Building - Suite North Second Street Harrisburg, PA Kandace Melillo, Esquire Office of Trial Staff Coonwealth Keystone'Bui 400 North Street, 2 nd Floor Harrisburg, PA Iding O TO cocz TO ro fn5 rn o < rn a Paela C. Polacek Dated this 11* day of June, 2001, Harrisburg, Pennsylvania.

8 COMKONWEALTH OF PENNSYLVANIA DATE: June 13,2001 SUBJECT: R OCKETE TO: Office of Adinistrative Law Judge JUN FROM: ^Jaes J. McNulty, Secretary * ) 0 C ^ FOLDER Pennsylvania Public Utility Coission v. UGI Utilities, Inc.-Gas Division Attached is copy of a Petition to Intervene filed by UGI Industrial Interveners in connection with the above docketed proceeding. This atter is assigned to your Office for appropriate action. Attachent Cc: OTS laf

9 U TIL ITIES. INC. June 18, 2C 01 UGI Utilities. Inc. 100 Kachel Boulevard, Suite 400 Post Office Box Reading. PA (610) Telephone Jaes J. McNulty, Secretary Pennsylvania Public lutility Coission P.O OT 6 I 57 Harrisburg, PA JUN20 AH 8:51' RECEIVED SECRETARY'S BUREAU Re: Pennsylvania Public Utility Coission v. UGI Utilities, Inc. - Gas Division, Docket No. R Dear Secretary McNulty: Enclosed for filing in the above-captioned atter please find an original and three copies of the Prehearing Meorandu of UGI Utilities, Inc. - Gas Division. Copies of this docuent have been served upon the persons indicated on the attached Certificate of Service. Should you have any questions concerning this docuent, please feelfreeto contact e. D Very truly yours, Mark C. Morrow Counsel for UGI Utilities, Inc. Gas Division cc: Certificate of Service

10 \ * «It PENNSYLVANIA PUBLIC UTILITY COMMISSION BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION 0 f f 58 UvJ 01 JUN 20 AM RECEIVED SECRETARY'S 8U v. UGI UTILITIES, INC. - GAS DIVISION Docket No. R PREHEARING MEMORANDUM OF UGI UTILITIES, INC. - GAS DIVISION BEFORE ADMINISTRATIVE LAW JUDGE KY VAN NG I. BACKGROUND 2001 UGI Utilities, Inc. - Gas Division ("UGI" or the "Copany"), being a natural gas distribution copany with gross intrastate annual operating revenues in excess of $40,000,000, is authorized by the provisions of Section 1307(f) of the Public Utility Code, 66 Pa.C.S. 1307(1), and the Pennsylvania Public Utility Coission's ("Coission") gas cost recovery regulations at 52 Pa. Code , to ake annual purchase gas cost ("PGC") filings proposing odificati [tanff rates to reflect increases or decreases in its natural gas costs. 1, UGI provided the Coission with the prefiling inforation specified in 52 Pa. Code 53.64(c) and On that date UGI also provided certain inforation pertaining to syste reliability consistent with the provisions of Section 1317(c) of the Public Utility Code, 66 Pa.C.S. 1317(c). On June 1, 2001, in accordance with the schedule for Section 1307(f) filings established by the Coission, UGI subitted its 2001 PGC filing to the Coission with proposed

11 ft odifications to UGI's Gas Tariff Pa. P.U.C. No. 5, to becoe effective Deceber 1, This filing proposed to decrease the Copany's current PGC(l) rate to $8.1134/Mcf, a $1.10/Mcf decrease fro the PGC(l) rate that becae effective March 1, It also proposed to decrease Copany's PGC(2) rate to $6.6999/Mcf; a $ /Mcf decrease fro the PGC(2) rate that becae effective March 1, The direct written testiony of UGI's supporting witnesses was also subitted with its PGC filing. II. ISSUES Under Section 1307(f), the Coission ust deterine that portion of a natural gas distribution copany's actual gas costs incurred during a 12-onth historical period that eets the standards set forth in Section 1318 of the Public Utility Code, 66 Pa.C.S Section 1318, in tu, requires the Coission to deterine whether: 1. The utility has fully and vigorously represented the interests of its rate payers in proceedings before the Federal Energy Regulatory Coission. 2. The utility has taken all prudent steps necessary to negotiate favorable gas supply contracts and to relieve the utility fro ters in existing contracts with its gas suppliers which are or ay be adverse to the interests of the utility's rate payers. 3. The utility has taken all prudent steps necessary to obtain lower cost gas supplies on both short-ter and long-ter bases both within and outside the Coonwealth, including the use of gas transportation arrangeents with pipelines and other distribution copanies. 4. The utility has not withheld fro the arket or caused to be withheld fro the arket any gas supplies which should have been utilized as part of a least cost fuel procureent policy. Where applicable, the Coission ust also ake certain findings concerning gas purchases fro affiliates, and deterine whether a natural gas distribution copany has "shutin" gas that could have been brought to arket during the relevant period. -2-

12 Once such findings are ade for the historical period, the Coission ust deterine the reasonableness of the rates proposed for the projected PGC period. Such rates are coprised priarily of two eleents, the so-called "C-Factor" and "E-Factor." The "C-Factor" is a projection of the gas costs the natural gas distribution copany will incur during the future period. The "E-Factor" is the reconciliation of: (a) the natural gas distribution copany's gas costs that eet the standards of Section 1318 during the historic period; and (b) the PGC revenues collected by the natural gas distribution copany during such historic period, plus projections of over and under collections for the interi period (April through Noveber, 2001).. UGI WITNESSES UGI's witnesses in this proceeding will be Willia J. McAllister, Senior Rate Analyst and Tiothy J. Oaks, Manager - Gas Supply Federal Regulatory Affairs and Contract Adinistration. The subject atter of each witness' testiony is identified in Schedule WJM-1, a copy of which is attached as Appendix A hereto. IV. EVIDENCE The Copany intends to offer into evidence in this proceeding its May 1, 2001 prefiled supporting inforation and its June 1, 2001 PGC tariff filing with supporting schedules and the direct written testiony of its witnesses. UGI also reserves the right to present rebuttal and surrebuttal evidence as required. The subject atter of the direct written testiony of UGI's witnesses has been identified above. The subjects addressed in UGI's prefiling inforation ("Prefiling") and UGI's June 1, 2001 PGC filing ("Filing") are as follows: A. FERC Participation ( 1317fa)(l); 1318(a)(l)): See Prefiling, Section

13 B. Supplier Negotiations/Renegotiations ( 1317(a)(2); 1318(a)(2)): See Prefiling, Sections 2 and 5. C. Efforts to Obtain Lower Cost Supplies ( 1317(a)(3); 1318(3X3)): See Prefiling, Sections 1, 2, and 5. D. Withheld Supplies ( 1317(a)(4); 1318(a)(4)): See Prefiling, Section 5. E. Affiliated Purchases ( 1317(a)(5); 1318(a)(5)): See Prefiling, Section 13. F. Least Cost Fuel Procureent Policy ( 317(a); 1318(a)): See Prefiling, Section 1, 2 and 5. G. Calculation of 2001 PGC Rates ( 1317(f)(2)): 1. In General: See Filing, Attachents (1) - (7). 2. Reconciliation of Revenue and Cost for the 12-onth period ended March 31, 2001: See Filing, Attachent (7). 3. "E" Factor Calculations: See Filing, Attachent (4). H. Reliability ( 1317(c)): See Prefiling, Section 14. V. PROPOSED SCHEDULE UGI's proposed schedule for this atter is attached as Appendix B hereto. VI. DISCOVERY UGI has to date received two sets of interrogatories fro the Office of Consuer Advocate ("OCA") and two sets of interrogatories fro the Coission's Office of Trial Staff ("OTS"), and has either responded or is in the process of responding to these discovery requests. UGI is willing to eet with any party for the purpose of conducting inforal discovery. VII. SETTLEMENT There have been no settleent discussions to date. UGI would note, however, that it stands ready to engage in such settleent discussions if the parties to this proceeding so desire. -4-

14 VIII. PETITION TO INTERVENE On June 11, 2001, the UGI Industrial Interveners filed a Petition to Intervene in this proceeding. UGI has no objection to this petition. Respectfully subitted, Mark C. Morrow 460 North Gulph Road King of Prussia, PA Tel: ext Fax: Eail: orrow@ugicorp.co David B. MacGregor, Esquire Morgan, Lewis & Bockius LLP 1701 Market Street Philadelphia, PA Tel: Fax: Eail: dbacgregor@organiewis.co Counsel for: UGI Utilities, Inc.- Gas Division Dated: June 18,

15 (1 APPENDIX A

16 SCHEDULE WJM Purchased Gas Costs Contents of Filing Witness Developent of Purchased Gas Cost Reconciliation of Revenue and Expense for the 12 Month Period Ending 3/31/01 Tariff Addendu W. J. McAllister W. J. McAllister W. J. McAllister Prefiling Inforarion 53.64(C) and Gas Supply 1- A Developent of Attachent I-A-l Supply Considerations 2- B Developent of Attachents I-B-l and I-B-2 3- C Supplies Purchased for Interruptible Markets 2. Other Sources of Gas Supply 3. FERC and Other Proceedings 4. Supply/Deand Projections Deand Supply 5. Fuel Procureent Practices 6. Off-Syste Sales 7. Transportation Agreeents 8. End User Transportation Volue 9. Syste Map 10. Rate Structure Changes 11. Peak Day 12. PGC Revenue/Expense 13. Affiliated Purchases Gas Beyond the Mains W. J. McAllister T. J. Oaks T. J. Oaks T. J. Oaks T. J. Oaks T. J. Oaks W. J. McAllister T. J. Oaks T. J. Oaks W. J. McAllister T. J. Oaks W. J. McAllister W. J. McAllister T. J. Oaks W. J. McAllister T. J. Oaks W. J. McAllister T. J. Oaks W. J. McAllister 14. Reliability Plans T.J. Oaks

17 APPENDIX B

18 PROPOSED SCHEDULE Initial Prehearing Conference Initial Settleent Conference Parties other than UGI file Written Direct Testiony Settleent Conference Subission of Written Rebuttal Testiony Surrebuttal Testiony Hearings Main Briefs Reply Briefs Target Recoended Decision Date June 21, 2001 at 10:00 a.. July 9, 2001 at 2:00 p.. July 13,2001 (in hand) July 18,2001 at 2:00 p.. August 3, 2001 (in hand) August 13, 2001 (in hand) August 15, 16 and 17 Septeber 6, 2001 (in hand) Septeber 14, 2001 (in hand to ALJ) October 17, 2001

19 <0 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION PENNSYLVANIA PUBLIC UTILITY COMMISSION v. UGI UTILITIES, INC. - GAS DIVISION Docket No. R CERTIFICATE OF SERVICE I hereby certify that I have, this 18th day of June, 2001, served a true and correct copy of the foregoing docuent in the anner and upon the persons listed below in accordance with requireents of 52 Pa. Code 1.54 (relating to service by a participant): VIA FACSIMILE, ELECTRONIC AND FIRST CLASS MAIL: Stephen J. Keene, Esq. Zachary Rubinich, Esq. Office Of Consuer Advocate 555 Walnut Street 5 th Floor, Foru Place Harrisburg, PA Fax: skeene@paoca.org zrubinich@paoca.org Angela T. Jones, Esq. Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA Fax: (717) anjones@state.pa.us Kandace F. Melillo, Esq. Office of Trial Staff Pennsylvania Public Utility Coission P.O. Box 3265 Harrisburg, PA Fax: (717) eullo@puc.state.pa.us Paela C. Polacek, Esq. McNees, Wallace & Nurick 100 Pine Street P.O. Box 1166 Harrisburg, PA Fax: (717) ppolacek@wn.co

20 Brian Kalcic Excel Consulting Suite 720-T 225 South Meraec Avenue St. Louis, MO Fax: (314) Jerry Mierzwa Exeter Associates Suite Prosperity Drive Silver Spring, MD Fax:(301) j ierz wa@exeterassociates. co VIA FACSIMILE AND FIRST CLASS MAIL; The Honorable Ky Van Nguyen Adinistrative Law Judge Pennsylvania Public Utility Coission 1302 Philadelphia State Office Building 1400 West Spring Garden Street Philadelphia, PA Fax: (215) / Mark C. Morrow

21 C^lfvIONWEALTH OF PENNSYLVA^ OFFICE OF SMALL BUSINESS ADVOCATE Suite 1102, Coerce Building. 300 North Second Street Harrisburg, Pennsylvania Bernard A. Ryan, Jr Sall Business Advocate (717) (717) (FAX) June 19, 2001 co o TO rn... * ; i rn,^'* ~7" ~" * Fax and First Class Mail TO Hon. Ky Van Nguyen C3' CO»» * Adinistrative Law Judge "* Pa. Public Utility Coission 1302 Philadelphia State Office Bldg. ^ Broad and Spring Garden Streets Philadelphia, PA Re: Pennsylvania Public Utility Coission v. UGI Utilities Inc. Docket No. R-0' (GCR Proceeding) Dear Judge Nguyen: In anticipation of the Prehearing Conference scheduled for Thursday, June 21, 2001, I a enclosing a copy of the Prehearing Meorandu on behalf of the Office of Sall Business Advocate. As evidenced by the enclosed certificate of service, all parties have been served as indicated. Sincerely, Enclosures cc: icjaes^gt^mc.nul.ty:,. Secretary^ (w/2 copies) Parties of Record Ang^k T. Jones \ J Assistant Sall Business Advocate Brian Kalcic

22 BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION PENNSYLVANIA PUBLIC UTILITY COMMISSION v. DOCKET NO. R UGI UTILITIES INC.- Gas Division OFFICE OF SMALL BUSINESS ADVOCATE PREHEARING MEMORANDUM I. INTRODUCTION The Office of Sall Business Advocate (OSBA) is authorized to represent the interests of sall business consuers of utility services before the Pennsylvania Public Utility Coission pursuant to the provisions of the Sall Business Advocate Act", Act 181 of 1988, 73 P.S ("the Act"). In order to discharge this statutory duty, the Sall Business Advocate dees i t necessary to participate as a party to this proceeding. Representing the OSBA in this atter is Assistant Sall Business Advocate Angela T. Jones. Please address all correspondence as follows: Angela T. Jones, Esquire Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, Pennsylvania (717) (717) (fax)

23 n II. FILING BACKGROUMP Pursuant to Section 1307(f) of the Public Utility Code (66 Pa.C.S. Section 1307(f)), UGI Utilities, Inc. - Gas Division ("UGI" or "Copany") filed its tariff suppleent relating to its annual (f) proceeding. Modifications in this tariff reflect UGI's proposed purchased gas costs. The OSBA filed a Notice of Intervention on May 30, III. IDENTIFICATION OF WITNESSES AND TENTATIVE ISSUES Assisting in the developent and presentation of the OSBA's case in this proceeding will be: Mr. Brian Kalcic Excel Consulting Suite 720-T 225 S. Meraec Avenue St. Louis, MO (314) (314) Fax The OSBA will participate in the case to assure that the interests of sall business custoers of UGI are adequately represented and protected. As appropriate and necessary, the OSBA will investigate and analyze the clais and proposals of the Copany and other parties through the cross-exaination of witnesses appearing for tthose parties and through briefing. The OSBA will particularly focus on any issue where the ipact on the' interests of Peoples' sall business consuers would be unjustifiably different than or disproportionate to the ipact on another class of custoers, or otherwise lacking in reasonableness or basic fairness. The OSBA reserves the right to pursue additional issues as they arise throughout the proceeding.

24 IV. SETTLEMENT The OSBA notes its willingness to enter into settleent discussions at the appropriate phase of this proceeding. V. HEARING AND BRIEFING SCHEDULE schedule. The OSBA will cooperate with the other parties to develop a procedural Respectfully subitted, Angela T. Jones ASS i st; ant Sall Busruess Advocate Office of Sall Business Advocate Suite 1102, Coerce Building 300 North Second Street Harrisburg, PA {717} Dated: June 19, 2001

25 II PENNSYLVANIA PUBLIC UTILITY COMMISSION BEFORE THE PENNSYLVANIA PUBLIC UTILITY COMMISSION v. DOCKET NO. R UGI UTILITIES INC. CERTIFICATE OF SERVICE I certify that I a serving a copy of the Prehearing Meorandu on behalf of the Office of Sall Business Advocate by FAX and f i r s t class ail upon the persons addressed below: Hon. Ky Van Nguyen Adinistrative Law Judge Pa. Public U t i l i t y Coission 1302 Philadelphia State Office Bldg. Broad and Spring Garden Streets Philadelphia, PA (215) (215} Fax David B. MacGregor, Esquire Morgan, Lewis & Bockius 1701 Market Street Philadelphia, PA (215) (215) (fax) Mark C. Morrow, Esquire UGI Utilities, Inc. 460 North Gulph Road King of Prussia, PA (610) (610) (fax) Vicki O. Ebner, Vice President Marketing and Gas Supply 100 Kachel' Blvd. Suite 400 P.O. Box Reading, PA Zachary M. Rubinich, Esquire Stephen J. Keene, Esquire Office of Consuer Advocate 555 Walnut Street 5th FL Foru Place Harrisburg, PA (717) (717) Kandace F. Melillo, Esquire Office of Trial Staff Pa. Public U t i l i t y Coission P.O. Box 3265 Harrisburg, PA (Office of Trial Staff) (717) (717) (fax) Paela C. Polacek, Esquire McNees, Wallace & Nurick 100 Pine Street P.O. Box 1166 Harrisburg, PA (717) (717) (fax) Date: June 19, 2001 Ange^ T. Jones i^_j Assistant Sall Business Advocate

26 Alan C. Kohler Direct Dial: Direct Fax: Wolf, Block, Schorr and Solis-Cohen LLP fo 15 1 U 2l2LocuslSireet Suite 300 Harrisburg. R\ T:7t F: I61 tt\\w.wol(block.co June 20, 2001 VIA HAND DELIVERY Jaes McNulty, Secretary PA Public Utility Coission P.O. Box 3265 Harrisburg, PA 'TOI Utilities Inc. - Gas Divison cn :CR o c_ d ro TO- CD ni CO TD ti''"* o ZSi CD- t f-t d CO RE CO > CO o Dear SecEetii On behalf of Stroehan Bakeries, Inc. enclosed for filing please find an original and three copies of its Petition to Intervene with regard to the above referenced atter. Respectfully subitted, Alan C. Kohler For WOLF, BLOCK, SCHORR and SOLIS-COHEN LLP cc: Hon. KyVan Nguyen w/enc. Certificate of Service w/enc. DSH: PHILADELPHIA. PA I NEW YORK. NY I CAMDEN, NJ I CHERRY HILL. NJ I NEWARK. NJ I N0RR1ST0WN. PA I WILMINGTON. DE

27 BEFORE THE * * ^ ^ i V h b PENNSYLVANIA PUBLIC UTILITY COMS^Ojj/^ ^ ^ ^ ^ PENNSYLVANIA PUBLIC UTILITY COMMISSION HA. P.U.C. SECRETARY'S BUREAU v. UGI "UTILITIES, INC. - GAS DIVISION MN PETITION TO INTERVENE OF STROEHMAN BAKERIES, INC. Pursuant to 52 Pa. Code , Stroehan Bakeries, Inc. ("Stroehan"), hereby petitions to intervene in the above-captioned proceeding in order to protect its interests. In support thereof, Stroehan states as follows: 1. The nae and address of the entity seeking intervention is: Stroehan Bakeries, Inc. 255 Business Center Drive, Suite 200 Horsha,'PA Attention: Glenn E. Harris Director of Purchasing Phone! (215) Fax: (215) Stroehan will be represented in this proceeding by the following counsel: Alan Kohler, Esquire Mark Stewart, Esquire Wolf, Block, Schorr and Solis-Cohen LLP 212 Locust Street, Suite 300 Harrisburg, PA Phone: (717) Fax:(717) akohler(g),wol fblock.co stewart(a).wol fblock.co DSH:277]8.)

28 3. On May 1, 2001, UGI Utilities, Inc. ("UGI"), filed with the Coission its preliinary Section 1307(f) filing for the period of Deceber 1, 2001, through Noveber 30, Pa. C.S. 1307(f). On June 1, 2001, UGI subitted its definitive Section 1307(f) filing, including PGC 2001 Tariff Addendu Gas Pa. P.U.C. No. 5 and supporting testiony. Based on the definitive filing, UGI projects decreasing its PGC(l) rates by Sl.lOOO/Mcf to a charge of $8.1134/Mcf and decreasing its PGC(2) rates by SI.6017 per Mcf to a charge of $6.6999/Mcf. UGI's filing also addresses the recovery of interest on undercollections, UGI's igration rider, capacity release and off-syste sales, UGI's unaccounted for rate, and its Custoer Choice Interruptible Revenue Credit. 4. As part of its efforts to recover gas costs, UGI iposes a capacity charge on LFD class custoers, based upon assigned capacity costs, and in addition a Syste Access Fee, which represents the difference between the assigned capacity cost and UGFs weighted average cost of gas. Custoer class LFD is the only class of custoers that UGI charges a Syste Access Fee. 5. Stroehan is a large volue custoer receiving transportation and related services fro UGI pursuant to transportation delivery service rate schedules and the general ters of delivery service set forth in Rule 17 of UGI's tariff. Stroehan purchases service fro UGI under Rate LFD ~ Large Fir Delivery. Stroehan uses large volues of natural gas in its bakeries, and natural gas costs are a significant eleent of its products' cost. Accordingly, the Coission's final disposition of UGI's Section 1307(f) filing will have an ipact upon the DSH

29 rates and charges Stroehan pays for natural gas transportation and other services. 1 Therefore, Stroehan has a significant interest in this proceedings, and it is not represented by any other party of record. WHEREFORE, Stroehan respectfully requests that the Coission grant this Petition to Intervene with active party status. Respectfully subitted, Date: June 20, 2001 Alan Kohler, Esq. MarkS. Stewart, Esq. Wolf, Block, Schorr and Solis-Cohen LLP 212 Locust Street, Suite 300 Harrisburg, PA Counsel to Stroehan Bakeries, Inc. ' In addition to concerns with recovery of gas costs through UGI's Syste Access Fee, Stroehan shares in the concerns raised by the UGI Industrial Interveners ("UGIII") in footnote one of their June 11, 2001Petition to Intervene. DSH: "3-

30 CERTIFICATE OF SERVICE I hereby certify that I have this day served a true copy of the foregoing docuent upon the participants, listed below, in accordance with the requireents of 1.54 (relating to service by a participant). VIA FIRST CLASS MAIL AND David B. MacGregor, Esquire Morgan, Lewis & Bockius 1701 Market Street Philadelphia, PA Stephen J. Keene, Esquire Office of Consuer Advocate 555 Walnut Street Foru Place - 5th Floor Harrisburg, PA 17101=1923 Angela T. Jones, Esquire Office of Sall Business Advocate Coerce Building - Suite North Second Street Harrisburg, PA Mark C. Morrow, Esquire UGI Utilities - Gas Division PO Box 858 Valley Forge, PA o 5^ ZD CZ TO > CD ro o -o zs. CO CO CO 33 o o Kandace Melillo, Esquire Office of Trial Staff Coonwealth Keystone Building 400 North Street, 2nd Floor Harrisburg, PA Paela Polacek, Esquire McNees, Wallace & Nurick, LLC 100 Pine Street P.O.Box 1166 Harrisburg, PA Date: June 20, 2001 Alan Kohler, Esq. DSH:

31 OALJ Hearing Report PieaWfheck Those Blocks Which Apply Docket No.: YES NO Prehearing Held: Case Nae: \C^^sCUM^M^i^ Hearing Held: Cr. Testiony Taken: Transcript Due: Hearing Concluded: Location: Philadelphia, PA Y ^ Further Hearing Needed: Date: June2/i 2001 Estiated Add'l Days: RECORD CLOSED: ALJ: Ky Van Nguyen DATE: Briefs to be Filed: Reporting Fir: Coonwealth Reporting DATE: TP 'JUL Bench Decision: REMARKS: Nae and Tsieph$ne : Nuber Address Who are you representing? Telephone:^t^ ^ E-ail Address: City J State ^» Zip Hi o-l Fax Nuber: ^ ^ To eve. S LP City State Zip ll/df O 6 cai-e- Telephone:. - E-ail Address: v Fax Nuber: H^r IC Ko/ro to City State Zip Telephone: E-ail Address: Fax Nuber: ^ Check this box if additional parties or attendees appear on back of for. ' Reporter's Signature Note: Copletion of this for does not constitute an entry of appearance, see 52 Pa. Code 1.24 and 1.25.

32 * Nae and Telephone Nuber Address Who are you representing? \<jxnaic W U o Lido 0, Sf^ Fl Telephone: City E-ail Address: 0 State t* Zip -r- \ \ C 1 -C-L Fax Nuber: City Telephone: E-ail Address: Fax Nuber: State?«Zip Telephone: City E-ail Address: J State f4 Zip no \ Fax Nuber: City State Zip Telephone: E-ail Address: Fax Nuber: City State, Zip Telephone: E-ail Address: Fax Nuber: City State Zip Telephone: E-ail Address: Fax Nuber: City State Zip Telephone: E-ail Address: Fax Nuber: City State Zip Telephone: E-ail Address: Fax Nuber: / / v t/. y /