CANADA
QUÉBEC ENERGY BOARD
PROVINCE OF QUEBEC
DISTRICT OF MONTREAL
Re: Request to lift the obligation to issue a
call for tenders to meet the needs of
customers with Dual-Energy Business Rate
(BT) service contracts
NO. : R-3490-2002
HYDRO-QUÉBEC
Applicant
and
PG&E CORPORATION’S NATIONAL
ENERGY GROUP INC, a body corporate
created pursuant to the laws of Delaware,
having its head office at 7500 Old
Georgetown Road, in the City of
Bethesda, state of Maryland, U.S.A.
(Hereinafter “NEG”)
Intervenor
REQUEST FOR INTERVENTION
IN SUPPORT OF ITS PRESENT APPLICATION FOR INTERVENTION PURSUANT
TO RULE 8 OF THE REGULATION RESPECTING THE PROCEDURE OF THE
RÉGIE DE L’ÉNERGIE, THE INTERVENOR HEREBY STATES THAT:
NATURE OF NEG’S INTEREST
1.
PG&E Corporation is an integrated, full-service provider of energy and related
services throughout North America. It is composed of the regulated California
utility and four competitive business units that compete in the North American
energy market and that operate separately from the utility;
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2.
NEG, with regional offices from coast to coast, is one of North America’s leading
competitive power producers, has natural gas facilities that connect major
producing regions to some of the fastest-growing markets in North America, and
operates one of the top energy trading businesses in the United States;
3.
NEG is already doing significant business in the Northeast United States, in
Ontario and intends to expand its business in markets in eastern Canada and in
the Province of Québec;
4.
Furthermore, NEG has monitored the evolution of the Québec energy regulatory
environment, has intervened in the case R-3401-98 “Revised application for the
modification of rates for the transmission of electric power” and is currently
participating in the HQ-Distribution Call for Tender A/O 2002-01;
5.
Consequently, NEG is generally concerned with the open access, the reciprocity
and the market conditions of adjoining jurisdictions;
REASONS IN SUPPORT OF THE INTERVENTION
6.
NEG would like to have the opportunity to present its views on the different
avenues to supply the segment of BT rate Québec customers based on industries
practices and energy products available from its own generating and trading
portfolio, as well as surrounding power pools, for the ultimate benefit of Quebec
ratepayers.
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7.
Hydro-Québec’s request to lift its obligation to issue a call for tenders and to be
authorized to enter into an agreement with Hydro-Québec Production may deny
BT rate customers the opportunity to benefit from market prices offered by other
supply avenues;
8.
In this context, NEG submits that it is in the public interest that NEG’s request
for intervention be granted by the Québec Energy Board;
9.
NEG respectfully submits that it should be granted such an intervenor status
notwithstanding the lateness of its application;
10.
NEG apologizes for the lateness of its application, as NEG was only notified last
week of the existence of this present case;
11.
NEG has reacted as quickly as possible in order to file this request in a timely
fashion and to enable Hydro-Quebec to file it’s comments in regard to this
request, if any, along with it’s comments on other participant’s requests for
intervention;
12.
Despite the fact that NEG is filing this request four working (4) days following
the set date of July 12th 2002 by the Energy Board, NEG respectfully submits that
no prejudice will result for Hydro-Québec and that this filing will have little
impact on the advancement of this file;
13.
NEG intends to claim participation costs in the present proceedings;
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14.
NEG requests that a copy of the application and other documents submitted and
to be submitted in respect of the present proceeding be sent to:
Me Michel G. Ménard
LAPOINTE ROSENSTEIN
1250 René-Lévesque Blvd West
Suite 1400
Montreal, Quebec H3B 5E9
Tel.:
(514) 925-6328
Telecopier: (514) 925-9001
E-Mail:
michel.menard@lapointerosenstein.com
FOR THESE REASONS, NEG RESPECTFULLY REQUESTS THE QUÉBEC ENERGY
BOARD :
GRANT NEG’S request for intervention;
GRANT NEG intervenor status in the present proceedings;
Signed in Montreal, this 18th day of July 2002
__________________________________________
LAPOINTE ROSENSTEIN
Attorneys for NEG
(695929 v4)