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BEFORE THE
ARKANSAS PUBLIC SERVICE COMMISSION
IN THE MATTER OF THE APPLICATION OF
OKLAHOMA GAS AND ELECTRIC COMPANY
FOR APPROVAL OF A GENERAL CHANGE IN
RATES, CHARGES AND TARIFFS
) DOCKET NO. 16-052-U
)
)
)
ARKANSAS RIVER VALLEY ENERGY CONSUMERS
PETITION TO INTERVENE
Arkansas River Valley Energy Consumers ("ARVEC") petitions this Commission for
leave to intervene in this proceeding pursuant to Rule 4.02 of the Arkansas Public Service
Commission's ("APSC" or "Commission") Rules of Practice and Procedure. In support of its
Petition, ARVEC states as follows:
1.
ARVEC is an unincorporated, trade association whose members are industrial and
other large consumers of energy operating within the State of Arkansas that purchase electricity
from Oklahoma Gas and Electric Company ("OO&E"). Exhibit A to this Petition identifies the
members of ARVEC.
2.
On August 25, 2016, OG&E filed an Application for Approval of a General
Change in its Rates for Retail Electric Service. In its Application, OO&E requests approval of a
rate increase of $16.5 million, a formula rate plan and certain cost recovery riders.
3.
ARVEC has a direct interest in the outcome of this proceeding as OO&E's
Application affects its members. Therefore, ARVEC wishes to be heard on the matters at issue
herein as such matters will affect the costs and terms or conditions of electric service from
OO&E. Although ARVEC cannot identify all of the issues that it will address at this time,
ARVEC intends to address such issues as OO&E's proposed revenue requirement, OO&E's
proposed cost of service and rate design, OO&E's proposed formula rate plan and OO&E's
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proposed cost recovery riders, to ensure the implementation of fair and reasonable rates.
4.
An increase in the rates and charges for electricity such as that being requested by
OG&E in this Docket and the other relief requested by OG&E in this Docket may adversely
affect ARVEC members' businesses and operations in the state of Arkansas. As large industrial
consumers of OG&E, the interests of ARVEC differ significantly from those of other interveners
in this proceeding and ARVEC's interest in this proceeding cannot be adequately represented by
any existing or future participant in this Docket given the unique nature of ARVEC members'
interests. At this time, APSC General Staff, the Attorney General's Office (AG) and Wal-Mart
Stores, LLC and Sam's West, Inc. (collectively, Wal-Mart) have received approval to participate
in this proceeding. Each of these parties has interests that differ significantly from the interests
of ARVEC and its members. For example, OG&E seeks an increase in its rates and charges and
an allocation of those rates and charges among the various classes of customers on OG&E's
system. With regard to the allocation of rate and charges among rate classes, the AG has
historically advocated on behalf of smaller ratepayers, primarily the residential class while the
APSC General Staff has not typically advocated on behalf of large electric consumers, in fact,
neither of these parties exclusively support the interests of large electric users with regard to the
allocation of costs among rate classes and other rate case issues. At times, these parties have
taken positions adverse to the interests of large electric users such as ARVEC's members. In
addition to cost allocation matters, ARVEC intends to address a number of other issues in this
proceeding such as OG&E's proposed revenue requirement, OG&E's proposed formula rate plan
and OG&E's proposed cost recovery riders. In past rate proceedings, to the undersigned's
knowledge and belief, Wal-Mart has not taken a position regarding the utility'S proposed revenue
requirement as will ARVEC. Also, while Wal-Mart is a large commercial user of electricity,
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Wal-Mart is not an industrial customer of OG&E.
Wal-Mart cannot adequately represent the
interests of ARVEC and its members in this proceeding.
Therefore, ARVEC's intervention in
this proceeding is necessary as it will serve the public interest by ensuring that the Commission
is apprised of the interests of industrial and other similarly situated large consumers of energy.
5.
The undersigned requests that he be included on the official service list in this
proceeding and that all communications concerning this Petition should be addressed to him as
follows:
Thomas P. Schroedter
Hall Estill
320 S. Boston Avenue, Suite 200
Tulsa, Oklahoma 74103
918-594-0436
[email protected]
WHEREFORE, ARVEC respectfully requests that it be permitted to intervene as a party
to this Docket and for all other appropriate relief.
Thomas P. Schroedter
Hall Estill
320 S. Boston Avenue, Suite 200
Tulsa, Oklahoma 74103
918-594-0436
[email protected]
Arkansas Bar No. 2015019
ATTORNEY FOR ARKANSAS RIVER VALLEY ELECTRIC CONSUMERS
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CERTIFICATE OF SERVICE
I, Thomas P. Schroedter, do hereby certify that a copy of the foregoing has been served
upon all parties of record by forwarding the same by electronic mail and/or first class mail,
postage prepaid, this 21st day of October 2016.
_-
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,
Thomas P. Schroedter
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APSC FILED Time: 10/21/2016 3:08:39 PM: Recvd 10/21/2016 3:06:28 PM: Docket 16-052-U-Doc. 74
EXHIBIT" A"
ARKANSAS RIVER VALLEY ENERGY CONSUMERS
MEMBERSHIP LIST FOR PURPOSES OF
ARKANSAS PUBLIC SERVICE COMMISSION
DOCKET NO. 16-0S2-U
1.
Acme Brick Company
2.
Dixie Consumer Products
3.
Gerdau Macsteel, Inc.
4.
MPG/Cloyes
5.
OK Foods, Inc.
6.
Rheem Corporation
7.
Tyson Foods
2895578.1 :621046:01532
5