UNITED STATES OF AMERICA
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
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`Northern Natural Gas Company )
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`Docket No. RP22-1033-000
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`UNOPPOSED MOTION
`TO SUSPEND THE PROCEDURAL SCHEDULE,
`WAIVE ANSWER PERIOD AND REQUEST FOR EXPEDITED ACTION
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`To: The Honorable Andrew Satten
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`Acting Chief Administrative Law Judge
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`
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`The Honorable Patricia M. French
`Presiding Administrative Law Judge
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`Pursuant
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`to Rule 212 of
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`the Federal Energy Regulatory Commission's
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`(Commission) Rules of Practice and Procedure, 18 C.F.R. § 385.212 (2022), Northern
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`Natural Gas Company ("Northern") on behalf of all of the Participants in this proceeding,1
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`respectfully requests that the Chief Administrative Law Judge, in consultation with the
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`Presiding Administrative Law Judge, (i) suspend the procedural schedule in this
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`proceeding with the understanding that the Participants shall submit a status report to the
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`Chief and Presiding Judges if a settlement agreement has not been filed by June 30, 2023,
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`(ii) waive the answering period to this Motion provided by Rule 213, 18 C.F.R. §385.213
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`(2022), and (iii) expeditiously grant the motion so that the Participants may avoid the
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`significant time and expense associated with meeting a series of rapidly approaching
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`1 Northern provided a draft of this Motion to all Participants in this proceeding, and none has expressed opposition to
`the requests set forth herein.
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`
`BEFORE THE
`FEDERAL ENERGY REGULATORY COMMISSION
`
`
`
`
`Northern Natural Gas Company )
`
`Docket No. RP22-1033-000
`
`
`
`
`
`UNOPPOSED MOTION
`TO SUSPEND THE PROCEDURAL SCHEDULE,
`WAIVE ANSWER PERIOD AND REQUEST FOR EXPEDITED ACTION
`
`
`To: The Honorable Andrew Satten
`
`Acting Chief Administrative Law Judge
`
`
`
`
`The Honorable Patricia M. French
`Presiding Administrative Law Judge
`
`
`
`Pursuant
`
`to Rule 212 of
`
`the Federal Energy Regulatory Commission's
`
`(Commission) Rules of Practice and Procedure, 18 C.F.R. § 385.212 (2022), Northern
`
`Natural Gas Company ("Northern") on behalf of all of the Participants in this proceeding,1
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`respectfully requests that the Chief Administrative Law Judge, in consultation with the
`
`Presiding Administrative Law Judge, (i) suspend the procedural schedule in this
`
`proceeding with the understanding that the Participants shall submit a status report to the
`
`Chief and Presiding Judges if a settlement agreement has not been filed by June 30, 2023,
`
`(ii) waive the answering period to this Motion provided by Rule 213, 18 C.F.R. §385.213
`
`(2022), and (iii) expeditiously grant the motion so that the Participants may avoid the
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`significant time and expense associated with meeting a series of rapidly approaching
`
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`1 Northern provided a draft of this Motion to all Participants in this proceeding, and none has expressed opposition to
`the requests set forth herein.
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`
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`procedural deadlines. Granting this Motion will allow the Participants to draft and file
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`definitive documents memorializing the settlement that all Participants have agreed to in
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`principle, together with any associated documents.
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`
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`This proceeding began when Northern filed a general section 4 rate case on July 1,
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`2022. The Participants in these proceedings have engaged in extensive settlement
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`discussions which included multiple settlement conferences, numerous telephone
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`conference calls, the exchange of settlement offers and counter-offers, and countless other
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`communications to iron out the differences among the varied interests involved in this case.
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`Despite the many diverse interests and strongly held opinions, the Participants reached an
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`agreement in principle to settle the case on May 12, 2023. This Motion is an important step
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`towards promptly finalizing and filing definitive settlement documents that will benefit all
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`the Participants.
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`In light of the agreement in principle, the Participants request that the Chief Judge,
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`in consultation with the Presiding Judge, suspend the procedural schedule with provision
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`for a status report, as suggested above, so that the Participants can focus their time and
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`resources on finalizing and filing a definitive offer of settlement. Good cause exists to grant
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`this motion because it will (i) avoid the great time and expense of protracted litigation of a
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`complex case involving numerus participants, (ii) provide benefits to the Participants much
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`more quickly than litigation, and (iii) allow the Participants to focus their time and
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`resources on finalizing a definitive offer of settlement.
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`2
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`Northern circulated a draft of this Motion to all Participants in this proceeding. No
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`Participant has indicated that it opposes the request to suspend the procedural schedule. In
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`light of the lack of opposition to this Motion, Northern requests, on behalf of all
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`Participants, that the Chief Judge, in consultation with the Presiding Judge, act as soon as
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`possible to waive the answering period to this Motion and issue an order suspending the
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`procedural schedule, thereby allowing the Participants to focus their efforts on finalizing
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`an offer of settlement.
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`CONCLUSION
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`
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`The Participants request that (i) the procedural schedule be suspended with a
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`requirement to report to the Chief Administrative Law Judge and the Presiding
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`Administrative Law Judge or to file an offer of settlement by June 30, 2023, (ii) the
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`answering period for this motion be waived in light of the fact that all Participants either
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`support or do not oppose the Motion, and (iii) the Motion be granted expeditiously.
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`
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`Respectfully submitted,
`
`/s/ Monique L. Watson
`Monique L. Watson
`Karen Bruni
`STEPTOE & JOHNSON LLP
`1330 Connecticut Avenue, N.W.
`Washington, D.C. 20036-1795
`mwatson@steptoe.com
`kbruni@steptoe.com
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`Counsel for Northern Natural Gas
`Company
`
`
`Kirk Lavengood
`Vice President, General Counsel
`& Regulatory Affairs
`J. Gregory Porter
`Assistant General Counsel
`Britany S. Shotkoski
`Senior Attorney
`Northern Natural Gas Company
`1111 South 103rd Street
`Omaha, Nebraska 68124-1000
`kirk.lavengood@nngco.com
`greg.porter@nngco.com
`britany.shotkoski@nngco.com
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`3
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`CERTIFICATE OF SERVICE
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`I hereby certify that I have this day served a copy of the foregoing document on
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`each person designated on the official service list compiled by the Secretary for this
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`proceeding.
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`Dated at Washington, D.C. this 15th day of May 2023.
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` /s/ Karen Bruni
`Karen Bruni
`Steptoe & Johnson LLP
`1330 Connecticut Avenue, N.W.
`Washington, D.C. 20036
`(202) 429-6454
`kbruni@steptoe.com
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`4
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