STATE OF INDIANA

INDIANA UTILITY REGULATORY COMMISSION

VERIFIED PETITION OF NORTHERN INDIANA ) PUBLIC SERVICE COMPANY LLC FOR (1) APPROVAL ) OF AND A CERTIFICATE OF PUBLIC CONVENIENCE ) AND NECESSITY FOR A FEDERALLY MANDATED ) PIPELINE SAFETY II COMPLIANCE PLAN; (2) ) AUTHORITY TO RECOVER FEDERALLY MANDATED ) COSTS INCURRED IN CONNECTION WITH THE ) PIPELINE SAFETY II COMPLIANCE PLAN; (3) ) APPROVAL OF THE ESTIMATED FEDERALLY ) MANDATED COSTS ASSOCIATED WITH THE ) PIPELINE SAFETY II COMPLIANCE PLAN; (4) ) AUTHORITY FOR THE TIMELY RECOVERY OF 80% ) OF THE FEDERALLY MANDATED COSTS THROUGH ) CAUSE NO. 45560 RIDER 190 – FEDERALLY MANDATED COST ) ADJUSTMENT RIDER (“FMCA MECHANISM”); (5) ) AUTHORITY TO DEFER 20% OF THE FEDERALLY ) MANDATED COSTS FOR RECOVERY IN NIPSCO’S ) NEXT GENERAL RATE CASE; (6) APPROVAL OF ) SPECIFIC RATEMAKING AND ACCOUNTING ) TREATMENT; AND (7) APPROVAL OF ONGOING ) REVIEW OF THE PIPELINE SAFETY II COMPLIANCE ) PLAN; ALL PURSUANT TO IND. CODE §8-1-8.4-1 ET ) SEQ., § 8-1-2-19, § 8-1-2-23, AND § 8-1-2-42. )

NIPSCO INDUSTRIAL GROUP’S PETITION TO INTERVENE

Come now certain intervenors, designated collectively as the NIPSCO Industrial Group

(“Industrial Group”), by counsel, and file their Petition to Intervene in the above captioned proceeding and in support of their Petition state:

1. Industrial Group is an ad hoc group of industrial users located in the gas service territory of Northern Indiana Public Service Company (“NIPSCO”), including the companies listed on Appendix “A”, which is attached. Additional members may be joining the Industrial

Group for the purposes of this proceeding, and in the event of any changes in membership the

Commission will be so notified.

2. As industrial customers of NIPSCO purchasing gas services from it, the members of the Industrial Group have a direct, immediate, and substantial interest in the subject matter of this proceeding.

3. The interests of the members of the Industrial Group are not and will not be adequately represented by any other party in this proceeding.

4. Members of the Industrial Group believe that NIPSCO should provide gas service in an efficient, dependable, and economic manner consistent with sound management, and

NIPSCO has a duty and responsibility to make every reasonable effort to manage its gas system and conduct gas operations so as to provide gas services to retail customers at the lowest cost that is reasonably possible.

5. Because of the importance of energy in their industrial operations, members of

Industrial Group are substantially affected by the cost of gas service provided by NIPSCO.

Intervention by the Industrial Group in this proceeding is for purposes of responding to issues raised by NIPSCO’s Petition or required by law to be determined by the Commission in this proceeding and all related issues.

6. The intervention of the Industrial Group will not unreasonably broaden the issues involved in this proceeding.

7. The attorneys representing the Industrial Group in this proceeding are:

Todd A. Richardson, Atty. No. 16620-49 Aaron A. Schmoll, Atty. No. 20359-49 LEWIS & KAPPES, P.C. One American Square, Suite 2500 Indianapolis, Indiana 46282-0003 Telephone: (317) 639-1210 Facsimile: (317) 639-4882 Email: [email protected] [email protected]

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The above named attorneys are authorized to accept service of papers in this proceeding on behalf of the Industrial Group.

8. This Petition to Intervene is being filed more than five (5) days prior to any date set for the initial evidentiary hearing in this proceeding.

WHEREFORE, the members of the NIPSCO Industrial Group, as set forth on Appendix

“A”, respectfully request that they be granted leave to intervene and be made parties to the above captioned proceeding.

Respectfully submitted,

LEWIS & KAPPES, P.C.

/s/ Aaron Schmoll Todd A. Richardson, Atty No. 16620-49 Aaron A. Schmoll, Atty No. 20359-49

One American Square, Suite 2500 Indianapolis, Indiana 46282-0003 Telephone: (317) 639-1210 Facsimile: (317) 639-4882 Email: [email protected] [email protected]

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APPENDIX “A”

BP PRODUCTS NORTH AMERICA, INC. LINDE Whiting Business Unit 4400 Kennedy Ave. 2815 Indianapolis Blvd. East Chicago, IN 46312 Whiting, Indiana 46394 NLMK INDIANA CARGILL, INC. 6500 South Boundary Road 1100 Indianapolis Blvd. Portage, Indiana 46368 Hammond, Indiana 46320 UNITED STATES STEEL CORPORATION CLEVELAND-CLIFFS INC. Gary Works 3300 Dickey Road MC 4-442 One North Broadway East Chicago, Indiana 46312 Gary, Indiana 46402

GENERAL MOTORS, LLC USG CORPORATION 12200 Lafayette Center Road 301 Riley Rd. Roanoke, Indiana 46783 East Chicago, Indiana 46312

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CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of the foregoing has been served upon the following via electronic mail, this 27th day of July, 2021:

Robert E. Heidorn Jeffrey M. Reed Kathryn A. Bryan OFFICE OF THE UTILITY CONSUMER NISOURCE CORPORATE SERVICES – LEGAL COUNSELOR 150 West Market Street, Suite 600 115 W. Washington St., Suite 1500 South Indianapolis, IN 46204 Indianapolis, Indiana 46204 rheidorn@nisource.com [email protected] [email protected] [email protected]

Courtesy copy to: Alison M. Becker NORTHERN INDIANA PUBLIC SERVICE COMPANY 150 West Market Street, Suite 600 Indianapolis, IN 46204 [email protected]

/s/ Aaron Schmoll Aaron A. Schmoll

LEWIS & KAPPES, P.C. One American Square, Suite 2500 Indianapolis, Indiana 46282-0003 Telephone: (317) 639-1210 Facsimile: (317) 639-4882

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