20201112Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. lTth St.
Boise,ID. 83702
[phone] (Land)
[phone] (Cell)
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Attomey for Petitioner
Community Action Partnership
Association of Idaho
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
TN THE MATTER OF SUEZ WATER IDAHO
INC.'S APPLICATION FOR AUTHORITY
TO INCREASE ITS RATES AND CHARGES
FOR WATER SERVICE IN IDAHO
PRUDENTLY INCI.'RRED.
CASE NO. SUZ-W-20-02
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S PETITION
TO INTERVENE
COMES NOW, Community Action Partnership Association of ldaho ("CAPAI") and,
pursuant to Rules 071-076 of the Commission's Rules of Practice and Procedure, IDAPA
31.01.01 .071-076, as well as Order No. 34819 issued October 21,2020, hereby petitions the
Commission for leave to intervene in this proceeding and to appear and participate with full
party's rights. In support of this Petition, CAPAI states as follows:
1. The address and name of the Petitioner is:
Community Action Partnership Association of Idaho
3350 W. Americana Terrace, Suite 360
Boise,lD. 83706
2. CAPAI will be represented in this proceeding by, and nleadines and other
correspondence need only be sent to:
COMMUNITY PARTNERSHIP ASSOCIATION OF TDAHO'S PETITION TO TNTERVENE I
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Brad M. Purdy
AttomeY at Law
2019 N. tz6 st.
Boise, ID. 83702
208-384-1299 (Land)
208-484-9980 (Cell)
[e-mail]
CAPAI is a non-profit corporation consisting of six community action agencies serving
every county in ldaho and inctude Suez's service tenitory. CAPAI's mission is to fight the
causes and conditions of poverty through building the capacity and effectiveness of its member
agencies who have a direct and substantial interest in this proceeding. These causes and
conditions of poverty are numerous and disparate and include the cost of utility services.
Low income families pay a higher percentage of their income for utility expenses than
those in other economic categories. CAPAI is typically the only party who intervenes in
proceedings before the Commission specifically representing public utilities' low income
customers. CAPAI has been involved over many years in a considerable number of proceedings
before this Commission, some including Suez and its predecessor companies operating under
prior names.
Given the magnitude of the rate increase sought by Suez, as well as possible rate design
issues, and the potential that existing low income customers might effectively be effectively
subsidizing the costs associated with of growth in one of the nation's metropolitan areas
experiencing record growth, is of considerable concern to low income customers, CAPAI
believes that it will fuIfi|Ian important role in this proceeding, if given the opportunity to
participate as a Party.
COMMUNITY PARTNERSHIP ASSOCI"ATION OF IDAHO'S PETITION TO INTERVENE 2
Consequently, CAPAI respectfully submits that it has a direct and substantial interest in
the subject matter of this proceeding and its intervention will not unduly broaden the scope of
issues presented by Suez's Application.
4. CAPAI respectfully requests the right to futly participate in this proceeding as a party.
WHEREFORE, the Community Action Partnership Association of [daho hereby requests
that this Commission grant its Petition to [ntervene in this proceeding and the right to fully
appear and participate as a party with all the rights and responsibilities related thereto.
DATED, this l lth day of November, 2020.
M. Purdy
COMMUNITY PARTNERSHIP ASSOCIATION OF TDAHO'S PETITION TO TNTERVENE 3
CERTIHCATE OF SERYICE
I hereby certiff that on this 11ft day of November, 2020,I served true and correct copies
of the foregoing document to those individuals listed below via electronic delivery:
Diane Hanian
Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,ID 83702
Diane. hanian@puc. idaho. gov
Lisa D. Nordstrom
Idaho Power Company
P.O. Box 70
Boise,ID 83707-0070
l nordstrom(Eidahooower.com
dockets @.idahoDower. com
Connie Aschenbrenner
Idalro Power Company
P.O. Box 70
Boise,ID 83707-0070
caschenbrenner@ idahopower. com
Peter J. Richardson
Industrial Customers of ldaho Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N.27th St
P.O. Box 7218
Boise,Idaho $7Az
netertE richardsonadams. com
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Brad M. Purdy
Attorney for CAPAI
COMMUNITY PARTNERSHIP ASSOCIATION OF IDAHO'S PETITION TO INTERVENE 4