20041222Petition to Intervene .pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
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Attorney for Petitioner
Community Action Partnership
Association of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF UNITED WATER INC. FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
COMMUNITY ACTION
PARTNERSHIP ASSOCIA-
TION OF IDAHO'
PETITION TO INTERVENE
CASE NO. UWI-04-
COMES NOW, Community Action Partnership Association of Idaho (hereinafter
CAP AI" or "Intervenor ) and, pursuant to Rules 071-075 of the Commission s Rules of
Practice and Procedure, IDAPA 31.01.01.071-075 , hereby petitions the Commission for
leave to intervene in this proceeding and to appear and participate with full parties
rights. In support of this Petition, CAP AI states as follows:
The address and name of the respective Intervenor is:
Community Action Partnership Association of Idaho
O. Box 8224
Boise, ID. 83707
This Intervenor will be represented in this proceeding by:
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email:
Copies of all pleadings, production requests, responses, Commission Orders and
Notices and other documents should be provided to Brad M. Purdy.
CAP AI is a non-profit corporation consisting of six community action agencies
serving every county in Idaho and also includes, among others, the statewide Idaho
Migrant Council and fights the causes and conditions of poverty through building the
capacity and effectiveness of its members who have a direct and substantial interest in
this proceeding. These causes and conditions of poverty include high utility costs for
United Water Idaho s low income rate payers. Low income families pay a higher
percentage of their income for utility expenses that those in other economic categories.
CAP AI notes that beginning on page 16 of his pre-filed direct testimony, United
Water Idaho witness Gregory P. Wyatt states that the Company does not currently have a
low-income assistance program in place. Mr. Wyatt states that, in light of the requested
22% overall rate increase, United Water Idaho recognizes the need to consider and
discuss such a program. United Water Idaho proposes conducting a workshop(s) prior to
the hearing on its application for the purpose of collaboratively designing such a program
for the Commission s consideration.
CAP AI obviously supports United Water Idaho s foregoing proposal, in the
abstract. CAP AI respectfully submits that its invo lvement this proceeding is essential
to a full and meaningful consideration of the issue.
CAP AI further believes that, based upon empirical studies conducted on the issue
there are system-wide benefits to be derived ftom properly structured low-income
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
assistance programs, thereby potentially benefiting all of United Water Idaho
customers.
CAP AI intends to participate in this proceeding as a party and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral argument and
otherwise fully participate as a party.
WHEREFORE, the Community Action Partnership of Idaho hereby requests that
this Commission grant its Petition to Intervene in this proceeding and to fully appear and
participate as a party with all the attendant rights and responsibilities.
DATED, this 22nd day of December, 2004.
Brad M. Purdy
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22nd day of December, 2004, I caused to be
served the foregoing PETITION TO INTERVENE OF COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO on the following, in the manner indicated.
Weldon Stutzman
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID. 83702
(J U.S. Mail, postage prepaid
Hand delivered
(J Facsimile
(J Overnight mail
Dean J. Miller
McDevitt & Miller LLP
420 W. Bannock St.
Boise, Idaho 83702
1?9 U.S. Mail, postage prepaid
(J Hand delivered
(J Facsimile
(J Overnight mail
Mark Gennari
United Water
200 Old Hook Road
Harrington Park, NJ 07640-1738
,fJ, U.S. Mail, postage prepaid
(J Hand delivered
(J Facsimile
(J Overnight mail
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO