20110809Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
RECEIVEDi.
inu ~UG -9 PM 1: 59
Augut 9, 2011
Ms. Jean Jewell
Secreta
Idaho Public Utilities Commssion
472 W. Washigton
Boise,ID 83702
Re: Cas No. UWI-W-11-02: United Water Idaho's General Rate Case
Dear Ms. Jewell:
Enclosed, please fid an origial and s seven (7) copies of Communty Action
Parership Association of Idao's Petition to Intervene in the above-referenced
proceeding.
Yours trly,~-Brad M. Purdy
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Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdy(ßhotmail.com
Attorney for Petitioner
Communty Action Parership
Association of Idaho
RECEIVED
20" AUG -9 PM 2: 35
IDi\r.¡n
f' -I i L 1 -c' ,,-~ ;.:"J I ií~,j
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION )
OF UNTED WATER IDAHO, INC. FOR )
AUTHORITY TO INCREASE ITS RATES )
ANDCHAGESFORWATERSERVICEIN )THE STATE OF IDAHO. )
)
)
CASE NO. UW-W-LL-02
COMMTY ACTION
PARTNERSHI ASSOCIA-
TION OF IDAHO'S PETITION
TO INTERVENE
COMES NOW, Communty Action Parership Association ofIdao (hereinafer
"CAPAl' or "Intervenor") and, puruat to Rules 071-075 of the Commission's Rules of
Practice and Procedure, IDAPA 31.01.01.071-075, hereby petitions the Commssion for leave to
intervene in ths proceeding and to appear and paricipate with ful par's rights. In support of
this Petition, CAP AI sttes as follows:
1. The address and name of the Petitioner is:
Communty Action Parership Association of Idaho
5400 W. Frain Rd., Suite G
Boise, ID. 83705
2. Ths Intervenor will be represented in ths proceeding by, and pleadings and other
correspondence'llèed o11y be sent to:
Brad M. Pudy
Attorney at Law
CAP AI PETITION TO INTERVENE 1
2019 N. 17th St.
Boise, il. 83702
208-384-1299
FAX: [phone]
Email: bmpurdyCihotmail.com
3. CAP AI is a non-profit corporation consisting of six communty action agencies servng
every county in Idaho and also includes, among others, the sttewide Communty Council of
Idaho (fornerly the Idao Migrant Council) and fights the causes and conditions of poverty
through buildig the capacity and effectiveness of its members who have a direct and substatial
interest in ths proceeding. These causes and conditions of povert include high utility costs for
United Water Idao, Inc.' s low income rate payers. Low income famlies pay a higher
percentage of their income for utilty expenses than those in other economic categories. These
conditions are often caused by living in sub-stadard or older housing tht is not energy or utilty
efficient. CAPAI is the only par who tyically intervenes in proceedings before the
Commission; specifically representing public utilities' low-income cusomers. Consequently, it
is fai to say tht CAP AI has filled an importt role that long stood vact. CAP AI believes
that it fufills an importt role in ths, and simlar proceedgs, and without the opportty to
parcipate as a par in this proceeding, would be unable to fufill that role.
4. CAP AI respectfuly request the right to parcipate in ths proceedig as a par and
introduce testimony and exhbits, cross-examne other witnesses, engage in oral arguent, file
comments, and otherwse fuly paricipate as a par.
5. It is CAPAI's policy to only parcipate in cases where it believes that its involvement
will aid the Commssion in reachig evenly balanced decisions and where CAP AI's paricipation
adds to the substative analysis of the case without unduly expandig the scope of the
proceeding. CAP AI submits tht its paicipation in ths proceedig would meet these criteria.
CAP AI PETITION TO INTERVENE 2
As CAP AI has often pointed out to the Commission, its abilty to paricipate in proceedings
before the Commission is limited by available money and other resources.
WHREFORE, the Communty Action Parership Association of Idao hereby requests
that ths Commssion grt its Petition to Intervene in ths proceding and to fuly appea and
paricipate as a par with all the attendant rights and responsibilities.
DATED, ths 9t day of Augut, 2011.
ß~Bra M. Puy cß
CAP AI PETITION TO INTERVENE 3