20150623Petition to Intervene.pdf

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Bred M. Purdy
Attoraev etlaw
2ol9 N: 176 st.
Boise,Idalro 83702
[phone]
Cell: [phone]
Fa,x: [phone]
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Iwle22,2015
Ms. Jean Jewell
Secretary
Idaho Public Utilities Commission
472W. Washington
Boise,lD 83702
Re: Case No. IIWI-W-15-01: United Water Idaho's General Rate Case
DearMs. Jewell:
Enclose4 please find an original and s seven (7) copies of Community Action Partnership
Association of Idaho's Petition to Intervene in the above-referenced proceeding.
Yours tnrly,
i-'i
Brad M. Furdy
Brad M. Purdy
Attorney atLaw
Bar No. 3472
2019 N. lTth St.
Boise,lD. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NO. trWI,W-15-01
OF UNITED WATER IDAHO,INC. FOR )
AUTHORITY TO INCREASE ITS RATES ) COMMUNITY ACTION
AND CHARGES FOR WATER SERVICE IN ) PARTNERSHIP ASSOCIA.
THE STATE OF IDAHO. ) TION OF IDAHO',S PETITTON
) TO INTERYENE
)
COMES NOW, Community Action Partnership Association of Idaho (hereinafter
*CAPAI" 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 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 Idatro
3350 W. Americana Terrace, Suite 360
Boise,ID. 83706
2. This Intervenor will be represented in this proceeding by, and pleadinss and other
correspondence need only be sent to:
Brad M. Ptrdy
Attorney at Law
CAPAI PETITION TO INTERVENE
2ol9 N. l7m st.
Boise,ID. 83702
208-384-1299
FAX: [phone]
Email: [e-mail]
3. CAPAI is a non-profit corporation consisting of six community action agencies serving
every county in Idaho and also includes, among others, the statewide Community Council of
Idatro (formerly the Idatro 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, Inc.'s low income rate payers. Low income families pay ahigher
percentage of their income for utility expenses than those in other economic categories. These
conditions are often caused by living in sub-standard or older housing that is not energy or utility
effrcient. CAPAI is the only party w-ho typically intervenes in proceedings before the
Commission; specifically representing public utilities' low-income customers. Consequently, it
is fair to say that CAPAI has filled an importarrt role that long stood vacant. CAPAI believes
that it fulfills an important role in this, and similar proceedings, and without the opportunity to
participate as aparty in this proceeding, would be unable to fulfill that role.
4. CAPAI respectfully requests the right to participate in this proceeding as a party and
intoduce testimony and exhibits, cross-examine other witnesses, engage in oral argument, file
comments, and otherwise fully participate as a party.
5. It is CAPAI's policy to only pat'ricipate in cases w-here it believes that its involv-ement
will aid the Commission in reaching evenly balanced decisions and where CAPAI's participation
adds to the substantive analysis of the case without unduly expanding the scope of the
proceeding. CAPAI submits that its participation in this proce.eding would meet these criteria.
CAPAI PETITION TO INTERVENE
As CAPAI has often pointed out to the Commission, its ability to participate in proceedings
before the Commission is limited by available money and otherriesources.
WHEREFORE, the Community Action Partnership Association 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.
CAPAI PETITION TO INTERVENE
DATED, this 22nd day of Jrme,20l5.
CAPAI PETITION TO INTERVENE