20031112Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
Attorney for Petitioner
Community Action Partnership
Association ofldaho and
American Association of
Retired Persons.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
IDAHO POWER COMPANY FOR AUTHORITY)
TO INCREASE ITS INTERIM AND BASE
RATES AND CHARGES FOR ELECTRIC SERVICE
CASE NO. IPC-O3-
PETITION TO INTERVENE
OF COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO AND
AMERICAN ASSOCIATION
OF RETIRED PERSONS
COMES NOW, Community Action Partnership Association ofIdaho (hereinafter
CAP" or "Intervenor ) and the American Association of Retired Persons (hereinafter
AARP" or "Intervenor ) and, pursuant to Rules 071-075 ofthe Commission s Rules of
Practice and Procedure, IDAPA 31.01.01.071-075, and pursuant to that Notice of
Intervention Deadline issued by this Commission on October 28, 2003, hereby petition
the Commission for leave to intervene in this proceeding and to appear and participate
with full parties' rights. CAP , and AARP, in support ofthis Petition, states as follows:
1. The addresses and names of the respective Intervenors is:
Community Action Partnership Association ofIdaho
O. Box 8224
Boise, ID. 83707
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO and AMERICAN ASSOCIATION OF RETIRED
PERSONS
American Association of Retired Persons:
5400 Franklin Rd.
Boise, ID. 83705
These Intervenors will be represented in this proceeding by:
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email:
Michael Karp
147 Appaloosa Lane
Bellingham, W A. 98229
Phone [phone]
FAX: [phone]
Email: michael~awish.net
Copies of all pleadings, production requests, responses, Commission Orders and
Notices and other documents should be provided to Brad M. Purdy and Michael Karp.
CAP 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
Idaho Power s low income rate payers. Low income families pay a higher percentage of
their income for utility expenses that those in other economic categories. These
conditions are often caused by living in sub-standard or older housing that is not energy
efficient. Weatherization offers energy efficient retrofits for homes owned by low-
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO and AMERICAN ASSOCIATION OF RETIRED
PERSONS
income rate payers (at 150% poverty level). Currently, weatherization programs in Idaho
have as much as a six year backlog of customers needing the service.
CAP, ifallowed intervention, will address the current levels of funding in Idaho
Power s Low Income Weatherization Program as well as numerous other issues related to
low income ratepayers, including the proposed increase in Idaho Power s basic montWy
charge and how that increase disproportionately affects low income ratepayers.
CAP 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.
AARP is a non-profit membership organization dedicated to addressing the needs
of persons 50 or older. AARP serves over 35 million members, more than 150 000 of
whom live in Idaho. Through information and education, advocacy and service, AARP
seeks to enhance the quality of life for all its members. It does so by providing quality
information and education, as well as through legislative, legal and consumer advocacy at
the national and state level. AARP Idaho is an extension of the parent AARP
organization and has an office and full-time staff at the address listed herein.
AARP supports state utility regulators in their efforts to provide high quality and
non-discriminatory electric utility service at reasonable rates. AARP's members have a
direct and substantial interest in this proceeding. Older Americans, particularly those on
fIXed incomes, are particularly vulnerable to rapid increases in energy prices or to
unnecessary volatility in those prices. Retired, low-income households spend an average
of 16 percent oftheir income on residential energy bills
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO and AMERICAN ASSOCIATION OF RETIRED
PERSONS
AARP traditionally intervenes in state electric utility rate cases to foster the
lowest possible rates consistent with high quality services, innovative programs, and
fInancial stability. In this proceeding, AARP will present expert testimony on numerous
issues related to overall revenue requirement, residential revenue allocation and rate
design.
Though represented by one legal counsel, and though intervention is sought
through this single pleading, CAP and AARP seek intervention status as separate
intervenors. Their respective issues of concern and perspectives are distinct and they will
make their best effort to avoid any unnecessary redundancy in the presentation of
evidence and their general participation in this proceeding.
WHEREFORE, the Community Action Partnership ofldaho and the American
Association of Retired Persons hereby request that this Commission grant their respective
Petitions to Intervene in this proceeding and to fully appear and participate as a party
with all the attendant rights and responsibilities.
DATED, this 12th day of November, 2003.
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Brad M. Purdy
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO and AMERICAN ASSOCIATION OF RETIRED
PERSONS
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 12th day of November, 2003, I caused to be
served the foregoing PETITION TO INTERVENE OF COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO and the AMERICAN ASSOCIATION OF
RETIRED PERSONS on the following, in the manner indicated.
Barton L. Kline
Monica B. Moen
Idaho Power Company
O. Box 70
Boise, ID. 83707
)1 u.S. Mail, postage prepaid
() Hand delivered
Pi Facsimile
() Overnight mail
Gregory W. Said
Idaho Power Company
O. Box 70
Boise, ID. 83707
M U.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
Lisa Nordstrom
Deputy Attorney General
Idaho Public Utilities Commission
472 W. Washington St.
Boise, ID. 83702
VJ u.S. Mail, postage prepaid
() Hand delivered
t;r Facsimile
() Overnight mail
Peter J. Richardson
Richardson & O'Leary
99 East State Street, Suite 200
O. Box 1849
Eagle, ID. 83616
r1 u.S. Mail, postage prepaid
() Hand delivered
' Facsimile
T) Overnight mail
Don Reading
Ben Johnson Associates
6070 Hill Rd.
Boise, ID. 83703
;N u.S. Mail, postage prepaid
() Hand delivered
() Facsimile
() Overnight mail
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO and AMERICAN ASSOCIATION OF RETIRED
PERSONS