20091216Petition to Intervene.pdf

RECEivi:nBEFORE THE IDAHO PUBLIC UTILITIES COMMISSION ',.,.,
2009 DEC , 6 PH 3: I 2
IN THE MATTEER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR
AUTHORITY TO CONVERT SHEDULE 54-
-PILOT SCHEDULE TO AN ONGOING
PERMANENT SCHEDULE
)
) CASE NO. IPC-E-09-28
)
) PETITION TO INTERVENE
) OF THE COMMUITY ACTION
) PARTHERSHIP ASSOCIATION
) 9FIDAHO
COMES NOW, Communty Action Parership Association ofIdao (hereinafter
"CAPAI" or "Intervenor") and, puruant to Rules 071-075 of the Commssion's Rules of
Practice and Procedure, IDAPA 31.01.01.071-075, hereby petitions the Commission for leave to
intervene in ths proceeding and to appear and paricipate with ful paries' rights. In support of
this Petition, CAP AI states as follows:
1. The address and nae of the respective Intervenor is:
Communty Action Parership Association of Idaho
5400 W. Franin Rd., Suite G
Boise,ID. 83705
2. This Intervenor will be represented in ths proceeding by, and pleadings and other
corrspondence need only be sent to:
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
F AJ: 208-384-8511
Email: bmpurdy(ßotmail.com
3. CAP AI is a non-profit corpo~ion consisting of six communty action agencies serving
every county in Idaho and also includes, among others, the statewide Communty Council of
Idaho (formerly the Idaho Migrant Council) and fights the causes and conditions of povert
CAPAI PETITION TO INTERVENE 1
though building the capacity and effectiveness of its members who have a direct and substatial
interest in this proceeding. These causes and conditions of povert include high utilty 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 effcient. No other pary
typically intervenes in proceedings before the Commission, other than CAP AI, that represents
the Company's low-income customers. Consequently, CAPAI fulfills an importt role in ths,
and similar proceedings and, without the opportty to paricipate as a par in this proceeding,
would be unable to fulfill that role.
4. The concept of implementing a fixed cost mechansm, also sometimes generaly referred
to as "decoupling," It is fair to characterize the concept as controversial among some and stil in
somewhat of a stage of infancy, though Idaho Power has had in place for several years now a
Pilot Program. There are those who posit that the proposed mechanism might cause the rates of
seniors and low-income customers to go up, even when those same customers use less energy
though conservation efforts or measures. As a result, CAP AI has a direct and substatial
interest in this matter.
CAP AI did not have the resources to intervene in the initial Pilot Progr proceeding and
has not yet had the opportty to fully analyze the Company's proposed mechansm for
recovering fixed costs though a mechanism not altogether unlike the Power Cost Adjustment
("PCA") mechanism which attempts to captue unanticipated varable costs, though there are
certnly differences. Regardless, CAP AI has not yet formulated a firm position on the specifics
of the Compay's proposal, but is concerned that, even if it is waranted, it must be designed in a
maner that does not send inaccurate price signals and does not unduly impact Idaho Power's
CAP AI PETITION TO INTERVENE 2
low-income customers, while at the same time, encourging the acquisition of low-cost DSM
resources. To be sure, this is a tall order. As is said, "the devil is in the details" and that
admittedly worn-out adage very much applies to the Company's proposal in this case.
Consequently, CAP AI believes that Idaho Power's application has a substatial and direct
impact on its low-income customers and respectfully requests intervention in ths proceeding to
ensure that that impact wil not unduly har low-income customers and that, where appropriate,
safeguards be put in place to accomplish that objective.
5. CAPAI intends to paricipate in ths proceeding as a party and introduce testimony and
exhbits, cross-examine other witnesses, engage in oral arguent, fie comments, and otherwse
fuly paricipate as a par.fxc paricipate as a par with all the attendant rights and
responsibilities.
DATED, this 16th day of December, 2009.
'~/
Brad M. Purdy ...~'~
')
CAPAI PETITION TO INTERVENE 3