20091207Petition to Intervene.pdf

December 7, 2009
Ms. Jean Jewell
Commission Secreta
Idaho Public Utilties Commission
472 W. Washington St.
Boise, ID 83702
RE: Case No. IPC-E-09-30
Dear Ms. Jewell:
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
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Enclosed, please find Community Action Parnership Association of Idao's Petition to
Intervene in the above-referenced matter.
Sincerely,)?~/~'~~.PuY~. ~cd~-
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION E1\ .REC \,1
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IN THE MATTEER OF THE APPLICATION
OF IDAHO POWER COMPANY FOR AN
ACCOUNTING ORDER TO AMORTIZE
ADDITIONAL ACCUMULATED DEFERR
INCOME TAX CREDIT AND APPROVING A
RATE CASE MORATORIUM
)
) CASE NO. IPC-E-09~30
)
) APPLICATION FOR INTER-
) VENTION OF COMMUNTY
) ACTIONPARTNERSmp
) ASSOCIATION OF IDAHO
)
)
COMES NOW, Community Action Parership Association ofIdaho (hereinafer
"CAPAI" or "Intervenor") and, pursuat 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 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 Idao
5400 W. Frain Rd., Suite G
Boise,ID. 83705
2. This Intervenor will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
Brad M. Purdy
Attorney at Law
20 i 9 N. 17th St.
Boise, il. 83702
208-384-1299
FAX: [phone]
Email: bmpurdy(ßhotmail.com
3. CAP AI is a non-profit corpration consisting of six communty action agencies
serving every county in Idaho and also includes, among others, the statewide Communty
CAPAI PETITION TO INTERVENE Page 1
Council of Idaho (formerly the Idaho Migrant Council) and fights the causes and
conditions of povert though building the capacity and effectiveness of its members who
have a direct and substantial interest in ths proceeding. These causes and conditions of
povert include high utilty costs for Idao Power's low income rate payers. Low income
families pay a higher percentage of their income for utilty expenses that those in other
economic categories. These conditions are often caused by living in sub-stadard or
older housing tht is not energy effcient. No other pary typically intervenes in
proceedings before the Commssion, other than CAP AI, that represents the Company's
low-income customers. Consequently, CAPAI fulfills an importt role in this, and
simlar proceedings and, without the opportty to paricipate as a par in this
proceeding, would be unable to fufill that role.
3. Ths case has followed a somewhat unusua procedural path. Wh staed out
with a Notice of Intent to fie a General Rate Case, became a series of meetings among
numerous staeholders which transformed into a proposal by Idao Power to not fie a
rate case and, in fact, defer such a filing in exchange for certin considerations stated in a
stipulation that has been filed in this matter. The meetings were numerous, and lengty
leading to the settlement referr to, and regarding the appropriate procedural path by
which to present the settlement to the Commission for its review. CAP AI paicipated
fuly in all of those meetings and in communcating with other paricipants in the
settlement discussions, and ultimately executed the settlement. CAP AI agreed to execute
the settlement as did several other staeholders. Others did not.
The settlement, whether approved or not, will have a substatial and direct impat
on Idaho Power's low-income customers for reasons that CAP AI requests that it be given
CAPAI PETITION TO INTERVENE Page 2
the opportunty to explain through the testimony of a witness and paricipation in a
hearng. Consequently, CAP AI respectfully submits that it has satisfied all of the critera
entitlng it to intervene in ths matter.
4. CAP AI intends to paricipate in this proceeding as a pary and introduce
testimony and exhbits, cross-examine other witnesses, engage in oral arguent, file
comments, and otherse fully paricipate as a par.
WHEREFORE, the Communty Action Parership Association of Idao hereby
requests that ths Commission grant its Petition to Intervene in this proceeding and to
fully appear and paricipate as a pary with all the attendat rights and responsibilties.
DATED, this 7th day of December, 2009.
£C:i~ ~~J~c
Brad M. Purdy
CAPAI PETITION TO INTERVENE Page 3