20101207Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
2019 N. 17th S1.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
rì
lOIß DEC - ì AM II: 45
IDAHû
UTIliTiES
December 7, 2010
Jean Jewell
Secreta, Idaho Public Utilties Commssion
472 W. Washigton S1.
Boise,ID 83702
::Pe--G ..to -~ ')Re: CaseNo.~
Communty Action Parership Association of Idaho-Petition to Intervene
Dear Ms. Jewell:
Enclosed are the onginal and seven (7) copies of the Petition to Intervene of the
Communty Action Parership Association of Idaho in the above-referenced proceeding.
Tha you for your assistace.
Yours try,
ßfi~~Brad M.Pur y ~~
Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th S1.
Boise, il. 83702
[phone] (Land)
[phone] (Fax)
RECE t:
29fO DEC - 7 AHU=i.S
Attorney for Petitioner
Communty Action Parership
Association of Idaho
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF AN INSTIGATION )
OF APPROPRIATE COST RECOVERY ) CASE NO. IPC-E-IO-27
MECHASMS FOR IDAHO POWER'S )
ENERGY EFFICIENCY PROGRAS ) COMMTY ACTION
) PARTNRSHIP ASSOCIA-
) TION'S PETITION TO
) INTERVENE
)
COMES NOW, Communty Action Parership Association of Idao (hereinafter
"CAPAI" or "Intervenor") and, puruat to Rules 071-075 of the Commssion's Rules of
Practice and Procedure, IDAPA 31.01.01.071-075, as well as Order No. 32121 issued by ths
Commission on November 24,2010, hereby petitions the Commssion for leave to intervene in
ths proceeding and to appear and paricipate with ful par's nghts. In support of ths Petition,
CAP AI states as follows:
1. The address and name of the Petitioner is:
Communty Action Parership Association of Idaho
5400 W. Franin Rd., Suite G
Boise,ID. 83705
2. CAP AI will be represented in ths proceedin by, and pleadings and other
correspondence need only be sent to:
CAP AI PETITION TO INTERVENE 1
Brad M. Purdy
Attorney at Law
2019 N. 17th S1.
Boise, il. 83702
208-384-1299
FAX: [phone]
Email:
3. CAP AI is a non-profit corporation consisting of six community action agencies serving
every county in Idaho and also includes, among others, the statewide Communty Council of
Idaho and fights the causes and conditions of povert though building the capacity and
effectiveness of its members who have a direct and substatial interest in ths proceeding. These
causes and conditions of povert itclude utilty rates for Idaho Power's low income rate payers.
Low income famlies pay a higher percentage of their income for utilty expenses than
those in other economic categones. CAP AI is often the only par who intervenes in
proceedings before the Commssion specifically representing public utilities' low-income
customers. In paricular, CAP AI ha been involved in a vanety ofIdaho Power cass in recent
years and works with the utilty on a reguar basis for many reasns such as implementation,
maintaning and auditing of the Company's low-income weathenzation program.
CAP AI believes tht it would fufill an importt role in ths proceeding if given the
opportty to paricipate as a par. The mechansm by which Idaho Power fuds and recovers
its investment in all residential DSM progrs, including its low-income weathenzation
program, is of obvious relevance and importce to CAPAI. Consequently, it is fair to say that
CAP AI ha a direct and substatial interest in the subject matter of ths proceedig and its
intervention will not unduly broaden the issues presented by Idao Power's Application. Finally,
if granted intervention in ths case, CAP AI will address a vanety of issues of importce to the
general body of Idao Pòwer's ratepayers.
CAP AI PETITION TO INTERVENE 2
..
4. CAP AI respectfuly requests the right to paricipate in ths proceedig and introduce
testimony and exhbits, cross-exame other witnesses, engage in oral argument, fie comments,
and otherwse fully paricipate as a par.
WHREFORE, the Communty Action Parership Association ofIdao hereby requests
that ths Commssion grant its Petition to Intervene in ths proceeding and to fuly appear and
paricipate as a pary with all the rights and responsibilties as such.
DATED, ths7th day of December, 2010.
~Brad M. Purdy
-_..,._,,
CAP AI PETITION TO INERVENE 3