20110622Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
RECEIVED
201 l JUN 22 PH I¡:l 8
HA DELIVERED
June 22,2011
Jean Jewell
Secreta, Idao Public Utilities Commssion
472 W. Washington St.
Boise,ID 83702
Re:
II.. Oe
Case No. IPC-E'8-~ CAP AI Petition to Intervene
Dear Ms. Jewell:
Included herewith is the original and seven (7) copies of Communty Action Parership
Association of Idao's Petition to Intervene in above-referenced proceedig. Than you
for your acceptance of ths filing.
ß~QM#Brad M. Pudy -
"l..
Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdy(ihotmail.com
Attorney for Petitioner
Communty Action Parership
Association of Idao
RECEIVED
2011 JUN 22 PH I¡: 18
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTR OF TH APPLICATION
OF IDAHO POWER COMPAN FOR
AUTHORITY TO INCREASE ITS RATES
AN CHAGES FOR ELECTRC SERVICE
TO ITS CUSTOMERS IN TH STATE OF
IDAHO
)
) CASE NO. IPC-E-II-08
)
)
) COMMTY ACTION
) PARTNRSHI ASSOCIA-
) TION OF IDAHO'S PETITION
) TO INRVENE
)
)
COMES NOW, Communty Action Parership Association ofIdaho (hereinafer
"CAPAI" or "Intervenor") and, pursuant to Rules 071-075 of the Commssion's Rules of
Practice and Procedure, IDAPA 31.01.01.071-075, hereby petitions the Commssion for leave to
intervene in ths proceeding and to appear and paricipate with ful par's rights. 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. Frain Rd., Suite G
Boise,ID. 83705
2. CAP AI will be represented in ths proceedig by, and pleags and other
correspondence need only be sent to:
CAPAI PETITION TO INTERVENE 1
"..
Brad M. Pudy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdy(ßotmaiL.com
3. CAP AI is a non-profit corpration consisting of six communty action agencies serving
every county in Idaho and also includes, among other, the sttewide Communty Council of
Idaho and fights the causes and conditions of povert though buildig the capacity and
effectiveness of its membes who have a direct and substatial interst in ths proceedg. These
causes and conditions of povert include increasing utility rates for Idao Power's low income
rate payers.
Low income famlies pay a higher percentae of their income for utility expenss th
those in other economic categories. CAP AI is often the only par who intervenes in
proceedigs before the Commssion specifically representig public utiities' low-income
customers. In paricular, CAP AI has been involved in a considerable number of Idaho Power
proceedigs before ths Commssion widely ranging in scpe in recent year. CAP AI staff
works with the utility on a regular basis for many reasons such as implementation and auditing of
the Company's low-income weatherition program. If grted intervention in ths case, CAPAI
will address a varety of issues of importce to the genera body of ratepayers.
CAP AI believes that it would fufill an importt role in this proceeding if given the
opportty to paricipate as a pary. Consequently, it is fair to say that CAP AI has a diect and
substatial interest in the subject matter of ths proceeg and its intervention will not unduly
broaden the issues presented by Idao Power's Application.
CAP AI PETITION TO INTERVENE 2
.,
4. CAP AI respectfly requests the right to paicipate in ths proceeg and introduce
testimony and exhbits, cross-exame other witnesses, engage in ora arguent, file comments,
and otherwse fully parcipate as a par.
WHREFORE, the Communty Action Parership Associaton ofIdao hereby requests
that ths Commssion grant its Petition to Intervene in ths proceedig and to fuly appear and
paricipate as a par with all the rights and respnsibilties as such.
DATED, ths 21st day of June, 2010.
~~~Brad M. Puy ~
CAP AI PETITION TO INERVENE 3
....~ '..
CERTIICATE OF SERVICE
I, the undersigned, hereby certfy that on the 21st day of June, 2011, I sered a copy of
the foregoing document on the followig by U.S. mail, fi clas postae.
Lisa D. Nordstrm
Donovan E. Waler
Jason B. Willams
Idaho Power Company
P.O. Box 70
Boise, Idaho 83703
lnordstrom(iidahopower.com
dwalker(iidahopower.com
jwillams(iidahopower .com
Grgory W. Said
Vice President, Reguatory Afairs
Idaho Power Company
P.O. Box 70
Boise, Idaho 93707
gsaid(iidahopower.com
DATED, ths 21st day of June, 2011
/
Brad M. Purdy
CAPAI PETITION TO INRVE 4