20170413Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise,ID. 83702
(208) 384-12ee (Lafi)
[phone] (Cell)
bmpurdr,@irotmai l.com
Attorney for Petitioner
Community Action Partnership
Association of Idaho
BEFORE THE IDAHO PTIBLIC UTILITTES COMMISSION
IN THE MATTER OF THE APPLICATION
OF IDAHO POWER COPMANY FOR A
DETERMINATION OF 2016 DEMAND-SIDE
MANAGEMENT EXPENDITURES AS
PRUDENTLY INCURRED.
CASE NOS. IPC-E-I7-03
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S PETITION
TO INTERVENE
COMES NOW, Community Action Parfirership Association of Idaho ("CAPAI") and,
pursuant to Rules 071-076 of the Commission's Rules of Practice and Procedure, IDAPA
31.01.01 .071-076, as well as OrderNo. 33737 issued March 30,2017,hereby petitions the
Commission for leave to intervene in this proceeding and to appear and participate with full
party's rights. In support of this Petitiory CAPAI states as follows:
1. The address and name of the Petitioner is:
Community Action Partnership Association of Idaho
3350 W. Americana Terrace, Suite 360
Boise,ID. 83706
2. CAPAJ will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
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1CAPAI PETITION TO INTERVENE
Brad M. Purdy
Attornev at Law
2or9 N: 17ft st.
Boise,ID. 83702
208-384-1299 (Land)
208-484-9980 (Cell)
[e-mail]
3. CAPAI is a non-profit corporation consisting of six community action agencies serving
every county in Idaho. The agencies who provide services in Idaho Power's service territory
include Metro Community Services (MCS), El Ada Community Action Parurership @l-Ada),
South Central Community Action Partnership (SCCAP), SouthEastern Idaho Community Action
Agency (SEICAA) and Eastem Idaho Community Action Partnership (EICAP). CAPAI's
mission is to fight the causes and conditions ofpoverty through building the capacity and
effectiveness of its member agencies who have a direct and substantial interest in this
proceeding. These causes and conditions of poverty are numerous and disparate.
Low income families pay a higher percentage of their income for utility expenses than
those in other economic categories. CAPAI is typically the only party who intervenes in
proceedings before the Commission, specifically representing public utilities' low income
customers. Specifically, CAPAI has been involved over many years in a considerable number of
Idaho Power proceedings before this Commission. CAPAI staff works with Idaho Power on a
regular basis for many reasons such as implementation and auditing of the Company's Low-
Income Weatherization Program (LIWA). If granted intervention in this case, CAPAI will,
among other things, address the Company's low income DSM progrirms and the importance of
maintaining them to be effective and robust programs that assist the Company's low income
ratepayers while yielding positive benefits to all other ratepayers.
2CAPAI PETITION TO INTERVENE
CAPAI believes that it would fuIfill an important role in this proceeding if given the
opportunity to participate as a party. Consequently, it is fair to say that CAPAI has a direct and
substantial interest in the subject matter of this proceeding and its intervention will not unduly
broaden the scope of issues presented by Idaho Power's Application.
4. CAPAI respectfully requests the right to fully participate in this proceeding as a party.
WHEREFORE, the Community Action Partnership Association of Idaho hereby requests
that this Commission grant its Petition to hrtervene in this proceeding and the right to firlly
appear and participate as a party with all the rights and responsibilities related thereto.
DATED, this 13th day of April,2Ul7.
Brad M. Purdy
3CAPAI PETITION TO INTERVENE
CERTIflCATE OF SERVICE
I hereby certiff that on this l3e day of April,2Ol7,I served true and correct copies of the
foregoing document to those individuals listed below via electronic delivery:
Diane Hanian
Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,ID 83702
Diane.hanian@puc. idaho. eov
Lisa D. Nordsfom
Idaho Power Company
P.O. Box 70
Boise,ID 83707-0070
lnordstrom@idahopower. com
dockets@idahopower. com
Connie Aschenbrenner
Idatro Power Company
P,O. Box 70
Boise,ID 83707-0070
caschenbrenner@ i dahopower. com
Peter J. Richardson
Industrial Customers of ldalro Power
c/o Peter J. Richardson
Richardson Adams, PLLC
515 N.27th St
P.O. Box 7218
Boise,Idaho 83702
peter@richardsonadams. com
Brad M. Purdy
Attorney for CAPAI
4CAPAI PETITION TO INTERVENE