20050223Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
h.mtrnr9y(illhotmail. com
Attorney for Petitioner
Community Action Partnership
Association of Idaho
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
ACIFICORP DBA UTAH POWER & LIGHT
COMP ANY FOR APPROVAL OF CHANGES
TO ITS ELECTRIC SERVICE SCHEDULES
CASE NO. P AC-05-
COMMUNITY ACTION
PARTNERSHIP ASSOCIA-
TION OF IDAHO'
PETITION TO INTERVENE
COMES NOW, Community Action Partnership Association of Idaho (hereinafter
CAP AI" or "Intervenor ) and, pursuant to Rules 071-075 of the Commission s Rules of
Practice and Procedure, IDAP A 31.01.01.071-075 , hereby petitions the Commission for
leave to intervene in this proceeding and to appear and participate with full parties
rights. In support of this Petition, CAP AI states as follows:
The address and name of the respective Intervenor is:
Community Action Partnership Association of Idaho
O. Box 8224
Boise, ID. 83707
This Intervenor will be represented in this proceeding by, and pleadines and
other correspondence need only be sent to
Brad M. Purdy
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: hmpurdy(?Yhotmail. com
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 Idaho
Migrant Council and fights the causes and conditions of poverty through building the
capacity and effectiveness of its members who have a direct and substantial interest in
this proceeding. These causes and conditions of poverty include high utility costs for
PacifiCorp 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
efficient. Weatherization offers energy efficient retrofits for homes owned by low-
income rate payers (at 150% poverty level). Currently, weatherization programs in Idaho
have as much as a six year backlog of customers needing the service.
CAP AI, if allowed intervention, will, among other things, address the current
levels of funding in PacifiCorp s low-Income weatherization program as well as
numerous other issues related to low-income ratepayers. Though the breadth and nature
of issues addressed by CAP AI is yet to be precisely determined, CAP AI notes that this
Commission has found good cause to allow CAPAI's intervention in the Idaho Power
and A VISAT A recent general rate filings. CAP AI's involvement in the current
application will be at least as substantial and of interest to PacifiCorp s general body of
ratepayers.
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
CAP AI intends to participate in this proceeding as a party and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral argument and
otherwise fully participate as a party.
WHEREFORE, the Community Action Partnership of Idaho hereby requests that
this Commission grant its Petition to Intervene in this proceeding and to fully appear and
participate as a party with all the attendant rights and responsibilities.
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DATED, this ;)J day of February, 2005.
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PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the ~311 day of February, 2005, I caused to be
served the foregoing PETITION TO INTERVENE OF COMMUNITY ACTION
PARTNERSHIP ASSOCIATION OF IDAHO on the following, in the manner indicated
in Case No. P AC-05-
James M. Van Nostrand
( )
S. Mail, Postage prepaid
Stoel Rives, LLP
( )
Hand Delivery
900 SW Fifth Ave, Suite 2600
( )
Overnight Delivery
Portland, Oregon 97204 Facsimile
Curtis D. McKenzie
( )
S. Mail, Postage prepaid
Stoel Rives, LLP
( )
Hand Delivery
101 S. Capitol Blvd.
( )
Overnight Delivery
Boise, ID. 83702 ()t Facsimile
Randall C. Budge
( )
S. Mail, Postage prepaid
O. Box 1391; 201 E. Center
( )
Hand Delivery
Pocatello, ID. 83204-1391 r-:f'Facsimile
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Brad M. Purdy
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PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO