20050830Petition to Intervene.pdf

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...JBrad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. th St.
Boise, ID. 83702
[phone]
FAX: [phone]~y~ho mail. 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 JOINT
APPLICATION OF MIDAMERICAN
ENERGY HOLDINGS COMPANY (MEHC)
AND PACIFICORP DBA UTAH POWER &
LIGHT COMPANY FOR AN ORDER
AUTHORIZING MEHC TO ACQUIRE
PACIFICORP
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 pleadinl!s and
other correspondence need only be sent t!!.
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: bmpurdy~hotmail. 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, ensure that the
proposed merger is in the best interests of all ratepayers, particularly those falling into the
low-income category. CAP AI will also address the current levels of funding in
PacifiCorp s low-Income weatherization program as well as numerous other issues
related to low-income ratepayers.
In its settlement negotiations with PacifiCorp during the recent general rate case
(Case No. PAC-05-1), CAP AI and PacifiCorp reached an agreement under a
compressed timeline. PacifiCorp explicitly acknowledged that to the extent CAP AI'
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
concerns had not been fully addressed, the merger case, soon to be filed, would be an
appropriate opportunity to raise those issues again.
The Commission is, of course, not obligated by this understanding between the
parties. CAP AI offers it, however, for the Commission s consideration. CAP AI
continues to be the only party regularly appearing before this Commission that represents
low-income utility customers. CAP AI's proposals have led, and will continue to lead, to
the implementation and enhancement of programs that benefit not only low-income
ratepayers, but the general body of customers as well through the reduction of collection
costs, bad debt write-offs, improved cash flow, disconnection and reconnections costs
etc.
CAP AI intends to participate in this proceeding as a party and introduce
t~stimony 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.
DATED, this day of August, 2005.
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avail M. Purdy
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PETITION TO INTERVENE OF COMMUNITY ACTWN,:pARTNERSHIPASSOCIATION OF IDAHO
CERTIFICATE OF SERVICE
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I HEREBY CERTIFY that on the)Q day of August, 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-05-3
James M. Van Nostrand
Stoel Rives, LLP
900 SW Fifth Ave, Suite 2600
Portland, Oregon 97204
Curtis D. McKenzie
Stoel Rives, LLP
101 S. Capitol Blvd.
Boise, ID. 83702
Barton L. Kline
Monica B. Moen
Idaho Power Company
1221 W. Idaho St.
, Boise, ID. 83702
Eric L. Olsen
O. Box 1391; 201 E. Center
Pocatello, ID. 83204-1391
Randall C. Budge
O. Box 1391; 201 E. Center
Pocatello, ID. 83204-1391
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Br . Purdy
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PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO