20060712Petition to intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone]
FAX: [phone]
bmpurdy~hotmail. com
Attorney for Petitioner
Community Action Partnership
Association ofIdaho
"RECEIVED
2006 JUL 12 PM 3:
IDAHO PUBLIC
UTILITIES COMMISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF P ACIFICORP DBA ROCKY MOUNTAIN
ELECTRIC SERVICE SCHEDULES NOS. 10
400 AND 401
CASE NO. PAC-06-
COMMUNITY ACTION
PARTNERSHIP ASSOCIA-
TION OF IDAHO'
PETITION TO INTERVENE
COMES NOW, Community Action Partnership Association ofIdaho (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
5400 W. Franklin Rd., Suite G
Boise, ID. 83705
This Intervenor will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
Brad M. Purdy
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 has already executed a settlement stipulation with PacifiCorp as a result
of that company s attempt to limit the scope of this proceeding in a manner that will not
affect the residential class of customers. In addition, PacifiCorp has made certain other
concessions that are of benefit to its low-income customers that will also benefit its
customers system-wide. Among those concessions is the agreement that PacifiCorp will
initiate a proceeding no later than September 1, 2006 for the purpose of addressing the
Company s policy oflimiting its investment in low-income weatherization projects to
50% of total project cost. The company agreed that it would address this issue in the
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO
current case during a settlement negotiation conducted in the recent merger case with
Mid-American Holding Company (Case No. PAC-05-08), and memorialized in a
settlement agreement executed in that case. As evidenced by the attached settlement
agreement executed in this case and identified as Exhibit "A," CAP AI agrees that it is
reasonable to limit the scope of the current general rate case and to address the 50% issue
in a separate proceeding. CAP AI's involvement in the current application will be of
interest to PacifiCorp s general body of ratepayers.
CAP AI intends to participate in this proceeding as a party and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral argument, file
comments, and otherwise fully participate as a party.
WHEREFORE, the Community Action Partnership ofIdaho 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.
1v\'DATED, this fL- day of July, 2006.
PETITION TO INTERVENE OF COMMUNITY ACTION PARTNERSHIP
ASSOCIATION OF IDAHO