20100630Petition to Intervene.pdf

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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
Community Action Partnership
Association of Idaho
RECE ED
iUlD JUN 30 PM 1:04
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN
POWER FOR APPROVAL OF CHANGES TO
ITS ELECTRIC SERVICE SCHEDULES
)
) CASE NO. PAC-E-IO-07
)
) COMMUNITY ACTION
) PARTNERSHIP ASSOCIA-
) TION'S PETITION TO
) INTERVENE
)
COMES NOW, Community Action Parnership Association of Idaho (hereinafter
"CAP AI" or "Intervenor") and, pursuant to Rules 071-075 of the Commission's Rules of
Practice and Procedure, IDAPA 31.01.01.071-075, hereby petitions the Commission for leave to
intervene in this proceeding and to appear and participate with full pary's rights. In support of
this Petition, CAP AI states as follows:
1. The address and name of the Petitioner is:
Community Action Parnership Association of Idaho
5400 W. Franklin Rd., Suite G
Boise,ID. 83705
2. CAP AI wil be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
Brad M. Purdy
Attorney at Law
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CAPAI PETITION TO INTERVENE
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2019 N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdy(hotmail.com
3. 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 Community Council of
Idaho 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 rates for Rocky Mountain Power's low
income rate payers.
Low income families pay a higher percentage of their income for utilty expenses than
those in other economic categories. CAP AI is often the only pary who intervenes in
proceedings before the Commission specifically representing public utilities' low-income
customers. In particular, CAP AI has been involved in the vast majority of PacifiCorp cases in
recent years and works with the utility on a regular basis for many reasons such as
implementation and auditing of the Company's low-income weatherization program. If granted
intervention in this case, CAP AI wil address a variety of issues of importance to the general
body of ratepayers.
CAP AI believes that it would fulfill an important role in this proceeding if given the
opportunity to paricipate as a party. Consequently, it is fair to say that CAP AI has a direct and
substantial interest in the subject matter of this proceeding and its intervention wil not unduly
broaden the issues presented by Rocky Mountain Power's Application.
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CAP AI PETITION TO INTERVENE
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4. CAP AI respectfully requests the right to participate in this proceeding and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral argument, fie comments,
and otherwise fully participate as a party.
WHEREFORE, the Community Action Partnership Association 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 rights and responsibilities as such.
DATED, this 30th day of June, 2010.
I./
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CAPAI PETITION TO INTERVENE
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that on the 30th day of June, 2010, I served a copy of
the foregoing document on the following by U.S. mail, first class postage.
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted. weston(ipacificorp. com
Daniel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
daniel.solander(iacificorp.com
Michael C. Creamer
Kelsey J. Nunez
GIVENS PURSLEY LLP
601 W. Banock St.
P.O. Box 2720
Boise,ID 83701-2720
mcc(i givenspursley. com
Tim Buller
Agrum, Inc.
3010 Conda Rd.
Soda Springs, ID 83276
TBuller(iagrum.com
Benjamin J. Otto
Idaho Conservation League
710 N. 6th St.
Boise,ID 83702
botto(iidahoconservation.org
Eric L. Olsen
Racine, Olson, et al
201 E. Center
Pocatello, ID 83201
elo(iracinelaw.net
Anthony Yankel
29814 Lake Rd.
Bay Vilage, OH 44140
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CAPAI PETITION TO INTERVENE
tony(iyankel.net
Randall C. Budge!
Racine, Olson, et al
201 E. Center
Pocatello, ID 83201
rcb(iracinelaw.net
James R. Smith
Monsanto Company
P.O. Box 816
Soda Springs, ID 83276
J im.r.smith(imonsanto.com
Ronald L. Wiliams
Wiliams Bradbury PC
1015 W. Hays St.
Boise, ID 83702
ron(iwiliamsbradbury. com
Melinda J. Davison
Davison Van Cleve
333 SW Taylor St., Ste 400
Portland, OR 97204
mjd(idvclaw.com
DATED, this 30th day of June, 2010
~2€uBrad M. Purdy -
i Reference IDAP A 31.01.01.41 (02).
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CAPAI PETITION TO INTERVENE