20110620Petition to Intervene.pdf

..
Brad M. Pudy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdy!êhotmail.com
Attorney for Petitioner
Communty Action Parership
Association of Idaho
RECEIVED
lOt' JUN 20 AH 10: 40
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TH MATTR OF TH APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAI
POWER FOR APPROVAL OF CHAGES TO
ITS ELECTRIC SERVICE SCHEDULES
)
) CASE NO. PAC-E-Il-12
)
) COMMTY ACTION
) P ARTNRSliP ASSOCIA-
) TION'S PETITION TO
) INTERVENE
)
COMES NOW, Communty Action Parership Association ofIdao (hereinafer
"CAPAI" or "Intervenor") and, pursuat 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 ths proceeding and to appear and paricipate with ful par's rights. In support of
ths Petition, CAP AI states as follows:
1. The address and name of the Petitioner is:
Communty Action Parership Association of Idaho
5400 W. Frain Rd., Suite G
Boise, il. 83705
2. CAP AI will be represented in ths proceeding by, and pleadigs and other
correspondence need only be sent to:
Bra M. Purdy
Attorney at Law
CAP AI PETITION TO INTERVENE 1
2019 N. 17th St.
Boise,ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdy!êhotmail.com
3. CAP AI is a non-profit corporation consisting of six communty action agencies serving
every county in Idaho and also includes, among others, the statewide Communty Council of
Idaho and fights the causes and conditions of povert though building the capacity and
effectiveness of its members who have a direct and substatial interest in ths proceeding. These
causes and conditions of povert include increasing utilty rates for Rocky Mounta Power's
low income rate payers.
Low income famlies pay a higher percentage of their income for utilty expenses th
those in other economic categories. CAP AI is often the only par who intervenes in
proceedings before the Commission specifically representing public utilties' low-income
customers. In paricular, CAP AI has been involved in the vast majority of PacifiCorp cases in
recent years and works with the utilty on a reguar basis for many reasons such as
implementation and auditing of the Company's low-income weatherization program and other
matters. If grted intervention in ths case, CAP AI will address a varety of issues of
importce to the general body of ratepayers.
CAP AI believes that it would fulfill an important role in this proceeding if given the
opportty to paricipate as a par. Consuently, it is fai to say that CAPAI has a direct and
substatial interest in the subject matter of ths proceeding and its intervention will not unduly
broaden the issues presented by Rocky Mountain Power's Application.
Finally, the Commssion itself indicated an expectation that CAP AI would be involved in
ths proceeding to address, at the leat, an as of yet unesolved issue fist rased in Rocky
CAPAI PETITION TO INTERVENE 2
Mounta's last genera rate proceeding (Cas No. PAC-E-1O-07). Regardin whether RM's
Low-Income Conseration Education Progr is an ongoing progr, the Commssion rued in
Order No. 3224 issued April 18,2011: "We find tht it is both reasnable and appropriate to
revisit ths issue in the Company's next genera rate cas." Id at p. 5. Noting tht Rocky
Mounta ha alady fied a notice of intent to file a new genera rate case in the near futue, the
Commssion concluded: "Without reaching the merits of the issue, we generaly believe that
education programs addressing energy conservation provide valuable information to low-income
ratepayers. We foresee that ths issue will reeive carful attention from CAP AI, Rocky
Mountain and Staff and will be fuly resolved in the next general rate proceeng." Id
4. CAP AI respectfuly requests the right to paricipate in ths proceeding and introduce
testimony and exhbits, cross-exame other witnesses, engage in oral arguent, tile comments,
and otherwse fuly paricipate as a pary.
WHREFORE, the Communty Action Parership Association of Idao hereby requests
tht this Commssion grt its Petition to Intervene in ths proceing and to fully appear and
paicipate as a pa with al the rights and responsibilties as such.
DATED, ths 20th day of June, 2011.
¿~:~""¡Brad M. Purdy ::=?~
CAP AI PETITION TO INTERVENE 3
~ .
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify tht on the 20t day of June, 2011, I served a copy of
the foregoing document on the followig by electronic maiL.
Ted Weston
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted. weston!êpacificorp.com
Daniel E. Solander
Rocky Mountan Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
daniel. solander(fpacificorp. com
DATED, ths 20t day of June, 2011 --/---~'\ / ..~I'" ~~~ ....Bra M. Puy -e~ ~
CAPAI PETITION TO INTERVENE 4