20110622Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
HAND DELIVERED
RECEI D
ior r JUN 22 PH 4: '9
June 22, 2011
Jean Jewell
Secreta, Idao Public Utilties Commssion
472 W. Washigton St.
Boise, ID 83702
/J-13
Re: Case No. PAC-E ~ 11: CAP AI Petition to Intervene
Dear Ms. Jewell:
Included herewith is the original and seven (7) copies of Community Action Parership
Association of Idao's Petition to Intervene in above-referenced proceedig. Than you
for your acceptance of this filing.
ß~'§BradM. Pudy ~ .
\tI ·
Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdy(fhotmail.com
Attorney for Petitioner
Communty Action Parership
Association of Idao
RECEIVED
20r I JUN 22 P~f 4: '9
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF TH APPLICATION OF
ROCKY MOUNTAI POWER SEEKIG
AUTHORIZATION TO SUSPEND FUT
PROGRA EVALUATIONS OF SCHEDULE 21,
LOW INCOME WEATHRIZATION SERVICES
FOR INCOME QUALIFYIG CUSTOMERS
)
) CASE NO. PAC-E-ll-13
)
) COMMTY ACTION
) PARTNRSHIP ASSOCIA-
) TION OF IDAHO'S PETITION
) TO INTERVENE
)
)
COMES NOW, Communty Action Parership Association ofIdao (hereinafer
"CAPAI" or "Intervenor") and, puruat to Riles 071-075 of the Commission's Riles of
Practice and Procedure, IDAPA 31.01.01.071-075, hereby petitions the Commssion for leave to
intervene in ths proceedng 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. CAPAI will be represented in ths procding by, and pleadigs and other
correspondence need only be sent to:
Brad M. Purdy
CAPAI PETITION TO INTERVENE 1
¿
Attorney at Law
2019 N. 17th St.
Boise,ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdy(fhotmaiL.com
3. CAP AI is a non-profit corporation consisting of six community action agencies serving
every county in Idao and also includes, among others, the statewide Community Council of
Idao and fights the causes and conditions of povert though buildig 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 utility rates for Rocky Mountan Power's
low income rate payers.
Low income famlies pay a higher percntae 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 Commssion specifically representing public utilties' low-income
customers. In parcu1ar, CAP AI has been involved in the vast majority of PacifiCorp cases in
recent year and works with the utility on a reguar bais for many reasons such as
implementation and auditing of the Company's low-income weatherization (LIWA) program and
other matters.
Rocky Mountain Power's Application in ths proceeding cou1d clearly have a profound
impact on the Company's LIWA progr and the Company's low-income customers. Thus, the
Application rases a varety of issues of importce to the general body of ratepayers and CAPAI
has a direct and substatial interest in the subject matter of this proceeding. If granted
intervention, CAPAI will fuly address all aspects of the Company's Application. CAPAI's
interention in ths cas will not undu1y broaden the issues presented by Rocky Mounta
Power's Application.
CAP AI PETITION TO INTERVENE 2
"
./
4. CAP AI respectfuly requests the right to paricipate in ths proceedig and introduce
testimony and exhbits, cross-examine other witnesses, engage in oral arguent, fie comments,
and otherwse fuly paricipate as a par.
WHREFORE, the Communty Action Parership Association of Idao hereby requests
that this Commission grt its Petition to Intervene in ths proceeding and to fuly appear and
parcipate as a pary with all the rights and responsibilties as such.
DATED, ths 21st day of June, 2011.
3_~~
Brad M. Pudy
CAP AI PETITION TO INTERVENE 3
", ...
CERTIFICATE OF SERVICE
I, the undersigned hereby certfy that on the 21st day of June, 2011, I served a copy of
the foregoing document on the followig by U.S. mail, first class postae.
Ted Weston
Rocky Mountan Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
ted. weston(fpacificorp.com
Danel E. Solander
Rocky Mountain Power
201 South Main, Suite 2300
Salt Lake City, UT 84111
danel.solander(fpacificorp.com
DATED, this 21st day of June, 2011
¿~~Brad M. Purdy --7,_./
CAP AI PETITION TO INTERVENE 4