20130322Petition to Intervene.pdf

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Brad M. Purdy
Attorney at Law
Bar No. 3472
2019N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
ZU13 MAR 22 AM 8:14 7
• •. i •h
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION )
OF PACIFICORP DBA ROCKY MOUNTAIN )
POWER TO INITIATE DISCUSSIONS WITH
INTERESTED PARTIES ON ALTERNATIVE)
RATE PLAN PROPOSALS )
)
CASE NO. PAC-E-13-04
COMMUNITY ACTION PARTNER-
SHIP ASSOCIATION OF IDAHO'S
PETITION TO INTERVENE
COMES NOW, Community Action Partnership Association of Idaho (hereinafter
"CAPAI") and, pursuant to Rules 071-076 of the Commission's Rules of Practice and Procedure,
IDAPA 31.01.01.071-076, and Order No. 32761 issued in this proceeding on March 12,2013,
hereby petitions the Commission for leave to intervene in this proceeding and to appear and
participate with full party's rights. In support of this Petition, CAPAI states as follows:
1.The address and name of the Petitioner is:
Community Action Partnership Association of Idaho
5400 W. Franklin Rd., Suite G
Boise, ID. 83705
2.CAPAT will be represented in this proceeding by, and pleadings and other
corresnondence need only be sent to:
Brad M. Purdy
Attorney at Law
2019N. 17'h St.
CAPAI'S PETITION TO INTERVENE
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: [e-mail]
3. CAPAI 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 are numerous and disparate and include increasing utility rates
such as those for Rocky Mountain's low income rate payers.
Low income families pay a higher percentage of their income for utility expenses than
those in other economic categories. CAPAI is typically the only party who intervenes in
proceedings before the Commission specifically representing public utilities' low-income
customers. CAPAI has been involved in a considerable number of PacifiCorp proceedings
before this Commission widely ranging in scope in recent years. CAPAI staff works with the
utility on a regular basis for many reasons such as implementation and auditing of the
Company's low-income weatherization program and has advocated its position on issues in
general rate proceedings affecting the residential class as a whole and including, among other
things, issues involving revenue requirement and rate design as well as low-income assistance.
If granted intervention in this case, CAPAI will continue to address a variety of issues of
importance to the general body of ratepayers.
CAPAI believes that it would fulfill an important role in this proceeding if given the
opportunity to participate as a party. Consequently, it is fair to say that CAPAI has a direct and
substantial interest in the subject matter of this proceeding and its intervention will not unduly
broaden the issues presented by Rocky Mountain's Application.
CAPAI'S PETITION TO INTERVENE 2
4. CAPAI respectfully requests the right to participate in this proceeding 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 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 21st day of March, 2013.
Brad M. Purdy
CAPAI'S PETITION TO INTERVENE 3