20161122Petition to Intervene.pdf

November 22, 2016
Ms. Jean Jewell
Secretary
Brad M. Purdy
Attorney at Law
2019N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Idaho Public Utilities Commission
4 72 W. Washington
Boise, ID 83702-5983
Re: Case Nos. PAC-E-16-14
Dear Ms. Jewell:
RECEIVED
201u NOV 22 PM 2: '-i3
1r, ~ · L : ~ d ... 4. ISSION
Enclosed for filing are an original and seven (7) copies of the Community Action
Partnership Association ofldahos' Petitions to Intervene in the above-referenced matter.
Please do not hesitate to contact me should you have any questions.
Very truly yours,
Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
(208) 3 84-1299 (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
RECEIVED
2016 NOV 22 PM 2: 43
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF PACIFICORP DBA ROCKY MOUNTAIN
POWERFORPRUDENCY
DETERMINATION OF DEMAND-SIDE
MANAGEMENT EXPENDITURES
)
)
)
)
)
)
CASE NOS. PAC-E-16-14
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S PETITION
TO INTERVENE
COMES NOW, Community Action Partnership Association ofldaho (hereinafter
"CAPAI" or "Intervenor") and, pursuant to Rules 071-076 of the Commission's Rules of
Practice and Procedure, IDAPA 31.01.01.071-076, as well as Order No. 33639 issued November
1, 2016, 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:
I. The address and name of the Petitioner is:
Community Action Partnership Association of Idaho
3350 W. Americana Terrace, Suite 360
Boise, ID. 83706
2. CAPAI will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
CAP AI PETITION TO INTERVENE 1
Brad M. Purdy
Attorney at Law
2019N. 17th St.
Boise, ID. 83702
208-384-1299
Email: [e-mail]
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 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. CAP AI is typically the only party who intervenes in
proceedings before the Commission specifically representing public utilities' low-income
customers. In particular, CAP AI has been involved in a considerable number of Rocky
Mountain proceedings before this Commission widely ranging in scope in recent years. CAP AI
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. If granted intervention in this
case, CAP AI will address a variety of issues of importance to the general body of ratepayers
including, but not limited to, the Company's Low Income Weatherization Assistance DSM
program.
CAP AI 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 CAP AI 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 PETITION TO INTERVENE 2
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, 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 22nd day of November, 2016.
CAP AI PETITION TO INTERVENE 3