20210708Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. l7s St.
Boise,ID. 83702
(208) 384-129e (Land)
(208) 484-ee80 (Cell)
[e-mail]
Attorney for Petitioner
Community Action Parhrership
Association of Idaho
IN THE MATTER OF ROCKY MOUNTAIN
POWER'S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
IN CHARGES IN IDAHO AND APPROVAL
OF PROPOSED ELECTRIC SERVICE
SCHEDULES AND REGULATIONS
..1 d| 2 --U i!i U,UU
BEFORE THE IDAIIO PUBLIC UTILITIES COMMISSION
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CASE NOS. PAC-E.21-07
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S PETITION TO
TO INTERVENE
COMES NOW, Community Action Partnership Association of Idaho (hereinafter
"CAPAI''or "Intervenor") and, pursuant to Rules 071-076 of the Commission's Rules of
Practice and Procedure, IDAPA 31.01.01 .07l-076, hereby petitions the Commission for leave to
intervene in this proceeding and to appear and participate with full party's rights. [n support of
this Petition, CAPAI states as follows:
l. 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:
CAPAI'S PETITION TO INTERVENE
Brad M. Purdy
Attomey at Law
2019 N. 17ft St.
Boise,ID. 83702
208-384-t299
Email : bmpurdy@]rotrnail.com
3. CAPAI is a non-profit organization consisting of eight (8) community action partnership
agencies (CAPs) serving every county in Idaho fighting 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. The following are CAP members: Community Action Partnership
("CAP"-Lewiston); El-Ada CAP (*El-Ada"-greater Boise area as well as Elmore and Owyhee
counties); Metro Community Services (*Mcs'-Caldwell); South Central CAP (*SCCAP"-Twin
Falls); Community Council of ldaho ("CCl"-Caldwell); Southeastern Idaho Community Action
Agency ("SEICAAP"-Pocatello); Eastern Idaho CAP (*EICAP"-Idaho Falls), and; Western
Idaho CAP ("Wi-Cap"-purttte). CAPAI serves as the umbrella organization for all of the CAPs
providing numerous means of support including, but not limited to, representing the CAPs before
the IPUC. The 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. The two
CAP agencies that serve Rocky Mountain Power customers in Idaho include EICAP and
SEICAAP.
Low income families pay a higher percentage of their income for utility expenses than
those in other economic categories. For roughly the past twenty (20) years, CAPAI has
essentially been the only party who regularly intervenes in proceedings before the Commission
specifically representing public utilities' low-income customers and advocating on behalf of
those customers in a myriad of ways. Among other things, CAPAI oversees Rocky Mountain's
Low-Income WeatherizatronAssistance (LIWA) program for the Company's low-income
CAPAI'S PETITION TO INTERVENE 2
customers which, among other things, reduces the electricity consumption, and thereby the bills,
of customers who qualifu for and participate in the LIWA program. Thus, CAPAI's
participation in cases before the Commission penains to a specific program, regulated by the
Commission and designed to reduce energy consumption by those least able to pay their bills.
CAPAI's involvement in cases before the IPUC is not limited to the funding of energy
conservation programs. CAPAI also frequently takes a position on rate design, customer service
quality, cost of service and many other aspects of a typical rate case.
CAPAI's weatherization programs provide not only a much-needed benefit to those least
able to pay their electric bills by reducing electric consumption through weatherization, but also
enhance the comfort and safety of the programs' participants. CAPAI'S low-income
weatherization programs are recognized and approved by the U.S. Department of Health and
Human Services. Funding for the programs is passed through the Idatro Department of Health
and Welfare who also monitors the programs and their funding levels, as well as numerous other
aspects of CAPAI and its member agencies. In addition to the aforementioned oversight and
monitoring by state and federal agencies, the low-income weatherization programs are also
subject to scrutiny as to their effectiveness by the Idaho Public Utilities Commission. Thus, the
low-income programs operated by the CAPs, are very specific and regulated by numerous
goverrrmental agencies, including the Commission.
CAPAI has been involved in a considerable number of Rocky Mountain proceedings
before this Commission widely ranging in scope over a number of years. CAPAI staff works
with and provides administrative support to the CAPs on a regular basis for many reasons such
as implementation and auditing of the Company's low-income weatherization programs. CAPAI
also represents the CAPs before the Idaho Public Utilities and has done so effectively for more
3CAPAI'S PETITION TO INTERVENE
than twenty years. Furthermore, the services provided by CAPAI not only assist the poor by
helping to reduce their utility bills, but provide benefits to all of Rocky Mountain's ratepayers by
reducing energy consumption and the amount of bad debt incurred due to inability to pay; said
debt which is ultimately passed through to other ratepayers. Thus, if granted intervention in this
case, CAPAI will address a variety of issues of importance to the general body of Rocky
Mountain' s ratepayers.
CAPAI believes that it will fulfill an important role in this proceeding if given tlie
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.
4. CAPAI respectfully requests the right to participate in this proceeding and introduce
testimony and exhibits, cross-examine other parties' witnesses and provide its own, engage in
oral argument and written briefing, 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 righs and responsibilities as such.
DATED, this 8th day of July,202l.
Brad M. Purdy
Attorney for the Community Action
Association of Idaho
4CAPAI'S PETITION TO INTERVENE
CERTIFICATE OF SERVICE
I, the undersigned, hereby represent that on this 8th day of July,202l, caused a tue and
correct copy ofthis Petition to Intervene to be served on the following:
Idaho Public Utilities Commission
Jan Noriyuki
Commission Secretary
secretarv@f uc.idaho. gov
Dayn Hardie
Matt Hunter
Deputies Attorney General
Dayn. Hardie@puc. idatro. cov
Matt. Hunter@Fuc. idaho. gov
Ro c hv Mo unt ain P ow e r/ P ac ifiC orp
Emily L. Wegener
Mathew D. McVee
Ted Weston
Emi I v. weeener@pacifi corp.com
Matthew.mcvee@paci fi corp.com
Ted.weston@Jracifi corp.com
Data Request Response Center
datarequest@nacifi com.com
Bayer Corporation
Randall C. Budge
Thomas J. Budge
[e-mail]
[e-mail]
James R. Smith
Mike Veile
J im.r. [e-mail]
Mike. veile@[e-mail]
Pacificom ldaho Industrial Customers
Ronald L. Williams
ron@wi I I i amsbradbury.com
Bradley Mullins
brm ull ins@mwanalytics. com
5CAPAI'S PETITION TO INTERVENE
Idabo Inigation hrmperr Association
EricL. Olseir@
AnthonyYmkrel
tmt@rmtl|qc
DATED, this Sthday of July;2021
Brad M.
6CAPAI'S PETMON TO INTERVENE