20080509Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone]
FAX: [phone]
bmpurdyCfhotmail.com
Attorney for Petitioner
Community Action Parership
Association of Idaho
RECEIVED
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r-
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION FOR THE )
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR ELECTRIC AND )
NATUR GAS SERVICE TO ELECTRIC )
AN NATURA GAS CUSTOMERS IN THE )
)
CASE NOS. A VU-E-08-01
AVU-G-08-01
COMES NOW, Community Action Parership Association ofIdaho (hereinafter
"CAPAI" or "Intervenor") and, pursuant 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 this proceeding and to appear and paricipate with full paries'
rights. In support of this Petition, CAP AI states as follows:
1. The address and name of the respective Intervenor is:
Community Action Parnership Association of Idaho
5400 W. Franlin Rd., Suite G
Boise,ID. 83705
2. This Intervenor will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise,ID. 83702
1
208-384-1299
FAX: [phone]
Email: bmpurdyCfhotmail.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 Community
Council of Idaho (formerly the Idaho Migrant Council) 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
povert include high utility costs for PacifiCorp's low income rate payers. Low income
families pay a higher percentage of their income for utilty expenses that those in other
economic categories. These conditions are often caused by living in sub-standard or
older housing that is not energy efficient. Weatherization offers energy efficient retrofits
for homes owned by low-income rate payers (at 150% poverty level). Curently,
weatherization programs in Idaho have as much as a six year backlog of customers
needing the service.
4. In this case, A VISTA requests an overall rate increase of 16% for electrc and
slightly less than 7% for natual gas for residential customers. This rate of increase is not
only substantial but, because of the aforementioned reasons, will have a disproportionate
impact on low-income customers whose rates are not segregated into any paricular rate
design class other than residentiaL. CAP AI submits that the residential class of most of
Idaho's regulated electric utilities often bear their full share, if not more, of the utilty's
overall revenue requirement. This fact, combined with the disproportionate impact on
low-income, make substantial rate increases such as that proposed by AVISTA in this
case, paricularly burdensome absent some considerations or concessions that ensure that
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the negative effect the rate increase wil have on the poor, does not result in a negative
effect for all of the utilty's customers.
5. CAPAI intends to paricipate in this proceeding as a pary and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral argument, file
comments, and otherwise fully participate as a pary.
WHEREFORE, the Community Action Parnership Association ofIdaho hereby
requests that this Commission grant its Petition to Intervene in this proceeding and to
fully appear and paricipate as a pary with all the attendant rights and responsibilties.
. (/ tl_DATED, this iL dáyofMay, 2008.
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CERTIFICATE OF SERVICE¡, .I HEREBY CERTIFY that on the ~ day ofd~v, 2008, I caused to be served
the foregoing COMMUNITY ACTION PARTNERSHIP ÄSSOCIATION OF IDAHO'S
PETITION TO INTERVENE on the following in the maner stated.
Scott Woodbur
Deputy Attorney General
Idaho Public Utilties Commission
472 W. Washington St.
Boise,ID 83702
David Meyer
1411 East Mission
P.O. Box 3727
Spokane, W A 99220-0500
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:;.
Brad M. Purdy
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