20100413Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdyCfhotmail.com
Attorney for Petitioner
Community Action Parnership
Association of Idaho
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LOIO APR 13 PM f: 49
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC AND NATURAL GAS SERVICE
IN IDAHO.
)
) CASE NO. AVU-E-IO-Ol
) CASE NO. AVU-G-IO-Ol
)
) PETITION TO INTERVENE
) OF THE COMMUNITY
) ACTION PARTNERSHIP
) ASSOCIATION OF IDAHO
)
COMES NOW, Community Action Parnership Association of Idaho (hereinafter
"CAP AI" 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 participate with full pary's rights. In support of
this Petition, CAP AI states as follows:
1. The address and name of the Petitioner is:
Community Action Parnership Association of Idaho
5400 W. Franlin Rd., Suite G
Boise, ID. 83705
2. CAP AI wil be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
CAPAI PETITION TO INTERVENE 1
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise,ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdy(ihotmail.com
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 include high utilty rates for Idaho Power's low income rate
payers.
Low income families pay a higher percentage of their income for utilty expenses than
those in other economic categories. CAP AI is often the only pary who intervenes in
proceedings before the Commission specifically representing public utilities' low-income
customers. In paricular, CAPAI has been involved in the vast majority of A VISTA cases in
recent years and works with the utility on a regular basis for many reasons such as
implementation and auditing of the Company's low-income weatherization program. As a result,
CAP AI has acquired a solid foundation of understanding regarding the unique aspects of
AVISTA and its electric operations. Naturally, CAPAI occasionally takes positions contrary to
the Company as well, particularly in general rate cases. CAP AI intends, at this point in time, to
address a range of differing issues of importance in the pending rate case.
CAP AI believes that it fulfills an importnt role in this, and similar proceedings, and
without the opportunity to paricipate as a pary in this proceeding, would be unable to fulfill that
role. Consequently, it is fair to say that CAP AI has a direct and substantial interest in the subject
CAPAI PETITION TO INTERVENE 2
matter of this proceeding and its intervention will not unduly broaden the issues presented by
AVISTA's Application.
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 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 rights and responsibilties as such.
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DATED, this~th day of April, 2010.
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CAPAI PETITION TO INTERVENE 3
CERTIFICATE OF SERVICE
I HEREBY CERTIFY, that on the 10th day of April, 2010, I caused to be served by U.S. Mail,
first-class postage and by email:
David 1. Meyer, Esq.
Vice President and Chief Counsel
F or Regulatory and Governental Affairs
A VISTA Utilties
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
Kelly Norwood
Vice President, State and
Federal Regulation
A VISTA Utilties
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
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CAPAI PETITION TO INTERVENE 4