20110712Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
RECEIVED
ZOIl JUl 12 PH 3: 34
HAND DELIVERED
July 12, 2011
Jean Jewell
Secreta, Idaho Public Utilties Commssion
472 W. Washigton St.
Boise,ID 83702
Re: Case No. rI-8 8 i 11: CAP AI Petition to InterveneAVtt,e-//-o/
Dea Ms. Jewell: Aiil(- &-11-0/
Included herewith is the original and seven (7) copies of Communty Action Parership
Associat of Idao's Petition to Intervene in above-referenced proceeding. Than you
for your acceptace of this filing.
~~
Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th St.
Boise,ID. 83702
[phone] (Land)
[phone] (Fax)
bmpurdyaYhotmail.com
Attorney for Petitioner
Communty Action Parnership
Association of Idao
RECEIVED
20" JUL 12 PH 3: 34
BEFORE THE IDAHO PUBLIC UTILITIES COMMSSION
IN THE MATTER OF THE APPLICATION )
OF A VISTA CORPORATION FOR THE )
AUTHORITY TO INCREASE ITS RATES )
AND CHAGES FOR ELECTRC AN )
NATUR GAS SERVICE TO ELECTRC )
AND NATURAL GAS CUSTOMERS IN THE )STATE OF IDAHO )
)
)
CASE NOS. A VU-E-11-01
AVU-G-ll-01
COMMITY ACTION
PARTNERSHI ASSOCIA-
TION OF IDAHO'S PETITION
TO INTERVENE
COMES NOW, Communty Action Parership Association ofIdao (hereinafer
"CAPAI" or "Interenor") and, pursuant to Rules 071-076 of the Commssion's Rules of
Pratice and Procedure, IDAPA 31.01.01.071-076, hereby petitions the Commssion for leave to
intervene in this proceeding and to appear and paricipate with ful par's rights. In support of
this Petition, CAP AI states as follows:
1. The address and name of the Petitioner is:
Communty Action Parership Association of Idaho
5400 W. Frain Rd., Suite G
Boise, il. 83705
2. CAP AI will be represented in ths proceedg by, and pleadings and other
correspondence need only be sent to:
CAP AI PETITION TO INTERVENE 1
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdyaYhotmail.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 Communty Council of
Idaho and fights the causes and conditions of povert though buildig the capacity and
effectiveness of its members who have a direct and substatial interest in ths proceeding. These
causes and conditions of povert are numerous and disparte and include increasing utility rates
such as those for AVISTA Corporation's low income rate payers.
Low income famlies pay a higher percentage of their income for utility expenses than
those in other economic categories. CAP AI is tyically the only pary who intervenes in
proceedings before the Commssion specificaly representig public utilities' low-income
customers. In paricular, CAP AI ha been involved in a considerable number of A VISTA
proceedings before ths Commssion widely raging in scpe in recent year. CAP AI sta
works with the utility on a reguar basis for many reasons such as implementation and auditing of
the Company's low-income weatherization program. If grted intervention in this case, CAP AI
will addrss a varety of issues of importce to the general body of ratepayers.
CAP AI believes that it would fufill an importt role in ths proceeding if given the
opportty to paricipate as a pary. Consequently, it is fai to say that CAPAI has a direct and
substatial interest in the subject matter of ths proceeding and its intervention will not unduly
broaden the issues presented by AVISTA's Application.
CAP AI PETITION TO INTERVENE 2
4. CAP AI respectfuly requests the right to paricipate in ths proceedig and introduce
testimony and exhbits, cross-exame other witnesses, engage in oral arguent, file comments,
and otherwse fully paricipate as a pary.
WHREFORE, the Communty Action Parership Association ofIdaho hereby requests
that ths Commssion grant its Petition to Intervene in ths proceeding and to fuly appear and
paricipate as a par with all the rights and responsibilities as such.
DATED, this 12th day of July, 2011.
CAP AI PETITION TO INTERVENE 3
. ,
CERTIFICATE OF SERVICE
I, the undersigned, hereby represent tht on ths 12th day of July, 2011, I caused a tre and
correct copy of ths Petition to Intervene to be served on the followig via U.S. Mail, First Class,
Postae Prepaid.
David J. Meyer, Esq.
President and Chief Counel for Regulatory and Governenta Affair
AVISTA Corporation
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
Phone: [phone]
Fax: [phone]
Kelly Norwood
Vice President - State and Federal Reguation
A VISTA Utilities
P.O. Box 3727
1411 E. Mission Ave.
Spokae, WA 99220-3727
Phone: [phone]
Fax: [phone]
DATED, this 12th day of July, 2011
il~
CAP AI PETITION TO INTERVENE 4