20121107Petition to Intervene.pdf

ECEi\ ED
Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17' St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
20I2NOV-7 PM 4: 40
i --'- IDFr1u r UTILITIES COMM.
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION ) CASE NOS. AVU-E-12-08
OF AVISTA CORPORATION DBA AVISTA ) AVU-G-12-07
UTILITIES FOR AUTHORITY TO )
INCREASE ITS RATES AND CHARGES FOR )
ELECTRIC AND NATURAL GAS SERVICE ) COMMUNITY ACTION
IN IDAHO ) TION OF IDAHO'S PETITION
) 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 31.01.01.071-076, 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:
1.The address and name of the Petitioner is:
Community Action Partnership Association of Idaho
5400 W. Franklin Rd., Suite G
Boise, ID. 83705
2.CAPAI will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
Brad M. Purdy
Attorney at Law
2019N. 17th St.
Boise, ID. 83702
208-384-1299
FAX: [phone]
Email: [e-mail]
3. CAPAI 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 AVISTA Corporation's low income rate payers.
Low income families pay a higher percentage of their income for utility expenses than
those in other economic categories. CAPAI is typically the only party who intervenes in
proceedings before the Commission specifically representing public utilities' low-income
customers. In particular, CAPAI has been involved in a considerable number of AVISTA
proceedings before this Commission widely ranging in scope in recent years. CAPAI 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, CAPAI
will address a variety of issues of importance to the general body of ratepayers.
CAPAI 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 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 AVISTA's Application.
CAPAI notes that there is currently pending a generic, electric docket (Case No. (JNR-E-
12-0 1) pertaining to the issue of low-income weatherization funding including the cost-
effectiveness of that DSM resource and the appropriate funding levels. That case is being
processed under modified procedure and is still in the comment phase, the final deadline for
comments being December 7, 2012. CAPAI does not know if or when there will be final, formal
action taken by the Commission in Case No. GNR-E-12-01 that would fully resolve any and all
issues CAPAT might wish to raise in this proceeding. Further, regardless of whether the
Commission does issue some type of definitive ruling in the generic case resolving low-income
issues, such a ruling will come well after the intervention deadline established by the
Commission in this case and the scope and extent of such a definitive ruling is, of course, not yet
known. Thus, CAPAI believes it warranted to intervene in this proceeding, certainly until future
events take place.
Further, as evidenced in numerous, recent general rate cases in which CAPAI has
intervened' CAPAI believes that its constituents' interests transcend funding for low-income
weatherization funding and energy education. CAPAI intends to address the issues that affect
those interests in the case at hand.
4. CAPAI 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 Z day of November, 2012.
Brad M. Purdy
'See, e.g., Case Nos. A VU-E-11-01, JPC-E-11-08, PAC-E-11-12, PAC-E-11-13, UWI-W-11-02.
CERTIFICATE OF SERVICE
-it,
\ I, the undersigned, hereby represent that on this '6 day of November, 2012, I caused a
true and correct copy of this Petition to Intervene to be served on the following via U.S. Mail,
First Class, Postage Prepaid.
David J. Meyer, Esq.
President and Chief Counsel for Regulatory and Governmental Affairs
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 Regulation
AVISTA Utilities
P.O. Box 3727
1411 E. Mission Ave.
Spokane, WA 99220-3727
Phone: [phone]
Fax: [phone]
7-'..,
DATED, this day of November, 2012
n K - Brad M. Purdy