20140829CAPAI Petition for Funding.pdf

Brad M. Purdy
Attorney at Law
BarNo.3472
2019 N. 17ft St.
Boise,lD. 83702
[phone] (Land)
(208) 384-851 1 (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION TO INITIATE
DISCUSSIONS WITH INTERESTED
PARTIES ON AN EXTENSION OF THE
EXISTNG RATE PLAN AND AVOID A
GENERAL RATE CASE
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NOS. AVU-E-I4-05
AVU-G-14-01
COMMUNITY ACTION
PARTNERSHIP PETITION
FOR INTERVENOR FLTNDING
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I. INTRODUCTION
COMES NOW, the Community Action Partnership Association of Idaho (CAPAI) and,
pursuant to Idaho Code $ 6l-617A and Rules 161-165 of the Commission's Rules of Procedure,
IDAPA 31.01.01.161-165, petitions this Commission for an award of intervenor funding in the
above-captioned proceeding.
II. BACKGROTJND
Because this case was settled through confidential negotiations pursuant to IDAPA
31.01.01 .272,CAPAI will not divulge anything discussed during the two settlement meetings
leading to the Settlement Stipulation, but offers, in general terms, the nature, scope and extent of
CAPAI's involvement in this proceeding for the purposes of the Commission's procedtral rules
related to intervenor funding. Incidentally, the specifics of CAPAI's analysis of Avista's filing in
CAPAI APPLICATION FOR INTERVENOR FUNDING
this case and the resulting settlement agreement now pending before the Commission were set
forth in the formal, written comments filed by CAPAI on August 15,2014 and are incorporated
herein by reference.
The nature of this case is somewhat unique, both substantively and procedurally. There
is a similarity to Rocky Mountain Power's 2013 filing in Case No. PAC-E-13-04 in which that
utility proposed what amounted to a rate increase without going through the process of a formal
general rate case. Avista's filing also sought to avoid filing a general rate case after the previous
sefflement stay-out provision expired through a non-traditional rate filing, but the underlying
facts and procedure followed by Avista were quite different.
The process implemented in this case by Avista involved considerable pre-filing efforts
by the Company to, first and foremost, alert all known regular parties to Avista proceedings
before this Commission of the upcoming filing as early as March, 2014, and to provide those
parties with details as to the nature of the Company's planned filing. This immediately initiated a
fairly thorough back-and-forth information exchange between the Company and parties leading
to formal meetings with each party in May during which Avista made a series of presentations to
each individual parfy. By the time that the formal meetings with parties took place, considerable
work had been conducted by CAPAI to begin aralyzngthe Company's proposal and begin a
process of submitting informal information requests through which the Company provided
information rising to the level of formal discovery in a general rate case.
This informal process of discovery/information exchange continued through the date that
CAPAI executed the settlement agreement roughly four months later. Thus, although the
Company met with CAPAI on May 27th,20t4 to makes its formal presentation, CAPAI had
already invested considerable time and effort beginning more than two months prior to begin
CAPAI APPLICATION FOR INTERVENOR FI.]NDING
understanding the proposed filing and weighing the pros and cons in terms of the consequences
of the filing on the Company's low income customers.
The formal meetings between Avista and the parties included a thorough face-to-face
presentation by Company personnel followed by a thorough question and answer exchange.
Because of the proactive and transparent nature of the process employed by Avista, and the fact
that, because of informal discovery/information exchange already conducted by CAPAI prior to
the meeting, CAPAI's representatives already had an understanding of the proposed filing and
suff,rcient opportunity to analyze its consequences leading to an information exchange more
productive than it would otherwise have been. These formal meetings, therefore, af[orded
parties such as CAPAI the opportunity to ask questions relatively refined questions and to
provide input before the case was ever filed.
Following the formal meetings, CAPAI continued to avail itself of the opportunity to
obtain information relevant to its constituents'interests and that would enable CAPAI to
determine whether the Company's overall proposal was in the best interests of those constituents
and otherwise fair, just and reasonable. In this regard, CAPAI notes that Company personnel,
specifically Linda Gervais and Pat Ehrbar, were readily available and extremely prompt in
responding to all of CAPAI's questions and concerns. This approach by the Company of
reaching out to all interested stakeholders from the outset and through a process that eliminated
surprises and produced an equal distribution of information to all parties, certainly facilitated
CAPAI's ability to determine whether to join in the proposed settlement agreement.
Though, as stated elsewhere in this Petition and articulated by CAPAI in Rocky
Mountain Power's 2013 case, CAPAI continues to have pragmatic concerns about the practice of
avoiding general rate cases through expedited filings that, efflectively, result in general rate
CAPAI APPLICATION FOR INTERVENOR FUNDING
increases, the process implemented gave CAPAI had the ability to flrlly assess the Company's
overall impact on low income customers and conclude that it was in their best interests and
resulted in a fair, just and reasonable outcome for the general body of Avista's ratepayers.
CAPAI also wishes to acknowledge and express its appreciation for the fact that the
Commission Staffmade its personnel available for face-to-face meetings as well as numerous
telephone conversations to engage in discussions of LIWA programs in general, and Avista's
program in particular, to discuss and analyze the various issues at play for CAPAI's constituents
and to deliberate on the technical issues and procedural possibilities available to CAPAI under
the circumstances. Staffmade its experts available to CAPAI representatives through telephone
conferences, email exchanges and face-to-face meetings to discuss and analyze technical and
policy issues and considerations. It is CAPAI's position that the value of these various meetings
and conferences will prove of value into the as CAPAI continues to address the issues of Idaho's
low income public utility customers and advocate for those ratepayers as well as assess its
intemal proficiency in terms of Commission-approved programs including, but not limited to,
low income weatherization assistance (LIWA) and conservation education. CAPAI is
appreciative of Staffs efforts in this respect.
In summary, due to the proactive and transparent of the process implemented by Avista
in this case combined with the cooperation and assistance of Commission Staffto examine issues
of technical complexity and important policy considerations, CAPAI believed it had a solid
understanding of the case that enabled it to comfortably join in the settlement agreement that it
now supports for approval by the Commission.
III. PROCEDURAL REQUIREMENTS
Rule 161 Requirements:
CAPAI APPLICATION FOR INTERVENOR FUNDING
AVISTA is a regulated, electric and gas public utility with gross Idaho intrastate annual
revenues exceeding three million, five hundred thousand dollars ($3,500,000.00).
Rule 162 Requirements:
(01) Itemized list of Expenses
Consistent with Rule 162(01) of the Commission's Rules of Procedure, an itemized list of
all expenses incurred by CAPAI in this proceeding is attached hereto as Exhibit "A."
(02) Statement of Proposed X'indings
Like every other party who joined in the settlement, CAPAI supports the settlement in its
entirety and proposes that it be approved and adopted by the Commission. CAPAI appreciates
the parties who executed the seulement, particularly Avista and the Commission Staff, who
helped to devise a process of continuing to assess all aspects of the Company's LIWA program,
from cost-effectiveness to adequate levels of funding, and provide an agreed-upon timeline for
doing so. Furthernore, Avista has demonstrated over time its willingness to work with CAPAI
on an informal basis to better define and identifu the Company's low income customers and
understand the implications of residential rate design on those ratepayers.
CAPAI recommends, therefore, that the Commission approve the settlement agreement
as it exists, and find the same to be a fair, just and reasonable outcome for all ratepayers.
(03) Statement Showing Costs
For the reasons stated throughout this Petition, CAPAI respectfully submits that the costs
it seeks to recover and set forth hereto in Exhibit A, are reasonable in amount.
Although the Company's filing resulted in a negotiated settlement, there are several
factors that required CAPAI to engage in reasonable and significant effort to adequately
represent the interests of low income customers in much the same manner as had this been a
CAPAI APPLICATION FOR INTERVENOR FUNDING
general rate case filing. General rate cases have, historically, provided an opportunity for all
parties to raise a wide array of issues pertinent to the utility seeking a general rate increase. Due
to financial constraints and other reasons, it is often not feasible for parties like CAPAI to make
formal, issue-specific, filings with the Commission every time they believe that an issue
requiring Commission action exists. Thus, CAPAI, like all other parties, must ensure that any
settlement agreement that constitutes a de facto rate increase but does so without a formal
hearing and the opportunities such a process provides does address those critical issues that
CAPAI would otherwise raise during a general rate case. This is particularly true where the
settlement agreement includes a "stay-out" provision further deferring the next opportunity to
raise issues as described.
Filings such as the one at hand and in which rates are effectively increased without the
same degree of scrutiny that the proposed increase would be subject to if the matter were to
proceed to hearing, can be a source of concern for CAPAI. In saying this, CAPAI is in no way
suggesting that Commission Staff does not otherwise fully scrutinize a utility's proposed filings
to determine whether, from a ratemaking standpoint, the filing and resulting settlement would
result in rates that are fair, just and reasonable. Despite Staffs ratemaking scrutiny, however,
general rate cases often involve issues that simply do not fall within the scope of Staffs rate
analyses and, on occasion, justiff the airing of issues in a contested case hearing before the
Commission. In this respect, CAPAI generally concurs with the sentiments expressed by Snake
River Alliance in its comments filed in this matter.
In the case at hand, it was necessary for CAPAI to consider several potential
disadvantages to the proposed settlement. Pursuant to Order No.32788, issued in Case No.
GNR-E-12-01, funding for Avista's low income weatherization program (LIWA) is no longer
CAPAI APPLICATION FOR INTERVENOR FUNDING
necessarily frozen at existing levels. See, Order No. 32788, p.13 Thus, CAPAI had to factor in
to its settlement decision the fact that it was waiving, for the purpose of this case, an opportunity
to advocate moving forward with respect to a highly valuable and unique conservation program
that is capable of providing considerable benefits to low income customers and value to the
general body of ratepayers.
Another factor CAPAI had to consider is that the Company's current residential rate
design might no longer be fair, just and reasonable for low income ratepayers based on their
respective levels of consumption and the fact that they are prone to being more price inelastic
due to financial constraints making it difficult, if not impossible to weatherizethefu homes. It is
conceivable that, had this case gone to full hearing, CAPAI might have advocated for a change in
residential rate design to address inequities that might exist for low income customers.
The foregoing examples are but two of the number of issues that CAPAI analyzed in
considerable detail and discussed with Avista, the Commission Staff, and other parties. In short,
the majority of the same work that CAPAI must invest in preparing to go to hearing is required
to determine whether to join in an extended-term rate settlement. Although Avista acted in
exemplary fashion regarding its willingness to facilitate CAPAI's analyses, CAPAI was working
within a relatively compressed time frame in comparison to a general rate case, and its legal
counsel and technical and policy expert were required to put other matters aside and conduct the
work necessary to ensure that low income interests were sufficiently addressed by the proposed
settlement within the agreed-upon deadlines.
Another unique aspect to this case is that CAPAI invested considerable time working
with Commission Staffto address issues and concerns Staff had and those it still has regarding
Avista's LIWA program. As noted herein, CAPAI believes that these ef[orts were very
CAPAI APPLICATION FOR INTERVENOR FUNDING
worthwhile and will prove valuable in the future, there was considerable discussion with Staff
regarding the feasibility of seeking LIWA funding increases, current program design, cost-
effective analysis, and ideas for improving the overall efficacy of LIWA. These efforts
ultimately yielded a settlement provision set forth in Section III(FX3) of the settlement
agreement. CAPAI appreciates both Staffand the Company for agreeing to continue to address
the Company's LIWA program and believes that the time frame for doing so and contained in the
settlement agreement constitutes a reasonable approach to accomplish this objective.
Finally, regarding the reasonableness of CAPAI's costs, CAPAI notes that it has no
choice but to minimize its expenses and maximize the effect that its involvement has in
proceedings before the Commission in light of its limited financial resonrces for this type of
effort. Suffice it to say that CAPAI seldom can afford to retain an expert witness and does so
only in particularly technical and critical proceedings. Otherwise, it must adopt a resourceful
approach using what limited resources that are at its disposal. In this regard, CAPAI relies
heavily on its Executive Director, Christina Zamora, for all technical and policy aspects of this
and any other IPUC case that CAPAI intervenes in. In that and every other respect, Ms. Zamora
is a highly-qualified expert. Were CAPAI to track and bill her hours at anything remotely
resembling a modest market rate, CAPAI's funding requests would increase significantly. As it
is, Ms. Zatrtoraperforms what she considers to be another aspect of her work.
Thus, from CAPAI's perspective, it cannot afford to retain an outside expert and then be
compensated for that person's work, yet its own expert, Ms. Zamora, contributes substantial
amounts of time and resources into PUC cases and does not seek a single cent of money for her
efforts. CAPAI respectfully submits that this is something that should not be undervalued or
underappreciated.
CAPAT APPLICATION FOR INTERVENOR FUNDING
Finally, CAPAI notes that its legal counsel's stated rate is less than the average first year
associate practicing in Boise, Idaho. CAPAI's counsel has nearly 30 years of practice as an
attomey, 24 years of which include public utilities work, one of the most highly specialized
fields in the practice of law. Hourly rates for an attorney with commensurate experience in such
a specialized area of practice in this market are at least2-3 times what CAPAI seeks for recovery
in its intervenor funding requests. Furthermore, in the roughly eleven years that CAPAI's legal
counsel has represented CAPAI in PUC proceedings, counsel has increased his rate only 2-3
times and, even then, only an overall total of approximately $50/hour.
Based on the foregoing, the comments submitted by CAPAI on August 15,2014, and
Exhibit "A" to this Petition, CAPAI respectfully submits that the costs incurred and requested in
this case are reasonable in amount.
(04) Explanation of Cost Statement
CAPAI is a non-profit corporation overseeing a number of agencies who fight the causes
and conditions of poverty throughout Idaho. CAPAI does not have "memberships" and,
therefore, does not receive member contributions of any kind. Many of CAPAI's fi.rnding
sources are unpredictable and impose conditions or limitations on the scope and nature of work
eligible for funding. CAPAI, therefore, has relatively little "discretionary" funds available for all
projects.
CAPAI's sole source of funding to cover the costs of intervention before this
Commission is the LIHEAP progrcm. CAPAI's LIHEAP budget is severely limited and
inflexible and, if recent years serve as any indication, uncertain as to its future levels.
Thus, were it not for the availability of interyenor funds and past awards by this
Commission, CAPAI would not be able to participate in cases before this Commission
9CAPAI APPLICATION FOR INTERVENOR FUNDING
representing an important and otherwise unrepresented segment of regulated public utility
customers. Even with intervenor funding, participation in Commission cases constitutes a
significant financial hardship because CAPAI must pay its expenses as they are incurred, not if
and when intervenor funding becomes available.
(05) Statement of Difference
CAPAI was the only party to fully analyze rate design as it affects residential, low-
income customers and Avista's LIWA progftlm funding and waited until it had completed its
analysis before joining the settlement. Although the Company and Staffultimately provided
helpful input to CAPAI in the latter's efforts, it is fair to say that CAPAI's determination to
address this important issue before joining in the settlement was a material difference from the
position taken by Stafffor purposes of intervenor funding requirements.
(06) Statement of Recommendation
Avista's low income customers constitute a significantly and increasing segment of the
Company's residential ratepayers. In today's increasingly challenging economic times, issues
affecting low income public utility ratepayers also become increasingly important. To the extent
that low income customers are unable to reduce their energy consumption due to limited
financial and other means and to the extent that the poor are most vulnerable to disconnection
due to inability and failure to pay their bills, this clearly affects the general body of Avista's
customers.
(07) Statement Showing Class of Customer
To the extent that CAPAI represents a specific customer class of AVISTA, it is the
residential class.
CAPAI APPLICATION FOR INTERVENOR FLINDING 10
RESPECTFULLY SUBMITTED, this Z9thday ofAugust, 2014.
Brad M. Purdy
CAPAI APPLICATION FOR INTERVENOR FUNDING
CERTIX'ICATE OT SERVICE
I hereby certifu that I caused to be served the foregoing document on the following by
either hand delivery or U.S. Mail, first class, and via email:
KellyNorwood
David Meyer
Avista Corporation
P.O.Box3727
Spokane, WA 99220-3727
kelly.norwood@avistacorp. com
david.meyer@avistacorp. com
Dean J. Miller
McDevitt & Miller, LLP
420W. Bannock St.
Boise,ID 83702
j oe@mcdeviff -miller. com
Donald L. Howell, II
Idaho Public Utilities
Commission
472 W, Washington (83 702)
P0 Box 83720
Boise,lD 83720-0074
Peter J. Richardson
Gregory M. Adams
515 N.27th St.
Boise,ID 83702
peter@richardsonadams. com
greg@ichardsonadams. com
Benjamin Otto
710 N. Sixth Street
Boise,ID 83702
botto @idatroconservation. org
Ken Miller
P.O. Box l73l
Boise,ID 83701
kmiller@snakeriveral liance. org
Dated, this 15th Day of Augast,20l4
CAPAI APPLICATION FOR INTERVENOR FUNDING
a-\
t2
EXHIBIT ..A'
ITEMIZED EXPENSES
As outlined below, CAPAI respectfully seeks intervenor funding in this proceeding in the
amount of $9,920.00. The most recent case in which CAPAI sought intervenor funding was
Case No. PAC-E-I3-04 in which the Commission, for the first time since CAPAI began
intervening in cases before this Commission in the early 2000s, issued several orders questioning
the form and/or substance of CAPAI's funding petition initially requiring CAPAI to "indicate
the amount of hours or the percentage of hours spent on areas" which the Commission then
outlined. CAPAI complied with this directive by providing the percentage of hours spent on the
areas specified by the Commission in a subsequent filing. The Commission then awarded
intervenor funding in the sum of $12,000.00 but, despite CAPAI's compliance with the
Commission's specific directive, continued to note shortcomings in CAPAI's support for its costs
stating, in reference to the undersigned, that "[w]e urge counsel to develop or obtain a system to
more accurately track and document his professional services related to Commission
proceedings." Order No. 32946.
Because CAPAI's counsel had provided the percentage breakdown in the categories
outlined by the Commission, it remained unclear to CAPAI exactly what the Commission
expected from CAPAI's legal counsel to substantiate his hours and costs short of including actual
time sheets submitted by legal counsel to his client. As CAPAI explained in considerable detail,
legal counsel's time sheets are not only tracked and documented, but unusually detailed and
contain intimate descriptions of, among other things, legal strategy that is relevant not only to the
case at hand, but future cases as well.
Certain CAPAI invoice entries for a single day can fill nearly an entire page, single-
spaced. An invoice for a given month is typically 3-5 pages in length, with a level of detail so
great that individual telephone calls are often described. Compared to some attomeys, CAPAI's
legal counsel simply never has an entry to the effect of "worked on case." This would simply not
be acceptable for CAPAI's needs. As CAPAI also explained in detail in Case PAC-E-I3-04, the
various reasons that its legal counsel maintains such meticulous time sheets, include, among
many other things, the fact that they constitute an invaluable resource for quickly recalling what
actions were taken during a given case, and on what date. Most important is the fact that CAPAI
is monitored and audited by govemmental entities. As a govertment-funded entity, CAPAI must
account for its activities with specificity. Attorney time sheets that are anything other than
meticulous place CAPAI in a potentially difficult position with respect to federal laws and
expectations, something that CAPAI's legal counsel clearly cannot allow to happen for his client.
CAPAI is unclear why or when certain parties began attaching actual attomey time sheets
to their intervenor funding petitions, but maintains that this practice is a very slippery slope both
for the attorney, from an ethical standpoint and, more importantly, from the perspective of the
client's bests interests. Because of the detailed nature of CAPAI's legal counsel's time sheets,
they clearly convey CAPAI's litigation strategies, among other things, which are not
discoverable under the Idaho Rules of Civil Procedure and fall squarely within the letter and
intent of the Idaho Rules of Professional Responsibility approved by the Idaho Supreme Court
and enforced by the Idaho State Bar Association.
Notwithstanding the foregoing, CAPAI fully understands and appreciates the
Commission's need and desire for a factual basis on which to issue intervenor funding rulings
and wishes to provide the Commission with what it needs in that respect. This is why CAPAI
CAPAI APPLICATION FOR INTERVENOR FT.INDING 13
frled a Petition for Clarification with the Commission in Case PAC-E-I3-04. The Commission
denied that Petition, however, in Order No. 32975 and offered no greater specificity as to
precisely what it expects from CAPAI. This is the conundrum that CAPAI perceives itself to be
facing.
Regardless, and in a continued effort to provide the Commission with the information it
deems necessary, attached below is a monthly breakout of hours worked, and a general
description of the work performed during that month. CAPAI wishes to emphasize that the
work summaries, though accurate, do not fully reflect actual work performed. They do,
however, provide additional information from that previously provided to the Commission. If
the Commission still desires additional or different information, CAPAI welcomes any
specificity the Commission is willing to provide and will, to the very best of its ability, comply.
CAPAI'S SUMMARY OF WORK PERTORMED BY LEGAL COUNSEL
March Invoice (for work performed during March):l
Total Hours Worked:
Nature of work: Discussed upcoming Avista rate case filing and
need to fully assess current status of Company's LIWA program
and all issues related thereto prior to rate filing. Related research
re status of LIWA since 2012 generic rate case and current need
for program. Numerous phone conversations and emails with
Avista and client.
May Invoice
Total Hours Worked:2.4
Nature of Work Continued discussion of need to assess status of
LIWA progftrm and whether it will be considered in upcoming rate
case. Continued research into cost-effectiveness evaluations of
LIWA and pending studies/reports for same. Numerous phone
conferences with Avista personnel and client, including N. Idaho
Community Action Agency personnel.
June Invoice
Total Hours Worked:
Nature of Work Numerous communications with Avista personnel
including legal counsel re proposed filing and meetings with all
I Each invoice's stated month is for work actually performed during the preceding month. Invoices are sent out at
the beginning of each month after the previous month's work has been described and included in an invoice and the
hours (and any "costs") calculated.
CAPAI APPLICATION FOR INTERVENOR FUNDING 14
1.5
7.0
stakeholders prior to filing. Numerous emails/phone calls Avista
and client re scheduling of meetings, nature of same, nature of
frling and initial discussion of CAPAI's areas of interest and
issues to be addressed. Preparation for and conducting of meeting
with Avista to discuss proposed rate filing. Post-meeting communications
and strategy analyses with client. Initial information requests (informal
discovery) ilAvista re all LIWA and residential rate design issuess
relevant to low income customers. Meetings with other stakeholdrs
to discuss Avista proposal and other parties' position w/respect to
same. Follow-up meetings and other communications.
July Invoice
Total Hours Worked: 18.0
Nature of Work: Thorough analysis of Avista rate filing and numerous
communications with client and other parties re same. Identifr all
issues of all parties. Meetings ilother parties. Communications w/
Staffre procedural implications of Avista filing and housekeeping
matters including need for intervention filing, etc. Receipt/review
Commission intervention orders. Considerable discovery with Avista
and related teleconferences w/Company and client re same. Coordinate
best means to advance desire to improve LIWA progrzrm, where possible,
and to work with Staff to address latter's concerns and solicit input
re same. Phone calls/emails Commission Staffre technical and procedural
issues. Constant communications with client re foregoing. Outline
plan for meeting dStaff and Company to advance discussion of all
issues of interest to Company's low income customers. Numerous phone
conferences Avista re rate design issues including consumption data of
Company's low income customers. Receipt andanalyze data provided
by the Company re same. Communicatioins with other parties re their
respective issues and positions on same and possible settlement as
proposed by Avista. Internal discussions and analyses of pros and cons
of proposed settlement. Scheduling of settlement negotiations and prepa-
ration for same. Additional meetings/communications other parties
prior to settlement. Preparations for settlement negotiations and
participation in same. constant communications with client throughout.
Detailed discussions dAvista re cost-effectiveness evaluations of
LIWA programs in other cases and possible use in pending case.
Post-settlement phone calls Staff re procedural options for CAPAI
and LIWA/rate design in general. Follow-up discussions dStaff
with goal of meeting to discuss technical and policy aspects of low
income issues in person. Numerous teleconferences with client.
August Invoice
t5CAPAI APPLICATION FOR INTERVENOR FUNDING
Total Hours \trorked:
Nature of Work:Continued communications all parties re low
income issues and federal action affecting WAP weatheriztion
progftrm and gap created increasing importance of utility-funed
programs. Preparation for and participation in meeting dStaff
to discuss/analyze all low income issues. Follow-up communications
Staff and client re same. Intemal discussions re assessment of how
various agencies implement LIWA and assessment of whether efficiencies
can be obtained through implementation of various techniques, including
those recommended by Staff. Analysis of overall "need" for LIWA now
in relation to 2012 when funding levels were frozen. Many meetings and
other communications with client and CAPAI agency personnel. Additional
communcations dStaffand agreement to meet again Numerous
communications dAvista re meetings dStaff and proposed settlement.
Receipt and analysis of proposed settlement agreement from Avista and
many communications with all parties re same including whether it
adequately addresses the ongoing efforts to address low-income issues.
Review numerous back and forth proposed revisions from all parties to
settlement agreement. Propose revisions to settlement to better address
low income issues. Conduct second technicaVpolicy meeting with
Staffand CAPAI. Constant communications with client throughout
month. Additional detailed conversations dAvista technical staff re
low income issues and weighing pros and cons of various procedural
options. Receipt/review numerous revisions-counter-revisions and
many drafts of settlement agreement. Numerous communications all
parties re same. Discussions dclient re decision whether to join in
proposed settlement agreement. Detailed discussions dAvista re how
to proceed with addressing low income issues if settlement, as proposed,
is executed. Discuss timelines for same and procedural options.
Many communications and meetings w/client and CAPAI agency
personnel related to rate case and LIWA in general. Detailed discussions
w/Avista re rate design issues and agreement to further analyze same
on an ongoing, informal basis. Finalize and execute settlement agreement
on behalf of CAPAI. Post settlement meetings with client to discuss how
to actually implement agreed-upon process for addressing low income
issues and timeline for doing so as well as need to coordinate efforts
intemally within CAPAI. Additional communications dStaff re
procedural timelines for post-settlement issues, including filing of
comments as opposed to testimony and filing of intervenor funding
testimony.
September Invoice
Total Hours Worked:
22.0
15.00
CAPAI APPLICATION FOR INTERVENOR FUNDING t6
Nafure of Work: Prepare and file CAPAI's comments in support of proposed
settlement agteement. Numerous meetings and other communications
with Staff, Avista and other parties as follow-up to settlement. Receipt
and analysis of all other parties'comments filed with IPUC. Internal
meetings dCAPAI personnel to discuss and outline work needed to
engage in low income work outlined in settlement agreement and
preparation needed for same.
Total Hours Worked on Case 65.90
Costs:
Fees:
Total Expenses
Photocopies/postage
Total Costs
Legal (Brad M. Purdy -65.90hours @ $150.00/hr.)
Total X'ees
$3s.00
$3s.00
$9,885.00
$9,885.00
$9.920.00
CAPAI APPLICATION FOR INTERVENOR FT]NDING t7