20171026Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 1711' St.
Boise,lD. 83702
[phone] (Land)
(208) 384-8sl I (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
TN THE MATTER OF THE JOINT
APPLICATION OF HYDRO ONE LIMITED
AND AVISTA CORPORATION FOR
APPROVAL OF MERGER AGREEMENT
ELECTRICSERVICE IN IDAHO
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
CASE NOS. AVU-E-I7-09
AVU-G-17-05
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S PETITION TO
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
3350 W. Americana Terrace, Suite 360
Boise,ID. 83706
2. CAPAI will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
1
':,..11{,.-l i..' i- I ! :.- LJ
1r pl,'l 1. 1;LU I ll rJ'v'w
CAPAI PETITION TO INTERVENE
Brad M. Purdy
Attorney at Law
201g N. 17th St.
Boise,lD. 83702
208-384-1299
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 ahigher 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 and to address a wide variety of issues
ranging from rate design and revenue requirement to low income programs such as the
Company's LIWA weatherization program. If granted intervention in this case, CAPAI will
address a variety of issues of importance to the general body of ratepayers.
The case at hand is somewhat unique and certainly significant for all of Avista's
ratepayers, including low income. CAPAI submits that it will enhance the Commission's
understanding of how the proposed merger might affect the interests of the poor, both positively
and negatively. In its initial filing, Avista indicated that there will be synergies resulting from
2CAPAI PETITION TO INTERVENE
the benefits of which would inure to ratepayers. In addition, Avista has asserted that, due to the
different cultural climate in which Hydro One exists, there might be made available to the
Company's Idaho customers additional funding that would enhance the combined entity's ability
to address issues of social concern, perhaps including low income weatherization, conservation
education, and possibly the development of additional programs.
CAPAI intends to examine these possibilities and, as the primary low income advocate
appearing before the ldaho Commission, is in a favorable position to provide educated input
regarding low income interests and the interests of majority of Avista's Idaho ratepayers.
Based on the foregoing, CAPAI believes that it would fulfill an important role in this
proceeding if given the opportunity to participate as a party. Consequently, CAPAI respectfully
submits that it 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 and Hydro One's
Application.
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 the 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 26th day of October,2Ul7.
Brad M.
Attomey for CAPAI
aJCAPAI PETITION TO INTERVENE
(
CERTIFICATE OF SERVICE
I, the undersigned, hereby represent that on this 26th day of October,2017 , caused a true
and correct copy of this Petition to lntervene to be served on the following electronically (unless
otherwise indicated).
Diane Hanian, Secretary
Idaho Public Utilities Commission
472W. Washington St.
Boise,Idaho 83702
[e-mail]. gov
[e-mail]. sov
(Served electronically and by hand-delivery)
Branden Karpen
Deputy Attorney General
Idaho Public Utilities Commission
472W. Washington St.
Boise,ID 83702
Branden. kamen@puc. idaho. gov
(Served electronically)
Clearwater Paper Corporation
c/o Peter Richardson
Richardson Adams, PLLC
515 N. 27th St.
Boise,lD 83702
peter@richardsonadams. com
Dean J. Miller
3620E,. Warm Springs Ave.
Boise,ID 83716
deanj [e-mail]
Ronald L. Williams
P.O. Box 388
Boise,ID 83701
.com
James Scarlett
Chief Legal Officer
Hydro One
483 Bay St., 8th Fh, S. Tower
Toronto, Ontario
i scarlett@hydroone. com
CAPAI PETITION TO INTERVENE
David J. Meyer/I(elly Norwood
Avista Corporation
l4l I W. Mission Ave.
Spokane, WA 99220
david. meyer@avistacorp. com
kel ly. norwood@avi stacorp. com
Patrick Ehrbar
Avista Corporation
1411 E. Mission Ave.
Spokane, WA 99220
patri ck. [e-mail]
Dr. Don Reading
6070 Hill Rd.
Boise,ID 83703
dreadin [e-mail]
Larry Crowley
5549 S. Cliffsedge Ave.
Boise,ID 83716
[e-mail]
Elizabeth Thomas
Kari Vander Stoep
K&L Gates,LLP
925 Fourth Ave., St. 2900
I iz. thomas@kl gates. com
[e-mail]
4
DATED, this 26th day of October,Z}l7
---z_
Brad M.
5CAPAI PETITION TO INTERVENE