20210303Petition to Intervene.pdf

Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17e Sr
Boise,lD. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attomey for Petitioner
Community Action Partnership
Association of Idaho
IN THE MATTER OF THE APPLICATION
OF AVISTA CORPORATION DBA AVISTA
UTILITIES FOR AUTHORITY TO
INCREASE ITS RATES AND CHARGES FOR
ELECTRIC SERVICE TO ELECTRIC
CUSTOMERS IN THE STATE OF IDAHO
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NOS. AVU-E.2I-OI
AVU-G-21-01
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 3 I .0 I .01 .07 l-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:
l. The address and name of the Petitioner is:
Community Action Partnership Association of tdaho
3350 W. Americana Terrace, Suite 360
Boise,lD. 83706
2. CAPAI will be represented in this proceeding by, and pleadines and other
corresoondence need only be sent to:
CAPAI'S PETITION TO INTERVENE
Brad M. Purdy
Attorney at Law
2019 N. llh St.
Boise,ID. 83702
208-384-t299
Email: [e-mail]
3. CAPAI is a non-profit organization consisting of eight (8) community action partnership
agencies (CAPs) serving every county in Idaho fighting 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. The following are CAP members: Community Action Partnership
("CAP"-Lewiston); El-Ada CAP C'El-Ad4"-geater Boise area as well as Elmore and Owyhee
counties); Metro Community Services (*Mcs"-Caldwell); South Central CAP (*SCCAP"-Twin
Falls); Cornmunity Council of Idaho (*Ccf-Caldwell); Southeastern Idaho Community Action
Agency (*SEICAAP"-Pocatello); Eastern Idaho CAP (*EICAP"-Idaho Falls), and; Western
Idaho CAP (*Wi-Cap"-pur"n"). CAPAI serves as the umbrella organization for all of the CAPs
providing numerous means of support including, but not limited to, representing the CAPs before
the IPUC. The 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. For roughly the past twenty (20) years, CAPAI has
essentially been the only party who regularly intervenes in proceedings before the Commission
specifically representing public utilities' low-income customers and advocating on behalf of
those customers in a myriad of ways. Among other things, CAPAI oversees Avista's Low-
Income Weatherization Assistance (LIWA) pro$am for the Company's low-income customers
which, among other things, reduces the electricity consumption of customers who qualify for and
CAPAI'S PETITION TO TNTERVENE 2
participate in the LIWA program. Thus, CAPAI's participation in cases before the Commission
pertains to a specific progrrm, regulated by the Commission and designed to reduce energy
consumption by those least able to pay their bills. CAPAI's involvement in cases before the
IPUC is not limited to the firnding of energy conservation programs. CAPAI also frequently
takes a position on rate design, customer service quality, cost of service and many other aspects
ofa typical rate case.
CAPAI's weatherization progrcms provide not only a much-needed benefit to those least
able to pay their electric bills by reducing electric consumption through weatherization, but also
enhance the comfort and safety of the programs' participants. CAPAI'S low-income
weatherization programs are recognized and approved by the U.S. Department of Health and
Human Services. Funding for the progams is passed through the Idaho Department of Health
and Welfare who also monitors the programs and their funding levels, as well as numerous other
aspects of CAPAI and its member agencies. In addition to the aforementioned oversight and
monitoring by state and federal agencies, the low-income weatherization proglams are also
subject to scrutiny as to their effectiveness by the Idatro Public Utilities Commission. Thus, the
low-income programs operated by the CAPs, are very specific and regulated by numerous
govemmental agencies, including the Commission.
CAPAI has been involved in a considerable number of AVISTA proceedings before this
Commission widely ranging in scope over a number of years. CAPAI staff works with and
provides administrative support to the CAPs on a regular basis for many reasons such as
implementation and auditing of the Company's low-income weatherization programs. CAPAI
also represents the CAPs before the tdaho Public Utilities and has done so effectively for more
than $ro decades. Furthermore, the services provided by CAPAI not only assist the poor by
CAPAI'S PETITION TO INTERVENE J
helping to reduce their utility bills, but provide benefits to all of AVISTA's ratepayers by
reducing energy consumption and the amount of bad debt incurred due to inability to pay; said
debt which is ultimately passed through to other ratepayers. Thus, if granted intervention in this
case, CAPAI will address a variety of issues of importance to the general body of AVISTA's
ratepayers.
CAPAI believes that it will fulfiIl an important role in this proceeding if given the
oppornrnity 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.
4. CAPAI respectfully requests the right to participate in this proceeding and introduce
testimony and exhibits, cross-examine other parties' witnesses and provide its own, engage in
oral argument and written briefing, file comments, and otherwise fully participate as a party.
WHEREFORE, the Community Action Partnership Association of ldaho hereby requests
that this Commission grant its Petition to lntervene in this proceeding and to fully appear and
participate as a party with all the rights and responsibilities as such.
DATED, this 2nd day of March,2021.
Brad M. Purdy
Attorney for the Community Action
Association of Idaho
CAPAI'S PETITION TO INTERVENE 4
CERTIFICATE OF SERYICE
I, the undersigned, hereby represent that on this 2nd day of March,z0zl,caused a true
and correct copy of this Petition to lntervene to be served on the following:
Idaho Public Utilities Commtssion
JanNoriyuki
Commission Secretary
[e-mail]. eov
John Hammond
Deputy Attomey General
John.hammond@puc. idatro. gov
Avista Utilities
David J. Meyer, Esq., Vice-President
Patrick D. Ehrbar
David.mever@avi stacom.com
Pat. [e-mail]
Avistadockets@ avistacom.com
I daho C ons e rt atio n L e asue
Ben Otto
Idaho Conservation League
botto@ idahoconservation. orq
Walmart, Inc.
NormanM. Semanko
nsemanko @oarsonsbehle. com
Vicki M. Baldwin
vbaldwinOoarsonsbehle. com
DATED, this 2nd day of March,z0zl
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5CAPAI'S PETITION TO INTERVENE
Brad M. Purdy