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BEFORE THE IDAHO PUBLIC UTILITIES COMMISsioN
IN THE MATTER OF THE APPLICATION
INTERMOUNTAIN GAS COMPANY
FOR AUTHORITY TO CHANGE ITS
PRICES (2005 PURCHASED GAS COSTS
ADJUS TMENT)
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COMMENTS OF
COMMUNITY ACTION
PARTNERSHIP ASSOCIA-
TION OF IDAHO
COMES NOW, the Community Action Partnership Association of Idaho
CAP AI") and, pursuant to the Commission s Notice of Modified Procedure issued in this
case on August 26, 2005, submits the following comments regarding Intermountain Gas
Company s ("Intermountain") application.
Intermountain's proposed PGA adjustment will increase its rates by approximately
27%. The magnitude of such an increase is, of course, a concern and onerous financial
burden on all of Intermountain's ratepayers. As the level of poverty increases in Idaho
however, it is of particular concern to Intermountain's low-income customers.
According to the Idaho s Department of Commerce, 12% of Idahoans live below
the federal poverty guidelines, and 21 % live below 150% of the federal poverty guidelines.
Of the 104 537 Idahoans living at 150% of federal poverty guidelines or below, 34% live
at 50% or below the poverty guidelines. For a family of four: 50% represents an annual
income of $9 675, 100% of poverty represents an annual income $19 350, and the annual
income for 150% of poverty is $29 025. Already, demand for energy assistance well
outpaces availability. In 2004, 29 867 Idaho households were served by the federal
program, Low Income Home Energy Assistance, while 104 537 households were eligible.
Nationally, Idaho has the fourth highest energy burden according to the Department of
Energy. Based on affordability studies conducted by Fisher, Sheehan and Colton, there is
COMMENTS OF CAP
a gap of$50 470 559 between what Idahoans could afford to pay for energy in 2004 and
what they actually had to pay, according to Department of Energy affordability standards.
Given world-wide increases in oil prices, and the attendant increase that results in
energy rates, CAP AI respectfully asserts that it is now more critical than ever to take
substantive steps toward a deeper analysis and course of action toward addressing poverty
in Idaho, and those exacerbating factors, such as increasing utility costs.
CAP AI makes these comments keenly aware that this Commission has recently
taken commendable strides toward the aforementioned objectives. Intermountain, though,
is unique in that it does not have a low-income weatherization program in place.
While the concerns expressed herein might fall outside the scope of this
proceeding, CAP AI respectfully proposes that this Commission initiate a separate
proceeding for the purpose of assessing Intermountain's attempts to address the needs of
its low-income customers, and to determine what authority the Commission does have to
ensure that this important objective is accomplished.
RESPECTFULLY SUBMITTED, this 20th day of September, 2005.
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Brad M~ Purdy
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COMMENTS OF CAP
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT ON SEPTEMBER 20, 2005, I CAUSED TO BE
SERVED BY U.S. MAIL, FIRST CLASS, THE FOREGOING COMMENTS OF
COMMUNITY ACTION PARTNERSHIP ON THE FOLLOWING:
Paul R. Powell
Intermountain Gas Company
O. Box 7608
Boise, Idaho 83707
gOOon1erinput(?Yintgas, com
Morgan W. Richards, Jr., Esq.
804 E. Pennsylvania Lane
Boise, Idaho 83706
Commission Secretary
Idaho Public Utilities Commission
O. Box 83720
Boise, Idaho 83720-0074
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Brad M. Purdy
COMMENTS OF CAP