20160919Petition to Intervene.pdf

September 19, 2016, 2015
Ms. Jean Jewell
Secretary
Idaho Public Utilities Commission
472 W. Washington
Boise, ID 83702
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, Idaho 83702
[phone]
Cell: [phone]
Fax: [phone]
,E CEIVED
2Dlfi SEP 19 PM 3: 04
Re: Case No. INT-G-16-02: Intermountain Gas Company's 2016 General Rate Case
Dear Ms. Jewell:
Enclosed, please find an original and s seven (7) copies of Community Action Partnership
Association of Idaho's Petition to Intervene in the above-referenced proceeding.
Yours truly,
Brad M. Purdy
Brad M. Purdy
Attorney at Law
Bar No. 3472
2019 N. 17th St.
Boise, ID. 83702
[phone] (Land)
[phone] (Fax)
[e-mail]
Attorney for Petitioner
Community Action Partnership
Association of Idaho
REC EIVED
?016 SEP 19 PH 3: 04
,·,,. '.:, i ,JF-ll.!C
• i ! : • ,::ow.,ISSION
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF INTERMOUNTAIN GAS COMPANY'S
APPLICATION TO CHANGE ITS RA TES
AND CHARGES FOR NATURAL GAS
IN THE ST A TE OF IDAHO
)
)
)
)
)
)
) __________________ )
CASE NOS. INT-G-16-02
COMMUNITY ACTION
PARTNERSHIP ASSOCIATION
OF IDAHO'S PETITION TO
TO INTERVENE
COMES NOW, Community Action Partnership Association ofldaho (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, CAP AI 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. CAP AI will be represented in this proceeding by, and pleadings and other
correspondence need only be sent to:
CAPAI PETITION TO INTERVENE 1
Brad M. Purdy
Attorney at Law
2019 N. 17th St.
Boise, ID. 83702
208-384-1299
Email: bmpurd [e-mail]
3. CAP AI is a non-profit corporation whose membership consists of six community action
and two special purpose agencies serving every county in Idaho. The mission of CAP AI is to
fight the causes and conditions of poverty through building the capacity and effectiveness of its
members. CAP Al's members have a direct and substantial interest in this proceeding. The
causes of poverty are numerous and disparate, the conditions are exacerbated by decreasing
energy affordability caused by increasing utility unit and base rates such as those requested by
the Company.
This results in the necessity to make decisions on which basic needs (housing, food,
energy or medication) are most important at any given time. Low income families pay a higher
percentage of their income for utility expenses than those in other economic categories. CAP AI
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 lntermountain Gas proceedings before this Commission widely ranging
in scope in recent years. If granted intervention in this case, CAP AI will address issues of
importance to the general body of ratepayers, including the Company's substantial increase in the
customer charge and the impact of the proposed customer charge on low income customers.
CAP AI 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 CAP AI has a direct and
CAPAI PETITION TO INTERVENE 2
substantial interest in the subject matter of this proceeding and its intervention wilJ not unduly
broaden the issues presented by Intermountain's Application.
4. CAP AI 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 fulJy 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 fulJy appear and
participate as a party with all the rights and responsibilities as such.
DATED, this 19th day of September, 2016.
Brad M. Purdy
Attorney for Community Action Partnership Assoc. of Idaho
CAP AI PETITION TO INTERVENE 3
CERTIFICATE OF SERVICE
I, the undersigned, hereby represent that on this 21st day of June, 2016, caused a true and
correct copy of this Petition to Intervene to be served on the following both electronically and via
U.S. Mail, First Class, Postage Prepaid (unless otherwise indicated).
Jean Jewell, Secretary:
Idaho Public Utilities Commission
472 W. Washington St.
P.O. Box 83720
Boise, Idaho 83720-0074
[e-mail]
Clearwater Paper Corporation:
c/o Peter Richardson, Esq.
Richardson Adams, PLLC
515 N. 27th St.
P.O. Box 7218
Boise, ID 83702
[e-mail]
Northwest Industrial Gas Users:
Chad Stokes
Tommy Brooks
Cable Huston, LLP
1001 S.W. 5th, Ste 2000
Portland, OR 97204-1136
[e-mail]
[e-mail]
Michael Creamer
Givens Pursley, LLP
601 W. Bannock St.
Boise, ID 83702
[e-mail]
DATED, this 18th day of September, 2016
CAP AI PETITION TO INTERVENE 4