20081003Intervention Petition.pdf

Brad M. Purdy
Attorney at Law
BarNo. 3472
2019 N. 17th S1.
Boise,ID. 83702
[phone]
FAX: [phone]
bmpurdycmhotmail.com
Attorney for Petitioner
Communty Action Parership
Association of Idao
RECENED
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN TH MATTER OF TH COMMSSION'S
INQUIRY ABOUT ENERGY
AFFORDABILITY ISSUES AN
WORKSHOPS
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) CASE GNR-U-08-01
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COMMTY ACTION
PARTNRSHIP ASSOCIA-
TION OF IDAHO'S
PETITION TO INTER-
VENE
COMES NOW, Communty Action Parnership Association of Idaho (hereinaer
"CAP AI" or "Intervenor") and, pursuant to Rules 071-075 ofthe Commssion's Ru1es of
Practice and Procedure, IDAPA 3L.0l.0l.071-075,hereby petitions the Commssion for
leave to formally intervene in ths proceeding and to appear and participate with full
paries' rights. In support of this Petition, CAPAI states as follows:
1. The address and nae of the respective Intervenor is:
Communty Action Parership Association of Idaho
5400 W. Franin Rd., Suite G
Boise, ID. 83705
2. This Intervenor wil be represented in ths proceeding by, and pleadings and other
correspondence need only be sent to:
2019 N. 17th St.
Boise,ID. 83702
208-384-1299
FAX: [phone]
Email: bmpurdycmhotmai1.com
3. CAP AI is a non-profit corporation consisting of six communty action agencies
serving every county in Idaho and also includes, among others, the statewide Communty
Council ofIdaho (formerly the Idaho Migrat Council) and fights the causes and
conditions of povert through building the capacity and effectiveness of its members who
have a direct and substatial interest in ths proceeding. These causes and conditions of
povert include high utility costs for Idaho Power's low income rate payers. Low income
famlies pay a higher percentage of their income for utility expenses that those in other
economic categories. These conditions are often caused by living in sub-stadad or
older housing that is not energy effcient. No other pary tyically intervenes in
proceedings before the Commission, other than CAP AI, that represents the Company's
low-income customers. Consequently, CAP AI fulfills an importt role in this, and
similar proceedings and, without the opportty to paricipate as a pary in this
proceeding, would be unable to fulfill that role.
4. This proceeding (referred to herein as the "Energy Affordabilty case") was
proposed for the purose of addressing the increasing diffculty of utility customers to
pay their electrc and natual gas bils. The groundwork for ths proceeding was due to a
decision memorandum submitted by Staff following settlement negotiations conducted in
Case No. A VU-E-08-01 and AVU-G-08-01 (collectively referred to as the "A VISTA
case"), during which CAP AI proposed and no par opposed ths proceeding, and by the
Commission's own motion. Durg settlement negotiations, all paries agreed that ths
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was an acceptable provision to incorporate into the settlement agreement in the A VISTA
case, but that the Energy Affordability case should be generic in natue ensurg that
Idaho Power Company, Rocky Mountain Power Company and Intermountain Gas
Company be included as well as A VISTA. Consequently, the Commission issued Order
No. 30644, initiating the case at hand.
5. CAP AI intends to paricipate in this proceeding as a pary and introduce
testimony and exhibits, cross-examine other witnesses, engage in oral arguent, fie
comments, and otherwse fully paricipate as a par.
WHEREFORE, the Communty Action Parnership Association of Idaho hereby
requests that this Commission grnt its Petition to Intervene in this proceeding and to
fully appear and paricipate as a pary with all the attendant rights and responsibilities.
~
DATED, thisJ day of Q¿:fobaie ,2008.
~~Brad M. Purdy ~.
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