UTAH RATEPAYERS ALLIANCE
Salt Lake Community Action Program
Crossroads Urban Center
764 South 200 West
Salt Lake City, Utah 84101
October 12, 2004
Julie Orchard, Commission Secretary
Public Service Commission
160 East 300 South, 4th Floor
Salt Lake City, Utah 84101
Re: Docket No. 04-035-42
Dear Ms. Orchard:
Enclosed is the Petition for Leave to Intervene of Salt Lake Community Action Program and Crossroads Urban Center (collectively referred to as the Utah Ratepayers Alliance) in the above-referenced docket. Please file as is your usual practice.
Thank you for your attention in this matter.
Sincerely,
_____________________________________
Betsy Wolf
Utility Ratepayer Advocate
Salt Lake Community Action Program
BEFORE THE PUBLIC SERVICE COMMISSION OF UTAH
***
In the Matter of the Application of )
PacifiCorp for Approval of its Proposed ) Docket No. 04-035-42
Electric Service Schedules and Electric )
Service Regulations )
PETITION FOR LEAVE TO INTERVENE
Pursuant to the Rules of Practice and Procedure of the Utah Public Service Commission (Commission), Salt Lake Community Action Program and Crossroads Urban Center (collectively known as the Utah Ratepayers Alliance) hereby petition for leave to intervene in the above-captioned docket and, in support thereof, state as follows:
1. The Salt Lake Community Action Program (CAP) is a private nonprofit community-based organization that addresses the needs of low-income people through service delivery and advocacy.
2. Crossroads Urban Center (Crossroads) is a nonprofit community-based organization serving the needs of low-income people in the Salt Lake Metropolitan Area.
3. CAP and Crossroads have a special interest in ensuring that the people they represent are charged fair and reasonable electric rates. Any change in the rates of PacifiCorp may have an impact on residential electric customers and the price that residential electric customers will have to pay.
4. Furthermore, since Salt Lake Community Action Program and Crossroads Urban Center represent low income people, those organizations have a particular interest in ensuring that electric utility rates remain as low as possible since people with limited incomes pay such a disproportionate share of their income for electric service.
5. Accordingly, CAP and Crossroads possess a direct and substantial interest in the subject matter of this case, and seek via this intervention petition to protect that interest as it may appear. Participation in this docket will be in the public interest and may also be of particular assistance to the Commission in rendering informed decisions on the issues that will likely be raised.
6. Intervention by CAP and Crossroads will not delay the proceeding or unduly burden the other parties in the proceeding.
7. CAP and Crossroads request that all pleadings, correspondence, discovery, and other documents be served on:
Utah Ratepayers Alliance
c/o Betsy Wolf
Salt Lake Community Action Program
764 South 200 West
Salt Lake City, Utah 84101
FAX: (801) 355-1798
VOICE: (801) 582-2149
E-mail bwolf@slcap.org
8. When sending information regarding this docket electronically, we request that information also be sent to:
Bruce Plenk: bplenk@igc.org
Respectfully submitted this _______ day of October, 2004.
_____________________________________________
Betsy Wolf, Utility Ratepayer Advocate
Salt Lake Community Action Program
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing Petition for Intervention in Docket No. 04-035-42, of Salt Lake Community Action Program and Crossroads Urban Center (collectively known as the Utah Ratepayers Alliance) was mailed, postage prepaid, this ______ day of October, 2004, to the following:
Edward A. Hunter, Jr.
Jennifer Horan
STOEL RIVES LLP
201 South Main Street, Suite 1100
Salt Lake City, UT 84111-4904
Michael Ginsberg Patricia Schmid
Assistant Attorneys General
160 East 300 South, 5th Floor
Salt Lake City, UT 84111
Reed Warnick
Paul Proctor
Assistant Attorneys General
160 East 300 South, 5th Floor
Salt Lake City, UT 84111
Dale F. Gardiner
Parry, Anderson & Gardiner
60 East South Temple, #1200
Salt Lake City, UT 84111
Thomas W. Forsgren
2868 Jennie Lane
Holladay, UT 84117
Coralette M. Hannon
6705 Reedy Creek Rd.
Charlotte, NC 28215
Laura Polacheck
AARP Utah
6975 S. Union Park Center, #320
Midvale, UT 84047
Ron Binz
Public Policy Consultant
333 Eudora Street
Denver, CO 80220
F. Robert Reeder
Vicki M. Baldwin
Parsons Behle & Latimer
One Utah Center, Suite 1800
Salt Lake City, UT 84111
Gary A. Dodge
Hatch, James & Dodge
10 West Broadway, Suite 400
Salt Lake City, UT 84101
Rick Anderson
Kevin Higgins
Neal Townsend
Energy Strategies
39 Market Street, Suite 200
Salt Lake City, UT 84101
Major Craig Paulson
AFLSA/ULT
Utility Litigation Tean
139 Barnes Drive, Suite 1
Tyndall AFB, FL 32403
Mr. James Howarth
OO-ALC/JAN
6026 Cedar Lane, Bldg. 1278
Hill AFB, UT 84056
Peter J. Mattheis
Shaun C. Mohler Brickfield, Burchette, Ritts& Stone, P.C. 1025 Thomas Jefferson Street, N.W.
800 West Tower
Washington, D.C. 20007
Gerald H. Kinghorn
Parsons Kinghorn and Harris, P.C.
111 East Broadway, 11th Floor
Salt Lake City, Ut 84111
Michael L. Kurtz, Esq.
Kurt J. Boehm, Esq.
Boehm, Kurtz & Lowery
36 E. Seventh Street, Suite 1510
Cincinatti, OH 45202
Stephen R. Randle
Randle Deamer & Lee, P.C.
139 East South Temple, Suite 330
Salt Lake City, UT 84111
Respectfully,
________________________________
Betsy Wolf
Salt Lake Community Action Program
Jerold G. Oldroyd
Angela W. Adams
Ballard Spahr Andrews & Ingersoll, LLP
201 South Main Street, Suite 600
Salt Lake City, UT 84111-2221
Michael D. Woods
Comcast Cable Communication, LLC
183 Inverness Drive West, Suite 200
Englewood, CO 80112
J. Davidson Thomas
Genevieve D. Sapir
Cole, Raywid & Braverman, LLP
1919 Pennsylvania Ave., N.W.,
Second Floor
Washington, D.C. 20006