20240412Staff 29-30 to VPI.pdf

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Friday,April lZ 2024 3:33:03 PM
IDAHOPUEQC
UIIIITIES CIONMSS10N
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334- 0318
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF VP INC.'S )
APPLICATION FOR A CERTIFICATE OF ) CASE NO. VPI-W-24-01
PUBLIC CONVENIENCE AND NECESSITY )
AND TO INCREASE ITS RATES AND )
CHARGES FOR WATER SERVICE IN THE ) THIRD PRODUCTION
STATE OF IDAHO ) REQUEST OF THE
COMMISSION STAFF
TO VP INC.
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Adam Triplett, Deputy Attorney General, requests that VP Inc. ("Company")provide the
following documents and information as soon as possible,but no later than FRIDAY, MAY 31
2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO VP INC. 1 APRIL I2, 2024

In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 29: Please provide the total amount (in pounds) and cost of chlorine
purchased (including sales tax) each month from January 2021 through December 2023. In
addition, please provide the total monthly usage of chlorine used (in pounds) for each well for
the same time period. Also please specify whether a solid or liquid form of Chlorine was used
for each well.
Please provide your responses in spreadsheet(such as, Microsoft Excel) format with
formulas intact.
REQUEST NO. 30: On page 3 of the Sanitary Survey(Exhibit 4 of the Application) it
states: "The system currently serves 81 service connections, all of which are metered." Please
respond to the following:
a. Does the Company currently read the individual service connection meters? If so,
how often are the meters read?
b. If the Company does read the individual service meters,please provide the monthly
metered total customer water usage data(gallons) by customer type from January
2021 through December 2023. Please provide your responses in spreadsheet(such as,
Microsoft Excel) format with formulas intact;
c. If the meters are not read, please explain why the meters are not read; and
d. Please reconcile the difference between the 81 service connections mentioned in the
Sanitary Survey and the 72 customers included in the customer list provided in
response to Staff Production Request No. 21.
DATED at Boise, Idaho, this 12'h day of April 2024.
V4,x� e,—
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\VPI-W-24-01 PR#3.docx
THIRD PRODUCTION REQUEST
TO VP INC. 2 APRIL 12, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 12TH DAY OF APRIL 2024,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VP, INC., IN CASE NO. VPI-W-24-01, BY E- MAILING
A COPY THEREOF, TO THE FOLLOWING:
RICHARD A. VILLELLI BOB HANSEN
VP, INC. WATER SYSTEMS MGT., INC.
PO BOX 1785 WSM, INC.
SANDPOINT, ID 83864-0903 67 WILDHORSE TRAIL
E-MAIL: dick(avillellipnw.com SANDPOINT, ID 83864
E-MAIL: wsmibob�,aol.com
—;w'—
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE