20241218Staff 1-3 to VPI.pdf

RECEIVED
Wednesday, December 18, 2024 12:19:55 PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 THE APPLICATION )
OF VP INC. TO AMEND CERTIFICATE OF ) CASE NO. VPI-W-24-02
PUBLIC CONVENIENCE AND NECESSITY )
CERTIFICATE NO. 552 )
FIRST PRODUCTION
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 WEDNESDAY,
JANUARY 8, 2025.
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.
FIRST PRODUCTION REQUEST
TO VP INC. 1 DECEMBER 18, 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. 1: Please provide the legal descriptions for each of the three parcels the
Company proposes to add to its certificate. The maps and legal descriptions submitted by the
Company in Exhibit A are truncated and missing important information. For an example, please
refer to the legal description included as Exhibit A of the Company's Certificate No. 552.
REQUEST NO. 2: Please provide a temporary name or title for each of the three
parcels proposed for addition to the certificate, so Staff and the Company can easily identify each
one in correspondence. For example, "Parcel A", "Parcel B", and"Parcel C."
REQUEST NO. 3: A review of the Company's three water rights suggests that the
northernmost parcel proposed for addition to the certificate is not within the Company's
authorized place of use. Please clarify this situation and if there is a need to rectify it,please
describe the Company's plan.
DATED at Boise, Idaho, this 18th day of December 2024.
Adam Triplett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\VPI-W-24-02 PR#l.docx
FIRST PRODUCTION REQUEST
TO VP INC. 2 DECEMBER 18, 2024

CERTIFICATE OF SERVICE
ONN
I HEREBY CERTIFY THAT I HAVE THIS v DAY OF DECEMBER 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO VP INC. , IN CASE NO. VPI-W-24-02, BY E-MAILING A
COPY THEREOF, TO THE FOLLOWING:
RICHARD A. VILLELLI
VP, INC.
PO BOX 1785
SANDPOINT, ID 83864-0903
E-MAIL: dickgvillellipnw.com
a
PA ILIA JORDAN ECRETARY
CERTIFICATE OF SERVICE