20250128Staff Comments .pdf

RECEIVED
Tuesday, January 28, 2025 12:08.26 PM
IDAHO PUBLIC
UTILITIES COMMISSION
ADAM TRIPLETT
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
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 TO AMEND CERTIFICATE ) CASE NO. VPI-W-24-02
OF PUBLIC CONVENIENCE AND )
NECESSITY NO. 552 )
COMMENTS OF THE
COMMISSION STAFF
COMMISSION STAFF ("STAFF") OF the Idaho Public Utilities Commission
("Commission"), by and through its Attorney of record, Adam Triplett, Deputy Attorney
General, submits the following comments.
BACKGROUND
On December 5, 2024, VP Inc. ("Company") applied to amend its Certificate of Public
Convenience and Necessity("CPCN")No. 552 to expand its certificated service territory.
The Company represents that it provides water service to the Hidden Lakes Subdivision
and First and Second Additions 1 and 2 in Bonner County, Idaho.
The Company seeks to serve areas adjacent to its current service area that, according to
the Company, cannot be served by any other water utility.
STAFF COMMENTS I JANUARY 28, 2025

The Company represents that one of the parcels in the expansion area is being subdivided
into 7 parcels subject to County approval.
The Company represents that it currently can provide safe, reliable service to the
expanded service area.
STAFF ANALYSIS
Staff reviewed the Company's Application, exhibits, and responses to production
requests. Based on its review, Staff recommends the Commission amend the CPCN No. 552 to
include additional service areas as described in Attachment A, and depicted in Attachment B.
Description of the Proposed Amendment
In its Application, the Company proposed to amend its service area by adding three
separate parcels, each parcel being contiguous with its existing service area. See Application at
3. For convenience, the Company and Staff agreed to call these three parcels "Parcel A", "Parcel
B", and"Parcel C". See Response to Production Request No. 2.
Water Rights
Staff believes the Company's existing water rights are adequate to support some of the
additional service area, but not all of it.
The Company owns three water rights with a combined total diversion amount of 494
gpm. Staff believes this flow rate is sufficient to meet current load and likely future
development.
However, Staff research suggested that Place of Use boundaries for the Company's water
rights did not include the northernmost parcel ("Parcel C") the Company proposed to add to its
service area. When asked about this issue, the Company requested that Parcel C be removed
from its proposed amended service area. See Response to Production Request No. 3. Staff has
modified the proposed Service Area accordingly.
STAFF COMMENTS 2 JANUARY 28, 2025

Company Service Area
Staff believes that Parcel A and Parcel B can be properly added to the Company's service
area. The resulting amended legal description is provided as Attachment A, and the amended
map of the service area is provided as Attachment B.
Attachment A lists each of the individual plats within the Company's overall service area
with a short description of each plat. This now includes Parcel A and Parcel B that the Company
asked to add. See Response to Production Request No. 1. This list of plats serves as an index for
the detailed property descriptions, which Staff included as separate exhibits within Attachment A
(attached hereto as Exhibit 1, Exhibit 2, and Exhibit 3). These detailed property descriptions
were obtained from Bonner County's records.
Attachment B provides an illustrated view of the new boundaries, including Parcel A and
Parcel B, for the recommended overall service territory.
Staff confirmed the amended service area(1) encompasses all areas for which the
Company is currently providing service, (2) does not encroach upon any other water systems,
and (3) is within the limits of the Company's water rights.
STAFF RECOMMENDATION
Staff recommends the Commission amend CPCN No. 552 to include additional service
areas described in Attachment A and depicted in Attachment B.
Respectfully submitted this 28th day of January 2025.
Adam Triplett
Deputy Attorney General
Technical Staff: Matt Suess
I:\Utility\UMISC\COMMENTS\VPI-W-24-02 Comments.docx
STAFF COMMENTS 3 JANUARY 28, 2025

Legal Description of VP Inc. Service Area(Amendment 1)
Hidden Lakes, Bonner County, Idaho, Instrument No. 344989
A tract of land located in a portion of the East half of Section 36,Township 58 North, Range 1 West,
Boise Meridian, Bonner County, Idaho
and
First Addition to Hidden Lakes, Bonner County, Idaho, Instrument No. 420411
A tract of land located in a portion of the East half of Section 36,Township 58 North,Range 1 West,
Boise Meridian, Bonner County, Idaho
and
Second Addition to Hidden Lakes, Bonner County, Idaho, Instrument No. 460566
A tract of land located in a portion of the East half of Section 36,Township 58 North, Range 1 West,
Boise Meridian, Bonner County, Idaho
and
Lots 1,2, and 3 of Mary's Pack River Lots, Bonner County, Idaho, Instrument No. 699091
A tract of land located in a portion of the East half of Section 36,Township 58 North, Range 1 West,
Boise Meridian, Bonner County, Idaho
and
Bonner County, Idaho, Instrument No. 953774
A tract of land located in a portion of the Southwest quarter of the Southeast quarter of Section 36,
Township 58 North, Range 1 West, Boise Meridian, Bonner County, Idaho
(See Exhibits I and 2 for the detailed property description)
and
Bonner County, Idaho, Instrument No. 959349
A tract of land in the East half of the Northeast quarter of the Southwest quarter and the Northwest
quarter of the Southeast quarter of Section 36, Township 58 North, Range 1 West, Boise Meridian,
Bonner County, Idaho
(See Exhibits I and 3 for the detailed property description)
Attachment A
Case No. VPI-W-24-02
Comments
January 28, 2025

T_
J r-
toy
!r J�py
�r £• n
* "•" �(' oo 0 0 0 oa1710,inlfe �Oo a �ogapCo oo�G°� ®�Oo�4
,.tjf 11�r
ingTo�
m o
� � 1
i

91
Cp
p
e:5i m z
-5
0
CD W
ILI
Co
C/7
In
CL
D3
CL
Co
10
M a M Q Parcel C
removed from the
amendment]
Exhibit 1

Instrument#953774 f� ,rG�� Order Number: N-50178
02128/2020 08:54:50 AM Page 2 of 2 C Q.+
EXHIBIT"A"
LEGAL DESCRIPTION
A tract of land located in a portion of the Southwest quarter of the Southeast quarter of Section 36,Township"58.North,
Range 1 West, Boise Meridian, Bonner County, Idaho, more particularly described as follows: ..
Beginning at the Northwest corner of said Southwest quarter of the Southeast quarter of Section36;The'ce,South 89'
36'03" East 60.37 feet(record=South 89'37'09" East, 59,55 feet)to the Westerly right of way of B'Orry Drive (shown as
Olympic Drive on the Plat of the Second Addition to Hidden Lakes);thence along said right of*4yr-for the following four
(4) courses;
1. South 27'04'48" East,299.95 feet(record-South 27'06'40" East,300.83 feet); tom(f
2. North 62'55' 12" East, 60.00 feet(record= North 62°53' 20" East, 60.00 feet);
3. North 27°04'48"West, 125.34 feet(record- North 27°06'40" West, 125.34 feet);;`tf� -�
4.Thence on a curve to the right having a central angle of 79°01'27" and a radius of 25.00 feet;,for an arc distance of
34.48 feet(chord=North 12° 25'55" East,31.81 feet-record- North 12*24'03" East;-3181_feet)to a point on the
Southerly right of way of Fairway View Drive,as shown on the Plat of First Additfon`,to Hidden Lakes;
Thence along said right of way for the following eight(8)courses:
1. North 51'56'39" East, 74.67 feet(record-North 51'54'47" East, 74.67 feet);..
2.Thence on a curve to the right having a central angle of 99'26' 33" and'a_radius'of 7P.00 feet,for an arc distance of
121.49 feet(chord-South 78' 20'05" East, 106.81 feet-record=South 7$"-x1'-577"Eait, 106.81 feet);
3.Thence South 28'36'48" East, 154.03 feet(record=South 28°38'4W_!..ast,'154.03 feet);
4.Thence on a curve to the right having a central angle of 55°41' 27"and a radius of 90.00 feet for an arc distance of
87.48 feet(chord=South 00°46' 05" East,84.08 feet-record=South.OW 47 56�' East,84.08 feet);
5.Thence South 27°04' 39"West, 170.14 feet; -
6.Thence on a curve to the left having a central angle of 71'37' 11"and'a radius of 60.0 feet,for an arc distance of
75.00 feet(chord=South 08'43' 57" East, 70.21 feet); 1
7.Thence South 44'32' 32" East,50.94 feet;
8.Thence on a curve to the right having a central angle of-6T- 10',.16"and a radius of 25.00 feet,for an arc distance of
30.18 feet(chord-South 09'57' 24" East, 28.38 feet:-`record=South 11'23'51" East, 30.18 feet)to a point on the West
right of way of Lower Pack River Road;
Thence Southerly along said right of way for the following four,(4)courses:
1 .on a non-tangential curve to the right having a central angle,of 04`15' 19" and a radius of
1180.00 feet for an arc distance of 87.69 feet(chord=South 22°30' 38" West,87.67 feet);
2.Thence South 20'22'44"West, 114.57 feet;'",.,
3.Thence on a curve to the left having a central-angle.of 22°29' 50" and a radius of 502.65 feet,for an arc distance of
197.36 feet(chord=South 09°07'49"West, 196.T0 feel);
4.Thence South 02°07' 06" East, 157.81 feet to tihe,,( ortherly right of way of State Highway No. 200;
Thence along the highway right of inray,_South 7"2''28"West, 72.14 feet(record=South 780 15' 06" West,71.11 feet);
Thence continuing along the Highwayright,of way;South 69°44'57"West, 262.22 feet(record=South 69°43' 16"
West, 261.65 feet)to the West line of the Southwest quarter of the Southeast quarter of said Section 36;
Thence along the West line of the touthwest.,quarter of the Southeast quarter, North 00°08'19" East, 1223.36 feet
(record=North 00°07' 13'..,--East, 1223.17 feet)to the point of beginning.
Exhibit 2

FOY
Instrument#959349
Bonner County, Sandpoint,Idaho
0611912020 08:14:38 AM No. of Pages: 3
Recorded for:NORTH IDAHO TITLE COMPANY.COEUR D'ALENE-R
Micnae1 W.Rosedale Fee:515.00
Ex-Officio Recoroer Deputy cbrannon /
v
InM♦lo.WARRANTY DEW
Escrow No.. N-SI689
WARRANTY DEED
the following described premises, County of Bonner, State of Idaho to-wit:
A tract of land in the East half of the Northeast quarter of the Southwest quarter
and the Northwest quarter of the Southeast quarter of Section 36,Township 58
North, Ranges West of the Boise Meridian, Bonner County, Idaho, more particularly
described as follows.-
}
Beginning at the Southeast comer of'the East haif of the Northeast quarter of the
Southwest quarter of said Section 36;
Thence along the South line of the East half of the Northeast quarter of the
Southwest quarter, North 891136' 27"West, 661.51 feet(record = North 89° 37' 10"
West, 661.57 feet to the Southwest corner of the East half of the Northeast quarter
of the Southwest quarter;
Thence along the West line of the East half of the Northeast quarter of the
Southwest quarter, North 001110'22" East 856.45 feet(record = North 00' 09' 25"
East, 856.45 feet); Thence North 890 10'53"East, 30.21 feet(record = East, 29.58
feet) to the Westerly right of way of Berry Drive (shown as Olympic Drive on the
Second Addition Plat to Hidden Lakes);
Thence Southeasterly along said right of way the following six (6) courses:
1. On a non-tangential curve to the left(radial bearing= North 87039'13" East)
having a central angle of 360 44'06"and a radius of 131.00 feet for an arc distance
of 83.99 feet(record = 84.54 feet) (chord = South 200 42'50" East, 82.56 feet-
record = South 200 37' 27" East,83.08 feet);
2. Thence South 390 04'53" East, 419.67 feet (record = South 390 06'45" East,
��419.68 feet;
j Page i of 3-6/1 6,'2020
m-Wz=dy Dma
Exhibit 3
pg 1 of 2

Instrument#959349
06/19/2020 08:14:38 AM Page 2 of 3
3. Thence on a curve to the left having a central angle of 110 42'45"and-a,itdfns of
530.00 feet:for an arc distance of 108.34 fit(chord = South 440.56',1e'Eai5t,
108.15 feet-record = South 440 58'08" East,108.16 feet);4. Thence South 500 47'39" East,69.68 feet(record = South 5�( �\
49'31"tast, 69.68
feet);
S. Thence on a curve to the right having a central angle of.23°4r51�and a radius
of 970.00 feet;for an arc distance of 401.47 feet(chord `South 3$1D 56'14" East,
398.61 feet-record = South 38" 58'05" East 398.61
6. Thence South 270 04'48" East, 31.65 feet to the South lire of the Northwest
quarter of the Southeast quarter(record = South 270 Ots'_4p';East, 30.77 feet);
Thence leaving said right of way North 890 36'03"We4-41i6 37 feet(record = North
890 37'09"West,59.55 feet) to the point of beginnings
i
r
Page 2 of3-6116=0
Exhibit 3
pg2of2

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 28th DAY OF JANUARY 2025,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF , 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: dick(a),villellipnw.com
f
PATRICIA JORDAf4, SECRETARY
CERTIFICATE OF SERVICE