20230316Staff to VP Inc 1-9.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11202
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE INVESTIGATION )INTO WHETHER VP,INC.IS A PUBLIC )CASE NO.GNR-W-17-01
UTILITY SUBJECT TO REGULATION BY )THE IDAHO PUBLIC UTILITIES )
COMMISSION )FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO VP,INCORPORATED
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Riley Newton,Deputy Attorney General,requests that VP,Incorporated ("Company"or "VP,
Inc.")provide the followingdocuments and information as soon as possible,but no later than
THURSDAY,APRIL 6,2023.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 workpapersthat provide detail or are
the source of information used in calculations,and the name,job title,and telephonenumber 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,INCORPORATED 1 MARCH 16,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUESTNO.1:Does VP,Inc.("the Company")or any other entity associated with
VP,Inc.,currentlyown and operate a water system that provides water to customers?
REQUESTNO.2:Please provide a legal description of the territory in which VP Inc.
operates and provides potable drinking water.
REQUESTNO.3:Is the Company's system currentlyinterconnected with any other
water or sewer system?If yes,please describe the interconnection and ownership of the
system(s)the Company's system is interconnectedwith.Please provide any applicable
agreements or contracts.
REQUESTNO.4:Has the Company's system been interconnected with any other
water or sewer system?If yes,please describe the interconnection and ownership of the
system(s)the Company's system was connected to and when physical separation of the
system(s)was completed?Provide any applicable agreements or contracts.
REQUESTNO.5:Please indicate whether any private water,co-operative,municipal
or Commission regulated water utility customer service territories overlap VP Inc's customer
service territory.If so,please identify all those that overlap,how they overlap,and explain any
effect from the overlapping of territories,such as disputes that may occur or current agreements
for keeping them separated.
REQUESTNO.6:Is VP,Inc.,or any of its associated entities,involved in current,
pending,or resolved litigation outside of the Bonner County cases (and the related appeals)
Genesis GolfBuilders,Inc vs.Pend Oreille Bonner Development,LLC,et.al.,CV-2009-1810
and VP,Incorporated,vs.TIC Property Management,LLC,CV09-20-1602.If so,please state
the Case No.,County,and date filed.
FIRST PRODUCTION REQUEST
TO VP,INCORPORATED 2 MARCH 16,2023
REQUESTNO.7:Please provide a copy of articles of incorporation and bylaws for
VP,Inc.and any of its associated entities.
REQUESTNO.8:Is the Company currentlyin compliance with all Idaho Department
of Environmental Quality("IDEQ")and Idaho Department of Water Resources ("IDWR")
requirements and regulations?If not,please describe all noncompliance issues and resolution
plans.
REQUESTNO.9:Please provide details of all IDEQ and IDWR compliance
discrepancies resolved since 2017.
DATED at Boise,Idaho,this 1 day of March 2023.
Riley Newton
Deputy Attorney General
i:umise:prodreq/gnrwl7.lrnjt prod req l
FIRST PRODUCTION REQUEST
TO VP,INCORPORATED 3 MARCH 16,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 16th DAY OF MARCH 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUESTOF THE
COMMISSION STAFF TO VP,INCORPORATED,IN CASE NO.GNR-W-17-01,
BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
RICHARD A VILLELLI SUSAN WEEKS
VP INCORPORATED 1626 LINCOLN WAY
PO BOX 1785 COEUR D'ALENE ID 38314
SANDPOINT ID 83864-0903 E-MAIL:sweeks ivwlaw.net
E-MAIL:[e-mail]
SÈCRETARY
CERTIFICATE OF SERVICE