20230410Staff 10-24 to VP Inc.pdf

RILEY NEWTON CU
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION *O 00
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-17-01UTILITYSUBJECTTOREGULATIONBY)THE IDAHO PUBLIC UTILITIES )COMMISSION )SECOND 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 AttorneyGeneral,requests that VP,Incorporated ("Company"or "VP,
Inc.")provide the followingdocuments and information as soon as possible,but no later than
MONDAY,MAY 1,2023.
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 informationused 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.
SECOND PRODUCTION REQUEST
TO VP,INCORPORATED 1 APRIL 10,2023
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.10:Please provide an up-to-date geo-spatial system map showing the
location and elevation of major equipment including wells,distribution piping,storage tanks,
booster pumps,shut-off valves,meters,fire hydrants,and water treatment equipment.Please
include the followinginformation:
a.The make,model,and rating of each well pump;
b.The make,model,and rating of each well pump motor;
c.The make,model,capacity,and limit switch settings of each pressurized storage
tank;
d.The make,model,capacity,and limit switch settings of each unpressurized
storage tank/reservoir;
e.The make,model,and rating of each booster pump and motor;
f.The make,model,and capacity of all water treatment equipment;
g.The year,make,model,and capacity for backup generation supporting the well
pumps.Indicate if the generationhas an Automatic Transfer Switch (ATS)or if it
must be manually started;and
h.The distribution piping line size and materials specified in the installation.
NOTE:Please provide this map in an electronic format which can be enlarged to identify all
aspects of the system.
REQUESTNO.11:Please provide a thorough and complete description of the water
system(s).This should include any known deficiencies that need to be addressed to maintain
system integrity and to support growth,as well as any changes/investments that the Company
plans to implement to address deficiencies relative to items included below.In the response,
please include the amount of costs and benefits for any investments or increases in expense.
a.Processes and methods.This should include processes involved in the deliveryof
water and business processes (i.e.billing,maintenance,customer support,etc.);
b.Manpower/staffmg,including the amount of labor and the level of
expertise/experience;
SECOND PRODUCTION REQUEST
TO VP,INCORPORATED 2 APRIL 10,2023
c.Equipment/infrastructure/software both direct (i.e.pipes,tanks,and pumps)and
indirect (maintenance equipment,computers,etc.);
d.Policies and standards (i.e.service level,maintenance turnaround time,etc.);and
e.Materials (productive material used for water quality,spare parts inventory,etc.)
REQUESTNO.12:If the system includes fire protection,please provide the following:
a.The name and contact information for the fire authority who prescribes
requirement for the system;and
b.Fire flow and storage requirements prescribed by the fire authority.
REQUESTNO.13:Please provide the specified installation and material requirements
detailing the construction and installation of the wells,pumping,storage,and distribution system.
REQUESTNO.14:Please provide all information related to the capacity and sizing of
the system and the ability of the system to meet historical and future system peak demand.
Information would include not only capacity/constraints of/in the system,but also consumption
and consumption at peak periods.
REQUESTNO.15:Please provide the most recent Idaho Department of Environmental
Quality(DEQ)Sanitary Survey for the system.
REQUESTNO.16:For each water right in the system,please provide the Idaho
Department of Water Resources (IDWR)Water Right Numbers (basin and sequence number).
REQUESTNO.17:For each well in the water system,please provide the following:
a.The IDWR Well Tag Number (D-Tag Number)currentlyon-file with IDWR;
b.Location (Township,Range,Section,and Tract);and
c.The well log.
SECOND PRODUCTION REQUEST
TO VP,INCORPORATED 3 APRIL 10,2023
REQUESTNO.18:Please provide an estimate of total unaccounted water losses due to
leaks,wasted water,etc.by month over the past 5 years.Please explain how these losses are
estimated.
REQUESTNO.19:Please provide the power bills over the past five years indicating
the amount of electricity(kilowatt-hours)used by each well and booster pump.
REQUESTNO.20:Please provide the monthlymetered amount of water produced by
each well over the past five years.
REQUESTNO.21:Please provide a map that outlines all water utility systems
operated by VP,Inc.in the State of Idaho.NOTE:Please provide this map in an electronic "pdf'
format which can be scaled and enlarged to identify details for each system.
REQUESTNO.22:Please provide details of all DEQ and IDWR compliance
discrepancies resolved since 2017.
REQUESTNO.23:Please provide a schedule of the rates charged to the customers.
REQUESTNO.24:Please provide a set of annual financial statements for the water
company for the last three years (2020,2021,and 2022).These could be actual income
statement and balance sheets like ones created from QuickBooks (or other bookkeeping
software),or income tax filings for the company if actual financial statements are available.
DATED at Boise,Idaho,this (O day of April 2023.
Riley Newton
Deputy AttorneyGeneral
i:umisc:prodreq/gnrwl7.linjt prod req 2
SECOND PRODUCTION REQUEST
TO VP,INCORPORATED 4 APRIL 10,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 10th DAY OF APRIL 2023,
SERVED THE FOREGOING SECOND PRODUCTION REQUESTOF THECOMMISSIONSTAFFTOVP,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 jvwlaw.net
E-MAIL:[e-mail]
SECREVARY
CERTIFICATE OF SERVICE