20240201Staff 1-2 to VPI.pdf

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 BL VD, BLDG 8, SUITE 201-A BOISE, ID 83 714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF VP, INC., FOR A CERTIFICATE OF PUBLIC CONVENIENCE AND NECESSITY
) ) CASE NO. VPI-W-24-01
) ) FIRST PRODUCTION ) REQUEST OF THE
) COMMISSION STAFF ) TO VP, INC.
) ___________________)
Staff of the Idaho Public Utilities Commission, by and through its attorney ofrecord,
Adam Triplett, Deputy Attorney General, requests that VP, Inc. ("VP" or the "Company")
provide the following documents and information as soon as possible, but no later than
THURSDAY, FEBRUARY 15, 20241 .
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 1 Staff is requesting an expedited response. If responding by this date will be problematic, please call Staff's attorney at [phone]. FIRST PRODUCTION REQUEST
TO VP,INC. 1 FEBRUARY 1, 2024
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
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: VP, Inc. ("Company") is requesting multiple rates for the same
customer class based on when each customer established service. This appears to discriminate
between customers in a class and does not comply with Idaho law. See Idaho Code § 61-315.
Does the Company intend to adjust rates in this filing? If yes, what rate(s) is the Company
intending to charge? If not, please explain.
REQUEST NO. 2: Does the Company charge a customer ifthere is no service
connection or owns an empty lot?
DATED at Boise, Idaho, this 1st day of February 2024.
l:\Utility\UMlSa!'RDREQ\VPI-W-24-01 PR# 1 docx
FIRST PRODUCTION REQUEST
TOVP,INC. 2
Adam Triplett Deputy Attorney General
FEBRUARY 1, 2024
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 1 sT DAY OF FEBRUARY2024,
SERVED THE FOREGOING FIRST 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 VP, INC. PO BOX 1785 SANDPOINT, ID 83864-0903
E-MAIL: [e-mail]
SECRETA
CERTIFICATE OF SERVICE