20240202VPI to Staff 1-2.pdf

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 BL VD, BLDG 8, SUITE 201-A
BOISE, ID 83 714
Atorney 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 U�li�es Commission, by and through its atorney ofrecord,
Adam Triplet, Deputy Atorney General, requests that VP, Inc. ("VP" or the "Company")
provide the following documents and informa�on as soon as possible, but no later than
THURSDAY, FEBRUARY 15, 2024 1
.
This Produc�on Request is to be considered as con�nuing, and the Company is requested
to provide, by way of supplementary responses, addi�onal documents that it, or any person
ac�ng on its behalf, may later obtain that will augment the documents or informa�on
produced.
Please provide answers to each ques�on, suppor�ng workpapers that provide detail or are
the source of informa�on used in calcula�ons, and the name, job �tle, and telephone number
of
1 Staff is reques�ng an expedited response. If responding by this date will be problema�c, please call Staff's
atorney at [phone].
FIRST PRODUCTION REQUEST
TO VP,INC. 1 FEBRUARY 1, 2024
the person preparing the documents. Please also iden�fy the name, job �tle, loca�on, and
telephone number of the record holder.
In addi�on to the writen 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 reques�ng mul�ple 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? We were informed previously that the
PUC would be determining the rates we could charge. Based on that we did not request rate
changes. WE don’t believe having different rates to respect original users and being considerate
of their circumstance to be discrimina�ng. That being said we would like to stabilize our rates in
order to proceed with water service that is provided at a fair rate that will allow My wife and I,
in that it is our company, to expect a return of some kind. A�er the state of Idaho decided to
take our infrastructure that we paid more than a million dollars for and leave us with less than
one fi�h of our improvements we would like to request a fair service fee to provide some
income. If yes, what rate(s) is the Company
intending to charge? We feel that a new rate of $55 dollars per service customer would at the
minimum allow us to proceed with opera�ng although not return any reasonable return on our
investment. If not, please explain.
REQUEST NO. 2: Does the Company charge a customer if there is no service
connec�on or owns an empty lot? Yes.
DATED at Boise, Idaho, this 1st day of February 2024.
l:\U�lity\UMlSa!'RDREQ\VPI-W-24-01 PR# 1 docx FIRST PRODUCTION REQUEST
TOVP,INC. 2
Adam Triplet
Deputy Atorney 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