20190611Comments.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
RECEIVED
;019 JUI{ I I ill l0: 59
rDl,il0 puBLlc
;t'-itt;:i c0MMl$sloN
Street Address for Express Mail:
4]2 W. WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
SPIRIT LAKE EAST WATER COMPANY AND
LYNNWOOD FOR AMENDMENT AND
TRANSFER OF CPCN
CASE NO. SPL-W.19.01
COMMENTS OF THE
COMMISSION STAFF
STAFF OF the Idaho Public Utilities Commission, by and through its Attorney of
record, Edward Jewell, Deputy Attorney General, submits the following comments.
BACKGROUND
On February 15,2019, Gem State Water Company, LLC ("Gem State Water"; or
"Company") filed an Application with the Commission requesting approval of Gem State
Water's acquisition of Spirit Lake East Water Company ("Spirit Lake"), Lynnwood Water, and
Water Works Management LLC ("Water Works"), and approval to amend Spirit Lake's
certificate of public convenience and necessity ("CPCN") to incorporate the customers currently
served by Lynnwood Water and transfer the amended CPCN to Gem State Water (collectively,
"Application").
Gem State Water is an Idaho limited liability company created to own and operate water
utilities in Idaho. Gem State Water, through its parent companies, is owned by Northwest
Natural Holding Company.
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1STAFF COMMENTS JLINE II,2OI9
Spirit Lake is a regulated water utility that serves approximately 315 customers in north
Idaho. Lynnwood Water serves approximately 18 customers. Water Works is a non-regulated
entity that holds certain water systems management contracts.
STAFF ANALYSIS
Staff recommends that the Commission approve the proposed Gem State Water
acquisition of Spirit Lake and Lynnwood Water. Staff s recommendation is based on its review
of Gem State Water's Application, the direct testimony and exhibits of Justin Palfreyman,
President of Gem State Water, and Gem State Water's responses to Staff s production requests.
Idaho law does not specifically address the acquisition of water companies. As it has
done in previous water company acquisition cases, Staff relied on the standards outlined in Idaho
Code $ 6l-328 related to the sale of electric utilities. Those standards dictate that:
a) The transaction is consistent with the public interest;
b) The cost of and rates for supplying service will not be increased by reason of such
transaction; and
c) The applicant for such acquisition or transfer has the bona fide intent and
financial ability to operate and maintain the system in the public service.
Staff believes that the proposed acquisition by Gem State Water meets all three standards.
Public Interest
Staff believes this acquisition is in the public interest for two primary reasons. First,
Gem State Water provides improved access to capital, potentially at lower cost, for infrastructure
improvements, which will be discussed in more detail below, under Operation and Financial
Ability. Second, ownership by Gem State Water may provide benefits through operational
efficiencies and economies of scale as it acquires more water systems. Improved access to
capital and scale economies help reduce the cost of providing service from where it would be
otherwise and may mitigate rate increases over time.
Due to planned acquisitions of other water companies in the region, Gem State Water
believes there may be operational efficiencies and opportunities for sharing overhead costs.
Response to Production Request No. 14. (See Attachment A). Examples of shared overhead
costs are certain legal and engineering costs. Engineering costs per customer and labor costs per
2STAFF COMMENTS JI.INE II,2079
customer will decrease if a fixed cost is spread over more water systems and customers.
Likewise, operational economies of scale are created by spreading downstream labor costs (e.g.,
wages and benefits of a skilled field technician) or capital equipment costs (e.g., cost of a new
backhoe) over more systems and customers, by getting quantity discounts for material and
supply purchases, orby realizing efficiencies through jointly operating nearby systems. In the
case of Spirit Lake and Lynnwood Water, Staff expects any savings to be relatively small.
Staff believes operational efficiencies and opportunities for sharing overhead costs are
possible, but limited, until Gem State Water can acquire more water systems sufficiently close in
proximity to operate in conjunction with each other. Staff notes that Gem States Water is
actively seeking to expand its operations in Idaho. Gem State Water and associated
companies have shown commitment to their growth plan through the acquisition of Falls Water
(FLS-W-18-01), the submission of this Application, and the application for the acquisition of
Diamond Bar Estates, L.L.C. and Bar Circle "S" 'Water, Inc. (BCS-W-19-01/DIA-W-19-01).
Rates
No Increase in Cost and Rates
Gem State Water states it will maintain the existing rates and charges. Application at 4.
Palfreyman at Direct at 6-1. The Company also states the transaction expenses related to the
acquisition will be paid by Gem State Water's parent company and will not be recovered from
ratepayers. Response to Production Request No. 8.
While future system improvements may justify higher rates, those improvements are
independent of the acquisition and would be necessary regardless of whether the systems are
acquired by Gem State Water or continue as stand-alone systems. Staff believes the acquisition
will not increase the cost to operate, maintain, and expand the systems because they will function
post-acquisition much the same as they have pre-acquisition. In the event that Gem State Water
successfully expands its operations in the vicinity of Spirit Lake and Lynnwood Water,
additional cost savings related to operational efficiencies and shared overhead may be realized in
the future.
aJSTAFF COMMENTS JUNE II,2OI9
Operational and Financial Ability
Ms. Leslie Rayner currently owns the assets of Lynnwood Water and is the sole
shareholder of Spirit Lake. Ms. Rayner and Mr. Cole Rayner, who is also employed by Spirit
Lake and Lynnwood Water, are both licensed water system operators. Pursuant to the terms of
the Purchase Agreement, Ms. Rayner and Mr. Rayner will be offered employment by NW
Natural Water of Idaho for a period of at least 36 months following Commission approval of the
Application, and their acceptance of this employment offer is a condition of the closing of the
Purchase Agreement. Gem State Water conhrmed in the Application that it intends to retain the
existing management and other employees of Spirit Lake and Lynnwood Water to maintain the
existing level of services, leverage their expertise, and prevent disruption to customers.
Application at 3. This helps demonstrate that Gem State Water has a bona fide intent to operate
and maintain the system in the public service. Purchase Agreement atl4.7. Staff agrees that
retaining the existing employees will help maintain the current level of service and is consistent
with the public interest.
Water systems routinely require repair, replacement and extension of infrastructure to
provide reliable and ample water service to customers. Financing this infrastructure at a
reasonable cost is a challenge for smaller water systems. Northwest Natural Holding Company
(NW Natural Holdings), a parent company of Gem State Water, has revolving credit facilities
totaling approximately $400 million. Palfreyman Direct at 3. Through its parent company, Gem
State Water has access to these financial resources and therefore is better positioned than Spirit
Lake or Lynnwood Water to adequately fund system upgrades in a timely manner at a
competitive cost. NW Natural Holdings' ability to access capital markets stems from it being a
publicly-traded company with strong credit ratings from two major credit rating agencies. It
received investment-grade ratings of "Al " from Moody's, and "AA-" from Standard and Poor's
in 2018. Lower financing rates help control costs that ultimately are passed on to customers.
4STAFF COMMENTS JUNE II,2O19
LYNNWOOD WATER
Lynnwood Water is a system that was not regulated by the Commission, and therefore
Lynnwood's rate have not been approved previously by the Commission. Staff s analysis of
Lynnwood Water's rates is below.
Basic Service Charges and Usage Rates
Staff supports maintaining the current basic service charges and usage charges, including
the rate structures for customers of Spirit Lake and Lynnwood Water, consistent with Gem State
Water's request in the Application. Spirit Lake rates were approved by this Commission in its
last general rate case. Lynnwood Water rates were in place prior to the system being acquired by
Ms. Leslie Rayner, its current owner, in April 2015. Lynnwood Water rates have not been
approved by the Commission; however, an abbreviated audit performed for this proceeding
indicates that the Company is not overearning.
Gem State Water indicated that it will work toward consolidating the rates between Spirit
Lake and Lynnwood Water in the future, but has not asked for consolidated rates at this time.
Staff believes this is a reasonable and prudent approach for base rates. Lynnwood Water has
only eighteen customers. Typically, separate rates are not feasible for such a small group of
customers because there are too few customers over which to spread the administrative costs of
managing a separate rate structure. However, any consideration of rate consolidation should be
deferred to the Company's next general rate case. Also, moving Lynnwood customers to the
rates of the larger Spirit Lake system would result in an average rate increase of approximately
9%. Such an increase cannot be supported outside of a rate case.
5STAFF COMMENTS JUNE II,2OI9
Non-Recuruing Charges
Gem State Water submitted the fee schedule for non-recurring charges for Lynnwood
Water. In its Production Responses, the Company provided additional explanation of the
charges and stated that the charges were in effect when Leslie Rayner originally purchased the
system. (See Attachment B).
The Company's Account Change (Account Transfer Fee) of $35.00 is charged when a
new customer takes service, and is similar to an Account Initiation Fee approved by the
Commission in Order No. 32958 for Troy Hoffman Water in20l4 (TRH-W-I3-01). Staff does
not object to the idea of an account initiation fee if the Company can justify the charge; however,
since Spirit Lake East does not currently have such a fee, and no justification has been presented,
Staff recommends denial of the fee for Lynnwood Water.
The Meter Set is applicable for a new connection within Lynnwood Water's service area
and is the same in nature as Spirit Lake's Hook-up Fee. According to the Company's Production
Response, the fee of $4,500 is based on an estimate and is a caffyover from the previous owner.
The Company provided the cost detail of a new connection completed in2018, which was almost
the same as the Meter Set charge. However, with only one Meter Set charge collected since the
Company took over Lynnwood Water, it's not clear if the cost detail provided is appropriate cost
justification for future connections. (See Attachment C). Staff recommends the Meter Set
charge be denied and Spirit Lake's previously approved Hook-Up Fee of $2,500 be
implemented, subject to further review in a future case.
Lynnwood Water currently charges a Turn On Fee of $95.00 to reconnect service
whether the account was disconnected for non-payment or at the customer's request. The
company states that the $95.00 is based on actual time and travel distance. Spirit Lake's
Reconnection Fees as approved by the Commission in Order No. 32904, (SPL-W-09-01) are set
at $16.00 if reconnected during normal business hours and $32.00 if reconnected after business
hours for an account closed for thirty days or less. For accounts closed more than thirty days, the
Commission approved a $52.00 charge if reconnected during normal business hours and $65.00
if reconnected after normal business hours. Reconnection charges previously approved by the
Commission are designed to cover only a portion of the cost of the reconnection. Because both
companies are in the same approximate area, Staff believes the Spirit Lake East charges are
appropriate for Lynnwood Water. Staff recommends the Reconnection Fees approved for Spirit
Lake also be approved for Lynnwood Water.
The Bounce Check Charge QrISF Fee) of $35.00 for Lynnwood Water is higher than
allowed by statute. Idaho Code $ 28-22-105. Staff recommends the fee be reduced to $20.00,
the maximum amount allowed under statute.
With respect to the lYo frnance charge for unpaid balance on the Lynnwood Estates
schedule, Staff finds the charge to be consistent with that approved by the Commission for other
utility companies. In review of Spirit Lake's scheduled non-recurring charges, Staff discovered
that its Late Payment Charge incorrectly states that it applies to the unpaid balance after the due
STAFF COMMENTS JUNE II,2OI96
date. This is inconsistent with the policy approved for other utility companies wherein a late
payment charge is applied to the unpaid balance owed at the time of the next billing statement.
Staff notes that in Spirit Lake's Rules and Regulation section of its Tariff, it states that the Late
Payment Charge is consistent with the policy approved for other utility companies. Staff
recommends that the Commission approve a Late Payment Charge to lYo of the unpaid balance
owing at the time of the next billing statement for both Spirit Lake and Lynnwood Water.
CUSTOMER NOTIFICATION AND PRESS RELEASE
The Commission's Rules of Procedure, IDAPA 31.01.01, et. seq., do not require
customer notification unless the company is requesting a rate increase. Commission Rule 125.
Gem State Water published a notice to customers on April 5,2019, in the CDA Press (Coeur
d'Alene). It also issued a press release dated March, 22,2019. The Commission published a
press release March 9,2019.
As of June 6,2019, one customer comment has been received. The customer does not
expressly object to the sale. However, she is concerned about whether the Company plans "to
sell our water outside the subdivision" and the acquisition's impact on future rates.
The Company has stated that if the Commission approves the sale it will notify customers
in a press release in the CDA Press. Instead of a press release, Staff recommends Gem State
Water provide written notice of the sale of the companies directly to the customers, either
through a separate mailing or as an insert in the customer billing statement.
COMPANY TARIFF AND RULES AND REGULATIONS
The Company's Tariff, including its Rules and Regulations, will need to be updated to
reflect the change in ownership and the recurring and non-recurring rate schedules approved by
the Commission in this case. Staff is willing to work with Gem State Water to ensure its Tariff
properly reflects the latest rules and regulations, as well as the approved rates and charges. Staff
recommends the Company submit its revised Recurring and Non-Recurring Rate Schedules prior
to the effective date. Staff recommends the Company submit any necessary revisions to the
Rules and Regulations section of its Tariff for final approval within three months of issuance of
the final order in this case.
7STAFF COMMENTS JLINE 11,2019
COMPANY DOCUMENTATION
The Company will need to update customer documents to reflect any changes brought
about by the sale of the Company. Staff is willing to work with the Company to update its
billing and collection documents as well as its Explanation of Rates and Rules Summary. Staff
recommends the Company work with Staff to make any necessary revisions within three months
of issuance of the final order in this case.
STAFF RECOMMENDATION
Staff recommends the Commission:
. Approve the sale of Spirit Lake East to Gem State Water.
o Amend Spirit Lake East's CPCN No. 293 to include Lynnwood Water.
o With respect to the Non-Recurring charges:
o Deny the proposed Account Change Fee for Lynnwood Water.
o Deny Lynnwood Water's proposed Meter Set Fee for Lynnwood Water and
approve Spirit Lake's Hook-up Fee of $2,500 for Lynnwood Water.
o Deny Lynnwood Water's proposed Turn On Fee for Lynnwood Water and
approve Spirit Lake's Reconnection Fees for Lynnwood Water.
o Deny Lynnwood Water's proposed Bounce Check Fee and approve the
Insufficient Funds Charge at the statutory limit of $20.00 for Lynnwood Water.
o Deny Lynnwood Water's proposed Finance Charge and approve a Late Payment
Fee of l% of the unpaid balance owed at the time of the next billing.
o Revise the Late Payment Fee description in Spirit Lake's Tariff to clarify when it
will apply.
o Order Gem State Water to notify the customers directly of the sale of the Company to
Gem State Water, either through a separate mailing or as a billing insert.
o Order Gem State Water to file updated Tariff rate schedules consistent with the
Commission's decision prior to the effective date.
. Order Gem State Water to work with Staff to revise the Company's Tariff, including its
Rules and Regulations.
o Order Gem State Water to work with Staff to revise the billing and collection documents
and the Explanation of Rates and Rules Summary.
STAFF COMMENTS JUNE 11,20198
Respectfully submitted this llt{,^rt day ofJune 2019
Edward
Deputy General
Technical Staff: Joseph Terry
Michael Eldred
Bentley Erdwurm
Chris Hecht
Johan Kalala-Kasanda
i : umisc/comments/splw I 9. I ejjtcwhbejkme comments
9STAFF COMMENTS JUNE II,2OI9
Gem Stqteratfn*
SPL-W-19-01
Spirit Lake and Lynnwood Acquisition
Data Request Response
DR Request: March 20,2019
Date of Response: April 10, 2019
Responder: Nicholas Whitley
Telephone: [phone] ext. 4804Email: [e-mail]
Witness: Justin Palfreyman
Request No.: SPL-W-19-01 IPUC DR 14
14. Please identify any expected operational efficiencies or opportunities for sharing
overhead costs attributable to expanding the number of water utilities owned directly or
indirectly by Northwest Natural in Oregon, Washington and ldaho. Please explain
whether and how Spirit Lake East and Lynnwood Water customers will share in these
benefits.
Resnoqsel
Over time, as strategic acquisitions continue to be made in Oregon, Washington, ldaho
and possibly other jurisdictions, there could be operational efficiencies or opportunities
for sharing overhead costs. To the extent that Gem State Water and its parent
companies can achieve operational efficiencies or opportunities for sharing overhead
costs, Spirit Lake East and Lynnwood customers would benefit from such efficiencies or
opportunities, as would any other entity that shares in such efforts. Gem State Water
currently has not quantified benefits associated with operational efficiencies or
opportunities for sharing overhead costs as the magnitude of such benefits will depend
on our ability to successfully execute our growth strategy and other factors.
SPL-W,19.01 IPUC DR 14
NWN Response
Page 1 of 1
*
Attachment A
Case No. SPL-W-19-01
Staff Comments
06ltUt9
Gem Stoterl?tl"
SPL-W-19-01
Spirit Lake and Lynnwood Acquisition
Data Rpquest Response
DR Request: March 20,2019
Date of Response: April 10, 2019
Responder: Leslie Rayner
Telephone: [phone]Email: [e-mail]
Witness: Leslie Rayner
Reouest No,: SPL-W-19-01 IPUC DR 1
1. Mr. Palfreyman's testimony includes an itemization of charges that currently apply to
Lynnwood Water customers. See Exhibit 2, Attachment 2, Lynnwood Water Price List.
Please describe more fully the circumstances under which each fee applies:
a) Account Change (Account Transfer Fee)
b) lvleter Set
c) Turn On Fee
d) Bounce Check Charge (NSF Fee)
e) Fin Chg (Finance Charges on Overdue Balance)
*
$ 35.00
$4,500.00$ ss.00$ 35.00
lolo
Response:
a) Account Change (Account Transfer Fee)$ 35.00
This fee ls charged when a property changes responsible parties; that is, administrative
time and resources are needed when one account is closed and a new account is
initiated. This situation typically occursi in response to a property sale or a change in
renter. This fee is not charged when an account is arnended for the cunent account
owner, such as name change or billing address change. This fee is a carry-over frCIm
prior ownership of Lynnwood Water.
b) Meter Set $4,500.00
This fee is applicable for a new connection within Lynwood Water's seryice tenitory that
requires a service connection. This fee is based on estimates received from excavation
contractors for the price to install the service connection. This fee is a carry-over from
prior ownership of Lynnwood Water.
c) Tum on Fee
SPL-W-19-01 |PUC DR 1
NWN Response
Page 1 o'f 2 Attachment B
Case No. SPL-W-19-01
Staff Comments
06lllllg Page 1 of 2
$ s5.00
This charge is applied at the time that Lynnwood Water terminates water service due to
nonpayment or vacancy. The $95 amount reflects the actual cost to travel to the
system and perform the meter turn on: one-hour round trip - $35.00, 44 miles =
$25.00, and time on site = $35,00. This fee is a carry-over from prior ownership of
Lynnwood Water.
d) Bounce Check Charge (NSF Fee)$ 35.00
lf Lynnwood Water receives a NSF check, the customer is passed along this charge
that the financial institution charges the Company for processing. This set bank fee is a
carry-over from prior ownership of Lynnwood Water.
e) Fin Chg (Finance Charges on Overdue Balance)1o/o
Consistent with industry standard, Lynnwood Water applies a 1o/o par month finance
charge on unpaid balances after the due date. This fee is a carry-over from prior
ownership of Lynnwood Water.
SPL.W-19-01 IPUC DR 1
NWN Response
Page 2 of 2
Attachment B
Case No. SPL-W-19-01
staff comments
06111119 Page2 of 2
Gem Stote
rr lTf i*
SPL-W-19-01
Spirit Lake and Lynnwood Acquisition
DS"ta Reouest Fesponse
DR Request: April 25, 2019
Date ofResponse: May 16,2019
Responder: Leslie Rayner
Telephone: [phone]
Email: [e-mail]:l
Wtness: Leslie Rayner
Request No.: SPL-W-19-01 IPUC DR 19
19. Following up on Production Reguest No. 6, there appears to be a new customer
connection in 2018. Please provide an itemized list of costs with a description of each
item required to connect the customer. Please include all costs related to labor,
machinery rental, equipment costs, meter set materials, etc.
Response:
Please see the following itemized list of costs
1, See meter material quote - BID # S9251593 (May 2019 price Quote) =
$2,573.23 (see SPL-W-19-01 IPUC DR l9Attachment 1)
2. Equipment Rental Backhoe - H&E Equipment Rental = $623/day
Pick-up and Delivery = $300
3. Fuel- Estimated/ Diesel Fuel = $40.00
Estimated/ Gas Fuel = $20.00
4. Whacker Rental United Rental = $109/day
5. Day Labor - $25lhr. x 10 hrs = $250.00
6. Equipment Operator - $45/hr. x 10 hrs = $450.00
7. Office Staff - Call in locates, process new customer paperwork, coordinate
installation, etc - $16.50/hr. x 2 hours = $33.00
8. Operator site visit with customer pre-construction meeting - $25lhr. x 3 hrs. =
$75.00
Total: $4,472.23
SPL-W-19.01 IPUC DR 19
Gem State Response
Page 1 of I
.,.4;. ?
Attachment C
Case No. SPL-W-19-01
Staff Comments
06111ll9 Page 1 of 4
** Quotation **
-send l',/o 'lo:
CONSOLIDATED SUPPLY CO -
]-55 EAST DALTON AVE
DAITON GARDENS, ID 838].5
**rr^n**aia.tn**
Bid To:
CDA Phone # l 2o8-162-2558
Ship Tor
SPIRTT U\KE EAST WATER COMPANY
PO BOX 3388
COEUR D ALEISE, ID 83816
JOB: Spirit Lake East
alespers Ship Via
WCN WC NOW
** rr n nL-.V.U
SPIRTT I,AKE EAST WATER COMPANY
PO BOX 3388
COEUR D ALENE, TD 83816
Phone # : [phone]'7
Bid-nate-os/os/re r-DaEe-writ.e
Bid #:Page S:
s9251_593
1
ConsolHated
Supply Co.
Expa6/07 /L9 Corina Beyer CDA HOUSE WW CDA
QuanLiEy Description UniE Price ExU Price
l-ea
lea
lea
100,
1rI
l-ea
1ea
lea
lea
].ea
1ea
1ea
ROMAC 2025-6. 90X1" IPr 6 '!X1( DBL
SS STRAP SADDLE 6 .63 -6 .90
AY NL 74'.tO4B-3Q 1il SAr,l MrP X rPS
COMPRESSTON CORP STOP AY NL
MCDONALD 5L82_2406136 I'l SS IPS STTFFmIER Ay
MCDONALD 4130-765 (SAME AS 6t-337
L-L/4" CTS 4L3o-761)
l-'rx100' SIDR-? IPS 250 PSI PE4710
BLACK POLY TUBTNG
L2/LX5O0' BLUE UF TRACER WrRE
54502-05*06
2''X1OOO' BLUE DE?ECTABLE TAPE
I.IATER LINE BELOW
6].36 1'I SS IPS STTFFM{ER AY
MCDONALD 4130-765 (SAME AS 61337L-1/4', CTS 4130-761)
AY NL 76L02-3Q L" CURB BA],L IIALVEIPS COMP X FIP MCDONALD
5]-82-227
95.E C] CURB BOX COMPLETE
41" -64 " OLYMPIC L3-517 oWSET(Ty1er 11L9ss)L"X24" GAL STEEL NIPPLEAy NL '720-436WCDD l-"X36" 44 METER
SETTER 1I' A}INiT X 1T SINGLE AMC AY
MCDONALD FTP X FTP ( CDA/NKWD SPEC
I 5l.s2-Ll7
HERSEY 452TTS ].' CU FT LOW LEAD PD
METER STANDARD VISUAL READ NSF.61
ANNEX G COMPLIANT VOKS].o].
B37H 5' CONCRETE STANDARD METER SET
W/ HINGE LID
87 -528ea
9l- .533ea
2 .334ea
o.544ft
94 .7 S:-.r:--
28. 938EA
2 - 334ea
l-21 .989ea
47.234ea
15 .4 93EA
422.844ea
87. s3
91.53
2.33
64.40
94.78
28 -94
2.33
l.z]- .99
47 .23
l-5 .4 I
422.80
222.685ea 222.69
199.851ea 199.85
ConEinued on NexE Page 't**
SPL.W.I9.OI IPUC DR 19
Gem Statc Response
Attachment I
Attachment C
Case No. SPL-W-19-01
Staff Comments
06/ll/19 Page2 of4
lea
f**
** Quotation **
Bid #:Page $:
s 9251593
2
SPTRIT LAKE EAST WATER COMPANY
QuanEity DescripEion Unit Price Ext Pri-ce
Lea
l-ea
l-ea
Lea
1ea
**rl***r.**** Kit COmpOnentS ***,trk******* 1 - BROOKS 37 7.2N CONC METER BOX T ** sEc?roN (No Kl{ocKouTs) ** L2rrx2otf x12 il ** Loc: YA05 -27 -lA Pn: 158307 *
* 1 - BROOKS 37-H CONCRETE COVER W/ *
* cr HINGED LID LL-l/ 4 "X18 -1/8 " )k* Loc: YA05-29-LB Pn: 1551? *
* 1 . BROOKS 37 A2I CONC METER BOX B *
* SECTION (W]TH KNOCKOUTS) *
* L2"X2O"XL2[ *
* Loc: YA05-23*I-A Pn: L58L62 ** 3 - BROOKS 37 A2N CONC METER BOX M ** SECTTON (NO KI{OCKOUTS ) *
* lztrX?Onx!2tt ** Loc: YA05-25-LA Pn: f 58268 rt
* !f * * :k * r( * rt * * * * r( !k * tt * * rr * Jr * * * * * r( r( :t r( )k r( * * * * rk
].'IX36II GAT. STEEL NIPPLE
].'' GAL MI CAP
DOMESTIC
COTL BOX
AY ]-8IIX48'! COIL BOX FOR A 1'' METER
AMV X AMC W/ 1'' MIP INLET AND
oUTLET -- 79O-448-QFPP440X18
518 9 - 068
AY ]-8'' LOCKTNG LID FOR COIL PI?
BOX 90Lt-8 4l-89-001
AY 90-C]- ]"8X4 INSULATTNG CUSHION
MCDONALD 4189-034
833.545ea 833.65
20.689E4
4.42tEA
;--28.520ea
38 .4a2ea
24.69
4 .42
]-28.52
38 .4L
Bid Total
Sales Eax
Bid Amount
2427
L45
58
65
257 3 .23
SPL.W-I9.01 IPUC DR 19
Gem State Response
Attachment I
Attachment C
Case No. SPL-W-19-01
Staff Comments
06/11/19 Page 3 of4
?hank you for requesting a quotation from Consolidat.ed Suppiy Co.("CcnsolidaEed") for certain malerials you need for Ehe project idenEifiedin che at,tached or enclosed quotati-on documenL (Uhe "Project") . Theenclosed guotation Eo you is made subject. to the following Lerms andconditions:
1. You must carefully review the quoLatlon to confirm Ehat j-i meets yourreguirements before using iL for a bid. Unless you have providedConsolidated wj-th a deEailed bill of mat,erlals and specificaEions wich yourrequirements (with any applicable addendums), this quoEaEion is only agood-fa:Eh esEimaEe and does not constj-EuEe an offer whlch can be accepcedor relied on in any manner. Building plans alone do not constitute adet.ailed bill of maEerials or specifications. particularly if more Lhan onesupplier or eubconbractor may be involved in supplying pluurbing and/or
waEerworks materials. Unless Ehe quotation is based on your detajled billof material-s and specificaf,ions, you agree that aL1 risk of loss arisingfrom the use of this guotation for bidding purposes-including any lorsrelating Lo errors in scope, quanEit:/, price, tinre, arrd place ofdelivery-is on you. All quoLations are conditioned upon availairilluy oflabor and materials at Lhe time an order acrually ie placed. You areresponsible to specify and select, appropriace materials for your inrend.eduse. CSCO provideo no desJ.gn, engineering, or oEher professional- ser,ricesand ca.nnot recommend or warranL goode to be fit for your parcicularpurposes.
2. If you place an order with Consolj.dateC for work or materj.als f or EheProjecE, the resulting conErac[ will be subject, to ConsolidaEed's GeneralTerms and Conditions of Sa1e. If credlt is provided by Consolidated, thenthaE crediE is provided on Consolldated's general creclit tenr,s andconditions. These Eerms and condicj-ons are available to you upon requesEand can be viewed on our websj.te at r{\^/rir/.consolidated*rppiy.com.
3. Delivery under this quotatj-on is FOB Consolidated's OR manufacturer'sfacility. If the quoLation includes delivery to a jobsite, Consolidated mayuse a method and carrier of Consolidated's choice, unless oLherwise statedin the quotation, and Consolidated assumes Ehat Lhe location is 1ega1ly andphysically accessible fo inrerstate freight carriers operating r"rnder rCCreg';lations. Unloading labor wil-1 be provided by purchaser. Additionalcharges may a1>p).y if Lhese assurnpLions are incorrect or if multipledeliveries are reguired. consolidated will make a good faj.th effort to meeLdelivery dater agreed to in wriLing, l:ut cannot g'uaranty delj"very dates forgoods noE in stock or for wh.ich Ehe Lerms of delivery are ouLside ourconLrol.
4. Pricing in Lhis guoLation is based on unit amounLs and is firm and vaiidonly if the goods are ordered wiChin 30 calendar days from the daEe of thequotation. ConsolidaEed may extend quoLed prices on a case-by-case basisbeyond the 3o-day period. ConsolidaEed reserves the right to correct orwithdrarv this qfuoLacion in the case of clerical error. Any change inquant.ities ordered or rime for delivery may resiult in a change of the
guoE.ed prices, including unit prices, unless otherwise agreed to byConsolidat,ed in writing. In the case of commodity iEems subjece to dramaElcprice increases from the manufacturer such as PVC pipe, plastics, iron andcopper, ConsolidaEed reserves the righE to modify prices in this guoEationafEer the daEe thaE it is issued. This quoEation is noE a bid or a lump-sum
quoL.e, unless specifically stated in the guotation.
SPL.W.I9-01 IPUC DR 19
Cem State ltcsponse
Atlaehment I
Attachment C
Case No. SPL-W-19-01
Staff Comments
06/11119 Page 4 of 4
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS I ITH DAY OF JUNE 2019,
SERVED THE FOREGOING COMMENTS OF THE COMMISSION STAFF, IN
CASE NO. SPL-W-Ig-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
PRESTON CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
ERIC W NELSEN
SR REGULATORY ATTORNEY
NW NATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-mail : Ilric.Nel sen(Dnr,vnatural.com
E-mail conl
k en d rah(d given spur:sl ey. co nr
*-r-, /)A.^
SECRETARY
CERTIFICATE OF SERVICE