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Home My WebLink About20250121Staff 1-30 to GSW.pdf RECEIVED Tuesday, January 21, 2025 11:46:44 AM IDAHO PUBLIC UTILITIES COMMISSION DAYN HARDIE DEPUTY ATTORNEY GENERAL IDAHO PUBLIC UTILITIES COMMISSION PO BOX 83720 BOISE, IDAHO 83720-0074 (208) 334-0312 IDAHO BAR NO. 9917 Street Address for Express Mail: 11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A BOISE, ID 83714 Attorney for the Commission Staff BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION IN THE MATTER OF GEM STATE WATER ) COMPANY, LLC'S APPLICATION FOR ) CASE NO. GSW-W-24-01 AUTHORITY TO INCREASE ITS RATES ) AND CHARGES FOR WATER SERVICE ) FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO GEM STATE WATER COMPANY, LLC Staff of the Idaho Public Utilities Commission("Commission"), by and through its attorney of record, Dayn Hardie, Deputy Attorney General, requests that Gem State Water Company, LLC ("Company")provide the following documents and information as soon as possible, but no later than TUESDAY, FEBRUARY 11, 2025. 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 the person preparing the documents. Please also identify the name,job title, location, and telephone number of the record holder. FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 1 JANUARY 21, 2025 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: Please explain how the Company calculated the proposed monthly minimum charge dollar amount and minimum customer volume for 3-inch, 4-inch, and 6-inch metered connections. Please provide any workpapers used in the Company's calculations in Excel format with formulas intact. REQUEST NO. 2: Please explain any known reasons for the difference in Test Year revenue of$763,610 shown in Company Application Exhibit 2 and the revenue requirement of $834,870 authorized in Commission Order No. 35728. REQUEST NO. 3: Please answer the following regarding Diamond Bar Estates Irrigation customer connections: a. Please explain the types of properties that the irrigation connections serve, such as single-family properties, commercial properties, common areas such as those found in an HOA, or other property type; and b. Please explain if the irrigation customers are billed the current Schedule No. 9 monthly minimum charge for all 12 months of the year. If not,please provide the number of months of the year that these customers are billed the monthly minimum charge. REQUEST NO. 4: Please provide individual monthly consumption data for all customers in gallons, and billed customer charges, from January 1, 2022, to present. Please include meter size and water system (Bar Circle "S", Diamond Bar, etc.) with the data. REQUEST NO. 5: For each of the Company's wells, please provide the quantity (gallons)pumped for each month between January 2020 to date. REQUEST NO. 6: Please provide the power bills for the years ending December 31, 2022, 2023, and 2024. FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 2 JANUARY 21, 2025 REQUEST NO. 7: Please provide the supporting documentation for the proposed 5.22% cost of debt. REQUEST NO. 8: Please provide the rationale and costs supporting the account change/closing fee, as shown on the non-recurring charges in the Company's proposed tariff. REQUEST NO. 9: Please provide the rationale and costs supporting the refundable meter and backflow device key deposit, as shown on the non-recurring charges in the Company's proposed tariff. REQUEST NO. 10: Please provide the rationale and costs supporting the annual fee for removal, storage and reinstallation of irrigation meters, as shown on the non-recurring charges in the Company's proposed tariff. REQUEST NO. 11: Please provide a copy of the Company's Chart of Accounts. REQUEST NO. 12: Please provide either a copy of the Company's QuickBooks file or a full general ledger for the years ending December 31, 2022, 2023, and 2024. REQUEST NO. 13: Please provide all Company Bank Statements for 2023 and 2024. REQUEST NO. 14: Please provide the criteria for issuing employee bonuses along with any scorecard or other documentation supporting the Company's decision to provide bonuses in the 2024 test year. REQUEST NO. 15: Please provide access to copies of all studies used to determine employee compensation. REQUEST NO. 16: Please provide the rationale and supporting documentation for hiring a new part time employee. FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 3 JANUARY 21, 2025 REQUEST NO. 17: Please summarize all benefit and retirement plans provided to Company employees of all classifications. Please also include any changes that have occurred to the benefits/accruals during the past five years. Also, please include the costs of those benefit plans supporting the Company's employee benefit expense. REQUEST NO. 18: Please provide a list of all job titles and descriptions. Please include the number of employees that are currently employed for each job title. REQUEST NO. 19: Please provide the supporting documentation for the payroll taxes. REQUEST NO. 20: Please provide a schedule or required water test for each well and the frequency of each test. REQUEST NO. 21: Please provide a schedule showing the costs for each water test. REQUEST NO. 22: Please provide the current insurance policy and the invoices for that insurance policy supporting the Company's insurance expense. REQUEST NO. 23: Please provide the most recent property tax bills. REQUEST NO. 24: Please provide invoices for all rate case expenses to date associated with this case. Please update this as new invoices are received. REQUEST NO. 25: Please provide internal and external audit reports from 2020— 2024, if any, related to capital projects including: planning, execution, and accounting. Please also include a description of the steps taken to address any issues identified within the audit reports or as a result of the audit process. REQUEST NO. 26: For any grant or federal funding awarded or pending distribution to benefit the Company,please provide the following: a. Name of the grant or funding program; FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 4 JANUARY 21, 2025 b. Amount awarded; c. Account the funds were allocated to; and d. Explanation of why the allocation of funds was appropriate. REQUEST NO. 27: Please provide a detailed description of the Company's method for developing, managing, executing, and completing Capital Projects that ensures that the projects are procured or built in a least cost manner. REQUEST NO. 28: Please provide the details, scope of work, reason for the project, initial budgets, and bids received, etc. for the following pro forma capital projects: a. New truck; b. Bitterroot System rebuild; and c. Meter Replacement Program. REQUEST NO. 29: Please provide a sortable spreadsheet listing all the fully completed capital projects that have been placed in service since the end of the test period used in the Case No. GSW-W-22-01 (December 31, 2022) and the last date actual plant-in-service is included in the Company's Application(end of the Company's Historic Test Year on September 30, 2024). Projects that are partially placed in service during the Historic Test Year or estimated for completion during the proforma period SHOULD NOT be included on this list. Additionally,please identify which projects are unique one-time projects and which are "blanket"projects that capture multiple recurring smaller projects such as vehicle replacements or O&M type of projects that are capitalized. At a minimum, the list should contain the following information for each project: a. The project unique identification number; b. The project title; c. A short description of the project scope; d. Classification as "one-time" or"blanket"project; e. The project's primary function(based on standard accounting practices); f. The initial approved budget for the project; FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 5 JANUARY 21, 2025 g. The latest approved budget for the project; h. The actual expenditures for the project; i. The final in-service date for the project; j. Whether or not the Company solicited contractors to execute some or all of the project; k. The number of change orders; and 1. The total cost of the change orders. REQUEST NO. 30: Please provide a sortable spreadsheet listing all the projected capital projects that the Company expects to be placed in service between the last date actual plant-in-service was included in the Company's Application (end of the Company's Historic Test Year on September 30, 2024 and the end of the Company's proforma period(end of the Company's Adjusted Test Year on January 30, 2025. Projects that are partially placed in service during the Historic Test Year or estimated for completion during the proforma period SHOULD be included on this list. Additionally,please identify which projects are unique one-time projects and which are "blanket"projects that capture multiple recurring smaller projects such as vehicle replacements or O&M type of projects that are capitalized. At a minimum, the list should contain the following information for each project: a. The project unique identification number; b. The project title; c. A short description of the project scope; d. Classification as "one-time" or"blanket"project; e. The project's primary function (based on standard accounting practices); f. The initial approved budget for the project; g. The latest approved budget for the project; h. The actual expenditures for the project; i. The final in-service date for the project; j. Whether or not the Company solicited contractors to execute some or all of the project; FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 6 JANUARY 21, 2025 k. The number of change orders; and 1. The total cost of the change orders. DATED at Boise, Idaho, this 21 st day of January 2025. le ,)qZ Dayn Ha die Deputy Attorney General 1:\Utility\UM1SC\PRDREQ\GSW-W-24-01 PR#I.docx FIRST PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 7 JANUARY 21, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS !�-I DAY OF JANUARY 2025, SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION STAFF TO GEM STATE WATER COMPANY, LLC , IN CASE NO. GSW-W-24-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING: PRESTON N CARTER LESLIE ABRAMS-RAYNER GIVENS PURSLEY LLP GENERAL MANAGER 601 W BANNOCK ST GEM STATE WATER CO BOISE ID 83702 PO BOX 3388 E-MAIL: prestoncartergrc ivenspursley.com COEUR D'ALENE, ID 83816 stephaniew a ig venspursley com E-MAIL: Leslie a gemstate-water.com MATT ROWELL MANAGER OF WATER RATES & REG. ERIC NELSEN SENIOR REGULATORY ATTORNEY NW NATURAL 250 SW TAYLOR ST PORTLAND OR 97204 E-MAIL: matt.rowell a,nwnatural.com eri c.nel s en gnwnatural.com PA ICIA JORDAN, S CRETARY CERTIFICATE OF SERVICE