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Home My WebLink About20250203Staff 31-45 to GSW.pdf RECEIVED Monday, February 3, 2025 2:42:14 PM IDAHO PUBLIC UTILITIES COMMISSION 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 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 ) SECOND 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, Adam Triplett, 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 MONDAY, FEBRUARY 24, 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. SECOND PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 1 FEBRUARY 3, 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. 31: Please provide up-to-date and separate geo-spatial system maps that outline all water utility systems operated by the Company. The map should include the location and elevation of major equipment including wells, distribution piping, storage tanks, booster pumps, shut-off valves, meters, fire hydrants, water treatment equipment, etc. NOTE: Please provide this map in electronic format(pdf) which can be scaled and enlarged to identify all aspects of the system. REQUEST NO. 32: Please provide a thorough and complete description of the water system including the following details regarding the system as applicable: a. The depth, width, length, capacity, construction materials of each well (including backup wells, if any), and length of time in service. b. The make, model, type, and rating of each well pump motor, and length of time in service. c. The make, model, capacity, and limit switch settings of each pressurized storage tank, and length of time in service. d. The make, model, capacity, and limit switch settings of each unpressurized storage tank/reservoir, and length of time in service. e. The make, model, and rating of each booster pump and motor, and length of time in service. f. The make, model, and capacity of all water treatment equipment, and length of time in service. g. The year, make, model, and capacity for backup generation supporting the well pumps, and length of time in service. Indicate if the generation has an Automatic Transfer Switch or if it must be manually started. h. The distribution piping line size and materials specified in the installation, and length of time in service. SECOND PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 2 FEBRUARY 3, 2025 REQUEST NO. 33: Please provide detailed information related to the capacity and size of the system and the ability of the system to meet historical and future system peak demands. The information provided should include not only capacity or constraints of/or within the system, but also consumption and consumption at peak periods. Please provide necessary workpapers in spreadsheet (such as, Microsoft Excel) format with formulas intact. REQUEST NO. 34: For each well used by the water system,please provide the following: a. The Idaho Department of Water Resources Well Tag Number (D-Tag Number) that is currently on-file with IDWR. b. Location(Township, Range, Section, and Tract). REQUEST NO. 35: Please provide the monthly amount of electricity (kWh)used and corresponding electricity cost(in US Dollars) for each well and booster pump from January 2020 through December 2024. Please provide your responses in spreadsheet(such as Microsoft Excel) format with formulas intact. REQUEST NO. 36: Please provide the monthly metered amount of water(gallons) pumped from each well from January 2020 through December 2024. Please provide your responses in spreadsheet(such as Microsoft Excel) format with formulas intact. REQUEST NO. 37: Please provide the monthly metered total customer water usage data (gallons)by customer types from January 2020 through December 2024. Please provide your responses in spreadsheet(such as Microsoft Excel) format with formulas intact. REQUEST NO. 38: Please provide an estimate of total unaccounted water losses due to leaks, wasted water, etc. by month from January 2020 through December 2024. Please provide your responses in spreadsheet(such as Microsoft Excel) format with formulas intact. REQUEST NO. 39: Please provide the total monthly amount of Chlorine used(in pounds), and total expense for Chlorine purchase (including Sales Tax) for each well from SECOND PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 3 FEBRUARY 3, 2025 January 2020 through December 2024. Also please specify whether a solid or liquid form of Chlorine was used for each well. Please provide your responses in spreadsheet(such as Microsoft Excel) format with formulas intact. REQUEST NO. 40: Please provide a copy of the Company's latest Idaho Department of Environmental Quality Sanitary Survey. REQUEST NO. 41: Please provide the average monthly pressure data in the main distribution line from January 2020 through December 2024. Please provide your responses in spreadsheet (such as Microsoft Excel) format with formulas intact. REQUEST NO. 42: Does the Company expect customer growth? If so,please provide workpapers and documentation including but not limited to the potential number of customers and type of customers by year for the next five years. REQUEST NO. 43: Please explain why customer connections served by 5/8-inch, 3/4- inch, and 1-inch meters all have the same monthly minimum charge. Please include any cost- based reasons for charging these customers the same monthly minimum charge. REQUEST NO. 44: Please describe how the parent company (NW Natural Water Company, LLC) allocates costs to the Company. Please provide a list of all allocated costs from the parent company along with any supporting documentation for the allocation method used. REQUEST NO. 45: Please provide a description of the Company's practices for determining uncollectible debts, including the criteria used in determining when an account is uncollectible. Please also provide the actual net write-offs for years 2021 through 2024. SECOND PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 4 FEBRUARY 3, 2025 DATED at Boise, Idaho, this 3rd day of February 2025. AA,� Adam Triplett Deputy Attorney General I:\Utility\UMISC\PRDREQ\GSW-W-24-01 PR#2.doex SECOND PRODUCTION REQUEST TO GEM STATE WATER COMPANY, LLC 5 FEBRUARY 3, 2025 CERTIFICATE OF SERVICE I HEREBY CERTIFY THAT I HAVE THIS_Z�DAY OF FEBRUARY 2025, SERVED THE FOREGOING SECOND 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: prestoncarterk ig venspursley com COEUR D'ALENE, ID 83816 stephaniewk ig venspursley.com E-MAIL: leslieggemstate-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@nwnatural.com eric.nelsen(anwnatural.com PAT ICIA JORDAN, S CRETARY �I i I CERTIFICATE OF SERVICE