HomeMy WebLinkAbout20250203Staff 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
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CERTIFICATE OF SERVICE