20250211GSW to Staff 1-4_6-16_18-27.pdf

RECEIVED
Tuesday, February 11, 2025
IDAHO PUBLIC
UTILITIES COMMISSION
Preston N. Carter, ISB No. 8462
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
[phone]
18597179.3[13988.231
Attorneys for Gem State Water Company, LLC
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION Case No. GSW-W-24-01
OF GEM STATE WATER COMPANY,
LLC. FOR THE AUTHORITY TO GEM STATE WATER CO.,INC.'S
INCREASE ITS RATES AND CHARGES RESPONSE TO THE FIRST PRODUCTION
FOR WATER SERVICE IN THE STATE OF REQUEST OF COMMISSION STAFF
IDAHO
In response to the First Production Request of the Commission Staff to Gem State Water
Co, Inc., ("Gem State" or"Company") dated January 21, 2025, Gem State submits the following
responses. Responsive documents are available for download using the link provided in the
accompanying email. Confidential responses and documents are subject to the protective
agreement in this case, and are available for download using a password-protected link that will
be provided separately by email. The password will be provided in a third email.
Dated: February 11, 2025.
GIVENS PURSLEY LLP
By Is/Preston N. Carter
Preston N. Carter
Givens Pursley LLP
Attorneys for Gem State Water Company, LLC
RESPONSES TO STAFF's FIRST PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I hereby certify that on February 11, 2025, I caused to be served a true and correct copy of
the foregoing document to the person(s) listed below by the method indicated:
Monica Barrios-Sanchez ® Email
Commission Secretary ❑ U.S. Mail
Idaho Public Utilities Commission ❑ Fax
P.O. Box 83720 ❑ Hand Delivery
Boise, Idaho 83720-0074
monica.barriossanchez&puc.idaho.gov
Is/Preston N. Carter
Preston N. Carter
RESPONSES TO STAFF'S FIRST PRODUCTION REQUEST PAGE 2 OF 2

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Matt Rowell
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
The proposed monthly minimum charges for 3-inch, 4-inch, and 6-inch meters were
calculated by applying the AWWA Meter Weighting Factors to the implied 3/4" monthly
minimum charge. See the tab labeled "Exh 5 (E)_(AWWA Meter Factors)" in GSW-W-
24-01 IPUC DR 1 Confidential Attachment 1 Gem State Rate Case Model Final for
calculations. This attachment was previously produced to Staff attorney on February 7,
2025 via email.
GSW-W-24-01
IPUC Staff PR 1
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
The $763,610 in revenue is based on the following billing data:
Revenue at
Bills Customers Gallons Sold Current Rates
Bar Circle and Spirit Lake 7,003 584 104,906,995 430,610
Happy Valley 288 24 6,679,960 17,035
Troy Hoffman 1,768 147 22,738,299 94,603
Bitter Root and Rickle 2,054 171 37,403,101 125,355
Lynnwood 296 25 4,013,074 14,273
Diamond Bar Estates 690 57 10,679,460 48,845
Diamond Bar Estates Irrigation 213 18 9,575,716 32,581
Total 12,312 1,026 195,996,60E 763,303
(The detail behind this data is provided in response to GSW-W-24-01 IPUC DR 1
Confidential Attachment 1 Gem State Rate Case Model Final.) To try and determine
why the test year revenue is less than what was authorized in the previous Gem State
Water rate case, we compared the current billing data to the billing data from that case.
We found that the test year gallons sold in the current case are significantly less than
the 251,897,767 gallons reported sold in the previous rate case. While some of the
GSW-W-24-01
IPUC Staff PR 2
Page 1 of 2

difference in gallons sold may be attributable to conservation, we believe that issues
with the billing data in the previous case are a more likely cause. In the previous case
we were relying on data from previous owners for some systems, and that data may
have been unreliable. Also, during the test year in the previous rate case leaks on the
customer side of the meter were common, which inflates the gallons sold number if not
accounted for properly. Further, some Gem State Water customers are billed in gallons,
some in cubic feet, and others in centi-cubic feet. Problems converting between these
units could have caused issues with the gallons sold used to determine rates in the
previous rate case.
GSW-W-24-01
IPUC Staff PR 2
Page 2 of 2

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
a. The irrigation lots are all 5 acres or larger— they typically have a large single-
family home with shop and/or barn configuration. They use their acreage for
raising livestock, gardens, and crops.
b. Irrigation customers are currently being billed minimum and usage only during
active usage months set by their HOA, May through September. These meters
are in addition to their domestic meters. They are optional, not required.
GSW-W-24-01
IPUC Staff PR 3
Page 1 of 1

(;) NW Natural'
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Matt Rowell
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
Please see the tabs labeled "Bar Cir S and Spirit Lake", "Happy Valley", "Troy Hoffman",
"Bitter Root and Rickle", "Lynwood", "Diamond Bar Estates", and "Diamond Bar Estates
IRR" in GSW-W-24-01 IPUC DR 1 Confidential Attachment 1 Gem State Rate Case
Model Final.
GSW-W-24-01
IPUC Staff PR 4
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 6
Please provide the power bills for the years ending December 31, 2022, 2023, and
2024.
Response:
Please see GSW-W-24-01 IPUC DR 6 Attachment 1 for the Company's power bills for
the years ended December 31, 2022, 2023, and 2024.
GSW-W-24-01
IPUC Staff PR 6
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Matt Rowell
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 7
Please provide the supporting documentation for the proposed 5.22% cost of debt.
Response:
The 5.22% cost of debt is the blended cost of NW Natural Water Company, LLC, which
is the parent company of NW Natural Water of Idaho, LLC, which is the parent company
of Gem State Water Company, LLC.
See GSW-W-24-01 IPUC DR 7 Attachment 1 for the calculation.
GSW-W-24-01
IPUC Staff PR 7
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
Closing assessments are sent to our office for a property sale/transfer for the inclusion
of final water charges to be paid at close of the agreement. These transactions require
coordination between office staff, field staff, title companies, lenders, real estate agents,
and often the buyers and sellers. The assessment requests are scheduled to be
provided to the title company two days prior to a property sale. Office staff schedules a
field staff to perform a final read on the meter prior to scheduling the current customer
for move out and entering a new customer in waiting. Processing these closing
assessments, for the office staff and the field staff, require approximately two employee
hours. There were 152 closing assessments performed in 2024.
GSW-W-24-01
IPUC Staff PR 8
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
This proposed "refundable meter and backflow device key deposit" of $2,500 (Sheet No.
2, Schedule No. 2 — Non-Recurring Charges) is for customers requesting bulk water via
a hydrant, typically for construction. In a bulk water draw via fire hydrant, a double
check valve is required to protect the water system from backflow contamination. Also,
a meter is needed to record the amount of flow. The hydrant assembly for bulk water
connections via fire hydrant run approximately $2,270.75, pretax (quote provided in
Confidential GSW-W-24-01 IPUC DR 9 Attachment 1). They are also then provided with
a set of special keyed locks and cables to secure the device to the fire hydrant.
The customer/contractor requesting the bulk connection is provided with the hydrant
assembly when the deposit is received which then becomes their responsibility. When
the customers/contractor is finished with the bulk connection and the assembly is
returned to the Company in good working condition, the deposit is returned in full.
Please see Confidential GSW-W-24-01 IPUC DR 9 Attachment 1 for support of the cost
of the hydrant assembly for bulk water connections via fire hydrant.
GSW-W-24-01
IPUC Staff PR 9
Page 1 of 1

(;) NW Natural'
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
These charges apply to Diamond Bar Estates irrigation meters. These meters are
removed and stored to protect them from winter weather. Under the previous owners of
Diamond Bar Estates, the customers were responsible for removal and installation as
well as maintenance of their meters (the irrigation meters belong to the customers, not
the utility). However, it was difficult to track what meters were active and inactive with
customers controlling their meters and activity. Customers were also requesting the
Company to repair or replace irrigation meters that were being damaged due to
improper installation, removal, or storage, although these meters are not owned by the
Company. Therefore, the Company took over the responsibility of removal, storage and
reinstallation of irrigation meters.
These meters are not required and take many man hours to install, remove, and
maintain. They also require additional work by the office staff to reactive and deactivate
meters on customer accounts as well as to bill them during active months.
There are approximately 16-man hours to install meters in the spring and 16-man hours
to remove meters in the fall.
Office staff spends approximately 15 additional office hours each year on irrigation
meter billing operations.
GSW-W-24-01
IPUC Staff PR 10
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Jeremy Aird
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 11
Please provide a copy of the Company's Chart of Accounts.
Response:
Please see GSW-W-24-01 IPUC DR 11 Attachment 1.
GSW-W-24-01
IPUC Staff PR 11
Page 1 of 1

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Jeremy Aird
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
Please see GSW-W-24-01 IPUC DR 12 Attachment 1.
GSW-W-24-01
IPUC Staff PR 12
Page 1 of I

(;) NW Natural'
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 13
Please provide all Company Bank Statements for 2023 and 2024.
Response:
Please see Confidential GSW-W-24-01 IPUC DR 13 Attachment 1 or all Company bank
statements for 2023 and 2024.
GSW-W-24-01
IPUC Staff PR 13
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Phone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
The General Manager is the only Gem State Water employee who receives a bonus.
The criteria and scorecard for the General Manager's bonus is provided as Confidential
GSW-W-24-01 IPUC DR 14 Attachment 1 .
GSW-W-24-01
IPUC Staff PR 14
Page 1 of I

(;) NW Natural'
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 15
Please provide access to copies of all studies used to determine employee
compensation.
Response:
The Company has not completed any formal compensation studies. However, given the
cost of living in the Coeur d'Alene area, salaries and benefits for comparable jobs in the
area, and the nature of the work our employees are responsible for, we believe the
requested salaries are reasonable and justified.
The cost of living in the Coeur d'Alene area is high relative to the US in general and to
other areas of Idaho. The cost of living in the Coeur d'Alene area has been determined
to be 29% higher than the national average. (See: Cost of Living in Coeur d'Alene, ID
Cost of Living Index I ERI) Housing costs are especially high in the area making
homeownership challenging.
Compensation at other utilities close by are comparable to Gem State Water's
compensation. For instance, the City of Coeur d'Alene's Water Department's salaries
are comparable to those of Gem State Water. (See: City of Coeur d'Alene -
Compensation Summary.) Since the city offers a pension plan for its employees and
Gem State Water does not, the City's salaries alone do not tell the whole story of how
attractive employment with them is viewed.
Unlike the City of Coeur d'Alene Water Department and other urban water systems,
Gem State Water is a very rural system which creates significant added stress for our
field employees. The various Gem State Water systems are spread out over a large
area so that almost any field service will require a significant drive. In many instances,
jobs require a significant hike from the work truck to the location needing service. Gem
GSW-W-24-01
IPUC Staff PR 15
Page 1 of 2

State Water has only three field employees to cover this extensive territory. This means
that each one of them is almost always on call. It also means that institutional
knowledge is very important, knowing the layout of the systems and the location of
infrastructure as well as the best routes between the various parts of the systems
requires spending significant time on the job. So even an experienced new operator
would still have to undergo extensive training. For these reasons, field work on the Gem
State Water systems is not easy; it is a difficult job that requires unique knowledge and
physical toughness.
The office work involved with Gem State Water is also difficult. Unlike a typical office
administration job, Gem State Water's office employees are responsible for complicated
and extensive regulatory reporting, administering a billing system that issues about
1,000 bills a month, and fielding customer service calls and inquiries. Gem State
Water's regulatory reporting requirements are extensive; for instance, we must produce
sanitary surveys for each individual water system. Most other regulatory reporting to the
IDEA is also required to be done on a system-by-system basis. When customers have
billing questions, our employees must be able to figure out the issue and respond to the
customers in a timely way, not just follow a customer service script. This requires
familiarity with the billing software and Gem State Water's tariffs as well as a willingness
and ability to problem solve and work out the math behind billing issues. For these
reasons, Gem State Water's office work is significantly more difficult than the typical
Coeur d'Alene administrative position.
The small size of Gem State Water's staff means that when any one employee takes
sick leave or paid time off, the other employees are forced to put in significant extra
effort. It also means that the institutional knowledge any one employee would take with
them if they were to leave Gem State Water's employment is significant. So, it is
extremely important for us to limit employee turnover. For all of these reasons, we
believe our employee's salaries are reasonable and justified.
GSW-W-24-01
IPUC Staff PR 15
Page 2 of 2

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 16
Please provide the rationale and supporting documentation for hiring a new part time
employee.
Response:
The additional part time employee will focus on customer service work. Gem State
Water relies on a very small staff for day-to-day operations. As we find ourselves in
need of staff to perform more required reporting duties for public agencies, for example
compliance with the new lead line rule, it is becoming increasingly difficult to meet those
reporting deadlines while maintaining the normal day-to-day customer service
requirements. It is important to note that these requirements are per system, so multiple
reports must be created. Hiring an additional staff member in our office will allow us to
continue to provide a high level of customer service during times of heavier workloads.
This will reduce the instances where customers may be sent to voicemail. Currently,
about 75% of our customers still pay their bills with physical checks. Processing
physical checks is a relatively labor-intensive process. Adding an additional part time
position will also help ease the feeling of being overwhelmed felt by staff when an
employee is out sick or on PTO, and will thus lower employee turnover. Please see
Confidential GSW-W-24-01 IPUC DR 18 Attachment 1 , pages 6 and 7, for the job
description of the new part-time Customer Service Associate employee.
GSW-W-24-01
IPUC Staff PR 16
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
A list of Gem State Water job titles and number of employees is included below:
Number of Employees Position Full-Time/ Part-Time
1 General Manager Full Time
1 Billing Specialist Full Time
1 Operator in Training Utility Full Time
Worker
1 Distribution Operator 1/2 Full Time
1 Field Operations Manager Full Time
1 Senior Operator Level 4 Full Time
1 Customer Service Full Time
Assoc./AP/Program
Administrator
FUTURE Customer Service Assoc. Part Time
Please see Confidential GSW-W-24-01 IPUC DR 18 Attachment 1 for the job
descriptions.
GSW-W-24-01
IPUC Staff PR 18
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Jeremy Aird
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 19
Please provide the supporting documentation for the payroll taxes.
Response:
Please see Confidential GSW-W-24-01 IPUC DR 19 Attachment 1.
GSW-W-24-01
IPUC Staff PR 19
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 20
Please provide a schedule or required water test for each well and the frequency of
each test.
Response:
The attached PDF file GSW-W-24-01 IPUC DR 20 Attachment 1 provides a schedule
for each of the Company's seven systems.
GSW-W-24-01
IPUC Staff PR 20
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 21
Please provide a schedule showing the costs for each water test.
Response:
Please see GSW-W-24-01 DR 21 Attachment 1.
GSW-W-24-01
IPUC Staff PR 21
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 22
Please provide the current insurance policy and the invoices for that insurance policy
supporting the Company's insurance expense.
Response:
Gem State Water is insured through policies held at NW Natural Water and NW Natural
Gas. Confidential GSW-W-24-01 IPUC DR 22 Attachment 1 details the allocations.
Confidential GSW-W-24-01 IPUC DR 22 Attachment 2 contains the supporting invoices.
GSW-W-24-01
IPUC Staff PR 22
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 23
Please provide the most recent property tax bills.
Response:
Please see GSW-W-24-01 IPUC DR 23 Attachment 1.
GSW-W-24-01
IPUC Staff PR 23
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Matt Rowell
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 24
Please provide invoices for all rate case expenses to date associated with this case.
Please update this as new invoices are received.
Response:
Please see the Confidential GSW-W-24-01 IPUC DR 24 Attachments 1 and 2. The
Company will update this response as new invoices are received.
GSW-W-24-01
IPUC Staff PR 24
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
Gem State Water does not have audited financial statements. NW Natural Water does
conduct an audit of the consolidated water company, but not individual entity audits.
GSW-W-24-01
IPUC Staff PR 25
Page 1 of I

(�) NW Natural
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Matt Rowell
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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;
b. Amount awarded;
c. Account the funds were allocated to; and
d. Explanation of why the allocation of funds was appropriate.
Response:
There are no grants or federal funding awarded or pending distribution to benefit the
Company.
GSW-W-24-01
IPUC Staff PR 26
Page 1 of I

(;) NW Natural'
Rates & Regulatory Affairs
GSW-W-24-01
In the Matter of Gem State Water Company, LLC's Application for Authority to Increase
its rates and Charges for Water Service
Data Request Response
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
To develop, manage, and execute capital projects in a cost-effective and least-risk
manner, Gem State Water first identifies a deficiency that will require capital investment
either through maintenance and operations, through IDEA Sanitary Surveys, or through
Facilities planning. Gem State Water then defines the project scope and objective,
determining what resources, personnel, equipment, and materials might be
needed. Gem State Water analyzes potential options for achieving the project objective
by conducting a base feasibility process which looks at design options, and cost
estimates to identify the most cost-effective and least-risk approach. A budget is
determined with a breakdown of major project components and a closer look is taken at
these individual parts to identify potential opportunities for cost reductions. Gem State
Water researches potential materials and service providers to ensure we are receiving
the most competitive pricing options. We then enter the procurement phase where we
collect competitive bids, and review vendor or service contracts to minimize any
potential cost risk. Upon executing the contract, we begin scheduling via a previously
established project calendar that assists us in identifying milestones and monitoring
progress to minimize or eliminate change orders or cost increases and other risks.
Monitoring the progress also allows us to ensure quality control across all aspects of
construction. Finally, upon completions we review the project costs to ensure alignment
with quotes and financial expectations.
GSW-W-24-01
IPUC Staff PR 27
Page 1 of I