20250224GSW to Staff 5_17_28-30.pdf

RECEIVED
Monday, February 24, 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 19, 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 19, 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: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 5
For each of the Company's wells, please provide the quantity (gallons) pumped for each
month between January 2020 to date.
Response:
Please see the attached file GSW-W-24-01 IPUC DR 5 Attachment 1.
GSW-W-24-01
IPUC Staff PR 5
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: Deborah Davis
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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.
Response:
The attached file GSW-W-24-01 IPUC DR 17 Attachment 1 provides a summary of all
benefits and retirement plans provided to Company employees of all classifications. The
attached file GSW-W-24-01 IPUC DR 17 Attachment 2 provides more detail on the
available benefits plan. The attached file GSW-W-24-01 IPUC DR 17 Attachment 3
provide historical perspective on changes made to the benefits plans.
The attached confidential file Confidential GSW-W-24-01 IPUC DR 17 Attachment 4
shows benefits costs for 2025 which are $3,525 lower than the test year benefits costs.
We would not oppose an adjustment to benefits costs that would lower them by that
amount.
GSW-W-24-01
IPUC Staff PR 17
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 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.
Response:
a. New truck —
The decision was made to purchase a company truck for the field manager to replace
the use of his personally owned vehicle. Given the amount of driving necessary to
service Gem State's geographically dispersed systems, use of employee-owned
vehicles is untenable. The budget was set at $50,000 which is typical for a full-sized
work truck. Comparable vehicles were searched for in the area prior to completing the
purchase. A purchase order for the truck is attached as GSW-W-24-01 IPUC DR 28
Attachment 1.
b. Bitterroot System rebuild —
The Bitterroot system was disapproved by the Idaho Department of Environmental
Quality ("IDEQ") in a letter dated April 16, 2019, for violations stemming from
improvements completed without prior IDEQ review and approval. Gem State Water
acquired the system in late 2019 and was tasked with bringing the system into
compliance. Through engineering and working closely with IDEQ, a facilities plan was
created addressing the required upgrades. Preliminary engineering reports were
submitted to IDEQ for each phase of the project. The project included additional
GSW-W-24-01
IPUC Staff PR 28
Page 1 of 2

storage, source, backup power generation, pumping capacity, and additional site
improvements. Engineers provided Gem State Water with an estimated cost for system
upgrades in 2022. Gem State Water worked through the bidding and procurement with
the assistance of the engineers — requiring no less than 2 bids per project phase to
ensure best cost and value. This project was identified as a required project to the
Commission by Gem State Water during the acquisition of the Bitterroot system. The
Facilities Plan is attached as GSW-W-24-01 IPUC DR 28 Attachment 2 and the
engineer's cost estimate is attached as GSW-W-24-01 IPUC DR 28 Attachment 3. The
total spent on the project is $1,114,073; an Excel spreadsheet detailing the components
of that amount is attached as GSW-W-24-01 IPUC DR 28 Attachment 4. Supporting
invoices are available on request.
c. Meter Replacement Program —
A typical water meter has an estimated 20-year life span; all meters on Gem State
Water systems were well in exceedance of this estimated service life. Older meters are
inaccurate, they leak, and they do not allow remote access during inclement weather. A
budget was set for each separate system based on the amount of meters needed and
the technology required. Gem State Water received bids from 3 vendors for varying
meter brands and technologies before choosing a meter that would perform the best in
all applications and provide the most efficient installation, ongoing maintenance, and
tech platform for field use. Gem State Water wanted to ensure that we could accomplish
a year-round meter reading schedule regardless of snow load and reduce customer
leak loss due to months of inaccessible meters. Invoices for all meters purchased are
available on request.
GSW-W-24-01
IPUC Staff PR 28
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
Date of Response:
Witness/Preparer: Leslie Abrams-Rayner
Telephone: [phone]
Email: [e-mail]
Request No.: GSW-W-24-01 IPUC DR 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;
GSW-W-24-01
IPUC Staff PR 29
Page 1 of 2

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
I. The total cost of the change orders.
Response:
See the GSW-W-24-01 IPUC DR 29 Attachment 1 .
GSW-W-24-01
IPUC Staff PR 29
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 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;
GSW-W-24-01
IPUC Staff PR 30
Page 1 of 2

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;
a. The number of change orders; and
1. The total cost of the change orders.
Response:
Please see the GSW-W-24-01 IPUC DR 30 Attachment 1 . Note that the Kamstrup
Meter purchase of $253,253 has an in-service date of 6/28/24 within the test year.
However, these 575 meters were actually installed starting in the test year and the
installations were complete in January 2025. All 575 meters were moved from CWIP to
plant in service at the same time when the last meter was installed. The purchase date
was used as the in-service date for all these meters.
GSW-W-24-01
IPUC Staff PR 30
Page 2 of 2