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HomeMy WebLinkAbout20250228GSW to Staff 44.pdf RECEIVED February 28, 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 (208) 388-1200 18811087.1 [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 SECOND PRODUCTION FOR WATER SERVICE IN THE STATE OF REQUEST OF COMMISSION STAFF IDAHO In response to the Second Production Request of the Commission Staff to Gem State Water Co, Inc., ("Gem State" or"Company") dated February 3, 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 28, 2025. GIVENS PURSLEY LLP By/s/Preston N. Carter Preston N. Carter Givens Pursley LLP Attorneys for Gem State Water Company, LLC RESPONSES TO STAFF'S SECOND PRODUCTION REQUEST PAGE I OF 2 CERTIFICATE OF SERVICE I hereby certify that on February 28, 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 SECOND 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: 877.755.9287 Email: leslie@gemstate-water.com Request No.: GSW-W-24-01 IPUC DR 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. Response: Generally, Gem State Water's affiliates, which includes its parent company NW Natural Water, attempt to directly assign costs to Gem State Water and other subsidiaries for which the services are being performed. Costs that cannot be directly assigned are allocated to the subsidiaries using the NW Natural Cost Allocation Manual. Gem State Water is allocated shared services from Northwest Natural Gas Company dba NW Natural ("NW Natural") and NW Natural Water. This reflects the fact that, currently, some shared services—such as corporate communications, legal, purchasing, and tax—are provided by NW Natural Gas employees, while others —such as accounting, insurance, and third-party legal—are provided by NW Natural Water. We anticipate that as NW Natural Water continues to acquire additional companies, more shared services will be provided by NW Natural Water. This is the same allocation methodology that is used with NW Natural Water's subsidiaries in Washington, Oregon, Idaho, Texas, and Arizona; the methodology has been approved by commissions in these jurisdictions in prior proceedings to allocate shared services costs. The services that are allocated to Gem State Water include services such as accounting, safety, human resources, regulatory support, and legal services. These are back-office functions that every company must provide to continue to serve customers. If Gem State Water's affiliates did not perform these functions, then Gem State Water would have to perform them directly at higher costs. In addition, by participating in GSW-W-24-01 IPUC Staff PR 44 Page 1 of 2 shared services, Gem State Water is able to leverage the economies of scale experienced by its affiliates. A list of all allocated costs from the parent company along with supporting documentation for the allocation method used is provided in Confidential GSW-W-24-01 IPUC DR 44 Attachment 1. GSW-W-24-01 IPUC Staff PR 44 Page 2 of 2 GEM STATE WATER CO., INC. CASE No. GSW-W-24-01 RESPONSE TO PRODUCTION REQUEST NO. 44 CONFIDENTIAL ATTACHMENT I PROVIDED UNDER SEPARATE COVER