20250228GSW 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
[phone]
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: [phone]
Email: [e-mail]
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