20250304GSW to Staff 32_38.pdf

RECEIVED
March 4, 2025
Idaho Public
Preston N. Carter, ISB No. 8462 Utilities Commission
GIVENS PURSLEY LLP
601 West Bannock Street
P.O. Box 2720
Boise, Idaho 83701-2720
[phone]
18815539.1 [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.
Dated: March 4, 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 SECOND PRODUCTION REQUEST PAGE I OF 2

CERTIFICATE OF SERVICE
I hereby certify that on March 4, 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 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.
Response:
Please see GSW-W-24-01 IPUC DR 32 Attachment 1.
GSW-W-24-01
IPUC Staff PR 32
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(�) 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 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.
Response:
Obtaining useful monthly estimates of water loss was not possible prior to the
installation of AMR meters (which started in 2024 and was completed in early 2025).
Without a full year of AMR data reads for all customers, the requested estimate is not
possible to calculate. One system, Troy Hoffman, did have AMR meters for all
customers for a full year; however, its master meter on the well was not functional for
most of that time.
GSW-W-24-01
IPUC Staff PR 38
Page 1 of I