20250312Staff 46-55 to GSW.pdf

RECEIVED
MARCH 12, 2025
IDAHO PUBLIC
ADAM TRIPLETT
UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10221
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF GEM STATE WATER )
COMPANY, LLC'S APPLICATION FOR ) CASE NO. GSW-W-24-01
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR WATER SERVICE )
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO GEM STATE WATER
COMPANY, LLC
Staff of the Idaho Public Utilities Commission ("Commission"), by and through its
attorney of record, Adam Triplett, Deputy Attorney General, requests that Gem State Water
Company, LLC ("Company")provide the following documents and information as soon as
possible, but no later than WEDNESDAY,APRIL 2, 2025.
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
THIRD PRODUCTION REQUEST
TO GEM STATE WATER COMPANY, LLC 1 MARCH 12, 2025

In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUEST NO. 46: Please respond to following request for the Bitterroot Water
System Upgrade project referenced in response to Production Request No. 28 (Attachment 2, 3,
and 4) and 29 (tab BR Upgrade in Attachment 1). Please include workpapers with formulas
intact.
a) Please provide a detailed description of the scope of and need for the overall project
with identification and descriptions of individual subprojects within the overall scope.
b) Please provide an explanation of the need for each subproject.
c) Please provide a baseline budget-to-actual comparison for each subproject.
d) For any budget-to-actual cost overages that are over 5%,please explain the reason for
the differences and provide any documentation, including approved change orders.
e) Please categorize by subproject the items listed on tab: `BR Upgrade" in response to
Production Request No. 29, Attachment 1.
f) Please explain how each of the subprojects were implemented at least cost. If a
Request for Proposal ("RFP") or Request for Quote ("RFQ") was issued, please
provide the following:
i. A copy of the RFP or RFQ;
ii. An explanation of the selection process including the scorecard and list of the
criteria used to select the contractor;
iii. The short-list bidder scorecard; and
iv. A copy of the winning bid.
REQUEST NO. 47: The Company states the actual cost spent on the Bitterroot Upgrade
project is $1,114,073. However, according to responses to Production Request Nos. 29 and 30,
the total project cost is $1,065,854.53 excluding AFUDC. Please reconcile the difference.
REQUEST NO. 48: In reference to the meter replacement program in responses to
Production Request Nos. 29 and 30,please provide the following for each item listed below: (1)
THIRD PRODUCTION REQUEST
TO GEM STATE WATER COMPANY, LLC 2 MARCH 12, 2025

a detailed description, (2) an explanation of the need, (3) any price quotes from competing
vendors, and(4) copies of invoices for the costs provided in the Production Requests:
a) Meter Set—Meters BCS/SLE/BR 1.5", 25 2" 25 3/4" 30 3" 1;
b) Meter Set-Kamstrup Meter purchase;
c) Kamstrup Meters (240); and
d) Meter—quantity 50.
REQUEST NO. 49: Please provide the following information for the Arc Flash Study
line items listed in response to Production Request No. 29:
a) Explain the reason for the Are Flash Study in 2023.
b) Copies of all estimates and/or quotes received for this study to be completed.
c) Provide a complete list of the locations included while conducting this study.
d) Copies of all reports from this study and corrective action taken if any.
e) What was the impact on insurance premiums, if any?
REQUEST NO. 50: In response to Production Request No. 29, the Company provided
information listed as Arc Flash Study with expenses in 2024. Please explain the additional Arc
Flash Study expenses in 2024. Also, please provide a complete list of the locations included for
any additional Arc Flash Study work conducted in 2024, including copies of all reports from
including any corrective action taken as a result.
REQUEST NO. 51: Please provide the following information for all Company vehicles:
a) Please provide the purchase agreement and any payment plan.
b) Identify any relevant documentation for modifications or upgrades to a Company
vehicle.
c) Identify the employee the vehicle is assigned to.
d) Identify the primary location and use for the vehicle.
e) Provide the policy or standard practice regarding allowing employees to take vehicles
home overnight or on the weekends.
THIRD PRODUCTION REQUEST
TO GEM STATE WATER COMPANY, LLC 3 MARCH 12, 2025

REQUEST NO. 52: Please provide a map of the Company's water system identifying all
sample stations and end of line blow off valves, as well as the year they were installed.
REQUEST NO. 53: In the Company response to Production Request No. 30, row 10,
line item with the description—"Corrected duplicate check on 3/17/22". Please provide the
following information:
a) Please provide the payee, date, and amount of the original and duplicate check.
b) Explain how and when the duplication error was discovered.
c) Explain the situation surrounding the original check as well as the duplicate check
being issued.
d) Provide a copy of the original invoice.
e) Identify which capital project the original invoice was associated with.
REQUEST NO. 54: Please provide additional information relating to the Vac Trailer
purchased by Pelican Pt that is listed in response to Production Request No 29. Please also
explain the reason for the purchase by Pelican Pt to be included as a capital expenditure in this
case.
REQUEST NO. 55: For the capital expenses listed on the attached spreadsheet"GSW-
W-24-01 Staff Capital Expenses", please provide the corresponding invoices, identify the items
or services provided, and explain what capital project the items or services are associated to if
appropriate.
DATED at Boise, Idaho, this 12th day of March 2025.
Adam plett
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\GSW-W-24-01 PR#3.docx
THIRD PRODUCTION REQUEST MARCH 12, 2025
TO GEM STATE WATER COMPANY, LLC 4

CERTIFICATE OF SERVICE
/
I HEREBY CERTIFY THAT I HAVE THIS D:'-O
DAY OF MARCH 2025,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPANY,LLC , IN CASE NO.
GSW-W-24-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:
PRESTON N CARTER LESLIE ABRAMS-RAYNER
GIVENS PURSLEY LLP GENERAL MANAGER
601 W BANNOCK ST GEM STATE WATER CO
BOISE ID 83702 PO BOX 3388
E-MAIL: prestoncarter@a,,givenspursley.com COEUR D'ALENE, ID 83816
stephaniew@ ig.venspursley.com E-MAIL: [e-mail]
MATT ROWELL
MANAGER OF WATER RATES & REG.
ERIC NELSEN
SENIOR REGULATORY ATTORNEY
NW NATURAL
250 SW TAYLOR ST
PORTLAND OR 97204
E-MAIL: [e-mail]
eric.nelsen@,nwnatural.com
Vl
PATRICIA JORDAN, ECRETARY
CERTIFICATE OF SERVICE