20190517Staff 1-14 to Gem State.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPROVAL OF
ACQUISITION OF THE ASSETS OF'DIAMOND
BAR ESTATES, L.L.C. AND BAR CIRCLE ''S',
WATER, INC.; FOR TRANSFER OF
CERTIFICATES OF PUBLIC CONVENIENCE
AND NECESSITY OF DIAMOND BAR
ESTATES, L.L.C. (NO.413) AND BAR CTRCLErrstr WATER,INC. (NO.296); AND REQUEST
FOR MODIFIED PROCEDURE
CASE NO. BCS.W.19.O1
DIA-W-19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
GEM STATE WATER
COMPANY
RECEIVED
3019f{lY l7 []l 9:05
iDAHO PUBLIC
TII.ITIES CCMMISSION
Street Address for Express Mail:
472 W. WASHTNGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THB IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission, by and through its attomey of record,
Edward Jewell, Deputy Attorney General, request that Gem State Water Company (Gem State
Water) provide the following documents and information as soon as possible, or by FRIDAY,
JUNE 7,2019.
This Production Request is continuing, and Gem State Water 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Gem State Water is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY MAY 17,2019I
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.01.01.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a schedule showing all expected expenses required to
complete the sale. Please include all expenses incurred and anticipated.
REQUEST NO. 2: Please provide a schedule showing all anticipated capital
expenditures/improvements for the next three years.
REQUEST NO.3: Please provide the location where accounting, financial, and
customer records will be kept should the purchase be approved.
REQUEST NO. 4: Please explain how and where service requests and customer service
questions will be addressed should the purchase be approved.
REQUEST NO. 5: Please confirm that the sale includes the land where Diamond Bar's
backup well is located. If the land included in the purchase is not, please explain how Gem State
Water will provide backup water service to Diamond Bar.
REQUEST NO. 6: Please provide the "lnterim Financial Statements," "Financial
Statements," and "lnterim Balance Sheet" mentioned in Confidential Exhibit 2 page 41.
REQUEST NO. 7: If the Commission approves the sale, does the Company intend to
notify its customers of the purchase of the water system through the use of a billing insert or
separate mailing? If a document has already been drafted, please provide a copy and explain
how it will be delivered to customers.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY MAY 17,20192
REQUEST NO. 8: For each Company, Diamond Bar and Bar Circle "S", please provide
the following:
a. When are meters currently read?
b. How often are the customers billed?
c. Does the Company plan on maintaining the current schedule for meter reading and
billing? If not, please explain.
REQUEST NO. 9: Please provide Company contact information including business
hours and24 hour emergency contact, including post-acquisition contact information.
REQUEST NO. 10: Please provide a copy of the proposed billing statements and
collections documentation to be used.
REQUEST NO. 11: Will Gem State Water continue to bill all customers using the same
billing format and billing system currently used by Bar Circle "S" and Diamond Bar? Please
explain.
REQUEST NO. 12: For Diamond Bar Water:
a. Please provide an up-to-date system map showing the location of major equipment
including wells, mains, storage tanks, and water treatment equipment. Clearly
identify any easements and equipment that is not Company owned (e.g. backup
wells).
b. Please provide a copy of the agreement for any easements or any equipment used by
the Company that is not Company owned.
c. For the Idaho Division of Environmental Quality Licensed System Operator who will
be in responsible charge of the system, please provide the following information:
i. Name.
ii. License Number and Class.
iii. Business Address.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY J MAY 11,2079
REQUEST NO. 13: For Bar Circle "S":
a. Please provide an up-to-date system map showing the location of major equipment
including wells, mains, storage tanks, and water treatment equipment. Clearly
identify any easements and equipment that is not Company owned (e.g. backup wells)
b. Please provide a copy of the agreement for any easements or any equipment used by
the Company that is not Company owned.
c. For the Idaho Division of Environmental Quality Licensed System Operator who will
be in responsible charge of the system, please provide the following information:
i. Name.
ii. License Number and Class.
iii. Business Address.
REQUEST NO. 14: Please provide a schedule showing the job title and function of
each current employee of Diamond Bar and Bar Circle o'S". Please indicate which employees, if
any, that Gem State Water plans to retain, and their anticipated function after the acquisition.
Dated at Boise, Idaho, this [-?'^^day of May 2019.
Deputy General
i:umisc:prodreq/bcswl9. l_ejcwh prod reql
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY MAY 17,20194
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS ITTH DAY OF MAY 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPANY, N CASE NOS.
BCS-W-I9-OI/DIA-W-I9-OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
PRESTON CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-mail : prestoncarter(?,? givensp ursl e,v. com
kendrah(P givenspursley. com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NW NATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-mail : Lric.Ne Iseni.rDnw:n:rtulirl, qqlr
,l/
SECRETAR
CERTIFICATE OF SERVICE