20180330Staff 24-33 to NW Natural.pdf

BRANDON KARPEN
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 7956
RECEIVED
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Street Address for Express Mail:
472W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
NORTHWEST NATURAL WATER COMPANY,
LLC TO ACQUIRE FALLS WATER COMPANY
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
NORTHWEST NATURAL
WATER COMPANY, LLC
The Staff of the Idaho Public Utilities Commission request that Northwest Natural Water
Company, LLC (Company; NW Natural) provide the following documents and information as
soon as possible, by FRIDAY, APRIL 20,2018.
This Production Request is 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. The Company is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
SECOND PRODUCTION REQUEST
TO NORTHWEST NATURAL
WATER COMPANY
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cAsE NO. FLS-W-18-01
I MARCH 30,2018
person preparing the document, and the name, location and phone number of the record holder
and if different the witness who can sponsor the answer at hearing if need be. 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. 24: How many state certified Water Treatment Operators or Water
Distribution Operators are currently employed by NW Natural?
REQUEST NO. 25: Assuming NW Natural's acquisition of Falls Water is approved by
the Commission, please separately identify how many state certified Water Treatment Operators
or Water Distribution Operators will be employed by Falls Water and NW Natural?
REQUEST NO. 26: In Staff s First Production Request, Request No. 18, Staff sought
information on anticipated capital improvement projects. How were these projects selected and
prioritized?
REQUEST NO. 27: Please refer to Staffls First Production Request, Request No. 18.
Please provide the water/wastewater background (e.g., including level and number of
certifications, years of water experience, PE designation, college or other training) of employees
and/or outside parties who identified the anticipated capital improvement projects. Please
identify each person as an employee or a non-employee of NW Natural.
REQUEST NO. 28: Has NW Natural made commitments to any party, including
regulators or other government entities, to embark on and,/or complete any project referred to in
Stafls First Production Request, Request No. 18?
REQUEST NO. 29: Please refer to Staff s First Production Request, Request No. 18.
Are any of the listed projects necessary over the next five years to comply with federal and/or
state standards?
SECOND PRODUCTION REQUEST
TO NORTHWEST NATURAL
WATER COMPANY 2 MARCH 30,2OI8
REQUEST NO. 30: Will NW Natural commit to completing any of the projects referred
to in Staffls First Production Request, Request No. 18, within a certain time frame? Please list
the project(s), and the scope clearly defined; e.g., replace'/omile of 8 inch main, along with the
asssumed completion date.
REQUEST NO. 31: Please provide total a payroll expense by employee, including
wages and salaries, for calendar year 2017. What changes do you anticipate for calendar year
20t8?
REQUEST NO.32: How will NW Natural and/or Falls Water account for the
transaction outlined in section L05(b) of Exhibit No. 2, and will it affect rates for Falls Water
customers?
REQUEST NO. 33: Please provide the two most recent bond ratings from all major
credit rating agencies that issue ratings on NW Natural's outstanding bonds.
Dated at Boise, Idaho, this 30* day of March 2018.
Karpen
Deputy Attorney General
Technical Staff: Bentley Erdwurm (24-30)
Brad Long (31-33)
i:umisc:prodreq/flswl8. lbkbe prod req2
SECOND PRODUCTION REQUEST
TO NORTHWEST NATURAL
WATER COMPANY J MARCH 30,2018
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 3oth DAY OF MARCH 2018,
SERVED THE FOREGOING SECOND PRODUCTION REQUEST OF THE
COMMISSION STAFF TO NORTHWEST NATURAL WATER COMPANY, LLC IN
CASE NO. FLS-W-I8.OI, BY MAILING A COPY THEREOF, POSTAGE PREPAID,
TO THE FOLLOWING:
MICHAEL C CREAMER
PRESTON N CARTER
GIVENS PURSLEY LLP
60I W BANNOCK ST
BOISE ID 83702
E-MAIL: mcc@ givenspursley.com
prestoncarter@ givenspursley. com
ZACHARY D KRAVITZ
NORTHWEST NATURAL GAS CO
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE