20191217Staff 1-3 to Gem State Water.pdf

MATT HT]NTER
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, rDAHO 83720-0074
[phone]
IDAHO BARNO. I0655
IN THE MATTER OF THE APPLICATION OF
GEM STATE WATER COMPANY, LLC FOR
APPROVAL OF ACQUISITION OF THE
ASSETS OF THE WATER BUSINESS OF
HAPPY VALLEY WATER SYSTEM INC. AND
BITTERROOT WATER CO., INC.
FIRST PRODUCTION REQUI]ST
TO GEM STATE WATER
CASE NO. GSW-W-19-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
GEM STATE WATER
COMPANY, LLC
RECEIVED
ll9 OiC l7 PH t: 02
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUITE 201.4
BOISE, ID 83714
Attomey lbr the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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The Staff of the Idaho Public Utilities Commission requests that Gem State Water
Company, LLC (Cem State; Company) provide the lollowing documents and information as
soon as possible, by TUESDAY, JANUARY 7,2020.
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 ofProcedure must include the name and phone number ofthe
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. Reference IDAPA
31.01.01.228.
I DECEMBER 17,2019
In addition to thc written copies provided as response to the qucstions, please provide all
Excel and electronic liles on CD with formulas activated.
REQUEST NO, 1: In reference to Confidential Exhibit I on page l2 under the
Bitterroot Owned Real Property section l, subsection C. The description provided in subsection
C describes Lot I in Block 1, but the Parcel Number provided corresponds to Lot 1 in Block 3.
a. Please identily which Parcel is being included in the Asset Purchase Agreement.
b. In addition, please identify any assets on the Parcel used in or neccssary for
conducting of business.
REQUEST N0.2: Have there been any changes to the configuration of the Bitterroot
system since the Company's filing in Case No. RIC-W-I7-01 (July 28, 2017)? If so, ptease
provide the following:
a. An updated system map showing the location of major equipment including wells,
pipes, storage tanks, booster pumps, shut-off valves, meters, fire hydrants,
and water treatment equipment.
b. A description of the changes that have been made since July 28,2017, including the
sizes and ratings of any new equipment. Please identily the location
of each change on the map described in (a).
REQUEST NO.3: In reference to the letter dated April 16,2019 to the Bitterroot Water
Company from the Idaho Department ofEnvironmental Quality on the subject of: System
Disapproval for Material Modifications without Engineered Design Basis review and approval
for Bitterroot Water Company, ID1280260 - Action Required. Please provide the status of this
System Disapproval and how it will affect the acquisition of the Bitterroot Water Company.
FIRST PRODUCTION RF],QUEST,f0 (iEM STATF] WAI'LR )DECEMBER 17,2019
dDated at Boise, Idaho, this / 7 day of December 2019.
Matt Hunter
Deputy Attorney General
i/utility/umisc/production rcqucstygswwl9.Imhme prod req I
FIRST PRODUCTION REQUEST
TO GEM STATE WATER )DECEMBER 17,2019
CERTIFICATE OF SERVICE
I HERI,BY CER]IFY THAT I HAVE THIS ITTH DAY OF DECEMBER2O19.
SERVED THE FORECOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPANY, LLC, IN CASE NO.
GSW.W.19-01, BY MAILING A COPY THI]REOF, POSTAGE PREPAID, TO THE
FOLLOWING:
PRESTON N CARTER
CHARLIE S BASER
GIVENS PURSLEY LI,P
60I WBANNOCKST
BOISE ID 83702
E-MAIL: prcstoncartcr /nl:givensDurs c(]tlt
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-MAIL: eric.nqlscnl.rln$natural.com
SECRETARY
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clT :rrliebaser(a)g ivensDurslev.con'r
kendrahtalgir, ensDursley.com
CERTIFICATF, OF SERVICE
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