20210322Staff 1-9 to GSW.pdf

EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. 10446
IN THE MATTER OF THE APPLICATION
OF GEM STATE WATER COMPANY, LLC
FOR APPROVAL OF ACQUISTION OF Trm
ASSETS OF THE WATER BUSINESS OF
TROY HOFFMAN WATER CORPORATION,
INC.
i'i l;';i f; iY H#
Street Address for Express Mail:
1I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, TD 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
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CASE NO. GSW-W-21-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO GEM
STATE WATER COMPANY
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Gem State Water Company,LLC
(Company) provide the following documents and information as soon as possible, or by
MONDAY, APRIL 12,2021.
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 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
31.01.0r.228.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER MARCH 22,202II
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: The Company's Application states that the Troy Hoffman water
system is designed to supply fire flows. Application at7. lnthe 2016 DEQ Sanitary Survey, two
fire hydrants were identified as not having sufficient fire flow. Id at 5.
The system does not provide adequate fire flow as established by the
Coeur d' Alene Fire Department to two fire hydrants installed on 6-inch
distribution main. As per Idaho Rules for Public Drinking Water
Systems (Rules) 58.01.08.003.52 "adequacy of the water system fire
flow capacity is determined by local fire authority." Lack of adequate
fire flow presents a risk of damage to main in the event fire pumps were
connected to hydrants. In order to prevent this, operators have notified
the Coeur d'Alene Fire Department regarding this concern. In response
the Fire Department does not recognize the two hydrants supplied by
the system. Rather, fire flow is provided to the subdivision from four
hydrants supplied by the City of Coeur d'Alene Water Department and
located at Troy, Margaret, and Anne Avenues, and Easy Street.
a) Please explain why the Troy Hoffrnan water system design fails to meet fire flow
requirements.
b) Please provide a map of the Troy Hoffman fire flow system including locations of all
fire hydrants and fire flow capability at each individual hydrant. Identiff the two
hydrants that do not provide adequate fire flow as described in the DEQ 2016 Sanitary
Survey.
c) Please provide a map that shows locations of the four hydrants supplied by the City of
Coeur d'Alene for fire flow.
d) Please provide copies of agreements between Troy Hoffman and the City of Coeur
d'Alene Water Department for fire flow.
e) Please explain what actions have been taken to prevent the Coeur d'Alene Fire
Department from connecting to the two Troy Hoffman hydrants identified in the DEQ
2016 Sanitary Survey and potentially damaging the water system. If no actions have
been taken to prevent connection by the Coeur d'Alene Fire Department, please explain
why not.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER MARCH 22,202I2
REQUEST NO.2: Please explain how and when all deficiencies, requirements, and
recommendations listed in the 2016 DEQ Sanitary Survey were resolved. If deficiencies,
requirements, and recommendations have not been resolved, please explain why not, what actions
are taking place to resolve them and when they will be completed.
REQUEST NO.3: Please provide electronic copies of all water quality test results and
reports conducted since the 2016 DEQ Sanitary Survey.
REQUEST NO. 4: Please describe how the Company will manage the transfer of Troy
Hoffrnan water rights if the transaction is approved by the Commission. If an Idaho Department of
Water Resources Form 42-248142-1409 (Notice of Change in Water Right Ownership) has already
been submitted, please provide a copy.
REQUEST NO. 5: In reference to Confidential Exhibit No. 1, Page 11, under the
"Schedule 2. Assets," subsection (b), the descriptions for the real property parcel, buildings,
fixtures, structures, and improvements have information that is incomprehensible. For example, the
property description as written does not match the general location of the property, and some of the
items listed in the table contain potential mistakes and typos. Please review and verifu this
document for accuracy and provide a corrected version.
REQUEST NO. 6: In Bullet 22, onpage 6 of the Application, the Company states,
"Transaction-related costs related to the acquisition have been incurred by NW Natural Holdings,
not by Gem State Water, related to activities including due diligence, environmental consultants,
research, legal, travel and negotiations. The costs will not be passed to Gem State Water and will
not be included in any rate case filings." Will the acquisition costs in this case be treated similarly
to the transaction-related costs and if not, please explain how the Company plans to address the
acquisition costs in future proceedings?
REQUEST NO. 7: Please identiff the "Assumed Liabilities" included in the Purchase
Price as shown on page I of the Confidential Exhibit No. l.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER MARCH 22,2021J
The following questions pertain to the 2019 Annual Report submitted to the Idaho Public Utilities
Commission on March 31,2020, specifically the balance sheet, where on page 8 of l3 it shows
Other Long-Term Debt of $16,656. This debt is detailed on page 9 of 13 as being owed to the
following lenders:
All Service Electric - Year-end Balance of $1,661.00
Northstar - Year-end Balance of $1,715
Dalton Square - Year-end Balance of $13,279.00
REQUEST NO. 8: Please provide the loan documents for these loans.
REQUEST NO. 9: These loans appear to be with affiliated companies. Therefore, please
demonstrate that these loans were obtained at the lower of cost or market. Please provide the
documentation that ensures that these loans do not shift costs from the non-regulated affiliate to the
regulated water company.
DATED at Boise,Idaho, this 22"d day of March2}2l
W *--Lt
Edward J6s€$
Deputy Attorney General
i:umisc:prodreq/gsww2l. lejksk prod reql
FIRST PRODUCTION REQUEST
TO GEM STATE WATER 4 MARCH 22,202I
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF MARCH 2020,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPANY, N CASE NO.
GSW-W-2I-01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWING:
PRESTON N CARTER
CHARLIE S BASER
GJVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
charliebaser@ gi venspursley.com
kendrah@ givenspursley.com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
250 SW TAYLOR ST
PORTLAND OR 97204
E-MAIL: [e-mail]
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SECRETARY
CERTIFICATE OF SERVICE