20220815Staff 1-19 to Gem State.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
[phone]
IDAHO BAR NO. II2O2
Street Address for Express Mail:
I 1331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attomey for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF GEM STATE WATER
COMPAIYY LLC'S APPLICATION FOR AN
ORDER AUTHORIZING AN INCREASE IN
ITS RATES AND CHARGES FOR WATER
SERVICE IN THE STATE OF IDAHO
CASE NO. GSW-W-22-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO GEM STATE WATER
COMPAI{Y
Staffof the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attorney General, requests that Gem State Water ("Company") provide
the following documents and information as soon as possible, but no later than TUESDAY,
SEPTEMBER 6, 2022.
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 identifu the name, job title, location, and
telephone number of the record holder.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER
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1 AUGUST 15,2022
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files on CD with formulas intact and enabled.
REQUEST NO. 1: Please provide a copy of or access to the Company's QuickBooks
file
REQUEST NO.2: Please provide a copy of the invoice for the purchase of the truck
included in the Company's Application.
REQUEST NO.3: Please provide the supporting documentation including any cost
benefit analysis used by the Company justiffing the purchase of the truck.
REQUEST NO. 4: Please provide the supporting documentation for the increase in the
fuel cost as shown in Exhibit No. 2 (D).
REQUEST NO. 5: Please provide the supporting documentation showing the number of
meters planned on being replaced, dates of replacement, and costs of each replacement.
REQUEST NO. 6: Please provide the supporting documentation for the expiring lease
amount as shown in Exhibit No. 2 (D); Account64l-42 Rental property & Equipment.
REQUEST NO. 7: Please provide copies of all bids received for the lease of the new
office space and a copy of the signed lease agreement.
REQUEST NO. 8: For each well that the Company owns, please provide a list of all
water tests required, the frequency of each test, and the cost of each test.
REQUEST NO. 9: For the customers listed in Exhibit No. 5 (A), please provide the
meter size for each customer. Please provide a list of customers that would receive a customer
charge for a larger than one-inch meter. Please include the usage for those customers with larger
than one-inch meters.
FIRST PRODUCTION REQUEST
TO GEM STATE WATER 2 AUGUST 15,2022
REQUEST NO. l0: Please explain why the Company did not include any fixed charges
for meters larger than one inch in the Company's rate proof in Exhibit No. 5 (A).
REQUEST NO. 11: Please provide a list of all capital projects the Company has
completed for each system since purchasing the system. Please include the costs of each project
as well as completion dates.
REQUEST NO. 12: Please describe how the parent company allocates costs to Gem
State Water. Please provide a list of all allocated costs from the parent company along with any
supporting documentation for the allocation method used.
REQUEST NO. 13: Please provide the supporting documentation for the allocation of
salaries to Capitalized Labor, Gem State, Pelican Point, and GSI.
REQUEST NO. 14: Please provide the supporting documentation for the insurance
benefits for the Company employees.
REQUEST NO. 15: Please provide the number of employees by classification and
salary of each classification of employee currently employed by the Company.
REQUEST NO. 16: Please provide all analysis and compensation studies supporting the
wages for each employee classification.
REQUEST NO. 17: Please provide a description of the Company's practices for
determining uncollectible debts, including the criteria used in determining when an account is
uncollectible? Please also provide the actual net write-offs for the test year separated by each
water system.
REQUEST NO. 18: Please provide a list of any events that occurred during the test year
that may have caused infrequent expense levels. Please provide a narrative on how these events
FIRST PRODUCTION REQUEST
TO GEM STATE WATER J AUGUST 15,2022
affected the Company's operating expenses (for example loss of power, storm damage or other
extreme weather conditions, etc.).
REQUEST NO. 19: Please provide an allocation schedule that shows how overheads
such as vehicles, executive personnel, materials and supplies, are allocated among the dififerent
water systems, plant, and expense accounts.
DATED at Boise, Idaho, this l5m day of August2022.
Riley Newton
Deputy Attorney General
i:umisc:prodreq/gsww22. lmrm prod req I
FIRST PRODUCTION REQUEST
TO GEM STATE WATER 4 AUGUST 15,2022
CERTIFICATE OF SERVICE
r HEREB' cERrIFy rHAr I HAVE rHrs tiforoF AUGU sr 2022,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF TIIE
COMMISSION STAFF TO GEM STATE WATER COMPAI\TY, IN CASE NO
GSW-W-22-OI, BY E.MAILING A COPY THEREOF TO THE FOLLOWING:
LESLIE ABRAMS.RAYNER
GENERAL MANAGER
GEM STATE WATER CO
PO BOX 3388
COEUR D'ALENE ID 83816
ERIC W NELSEN
ADAM RUE
NWNATURAL
250 SW TAYLOR ST
PORTLAND OR972O4
E-MAIL: [e-mail]
Jo,4Z-r<
secneranv/
CERTIFICATE OF SERVICE