20220920Staff 44-46 to Gem State.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BARNO. II2O2
Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF GEM STATE WATER
COMPANY LLC'S APPLICATION FOR AN
ORDER AUTHORIZING AN INCREASE IN
ITS RATES AI\D CHARGES FOR WATER
SERVICE IN THE STATE OF IDAHO
CASE NO. GSW-W-22-01
THIRD PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO GEM STATE WATER
COMPANY
Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Riley Newton, Deputy Attomey General, requests that Gem State Water ("Company") provide
the following documents and information as soon as possible, but no later than TUESDAY,
ocToBER 11, 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, identification of the original water system,
allowing the data to be sorted accordingly. Include the name, job title, and telephone number of
THIRD PRODUCTION REQUEST
TO GEM STATE WATER
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I SEPTEMBER2O,2022
the person preparing the documents. Please also identifu the name, job title, location, and
telephone number of the record holder.
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. 44: Please provide a reconciliation of the Company's response to
Production Request No. 1 to the Company's Exhibit Nos. 1 and2.
REQUEST NO. 45: Regarding the Company's response to Production Request No. 13,
please provide a justification for overtime hours paid, specifically explaining why the Field
Manager and Operator in Training receive 104 hours of overtime per year and the Billing
Administrator receives 156 hours ayear of overtime. Please provide any calculations and
assumptions.
REQUEST NO. 46: Regarding the Company's response to Production Request Nos. 12
and 14, please provide complete copies of the Company's life insurance policies and health
insurance policies.
DATED at Boise, Idaho, this /9h Ou, of Septemb er 2022.
Riley Newton
Deputy Attomey General
i:umisc:prodreq/gsww22. I mrm prod req 3
THIRD PRODUCTION REQUEST
TO GEM STATE WATER 2 SEPTEMBER2O,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF SEPTEMBER 2022,
SERVED THE FOREGOING THIRD PRODUCTION REQUEST OF' TITE
COMMISSION STAFF TO GEM STATE WATER COMPANY, IN CASE NO.
GSW-W.2Z-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
E-MAIL : leslie@ gemstate-water.com
ERIC WNELSEN
ADAM RUE
NWNATURAL
250 SW TAYLOR ST
PORTLAND OR 97204
E-MAIL: [e-mail]
SECRET Y
CERTIFICATE OF SERVICE