20221013Staff 54-62 to Gem State.pdf

RILEY NEWTON
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITTES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720.0074
[phone]
IDAHO BAR NO. II2O2
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Street Address for Express Mail:
I I33I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, TD 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 AND CHARGES FOR WATER
SERVICE IN THE STATE OF IDAHO
CASE NO. GSW-W-22-01
FIFTH 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 Attorney General, requests that Gem State Water ("Company") provide
the following documents and information as soon as possible, but no later than
THURSDAY, NOVEMBER 3, 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
FIFTH PRODUCTION REQUEST
TO GEM STATE WATER
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ocToBER 13,2022
the person preparing the documents. Please also identiff 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. 54: Please provide supporting documentation for all contract labor
services expenses for the test year. Please include invoices, work papers, and a description of the
services received.
REQUEST NO. 55: Please provide supporting documentation for every expense booked
to the miscellaneous expense account for the test year. Please include invoices, workpapers,
journal entries, and any additional documentation to support these expenses.
REQUEST NO. 56: Following up to Production Request No. 13, please provide job
descriptions for all positions at the Company.
REQUEST NO. 57: Please provide any matrix or methodologies the Company used to
determine the appropriate number and compensation of employees. Please include any labor
studies performed, whether intemally or externally.
REQUEST NO. 58: Please provide a breakdown showing the percentage and dollar
amount of labor expense allocated to Gem State (both capitalized and expensed), Pelican Point,
and GSI, for each staff position.
REQUEST NO. 59: Please provide copies of the Company's State Income Tax retum
for 2021with supporting schedules and worksheets.
REQUEST NO. 60: Please provide copies of the Company's Federal lncome Tax retum
for 2021with supporting schedules and worksheets.
REQUEST NO. 61: Please provide a schedule of deferred taxes for the last three years
FIFTH PRODUCTION REQUEST
TO GEM STATE WATER 2 ocToBER 13,2022
REQUEST NO. 62: Please provide supporting documentation for the truck purchased in
2022. Please include in your response a copy of the invoice, the year, make and model, mileage,
and fuel type. Also include the intended use of the asset, estimated yearly mileage, and primary
users. Please include any cost benefit analysis for the truck.
-#DATED at Boise, Idaho, this | ) day of October 2022.
Riley Newton
Deputy Attorney General
i:umisc:prodreq/gsww22. lmrmsprod req 5
FIFTH PRODUCTION REQUEST
TO GEM STATE WATER 3 ocroBER 13,2022
CERTIFICATE OF SERYICE
I HEREBY CERTIFY THAT I HAVE THIS I3TH DAY OF OCTOBER 2022,
SERVED THE FOREGOING FIFTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPAI\IY, 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
E-MAIL: [e-mail]
ERIC W NELSEN
ADAM RUE
NWNATURAL
250 SW TAYLOR ST
PORTLAND OR 97204
E-MAIL: [e-mail]
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SECRE:TXRY-
CERTIFICATE OF SERVICE