20230411GSW to Staff 2-27.pdf

RESPONSES TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 1 OF 2
Preston N. Carter, ISB No. 8462
Rebecca M. Fitz, ISB No. 11874
Givens Pursley LLP
601 W. Bannock St.
Boise, Idaho 83702
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
13988.14[16703222_1.docx]

Attorneys for Gem State Water Company, LLC

BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION
OF GEM STATE WATER COMPANY, LLC
FOR APPROVAL OF ACQUISITION OF
THE ASSETS OF THE WATER BUSINESS
OF VALIANT IDAHO, LLC

Case No. GSW-W-23-01

GEM STATE WATER’S RESPONSES TO
FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF

In response to the First Production Request of the Commission Staff to Gem State Water
Company dated March 14, 2023, Gem State Water Company, LLC, (“Gem State Water,”
“Applicant,” or “Company”), submits the following responses. Responsive documents are
available for download using the link provided in the accompanying email. Confidential
responses and documents are subject to the protective agreement in this case, and are available
for download using a password-protected link that will be provided separately by email. The
password will be provided in a third email.
DATED April 11, 2023.
GIVENS PURSLEY LLP
By
Preston N. Carter
Givens Pursley LLP
Attorneys for Gem State Water Company LLC
RECEIVED
2023 April 11, 4:53PM
IDAHO PUBLIC
UTILITIES COMMISSION
RESPONSES TO FIRST PRODUCTION REQUEST OF COMMISSION STAFF PAGE 2 OF 2
CERTIFICATE OF SERVICE

I certify that on April 11, 2023, a true and correct copy of the foregoing was served upon
all parties of record in this proceeding via electronic mail as indicated below:

Commission Staff Via Electronic Mail
Jan Noriyuki, Commission Secretary
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Suite 201-A
Boise, ID 83714

[e-mail]

Preston N. Carter

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 2
Please provide all documentation used by the Company in performing its due diligence
for the purchase of the water business assets of Valiant Idaho, Inc. and TIC Utilities,
LLC.
Response:
The files the Company used to perform due diligence can be found in GSW-W-23-01
DR 2 Attachments.

GSW-W-23-01
IPUC DR 2
Page 1 of 1
Sponsored by Hank Manilla

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 3
Please provide the legal description for the requested service territory attributed to the
Valiant Idaho, Inc. and TIC Utilities, LLC. water business.
Response:
All area under the Idaho Club development plan (see Exhibit C of Confidential Exhibit
No. 1 of the Direct Testimony of J. Palfreyman for a map), is located within Township
57N and 58N, Range of 01W and 01E.
GSW-W-23-01
IPUC DR 3
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 4
Please provide a thorough and complete description of the system being acquired. This
should include any known deficiencies that need to be addressed to maintain system
integrity and to support growth, as well as any changes/investments that the Company
plans to implement to address deficiencies relative to items included below. Please
include the costs and benefits for any future investments or potential increases in
expense.

a. Processes and methods. This should include processes involved in the delivery of
water and business processes (i.e. billing, maintenance, customer support, etc.);

b. Manpower/staffing, including the amount of labor and the level of
expertise/experience;

c. Equipment/infrastructure/software both direct (i.e. pipes, tanks, and pumps) and
indirect (maintenance equipment, computers, etc.);

d. Policies and standards (i.e. service level, maintenance turnaround time, etc.); and

e. Materials (productive material used for water quality, spare parts inventory, etc.).

Response:
SYSTEM DESCRIPTION:
Golden Tee phase 1&2 10/31/2000 (on the North Side of Hwy 200)
Valve boxes are PVC with cast iron lids, service valves are PVC ball valves. No tracer
wire.
Fire protection by others dry hydrants (still in place)
A dry fire hydrant is a non-pressurized pipe system permanently installed in a water
source such as lakes, streams or ponds that permits the withdrawal of water by drafting
Sponsored by Chris Galati
GSW-W-23-01
IPUC DR 4
Page 1 of 4
from a fire truck to provide a reliable water source for fire suppression close to the
incident.
Some Water System Fire Hydrants N of Hwy 200, where new water main installed 2008
and after. 756’ of 6” water main and one FH installed at realignment of Jim Brown Way,
and along new water mains from well at Hidden Lakes Drive N to Oxbow, W to
Waterdance, N to Jim Brown Way, W. on Idaho Club Dr.

Golden Tee 12th add 2021, new add Oxbow Rd 8” water mains and FH
Idaho Club 04/21/2008
Well site (need to confirm ownership/easement for well site)
Wells 8” casing with 4” column pipe
Well # 1 Depth 173’ with 120 mesh screen from 163’ to 173’,
Well # 2 Depth 163’ with 120 mesh screen from 153’ to 163’
307’ 6’ distribution line to existing 6” mains
Well 1 -50 hp AY Mcdonald 300S50HP66
Well 2 -30 hp Goulds MODEL 320L30
Controls (No details for controls provided)
Well on/off switch by reservoir elevation at booster station #1

Disinfection
Voluntary chlorine disinfection of system, water meets drinking water standards without
disinfection.
Water Treatment Sand Filters (no plans provided)

All water main lines N of Hwy 200 are mostly 6”; except 8” water mains start at Hidden
Lakes Drive and Oxbow, W to Waterdance, N to Jim Brown Way, W on Idaho Club Dr.
At end of Idaho Club Dr before going under Hwy 200 12” pipe, before booster station 1
switch to 2 8” lines. A dedicated Water Booster Pump feed line and another distribution
GSW-W-23-01
IPUC DR 4
Page 2 of 4
line. Pressure relief valve (PRV) #14 at this location. Distribution line changes from 8” to
12” with 1500’ of 12” line from White Cloud E on Idaho Club Dr, and from Upper
Reservoir to SE for future extension.

Booster Station #1 (Manual operation)
2 each 9200 Gallon Storage tanks, one in service, one to be lined this year.
Reservoir filled by well pumps.
Grundfos triplex booster system (need to confirm 20hp) currently owner only uses one
of these pumps, marked on the control panel.

Booster station #2 (Manual Operation)
1 each 9200-gallon Reservoir
Grundfos triplex booster system (need to confirm 20hp) currently owner only uses one
of the pumps, marked on the control panel
Upper Reservoir; Moose Mountain Reservoir, 225,000-gallon tank
To fill the reservoir, manually monitor reservoir level by opening lid, if fill needed
manually operate Booster stations 1 & 2 and monitor Upper Reservoir until full and then
shut down Booster stations.

a. Processes and methods. This should include processes involved in the delivery of
water and business processes (i.e. billing, maintenance, customer support, etc.);
There is one main well house and 2 booster stations. The Idaho Club is served by 2
ground water wells. The water fills 4 reservoirs in various pressure zones and is
provided to the customers through both booster and gravity pressure lines. Mainlines
range from 12” down to 3”. Water is delivered to the customer through unmetered
connections. Fire flow is provided at a rate of 1000 gallons per minute. Gem State
Infrastructure is providing operations using licensed staff and contract operations by E3
consultants.
Billing operations have recently been led by Gem State Water. Customers are billed on
a quarterly basis and at flat monthly rates of $60 per month. The system is currently
unmetered. Customer service is provided through Gem State’s office staff. The Idaho
GSW-W-23-01
IPUC DR 4
Page 3 of 4
Club is performing billing using desktop QuickBooks. After acquisition it is expected that
the customers will be moved to Gem State Water billing, and customer service
processes and will follow all IPUC rules and regulations and tariff. The water system will
also move to Gem State O&M schedule and be run with our customary management
practices.
The Company does not have detailed estimates of the costs but the per customer costs
will likely be higher for the acquired system (compared to its other systems) due to the
remote nature of the system and the distance from the other systems.
b. Manpower/staffing, including the amount of labor and the level of expertise/experience.
The system is currently classified as a distribution 1 system but will likely become a
treatment level 1 once there is iron and manganese removal treatment applied. The
system will likely require daily sampling to keep treatment levels stable. A back up
operator is also required to fulfill the state requirements. As with all systems, there is a
great amount of O&M time that is required for servicing booster pumps, approx. 18 air
reliefs, exercising valves and hydrants, contracting services for approx. 16 PRVs
inspecting of connections, providing one call locating and locating of unmarked lines,
valves and services, site and building maintenance, water monitoring and sampling.
There will be a larger amount of time spent on customer compliance with backflow
devices due to pressure zone extremes, not only irrigation backflow.
The Company believes the increased time required for this system will be higher than the
other Gem State Water systems but does not have detailed cost estimates at this time.
c. Equipment/infrastructure/software both direct (i.e. pipes, tanks, and pumps) and
indirect (maintenance equipment, computers, etc.);
The utility is currently working to install filtration systems on its wells that will treat Iron
and Manganese levels in the water. That project is currently moving forward with an
estimated cost estimate of approximately $400,000.
Future identified projects include Mission SCADA, meter installation, and customers moving
to CUSI billing software. We do not have a cost estimate for those projects at this time.
d. Policies and standards (i.e. service level, maintenance turnaround time, etc.); and
This system will be owned and operated using the same standards of all Gem State
Water systems.
e. Materials (productive material used for water quality, spare parts inventory, etc.).
Unknown. Currently the system is being chlorinated. The system being installed for the
removal for iron and manganese will require treatment chemicals once it is fully operational.
GSW-W-23-01
IPUC DR 4
Page 4 of 4

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 5
Please provide an up-to-date geo-spatial system map showing the location and
elevation of major equipment including wells, distribution piping, storage tanks, booster
pumps, shut-off valves, meters, fire hydrants, and water treatment equipment. Please
also include the following information

a. The make, model, and rating of each well pump motor;

b. The make, model, capacity, and limit switch settings of each pressurized storage
tank;

c. The make, model, capacity, and limit switch settings of each unpressurized storage
tank/reservoir;

d. The make, model, and rating of each booster pump and motor;

e. The make, model, and capacity of all water treatment equipment;

f. The year, make, model, and capacity for backup generation supporting the well
pumps. Indicate if the generation has an Automatic Transfer Switch ("ATS") or if it must
be manually started; and

g. The distribution piping line size and materials specified in the installation.

NOTE: Please provide this map in an electronic format which can be enlarged to identify
all aspects of the system.
Response:
We are currently working with The Idaho Club to obtain this information with the help of
its engineers. We will supplement this response with requested information upon our
receipt of it; however, some information may need to be determined post-close.
Sponsored by Chris Galati
GSW-W-23-01
IPUC DR 5
Page 1 of 1

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 6
If the system includes fire protection, please provide the following:
a. The name and contact information for the fire authority who prescribes
requirement for the system; and Northside Fire District (no records located)
b. Fire flow and storage requirements prescribed by the fire authority.
Response:
Eric Clayton
Northside Fire District
Station 2
479653 Hwy 95
Sandpoint, ID 83864

See technical document 1.25 in the attachment to GSW-W-23-01 IPUC 2 for fire flow
information.
GSW-W-23-01
IPUC DR 6
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 7
Please provide the specified material requirements and construction details used in the
installation of the distribution system piping.
Response:
Please see GSW-W-23-01 IPUC DR 7 Attachments 1 and 2, which are the scans and
record drawings that are in our possession right now; however, they are outdated.
Accordingly, we are working with Valiant and its engineers now to obtain an updated
and complete picture of the system.
Sponsored by Chris Galati
GSW-W-23-01
IPUC DR 7
Page 1 of 1

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 8
Please provide information related to the capacity and sizing of the system and the
ability of the system to meet historical and future system peak demand. Information
would include not only capacity/constraints of/in the system, but also average
consumption and consumption at peak periods.
Response:
We are currently working with The Idaho Club to obtain this information with the help of
its engineers. We will supplement this response with requested information upon our
receipt of it; however, some information may need to be determined post-close.
Sponsored by Chris Galati
GSW-W-23-01
IPUC DR 8
Page 1 of 1

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 9
Please provide the most recent Idaho Division of Environmental Quality Sanitary
Survey.
Response:
Given the newness of the system, IDEQ has not yet performed a sanitary survey. We
have been informed by IDEQ that a sanitary survey is scheduled to be completed in
2023.
GSW-W-23-01
IPUC DR 9
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 10
For each water right used by the system, please provide the Idaho
Department of Water Resources Water Right Numbers (basin and sequence number).
Response:
Please see the Company’s response to GSW-W-23-01 IPUC DR 2, and the document
attached therein titled “2.02 IdahoClub-IDWR-WaterRight-Permit.PDF”.
GSW-W-23-01
IPUC DR 10
Page 1 of 1
Sponsored by Chris Galati

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 11
For each well in the water system, please provide the following:
a. The Idaho Department of Water Resources Well Tag Number (D-Tag Number)
currently on-file with IDWR;
b. Location (Township, Range, Section, and Tract); and
c. The well log.

Response:
Please see GSW-W-23-01 IPUC DR 11 Attachments 1-3.
GSW-W-23-01
IPUC DR 11
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 12
Please provide an estimate of total unaccounted water losses due to leaks, wasted
water, etc. by month over the past 5-years. Please explain how these losses are
estimated.
Response:
We have been informed by Seller, Owner and Operator that they do not have an
estimate of total unaccounted-for water losses due to leaks, wasted water, etc. by
month over the past five years, as none of the customers at the Idaho Club are
metered. Gem State Water plans to install meters for all Idaho Club customers, after
further review of system needs following transaction closing.

GSW-W-23-01
IPUC DR 12
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 13
Please provide the power bills over the past 5-years indicating the amount of electricity
(kilo-watt-hour) used by each well and booster pump.
Response:
We are currently working with The Idaho Club to obtain this information. We will
supplement this response with copies of the power bills upon our receipt of them.
However, due to the ownership dispute with the system, we will only be able to provide
information going as far back as October 2021.
Sponsored by Leslie Abrams-Rayner
GSW-W-23-01
IPUC DR 13
Page 1 of 1

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 14
Please provide the monthly metered amount of water produced by each well over the
past 5-years?
Response:
We are currently working with The Idaho Club to obtain this information. We will
supplement this response upon our receipt of the requested information. However, due
to the ownership dispute with the system, it is unlikely we will be able to provide the full
five years of monthly metered amounts.
Sponsored by Leslie Abrams-Rayner
GSW-W-23-01
IPUC 14
Page 1 of 1

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 15
Please indicate whether any private water, municipal water, or Commission regulated
water utilities overlap or potentially may overlap in the future, as can be determined by
municipal comprehensive plans and impact areas, with the customer service territory of
the Valiant Idaho, Inc. water system. If so, please explain any effect to the requested
Certificate of Public Convenience and Necessity (“CPCN”).
Response:
There are no overlapping or potentially overlapping water utilities in the area.

GSW-W-23-01
IPUC DR 15
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 16
Please provide a map that outlines the borders of all individual water utility systems
operated by Gem State Water in the State of Idaho. Please provide this map in an
electronic “pdf” format which can be scaled and enlarged so that Staff can identify each
system and their spatial relationship to one another.
Response:
Please see GSW-W-23-01 IPUC DR 16 Attachment 1.
GSW-W-23-01
IPUC DR 16
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 17
Please explain the involvement of TIC Utilities, LLC in this acquisition.
Response:
TIC Utilities, LLC is an operating subsidiary of Valiant Idaho, Inc. Valiant owns the utility
assets and the assets are operated by TIC Utilities. The manager of TIC Utilities is Bill
Haberman, who is also the managing member of Valiant. Under the Water System
Asset Purchase Agreement (Confidential Exhibit No. 1 of the Direct Testimony of J.
Palfreyman), TIC is “Operator.”
GSW-W-23-01
IPUC DR 17
Page 1 of 1
Sponsored by Hank Manilla

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 18
Are there any lawsuits between the selling party and any other entity. If so, please
include the following:
a. Case No.;
b. County filed in;
c. Name of parties;
d. Case caption;
e. Date filed; and
f. Any other relevant information.

Response:
Please see GSW-W-23-01 IPUC DR 2 Attachments 2.03 and 2.08 for the requested
information.
GSW-W-23-01
IPUC DR 18
Page 1 of 1
Sponsored by Eric Nelsen

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 19
Please describe all resolved lawsuits from 2008 to present between the selling parties
and any other entity regarding CPCN No. 293, or the proposed area of the Water
Business. Please include the following:
a. Case No;
b. County filed in;
c. Name of parties;
d. Case caption;
e. Date filed;
f. Date resolved;
g. The outcome of the case; and
h. Any other relevant information.
Response:
There are no lawsuits from 2008 to present between the selling parties and any other
entity regarding Gem State Water’s CPCN No. 293 (Spirit Lake East). For information
on lawsuits from 2008 to present between the selling parties and any other entity
regarding the proposed area of the Water Business, please see the Company’s
response to GSW-W-23-01 IPUC DR 18.
GSW-W-23-01
IPUC DR 19
Page 1 of 1
Sponsored by Eric Nelsen

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 20
Are there any pending claims regarding the assets of the Water Business?
Response:
There is a pending mortgage regarding the assets of the Water Business, but the
Company is requiring that such claim be released as a condition to Closing. See
Confidential Exhibit No. 1, Section 6(c).
GSW-W-23-01
IPUC DR 20
Page 1 of 1
Sponsored by Eric Nelsen

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 21
Please describe any legal obligations, beyond water service, that would be assumed by
the Company as a result of the proposed acquisition.
Response:
Please see Confidential Exhibit No. 1, Section 5 and its Exhibit A.

GSW-W-23-01
IPUC DR 21
Page 1 of 1
Sponsored by Eric Nelsen

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 22
The Company anticipates adding new customers as The Idaho Club development
expands. Have the legal issues regarding water service to that area been
fully resolved? Please explain.
Response:
To the Company’s knowledge, the legal issues regarding water service to that area
have been fully resolved.
GSW-W-23-01
IPUC DR 22
Page 1 of 1
Sponsored by Eric Nelsen

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 23
Please explain if, and how, the Water Business to be acquired is interconnected to any
other entity’s water systems.
Response:
The Water Business is not interconnected to any other entity’s water system.
GSW-W-23-01
IPUC DR 23
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 24
Within the proposed modified CPCN No. 293, are there customers that would be, or are
currently, served by another water business?
Response:
Within the proposed modified CPCN No. 293, there are no customers that would be, or
are currently, served by another water business.

GSW-W-23-01
IPUC DR 24
Page 1 of 1
Sponsored by Leslie Abrams-Rayner

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 25
Please provide a schedule showing the rates and other charges that Gem State Water
intends to charge customers of Valiant Idaho, Inc. and TIC Utilities, LLC.
Response:
The Company is not proposing to change rates or charges as a part of the acquisition.
The monthly fee for water service is $45.00 (with a late payment fee of 15% per annum,
compounded monthly) and the water hookup fee for new service is $2,500.
GSW-W-23-01
IPUC DR 25
Page 1 of 1
Sponsored by Hank Manilla
Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response
Request No.: GSW-W-23-01 IPUC DR 26
Please provide the financial statements that Gem State Water receives as stated in the
purchase sale agreement. (See Page 16 of 27, CONFIDENTIAL Exhibit No. 1)
Response:
See data files provided in response to GSW-W-23-01 IPUC DR 2 in the folder titled
"CONFIDENTIAL DR 2 Tax Accounting Finance".
GSW-W-23-01
IPUC DR 10
Page 1 of 1
Sponsored by Hank Manilla

Rates & Regulatory Affairs
GSW-W-23-01
In the Matter of Gem State Water Company, LLC's Application for Approval of the
Acquisition of Assets of Valiant Idaho, LLC
Data Request Response

Request No.: GSW-W-23-01 IPUC DR 27
If Valiant Idaho, Inc. and TIC Utilities, LLC customers have metered service, please
provide the consumption data by customer for the last two years.
Response:
The customer connections are currently not metered and so consumption data are not
available.
GSW-W-23-01
IPUC DR 27
Page 1 of 1
Sponsored by Hank Manilla