20230314Staff 1-28 to GSW.pdf

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 1 MARCH 14, 2023
CLAIRE SHARP
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 8026

Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-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
APPROVAL OF THE ACQUISITION OF THE
ASSETS OF THE WATER BUSINESS OF
VALIANT IDAHO, LLC
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CASE NO. GSW-W-23-01

FIRST 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,
Claire Sharp, Deputy Attorney General, requests that Gem State Water (“Company”) provide the
following documents and information as soon as possible, but no later than
TUESDAY, APRIL 4, 2023.
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 identify the name, job title, location, and
telephone number of the record holder.
RECEIVED
2023 March 14
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 2 MARCH 14, 2023
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.

REQUEST NO. 1: Please provide all Company analysis used for determining the
Purchase Price stated in CONFIDENTIAL Exhibit No. 1, Page 1.

REQUEST NO. 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.

REQUEST NO. 3: Please provide the legal description for the requested service
territory attributed to the Valiant Idaho, Inc. and TIC Utilities, LLC. water business.

REQUEST NO. 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.).

REQUEST NO. 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:

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 3 MARCH 14, 2023
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.

REQUEST NO. 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
b. Fire flow and storage requirements prescribed by the fire authority.

REQUEST NO. 7: Please provide the specified material requirements and construction
details used in the installation of the distribution system piping.

REQUEST NO. 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.

REQUEST NO. 9: Please provide the most recent Idaho Division of Environmental
Quality Sanitary Survey.

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 4 MARCH 14, 2023
REQUEST NO. 10: For each water right used by the system, please provide the Idaho
Department of Water Resources Water Right Numbers (basin and sequence number).

REQUEST NO. 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.

REQUEST NO. 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.

REQUEST NO. 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.

REQUEST NO. 14: Please provide the monthly metered amount of water produced by
each well over the past 5-years?

REQUEST NO. 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”).

REQUEST NO. 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.

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 5 MARCH 14, 2023
REQUEST NO. 17: Please explain the involvement of TIC Utilities, LLC in this
acquisition.

REQUEST NO. 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.

REQUEST NO. 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.

REQUEST NO. 20: Are there any pending claims regarding the assets of the Water
Business?

REQUEST NO. 21: Please describe any legal obligations, beyond water service, that
would be assumed by the Company as a result of the proposed acquisition.

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 6 MARCH 14, 2023
REQUEST NO. 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.

REQUEST NO. 23: Please explain if, and how, the Water Business to be acquired is
interconnected to any other entity’s water systems.

REQUEST NO. 24: Within the proposed modified CPCN No. 293, are there customers
that would be, or are currently, served by another water business?

REQUEST NO. 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.

REQUEST NO. 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)

REQUEST NO. 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.

REQUEST NO. 28: Please provide the book value of assets that Gem State Water will
acquire from Valiant Idaho, Inc. and TIC Utilities, LLC, and the proposed accounting entries if
the acquisition is approved.

DATED at Boise, Idaho, this 14th day of March 2023.

_________________________________
Claire Sharp
Deputy Attorney General

Technical Staff: Rick Keller

i:umisc:prodreq/gsww23.1rnrm prod req 1

FIRST PRODUCTION REQUEST
TO GEM STATE WATER 7 MARCH 14, 2023
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 14TH DAY OF MARCH 2023,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO GEM STATE WATER COMPANY, IN CASE NO.
GSW-W-23-01, BY E-MAILING A COPY THEREOF TO THE FOLLOWING:

PRESTON N CARTER
REBECCA M FITZ
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
[e-mail]

ERIC W NELSEN
NW NATURAL
250 SW TAYLOR ST
PORTLAND OR 97204
E-MAIL: [e-mail]

_________________________________
SECRETARY