20190320Staff 1-18 to Gem State .pdf

IN THE MATTER OF THE APPROVAL OF
ACQUISITION OF THE ASSETS OF SPIRIT
LAKE EAST WATER COMPANY AND
LYNNWOOD WATER; FOR AMENDMENT
AND TRANSFER OF SPIRIT LAKE EAST
WATER COMPANY' S CERTIF'ICATE OF
PUBLIC CONVENIENCE AND NECESSITY
(NO. 293); AND REQUEST FOR MODIFIED
PROCEDURE
CASE NO. SPL-W.19.01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO
GEM STATE WATER
COMPANY
--, r'.4 _ tr ,r hI .. i,:1.. ,-- I l.i 1: lJ
i,:il 20 Pfi L: l9
!.^
U
Street Address for Express Mail:
472 W, WASHINGTON
BOISE, IDAHO 83702-5918
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
)
)
)
)
)
)
)
)
)
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Edward Jewell, Deputy Attorney General, request that Gem State Water Company (Gem State
Water) provide the following documents and information as soon as possible, or by
WEDNESDAY, APRrL 10, 2019.
This Production Request is continuing, and Gem State Water 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 produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations. Gem State Water is reminded that responses
pursuant to Commission Rules of Procedure must include the name and phone number of the
person preparing the document, and the name, location and phone number of the record holder
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY 1 MARCH 2O,2OI9
EDWARD JEWELL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03t4
IDAHO BAR NO. 10446
and if different the witness who can sponsor the answer at hearing if need be. Reference IDAPA
31.0t.0t.228.
In addition to the written copies provided as response to the questions, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Mr. Palfreyman's testimony includes anrtemization of charges that
currently apply to Lynnwood Water customers. See Exhibit 2, Attachment2, Lynnwood Water
Price List. Please describe more fully the circumstances under which each fee applies:
a) Account Change (Account Transfer Fee)
b) Meter Set
c) Turn On Fee
d) Bounce Check Charge (lttSF Fee)
e) Fin Chg (Finance Charges on Overdue Balance)
$ 3s.00
$4,500.00$ 9s.00$ 3s.00
1%
REQUEST NO. 2: For the Exhibit identified in Request No. 1, please provide cost
justification for those fees and charges, if available.
REQUEST NO. 3: In the Exhibit identified in Request No. 1, there are several items
that have no associated price listed. Please explain the purposes for those items. Are there fees
associated with these items? If so, please provide the missing prices.
REQUEST NO. 4: With respect to Lynnwood Estates, how many lots remain that could
still be connected to the system and charged a Meter Set (fee)? How many times has Lynnwood
Water collected a Meter Set (fee) since Ms. Rayner assumed ownership of the system in 2015?
REQUEST NO. 5: Please provide electronically monthly billing records for Lynnwood
Water showing monthly usage and monthly billed amount since January 2016. Please specify
units for monthly billed usage. For billing periods where usage is less than the water allotment
in the base fee, please provide actual usage (even though there may be no incremental charge for
the usage).
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY 2 MARCH 2O,2OI9
REQUEST NO. 6: Please provide financial statements for Lynnwood Water from the
time Ms. Rayner acquired the system to present.
REQUEST NO. 7: Please provide a listing of all plant in service for Lynnwood Water,
along with the in-service dates, original costs, and depreciation rates.
REQUEST NO. 8: Please provide a schedule showing both budgeted and actual
expenses for this acquisition.
REQUEST NO. 9: Please provide the location where accounting, financial, and
customer records will be kept should the purchase be approved.
REQUEST NO. 10: Does Gem State Water intend to provide customers with notice of
Gem State Water's Application? If not, please explain why it does not wish to notifu customers.
If a document has already been drafted, please provide a copy and explain how it will be
delivered to customers.
REQUEST NO. 11: If the Commission approves the sale of Spirit Lake East and
Lynnwood Water, does Gem State Water intend to notify its customers of the purchase of the
water system? If a document has already been drafted, please provide a copy and explain how it
will be delivered to customers.
REQUEST NO. 12: When are Spirit Lake East and Lynnwood Water meters currently
read? Are customers billed each month? If not, when are bills issued? Does Gem State Water
plan on maintaining the current schedule for meter reading and billing?
REQUEST NO. 13: Will Gem State Water continue to bill all customers using the same
billing format and billing system currently used by Spirit Lake East?
REQUEST NO. 14: Please identify any expected operational efficiencies or
opportunities for sharing overhead costs attributable to expanding the number of water utilities
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY J MARCH 2O,2OI9
owned directly or indirectly by Northwest Natural in Oregon, Washington and Idaho. Please
explain whether and how Spirit Lake East and Lynnwood Water customers will share in these
benefits.
REQUEST NO. 15: Please explain how and where Spirit Lake East and Lynnwood
Water service requests and customer service questions will be addressed post-acquisition.
REQUEST NO. 16: In reference to Mr. Palfreyman's direct testimony statement,
"However, like many water utilities, the water systems, and Spirit Lake in particular, are in need
of capital investment to support system growth and maintain system integrity." (Palfreyman, DI
at 5, lines 9-11). Please provide all the identified capital investments for Spirit Lake and
Lynnwood Water. In addition, provide when Gem State Waterplans on making the capital
investments and the estimated cost of the investment.
REQUEST NO. 17: Please provide an as-built system map for Lynnwood Water.
Please include the location of wells and pumps, main/distribution systems, and areas/lots served
by Lynnwood Water.
REQUEST NO. 18: Please provide any available cost-based justification for the rates of
Lynnwood Water, including the monthly water base fee, the water allotment included in the base
fee, and the usage charges by rate tier. If no cost-based justification exists, please explain why
the fees and charges are appropriate.
Dated at Boise, Idaho, tfris l0wday of Mar ch20l9.
Deputy
i:umisc:prodreq/splwl9. lejitcwhbeme prod reql
FIRST PRODUCTION REQUEST
TO GEM STATE WATER COMPANY 4
General
MARCH 2O,2OI9
(
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 2OTH DAY OF MARCH 2019,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAF'F TO GEM STATE WATER COMPANY, N CASE NO.
SPL-W.19.01, BY MAILING A COPY THEREOF, POSTAGE PREPAID, TO THE
FOLLOWNG:
PRESTON CARTER
GIVENS PURSLEY LLP
601 W BANNOCK ST
BOISE ID 83702
E-mail : prestoncarter(Ogivensrrursley.com
kendrah@ givenspursley. com
ERIC W NELSEN
SR REGULATORY ATTORNEY
NWNATURAL
220 NW 2ND AVE
PORTLAND OR 97209
E-mail: Eric.Nelsen@.nwnatural.com
-L,4Art--
-
CERTIFICATE OF SERVICE