20200407Application.pdf

RECEIVED
2020 April 7PM2:04
IDAHO PABLIC
UTILITIES COMMISSION
PrestonN. Carter (ISB No. 8462)
Givens Pursley LLP
601 W. Bannock St.
Boise,ID 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@ givenspursley. com
15081876_3.docx [3988-9]
Attorneysfor Gem State Water Company, LLC
IN THE MATTER OF THE
APPLICATION OF GEM STATE
WATER COMPANY,Lrc FOR COVID-
19 COST DEFERRALS
Preston N. Carter
Givens Pursley LLP
601 W. Bannock St.
Boise,ID 83702
Telephone: [phone]
Facsimile: (208) 388-l 300
prestoncarter@givenspursley. com
kendrah@ givenspursley. com
BEFORE THE IDAHO PUBLIC UTILITIES COM1VIISSION
Gern State Water Company, LLC ("Gem State Water" or "Company") files this
application to defer costs associated with the COVID-I9 public health emergency pursuant to the
Idaho Public Utility Commission ("Commission") Rules of Procedure 52 and Idaho Code $ 61-
524.\n support of this Application, Gem State Water states the following.
Please serve all notices and communications with regard to this Application upon:
Case No. GSW-W-20-!L
Appr,rcltIoN oF Gnpr SrarE WATER
CouraxY, LLC To DprrR Cosrs
Assocu,roo Wrrn COVID-l9 Punr,rc
Hpalrn E*rpncrxcy
Eric W. Nelsen
Senior Regulatory Attorney
NWNatural
220 NW 2nd Ave.
Portland, Oregon 97209
Telephone: [phone]
Eric.Nelsen@nwnatural. com
BlcxcRouxo
l. Gem State Water is a regulated water utility located in Coeur d'Alene that
provides service to approximately 2,090 customers through 836 connections in northern Idaho.
AppLrcenoN oF GEM Srers Wlrsn Coupltw - I
2. Gem State Water is a wholly owned subsidiary of NW Natural Water of Idaho,
LLC, which is in turn wholly owned by NW Natural Water Company, LLC.
3. On March 13,2020,Idaho Governor Brad Little issued a proclamation declaring a
state of emergency and providing directives to combat the spread of COVID-I9, to provide
essential services, and to limit exposure.
4. On March 25,2020, Governor Little issued an additional proclamation declaring
"a condition of extreme peril" in the State of Idaho due to the increasing presence of COVID-19.
5. Governor Little's "extreme emergency" proclamation was accompanied by a
statewide order to self-isolate, which directed all individuals living in the State of Idaho to self-
isolate at their place of residence, subject to certain exceptions for individuals that provide or
receive essential services or that engage in essential activities.
6. The Commission has taken actions in response to COVID-I9, including
suspension of in-person hearings and otherwise limiting procedures that would result in in-
person contact. See Order NO. 34602 (March 18,2020).
Rnqunsr FoR DEFERRAL
7. The continuing spread of COVID-I9 and associated proclamations and orders has
resulted in widespread economic disruption across the State of ldaho, the Pacific Northwest, the
United States and internationally.
8. Gem State Water recognizes the extent to which its customers rely on the
essential services that it provides and remains committed to using its best efforts to provide these
essential services.
9. Gem State Water also recognizes the economic hardship that the public health
emergency and accompanylng orders has created for its customers. Gem State Water is
AppLICATIoN or Gru Srere Wersn CoupeNy - 2
committed to assisting its customers through these difficult times, including suspending
disconnections for nonpayment, and suspending late fees, during the COVID-I9 emergency.
10. In addition, Gem State Water is actively participating in discussions regarding
mutual assistance for small water companies in Idaho to assist in responding to the public health
emergency. Gem State Water's efforts include entering into the IdWarn agreement, a statewide
water and wastewater agency response network to facilitate coordination in preparing and
responding to intemrptions in service.
11. Gem State Water anticipates that the public health emergency, associated orders,
and economic disruption will cause it to incur unusual and unexpected costs. Anticipated costs
include expenses associated with the suspension of disconnections and late payments, anticipated
write-offexpenses associated with uncollectible accounts receivable, potential direct expenses
for additional personal protective equipment (PPE) and additional expenses that the Company is
currently unable to predict.
12. Due to the unpredictable and unprecedented nature of the public health
emergency, these costs are not currently recovered in rates and are outside normal business risk.
13. Accordingly, deferred accounting teatment for these costs is appropriate and
reasonable.
14. Gem State Water recognizes that the increased costs may be offset by certain
reduced costs caused by the public health emergency, and that decreased costs will be taken into
account in any future proceeding.
15. Gem State Water does not request that the Commission make a determination of
prudency, or to determine whether these costs are recoverable, at this time. Gem State Water
understands that these issues will be determined in a future proceeding.
AppLICATIoN or GBu Srnrr WerER Coupetw - 3
Rngunsr roR Moorrrro PRocBDr.rRE
16. Gem State Water believes a hearing is not necessary to consider the issues
presented in this Application and respectfully requests that it be processed by modified
procedure, using written submissions rather than a hearing, under the Commission's Rules of
Procedure 201 through 210.
Coxcr,usroN AND Rrqursr FoR RELTEF
Gem State Water respectfully requests that the Commission enter an order:
1. Authorizing this matter to be processed by modified procedure;
2. Authorizing Gem State Water to separately account for, and to defer, costs
associated with the public health emergency posed by COVID-I9, with the amount, prudence,
and recovery of these costs to be determined in a future proceeding; and
3. Any other relief that the Commission deems just and reasonable.
DATED: Api17,2020.
GMENS PURSLEY LLP
/ -*. --:
Preston N. Carter
Givens Pursley LLP
Attornqtsfor Gem State Water Company, LLC
APPLICATIoN oT GTU STATE WATER CoMPAI.IY - 4