20210408Report in Response to Order No. 34974.pdf

Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, ID 83702
Telephone: [phone]
Facsimile: (208) 388-1 300
prestoncarter@ givenspursley. com
blakeringer@givenspursley. com
Attomeys for the Company
IN THE MATTER OF THE COMMISSION'S
INVESTIGATION INTO CDS STONERIDGE,
LLC'S HOOK-UP FEE FORNEW
CUSTOMERS TO CONNECT TO ITS WATER
SYSTEM
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Case No. SWS-W-20-02
RrpoRr PuRsulxr ro ORDER No.
34974
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
In accordance with the Idaho Public Utilities Commission's (the "Commission's") Order
No. 34974, dated March25,2021 (the "Order"), CDS Stoneridge, LLC, owned by J.D. Resort,
Inc. (collectively, the "Company'') through its attorneys of record Givens Pursley LLP, submits
the following report in response to the Commission's Order.
A.IdentiS the three additional customers who have filed complaints with the
Commission.
Per the Order,
Staff shall communicate with the Company to identiff the three
additional customers who have filed complaints with the
Commission. Stoneridge shall have fourteen days from the issuance
of this Order to provide these customers' records to the
Commission. The records to be provided for each customer must
itemize and describe the labor performed, equipment and materials
installed, and all charges the customer paid to connect to
Stoneridge's system. After receiving these records the Commission
will determine whether and to what extent Stoneridge overcharged
these customers and will direct the Company to act based on the
facts presented.
Rpponr PunsuANr ro ORDERNo. 34974
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Order at p. 15. The Company has identihed the three additional customers referenced in the Order.
Those customers, their names and addresses, are listed in Exhibit A, which is frled with the
Commission under separate cover so as to preserve the confidentiality of customer information.
All Company records related to these customers are likewise filed with the Commission under
separate cover, titled Exhibit C.
B. Customers who have paid but have not yet been connected.
Per the Order
Stoneridge [shall] provide, within fourteen days of issuance of this
order, documentation concerning customers who have paid to
connect to the system but have yet to be connect[ed and] (A) explain
to the Commission whether each customer remains unconnected,
and (B) if so, why Stoneridge has not yet connected each customer;
whether Stoneridge has charged each customer more than $ 1,200 for
theirpending connections; and when the customer will be connected
to the water system.
Order at p. I 5. ln response to this request, and as of April 6, 2021 , every customer who has
applied and paid for a connection has been connected. The Company will be updating the
Commission on any new customer applications and payments in its "new connection quarterly
reports," per the Order.
C. Customers with previous connections to the system.
Per the Order
Stoneridge [shall] provide a written report to the Commission,
within fourteen days from the service date of this Order, with the
identity, location of service and address of each customer who was
charged $1,200 to start receiving water service from Stoneridge
where a previous connection to the system already existed.
Order at p. 16. In response to this request, and to the best of the Company's knowledge, the
Company has never charged a customer $ 1,200 to start receiving water service from the
Company where a previous connection to the system already existed.
Rsponr PunsuANr ro Onorn No. 34974
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D Additional customers who were charged more than a $1,200 Hook-Up Fee.
Per the Order,
Stoneridge shall, within fourteen days of the service date of this
Order, submit a report to the Commission with the names and
addresses of any additional customers who were charged more than
a $1,200 Hook-Up Fee since Stoneridge began operating the water
system in June of 2018 who have not yet already been identified.
This report shall include all records related to these customers. After
receiving this report and all associated records, the Commission will
determine whether and to what extent Stoneridge overcharged these
customers and will direct the Company to act based on the facts
presented.
Order at p. 16. [n response to this request, the Company directs the Commission's attention to
Exhibit B, where all customers who have been charged more than a $1,200 Hook-Up Fee but
have not yet been identified in this case are listed. Exhibit B is frled with the Commission under
separate cover so as to preserve the confidentiality of customer information. All Company
records related to these customers are likewise filed with the Commission under separate cover,
titled Exhibit C.
E. The Company will timely respond to the remaining elements of the Order.
The Company recognizes and acknowledges that the Order contained various elements,
each obligating the Company to provide the Commission with certain information or otherwise
perform certain tasks. This report responds to all elements of the Order that required a response
within fourteen days of the issuance of the Order. All remaining elements of the Order provided
the Company with more time to respond. The Company will respond to each element of the
Order in a timely fashion.
Rrponr PunsuANr ro ORDERNo. 34974
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Dated: April8,2021
REPoRT PuRsuANr ro Onpnn No. 34974
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Respectfully submitted,
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Preston N. Carter
Blake W. Ringer
Givens Pursley LLP
Attomeys for the Company
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CERTIFICATE OF SERVICE
I certiff that on April 8, 2021, 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 STATT'
JanNoriyuki
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-4
Boise,ID 83714
EMAIL: j [e-mail]
John R. Harnmond, Deputy Attorney General EMAIL: [e-mail]
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Bldg.8, Ste.201-4
Boise,ID 83714
2 A_--=:-
PrestonN. Carter
Rrponr Pr.nsuANr ro ORDsn No. 34974
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