HomeMy WebLinkAbout20201120Reply Comments.pdfJOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
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Street Address for Express Mail:
1 133I W CHINDEN BLVD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
INVESTIGATION INTO CDS STONERIDGE,
LLC'S HOOK-UP FEE FOR NEW CUSTOMERS
TO CONNECT TO ITS WATER SYSTEM
CASE NO. SWS-W-20-02
REPLY COMMENTS OF
THE COMMISSION STAFF
The Staff of the Idaho Public Utilities Commission ("Staff') submits the following reply
comments.
BACKGROUND
Based on evidence submitted by Staff and additional customer complaints the
Commission issued emergency Order No. 34770. In the Order, the Commission directed CDS
Stoneridge,LLC ("Company") to: (l) immediately cease all billing practices that conflict with
the Company's tariff ("Tariff'), including charging new customers more than the Commission-
approved $1,200 hook-up fee to connect to the Company's water system; (2) continue serving,
and immediately reconnect customers who did not pay amounts that exceed the $1,200 hook-up
fee; (3) connect requesting new customers to the water system who pay the $1,200 hook-up fee,
consistent with the Company's Tariff; and, (4) within twenty-one (21) days of the service date of
this Order, produce and provide the Commission true and correct copies of all records
concerning new customer connections to the water system since November of 2018 through the
present, including an itemization and description of the labor performed, equipment and
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ISTAFF REPLY COMMENTS NOVEMBER}O,2O2O
materials installed and all charges the customer paid to connect to the Company's water system.
Order No. 34770 at 4.
The Commission noted that the Company's failure to comply with Order No. 34770,
could lead the Commission to penalize the Company under ldaho Code $ 6I-706. Id. at 4. The
Commission also stated that its investigation in this case would include whether the Company
violated ldaho Code 5 61-313, Commission Order No. 34391 and the Tariff by charging or
threatening to charge its customers more than a $1,200 hook-up fee. Id. Finally, the
Commission directed the Company to file a written response/answer to the Commission's
initiation of this investigation within twenty-one (21) days of the service date of Order No.
34770 addressing the Commission's findings and Staff s allegations about the Company
overcharging new customers to connect to the Company's water system. Id. The Company filed
its response ('oResponse") to Commission Order No. 34770 on September 30, 2020. Separately,
the Company provided certain documentation partially responsive to the requirements of Order
No.34770.
At the Commission's October 27,2020 Decision Meeting, Staff requested an opportunity
to reply to the Company's Response. The Commission found it reasonable to let Staff reply to
the Company's Response within twenty-one days of the service date of Order No. 34828. The
Commission also found it appropriate to let the Company to file a sur-reply within seven (7) days
after Staff filed its reply.
COMPANY'S RESPONSE
In its Response, the Company alleged it had been run unsustainably for years. Response
at 1. The Company asserted that its rates had not been updated since 2007, the prior owner did
not keep adequate records, and the Company's policies and procedures were not readily
available. Id. at L The Company also claimed to not fully appreciate the depth and intricacy of
the Commission's regulations. Id. at2. The Company discussed its interpretation of the Tariff
and that it did not clearly understand the labor and materials that should be included in the
approved S1,200 hook-up fee. Id. at2 and 4-5. The Company believed the Tariff allowed it to
charge additional fees for line extensions to customers' homes based on extraordinary
circumstances. Id. at 2.
STAFF REPLY COMMENTS NOVEMBER20,2O2O2
The Company represented it would comply with Order No. 34770 and proposed to work
with Staff to create and file a compliance plan within 90 days addressing certain issues "after the
Commission's order regarding [its] Response." Id. atZ and 6.
STAFF'S REPLY
Staff has reviewed the Company's Response and the additional information the Company
provided. Based on its review, Staff believes the Company incorrectly interprets the difference
between main line extensions and normal hook-ups. Staff also believes the Company's
Response does not comply with Order No. 34770. Staff discusses each element of the
Company's Response in relation to the requirements of Order No. 34770 in more detail below.
Extraordinarv Expenses that Allow -for Extra Charges Under Section 9.4
Staff stated the Company provided no evidence of extraordinary circumstances that might
justifu the Company charging customers more than the Commission-approved $1,200 connection
charge. Furthermore, the information provided by the Company did not explain the cost
variation between each connection. See generally, Company's Additional Documentation
submitted in Response to Order No. 34770 on October 26,2020 ("Company "Documents")l and
Responses to Production Requests in Case No. SWS-'tl-20-0l attached as Attachment E.
The Company's maps show all residential lots are similarly situated and abut streets
under which the Company's mains are located. The Company's invoices claimed connection
costs ranged from $800 to 514,620 per lot.2
To determine whether the Company could support its extraordinary costs, Staff focused
on whether the Company might have encountered extraordinary circumstances that might justifr
those costs. Staff s test used certain assumptions. Staff assumed the Company ordinarily
I In an abundance of caution the Company Documents have been redacted to remove customer identifuing
information.
2 Stuffr reviewed all connections for which the Company provided information about labor, equipment, and
materials in this case and in Case No. SWS-W-20-01. These included all connections for which the Company
provided invoices (both internal invoices and those from contractors), maps, and drawings. See generally,
Company's Additional Documentation submitted in Response to Order No. 34770 and Responses to Production
Requests Nos. 1-14 inCaseNo. SIVS-1L20-02 (filed inpieces in CaseNo. SWS-W-20'02on July 15,2020, August
6,z)2},and September 4,2020). In Case No. SWS-W-20-01 the Company has still not responded to Staff
Production Requests Nos. 10, l5-19 which were served on the Company on June29,2020.
STAFF REPLY COMMENTS NOVEMBER20,2O2OJ
incurred costs for the following work when installing a basic service connection are: 1) locating
the main, 2) installing a hot taplcorp stop on the main,3 3) installing a water meter and curb stop
near the edge of the customer's property, 4) running a service line between the main and the
water meter, and, 5) all excavation and horizontal boring necessary to perform this work. Staff
also assumed the typical service line from the customer's property to the Company's water main
was no more than 50 feet long. Staff determined the Company could reasonably incur
extraordinary costs when installing a connection if the service line was longer, or the work was
more complex, than that for an ordinary basic service connection in the Company's service area.
In no instance was the service line for a customer's property more than 50 feet long, or work
performed beyond the typical work referenced in l-5, above. In other words, the Company
provided no evidence suggesting extraordinary circumstances existed that might justifl, it
incurring extraordinary costs for any connection. The mere fact that the Company's costs for a
given connection may have exceeded the Commission-approved $1,200 connection charge does
not establish that the excessive costs reasonably represent a justified additional charge to the
customer above a standard service line connection that is allowable under the Tariff.
In its Response, the Company states that it interpreted Tariff Sections 9.1 and l2 as
"authorizing it to recuperate costs associated with extending the water system to serve particular
customers." Response at 4. While Staff generally agrees that the costs of extending a main to
benefit a particular customer should be borne by that customer, there is no evidence that the
Company had to extend a main to serve a customer's property. None of the Company's invoices
for materials or work suggest a water main was extended. See generally Company Documents.
Staff is also concemed by the number of instances in which the Company and its
contractors provided invoices for identical work. Sometimes, contractor invoices that described
all work necessary to connect a new customer to the Company's mains came with additional
invoices indicating that the Company had performed additional excavation work. The Company
gave no reason for this additional work.
3 The use of a hot tap allows the service line to be connected without depressurizing the main.
4STAFF REPLY COMMENTS NOVEMBER20,2O2O
Compliance Plan
In its Response, the Company proposed to work with its attorneys, Staff, and outside
professionals to establish a compliance plan and file it with the Commission within 90 days of a
Commission's order acknowledging the Response. The proposed compliance plan would
include:
o An understanding of what circumstances are considered a customer connection
subject only to the hook-up fee, and what circumstances are considered main
extensions or extraordinary expenses allowing recoupment of costs under the Tariff;
o Identification of potential changes to the Tariff that will enable the Company to
recuperate costs associated with adding new customers, consistent with Commission
rules;
o Considering hiring or consulting with a water operator that is familiar with the
Commission's rules and business practices of regulated water utilities; and
. AnY other compliance issues or operational challenges identified while reviewing the
Company' s practices.
The Company also proposes, as part of the compliance plan, that changes be identified
o'... that will enable the company to recuperate costs associated with adding new customers." 1d.
at 6. Staff agrees that the Company's Tariff needs changes, which can be addressed in a current
docket, Case No. SWS-W-20-01. The Company applied on June 4,2020 to increase its charges
to hook-up new customers to its water system. As discussed in footnote 1 above Staff is
awaiting the Company's reply to outstanding Production Requests. As of November 20,2020,
the Company has not responded to those Requests.
Directives of Order No. 34770
Staff has reviewed the Company's Response and operations as they apply to the specific
directives in the Order No. 34770. Staff offers reply comments on each directive below.
Cease Practices that do not Compbt with the Tariff
Staff has received one new complaint of the Company charging more than $1,200 since
the Order was issued. Initially, the Company advised the customer that the customer had to pay
$4,000 for the new connection. But the Company did not cash the customer's check and
STAFF REPLY COMMENTS NOVEMBER20,2O2O5
returned it to the customer. The Company then claimed the customer's seryice application was
incomplete because it lacked a building permit. The Company cited Tariff Section 9.3, which
states, "[f]ees and applications must be accompanied by an approved building location or
building permit issued by Bonner County." In reviewing the complaint, Staff obtained land
records from North Idaho Title Company. These records show the customer owns the lot, which
is in a platted subdivision that was accepted by Bonner County. See Attachment A.4 Staff
believes that owning a platted lot within the certificated area of the Company could satisff
Section 9.3. The customer commented in this case on October 29,2020 to request that the
building permit provision be removed from the Tariff.
Staff has also reviewed a draft of the Company's revised customer Application for Water
Service ("Revised Customer Application"). See Attachment B. The Revised Customer
Application reflects the Commission-approved $1,200 hook-up fee; however, Staff has other
concerns. The Revised Customer Application cites Tariff Section 9.2 when inquiring if
irrigation is required. But Section 9.2 does not mention irrigation. The Revised Customer
Application also has a section on meter size stating that the hook-up fee for a3/c inch meter
would be $ 1,200. But for other size meters the amount is blank. The Company historically has
connected every customer with a l-inch meter, so the Revised Customer Application should
specifu the approved hook-up fee for a 1-inch meter as reflected in the Company's Tariff. The
Revised Customer Application cites Tariff Section 9.4 and states that any extraordinary
circumstances will require extra costs, not to exceed $10,000, to be agreed in advance. However,
there is no definition of which costs are included in the $ 1,200 hook-up fee and what types of
costs are considered extraordinary.
While Staff saw little evidence that the Company has attempted to charge more than the
$1,200 hook-up fee allowed by the Tariff since the Commission issued Order No. 34770, it
appears the Company has interpreted the Tariff incorrectly in the past and does not understand
what additional costs it may charge to customers lawfully.
a The Amended Plat Map in Attachment A is similar to the map of the Stoneridge Subdivision provided by the
Company in response to Staff s Production Requests Nos. I - 19 in Case No. SWS-W-2}-O| .
STAFF REPLY COMMENTS NOVEMBER20,2O2O6
ue Did
s1.200 Fee.
Staff has received no inquiries or complaints suggesting that service has been intemrpted
for nonpayment of a connection fee.
200
The Company has not yet connected some individuals who completed the Company's
Application for Water Service before Order No. 34770 was issued. These new customers paid
the Company's unauthorized $4,000 hook-up fee and Staff does not know why the Company has
not yet connected them. Staff believes the Commission should require the Company to explain
to the Commission why the Company: 1) has not yet connected these customers to the water
system; 2) has charged each customer more than $1,200 for their pending connections; and, 3)
when the customer will be connected to the water system.
Within 2l Davs of Date. Produce and Provide Commission and Correct Conies of
All Records About New Customer Connections to the Water Svstem
When the Company responded to Order No. 34770, the Company provided to Staff under
separate cover a one-page list of new connections. See Attachment C. Staff believes this
information is inadequate, incomplete, and did not meet the requirements in violation of the
Order. Id. The addresses or lot identifications, or both, often were incomplete. Some entries had
"Have Not Paid" under the fee, and the internal costs were nearly all labeled with "Internal Cost
being quantified." 1d.
On October 21,2020, the Company provided Staffan updated one-page response. See
Attachment D. The updated response included: (1) either an address or lot identification, (2)
hook-up fees paid for each listing, and (3) the amount of costs incurred, either internally by the
Company or externally through a contractor. The internal costs ranged from $800 to $10,020,
and many listings included extemal costs, though the Company provided no supporting
documentation, or anitemization of the labor or equipment installed. 1d. While there was some
breakout of the internal labor performed, the itemization was only by the employee class and
lacked specificity for the labor performed.
7STAFF REPLY COMMENTS NOVEMBER20,2O2O
On October26,2020, the Company provided Staff with additional supporting
documentation. The Company also provided invoices for the extemal costs entered in the one-
page response provide on October 26,2020; however, these additional invoices lacked detail.
See generally, Company Documents. The Order states that the Company must include "...an
itemization and description of the labor performed, equipment and materials installed, and all
charges the customer paid..." Order No. 34770 at 4. Staff believes the Company violated this
requirement by failing to describe labor performed or equipment and materials installed.
The Company's Response also contained errors. For example, in one case the sum of the
items used for the Company's internal costs did not reconcile with the total amount at the bottom
of the invoice. Also, in l7 of the 33 new connections to the water system since 2018, the dates
on the Company's internal invoices for the internal costs often were dated on the day the
Application for Water Service was submitted. See generally, Company Documents. The internal
costs reported on these entries ranged from $800 to $ 10,020.
Staff could not confirm the Company's hook-up list is complete and accurate. Staff has
received inquiries and complaints from customers who had paid more than the approved hook-up
fee. But Staff could not ascertain if those customers were included in the Company's Response.
A complete list of customers, the date billing first commenced, and monthly billed amounts
reconciled to the Company's revenue would suffice to show that the Company's Response was
complete and accurate.
Another discrete issue has arisen from Staff s review of the Company's documents.
Sometimes the Company charged new customers a $1,200 hook-up fee even though the property
already had a service connection because the Company appears to have previously served the
prior owner. Staff isn't certain that a $1,200 fee should have been assessed to these customers.
Re.funds to Customers
Staff appreciates the Company's representation that it is willing to provide refunds to
customers who were charged more than the $1,200. Response at 3. However, the Company still
believes some of its excessive charges were justified. Id. at 3-5. As mentioned above, the
Company's Response did not show any customer required extraordinary work to connect to the
water system. Further, it appears from the Company's Response that the Company has not yet
refunded anything to these customers. Unless the Company has additional information not given
STAFF REPLY COMMENTS NOVEMBER20,2O2O8
to Staff, there is no reason for it to delay refunds to any customers who paid more than $1,200.
Staff thus recommends the Commission order the Company to make refunds to any customer on
the Company's list, Attachment D, all funds paid above the $1,200 hook-up fee. The
Commission should require the Company to pay the refunds within 14 days of the service date of
the Commission's order, and to provide evidence of each refund to the Commission. The
Commission should also order the Company to provide the Commission with a list of any
additional customers that the Company charged more than $1,200 to connect to the water system.
Staff notes that the Idaho Public Utility Law authorizes the Commission to order a public
utility to pay reparations to customers who were over-charged, with interest on such amount
from the date on which the utility collected the excessive fee. See ldaho Code $ 6l-641. The
Commission also may penalize a utility for failing to provide a Commission-ordered refund.
Failure to repay the amounts to be refunded, or the Commission-imposed penalties, can also lead
to actions being filed in court to recover each. See ldaho Code $$ 61-641, - 706, -342, and -712.
CUSTOMER NOTICE AND PRESS RELEASE
The Commission's Rules of Procedure do not require the Company to provide either a
customer notice or press release. The Commission also did not issue a press release. Staff did
provide the Commission's web address for case documents and for Order No. 34770 to some
customers who had filed informal complaints. The single customer comment received to date
resulted from Staff s follow-up with a customer who has an open informal complaint.
STAFF RECOMMENDATION
Based on its review of all information provided in this case and Case No. SWS-W-20-01,
Staff recommends the Commission order the Company to:
1. Respond to all current Production Requests in this case by the date set in such
request.
2. File the annual report as required by $ 61-405 within 14 days of the Final Order in
this case.
3. Provide refunds to all customers who paid more than the Commission-approved
$1,200 hook-up fee of any amount in excess of the $1,200 stated in the Tariff within
STAFF REPLY COMMENTS NOVEMBER20,2O2O9
14 days of the Final Order in this case and provide evidence of each refund to the
Commission.
4. Provide the Commission with a complete list of all customers to whom the Company
charged more than $1,200 to connect to the water system.
Additionally, Staff recommends the Commission remind the Company, as it did in Order
No. 34391, that the Company's failure to meet its specific or statutory reporting requirements in
a timely manner will potentially subject the Company to penalties.
Respectfully submitted this 3*duvof November 2020
J Hammond, Jr.
Attomey General
Technical Staff: Joseph Terry
Chris Hecht
Michael Morrison
i:umisc/comments/swsw20.2jhjtchmm reply comments
STAFF REPLY COMMENTS l0 NOVEMBER20,2O2O
RECORDING REQUESTED BY:
CRANDALT I.AW GROUP, PLLC
AND WHEN RECORDED MAILTO:
CRANDALL LAW GROUP, P[tC
8596 N. WAYNE DR., STE. B
HAYDEN, tD 83835
lnstrument #888671EoiiltER IDAHO6{-20r8 Pages: ?Recorded
MICHAEI.Foel lt 00Er0fflctoRecordertldrx b:DEEl}
DEED
THIS TNDENTURE, made as of thrs 29th day of Apiir, 201o between Larry A,Decker and Rosanne E. Decker, husband and wife, having'an address at 444otts Basin Rd.,sdgre, rD 83960, as the grantors hereunder (c;ile;d;; hereinafter referred to as the"Grantor"), and Larry Alan Decker and Rosanne Elleen Decker, havlng an address at 444 OttsBasin Rd., Sagle, lD 83860, as Trustees of the f.rry p*L"rlnO norrnne Decker Living Trustdated Aprll ?g,2016, and any amendments thereto, ,;;" ili"rry Atan Decker and RosanneEileen Decker and said trustee, as the grantee hereunder (hereinafter referred to as the"GrantOe"),
wrrNEssETH, that Grantor, for vatuabte consideration, the receipt andsufflclency of which rs hereby acknowredged, does r,.i.nv grrnt, convey and rerease untoGrantee and the heirs, personar representative$, a*uariorr,".dministrators, successors andassigns' of G rantee forever,
ALL that certain prot, prece or parcet of tand, with the buirdrngs andimprovements thereon erected, situate, rying and u.i.s i, Bonner county, rdaho,descrlbed as foilows;
Lot 158 ln Block q LAKE SANS SOUCT UNIT ONE, according to the plat thereof,recorded rn Book 3 0f prats, page 133 records of gonner iounty, rdaho.
ToGETHER with the appurtenances and all the estate and rlghts of Grantor inand to said premises,
To HAVE AND To HoLD the premises herein granted unto Grantee and the
ffJll.Lt""nal representatives, executors, admintstratorr, ,r.l.rrors and assigns of Grantee
above written.lN
wlrNEss WHEREoF, Grantor has duly executed thrs Deed on the date first
Attachment A
Case No. SWS-W-20-02
Staff Comments
11/20120 Page I of 5
LarryA.Rosanne E, Decker
STATE OF IDAHO
ss.
COUNWOF KOOTENAI
on this day, April 29, 2oL6, before me personatly appeared Larry A, Decker and Rosanne E.Decker, personally known to me (or proved to me on the basls of satisfactory evldence) to bethe lndlvlduals whose names are subsolbed to the foregolng lnstrument, and acknowledgedthat they executed the same as thetr voluntary act and deed for tl.re purposes thereincontained.
Wltness my hand and officlal seal.
lSealI
Notary
8596 N. Wayne Dr., Ste, B
Hayden; ldaho 83835
My commission expires: l/LllZOZe
il
Attachment A
Case No. SWS-W-20_02
Staff Comments
11/20/20 page 2 of 5
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Case No. SWS-W-20-02
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S-'<,T\TE'F{IIDGE,
StoneRidge Utility Co.
PO Box 298 Blanchard, ID 83g04
(208) 437_3148
APPLICATION FOR WATER CONI{ECTION
BTIILDING-PERMIT-YES NO
NAM F DATE
MAILING ADDRESS
CITY, STATE, ZIP
TELEPHONE NO.:
BLK:
STREET ADDRESS:
UBDIVISION:
ATER: PER SECTTON 9.2 tRRtGATtON REQU|RED? yES NOW
PER SECTION 9.2: METER S|ZE:% tNcH st,zoo
I|NCH s_
cost may apply if any out of the ordinary circumstances
occur requiring special equipment or a special construction technician involved
in the installation of service. These terms will be agreed upon in advance and
PER TARIFF 9.4 extra
will not exceed S10,OOO.
FOR COMPANY USE ON[Y:
TOTAL CHARGES s
TOTAL PAYMENT s
Attachment B
Case No. SWS-W-20-02
Staff Comments
lll20l20 Page I of 2
RECEIVED DATE:
RESPONSE DATE:
PER SECTION 7.LTHE METERS WILL BE INSTALLED BY THE COMPANY NEAR THE PROPERTY LINE OR ATANY LOCATION PREFERRED BY THE CUSTOMER AT THE CUSTOMERs EXPENSE.
PER SECTION 8.3 A STOP AND WASTE VALVE MUST BE INSTALLED BY THE CUSTOMER ON THECUSTOMER SIDE OF THE METER.
\ilAIER COITh[ECTION:
Hookup fee includes the meter set vdth a supply line, a water meter and installation valve only.
Homeowners acknowledge that they are responsible for all costs associated with maintenance, repair and labor ofall lines, pressure reducing and/or backflow prevention devices or parts and materials necessary for the watersystem to function properly from the meter to the home.
Fees are subject to change until payment in FULL is received.All fees must be paid prior to issuing "will serye" letter. work will only be scheduled after receipt of fees.stoneRidge Utility must inspect all work prior to backfiil and/orcompretion.
StoneRidse Utilities.
CONTRACTORLICENSE NI]MBER BOND NUMBER
Customer Signature
Sipahre Date
Stoneridge Utility lnspection/commencing billing date
Date
Attachment B
Case No. SWS-W-20-02
Staff Commentsll/20/20 Page2 of 2
2I
** *'*e E i
,tl,'
Attachment C
Case No. SWS-W-20-02
Staff Comments
11/20t20
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Attachment D
Case No. SWS-W-20-02
Staff Comments
11120120
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To whom it may concern,
RECEIVED
2020 August 6, PM 4:22
IDAHO PUBLIC
UTILITIES COMMISSION
This is the response from Stoneridge utilities addressing requests 1 and 2 from the first production
request Case NO. SWS-W-20-01.
Request # 1:
Maps of our service area have been forwarded
Here is the break down of lots by Subdivision;
Happy Valley Ranchos units 2 and 3 Total tots: 103 Undeveloped: 23
Happy Valley Ranchos Unit 1 Totallots: 44 Undeveloped: g
Stoneridge Addition Totallots: 19 Undeveloped: 4
Forest Subdivision Total lots: gg Undeveloped: 4G
Notes: Block 1,2 and 3 are not platted as of now, Block 5 lots 1 and 2 are for multi family units
and have4 hook up each, accountingforS ofthe undeveloped connections.
take Neighbor Hood Totallots: 60 Undeveloped: 2g
Stoneridge road Totallots: 50 Undeveloped: 21
Fairway Meadows Totallots: 30 Undeveloped: 0
stoneridge Resort timeshare Tota! lots: 150 rooms plus poo!/event center Undeveloped: 0
Affachment E
Case No. SWS-W-20-02
Staff Comments
11/20/20 Page 1 of 24
Vineyards Totallots: 24 Undeveloped: 0
Fairways Totallots: 71 Undeveloped: 30
Motor Coach Totallots: 77 Undeveloped: 0
lronwoods Totallots:13 Undeveloped:5
Notes: ironwoods is a total of 28 lots, but lots 8 through 22 where never completed and cannot be developed at this time.
Total number stoneridge lots: 579 plus the timeshare Undeveloped tots: 165
Request No. 2:
A) We became aware of the lack of lot connections after closing. lt became more evident as we
took responsibility for making the water and sewer connections for the undeveloped lots.B) The fact the most of the old subdivisions date back to the late 1960's and the lack of ,,as builtplans" it is hard to answer why this information was not discovered.C) Lots with corp. stops:44
D) Lots without corp. stops: 121 Some of the lots in the Forest and lake neighbor hoods
have inadequate water connections. What we are finding is oNE, 1 inch tap to the water mainwith the intent to hook up as many as FOUR homes, Two homes on each side of the road. This
along with the products used does not meet state standards. So a new up to date connection is
needed for each lot in these neighborhoods.
Request No.3:
The 59,375 charge would cover even^hing in lines A-F and l. H falls under the ,.contingency
estimates" which is line J.
Request No. 11: Rejected bids were not used in the calculations to my knowledge. The information
submitted from the three contractors is actual work preformed or a bid from Leo,s excavation.
Contractors are largely chosen by availability and capability.
Request No. 12: Stoneridge does allow owner to use their own contractors, but they must have amunicipality license and their information (license, bond, insurance ect.) must be submitted to our office
along with a cost estimate.
Attachment E
Case No. SWS-W-20-02
Staff Comments
lll20l20 Page2 of 24
Request No. 13: No one to my knowledge has any financial interest in any of the companies that havebid for work at Stoneridge.
Request No' 14: No one to my knowledge has any financial interest in any of the companies that haveperformed work to connect new customers at Stoneridge.
Attachment E
Case No. SWS-W-20-02
Staff Comments
11120/20 Page 3 of 24
To whom it may concern, i1i: * f; I ? & *
This is a response to the First production request from the tpUC staff. Case# SWS-W-2o{d* Slf *l+ P* 3: 3S
, 1.. i, _. ,-:i:::*iil
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Answer to request f4.
A) The complete break-down for the cost of parts is attached. Estimate Ezozs2from H.D.Fowler Dated 7 /912o2a. Abo attached is the current cost for the meter in the estimate fromconsolidated supply. The full cost of $2273.52 and $gzs.eo is for a connection that must betied back to the water main. These costs do not reflect excavation labor. parts costs can bereduced for connections that have curb stops in place by subtracting line items 1, 2 and 5bringing the cost of parts to 52038.64 plus the cost of the meter. These are approximateprices and the most up to date that we can provide at this time.B) To comptete a road crossing a bore is achieved by the contrastor exposing the water lineand preparing a pit on both sides of the road. The contractor then pu[s a 3-inch casingunder the road to installthe water connection in. exploratory excavation and labor (hand
digging around underground utilities) takes time to accomplish safely. Boring prevents theneed of closing the road and putting unneeded asphalt patches in our roads. pavement
cutting and patching falls in the contingency category and is not included in the costestimate for a standard bore. Asphalt cutting and patching is based on the size of areaeffected and the cost of product at the time. This will be discussed in greater depth inrequest #9.
c) The responsibilities of the operator, at the point that a person turns in their application forwater service, the operator must do a preliminary survey of the lot for a will or wilt not serveletter. Next is a location plan, locate all utilities and the location of the new services. Thiscan include reading maps and looking for valves and lines with a metal detector or otherlocating devices. Determining if a bore will be needed, do we have a curb stop or wilt weneed to tap the main. will a shut down of the neighborhood be needed. lf so a 24-hournotice must be handed out, construction samples must be taken after wards. At this pointthe contractor is scheduled. The operator observes alt phases of the work preformed by thecontractor. The operator completes the documentation and returns it to the office staff forthe setup of accounting. With the lack of verifiable information and the age of the
subdivisions this can be a lengthy process.
Request #5
A) The bid from Leo's excavation. Leo was given the required parts list that was included in ourapplication from consolidated supply dated 6l2oh9. I can not speak for Leos excavation butI assume the $2500.00 included a[ of the required parts.B) Leo did not give a breakdown of his estimates, but what was expected is the excavation ofthe water main, open a pit to bore from, open a pit to set the meter and perform the tie in,bore under the road. with appropriate backfill and compaction.c) once again, I cannot speak for Leos excavation. The work expected is, hot tap the watermain. Assemble all required parts and installthe meter set. Test and back fill with proper
compaction.
Attachment E
Case No. SWS-W-20-02
Staff Comments
lll20l20 Page 4 of 24
D) To my knowledge this bid did not include any permitting traffic control or companyadministrative Costs.
E) To my knowredge this bid did not incrude any contingency estimates.
Request #6
A)swank Excavation was given the same required parts list as Leo,s. this was included in theapplication and you can see the parts again in the "parts estimates, attached to this email.Due to the environment in this country at the moment prices are fluctuation regularly.These costs wourd be under th e sz+az.zl parts and materiats. The estimated cost ofs3708'00 to my understanding was for exploratory excavation to locate all unmarkedutilities and the close proximity to the phone and power .,hand work,, that was required onboth sides of the road. Also, reshaping of the ditch line after installation of the meter setthat was required.
B) The scope of work that was expected was the excavation of the water main, open a pit tobore from, open a pit to set the meter and perform the tie in, bore under the road. lnstal a3-inch sleeve and finish with appropriate backfiil and compaction.C) No patching was required
D) Yes, this bid included traffic control
E) No' to my knowledge this bid did not include any of the stoneridge administrative costs.F) No, to my knowredge this bid did not incrude any contingency estimates.
Request #7
as in response to the work preformed by c&D Dirtworks that was included in the application.That was completed prior to my emptoyment with stoneridge. I have no information to add tothe invoices and the employees that were involved no longer work here. so I can not expand onthe scope of work preformed or why the costs. That invoice was included to show actuat costbeing paid by stoneridge for connections not just bids. But those costs reflect prices from 2019.
Request #8
To my understanding c&D Dirtworks is no longer available to or will perform the work at thosecosts any longer.
Request #9
contingencies: are costs that accrue from abnormal conditions. Damage to unmarked orunknown utilities' Excessive exploratory excavation to rocate utilities. Asphatt cutting andpatching' Reconstruction of landscape or ditch lines due to excessive exploration. or any otherunforeseen issue' Each of these issues are priced on an individual basis by cost, size or timeallotted.
Attachment E
Case No. SWS-W-20-02
Staff Comments
1l/20120 Page 5 of 24
To whom it may concern,
This is a response to the First production request from the lpUC staff. Case# sws-w-20-o1
Answer to request #4.
A) The complete break-down for the cost of parts is attached. Estimate Ezozs2from H.D.Fowler Dated 7/9/2a20. Also attached is the current cost for the meter in the estimate fromConsolidated Supply. The full cost of 52273.52 and 5g26.g0 is for a connection that must betied back to the water main. These costs do not reflect excavation labor. parts costs can bereduced for connections that have curb stops in place by subtracting line items 1, 2 and 5bringing the cost of parts to 52038.64 plus the cost of the meter. These are approximateprices and the most up to date that we can provide at this time.B) To complete a road crossing a bore is achieved by the contractor exposing the water lineand preparing a pit on both sides of the road. The contractor then pulls a 3-inch casingunder the road to install the water connection in. exptoratory excavation and labor (handdigging around underground utilities) takes time to accomplish safeiy. Boring prevents theneed of closing the road and putting unneeded asphalt paiches in our roads. pavement
cutting and patching falls in the contingency category and is not included in the costestimate for a standard bore. Asphalt cutting and patching is based on the size of areaeffected and the cost of product at the time. This will be discussed in greater depth inrequest #9.
c) The responsibilities of the operator, at the point that a person turns in their application forwater service, the operator must do a pretiminary survey of the lot for a will or wifl not serveletter' Next is a location plan, locate all utilities and the tocation of the new services. Thiscan include ieading maps and looking for valves and lines with a metat detector or otherlocating devices. Determining if a bore will be needed, do we have a curb stop or will weneed to tap the main. willa shut down of the neighborhood be needed. lf so a 24-hournotice must be handed out, construction samples must be taken after wards. At this pointthe contractor is scheduled. The operator observes all phases of the work preformed by thecontractor' The operator completes the documentation and returns it to the office staff forthe setup of accounting. with the lack of verifiable information and the age of thesubdivisions this can be a lengthy process.
Request #5
A) The bid from Leo's excavation. Leo was given the required parts list that was included in ourapplication from consolidated supply dated 6120/19. I can not speak for Leos excavation butI assume the S2500.0O included all of the required parts.B) Leo did not give a breakdown of his estimates, but what was expected is the excavation ofthe water main, open a pit to bore from, open a pit to set the meter and perform the tie in,bore under the road. with appropriate backfill and compaction.c) once again, I cannot speak for Leos excavation. The work expected is, hot tap the watermain' Assemble all required parts and install the meter set. Test and back fill with propercompaction.
Attachment E
Case No. SWS_W-20_02
Staff Comments
tt/20/20 page 6 of 24
D) To my knowledge this bid did not include any permitting, traffic control or companyadministrative Costs.
E) To my knowledge this bid did not include any contingency estamates.
Request f6
A)Swank Excavation was given the same required parts list as Leo's. this was included in theapplication and you can see the parts again in the "parts estimates'attached to this email.Due to the environment in this country at the moment prices are fluctuation regularly.
These costs would be under the 52462.27 parts and materials. The estimated cost of
53708'00 to my understanding was for exploratory excavation to locate all unmarkedutilities and the close proximity to the phone and power "hand work,, that was required onboth sides of the road. Also, reshaping of the ditch llne after installation of the meter setthat was required.
The scope of work that was expected was the excavation of the water main, open a pit tobore from, open a pit to set the meter and perform the tie in, bore under the road. lnstall a3-inch sleeve and finish with appropriate backfilland compaction.
No patching was required
Yes, this bid included traffic control
No, to my knowledge this bid did not include any of the Stoneridge administrative costs.No, to my knowledge this bid did not include any contingency estimates.
Request #7
as in response to the work preformed by c&D Dirtworks that was included in the application.That was completed prior to my employment with Stoneridge. I have no information to add tothe invoices and the employees that were involved no longer work here. so I can not expand onthe scope of work preformed or why the costs. That invoice was included to show actual costbeing paid by stoneridge for connections not just bids. But those costs reflect prices from 2019.
Request #8
To my understanding c&D Dirtworks is no longer available to or will perform the work at thosecosts any longer.
Request #9
contingencies: are costs that accrue from abnormal conditions. Damage to unmarked orunknown utilities. Excessive exploratory excavation to locate utilities. Asphalt cutting andpatching' Reconstruction of landscape or ditch lines due to excessive exploration. or any otherunforeseen issue. Each of these issues are priced on an individual basis by cost, size or timeallotted.
B)
c)
D)
E)
F)
Attachment E
Case No. SWS-W-20-02
Staff Comments
1l/20120 PageT of24
**Shtp Ticket **COIiISOIJIDATED SUPPLY CO . CDA155 SAST DAI|TON AVE
DAIJTOI{ GANDETIS, ID 83815Fhoae * I 208-?dA-2S69
Consolidatod
Supply Co.
[lItilfifr0flffinlll[]fi]liltll[Prlntcd: 10:21:36 09 JUL 2020
EILL To: '190397
LUKE SWAI{T
1.380 EWELI,
POST TAIJLS,ID 83854
SHIP TO:
LUKE SWANK
1380 EWETL
POST FALLS, ID 83854
208 - 6s9- 7008
Pl,ecca:_ Boxea;_ pallctel _ Bagar_ Buad.l.ca:_ ghr*ar_
Attachment E
Case No. SWS-W-20-02
Staff Comments
11120/20 Page 8 of 24
07/ae/2a s00984688L. 00
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07 09 20 ***c,o.D.! ***wc NoIf 4Prc Br 14
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AN:TB'INA A$TD PIT MOUNT, ]",zw LEAD
1x sIIETERGRATJ
TOUCI{ PAD
fnvoice Amorrnt
Loc: BB02-02-J.F
ORDER TOTAL
Sa1es tax
Pn: L3L52t-7
0 78
826.80
0
780.00
45.80
Pl.ckcd Byr
Customer:
Estimator:
Job ltarns:
tocation:
H.D. FOWLER
colilPAtrrv
SWANK EXCAVATING
Josh Shore
STONERIDGE RE5ORT
BI.ANCHARD IDAHO
Estimate:
Bld Datei
Bid No: E420252 page 1 of 2
842A252
7lel2aza
Line ety UoM Description
Unit Price Extended price
1
2
3
4
5
6
7
8I
10
11
12
13
24
15
16
18
19
20
21
22
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C86-44Q.NI 1' MIP X PEP QUICX JOINT COUPLING NO.LEAD FORD811.{44-NL 1" Ftp x Flp SALLVALVE CURS Srop No-rr* ro^o6, SDR35 3034 CASKETED PVC SEWER PIPE 14' |-,*EO6' PSM CAP SW FOR SEWER OR DRAIN
c1G44Q-t{L I' Ftp x pEp qutcx Jolr{T coupLtNc NO-|-EAD FORD1' rps eurcK JorNT
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tr 2eArso cAN ,rriio * 1-114, crsSTIFFENER #53Q FOiDFT 1" tps StoR-7 250 psl poty ptpE 100, ROLL p84710 ASTM D_2239EA ,FCBHH''88'18'4&R-Nr l', corl ,n srttan ,ui, vAtvE x .HECK VALVE l8'XiI8" No-LEAD FoRD
1EA
lEAt4 Fr
1EA
1EA3tA
42.86
58.20
721.77
48.27
133.82
3.22
14.78
41.55
3.11
42.86
115.40
127.77
48.27
133.82
45.08
14.78
4t.55
9.33100
1 0.86
1,423.25
85.00
L,423.25lEA
1EA
1EA
1EA
lEA
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EA 4'SCHitopVCTEESXSXS
EA 4"x2'ScH40PVCBUSHINGSXS
EA 4" PVC PRO SPAN EXPAN'ON REPAIR COUPTING IPS HU' X SPIGOT
''OPSI
f0118-40 FLO CONTROL
CCID.18 18" CC INSULATING DISC FORD
PPSG18.L 18'ONE PIECE FTAITOCI(ING METER BOX COVER FOftD1" SCH 40 GAIVANIZED COUPLING IMPORT1. X 12" SCH 40 GAIVANIZED NIPPE A53 ERW1'SCH 40GAI.VANIZED CAP IMPORT
Section Subtotal:
1" x 3/4,, SCH rm u*ro*,rrffiT
1..SCH 40 GALVANIZED MAIE INSERTADAPTER IMPORT73/16" - 7-314'SS WORM ORTVE HOSE CtAMp3/4I X 6'' sCH 40 GATVAilIZED NIPPTE A53 ERW1" sCFI40 GALVANIZED 90 sTREfi ELBOW IMPOBTstMMoNs 4' BURy yARo HYDRANT 3/4" ,,r, ,rlr *oo rEAD FREE r*78ssOVERAI,I LENGTH
Section Subtotal:
4' scil 40 tps soLVEilT WEID pvc ptpE 20, IENGTH2" SCH 40 lps solvE'rtT WELD pvc ptpE
'0,
Lunift2" pvc EALL VALW tps sllp x sl_tp 150pst g1310-20
2" SCH 40 Pvc 45 El30w $(s
47.31
12s.98
4.87
9.31
3.00
47.31.
125.98
4.87
9.31
3.00&ffi
L7 1EA
2EA
10 EAlEA
2eA
1EA
7.16
2.56
0.64
3.18
5.13
1?4.6A
7.!6
5.12
6.40
3.18
10.25
124,ffi
23
24
2s
26
27
28
29
30
I
1
1
1
10.95
35.40
14.45
59.92
tKf,}
10.9s
35.40
14.45
s9,92
57.80
39.20
25.24
8.60
Attachment E
Case No. SWS-W-20-02
Staff Comments
11/20/20 Page 9 of 24
20 FT40 FT
2EA
2EA
2.89
0.98
12.62
4.30
Bid No: E420252 page 2 of 2
31
32
33
2EA10 rT
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?'sH 40 PVC 90 Et30w sxs
5" 2729 SOUo S0LVENT urEll) pVC DRATN ptpE 10, L€N6TH6' PSM CAP S1,1' FO8 SEWER OR DRAIN
Secllon Subtotal:
3.5s
1.93
14.78
7.30
19,30
29.56
3A7.72
Approximate Total
n
2,737,96
i,,r ro{ r/a 6 .4.:
#'5 '5 rr4. ,? b
Attachment E
Case No. SWS-W-20-02
Staff Comments
11120120 Page 10 of 24
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Case No. SWS-W-20-02
Staff Comments
ll/20120 Page l1 of 24
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Attachment E
Case No. SWS-W-20-02
Staff Comments
11120120 Page 12 of 24
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Attachment E
Case No. SWS-W-20-02
Staff Comments
11120/20 Page 13 of 24
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Case No. SWS-W-20-02
Staff Comments
11120120 Page23 of 24
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Case No. SWS-W-20-02
Staff Comments
11120120 Page24 of 24
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE 20th DAY OF NOVEMBER 2020,SERVED THE FOREGOING REPLY COMMENTS OF THE COMMISSION STAFF,IN CASE NO. SWS-W-20-O2, BY E-MAILING A COPY THEREOF, TO THEFOLLOWING:
STEVEN DURBIN
CDS STONERIDGE UTILITIES
PO BOX 298
BLANCHARD ID 83804
E-MAIL: steve.durbin @ stoneridgeidaho.com
CERTIFICATE OF SERVICE