20240212Comments_18.pdf

1

The following comment was submited via PUCWeb:

Name: Darren Drinnin
Submission Time: Feb 9 2024 2:56PM
Email: [e-mail]
Telephone: [phone]
Address: 51 Sandtrap Lane
Blanchard, ID 83804

Name of U�lity Company: Inland power

Case ID: SWS-W-23-02

Comment: "How do you let one person dictate the way a region is run, I hope you turn this down. Thanks
Darren "
----------------------------------------------------------------------------------------

The following comments were submited via PUCWeb:

Name: Jim Ant
Submission Time: Feb 9 2024 3:13PM
Email: [e-mail]
Telephone: [phone]
Address: 266 Par Loop
Blanchard, ID 83804

Name of U�lity Company: CDS Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION

Opposi�on and Comments against CDS Stoneridge U�li�es:

(A) Applica�on for Increase to Water Meter New Installa�on fees, Case # SWS-W-23-02; and,
(B) Applica�on for Addi�onal Capital Contribu�ons, Case # SWS-W-23-03.

The undersigned (residents of Stoneridge) file these comments in opposi�on to both the above maters
pending before the IPUC:

(1) 157% Increase: Stoneridge U�li�es requests an increase in water meter installa�on fees from
$3,500.00 to $9,000.00, per meter. This is a 157% increase. As explained below, Stoneridge U�li�es’s
applica�on provides insufficient evidence mee�ng its burden of proof for such increase. “Most o�en, it
is the party which requested the hearing who will bear this ‘burden of proof.’” Idaho Office of
Administra�ve Hearings, htps://oah.idaho.gov/represen�ng-yourself/
2

(2) Outside Contractors vs In House Installa�ons: Stoneridge U�li�es claims in its water meter
increase applica�on [exhibit “D”],
“The majority of [water meter] installs were done by Swank Excava�ng in 2021 - 2023. Our prior system
operator (le� SRU summer 2023) was able to do some of the installa�ons which did not include "boring
under road" or "cu�ng open the road." When we did this complex "in-house" installa�ons they were
typically installing a meter only and our costs were minimal for parts/materials, etc.
. . . .
“In total we had the following new connec�ons in each �me period [as follows]:
2020 - 29
2021 - 18 [connec�ons] less 15 either prior to Tariff # 3, or "Not Arm's-Length"
2022 - 18 [connec�ons] less 11 in-house transac�ons.
2023 - 04 [connec�ons] less 2 in-house transac�ons and two not connected yet." [emphasis added]
Stoneridge U�li�es’ applica�on itself disproves its own request. For example:
(a) The “majority” of installs were NOT done by an outside contractor (“Swank Excava�ng”], as
claimed by applicant.
(b) From the informa�on provided by Stoneridge U�li�es, for the “test period” between 2021 -
23, there were a total of 10 outside contractor installa�ons [3 for 2021; 7 for 2022; and a net 0 for 2023].
For the same period, there were a total of 30 connec�ons (75% of total connec�ons) NOT done by
outside contractors.
© Stoneridge U�li�es has had no increase costs from 75% of the total connec�ons (30), but yet
requests a 157% increase in fees. D
(d) Stoneridge U�li�es submits sample billings from “Swank Excava�ng” [exhibits “E” &
“F”]. None of these billings are as much as applicant’s requested increase ($9,000.00).
(3) The Request results in a Windfall: The applicant’s Exhibit “D” also claims:
“In 2022 our new construc�on revenue was 48,895 and the associated installa�on costs were $70,148
for a net loss in 2022 on New Connec�ons”.
If the 18 connec�ons in 2022 were charged $9,000.00 per connec�on [total revenue: $162,000],
and costs were $70,148, the applicant would receive a $91,852 windfall for u�lity connec�ons in 2022.
(4) $980,000.00 Capital Contribu�on: Stoneridge U�li�es is applying “to the Commission for
authoriza�on to borrow $980,000.00 from related en��es and or receive addi�onal capital contribu�ons
for $980,000.00, from the same related en��es”.
(a) Stoneridge U�li�es’ is clearly not reques�ng preauthoriza�on for the borrowing, because the
borrowing has already been completed. Instead, Stoneridge U�li�es is reques�ng retroac�ve approval
of its ac�ons, having already completed the transfer. Stoneridge U�li�es’ applica�on for retroac�ve
approval is completely disingenuous. Permission should be sought prospec�vely, not retroac�vely.
(b) In order to jus�fy its request, Stoneridge U�li�es argues:
“Esprit Enterprises, LLC had no prior experience managing a publicly regulated water company. The first
four years of learning the repor�ng requirements along with upda�ng opera�ons and administra�ve
procedures and evalua�ng the condi�on of the approximately 30+ year old water system(s) has been a
steep learning curve for an organiza�on with a complete staff turnover in 2019."
(i) However, this was not the tone or tenor of the applicant when a request was made of the
Commission to approve Stoneridge U�li�es’ purchase of the water u�lity.
(ii) For example, the staff report [Case # SWS-W-18-01] recites:
“Staff believes Mr. Karupiah has the ability to financially operate the water company. From discovery,
staff is learned that Mr. Karupiah is an experienced investor, familiar with the commercial real estate
markets and investment opportuni�es in northern Idaho. In addi�on, staff has reviewed the last 3 years
of financial statements from Mr. Karupiah and believes that Mr. Karupiah has the ability to finance the
capital needs of the u�lity." And,
3

(iii) Also, from the staff report [Case # SWS-W-18-01]: “ . . JD Resort [applicant] indicated that t"

----------------------------------------------------------------------------------------

Name: Jim Ant
Submission Time: Feb 9 2024 3:54PM
Email: [e-mail]
Telephone: [phone]
Address: 266 Par Loop
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "(iii) Also, from the staff report [Case # SWS-W-18-01]: “ . . JD Resort [applicant] indicated
that there are no plans to change the current rates and charges in the current CDS tariffs. Although rates
will not increase because of the transac�on, the engineering analysis will iden�fy only necessary capital
improvements in the system that may be a driver for a future rate case."
Applicant’s approval for purchase of the water u�lity was based upon an express statement that rates
would not be increased, except based upon an engineering analysis for necessary capital improvements.
Applicant has presented no engineering analysis and no basis for capital improvements.
(5) It’s really all about a General Rate Increase: Stoneridge U�li�es makes clear that it is using both
these proceedings as a springboard for a general rate increase applica�on. For example,
(a) “In addi�on, we [Stoneridge U�li�es] are in the process of filing a general Taif rate increase
applica�on.” And,
(b) "In recent years, Stoneridge U�li�es has "Capitalized" all that losses on "New Connec�ons" on to
the balance sheet into balance sheet account # 333 . . . This strategy allows those "new connec�on
losses" to be amor�zed . . . annually and therefore increase our "Rate Base" for Rate Design purposes to
recover in future years."
Stoneridge U�li�es’ applica�ons must not be used as a springboard for a general rate increase.
The undersigned strongly urge the Commission to reject both applica�ons, as neither are the proper
basis for a future general rate increase. Any general rate increase should stand on its own.
(6) Audit Requested: The undersigned request the Commission conduct an audit of Stoneridge
U�li�es, as a next step in these proceedings. The authority for an audit is contained in paragraph (9)(d),
infra, Condi�ons of Sale. The applicant self-serving income statements and balance sheets and
calcula�ons simply have no reliability or credibility without audit. The size [157% increase] and nature of
applicant’s requests [$980,000.00 in already made loan “capitaliza�on”] alone jus�fy an audit.
Applicants are not in compliance with the financial requirements described in paragraph (9), infra,
Condi�ons of Sale.
(7) Bank Line of Credit Required: As recited infra [paragraph (9)(b)], the IPUC final order requires a
bank line of credit. There is no evidence that a bank line of credit has ever been established. The only
evidence given by the applicant of a line of credit is one from Esprit (not a bank) to the JD Resort (both
wholly owned by Chan Karupiah). And this informa�on has been filed just recently, 17 January 2024. A
bank line of credit was due shortly a�er the final order approving the sale of the u�lity (2019). Without
compliance with the Commission’s exis�ng orders, the Commission should deny applicant’s present
requests.
4

(8) No Timely Repor�ng: Further, there is no evidence that applicant has �mely filed the periodic
monthly and yearly statements required by the Commission’s Final Order [see paragraph (9)(b). Without
compliance with the Commission’s exis�ng orders, the Commission should deny applicant’s present
requests.
(9) Condi�ons of Sale: As argued above, the IPUC Final Order allowing sale of the water u�lity to
applicant contained several condi�ons [Case # SWS-W-18-01]. For example:
(a) "JD Resort [applicant] must demonstrate his financial ability to operate on its own accord. The
notarized personal guarantee of Chan Karupiah to use his personal finances to support the financial
needs of the company is of uncertain value. If Mr. Karupiah were to file bankruptcy or otherwise being
unable to meet all of his financial obliga�ons, a signed personal guarantee to financially support a legally
separate company is dubious value compared to more standard cash capital or debt instruments likely
held by other creditors. Therefore, we require assurances that JD Resort has the financial ability to
operate the system in the public service, not JD resort by and through Chan Karupiah."
(b) "JD Resort [applicant] must be able to make and pay for ongoing repairs and have access to
capital for major repairs, including pump or well failures. . . JD resort must file balance sheets and
income statements with the commission quarterly . . . JD resort must file its balance sheet and income
statement for the quarter ended 30 June, 2019, within 60 days of this Order. Subsequent quarterly
financial statements must be filed within 45 days of the quarter end. JD resort must file monthly bank
statements showing at least a $50,000 balance un�l JD resort establishes a bank line a credit of at least
$250,000. If JD Resort does establish a sa�sfactory bank line of credit, JD Resort must con�nue to file
monthly statements showing a line of credit remains in place under JD Resorts name, along with the
dollar balance u�lized in remaining, un�l the commission orders otherwise . . ."
© " . . . JD"
----------------------------------------------------------------------------------------

Name: Jim Ant
Submission Time: Feb 9 2024 3:55PM
Email: [e-mail]
Telephone: [phone]
Address: 266 Par Loop
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "© " . . . JD Resort must also demonstrate compliance with the generally acceptable
repor�ng requirements under Idaho code."
(d) “We remind JD Resort [applicant] that the Commission has the authority to audit JD
Resort at any and all reasonable �mes. Idaho Code § 61-610.”
(10) Staff Memo on Capitaliza�on Request: Staff has filed a “Decision Memo" with the Commission
on 23 January, 2024. The undersigned concurs with the reasoning of the Decision Memo and
recommenda�on to deny applicant’s capitaliza�on request [Case # SWS-W-23-03].
(11) Conclusion: Both applica�ons must be denied because applicant has not met its burden of proof
and the applica�ons lack merit. If the applica�ons are not denied, prior to the Commission proceeding
further, the Commission should order an audit.

Jim and Faun Ant
5

266 Par Loop
Blanchard Id 83804
[e-mail]
[phone]

Suzanne Kamp
80 Eagle Way
Blanchard Id 83804
[e-mail]
[phone]

Barbara Gayer
94 Par Loop
Blanchard Id 83804
[e-mail]
[phone]

Jeff Leinwand
61 Par Loop
Blanchard Id 83804
jeff@sabinocreek.com
[phone]

Robert Simpson
43 Sand Trap Ln
Blanchard Id 83804
[e-mail]
[phone]
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: Randy Grimes
Submission Time: Feb 9 2024 4:55PM
Email: [e-mail]
Telephone: [phone]
Address: 27 Sandtrap
Blanchard, Id 83804

Name of U�lity Company: IPUC

Case ID: SWS-W-23-02

Comment: "Unreasonable, considering the costs were accrued under Chan's supervision. An annual
increase is understandable, however no more than the rate of infla�on. It was in Chan's error and should
not be passed on to the residents at any rate beyond a normal cost increases."
----------------------------------------------------------------------------------------
6

The following comment was submited via PUCWeb:

Name: Bob Rapalli
Submission Time: Feb 9 2024 5:35PM
Email: [e-mail]
Telephone: [phone]
Address: 179 Forest Ridge
Blanchad, ID 83804

Name of U�lity Company: Stoneridge Water U�li�es

Case ID: SWS-W-23-02

Comment: "Per above case number. We find it outrageous that the owner of the above u�lity (Chan
Karupiah dba Espirit Enterprises) is asking for a 157% increase for water meter hookup. Even the
governments COLA only amounted to 3.2%. for 2024. A 157% increase us pure price gouging. We hope
IPUC reject the request for this increase."
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: Ann Weaver
Submission Time: Feb 10 2024 8:25AM
Email: [e-mail]
Telephone: [phone]
Address: 664 Stoneridge Rd.
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�lity

Case ID: SWS-W-23-02

Comment: "Why in the world would they rise the water bill sky high? I am a widow and can barely make
it now since the loss of my husband's social security sure makes it tough. People like Chan that have the
money don't pay his way. Why is that? If I did that they would come a�er me, WHY don't they come
a�er him? I work had at what I have and pay my bills and so should everyone else. There was two case
# the other was
SWS-W-23-03 Thank you for listening. Ann Weaver "
----------------------------------------------------------------------------------------

The following comments were submited via PUCWeb:

Name: Gary Cook
Submission Time: Feb 10 2024 3:39PM
Email: [e-mail]
Telephone: [phone]
7

Address: 444 Stoneridge Rd
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "I am opposed to this enormous increase on the water for Stoneridge U�li�es.

Gary L. Cook
----------------------------------------------------------------------------------------

Name: Bety Cook
Submission Time: Feb 10 2024 3:42PM
Email: [e-mail]
Telephone: [phone]
Address: 444 Stoneridge Rd.
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "I am definitely opposed to this excep�onally high increase in the water bill. Not necessary.

Bety Cook
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: David Unruh
Submission Time: Feb 10 2024 7:06PM
Email: [e-mail]
Telephone: [phone]
Address: 106Hanaford Rd
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "I am wri�ng regarding the request of Stoneridge U�li�es to raise the water hookup rates by
157%. This is way too excessive and makes it prohibi�ve for people to come into our community. In
addi�on I believe this case along with case #SWS-W-23-03 will greatly impact our water rates making it
unaffordable for many of us re�rees who are on fixed incomes. We are asking that you reject both these
8

cases. We do understand that costs have gone up but raising fees 11% for our water and 157% or greater
for hookups is way to excessive.
Thank you for hearing our concerns"
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: Kathleen Lamanna
Submission Time: Feb 11 2024 7:52AM
Email: [e-mail]
Telephone: [phone]
Address: 112 B Columbia Blvd.
Blanchard, ID 83804

Name of U�lity Company: Inland Power

Case ID: SWS-W-23-02

Comment: "I live on the StoneRidge Property on a fixed income and am respec�ully asking you to decline
the request for an increase in this case."
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: Jeffrey Kvaternik
Submission Time: Feb 11 2024 10:20AM
Email: [e-mail]
Telephone: [phone]
Address: 500 Stoneridge RD
Blanchaard, ID 83804-9525

Name of U�lity Company: Stoneridge U�li�es, LLC

Case ID: SWS-W-23-02

Comment: "We are re�red and are on a fixed income and I see this applica�on to increase the new
connec�on hook-up fees for new water system customers by 185% could impact exis�ng customers of
the system. I think that the increase should be modified to a significantly lesser amount. Thank you."
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: Terry Walton
Submission Time: Feb 11 2024 2:49PM
9

Email: [e-mail]
Telephone: [phone]
Address: 80b Columbia Blvd.
Blanchard, ID 83804

Name of U�lity Company: CDS Stoneridge U�li�es

Case ID: SWS-W-23-02

Comment: "The owner is atemp�ng to collect an excessive amount of money, which is over 100% of
addi�onal fees. This is price gouging at its finest."
----------------------------------------------------------------------------------------

The following comment was submited via PUCWeb:

Name: Sandra Sammons
Submission Time: Feb 11 2024 3:47PM
Email: raff[e-mail]
Telephone: [phone]
Address: 30 Links Dr
Blanchard, ID 83804

Name of U�lity Company: Stoneridge U�li�es, LLC

Case ID: SWD-W-23-02

Comment: "
I am wri�ng in opposi�on to the requested increase for approved water hook-up fees, and the possible
excessive monthly rate increases that could follow in the near future.
Stoneridge, is a "re�rement community," and we have fixed incomes with many single income re�rees.
This approval as such could possibly become a hardship for many.
Thank you for your considera�on in denying this applica�on."
----------------------------------------------------------------------------------------