20240314Comments_27.pdf

1

The following comments were submited via PUCWeb:

Name: Ken Rauschenbach
Submission Time: Mar 13 2024 5:19PM
Email: [e-mail]
Telephone: [phone]
Address: 45 Forest Ridge Rd
Blanchard, ID 83804

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

Case ID: SWS-W-24-01

Comment: "I am wri�ng regarding a water rate increase proposed by CDS StoneRidge U�li�es (PO Box
298, Blanchard, Idaho 83804). This is regarding Case number SWS-W-24-01.
This u�lity has proposed water rate increases of 261% to 543%. A�er reviewing the jus�fica�on for these
increases, the reasons given are baseless. As a new member of the StoneRidge community I find the
rate increase outrageous, not only for the excessiveness but it also feels like a monopoly situa�on.
The applica�on for a rate increase should not be considered or approved un�l an accurate, honest,
complete and evidence-based applica�on is submited. A complete forensic audit by IPUC would be
appropriate in this instance to verify all financial documents and claims.
Please deny this applica�on. "
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Name: Jim Graham
Submission Time: Mar 13 2024 6:38PM
Email: [e-mail]
Telephone: [phone]
Address: 70 Links Dr.
Blanchard, ID 83804

Name of U�lity Company: StoneRidge U�li�es LLC

Case ID: SWS-W-24-01

Comment: "I am in receipt of the public no�ce for CDS Stoneridge U�li�es rate increase and I adamantly
oppose said increase. In review of 19 other approved water tariffs found on the IPUC Website, this tariff
increase would put CDS Stoneridge U�li�es at 395% over the average monthly base rate for a 1" service .
Even when adjusted for summer/winter rates and a normalized water usage of 20,000 Gallons they are
s�ll 333% over the average monthly rate of the other 19 u�li�es. In addi�on it appears that they have
put excessive burden on the single family residence's by increasing the 1" Min monthly rate by 543% in
lieu of the 261% increase for all other users (as the 1" service is the standard for all new construc�on).
Furthermore It is understood that we are all seeing increases however in review of other current cases
there is only one other request for a rate increase and it is a request for an increase of 24.61%. I am a
member of the Stoneridge community and many of the people affected by this rate increase are on fixed
incomes (My self included) This rate increase is absurd at best and I would request that the commission
insist that CDS Stoneridge U�li�es put forth a reasonable request.

2

Thank you for your considera�on"
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Name: Cindy Bell
Submission Time: Mar 13 2024 6:43PM
Email: [e-mail]
Telephone: [phone]
Address: 596 StoneRidge Road
Blanchard , ID 83804

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

Case ID: SWS-W-24-01

Comment: "I also oppose the outrageous water rate increase StoneRidge U�lity is reques�ng. I agree
with the comments that other customers have submited. I ask that the IPUC first verify that expenses
submited by the u�lity company truly are solely the water company’s alone. And secondly only approve
a more reasonable and just increase that’s in line with other water rates in Northern Idaho."
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Name: Kaycee Gray
Submission Time: Mar 13 2024 6:54PM
Email: kayo�[e-mail]
Telephone: [phone]
Address: 3151 Poirier Rd
Blanchard , ID 83804

Name of U�lity Company: Stone Ridge

Case ID: SWS-W-24-01

Comment: "I'm opposed to the current rate hike, due to the fact that it will tremendously impact our
financial situa�on."
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Name: Judy Henderson
Submission Time: Mar 13 2024 7:28PM
Email: [e-mail]
Telephone: [phone]
Address: 616 Stoneridge Rd.
Blanchard , ID 83804

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

Case ID: SWS-W-24-01

Comment: "I strongly oppose to the outrageous proposal to increase the water bill for Stoneridge and
surrounding residents. I understand periodic increases are inevitable, however an increase of over
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261% is absurd. How is this jus�fied? Perhaps an audit should be mandatory to show just cause. I
ques�on the quality of the water as it is now. In the summer, I am forced to use botled water due to the
pungent odor expelling from my tap water, and now this?
This is a re�rement community with many of us being on a fixed income. This could drive many of us to
find other living op�ons."
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Name: Judy Henderson
Submission Time: Mar 13 2024 7:28PM
Email: [e-mail]
Telephone: [phone]
Address: 616 Stoneridge Rd.
Blanchard , ID 83804

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

Case ID: SWS-W-24-01

Comment: "I strongly oppose to the outrageous proposal to increase the water bill for Stoneridge and
surrounding residents. I understand periodic increases are inevitable, however an increase of over
261% is absurd. How is this jus�fied? Perhaps an audit should be mandatory to show just cause. I
ques�on the quality of the water as it is now. In the summer, I am forced to use botled water due to the
pungent odor expelling from my tap water, and now this?
This is a re�rement community with many of us being on a fixed income. This could drive many of us to
find other living op�ons."
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Name: Kathi Malakowsky
Submission Time: Mar 13 2024 8:43PM
Email: [e-mail]
Telephone: [phone]
Address: PO Box 2
Blanchard, ID 83804

Name of U�lity Company: CDS StoneRidge U�li�es, LLC

Case ID: SWS-W-24-01

Comment: "I have lived in Happy Valley for 43 years. I was involved with H.V.R. Water Co. as their
treasurer. In 2004 H.V.R. Water Co. annex into Stoneridge U�li�es. Happy Valley Rancho residents were
to accrue an addi�onal charge of $14.03 per month to pay back the 20yr. loan for the hook-up costs. The
loan will be paid off in Sept. 2024 (SWS-W-04-01). We will see if that amount will come off our bill. CDS
StoneRidge U�li�es is now reques�ng a 261% increase in our water rates. This increase is unjus�fied
and full out robbery. Since StoneRidge U�li�es has been under new ownership they have demonstrated
ques�onable business prac�ces. It is hit and miss to be no�fy of a water outages. I have never received
water tes�ng results following a de-pressuriza�on of the system. There has been in-correct billings, not
receiving a bill and so on.

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I haven't witness any up-grades, maintaince to the lines, cleaning of the 30,000 gal. tank that all of
Happy Valley Rancho residents get their water a�er it is pumped there. A financial audit with proper
evidence needs to be done before any increase in our water rates are allowed. Since, StoneRidge
U�li�es and StoneRidge Golf Course is owned by the same person, is that the reason the golf course
would pay 0 for water?

Lastly , if this increase is granted it would make water un-affordable to my family and I know it would be
a hardship for many others that live here. The Public U�li�es Commission is our only hope to stop this
u�lity from unfair pricing.

Thank you for your �me and considera�on regarding this mater, Kathi Malakowsky "
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Name: Stephen Truss
Submission Time: Mar 13 2024 10:19PM
Email: [e-mail]
Telephone: [phone]
Address: 396 Mountain View Road
Blanchard , ID 83804

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

Case ID: SWS-W-24-01

Comment: "I object to the proposed 261% rate increase for water in my neighborhood. My wife and I are
on a fixed income and need to keep our property watered to mi�gate fire risk. Any increase in water
rates cuts into our limited disposal income. The owner of the Stoneridge water u�lity owns several LLCs
in real estate and business ventures in North Idaho. These are capitalis�c ventures that customers have a
say in with their wallets whether they choose to patronize his establishments or not and contribute to
his already mighty wealth. Clean water, on the other hand, is a world wide human right and should not
be the subject of a money grab by a greedy u�lity owner. In my opinion, an altruis�c u�lity owner would
use the massive wealth at his disposal from his other LLC venrures to offset this basic human need and
keep our rates reasonable. Thank you for your �me and considera�on. "
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-----Original Message-----
From: ken corning <[e-mail]>
Sent: Thursday, March 14, 2024 8:28 AM
To: secretary
Subject: Rate hike case #sws-w-24-01 cds Stoneridge’s u�li�es llc

CAUTION: This email originated outside the State of Idaho network. Verify links and atachments BEFORE
you click or open, even if you recognize and/or trust the sender. Contact your agency service desk with
any concerns.

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I believe these rates are crazy high and request a legi�mate audit be done and accountability also be
involved with this decision I’ve been using this water since hvr hooked up to stoneridge years ago my
name is Ken Corning 208-699-8463 Sent from my iPhone
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From: Jacob Polito <jlpoli�[e-mail]>
Sent: Thursday, March 14, 2024 10:02 AM
To: secretary
Subject: Re: sws-w-24-01

my name is Jacob Polito and i reside at 277 lakeview drive Blanchard, Id and i agree with all concerns in
this letter.
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The following comment was submited via PUCWeb:

Name: Douglas and Cassandra Nale
Submission Time: Mar 14 2024 10:54AM
Email: [e-mail]
Telephone: [phone]
Address: 1459 Blanchard Elk Rd.
Blanchard, ID 83804

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

Case ID: SWS-W-24-01

Comment: "Dear Idaho Public U�li�es Commission, We are homeowners who rely on Stoneridge water
daily. We are strongly against the enormous proposed water usage increase. We purchased our home in
2022 taking into considera�on all of the monthly expenditures and a 250+% increase is excessive for a
single-year hike. If the owner needs to raise the rate to improve and maintain equipment for their
customers that is understandable however we ask that an audit be performed to ascertain what a
reasonable increase would be.

We also researched the annual reports contained on your website and found that the current owner
only filed one report in 2018 when he purchased it. We did not find any reports for 2019-2023. If this is
true, the owner has not filed an Annual Report on the u�lity in the last 5 years. Why is that and what is
the current condi�on of our water system and our water? What has he done over the past 6 years to
maintain and/or improve the system that would jus�fy this ridiculous applica�on for increase?

We are relying on your exper�se in this area and request that you determine a fair and reasonable
response to the owner's applica�on.

Douglas and Cassandra Nale"
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The following comment was submited via PUCWeb:

Name: Stephan Rezac
Submission Time: Mar 14 2024 1:51PM
Email: [e-mail]
Telephone: [phone]
Address: 28 Sans Souci Drive
Blanchard, ID 83804

Name of U�lity Company: CDS StoneRidge

Case ID: SWS-W-24-01

Comment: "Please do not blindly accept any numbers submited by the u�lity making this
request...especially any statements including assets, deprecia�on, expenses, investments, claimed losses
or equity. Numbers are just numbers, and this u�lity's numbers require a detailed FORENSIC audit
conducted by IPUC."
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The following comment was submited via PUCWeb:

Name: Stephan Rezac
Submission Time: Mar 14 2024 3:39PM
Email: [e-mail]
Telephone: [phone]
Address: 28 Sans Souci Drive
Blanchard, ID 83804

Name of U�lity Company: CDS StoneRidge

Case ID: SWS-W-24-01

Comment: "The u�lity customers should have the right to examine the monthly financial statements of
the u�lity, and of any organiza�ons owned by Chan Karupiah that the u�lity does business with, such as
Esprit Enterprises or JD Resorts...from date of purchase of the u�lity to present."
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The following comments were submited via PUCWeb:

Name: Larry Cravens
Submission Time: Mar 14 2024 5:07PM
Email: [e-mail]
Telephone: [phone]
Address: 87 Links Rd
7

Blanchard, ID 83804

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

Case ID: SWS-W-24-01

Comment: "We agree with the “Opposi�on and Comment” form you received on Tuesday, Feb. 6th @
10:57 am from the Residents of the StoneRidge community opposing the requested increases from
StoneRidge U�li�es.

Larry and Joyce Cravens"
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Name: Joseph p
Submission Time: Mar 14 2024 5:17PM
Email: [e-mail]
Telephone: [phone]
Address: Happy Valley Ranchos
Blanchard, ID 83804

Name of U�lity Company: CDS StoneRidge U�li�es, LLC

Case ID: SWS-W-24-01

Comment: "Stone Ridge Water Customer- Happy Valley Ranchos Blanchard, Idaho, 83804
Email: [e-mail] 03/14/24 Joseph P.

Idaho Public U�lity Commission P.O. Box 83720 Boise, ID 83720-0074

SE# SWS-W-24-01

Subject: Urgent Opposi�on to Proposed Water Rate Increase by CDS StoneRidge U�li�es, LLC

Dear Members of the Idaho Public U�lity Commission,

I am wri�ng to express my strong opposi�on to the proposed water rate increase by CDS StoneRidge
U�li�es, LLC. As a concerned resident and loyal customer, I believe this proposal is unjus�fied, given the
company's ques�onable financial prac�ces, lack of transparency, and deteriora�ng water quality. I kindly
request the Idaho Public U�lity Commission to thoroughly inves�gate the mater and terminate this
proposal.

Lack of Transparency:
CDS StoneRidge U�li�es, LLC has failed to provide clear and transparent communica�on regarding the
need for a water rate increase. Customers, including myself, are le� in the dark about how the addi�onal
funds will be u�lized, crea�ng a sense of mistrust within the community.

Inappropriate Spending:
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There are reports of extra spending by the company on unrelated ventures, such as a golf course, pub
and grill, which are not directly related to water services. It is unacceptable to burden water customers,
par�cularly those on fixed incomes, with the financial consequences of poor management and unrelated
business ventures.

Owner's Responsibility:
Mr. Chan Karupiah, the owner of CDS StoneRidge U�li�es, LLC, is also the proprietor of the golf course,
pub and grill. It is only fair that he assumes responsibility for all expenses associated with these ventures,
and water customers should not be forced to cover the costs of his unrelated business ac�vi�es.

Financial Mismanagement:
Allega�ons of poor management within CDS StoneRidge U�li�es, LLC raise concerns about the
responsible handling of customer funds. An audit of the company's financial records from 2007 onwards
and definitely 2018 to present, (not just 1 year of 2022/2023 as submited recently by Thereasa as
confiden�al) is essen�al to determine if there have been any irregulari�es or financial mismanagement
and should be shown publicly.

Impact on Fixed-Income &amp; Elderly Families:
Many of CDS StoneRidge U�li�es, LLC's customers are elderly couples and families with children, on
fixed incomes. Burdening them with the consequences of poor business management, especially when
they are already grappling with the challenges of infla�on, is unfair and unacceptable.

Deteriora�ng Water Quality:
In addi�on to financial concerns, there is a no�ceable decline in the quality of the water provided by
CDS StoneRidge U�li�es, LLC. Customers have reported a chemical taste, raising ques�ons about the
safety and quality of the water supply.

Community Opposi�on:
The community strongly opposes this proposed water rate increase and does not want to have to
spend �me and money exploring all available avenues and resources to shed light on the mater and
protect the interests of residents. Chan Karupiah, will be responsible and held accountable for Stone
Ridge U�li�es water customer’s financial harm and emo�onal distress.

In light of the aforemen�oned concerns, I urge the Idaho Public U�lity Commission to thoroughly
inves�gate CDS StoneRidge U�li�es, LLC's financial prac�ces, terminate the proposed water rate
increase, and ensure the water supplied to the community meets the necessary quality standards.

Thank you for your prompt aten�on to this mater, I hope and pray that the Idaho Public U�lity
Commission will act in the best interests of the community.

Sincerely,

Stone Ridge U�li�es Water Customer.

Joseph P."
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Name: Junie Christensen
Submission Time: Mar 14 2024 5:57PM
Email: juniel@fron�er.com
Telephone: [phone]
Address: 704 Stoneridge Rd.
Blanchard, ID 83804

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

Case ID: SWS-W-24-01

Comment: "I bought my house in Stoneridge a�er my husband passed away in 2016. My water bill has
been $24/month since that �me. Now a huge increase has been proposed by Chan (owns water
company) of up to 261% increase. This is unbelievable. What do we do? How can you help?"
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From: DupreeJ <[e-mail]>
Sent: Friday, March 15, 2024 12:01 PM
To: secretary <[e-mail]>
Subject: SWS-W-24-01 + +

Name: John Dupree
Submission Time: Mar 15 2024 10:20 AM
Email: [e-mail]
Telephone: [phone]
Address: 181 Stewart Drive
Blanchard, ID 83804
Name of Utility Company: CDS StoneRidge Utilities
Case ID: SWS-W-24-01
Comment: "To the IPUC:

Greeting IPUC Commissioners,

The tax paying, homeowners of StoneRidge and Happy Valley communities are not
HAPPY at all. Since receiving the CDS StoneRidge Utilities notice with the proposals
of huge increases in the water fees, EVERYONE is extremely upset. It appears IPUC has
not received full and accurate data upon which to make a legal decision. That
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includes: SWS-W-23-01, SWS-W-23-02 and SWS-W-23-03

Upon reading the well written and detailed comments sent in thus far on your IPUC website, it is
clear a FORENSIC AUDIT needs to be implemented of all the same
owner businesses listed on those community comments. Something is just not right
and we would appreciate your investigations prior a final decision. Thank you for your
understanding and thoughtful, honest considerations. "Truth will set us free."

John D. Dupree
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RECEIVED
Wednesday, March 13, 2024 10:54AM
IDAHO PUBLIC
UTILITIES COMMISSION
IPUC
PO Box 83720
Boise, Idaho 83720
Case No. SWS-W-24-0 1
March 14, 2024
Hello,
I am writing regarding a water rate increase proposed by CDS StoneRidge Utilities (PO Box
298, Blanchard, Idaho 83804). This is regarding Case number SWS-W-24-01 .
This utility has proposed water rate increases of 261 % to 543%. After reviewing the rationale
for these increases, all of the reasons given are completely unwarranted.
I ask that you decline the entire rate request by CDS StoneRidge Utilities.
1) CDS StoneRidge claims to have "invested" more than $900,000 since ownership transfer.
This claim was made in the offic ial notice to users. There is no documentation about what
types of investment the ut ility has made. We s us p ect it is to try to recoup $980,000 the
utility owner transferred from Esprit Enterprises/JD's Resort, as found in Case number
SWS-W-23-03 where it was dec lared this was to be t reat ed as owner's equity. PLEASE
verify this claim by the utility. We s us pect that the claimed investment has not been in
infrastructure or system im provements, such as the water system infrastructure •••• the wells.
pumps, transfer pipe system , etc . are the same as when purchased by the utility operator. I
suspect the owner has transferred his OWN money as capital ization, which should be
regarded as owner's equity and not an expense to be rec ouped from utility customers, as
noted in SWS-W-23-03. Add itionally, this current rate inc rease request includes
infrastructure expenditures, which w e note are questionable, and are detailed below.
2) I believe that when CDS StoneRidge purchased the utility, Chan Karupiah, the owner,
claimed to have enough cash and asset s to fund improvements and capitalization. He
should live up to this agreement witho ut impacting users of the utility. Please refer to Case
number SWS-W-18-01 when Karupiah purc hased th e utility. That action declared that "JD
Resort (applicant) must demonstrate hi s fin anc ial abil ity to operate on its own accord. The
notarized personal guarantee of Chan Karup iah 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 al l of his financ ial obligations, 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 abi lity to operate the system in the
public service, not JD Resort by and through Chan Karupiah . JD Resort must be able to
make and pay for ongoing repairs and have access to capital for major repairs, including
pump or w ell failures ... JD Resort must file balance sheets and income statements with the
commi ssion q uarterly ... JD Resort must fi le its balance sheet and income statement for the
quarter ended 30 June, 2019, w ith in 60 days of this Order. Subsequent quarterly financial
statements mu st b e f iled w ithin 45 days of the quarter end. JD Resort must file monthly
bank state ments showing at least a $50,000 balance until JD Resort establishes a bank line
of cred it of at least $250 ,000 ."
3) !he operating expenses absolutely do not justify a rate increase. We believe this proposal
1s about greed. The owner of CDS StoneRidge also owns a golf course .... StoneRidge. The
golf course used to get its water from the utility, about 50,000,000 gallons annually ... we
h~ve h~ard the golf course did NOT pay its water bill at times, if at all. The golf course
dr!l~ed_ its o_wn water well recently and has separated from the utility for water supply. The
utility 1s trying to recapture that lost income from current users. This is unconscionable.
4) The employee related expenses are minimal. One person to read meters for six months of
the year, who also takes ch lorine readings every few days ... a part time employee at best.
Another part time person to administer billings and receive payments. Chan Karupiah
reportedly spends one day per week at StoneRidge ... where he oversees the utility, the
sewer system, the golf course, and the bar/grill. We suspect he has allocated too much
overhead for expenses into the rate increase paperwork. A complete forensic audit by
IPUC would be appropriate in this instance to verify all financial documents and
claims.
5) We understand that, at times, if not currently, CDS StoneRidge, the utility, has been
chronically late with filings and reports due to the IPUC since it was purchased by the
current owner.
Now, let's review Attachment Win the current CDS StoneRidge Utilities rate increase
application.
1) The owner claims to have financial harm from the reduction in water sales to the golf
course. The golf course drilled its own well to avoid water charges from the utility. The
same individual, Chan Karupiah owns the golf course and the utility. Jn essence, he was
paying himself ... the utility he owns was billing the golf course he owns for water. Now ... as
a result of the new golf course well, the golf course has a significantly lower cost for water,
a huge savings to Karupiah. BUT ... now he wants utility users to pay for what HE used to
pay. That is simply unconscionable. This proposal actually doubles his gain ... reduced water
fees for the golf course AND replace that lost income at the expense of the utility users ...
nearly 50,000,000 gallons of water cost annually! This should not be allowed.
2) The utility wants to replace 3 pump motors. To my knowledge , there are currently two
working wells for the utility. The application document cites attachment W-1, but it is not
included in the available download paperwork. This expenditure is a responsibility of the
utility, not the users. The owner shou ld fund this and absorb the expense, per the
agreements made when Karupiah purchased the utility (noted above).
3) The utility wants to install (replace?) "backup electrical generators" at water pump sites.
The application document c ites attachment W -2, but it is not included in the available
download paperwork. This expenditure is the responsibility of the utility, not the users. The
owner should fund this and absorb the expense, per the agreements made when Karupiah
purchased the utility (noted above).
4) The utility wants to purchase a pickup and a 4 wheeler. The application document cites
attachment W-3, but it is not included in the availab le download paperwork. The use of
these vehicles would likely be shared by other entities owned by Karupiah, and the
expense should be accurately allocated. The owner should fund these purchases and
absorb the expense, per the agreements made when Kaupiah purchased the utility (noted
above. HOWEVER, in the "Related Entity Narrative, Asset ownership and Existing Leases"
document in the current request, it states that Esprit leases to the water company the
following: vehicles and other light truck equipment. How can you have it both ways?
5) The utility wants the users to fund the connection costs for 20 vacant plotted lots. What
Karupiah fails to mention in the application is that he owns the 20 lots. The cost for this is
detailed in attachment W-4, which is not included in the available document download.
This clearly is an expense of the utility and the lot owner(s) ... not the utility users.
6) The utility wants to install approximately 360 meters to remotely read water usage. The
application cites attachment W-5, but is is not included in the available document
download. What is not noted or projected is the effective savings to the utility by not
manually reading the meters. This should be an expense of the utility and certainly not the
users.
Now let s take a look at some other concerns.
In Exhibit 1, schedule B, Accumulated Depreciation, there is a line item for "structures and
improvements. ' Also included are things like supply mains, power pumping equipment,
purification systems meters, hydrants, etc. But the largest line item is "Structures and
Improvements' at $774 820 ... by far the largest amount on this schedule. What could this utility
possibly have at more than 3/4 of a million dollars in this line item? In the documentation, it is
reported that the utility leases facilities from other entities owned by Karupiah. In the "Related
Narrative Asset Ownership and Existing Leases" it states "There is no land included nor, water
rights, or miscellaneous equipment included in the balance sheet for CDS StoneRidge Utilities"
and "Esprit owns all buildings, and miscellaneous equipment not on the StoneRidge Water
Company balance sheet as well as the remainder land parcels, and ROW rights." Esprit leases
to the water company the following: office and shop space, vehicles and other light truck
equipment, office equipment, and water rights and use of ROW. What is included in this
"structures and improvements" line item that totals $77 4,820? Also in this listing is a line item
for "Services" at $30,101. What services are depreciated?
Regarding Attachment L, Exhibit #2 Schedule B Expenses: Labor and Salaries total a
whopping $223,267. I would encourage the IPUC to review, forensically audit and validate this
level of expense for a relatively small, simple water utility. Meters aren't read half the year.
Chlorine levels are only sampled 2-3 times per week. Billing and payments are processed at a
part time level at best. This number is highly suspicious.
Regarding Attachment N Exhibit 3 Cost of Capital: Long term debt is listed at $104,005. Water
utility users should not be repaying a loan for the owners capital/equity.
The application for a rate increase should not be considered or approved until an accurate,
honest, complete and evidence based application is submitted.
Please deny this rate increase request in its entirety .
.:Je>~L-,$ .,-!lA"' {:,~
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(609) (; 71 -OI 9 '/
IPUC
PO Box 83720
Boise, Idaho 83720

Case No. SWS-W-24-01

March 14, 2024

Hello,

I am writing regarding a water rate increase proposed by CDS StoneRidge Utilities (PO Box 298, Blanchard, Idaho 83804). This is regarding Case number SWS-W-24-01.

This utility has proposed water rate increases of 261% to 543%. After reviewing the rationale for these increases, all of the reasons given are completely unwarranted.

I ask that you decline the entire rate request by CDS StoneRidge Utilities.
1)CDS StoneRidge claims to have “invested” more than $900,000 since ownership transfer. This claim was made in the official notice to users. There is no documentation about what types of investment the utility has made. We suspect it is to try to recoup $980,000 the utility owner transferred from Esprit Enterprises/JD’s Resort, as found in Case number SWS-W-23-03 where it was declared this was to be treated as owner’s equity. PLEASE verify this claim by the utility. We suspect that the claimed investment has not been in infrastructure or system improvements, such as the water system infrastructure….the wells. pumps, transfer pipe system, etc. are the same as when purchased by the utility operator. I suspect the owner has transferred his OWN money as capitalization, which should be regarded as owner’s equity and not an expense to be recouped from utility customers, as noted in SWS-W-23-03. Additionally, this current rate increase request includes infrastructure expenditures, which we note are questionable, and are detailed below.

2)I believe that when CDS StoneRidge purchased the utility, Chan Karupiah, the owner, claimed to have enough cash and assets to fund improvements and capitalization. He should live up to this agreement without impacting users of the utility. Please refer to Case number SWS-W-18-01 when Karupiah purchased the utility. That action declared that “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 obligations, 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. JD Resort 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 until JD Resort establishes a bank line of credit of at least $250,000.”

RECEIVED
Thursday, March 14, 2024 10:01AM
IDAHO PUBLIC
UTILITIES COMMISSION
3)The operating expenses absolutely do not justify a rate increase. We believe this proposal is about greed. The owner of CDS StoneRidge also owns a golf course….StoneRidge. The golf course used to get its water from the utility, about 50,000,000 gallons annually…we have heard the golf course did NOT pay its water bill at times, if at all. The golf course drilled its own water well recently and has separated from the utility for water supply. The utility is trying to recapture that lost income from current users. This is unconscionable.

4)The employee related expenses are minimal. One person to read meters for six months of the year, who also takes chlorine readings every few days…a part time employee at best. Another part time person to administer billings and receive payments. Chan Karupiah reportedly spends one day per week at StoneRidge…where he oversees the utility, the sewer system, the golf course, and the bar/grill. We suspect he has allocated too much
overhead for expenses into the rate increase paperwork. A complete forensic audit by
IPUC would be appropriate in this instance to verify all financial documents and
claims.
5)We understand that, at times, if not currently, CDS StoneRidge, the utility, has been chronically late with filings and reports due to the IPUC since it was purchased by the current owner.

Now, let’s review Attachment W in the current CDS StoneRidge Utilities rate increase application.

1)The owner claims to have financial harm from the reduction in water sales to the golf course. The golf course drilled its own well to avoid water charges from the utility. The same individual, Chan Karupiah owns the golf course and the utility. In essence, he was paying himself…the utility he owns was billing the golf course he owns for water. Now…as a result of the new golf course well, the golf course has a significantly lower cost for water, a huge savings to Karupiah. BUT…now he wants utility users to pay for what HE used to pay. That is simply unconscionable. This proposal actually doubles his gain…reduced water fees for the golf course AND replace that lost income at the expense of the utility users…nearly 50,000,000 gallons of water cost annually! This should not be allowed.

2)The utility wants to replace 3 pump motors. To my knowledge, there are currently two working wells for the utility. The application document cites attachment W-1, but it is not included in the available download paperwork. This expenditure is a responsibility of the utility, not the users. The owner should fund this and absorb the expense, per the agreements made when Karupiah purchased the utility (noted above).

3)The utility wants to install (replace?) “backup electrical generators” at water pump sites. The application document cites attachment W-2, but it is not included in the available download paperwork. This expenditure is the responsibility of the utility, not the users. The owner should fund this and absorb the expense, per the agreements made when Karupiah purchased the utility (noted above).

4)The utility wants to purchase a pickup and a 4 wheeler. The application document cites attachment W-3, but it is not included in the available download paperwork. The use of these vehicles would likely be shared by other entities owned by Karupiah, and the expense should be accurately allocated. The owner should fund these purchases and absorb the expense, per the agreements made when Kaupiah purchased the utility (noted above. HOWEVER, in the “Related Entity Narrative, Asset ownership and Existing Leases” document in the current request, it states that Esprit leases to the water company the following: vehicles and other light truck equipment. How can you have it both ways?

5)The utility wants the users to fund the connection costs for 20 vacant plotted lots. WhatKarupiah fails to mention in the application is that he owns the 20 lots. The cost for this isdetailed in attachment W-4, which is not included in the available document download.This clearly is an expense of the utility and the lot owner(s)…not the utility users.
6)The utility wants to install approximately 360 meters to remotely read water usage. Theapplication cites attachment W-5, but is is not included in the available documentdownload. What is not noted or projected is the effective savings to the utility by notmanually reading the meters. This should be an expense of the utility and certainly not theusers.
Now let’s take a look at some other concerns.

In Exhibit 1, schedule B, Accumulated Depreciation, there is a line item for “structures and improvements.” Also included are things like supply mains, power pumping equipment, purification systems, meters, hydrants, etc. But the largest line item is “Structures and Improvements” at $774,820…by far the largest amount on this schedule. What could this utility possibly have at more than 3/4 of a million dollars in this line item? In the documentation, it is reported that the utility leases facilities from other entities owned by Karupiah. In the “Related Narrative, Asset Ownership and Existing Leases” it states “There is no land included nor, water rights, or miscellaneous equipment included in the balance sheet for CDS StoneRidge Utilities” and “Esprit owns all buildings, and miscellaneous equipment not on the StoneRidge Water Company balance sheet as well as the remainder land parcels, and ROW rights.” Esprit leases to the water company the following: office and shop space, vehicles and other light truck equipment, office equipment, and water rights and use of ROW. What is included in this “structures and improvements” line item that totals $774,820? Also in this listing is a line item for “Services” at $30,101. What services are depreciated?

Regarding Attachment L, Exhibit #2 Schedule B Expenses: Labor and Salaries total a whopping $223,267. I would encourage the IPUC to review, forensically audit and validate this level of expense for a relatively small, simple water utility. Meters aren’t read half the year. Chlorine levels are only sampled 2-3 times per week. Billing and payments are processed at a part time level at best. This number is highly suspicious.

Regarding Attachment N Exhibit 3 Cost of Capital: Long term debt is listed at $104,005. Water utility users should not be repaying a loan for the owners capital/equity.

The application for a rate increase should not be considered or approved until an accurate, honest, complete and evidence based application is submitted.

Please deny this rate increase request in its entirety.
Thank you.
From: Jacob Polito <[e-mail]>
Sent: Thursday, March 14, 2024 10:01 AM
To: secretary
Subject: sws-w-24-01
RECEIVED
Thursday, March 14, 2024 2:13PM
IDAHO PUBLIC
UTILITIES COMMISSION
-----Original Message-----
From: Toni Kiel <[e-mail]>
Sent: Thursday, March 14, 2024 2:13 PM
To: secretary
Subject: CDS Stoneridge
Sws-w-24-01 Please see attached
Chris and Toni Curtis
177 Deer Trail Rd Blanchard ID
I
IPUC
PO Box 83720
Boise, Idaho 83720
I Case No. SWS-W-24-01
I
March 14, 2024
Hello,
I am writing regarding a water rate increase proposed by CDS StoneRidge Utilities (PO Box
298, Blanchard. Idaho 83804). This is regarding Case number SWS-W-24-01.
This utility has proposed water rate increases of 261 % to 543%. After reviewing the rationale
for these increases, all of the reasons given are completely unwarranted.
f ask that you decline the entire rate request by CDS StoneRidge Utilities.
1) CDS StoneRidge claims to have "invested" more than $900,000 since ownership transfer.
This cla.im was made in the official notice to users. There is no documentation about what
types of investment the utility has made. We suspect it is to try to recoup $980,000 the
utility owner transferred from Esprit Enterprises/JD's Resort, as found in Case number
SWS-W-23-03 where it was declared this was to be treated as owner's equity. PLEASE
verify this claim by the utility. We suspect that the claimed investment has not been in
infrastructure or system improvements, such as the water system infrastructure .... the wells.
pumps, transfer pipe system, etc. are the same as when purchased by the utility operator. I
suspect the owner has transferred his OWN money as capitalization, which should be
regarded as owner's equity and not an expense to be recouped from utility customers, as
noted in SWS-W-23-03. Additionally, this current rate increase request includes
infrastructure expenditures, which we note are questionable, and are detailed below.
2) I believe that when CDS StoneRidge purchased the utility, Chan Karupiah, the owner,
claimed to have enough cash and assets to fund improvements and capitalization. He
should live up to this agreement without impactfng users of the utility. Please refer to Case
number SWS-W-18-01 when Ka.rupiah purchased the utility. That action declared that u JD
Resort (appficant) 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 neBds of the company is of uncertain value. If Mr. Karupiah were to file bankruptcy
or otherwise being unable to meet all of his financial obligations, 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. JD Resort 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 tiled within 45 days of the quarter end. JD Resort must file monthly
bank statements showing at least a $50,000 balance until JD Resort establishes a bank line
of credit of at least $250,000."
Thunderbird
3) 7"he operating expenses absolutely do not justify a rate increase. We believe this proposal
1s about greed. The owner of CDS StoneRidge also owns a golf course .... StoneRidge. The
golf course used to get its water from the utility. about 50.000.000 gallons annuaUy ... we
h~ve h~ard the golf course did NOT pay its water bill at times, if at all. The golf course
d~l!ed. its o.wn water wen recently and has separated from the utility for water supply. The
ut1hty 1s trying to recapture that lost income from current users. This is unconscionable.
4) The employee related expenses are minimal. One person to read meters for six months of
the year. who also takes chlorine readings every few days ... a part time employee at best.
Another part time person to administer billings and receive payments. Chan Karupiah
reportedly spends one day per week at StoneRidge ... where he oversees the utility, the
sewer system, the golf course. and the bar/grilf. We suspect he has allocated too much
overhead for expenses into the rate increase paperwork. A complete forensic audit by
IPUC would be appropriate in this instance to verify all financi.a1 documents and
claims ..
5} We understand that, at times, if not currently, CDS StoneRidge, the utility, has been
chronically late with filings and reports due to the !PUC since it was purchased by the
current owner.
Now, let's review Attacl1ment W in the current CDS StoneRidge Utilities rate increase
applica ion.
1) The owner claims to have financial harm from the reduction in water sales to the golf
course. The gotf course drilled its own well to avoid water charges from the utility. The
same individual, Chan Karupiah owns the golf course and the utility. In essence. he was
paying himself ... the utility he owns was billing the golf course he owns for water. Now ... as
a result of the new gaff course well, the golf course has a significantly lower cost for water,
a huge savings to Karupiah. BUT ... now he wants utility users to pay for what HE used to
pay. That is simply unconscionable. This proposal actually doubles his gain ... reduced water
fees for the golf course AND replace that lost income at the expense of the utility users ...
nearly 50,000,000 gallons of water cost annuallyl This should not be allowed.
2} The utility wants to repface 3 pump motors. To my knowledge, there are currently two
working wells for the utility. The application document cites attachment W-1, but tt is not
included in the available download paperwork. This expenditure is a responsibility of the
utility, not the users. The owner should fund this and absorb the expense, per the
agreements made when Karupiah purchased the utility {noted above).
3) The utility wants to install (replace?) "backup er ctrical gen raters" at water pump sites.
The application document cites attachment W~2, but it is not included in the available
download paperwork. This expenditure is the responsibility of the utility. not the users. The
owner should fund this and absorb tl1e expense, per the agreements made when Karupiah
purchased the utility (noted above).
4) The utility wants to purchase a pickup and 4 wheeler. Toe . pplication document cites
attachment W-3, but it is not included in the available download paperwork. The use of
these vehicles would likely be shared by other entities owned by Karupiah and the
expense should be accurately allocated. The owner should fund these purchases and
absorb the expense, per the agreements made when Kaupiah purchased the utility (noted
above. HOWEVER, in the "Related Entity Narrative, Asset ownership and Existing Leases"
document in the current request, it states that Esprit leases to the water company the
following: vehicles and other light truck equipment. How can you have it both ways?
3/13/2024, 3:36 PM
Thunderbird
5) The utility wants the users to fund the connection costs for 20 vacant plotted lots. What
Karupiah fails to mention in the apptication is that he owns the 20 lots. The cost for this is
detailed in attachment W-4. which is not included in the available document download.
This clearly is an expense of the utility and the lot owner(s) ... not the utility users.
6) The utility wants to install approximately 360 meters to remotely read water usage. The
application cites attachment W-5, but' is is not included in the available document
download. What is not noted or projected is the effective savings to the utility by not
manually reading the meters. This should be an expense of the utility and certainly not the
users.
Now let's take a look at some other concerns.
In Exhibit 1. schedule B Accumulated Depreciation. there is a line item for ustructures and
improvements." Also included are things like supply mains, power pumping equipment,
purification systems, meters, hydrants, etc. But the largest line item is "Structures and
Improvements" at $774,820 ... by far the largest amount on this schedule. What could this utility
possibly have at more than 3/4 of a million dolfars in this line item? In the documentation, it is
reported that the utility leases facilities from other entities owned by Karupiah. In the "Related
Narrative. Asset Ownership and Existing Leases" it states "There is no land included nor, water
rights, or miscellaneous equipment included in the balance sheet for CDS StoneAidge Utilities''
and "Esprit owns alt buildings, and miscellaneous equipment not on the StoneRidge Water
Company balance sheet as well as the remainder land parcels, and ROW rights." Esprit leases
to the water company the following: office and shop space, vehicles and other light truck
equipment office equipment, and water rights and use of ROW. What is included in this
"structures and improvements" line item that totals $77 4,820? Also in this listing is a line i1em
for "Services'' at $30,.101. What services are depreciated?
Regarding Attachment L, Exhibit #2 Schedule B Expenses: Labor and Salaries totaJ a
whopping $223,267. I would encourage the IPUC to review, forensically audit and validate this
level of expense for a relafively small, simple water utility. Meters aren't read half the year.
Chlorine levels are only sampled 2-3 times per week. Billing and payments are processed at a
part time level at best This number is highly suspicious.
Regarding Attachment N Exhibit 3 Cost of Capital: Long 1:erm debt is listeo at $104,005. Wa-ter
utility users should not be repaying a loan for the owners capital/equity.
The application for a rate increase should not be considered or approved until an accurate,
honest, complete arid evidence based applic"8tion is submTtted.
Please deny this rate increase request in its entirety.
Thank you.
3/13/2024, 3:37 Pl\
RECEIVED
Thursday, March 14, 2024 7:51PM
IDAHO PUBLIC
UTILITIES COMMISSION
IPUC
PO Box 83720
Boise, Idaho 83720
Case No. SWS-W-24-01
March 14. 2024
Hello,
I am writing regarding a water rate increase proposed by COS StoneRidge Utilities (PO Box
298. Blanchard, Idaho 83804). This is regarding Case number SWS-W-24-01.
This utility has proposed water rate increases of 261 % to 543%. After reviewing the rationale
for these increases. all of the reasons given are completely unwarranted.
I ask that you decline the entire rate request by CDS StoneRidge Utilities.
1) CDS StoneRidge claims to have "invested" more than $900,000 since ownership transfer.
This claim was made in the official notice to users. There is no documen a ion about what
types of investment the utility has made. We suspect it is to try to recoup 980,000 he
utility owner transferred from Esprit Enterprises/JO's Resort, as found in Case number
SWS-W-23-03 where it was declared this was to be treated as owner's equi y. PLEASE
verify this claim by the utility. We suspect that the claimed investment has o oeen m
infrastruc ure or system improvements, such as the water system infrastruc ure ... he wells.
pumps, ransfer pipe system, etc. are the same as when purchased by he utility operator. I
suspec the owner has transferred his OWN money as capitalization, which should oe
regarded as owner's equity and not an expense to be recouped from u ility customers. as
noted in S S--23-03. Additionally, this current rate increase reques includes
infrastructure expenditures, which we note are questionable, and are detailed below.
2) I believe that when CDS StoneRidge purchased the utility, Chan Karupiah, the o ner,
claimed to have enough cash and assets to fund improvements and capi altza 10n. He
should live up to this agreement without impacting users of the utility. Please refer o Case
number SWS-W-18-01 when Karupiah purchased the utility. That action declared hat "JD
Resort (applicant) must demonstrate his financial ability to operate on its o n accord. The
notarized personal guarantee of Chan Karupiah to use his personal fin nces to support he
financial needs of the company is of uncertain value. If Mr. Karup, h ere to file n rup cy
or otherwise being unable to meet all of his financial oblig tions, sign p rsonal
guarantee to financially support a legally separate comp ny is dubious lue compared to
more standard cash capital or debt instruments likely h Id by other creditors. Therefore, we
require assurances that JD Resort has the financial ability to oper te the system in the
public service, not JD Resort by and through Ch n K rupi h. JD Resort must be ble to
make and pay for ongoing repairs and have ace s to c p1tal for m jor repairs. including
pump or well failures ... JD Resort must file b lance sh ts nd in ome statements with the
commission quarterly ... JO Resort must file its bat nee h t 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 qu rter end. JO Resort must file monthly
bank statements showing at least a $50,000 balance until JD Resort establishes a bank line
of credit of at least $250,000."
3) !he operating expenses absolutely do not justify a rate increase. We believe this proposal
1s about greed. The owner of CDS StoneRidge also owns a golf course .... StoneRidge. The
golf course used to get its water from the utility, about 50,000,000 gallons annually ... we
h~ve h~ard the golf course did NOT pay its water bill at times, if at all. The golf course
dr~l!ed_ its ~wn water well recently and has separated from the utility for water supply. The
utility 1s trying to recapture that lost income from current users. This is unconscionable.
4) The employee related expenses are minimal. One person to read meters for six months of
the year, who also takes chlorine readings every few days ... a part time employee at best.
Another part time person to administer billings and receive payments. Chan Karupiah
reportedly spends one day per week at StoneRidge ... where he oversees the utility, the
sewer system, the golf course, and the bar/grill. We suspect he has allocated too much
overhead for expenses into the rate increase paperwork. A complete forensic audit by
IPUC would be appropriate in this instance to verify all financial documents and
claims.
5) We understand that, at times, if not currently, CDS StoneRidge, the utility, has been
chronically late with filings and reports due to the IPUC since it was purchased by he
current owner.
Now. let's review Attachment W in the current CDS StoneRidge Utilities rate increase
application.
1) The owner claims to have financial harm from the reduction in water sales to he golf
course. The golf course drilled its own well to avoid water charges from the utility. The
same individual, Chan Karupiah owns the golf course and the utility. In essence, ne was
paying himself ... the utility he owns was billing the golf course he owns for a er. ow ... as
a result of the new golf course well, the golf course has a significantly lower cost for water,
a huge savings to Karupiah. BUT ... now he wants utility users to pay for what HE used to
pay. That is simply unconscionable. This proposal actually doubles his gain ... reduced water
fees for the golf course AND replace that lost income at the expense of the utility users ...
nearly 50,000,000 gallons of water cost annually! This should not be allowed.
2) The utility wants to replace 3 pump motors. To my knowledge, there are currently t o
working wells for the utility. The application document cites attachment W-1. but it is not
. included in the available download paperwork. This expenditure is a responsibility of he
utility, not the users. The owner should fund this and absorb the expense, per the
agreements made when Karupiah purchased the utility (noted above).
3) The utility wants to install (replace?) "backup electrical generators" at ater pump sites.
The application document cites attachment W-2, but it is not include in the available
download paperwork. This expenditure is the responsibility of the utility, not the users. The
owner should fund this and absorb the expense, per the agreements made when Karupiah
purchased the utility (noted above).
4) The utility wants to purchase a pickup and a 4 wheeler. The application document cites
attachment W-3, but it is not included in the available download paperwork. The use of
these vehicles would likely be shared by other entities owned by Karupiah, and the
expense should be accurately allocated. The owner should fund these purchases and
absorb the expense, per the agreements made when Kaupiah purchased the utility (noted
above. HOWEVER, in the "Related Entity Narrative, Asset ownership and Existing Leases''
document in the current request, it states that Esprit leases to the water company the
following: vehicles and other light truck equipment. How can you have it both ways?
5) The utility wants the users to fund the connection costs for 20 vacant plotted lots. What
Karupiah fails to mention in the application is that he owns the 20 lots. The cost for this is
detailed in attachment W•4, which is not included in the available document download.
This clearly is an expense of the utility and the lot owner(s) ... not the utility users.
6) The utility wants to install approximately 360 meters to remotely read water usage. The
application cites attachment W-5, but is is not included in the available document
download. What is not noted or projected is the effective savings to he utility by not
manually reading the meters. This should be an expense of the utility and certainly not the
users.
Now let's take a look at some other concerns.
In Exhibit 1 schedule B. Accumulated Depreciation, there is a line item for "structures and
improvements." Also included are things like supply mains, power pumping equipment,
purification systems, meters, hydrants, etc. But the largest line item is "Structures and
Improvements" at $774,820 ... by far the largest amount on this schedule. What could this utility
possibly have at more than 3/4 of a million dollars in this line item? In the documentation, it is
reported that the utility leases facilities from other entities owned by Karupiah. In the "Related
arrative. Asset Ownership and Existing Leases" it states "There is no land included nor, water
rights, or miscellaneous equipment included in the balance sheet for CDS StoneRidge Utilities"
and "Esprit owns all buildings, and miscellaneous equipment not on the S oneRidge Water
Company balance sheet as well as the remainder land parcels, and ROW rights." Espnt leases
to the water company the following: office and shop space, vehicles and other ligh ruck
equipment, office equipment, and water rights and use of ROW. What is included in this
"structures and improvements" line item that totals $774,820? Also in this listing isaJioe item
for "Services" at $30,101. What services are depreciated?
Regarding Attachment L, Exhibit #2 Schedule B Expenses: Labor and Salaries total a
whopping $223,267. I would encourage the IPUC to review, forensically audit and validate this
level of expense for a relatively small, simple water utility. Meters aren't read half the year
Chlorine levels are only sampled 2-3 times per week. Billing and payments are processed at a
part time level at best. This number is highly suspicious.
Regarding Attachment N Exhibit 3 Cost of Capital: Long term debt is listed at 104,005. Water
utility users should not be repaying a loan for the owners capital/equity.
The application for a rate increase should not be considered or approved until an accurate,
honest, complete and evidence based application is submitted.
Please deny this rate increase request in its entirety.
Thank you.
m Jl B • -,/;. / I CU'ff tA. , y a/l,(/4,' flPil/Y fJ, BR.; tf?IJ
1u1 s!Qneribe tl
/JIIIA1th4rJ Ji{ t3f01
(s n) PN:. h::; s I
Mary Brittin <[e-mail]>