20240322Staff 1-30 to SWS.pdf

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 MARCH 22, 2024
MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS STONERIDGE
UTILITIES, LLC’S APPLICATION FOR
AUTHORITY TO INCREASE ITS RATES
AND CHARGES FOR WATER SERVICE IN
THE STATE OF IDAHO
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CASE NO. SWS-W-24-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO CDS STONERIDGE
UTILITIES, LLC
Staff of the Idaho Public Utilities Commission (“Commission”), by and through its
attorney of record, Michael Duval, Deputy Attorney General, requests that CDS Stoneridge
Utilities, LLC (“Company”) provide the following documents and information as soon as
possible, but no later than FRIDAY, APRIL 12, 2024.
This Production Request is to be considered as continuing, and the Company is requested
to provide, by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name, job title, and telephone number of
the person preparing the documents. Please also identify the name, job title, location, and
telephone number of the record holder.
RECEIVED
Friday, March 22, 2024 2:24 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 MARCH 22, 2024
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.

REQUEST NO. 1: Please provide a schedule showing all costs incurred in processing
the general rate case to present.

REQUEST NO. 2: Please provide a schedule showing the details of the Known
Changes in the Accumulated Depreciation as shown in Exhibit No. 1, Schedule B.

REQUEST NO. 3: Please provide the costs and benefits to the system and a narrative to
explain why it is necessary for the golf course to be on its own well, as is stated in Exhibit No. 2,
Schedule A.

REQUEST NO. 4: Please provide a schedule explaining the known changes for the
Purchased Power and Chemical Expenses shown in Exhibit No. 2, Schedule B.

REQUEST NO. 5: Please provide a schedule detailing the calculation of the test year
actual depreciation expense and known changes to depreciation expense as shown in Exhibit No.
2, Schedule C.

REQUEST NO. 6: Please provide the loan documents for all debt outstanding. Please
include a current balance and amortization schedule for each debt.

REQUEST NO. 7: Please provide up-to-date and separate geo-spatial system maps that
outline all contiguous water utility systems operated by the Company. The map should include
the location and elevation of major equipment including wells, distribution piping, storage tanks,
booster pumps, shut-off valves, meters, fire hydrants, water treatment equipment, etc.
NOTE: Please provide this map in electronic format (PDF) which can be scaled and
enlarged to identify all aspects of the system.

REQUEST NO. 8: Please provide a thorough and complete description of the water
system including the following details regarding the system as applicable:
a. The depth, width, length, capacity, length of time in service, and construction
materials of each well (including backup wells, if any).
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 MARCH 22, 2024
b. The make, model, type, length of time in service, and rating of each well pump
motor.
c. The make, model, capacity, length of time in service, and limit switch settings of
each pressurized storage tank.
d. The make, model, capacity, length of time in service, and limit switch settings of
each unpressurized storage tank/reservoir.
e. The make, model, length of time in service, and rating of each booster pump and
motor.
f. The make, model, length of time in service, and capacity of all water treatment
equipment.
g. The year, make, model, length of time in service, and capacity for backup
generation supporting the well pumps. Indicate if the generation has an Automatic
Transfer Switch or if it must be manually started.
h. The distribution piping line size, length of time in service, and materials specified
in the installation.

REQUEST NO. 9: Please provide detailed information related to the capacity and
sizing of the system and the ability of the system to meet historical and future system peak
demands.
Provided information should include identification of the potential constraints in the
system, the capacity of each constraint, and the average and maximum peak consumption.
Please provide necessary workpapers in spreadsheet (such as, Microsoft Excel) format with
formulas intact.

REQUEST NO. 10: For each well used by the water system, please provide the
following:
a. The Idaho Department of Water Resources (“IDWR”) Well Tag Number (i.e. D-
Tag Number) that is currently on-file with IDWR.
b. Location (Township, Range, Section, and Tract)

REQUEST NO. 11: Please provide the monthly power bills indicating the amount of
electricity, in kilowatt hours, used and corresponding electricity cost (in US Dollars) for each
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 4 MARCH 22, 2024
well and booster pump from January 2019 to December 2023. Please provide your responses in
spreadsheet (such as, Microsoft Excel) format with formulas intact.

REQUEST NO. 12: Please provide the monthly metered amount of water (in gallons)
pumped from each well from January 2019 to December 2023. Please provide your responses in
spreadsheet (such as, Microsoft Excel) format with formulas intact.

REQUEST NO. 13: Please provide the monthly metered total customer water usage
data (in gallons) by customer types, customer ID, route, and meter size from January 2019 to
December 2023. Please provide your responses in spreadsheet (such as, Microsoft Excel) format
with formulas intact.

REQUEST NO. 14: Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc. by month from January 2019 to December 2023. Please provide your
responses in spreadsheet (such as, Microsoft Excel) format with formulas intact.

REQUEST NO. 15: Please provide the total monthly amount of Chlorine used (in
pounds), and total expense for Chlorine purchase (including Sales Tax) for each well from
January 2019 to December 2023. Also please specify whether a solid or liquid form of Chlorine
was used for each well. Please provide your responses in spreadsheet (such as, Microsoft Excel)
format with formulas intact.

REQUEST NO. 16: Please provide a copy of the Company’s latest Idaho Division of
Environmental Quality Sanitary Survey.

REQUEST NO. 17: Please provide the average monthly pressure data in the main
distribution line from January 2019 to December 2023. Please provide your responses in
spreadsheet (such as, Microsoft Excel) format with formulas intact.

REQUEST NO. 18: Please describe the Company’s methodology for developing,
managing, executing, and completing Capital Projects in a least cost manner. Please provide a
copy of all Company policies and procedures documenting the process.

RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 5 MARCH 22, 2024
REQUEST NO. 19: In “Exhibit 9 Cap Ex. Backup Generators Etc.” of the Application,
the Company listed the following items:
1. Well Pump House ($104,940)
2. Forest Lift Station ($26,235)
3. Upper Tank Pump ($13,118)
For each of the above-mentioned items, please provide the following documentation. If
any of the information requested below cannot be provided or is not available, please explain
why; also explain how the Company can ensure the project was or will be completed at least
cost.
a. Analysis of Need: a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b. Project Plan:
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. Requests for proposals (“RFP”) or requests for quotes (“RFQ”):
i. Project requirements and specifications.
ii. RFP/RFQ from winning bid.
d. Project construction documentation including:
i. Construction contracts, invoices, etc.
ii. Contractors change order request(s).
e. Explain how the Company ensured the project was or will be completed at
least cost.

REQUEST NO. 20: In “Exhibit 10 Cap Ex. Budget Wireless Meters” of the
Application, the Company listed several items.
1. For the Line Item “Meters Replaced (360),” please provide a list of customers
whose meters were or will be replaced including, but not limited to, meter
installation date, water service activation date, respective address for each
customer.
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 6 MARCH 22, 2024
2. For the Line Item “Plus Transceiver & Software ($9,275),” please provide the
following information and supporting documentation:
a. Proposed budget.
b. Proposed schedule.
c. Information regarding RFP or RFQ including, but not limited to,
requirements and specifications, RFP/RFQ of winning bid, etc.
d. Installation contracts, invoices, etc. justifying the cost.
e. Explain how the Company ensured the project was or will be completed at
least cost.

REQUEST NO. 21: In “Exhibit 11 Capital Expansion Budget Pump Motor
Replacement” of the Application, the Company listed the following items:
1. Well Pump House ($120,000)
2. Forest Lift Station ($14,000)
For each of the above-mentioned items, please provide the following documentation. If
any of the information requested below cannot be provided or is not available, please explain
why.
a. Analysis of Need: a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b. Project Plan:
i. Initial project scope.
ii. Proposed budget.
iii. Proposed schedule.
c. RFP or RFQ:
i. Project requirements and specifications.
ii. RFP/RFQ from winning bid.
d. Project construction documentation including:
i. Construction contracts, invoices, etc.
ii. Contractors change order request(s).
e. Explain how the Company ensured the project was or will be completed at
least cost.
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 7 MARCH 22, 2024

REQUEST NO. 22: In “Exhibit #12 CAP EX VEHICLE INVESTMENTS” of the
Application, the Company listed the following items:
1. 2024 Toyota Tundra 4 Wheel Drive Max 6 Hybrid ($78,000)
2. 4 Wheel Gator ($20,000)
For each of the above-mentioned items, please provide the following documentation. If
any of the information requested below cannot be provided or is not available, please explain
why.
a. Analysis of Need: a justification of need for the project and a cost/benefit
analysis comparing alternatives.
b. Project Plan:
i. Proposed budget.
ii. Proposed schedule.
c. RFP or RFQ:
i. Project requirements and specifications.
ii. RFP/RFQ from winning bid.
d. Documentation including, but not limited to, vehicle contracts, invoices, etc.
e. Explain how the Company ensured the purchase was or will be completed at
least cost.

REQUEST NO. 23: Does the Company expect customer growth? If so, please provide
workpapers and documentation including, but not limited to, the potential number of customers
and type of customers by year for the next five years.

REQUEST NO. 24: Please reconcile the Monthly Minimum Charge of Current Tariff
for 1-inch metered customers from Exhibit Nos. 5 and 7 of $42.72 and Attachment E “copy of
Customer Notice and Mailing Date” of $24.

REQUEST NO. 25: In Attachment B “Details on any affiliated entity relationships,” it
states that Esprit Enterprises, LLC leases “Vehicles and other light truck equipment” to the
Company. Please answer the following:
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 8 MARCH 22, 2024
1. Please provide a list of the vehicles and other light truck equipment leased to the
Company, please include:
a. A description of each leased item.
b. Purpose of the leased item.
c. Cost of the leased item; and
d. Length of the lease.
2. Please explain if each of the vehicles and other light truck equipment leased are
used full time by the Company; and
3. Please explain how the vehicle expenses were allocated to the Company.

REQUEST NO. 26: Please provide the proposed “disconnect/reconnect” fees as
mentioned in the Customer Notice. Please provide any supporting worksheets with formulas
intact.

REQUEST NO. 27: Please clarify what the proposed 1-inch irrigation minimum
monthly charge is. Additionally, please provide the following:
1. Please provide supporting workpapers of how the irrigation charge was
calculated.
2. Please provide the current number of 1-inch residential and irrigation customers.
3. Please explain if 1-inch irrigation customers have separate irrigation meters from
domestic meters. If not, please explain how the Company will meter irrigation
water use; and
4. Please explain why the Company wants to separate irrigation charges from
residential only for 1-inch meters.

REQUEST NO. 28: In Exhibit 5 “Sch C Proof Revenue,” included is a “Service Type”
of “Irrigation/Residential.” Please explain if one meter serves both domestic and irrigation water
use. If not, please explain the meter structure.

REQUEST NO. 29: Please explain why the Company believes that the Customer Group
“MCV Irrigation Backup” will not turn back on after being turned off on “10/22.”

RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION

FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 9 MARCH 22, 2024
REQUEST NO. 30: Please confirm the Company is proposing to charge all Residential
1-inch meter customers at the proposed ¾-inch meter rate as shown in Exhibit No. 7. If this is
not the Company’s proposal, please provide the following information related to ¾-inch and 1-
inch meters.
a. Please provide a list of all the Residential customers the Company has connected
to the system with ¾-inch meters and a separate list of customers with 1-inch
meter sizes;
b. For the customers with 1-inch meters, please identify those who requested 1-inch
meters and those that requested ¾-inch meters but received 1-inch meters due to
3/4 -inch meter unavailability.
c. Please provide any written evidence of meter size requests for all customers with
¾ and 1-inch meter sizes during the period when ¾-inch meters were unavailable.
d. Does the Company plan to replace all 1-inch meters with ¾-inch meters for
customers that requested them? If so, please provide details of the plan including
a schedule for replacement.

DATED at Boise, Idaho, this 22 day of March 2024.

_________________________________
Michael Duval
Deputy Attorney General

I:\Utility\UMISC\PRDREQ\SWS-W-24-01 PR# 1.docx
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION
CERTIFICATE OF SERVICE
CERTIFICATE OF SERVICE

I HEREBY CERTIFY THAT I HAVE THIS 22ND DAY OF MARCH 2024,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CDS STONERIDGE UTILITIES, LLC, IN CASE NO.
SWS-W-24-01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:

Chan Karupiah
Managing Partner
CDS StoneRidge Utilities, LLC
P.O. Box 298
364 Stoneridge Road
Blanchard, ID 83804
[e-mail]
[e-mail]

_________________________________
SECRETARY
RECEIVED
Friday, March 22, 2024 3:04:35 PM
IDAHO PUBLIC
UTILITIES COMMISSION