20240403Staff 31-52 to SWS.pdf

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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 ) CASE NO. SWS-W-24-01
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR WATER SERVICE IN ) SECOND PRODUCTION
THE STATE OF IDAHO ) 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 WEDNESDAY,APRIL 24, 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.
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 APRIL 3, 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. 31: Please provide a schedule showing monthly revenue by customer.
Please break out this revenue by fixed charges, volumetric charges, and any other charges the
company used.
REQUEST NO. 32: Please provide the amount of the Happy Valley Ranchos DEQ
Loan surcharge collected by month from the time the Company bought the system until present.
REQUEST NO. 33: Please provide a list of employees by title who received
compensation in the test year along with their salary,job descriptions, and the allocation of time
to the water system.
REQUEST NO. 34: Please provide all contracts for labor the Company has used from
2022 to present.
REQUEST NO. 35: Please provide all supporting documents for the services provided
to the Company by Terri Hunter CPA from 2022 to present.
REQUEST NO. 36: Please provide the WSM contracts used in the test year.
REQUEST NO. 37: Please provide a description of the services provided by 7B
Engineering.
REQUEST NO. 38: Please provide a list of all contaminants tested for by the Company
and include the cost and frequency of each test.
REQUEST NO. 39: Please provide copies of all lease contracts the Company has
entered into. Please ensure they include the building lease, vehicle and equipment leases, and the
ROW, water Rights, and Easement Leases.
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 APRIL 3, 2024

REQUEST NO. 40: Please provide a copy of the current insurance contract that
includes premiums and coverage along with any invoices from the insurance provider.
REQUEST NO. 41: Please provide a list of all the services the parent company
provides Stoneridge Utilities and any cost allocation methodologies used.
REQUEST NO. 42: Please provide a copy of the Company's bank statements for 2022
and 2023.
REQUEST NO. 43: Please provide the supporting documentation for the JD Resort
Uncategorized expenses of$1,049.02.
REQUEST NO. 44: Please provide all documents for the DEQ Loan.
REQUEST NO. 45: Please provide a list of any IT expenses the Company has incurred
since the Company's last rate case. Please provide a worksheet that provides:
a. Description of each purchase;
b. Purpose of each purchase;
c. Date of purchase; and
d. Cost of the purchase.
REQUEST NO. 46: Please list all available water rights to the Company. Please
provide supporting documentation, including the total maximum water production in acre feet
("AF") for each water right.
REQUEST NO. 47: In Attachment B "Details on any affiliated entity relationships," it
states that Esprit Enterprises, LLC leases "Water Rights and use of ROW held over other private
property"to the Company. Please answer the following:
a. Please define "use of ROW held over other private property." Additionally, please
describe how this term applies to the Company;
b. Please provide a list of the water rights that are leased to the Company, please
include:
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 APRIL 3, 2024

i. A description of each leased item;
ii. Cost of the leased item; and
iii. Length of the lease;
c. Please explain if each of the water rights leased are only used by the Company. If
not,please explain how many AF of each leased water right are used by the
Company; and
d. Please explain how the water right expenses were allocated to the Company.
REQUEST NO. 48: Please explain if the Company has conducted a load forecast for
the next 5 years. If so, please provide supporting worksheets. If not,please explain why.
REQUEST NO. 49: In addition to Production Request No. 25,please provide milage
logs for the vehicles used by the Company for 2023.
REQUEST NO. 50: In reference to the "Tiered" commodity charge for Residential
Meters discussed on Sheet 5 of the Marked-up Tariff#5 submitted on March 20, 2024,please
respond to the following:
a. Please explain the rationale and/or criteria the Company used to determine the water
volume levels (0-9,999 gallons, 10,000 to 19,999 gallons, and 20,000+gallons) for
each of the proposed Tiers. Please provide any associated workpapers in excel format
with all formulas intact and enabled;
b. Please explain the rationale and/or criteria the Company used to determine the
proposed charge for the"second tier" and the"third tier" ($3.75 and $5.25,
respectively). Please provide any associated workpapers in excel format with all
formulas intact and enabled; and
c. Please explain the rationale and/or criteria the Company used to determine the Tiered
rates that would only apply to Residential meters and not other service types. Please
provide any associated workpapers in excel format with all formulas intact and
enabled.
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 4 APRIL 3, 2024

REQUEST NO. 51: In reference to the Golf Course commodity charge receiving a 10%
discount discussed on Sheet 6 of the Marked-up Tariff#5 submitted on March 20, 2024,please
respond to the following:
a. Please explain the rationale and/or criteria the Company used to determine that the
Golf Course commodity charge should be reduced by 10%. Please provide any
associated workpapers in excel format with all formulas intact and enabled; and
b. Please identify the specific customer(s) and account number(s) who will receive the
10% discount.
REQUEST NO. 52: Please provide proof of revenue requirement workpapers that
include"Tiered"rates and all other proposed rates not included in the Application but are
proposed in Marked-up Tariff#5 submitted on March 20, 2024. Please provide all workpapers
in excel format with all formulas intact and enabled.
DATED at Boise, Idaho, this 3rd day of April 2024.
Michael Duval
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\SWS-W-24-01 PR#2.docx
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 5 APRIL 3, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS j/AY OF APRIL 2024,
SERVED THE FOREGOING SECOND 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
chansan ,comcast.net
utilities(&,stoneridgeidaho.com
r GL�G>G� 8'Ic�,U
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE