20240509Staff 56-61 to SWS.pdf

RECEIVED
2024 May 9, 4:23PM
IDAHO PUBLIC
UTILITIES COMMISSION
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 )
THE STATE OF IDAHO ) FOURTH 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 THURSDAY,MAY 30, 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.
FOURTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 MAY 9, 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. 56: Please provide a copy of the 2023 annual report. If not available,
please provide a date when it will be filed with the Commission.
REQUEST NO. 57: Please provide all documents, including invoices, receipts, time
sheets/weekly worked reports, etc., that support the Company's response to Staff s Production
Request No. 1, Rate Case Labor Cost Details to date schedule.
a. 2020-2023 Mailing Costs of$1,250;
b. 2020-2023 Publication Costs $225;
c. 2020-2023 Labor Costs $50,200;
d. Jan-Mar 2024 labor Costs $12,300; and
e. April 1-15, 2024, labor Costs $33,441.50.
REQUEST NO. 58: Staff is unable to open the following spreadsheets provided in
responses to Production Requests. Please provide the Excel and hardcopy printouts of the
following:
a. Response to Production Request No. 2 "2020_2023 Annual Depreciation Worksheet
SRU Water Known Schedule;"
b. Response to Production Request No. 5 "2023 Annual Depreciation Known changes"
and"2020_2024 Annual depreciation Known Changes;"
c. Response to Production Request No. 11 "Inland Power Master Meter List;"
d. Response to Production Request No. 12 "well pump record 2019,"well pump record
2020 2023" and"well volumes 20-24;"
e. Response to Production Request No. 15 "chlorine report 2019_2024;"
f. Response to Production Request No. 19 "Backup Power System;"
g. Response to Production Request No. 20 "Wireless meter changeout Cap Ex;"
h. Response to Production Request No. 30 "IPUC Excel General Rate Case 2_29_24
final;" and
i. Response to Production Request No. 32 "2020_2023 annual Depreciation Worksheet
SRU Water Known Schedule."
FOURTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 MAY 9, 2024

REQUEST NO. 59: Please provide copies of the Company's 2022 and 2023 tax
returns.
REQUEST NO. 60: As a supplement to Production Request No. 31, please provide
identical reports for all months of 2022 and 2023 in Excel format.
REQUEST NO. 61: Please explain the Company's billing policies and practices used
to read customer meters. Pease answer the following:
a. Please explain if the Company charges seasonal rates. If so, please provide the month
and dates of the first and last meter reading of a calendar year.
b. Please explain how a customer is billed if the meter is not read every month.
c. If multiple months pass between meter readings, what is the monthly customer
charge?
d. If multiple months pass between meter readings, how is a customer's monthly
consumption determined?
DATED at Boise, Idaho, this 9 h day of May 2024.
i
Michael Duval
Deputy Attorney General
[:\Utility\UMISC\PRDREQ\SWS-W-24-01 PR#4.docx
FOURTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 MAY 9, 2024

CERTIFICATE OF SERVICE
I HAVE THIS `��DAY OF MAY 2024
I HEREBY CERTIFY THAT ,
SERVED THE FOREGOING FOURTH 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 RICK HARUTHUNIAN
MANAGING PARTNER RAMSDEN, MARFICE, EALY& DE SMET,
CDS STONERIDGE UTILITIES, LLC LLP
P.O. BOX 298 700 NORTHWEST BLVD.
364 STONERIDGE ROAD P.O. BOX 1336
BLANCHARD, ID 83804 COEUR D'ALENE, ID 83816-1336
E-MAIL: chansan ,comcast.net E-MAIL: rharuthunianAnnedlaw.com
utilities(istoneridgeidaho.com
RANDOLPH LEE GARRISON,PRO SE
76 BELLFLOWER CT.
BLANCHARD, ID 83804
E-MAIL: izarrison(@,nngarrison.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE