20240522Garrison 1-62 TO SWS.pdf

RECEIVED
2024 May 22, 3:48PM
IDAHO PUBLIC
UTILITIES COMMISSION
Randolph Lee Garrison
Pro per
76 Bellflower Ct
Blanchard Idaho 83804
(541 ) 580-4446
garrison(.@_rmgarrison.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS ) Case No: SWS-W-24-01
STONERIDGE UTILITIES, )
LLC'S APPLICATION FOR ) INTERVENER GARRISON'S 3rd
AUTHORITY TO INCREASE ) REQUEST FOR PRODUCTION
ITS RATES AND CHARGES ) FROM CDS STONERIDGE
FOR WATER SERVICE IN THE ) UTILITIES
STATE OF IDAHO )
REQUEST FOR DISCOVERY: Pursuant to the authority cited below,
Intervener, Randolph Lee Garrison, a party, as a third request for production
of documents from CDS Stoneridge Utilities, LLC, hereby requests production
of the following document(s):
CONTINUING Request/Formats Intact/Identity of Person ANSWERING: 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. This Production Request is continuing and StoneRidge Utilities
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 produced. Please provide answers to each question,
supporting work papers that provide detail or are the source of information
used in calculations. Responses must include the name and phone number
of the person preparing the document, and the name, location and phone
number of the record holder and if different the witness who can sponsor the
answer at hearing if need be. See IDAPA 31 .01 .01 .228.
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Delivery: Please also identify a time and place the items can be picked
up from the StoneRidge Utilities' Office, which is described in the Application
as located at 364 StoneRidge Road, Blanchard, Id. If you would prefer, the
documents can be picked up at the StoneRidge Utility office, 105 Chatwold
Rd, Blanchard, ID 83804.
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
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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).
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
eachwell and booster pump from January 2019 to December 2023.
Please provide your responses in spreadsheet (such as, Microsoft Excel)
format with formulas intact.
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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
i ntact.
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.
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)
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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.
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 :
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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.
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.
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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:
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
i ntact.
REQUEST NO. 27:
Please clarify what the proposed 1-inch irrigation minimum monthlycharge 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.
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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."
REQUEST NO. 30:
Please confirm the Company is proposing to charge all Residential 1-inch
meter customers at the proposed 3/4-inch meter rate as shown in Exhibit No.
7. If this is not the Company's proposal, please provide the following
information related to 3/4-inch and 1-inch meters.
a.
Please provide a list of all the Residential customers the Company has
connected to the system with 3/4-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 3/4-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 3/4 and 1-inch meter sizes during the period when 3/4-inch
meters were unavailable.
d. Does the Company plan to replace all 1-inch meters with 3/4-inch
meters for customers that requested them? If so, please provide details
of the plan including a schedule for replacement.
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.
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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.
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
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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:
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.
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REQUEST NO. 51 : In reference to the Golf Course commodity charge
receiving a 10% discount on Sheet 6 of the Marked up Tariff # 5 , submitted
on 20 March, 2024, please respond to the following:
a. Please explain the rationale and/or criteria at 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" 20 March,
2024. Please provide all workpapers in excel format with all formulas intact
and embedded.
REQUEST NO. 53: Please provide a copy of the plat map for the current
service territory. Please note or mark any locations that currently do not have
any service.
REQUEST NO. 54: Please provide a schedule showing the estimated number
of new customers to be connected per year for 2024 — 2029. If there are
plans for additional sections to be developed, please provide a map of the
area and the number of connections planned and size of those connections
for each development.
REQUEST NO. 55: please provide a list of the residential customers with 1
— inch, meters that are being charged at the three-quarter inch meter rate.
Please identify the address, account number, actual meter size, and build
meter size for each customer.
REQUEST NO. 56: Please provide a copy of the the annual reports from
2018 to 2023. 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 and this 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;
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d. Jan-Mar 2024 labor Costs $12,300; and
e. April 1-15, 2024, labor Costs $33,441 .50.
REQUEST NO. 58: IPUC Staff reports they are unable to open the following
spreadsheets provided in responses to Production Requests. Please provide
the Excel and hard copy printouts of the following, capable of being opened:
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."
REQUEST NO. 59: Please provide copies of the Company's 2018, 2019,
2020, 2021 , 2022 and 2023 tax returns.
REQUEST NO. 60: As a supplement to production request number 31 ,
please provide identical reports for all months of 2018, 2019, 2020, 2021 ,
2022 and 2023 in excel format.
REQUEST NO. 61 : Please explain the Company's billing policies and
practices used to reead customer meters. Please answer the following:
a. Please explain if the company charges seasonal rates. If so,
please provide the month and date of the 1 st and last meter
reading of the calendar year.
b. Please explain how a customer's bill that the meter is not read
every month.
C. If multiplemonths pass between meter readings, what is the
monthly meter charge?
d. If multiple months pass between meter readings, how is a
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customer monthly, consumption determined?
REQUEST NO. 62: In reference to Note 4 that states "Existing 1" meters may
be converted to .75 inch meters over time" discussed on sheet 5 of the
Marked-up Tariff submitted on 20 March, 2024, please explain:
(a) The Company's plan for converting existing 1 inch meters, to .75
inch meters for customers who only require and/or need .75 inch
meters;
(b) How the Company will ensure customers who requested and/or
only need a .75 inch rate; and
(c) How the Company will track and document the customer's
request for the size of their service connection, the timing of the
change to the requested meter size, and the corresponding timing
of their change in rates.
DATED and Signed this 22 day of May 2024.
Randolph Lee Garrsion
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 22 day of May, 2024, 1 served a true and correct
copy of the foregoing upon each party in this matter by delivering the same to each of the
following individuals by the method indicated below, addressed as follows:
Michael Duval By e-mail [e-mail]
Deputy Attorney General
IDAHO PUBLIC UTILITIES COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
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CDS STONERIDGE UTILITIES, LLC By e-mail chansan(a)_comcast.net
P.O. Box 298 utilities(aD_stoneridgeidaho.com
Blanchard, ID 83804
Norman M. Semanko, ISB #4761 By e-mail nsemanko(@_parsonsbehle.com
Patrick M. Ngalamulume, ISB #11200 pngalamulume(oparsonsbehle.com
PARSONS BEHLE & LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
Rick Haruthunian By e-mail: rharuthunian(c_rmedlaw.com
CONDOMINIUM OWNERS ASSOC.
INC: Ramsden, Marfice, Ealy & De Smet,
LLP
(Exhibit Nos. 201-300) 700 Northwest
Blvd.
P.O. Box 1336
Coeur d'Alene, ID 83816-1336
DATED this 22 day of May 2024.
Randolph Lee Garrison
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