20240531SPOA 1-62 to SWS.pdf

RECEIVED
2024 May 31, 2:45PM
IDAHO PUBLIC
Norman M. Semanko, ISB #4761 UTILITIES COMMISSION
Patrick M. Ngalamulume, ISB #11200
PARSONS BEHLE&LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Stoneridge Property Owners Association
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 STONERIDGE PROPERTY OWNERS
AND CHARGES FOR WATER SERVICE IN ASSOCIATION FIRST REQUESTS FOR
THE STATE OF IDAHO PRODUCTION TO STONERIDGE
UTILITIES, LLC
COMES NOW, Stoneridge Property Owners Association, Inc. (hereinafter "SPOA" or
"Petitioner"), by and through its counsel of record, Parsons Behle & Latimer, requests that you
provide the following documents and information as soon as possible, but no later than June 21,
2024.
PRELIMINARY STATEMENT
When answering these discovery requests, you are requested to furnish all information
available to you, including information in the possession of your attorneys, investigators, experts,
employees, officers, directors, agents, representatives, guardians, or any other person or persons
acting on your behalf, not merely such information as is known by you on personal knowledge.
If you cannot answer any of the following discovery requests in full, after exercising due
diligence to secure the information to do so, so state, and answer to the extent possible,
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specifying your inability to answer the remainder, and stating whatever information and
knowledge you have concerning the unanswered portion.
These discovery requests are deemed continuing, and the answers thereto must be
supplemented to the maximum extent authorized by law and the applicable rules. If, after
responding to these discovery requests, you acquire any information responsive thereto, you are
requested to file and serve supplemental responses containing such information.
Defendants require you to respond to the following Requests for Production of
Documents by serving upon said Defendants a written response to each document request, and
by permitting said Defendants or Defendants' representatives to inspect and copy each of the
documents on or before the date such responses are due at the law offices of Parsons Behle &
Latimer, 800 West Main Street, Suite 1300, Boise, Idaho 83702.
If you contend that any information requested is privileged, in whole or in part, or
otherwise object to any part of the discovery request, or believe that any requested information
would be excludable from discovery, regardless of its relevance, you shall identify with
particularity each piece of information for which you claim a privilege, state the reasons for such
objection or grounds for exclusion, identify each person or entity having knowledge of the
factual basis, if any, on which the privilege or ground is asserted, and identify each discovery
request in any way related to either the privileged information or the factual basis for the claim
or privilege.
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.
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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).
b. The make, model, type, length of time in service, and rating of each well pump
motor.
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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)
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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
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.
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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:
I. 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.
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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 REP 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)
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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.
11. 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)
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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, EEC leases "Vehicles and other light truck equipment" to the
Company. Please answer the following:
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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:
I. 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.
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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 f-
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 I- 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 I-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.
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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.
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.
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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, EEC 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;
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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.
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:
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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.
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 % inch meter rate. Please identify the address, account number,
actual meter size, and billed meter size for each customer.
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.
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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."
REQUEST NO. 59: Please provide copies of the Company's 2022 and 2023 tax returns.
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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?
REQUEST NO. 62: In reference to Note 4 that states "Existing 1" meters may be
converted to .75" meters over time" discussed on Sheet 5 of the Marked-up Tariff#5 submitted
on March 20, 2024,please explain:
(a) The Company's plan for converting existing 1-inch meters to 0.75-inch meters for
customers who only requested and/or need 0.75-inch meters;
(b) How the Company will ensure customers who requested and/or only need a 0.75-
inch meter but had a 1.0-inch meter installed are only charged the 0.75-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.
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DATED this 3 1"day of May, 2024.
PARSONS BEHLE&LATIMER
Norman M. Semanko; Patrick M. Ngalamulume
Attorneys for Stoneridge Property Owners
Association
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 31 st 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, Deputy Attorney General ❑ U.S. Mail
IDAHO PUBLIC UTILITIES COMMISSION ❑ Facsimile
472 W. Washington(83702) ❑ Hand Delivery
P.O. Box 83720 ❑ Overnight Delivery
Boise, ID 83720-0074 ❑ Email michael.duval(dpuc.idaho.gov
Chan Karupiah ❑ U.S. Mail
CDS STONERIDGE UTILITIES,LLC ❑ Facsimile
P. O. Box 298 ❑ Hand Delivery
Blanchard, ID 83804 ❑ Overnight Delivery
® Email chansan(ccomcast.net
utilitieskstoneridgeidaho.com
Rick Haruthunian ❑ U.S. Mail
RAMSDEN,MARFICE,EALY&DE SMET LLP ❑ Facsimile
700 Northwest Boulevard ❑ Hand Delivery
P. O. Box 1336 ❑ Overnight Delivery
Coeur d'Alene, ID 83816-1336 ® Email rharuthunian(a,rmedlaw.com
Attorney for Stoneridge Recreational Club
Condominium Owners Assoc., Inc.
STONERIDGE PROPERTY OWNERS ASSOCIATION FIRST REQUESTS FOR PRODUCTION TO
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Randolph Lee Garrison ❑ U.S. Mail
76 Bellflower Court ❑ Facsimile
Blanchard, ID 83804 ❑ Hand Delivery
❑ Overnight Delivery
® Email garrisonAxingarrison.com
- �' S--
Norman M. Semanko
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