20240604Garrison 63-67 to SWS.pdf

RECEIVED
2024 June 4, 10:41AM
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 4th
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 4th 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
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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.
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. 63: In the meeting between the Company and Staff that
occurred on May 9, 2024, the Company discussed revisions to Marked-up
Tariff #5 submitted on March 20, 2024, and indicated in that meeting that it
will no longer pursue tiered rates in this case. The Company and Staff also
discussed several other miscellaneous items that need to be revised in
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the tariff. Please provide an update to Tariff #5 without the tiered rates and
with updates for the miscellaneous items after working with Staff. Please
include a summary of all the changes to the updated tariff.
REQUEST NO. 64: Please confirm that the Company is still proposing to
charge the Golf Course Irrigation customer the proposed minimum monthly
charge for their meter size (i.e. 6-inch meter with a $5,546 minimum monthly
charge and a 10% discounted $2.65/1000 gallon commodity charge) in
addition to the 10% discounted commodity charge. If this is not the case,
please clarify the Company's proposal and provide an updated tariff.
REQUEST NO. 65: In response to Production Request #13, the Company
stated that 2023 total consumption is 110,936,200 gallons. The total
consumption for the system minus 46,548,200 gallons from the Golf Course
6-inch meter would be 64,388,000 gallons. In the Company's Application,
Exhibit 5, Schedule A, the Company stated that 2023 total annual
consumption is 57,415,001 gallons—which excludes the Golf Course 6-inch
meter. Please reconcile these two numbers in Excel format with all formulas
intact. Additionally, please reconcile any other differences between the data
provided in response to Production Request #13 and the Application Exhibit
5, Schedule A.
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REQUEST NO. 66: In an email response to Staff on May 8, 2024, the
Company stated that the Golf Course 6-inch irrigation meter was
disconnected in Fall 2023. Please provide the date of disconnection.
Additionally, the Company stated that a new well for Golf Course irrigation
was put online in fall 2023. Please provide the date that the well began
serving the Golf Course's water demands.
REQUEST NO. 67: Please provide the estimated amount of water that the
Company is expected to provide to the Golf Course, 6 inch meter in 2024 and
2025. Please provide the estimated amount of water that the company is
expected to provide to the other golf course meters in 2024 and 2025.
DATED and Signed this 4th day of June 2024.
Randolph Lee Garrsion
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 4th day of June, 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:
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Michael Duval By e-mail [e-mail]
Deputy Attorney General
IDAHO PUBLIC UTILITIES COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
CDS STONERIDGE UTILITIES, LLC By e-mail chansan(@_comcast.net
P.O. Box 298 utilities(a�_stoneridgeidaho.com
Blanchard, ID 83804
Norman M. Semanko, ISB #4761 By e-mail nsemanko(D_parsonsbehle.com
Patrick M. Ngalamulume, ISB #11200 pngalamulume(a�_parsonsbehle.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 4th day of June 2024.
Randolph Lee Garrison
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