20240610Opposition to Modified Procedures.pdf

RECEIVED
Monday, June 10, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Randolph Lee Garrison
Pro per
76 Bellflower Ct
Blanchard Idaho 83804
(541 ) 580-4446
garrison(a-)_rmgarrison.corn
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS ) Case No: SWS-W-24-01
STONERIDGE UTILITIES, LLC'S )
APPLICATION FOR AUTHORITY ) INTERVENOR GARRISON'S
TO INCREASE ITS RATES AND ) OPPOSITION TO
CHARGES FOR WATER SERVICE ) MODIFIED PROCEDURES
IN THE STATE OF IDAHO )
Intervenor Garrison files this opposition to "Modified Procedures".
BACKGROUND
On 28 May 2024, a NOTICE OF MODIFIED PROCEDURE was given to the
parties. The notice was given pursuant to Rules of Procedure 201-204, IDAPA
31 .01 .01 .201-.204.
Pursuant to Rule 203, Intervenor Garrison files this opposition (protest) to
Modified Procedure. This opposition is timely, as it is filed within the time allowed by
Rule 202.02.
INTERVENOR GARRISON'S OPPOSITION TO MODIFIED PROCEDURES
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11
PROCEDURAL PREFERENCE
This is a General Water Rate Increase case. The IPUC "Case Processing
Manual" states that General Rate Increase cases will " . . . generally follow the
steps listed above in "Formal Technical Hearing" with additional substantive
processing requirements." A General Rate Increase case is not preferred to be
handled under Modified Procedures.
The IPUC "Case Processing Manual" [at III., C (page 10)] explains:
"A technical hearing process differs from Modified Procedure in several
ways.,,
These "several ways" include:
<< ". . . a prehearing scheduling conference is held and normally
conducted by the assigned DAG (Rules 211-215);
the parties typically engage in extensive discovery (Rules 221-29);
a public workshop may be held (Rule 127) [and has been held];
the parties present evidence in the form of pre-filed testimony and
exhibits of witnesses (Rules 230-31 , 266-67);
a technical hearing is scheduled for the parties; and
a formal public hearing located in the utility's service area is held for
INTERVENOR GARRISON'S OPPOSITION TO MODIFIED PROCEDURES
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customers, public officials and other interested persons not related to the
parties in the case (Rule 241 .04.b).
III
Written Comments Alone Are Insufficient
Pursuant to Rule 203, Intervener Garrison specifically request a hearing.
Written comments alone are insufficient, because:
(1 ) SIZE OF PROPOSED INCREASE_ Applicant's proposed minimum monthly rate
increase is 261 % or 543%, depending on meter size. Applicant's proposed
commodity (water) increase is a 300% increase (.79/1 ,000 Gallons to
$2.94/1 ,000 Gallons).
(2) Size of Increase Demands thorough Evidentiary Review: The size of
applicant's request alone demands a very thorough review of the evidence
supporting and opposing applicant's proposed huge increase. Applicant's huge
proposed increases is nothing less than "rate shock".
(3) AMOUNT OF DEBT: The dept accumulated by Applicant is significant. For
example, Stoneridge Utilities' 2022 Annual report (page 8) shows total debt
(liabilities) of $1 ,099,213. Total debt is more the 2 1/2 times total assets
($401 ,220, page 8). An Annual report for 2023 is yet to be filed by Stoneridge
Utilities.
INTERVENOR GARRISON'S OPPOSITION TO MODIFIED PROCEDURES
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(4) GOLF COURSE: The Applicant has removed the Golf Course (or at least most of
the Golf Course) from Stoneridge Utilities customer base. Intervener estimates
the removal of the Golf Course has resulted in a reduction in water volume to
the Utilitiy of 45%. Owner of the Golf Course is one and the same as the owner
of Stoneridge Utilities. Owner has removed a primary user of the Utility, and
wants the remaining users bare the increased burden.
(5) WELL: Applicant has dug anew well on his golf course property. The expense
of this well needs to be thoroughly examined. A review of whether the well
should be a part of the water utility needs to be explored.
(6) CREDIBILITY: Because of the above, actual testimony of the parites and
witnesses needs to be taken. The credibility of Stoneridge Utilities' owner(Chan
Karupiah) and its principal manager (Teresa Zamora) is an important criteria to
be examined.
IV
CONCLUSION
The Application presented by Stoneridge Utilities and the issues generated
therefrom do not present a typical or routine general rate case. The Commission
should not proceed with "Modified Procedure" and instead, proceed by way of a
Formal Technical Hearing and Public Hearing.
INTERVENOR GARRISON'S OPPOSITION TO MODIFIED PROCEDURES
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DATED and Signed this 8" day of June, 2024.
Randolph Lee Garrison
(541 ) 580-4446
garrison(q-)_rmgarrison.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 8th 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:
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(c com cast.net
P.O. Box 298 utilities(a�_stoneridgeidaho.com
Blanchard, ID 83804
INTERVENOR GARRISON'S OPPOSITION TO MODIFIED PROCEDURES
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Norman M. Semanko, ISB #4761 By e-mail nsemanko(c_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(a_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 8th day of June 2024.
r GVNA 9
Randolph Lee Garrison
INTERVENOR GARRISON'S OPPOSITION TO MODIFIED PROCEDURES
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