20240709Staff 68-79 to SWS.pdf

RECEIVED
Tuesday, July 9, 2024 4:10:17 PM
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 ) SEVENTH 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 TUESDAY,JULY 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.
SEVENTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 JULY 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. 68: Please provide all supporting documentation, including monthly
invoices, from Esprit Enterprises for contract employees, the weekly"worked reports" from
Stoneridge Utilities (SRU), and any other reports and spreadsheets that support the 2023 amounts
for the following accounts:
a. 601.2 Op/Maint. Laborer $8,803.92;
b. 601.1 Mgr.-Operation & Maintenance $71,531.52;
c. 601.7 Labor-customer Accounts Admin$35,765.76;
d. 601.8 Labor Administrative & General $67,863.24; and
e. 603 Salaries, Owners Contract $39,303.00.
REQUEST NO. 69: Please provide copies of invoices that support the following
expenses in account 620.1 Maintenance & supplies-Op & Maint. -other:
a. 1/1/23 JD Resort $6,151.07;
b. 1/17/23 Swank Excavating $1,103.78;
c. 3/13/23 Swank Excavating $8,600.00;
d. 7/11/23 H.D. Fowler Co $1,088.98;
e. 8/24/23 AMPED Pump $1,160.00; and
f. 8/31/23 Swank Excavating $2,700.00.
REQUEST NO. 70: Please provide a copy of the November 13, 2023 H.D Fowler
invoice for$838.75 and provide an explanation of the repair and rationale for splitting the bill
50150 between water and sewer.
REQUEST NO. 71: Please provide the number of connections for sewer customers.
SEVENTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 JULY 9, 2024

REQUEST NO. 72: Please provide the number of bills mailed for the water company
each month for 2023.
REQUEST NO. 73: Please provide the number of bills mailed for the sewer company
each month for 2023.
REQUEST NO. 74: Please provide copies of all invoices from Integrity Water
Management received to date. Please also include the contract with Integrity Water
Management.
REQUEST NO. 75: Please provide the number of fire hydrants on the Company's water
system.
REQUEST NO. 76: Please provide the cost for hydrant locks. Please provide the
invoice for the hydrant locks when received.
REQUEST NO. 77: Please provide a list of all the electric meters that Inland Power
bills the Company and what equipment or buildings those meters are used for. Please also
provide a copy of all Inland Power bills for 2023 and 2024 to date.
REQUEST NO. 78: Please provide copies of the Company's policies for collections,
late payments, and turn-offs.
REQUEST NO. 79: According to page 2 of the 2019 IDEQ Sanitary Survey that was
provided in response to Production Request No. 16: "Water feeds into the pump house from both
wells, where it then supplies two lines for the distribution system, and a separate line for the golf
course. A fourth line is abandoned." Based on this information,please provide the following:
SEVENTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 JULY 9, 2024

a. Please explain how the two distribution lines are connected to the rest of the
system;
b. Please confirm the chlorination status of the separate line for the golf course; and
c. Please confirm whether the fourth line was abandoned. If yes,please explain why
and when it was abandoned. Also explain the impact of this abandonment to the
system.
DATED at Boise, Idaho, this 9th day of July 2024.
F11'Michael Duval
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\SWS-W-24-01 PR#7.docx
SEVENTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 4 JULY 9, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS &DAY OF JULY 2024,
SERVED THE FOREGOING SEVENTH 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 JASON T PISKEL
MANAGING PARTNER PISKEL YAHNE KOVARIK PLLC
CDS STONERIDGE UTILITIES, LLC 612 W MAIN AVE, STE 207
P.O. BOX 298 SPOKANE WA 99201
364 STONERIDGE ROAD E-MAIL: jpiskelgpyklawyers.com
BLANCHARD, ID 83804
E-MAIL: chansangcomcast.net
utilities(c�stoneridgeidaho.com
RANDOLPH LEE GARRISON,PRO SE NORMAN M SEMANKO
76 BELLFLOWER CT. PATRICK M NGALAMULUME
BLANCHARD, ID 83804 PARSONS BEHLE & LATIMER
E-MAIL: garrisongrmgarrison.com 800 W MAIN ST STE 1300
BOISE ID 83702
E-MAIL: nsemankogparsonsbehle.com
pngalamulume(kparsonsbehle.com
RICK HARUTHUNIAN
RAMSDEN, MARFICE, EALY& DE SMET,
LLP
700 NORTHWEST BLVD.
P.O. BOX 1336
COEUR D'ALENE, ID 83816-1336
E-MAIL: rharuthuniangnnedlaw.com
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PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE