20240822Staff 84-101 to SWS.pdf

RECEIVED
Thursday, August 22, 2024 12:32:12 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 ) NINTH 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 THURSDAY, SEPTEMBER 12, 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.
NINTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 AUGUST 22, 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. 84: Referencing the comment from Mr. Collier on the case posted on
July 31, 2024,please provide the following:
a. All invoices from Woodhawk Controls, LLC from 2022 to present;
b. All cancelled checks Woodhawk Controls, LLC, from 2022 to present; and
c. A list of services provided by Woodhawk Controls, LLC.
REQUEST NO. 85: If any of the Woodhawk Controls, LLC invoices have not been
paid, or were paid late,please provide an explanation.
REQUEST NO. 86: In response to Production Request No. 31, the Company provided
Excel spreadsheets of billing register data for all months from January 2023 through June 2024.
Account 05-00540-00, Fairway Meadows, appears to be charged a monthly minimum amount of
$82.44 every month. Please provide the connection size for this account and why the account
has a monthly minimum charge of$82.44.
REQUEST NO. 87: In response to Production Request No. 66 regarding the Golf
Course's own well, the Company stated that"the minimum monthly billing recommenced in
April of 2024 when it became apparent that the Golf Course's new well pump had issues."
Further, the Company stated that"During this time that the new Golf Well was offline April-
June 2024 the Golf Course needed water to fill the storage reservoir and supply irrigation water."
April 2024 and May 2024 monthly billing register data provided by the Company do not show
any information for account 08-02980-00, Golf Irrigation Pond 6." According to June 2024
billing register data, water use for this account was 6,053,200 gallons. Please answer the
following:
a. Please explain why the Golf Irrigation Pond 6" customer did not appear on the April
2024 and May 2024 monthly billing registers?
b. Did the Company provide any water to the Golf Irrigation Pond 6" in April 2024 and
May 2024? If so, how much water did the company provide to this customer?
NINTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 AUGUST 22, 2024

REQUEST NO. 88: Has the Company discussed with the Golf Course the capacity
details of the Golf Course's well? If so, please provide the following:
a. The Idaho Department of Water Resources well ID number;
b. The make, model, type, and rating of each pump used in the well;
c. The pump curve of the pump(s)used in the well;
d. The depth (amount of head) of the well;
e. The measured well yield, with explanation of how the well yield was determined; and
f. Please provide the minimum and maximum amount of water the Company needs to
supply to the Golf Course on a daily basis.
REQUEST NO. 89: Please explain the Company's procedure and requirements for
determining when to interrupt service to the Golf Irrigation Pond 6" meter. What are the
requirements for returning service to the customer? What is the protocol for notifying the
customer of the interruption?
REQUEST NO. 90: Does the Company provide customers with a notice regarding
backflow assembly testing? If so, please provide examples of the notice or a reason it is not a
business practice to provide information.
REQUEST NO. 91: Does the Company keep annual backflow testing records? If so,
please provide the records for the last three years. If not,please explain what is the Company's
plan to ensure backflow compliance?
REQUEST NO. 92: Please explain what is the Company's current meter reading
schedule (e.g., 15th day of the month, third Saturday, etc.)? IDAPA 31.21.01, Utility Customer
Relations Rules ("UCRR") 202.01.
REQUEST NO. 93: Please explain what is the Company's current billing schedule
(e.g., bills sent three days after meters are read)?Id.
REQUEST NO. 94: Please describe the Company's billing practice. Id.
NINTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 AUGUST 22, 2024

a. When is a payment due?
b. When is a payment past due?
c. Please explain the Company's procedures for collecting past due bills.
REQUEST NO. 95: Please provide copies of the following Company documents
(UCRR 305.01 and 311.05):
a. Initial Notice to Terminate;
b. Final Notice of Intent to Terminate Service; and
c. Notice of Procedure for Reconnecting Service left at the premises following
disconnection of service (e.g., door tag or notice).
Production Request Nos. 96 and 97 pertain to UCRR Rules 201 and 202.
REQUEST NO. 96: Please provide samples of current monthly billing statements sent
to customers who have:
a. No past due balance; and
b. A past due balance.
REQUEST NO. 97: Does the Company intend to revise its billing statement? If so,
please provide samples of proposed monthly statements for customers who have:
a. No past due balance; and
c. A past due balance.
REQUEST NO. 98: Please explain if bills will be estimated for months in which the
Company is unable to read meters. If estimated, please explain how these estimated charges will
be reconciled and displayed in subsequent bills based on actual usage. Please provide formulas
and sample calculations. If not, please provide an example of the first spring statement after the
meters are read. UCRR 203.
REQUEST NO. 99: Does the Company offer customers a pre-printed form for the
medical emergency certificate? If so, please provide a copy of the form. UCRR 308.
NINTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 4 AUGUST 22, 2024

REQUEST NO. 100: Please provide a copy of the Summary of Rules provided to
customers. Please explanation how and when it is sent. UCRR 700.0l.a.
REQUEST NO. 101: Please provide a copy of the Explanation of Rate Schedules
provided to customers. Please explain how and when it is sent. UCRR 700.0l.c.
DATED at Boise, Idaho, this 22"d day of August 2024.
i
Michael Duval
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\SWS-W-24-01 PR#9.docx
NINTH PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 5 AUGUST 22, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS �O OF AUGUST 2024,
SERVED THE FOREGOING NINTH PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CDS STONERIDGE UTILITIES, LLC, IN CASE NO.
SWS-W-24-01, BY &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: jpiskel@)pyklawyers.com
BLANCHARD, ID 83804
E-MAIL: chansan&comcast.net
[e-mail]
jeff&merkeley.com
RANDOLPH LEE GARRISON,PRO SE NORMAN M SEMANKO
76 BELLFLOWER CT. PATRICK M NGALAMULUME
BLANCHARD, ID 83804 PARSONS BEHLE & LATIMER
E-MAIL: [e-mail] 800 W MAIN ST STE 1300
BOISE ID 83702
E-MAIL: nsemanko(a,parsonsbehle.com
[e-mail]
RICK HARUTHUNIAN
RAMSDEN, MARFICE, EALY & DE SMET,
LLP
700 NORTHWEST BLVD.
P.O. BOX 1336
COEUR D'ALENE, ID 83816-1336
E-MAIL: rharuthuniankrmedlaw.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE