20240906SWS to Garrison 65_69-96.pdf

September 6, 2024
Randolph Lee Garrison
76 Bellflower Court
Blanchard, ID 83804
~✓
STONE RIDGE ---~----
StoneRidge Water Company
P.O. Box 298
Blanchard, ID 83804
Ph [phone] Extn. 4
RE: SWS-W-24-01 General Rate Case Intervenor Garrison, 5th Request for Discovery Response
Mr. Garrison, please find attached, our written response to you 5th Request for Discovery.
This r spon e is also being uploaded to the shared cloud accounts by Jason Macek, JD our counsel on this
matte .
w if you have additional requests.
RECEIVED
Friday, September 06, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Case# SWS-W-24-O1-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
Request NO. 69: Bob Kuchenski, Integrity Water Management, send out a
notice/letter dated 24, July 2024. The notice stated that well number 3 was
not operational and that well number 1 was providing 100% of the water
demand.
Answer: Narrative overview of Water System
StoneRidge Water Company's domestic water system consists of two
groundwater wells. #1 and #3 both are located along the 18th Fairway of the
StoneRidge Golf Course (Well #2 failed prior to installation of Well #3-Well
#2 was abandoned in approximately 2006). Both active wells provide
ground water to the StoneRidge Water Company distribution system that
provides chlorinated drinking water to StoneRidge Golf Residential
Community, and Happy Valley Rancho residential community.
In addition, this same water distribution system has historically supplied the
StoneRidge Golf Course. The Golf Course's primary use of this water has
been by the StoneRidge Golf Course Irrigation System through a 6" meter
located within the StoneRidge Golf Course Irrigation Pump Building. The 6"
meter reduces to a 1 ¼ steel pipe that fills the irrigation pond located next
to the Motor Coach Village.
(a) Is any part of the golf course served by well number 1?
Yes, per the narrative above, both Well #1 and Well #3 have
historically provided all water to the The Company water
distribution system. The three follow-ups are unanswerable per
the above narrative.
(i) If so, what area of the golf course is served by well number
1?
(ii) If so, what is the yearly month by month for (2023) number
of gallons used by the golf course from well number 1?
(iii) If so, .what is the year to date by month for 2024 number of
gallons used by the golf course from well number 1?
(b) Is any part of the golf course served by well number 3?
COMPANYS RESPONSE Page 1 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-O1-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
(i) If so, what area of the golf course is served by well number
3?
(ii) If so, what is the yearly (for 2023) number of gallons used
by the golf course from well number 3?
(iii) If so, what is the year to date by month for 2024 number of
gallons used by the golf course from well number 3?
Answer: See answer to (a) above. The three follow-ups are
unanswerable per the above narrative. Company prior responses to
Staff PRR's #1-#8, include 2023 and 2024 monthly volumes of water
provided to Golf Course irrigation pond from the Company Wei l's # 1 &
#3 in total only.
(c) What wells/sources (other than wells #1 and 3) provide water to
non-golf course areas, for example Stoneridge generally and
Happy Valley?
(ii) If so, what is the annual number of gallons for 2023
(iii) If so, what is the annual number of gallons by month to date
2024?
Answer: There are no other wells The Company is aware of that
are providing water to "non-golf course areas". There are no answers
to the two follow-up questions.
(d) Is any part of the golf course served by other water
wells/sources (other than the well on fairway 16 and wells 1 &
3)?
(i) If so, what areas of the golf course are served?
(ii) If so, what is the annual number of gallons by month for
2023
(iii) If so, what is the annual number of gallons by month to date
for 2024?
Answer: There are no other wells The Company is aware of that are
providing water to the golf course Irrigation system other than well #1
COMPANYS RESPONSE Page 2 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-O1-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
and well #3 from StoneRidge Water Company and StoneRidge Golf
Clubs Irrigation well #1 on Fairway 16. There are no answers to the
Three follow-up questions.
( e) The notice stated: "we are requesting an expedited
review/approval from !PUC for this pump replacement request,
please contact !PUC staff and encourage Staff's expediting this
approval."
Answer: The Company has been in weekly contact with !PUC Staff on
this case since December 2023. Capital Expenditures are a significant
portion of this case and in recent weeks !PUC Staff has indicated a PRR
was forthcoming in regard to our "updated/supplemental" filing for
Capital Expenditures for this case
(i) Why did think any approval from !PUC is needed for a pump
replacement?
Answer: Staff has consistently reminded us that we may be
"reimbursed" for approved expenditures, but if we make the
expenditure without prior !PUC review we are not guaranteed that we
will be able to completely recover the expenditure either directly
and/or in an increase in general tariff rates (Outline of !PUC Capital
Expenditure Review & Approval Process below)
The /PUC Decision Process for Capital Expenditures Review &
Approval:
1. Proposal by Utility: The utility submits a proposal to the /PUC,
detailing its decision to capitalize or lease an asset. This proposal
includes financial analyses, expected benefits, cost implications,
and the impact on customer rates.
2. /PUC Review: The /PUC, along with its staff and sometimes
external consultants, reviews the proposal. They assess whether the
decision aligns with the principles of cost-effectiveness, risk
management, and consumer protection.
COMPANYS RESPONSE Page 3 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
3. Public Input: There may be public hearings or opportunities for
stakeholders, including consumer advocates, to provide input on the
proposed capitalization or leasing decision.
4. Commission Decision: The !PUC issues a decision, either
approving the utility's approach or requiring modifications. The
decision is based on whether the capitalization or lease arrangement is
Just, reasonable, and in the public interest.
5. Ongoing Oversight: The IPUC continues to monitor the financial
impacts of the decision to ensure that it remains in the best interest of
consumers over time.
The IPUC's goal in this process is to ensure that utilities make prudent
financial decisions that balance the need for reliable utility services
with the need to keep costs reasonable for consumers.
(ii) For what reason did you encourage "contact with IPUC staff
To encourage Staff's expediting this approval"?
Answer: We have invested significant capital into the Company
since purchasing it in 2018 and we continue to lose money each year
we operate The Company. We continue to evaluate alternative
funding sources for The Company to cover annual operating losses as
well as new capital investment requirements.
(iii) Do you agree IPUC approval was not necessary to replace
pump #3?
Answer: The use of "guidance" vs "approval" in Kuczenski's letter to
customers, in retrospect, would have been more appropriate.
(iv) What experience does Bob Kuchenski have working with the
IPUC?
Answer: Mr. Kuchenski has 24+ years in the water operator field
and managing multiple water systems. The majority of Bob's clients
are "non-regulated "water systems.
COMPANYS RESPONSE Page 4 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 70: Regarding well/pump# 2:
(a) When was this well last in service?
Answer: Well #2 failed in 2005/2006 time period.
(b) Why was it not repaired or replace?
Answer: We have no clue to the decision made 18 years ago by the prior
owners of The Company.
COMPANYS RESPONSE Page 5 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-O1-stoneRidge Water Company General Rate Case
5 th Request for Discovery--lntervenor Garrison
REQUEST NO. 65: In case number SWS-W-23-23, Commission staff noted:
The Company has already recorded a note payable to Esprit of $787,782 and
advances from associated companies of $196,422, totaling $984,204.
(a) Did any of this money pay for any repairs, improvements, or pumps
involving well number 1 or well number 3?
Answer: No .
(i) If so, exactly what amount of money was spent on repair,
improvements or pumps for well number 1 or well number 3?
Answer: N/A
(ii) If so, exactly what repair, improvement, or pumps was
done/to well number 1 or well number 3?
Answer: N/A
(iii) If not, why did you not allocate some of this money to a "30-
year-old pump"?
Answer: Other more immediate needs.
(b) Was this sum ($984,204) actually transferred into the accounts of
the water utility, CDS Stoneridge Utilities, LLC?
Answer: The water company was extended credit by related
companies.
(i) If so, please provide the deposit receipts.
Answer: See above--parent companies, extended credit to The
Company.
(ii) If not, please provide the company/entity/place the money was
deposited in the deposit receipts.
Answer: No funds were deposited into The Company.
COMPANYSRESPONSE Page 6 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-01-StoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 71: Are you aware of a water pressure problem in any area
you serve.
Answer: Yes.
(a) If so, what areas have a water pressure problem?
Answer: During power extended power outages some areas in
Happy Valley Rancho Community experience lower pressure.
(b) If so, what steps are being taken to remediate the water pressure
problem?
Answer: Happy Valley Rancho Community was annexed into The
Company in 2006. This community was developed (by the original
developer) with minimal water storage capacity and therefore in
extended power outages periods of lower pressure can be experienced
by homeowners. The resolution to this problem will likely require the
development of additional water reservoir storage capacity at an
elevation level capable of providing a higher-pressure water pressure
rate to the Happy Valley Rancho Community.
In addition to low pressure during outages, Fire-Flow is a very big
concern for this rural community within the wildfire and Wildland
Urban Interface zone. The Happy Valley Rancho Community was
"annexed" into the existing StoneRidge Golf Community in 2006.
Happy Valley was developed many years before StoneRidge and the
requirements for "FireFlow" were much less stringent. Current
estimates to provide sufficient "Fireflow" capacity to the entire Service
Area The Company serves exceed $2,000,000.00 to establish new
water tank reservoir capacity in excess of 1,000,000 gallons of
storage .
When the capital investment in FireFlow Capacity is made, it is our
expectation that all the StoneRidge Water Company customers will
share in the cost of that Capital Investment, not just the Happy Valley
Rancho customers.
COMPANYS RESPONSE Page 7 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 72: Regarding the new well for the Golf Course put on line at
or near October 2023:
(a) Is the new well located at, near and on the 16th Fairway?
Answer: Yes
(b) Discovery disclosed on 1 August 2024 contained a file "Gofl (sic)
Irrigation Meer (sic) Daily Readings 2024 -2025". Only one reading
was recorded and that was for July 9, 2024. These was no indication
when the last reading was taken.
Answer: The Golf Irrigation Meter has been read
(i) What is the number of gallons pumped by the new golf course
well on a monthly basis from and including October 2023 to
present?
Answer: The new Golf Course Irrigation Well #1 does not
currently have a flow meter installed on its system
(ii) What is the number of gallons pumped by the new golf course
well on a monthly basis 2024 to present?
Answer: N/A.
(iii) Please include a date for each entry from which the meter
reading is taken.
Answer: N/A
( c) Please identify the source of all funds, by date and amount, for the
construction and installation of the new well.
Answer: The new Golf Course Irrigation Well #1 was paid for by Esprit
Enterprises, LLC the owner of the Golf Course
( d) Please provide all cancelled checks for the funds used for the
construction and installation of the new well.
Answer: N/A
COMPANYS RESPONSE Page 8 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
(e) Please provide invoices (on a monthly basis) for all electricity paid by
for the pump and well from its inception to present.
Answer: Currently the new Golf Irrigation Well #1 is using power
provided by an Inland Power electrical service meter account billed to
StoneRidge Sewer Company that is located near the storage shack in
the Sewer Plant yard.
COMPANYS RESPONSE Page 9 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-O1-stoneRidge Water Company General Rate Case
5th Request for Discovery--! ntervenor Garrison
REQUEST NO. 73: Did the Golf Course reduce its water usage consistent
with Bob Kuchenski, Integrity Water Management, notice/letter dated 24
July 2024?
Answer: Yes, along with most other customers, the Golf Course Irrigation
system reduced the amount of water it was provided by the 6" Irrigation
Meter during the period we running on Well # 1.
(i) If so, what amount of gallons were reduced?
Answer: The flow rate was reduced from its maximum of 300
GPM down to and including O GPM by staff depending upon the
time of day and the load on the system. It is not possible to
calculate the amount reduced, as there was not projected
amount to compare a reduction to. The Golf Course was able to
draw down its large irrigation pond reservoir during the two
weeks we were running on one Well Pump.
(ii) What amount of water was reduced from pump # 1?
Answer: It is not possible to calculate this amount.
(iii) What amount of water was reduced from pump # 3?
Answer: Same as (ii) above .
(iv) If not, why not, in light of water to the golf course was to be
"interruptible" and therefore paid at a lesser rate?
Answer: No customers were cut back to zero usage during this
time period, including the Golf Course Irrigation account. The
account is interruptible, that does not mean it has to be cut off
completely in every situation.
(v) Does the CDS Stoneridge Utility presently receive any benefit
from the golf course water being "interruptible"?
Answer: Yes.
COMPANYS RESPONSE Page 10 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-StoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
(vi) If so, was is the benefit?
Answer: Sell surplus water.
(vii) In the event the golf course water is interrupted, how and in
water manner is that specifically done and accomplished?
Answer: The water demand for all primary customers is
addressed first, especially during peak demand and the fact that
only one of the two pumps was functioning. The utility was
managing the surplus water and reduced flow to the golf course
(which was able to draw down the level of the Golf Irrigation
Pond to supplement the current volume being provided by The
Company). During peak demand times the supply to the golf
course was reduced to zero gallons .
COMPANYS RESPONSE Page 11 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 74: Regarding Happy Valley loan:
(a) The Happy Valley loan was taken out in 2003, correct?
Answer: yes.
(b) The loan was for 20 years, correct?
Answer: We cannot confirm that.
(c) Why has the loan not been paid off?
Answer: We are not sure, we get an annual payment coupon from DEQ
which we pay each January.
(d) The balance of the loan was reported to be $104,005.43 as of January
2024. After 20 years, why is there still a balance?
Answer: Because, according to DEQ's statements it has not been paid
off.
(e) The contract provided in response to Request# 32 does not have a
copy of the promissory note referred to in Section VIII A. (page 8).
Please provide the promissory note.
Answer: We do not have a copy of the promissory note.
(f) The response to Request # 32 provided a loan payment schedule from
2019 to March 2024. Please provide a schedule for all other payments.
Answer: We get an annual statement from DEQ, that is all we have.
COMPANYS RESPONSE Page 12 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-StoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 75: Please provide all contract documents, directions or
instructions to/with Integrity Water Management. This request includes, but
is not limited to, both water and sewer operations involving or related to
Chan or Teresa Karupiah and/or for CDS Stoneridge Utilities, Esprit, JD
Resorts and Bayview.
Answer: See Request PRR NO. 74 for a copy of the Integrity Water
Management contract with StoneRidge Water.
In regard to Esprit & JD Resorts, etc.--Objection: the information requested is
irrelevant, inadmissible, and not reasonably calculated to lead to the legitimate
discovery of admissible evidence and exceeds the obligations of this
administrative process. Furthermore, the request for an organization's contractual
relations from entities or other sources not related to this case is not relevant or
the issues of this rate case.
COMPANYS RESPONSE Page 13 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 76: Please list all employees of the CDS Stoneridge Utilities.
Answer: CDS StoneRidge Utilities, LLC has no employees.
COMPANYS RESPONSE Page 14 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 77: Please list all contracted persons with CDS Stoneridge
UWities (except for Water Systems Management, Sandpoint, identified in
Request 36 and Integrity Water Management).
Answer: Jeff Merkeley, Teresa Zamora, Becca Loughnan, Greg Ziel, Randi
Flaherty, Judy Duffy.
COMPANYSRESPONSE Page 15 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 78: Please provide the contract, directions and/or instructions
to all contracted persons/entities with CDS Stoneridge Utilities.
Answer: Please see responses PRR NO. 34 & 68
COMPANY$ RESPONSE Page 16 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 79: Please provide all 2023 W-2s for all employees of the
Utility.
Answer: The Company has no employees.
COMPANYS RESPONSE Page 17 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 80: Provide all W-2s for Chan Karupiah from CDS Stoneridge
Utilities, Esprit, and JD Resorts.
Answer: CDS StoneRidge Utilities, LLC has no employees.
In regard to Esprit & JD Resorts--Objection: the information requested is
irrelevant, inadmissible, and not reasonably calculated to lead to the legitimate
discovery of admissible evidence and exceeds the obligations of this
administrative process. Furthermore, the request for an individual's compensation
from entities or other sources not related to this case is not relevant or the issues
of this rate case.
COMPANYS RESPONSE Page 18 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-O1-stoneRidge Water Company General Rate Case
5 th Request for Discovery--! ntervenor Garrison
REQUEST NO. 81: Provide all 2023 W-2s for Teresa Ka rupiah from CDS
Stoneridge Utilities, Esprit, and JD Resorts.
Answer: See NO. 80 above same answer.
COMPANYS RESPONSE Page 19 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 82: The Annual report filed with IPUC shows a 2019 expense
for Rentals-Property & Equipment in the amount of $85,200.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of which you already have a digital copy of, are the same for each
month in 2019. These contract typically have increased 8% per year
since 2019.
COMPANYS RESPONSE Page 20 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 83: The Annual report filed with IPUC shows a 2020 expense
for Rentals-Property & Equipment in the amount of $63,735.00, correct?
(a) Please provide a breakdown of this expense for each month, allocated
to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of which you already have a digital copy of, are the same for each
month in 2020. This contract typically has increased 8% per year since
2019.
COMPANYS RESPONSE Page 21 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5 th Request for Discovery--lntervenor Garrison
REQUEST NO. 84: The Annual report filed with IPUC shows a 2021 expense
for Rentals-Property & Equipment in the amount of $68,704.00, correct?
(a) Please provide a breakdown of this expense for each month, allocated
to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of which you already have a digital copy of, are the same for each
month in 2021. This contract typically has increased 8% per year since
2019.
COMPANYS RESPONSE Page 22 of 35 SEPTEMBER 6, 2024
Case # SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 85: The Annual report filed with IPUC shows a 2022 expense
for Rentals-Property & Equipment in the amount of $6~,371.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of, which you already have a digital copy of, are the same for
each month in 2022. This contract typically has increased 8% per year
since 2019.
COMPANYS RESPONSE Page 23 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 86: The Annual report filed with IPUC shows a 2023 expense
for Rentals-Property & Equipment in the amount of $79,465.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: Answer: These expenses were part of the contract
agreements between The Company and Esprit Enterprises. The monthly
Journal Entries (which detail the expense categories) in the QuickBooks
company records of, which you already have a digital copy of, are the
same for each month in 2023. This contract typically has increased 8%
per year since 2019.
COMPANYS RESPONSE Page 24 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 87: What is the 2024 year to present date for Rentals-
Property & Equipment Expenses?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: Answer: These expenses were part of the contract
agreements between The Company and Esprit Enterprises. The monthly
Journal Entries (which detail the expense categories) in the QuickBooks
company records of, which you already have a digital copy of, are the
same for each month in 2024. This contract typically has increased 8%
per year since 2019.
COMPANYS RESPONSE Page 25 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5 th Request for Discovery--lntervenor Garrison
REQUEST NO. 88: Esprit leases to the Water Utility water rights and use of
Rights of Way. Why are the water rights and use of Rights of Way not
already a part of and owned the Utility?
Answer: We cannot speak for the actions of prior ownership of the Water
Company.
(a) What are the annual actual cash costs to Esprit of the water rights
and use of the Rights of Way?
Answer: The amortization of the acquisition costs associated with
the Water Rights along with their annual cash costs exceeds
$2,000/ month.
COMPANYS RESPONSE Page 26 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 89: The Annual report filed with IPUC shows a 2023 expense
for Labor -Amin & General in the amount $67,863.00, correct?
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of, which you already have a digital copy of, are the same for
each month in 2023. This contract typically has increased 8% per year
since 2019.
COMPANYS RESPONSE Page 27 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-StoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 90: The Annual report filed with IPUC shows a 2023 expense
for Salaries-Off. & Directors in the amount $39,303.00, correct?
(a) Are the only persons in this expense item Chan Karupiah and
Teresa Karupiah?
Answer: Yes
(b) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of, wh ich you already have a digital copy of, are the same for
each month in 2023. This contract typically has increased 8% per year
since 2019.
COMPANYS RESPONSE Page 28 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 91: Regarding Randi Flaherty,
(a) Please provide any employment contracts, agreements, directions
or instructions involving her employment.
Answer: There are no written agreements etc .
(b) Please provide her 2024 compensation by month from all entities
associated with or involving Chan or Teresa Karupiah, and/or for
CDS Stoneridge Utilities, JD Resorts and Bayview.
Answer: Ms. Flaherty's part-time involvement this last spring in The
Company IPUC General Rate Case on The Company's behalf is the only
work she has completed for The Company. In regard to Esprit & JD
Resorts, etc.--Objection: the information requested is irrelevant, inadmissible,
and not reasonably calculated to lead to the legitimate discovery of admissible
evidence and exceeds the obligations of this administrative process .
Furthermore, the request for an individual's compensation from entities or other
sources not related to this case is not relevant or the issues of this rate case.
COMPANYS RESPONSE Page 29 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-StoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 92: The Annual report filed with IPUC shows a 2023 expense
for Labor -Amin & General in the amount $67,863.00, correct?
Answer: See answer to NO. 89
(a) Please provide a breakdown of this expense for each month,
allocated to each person or entity.
Answer: N/A
COMPANYS RESPONSE Page 30 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 93: Please provide a year to date (2024) detail for Labor -
Amin & General.
(a) Please provide a breakdown of this expense for each month (2024),
allocated to each person or entity.
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises. The monthly Journal
Entries (which detail the expense categories) in the QuickBooks company
records of, which you already have a digital copy of, are the same for
each month in 2024. This contract typically has increased 8% per year
since 2019.
COMPANYS RESPONSE Page 31 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 94: Regarding the schedule provided in response to Request
# 1, please provide the timecards, logs or details of each employee for the
days claimed to have been working (on the rate case).
Answer: These expenses were part of the contract agreements
between The Company and Esprit Enterprises.
COMPANY$ RESPONSE Page 32 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-O1-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 95: Regarding the IDEQ Report dated 10 October 2019 and
attached to response # 16:
(a) The report states (at pages 2/3) the pump house buildings contain
chlorination components for both wells 1 and 2. The water feeds from both
wells 1 and 2 into 2 lines for distribution and "a separate line for the golf
course. A fourth line is abandoned ... The golf course (irrigation) line is not
chlorinated".
(i) Is this still true today?
Answer: The DEQ Survey contained some errors. There was no
separate line for the Golf Course Irrigation Pond Storage-it is
fed by chlorinated water from the primary domestic distribution
system.
There is a smaller line for a water feature adjacent to the
Well/Chlorine buildings that may not be chlorinated and is not
currently being used, this is likely a statement made by the
inspector thinking that the 2" line was not being used-never
mind it is not of adequate size to service the Golf Irrigation Pond
demand flow.
(ii) Was this true in October 2023?
Answer: See above
(iii) If either of the above are not true, when was the change made
not to have a "golf curse (irrigation) line".
Answer: N/A
(iv) If a change was made not to have a "golf course (irrigation) line"
why was the change made?
Answer: N/A
(v) Explain why no current DEQ report is there (IDEQ Sanitary
Survey)?
COMPANYS RESPONSE Page 33 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
Answer: The last sanitary survey of The Company water system was
completed in October 2019. We are unable to predict if and when DEQ
intends to complete the next survey of our Water System.
Per ChatGPT-"In Idaho, sanitary surveys for small water systems (those
serving fewer than 10,000 people) are generally conducted by the Idaho
Department of Environmental Quality (DEQ) every three to five years. This
schedule applies to public water systems regulated under the Safe
Drinking Water Act, and the exact frequency can depend on the size and
type of the system, as well as its compliance history.
For small community water systems, the three-five year interval is more
typical if the system has known issues or if it's in a sensitive area (like
being close to bodies of water or other contamination sources). If the
system has a good track record of compliance, it might extend to five
years.
The sanitary survey assesses key components like the source water,
treatment, distribution, storage, and monitoring protocols, ensuring the
system is following state and federal regulations. "
COMPANYS RESPONSE Page 34 of 35 SEPTEMBER 6, 2024
Case# SWS-W-24-01-stoneRidge Water Company General Rate Case
5th Request for Discovery--lntervenor Garrison
REQUEST NO. 96: Regarding all of the sub-questions in this Request# 91, if
any of the requests are not answered and/or are objected to, please provide
the name of the person best suited to answer the question; several dates
and times his/her deposition may be taken; and a proposed place of
deposition.
(a) Do you agree that CDS Stoneridge Utilities owes its customers a duty
of good faith and fair dealing as describe in Burns Concrete, Inc. v. Teton
County, 168 Idaho 442, 483 P.3d 985 (2020) ["The district court did not err
in its determination that the County violated the covenant of good faith and
fair dealing. A party violates this covenant when it "violates, nullifies or
significantly impairs any benefit of the contract."]
Answer: No.
(b) Do you agree CDS Stoneridge Utilities violated its duty of good faith
and fair dealing, by significantly impairing a benefit of its contract when
removing most of the golf course water service from CDS Stoneridge
Utilities?
Answer: No.
( c) Do you agree that the golf course was a significant benefit to CDS
Stoneridge Utilities by providing the Utility net review (after electricity and
chlorine expense) of $12,648.59.
Answer: No.
(d) Do you agree that the golf course was a significant benefit to the
customers of CDS Stoneridge Utilities by providing a broader base and a
high-end user to cover and pay for the costs of the Utility?
Answer: No, but selling surplus water was.
COMPANYS RESPONSE Page 35 of 35 SEPTEMBER 6, 2024