20240918Responses to Joe.pdf

Sent By: Email
September 17, 2024
Monica Barrios-Sanchez
Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83720
Boise, ID 83720-0074
~✓~
STONE RIDGE
---~---
CDS StoneRidge Utilities, LLC
P.O. Box 298
Blanchard, ID 83804
Ph (208) 43 7-3148 Extn. 4
RE: CDS StoneRidge Utilities SWS-W-24-01 General Rate Case Response
Mr. Dµval, please find attached our written response to Joe Terry's two questions he
emailed us in Aug st 2024.
Plea if you have additional requests.
Sine
Chan ir_..,,......,.~L
Man ging Member
RECEIVED
Wednesday, September 18, 2024
IDAHO PUBLIC
UTILITIES COMMISSION
Memorandum
To: IPUC Monica
From: CDS StoneRidge Utilities, LLC SWS-W
RE : General Rate Case 24-01--Two Questions received from Joe Terry with no
associated PRR #
1. Provide copies of replacement pump/drive invoices and cancelled check(s) as
proof of payment.
Narrative: At the end of August, the pump vendor requested payment in full on the new
pump motor and Drive. The Water Company did not have available funds to pay for the
#3 Well pump motor and Drive board replacement this summer. The Water Company
approached Esprit for assistance since IPUC did not provide any direction on how to
proceed with funding the capital expenditure.
In discussions with Esprit regarding this capital expenditure, Esprit was unwilling to
invest more capital in The Company in exchange for additional equity. Esprit offered a
Lease Purchase option which The Water Company accepted. A copy of the Lease
Purchase Agreement is attached as Exhibit 1. The lease payments should be part of
the rate calculation process. See Exhibit 2 for Monthly lease payments made by The
Company to Esprit Enterprises, LLC.
In addition to the equity stake Esprit holds in The Company, the accounts payables
balance owed by The Company to Esprit was approximately $179,322.00 as of August
31, 2024. The Company makes payments on the payable balance when excess funds
are available. We are going to need to transfer any A/P balance at year-end into long-
term debt in The Company. We want to ensure that the annual long-term interest paid
will be included in the rate calculation process as well.
2. Provide copies of billing statements from Piskel Yahne Kovarik Law Firm for
our legal support on the rate case.
a. Please find attached Exhibit 3 August billing statement
for Piskel Yahne Kovarik JD's.
b. Please find attached Exhibit 4 September billing statement
for Piskel Yahne Kovarik JD's.
LEASE PURCHASE AGREEMENT
This Lease Purchase Agreement ("Agreement") is made and entered into on
this August 1, 2024 by and between:
Lessor: Esprit Enterprises, LLC
Address: 364 StoneRidge Road, Blanchard, Idaho 83804
Contact Information: 800-952-2948, [e-mail]
Lessee: CDS StoneRidge Utilities, LLC OBA StoneRidge Water Company
Address: 12 Holiday Loop, Blanchard, Idaho 83804
Contact Information: 208-208-437-3148 [e-mail]
Asset Description:
The lessor agrees to lease to the lessee, and the lessee agrees to lease from
the lessor, the following described asset (the "Asset"):
1.) SME USA l00HP Submersible Well Pump & Motor
Motor Code-207522-06-5
Serial #-00522401003
2.) Yaskawa IQl000 139A 460V Drive
3 .) UCC-1 Filing
1. Term of Lease
The term of this lease shall commence on August 1, 2024, and shall continue
for a period of Sixty Months, unless terminated earlier in accordance with
the terms of this Agreement.
2. Lease Payments
The lessee agrees to pay the lessor a monthly lease payment of $1,200.00
due on the 1st day of each month, beginning on August 1, 2024.
3. Option to Purchase
The lessee shall have the option to purchase the Asset on or before the end
of the lease term, subject to the following terms:
• Purchase Price: The purchase price of the Asset shall be One Dollar
($1.00) (the "Purchase Price").
• Option Period: The option to purchase may be exercised at no more
than 30 days prior to the lease expiration of July 31, 2030.
• Credit for Lease Payments: No portion of the lease payments shall be
applied to reducing the purchase price option on this lease.
4. Exercise of Option
To exercise the option to purchase, the lessee must provide written notice to
the lessor of their intention to exercise the option (the "Option Notice"). The
Option Notice must be delivered on or before the end of the lease term . The
Purchase Price, less any credits, shatl be paid in full within 30 days after
delivering the Option Notice.
5. Maintenance and Insurance
• Maintenance: The lessee agrees to maintain the Asset in good working
order and condition during the lease term. Any required maintenance
or repairs shall be the responsibility of the lessee.
• Insurance: The lessee shall, at their own expense, maintain insurance
on the Asset against loss or damage in an amount not less than
$55,000.00 and name the lessor as an additional insured.
6. Default
If the lessee fails to make any payment due under this Agreement or
otherwise breaches any term of this Agreement, the lessor may, at their
option, terminate this Agreement by providing written notice to the lessee.
Upon termination, the lessee shall immediately return the Asset to the
lessor.
7. End of Term Options
At the end of the lease term, provided the lessee is not in default, the lessee
shall have the following options:
1. Purchase the Asset: Exercise the option to purchase as described
above.
2. Return the Asset: Return the Asset to the lessor in good condition,
normal wear and tear excepted.
3. Renew the Lease: Enter into a new lease agreement with the lessor on
mutually agreeable terms.
8. Governing Law
This Agreement shall be governed by and construed in accordance with the
laws of the State of Idaho, without regard to its conflict of laws principles.
9. Entire Agreement
This Agreement constitutes the entire understanding between the parties
and supersedes all prior discussions, agreements, or understandings of any
kind.
10. Amendments
Any amendments to this Agreement must be made in writing and signed by
both parties.
11. Signatures
-r
Chan Karup ah
Member CDS StoneRidge Utilities, LLC
31 Page
STATE OF IDAHO
COUNTY OF BONNER
NOTARY PUBLIC -(; -.J ,, l C:'6<-
My Commission Expires: l \-o¼~ 202<;-
STATE OF IDAHO
COUNlY OF BONNER
My Commission Expires: l t-ol('-2DLS-
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August)6, 2024
612 W. Main Ave., Ste. 207
Spokane, WA 99201
P 509.321.5930 / F 509.321.5935
Jason T. Piskel
[e-mail]
JeffMerkeley
CDS StoneRidge Utilities, LLC
Via Email: [e-mail] &
[e-mail]
Re: August Invoice
Dear Jeff:
Enclosed for services rendered is Invoice #348465 in the amount of $3,952.50.
Your current trust account balance is $3,087.50. Please review the enclosed invoice and
if it meets with your approval, we will apply the sum of $3,087.50 from your trust account
in three business days. This will leave $865.00 owing for this invoice and $0 .00
remaining in your trust account.
JTP:co
Enclosure
Very truly yours,
\Vith Lawyers lmitted in • 1asbington, Idaho, MonWla, Califo1nia, Oregon, Arizona and Nevada
www.pyklawy .com
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Piskel Yahne Kovarik PLLC
612 W. Main Ave., Ste. 207
Spokane, WA 99201
us
www.pyklawyers.com
0: [phone]
Bill To:
CDS StoneRidge Utilities, LLC
P.O. Box298
Blanchard, ID 83804
INVOICE
Inv.No. 348465
Issue Date (_a,1a,20~ )
Re: IPUC Rate Case SWS-W-24-01 -4601
Email [e-mail]
WE HAVE MOVED. Please update your reco r ds wi th our n ew address listed above. All payments , if mailed, should
be mailed to the new address.
As a courtesy to our clients, Piskel Yahne Kovarik, PLLC offers online payments through Lawpay. If you wish to pay your invoice this
way, please review the CREDIT CARD & eCHECK PAYMENT TERMS at the end of this invoice as there are fees associated with
online payments .
Fees
Fees Billed by Rate -Subtotal
No Charge PA $0.00 2.30 $0.00
7/17/2024
Research re: confidentiality of records for rate case.
Time JTP $425 .00 0.60 $255.00
7/22/2024
review of email from Rick H. (0.2); draft response email to
Rick H. (0.2): email to client (0.2).
Time JTP $425.00 0.50 $212 .50
7/31/2024
call with M. Duval.
Time JTP $425.00 0.30 $127.50
7/31/2024
call with Jeff M. re: share file and documents.
Time JTP $425.00 0.20 $85 .00
7/31/2024
Respond to Garrison re: corns with Staff re: notice of
parties.
Time JTP $425 .00 2.00 $850.00
7/31/2024
communicate with client re: discovery (0.4); email to notice
parties (0.3); review client documents in response to PRR
(1.3}.
1-348465 Page 1 of:
Time
8/1/2024
Work on discovery responses to PRR and review
Intervenor's requests (2.5); call with client re: share file (0.3).
Time
8/5/2024
Review email from R. Haruthunian (0.3); call with J. Merkeley
re: discovery requests and application (0.3); email to R.
Haruthunian (0.2).
Time
8/6/2024
email to parties re: ex parte contact with J.M>.
No Charge
8/14/2024
4601 -JTP -Rsch on Agency Action in Idaho
Time
8/15/2024
conf. call with client re: Duval email re: scheudle.
Time
8/15/2024
call with M. Duvall.
Time
8/1512024
draft response to Scheduling process email.
Time
8/15/2024
Review Duval email (0.2); call with J. Merkeley (0.3).
A LL INVOICES ARE PUE UPON Rt:CEIPT .
JTP
JTP
JTP
PA
JTP
JTP
JTP
JTP
$425 .00 2.80
$425.00 0.80
$425.00 0.30
$0 .00 2.00
$425.00 0.50
$425.00 0.30
$425.00 0.50
$425.00 0.50
Fees Total 13.60
Total (USD)
Paid
Balance
Total Outstand ing
Thank you for your business. Please indicate the Invoice Number and Matter Number with your payment.
Tax ID: 46-0747076
$1,190.00
$340.00
$127.50
$0 .00
$212 .50
$127 .50
$212.50
$212.50
$3,952.50
$3 ,952 .50
$0 .00
$3,952 .50
$3 ,952 .50
CREDIT CARD & eCHECK PAYMENT TERMS: There will be a 3% processing fee for the use of any credit card and
a 1 % fee up to and never exceeding $10.00 for eCheck (eCheck payments are limited to $10,000 per transaction).
By using either of these forms of payment, you agree to pay the charges referenced, and these charges will be
billed to you during the next billing cycle. To use this service, go to w ww pyk !awye rs c om and click on the MAKE A
PAYMENT LINK and follow the directions there.
1-348465 Page2of3
Piskel Yahne Kovarik PLLC INVOICE
612 W. Main Ave., Ste . 207
Spokane, WA 99201
us
www .pyklawyers .com
0 : [phone]
Bill To:
CDS StoneRidge Utilities , LLC
P.O. Box298
Blanchard , ID 83804
Inv.No. 348684
Issue Date 9/16/2024
Re: IPUC Rate Case SWS -W-24-01 -4601
Email [e-mail]
WE HAVE MOVED. Please update your records wi t h our new address listed above. All payments, if mailed, should
be mailed to the new address.
As a courtesy to our clients, Piskel Yahne Kovarik, PLLC offers online payments through Lawpay . If you wish to pay your invoice this
way, please review the CREDIT CARD & eCHECK PAYMENT TERMS at the end of th is invoice as there are fees associated with
online payments.
Fees
Fees Billed by Rate -Subtotal
Time JTP $425.00 0.40 $170 .00
8/16/2024
Final email to parties re : procedure.
Time JTP $425.00 0.40 $170 .00
8/20/2024
call with M. Duvall .
Time JTP $425.00 0.40 $170 .00
8/22/2024
call from J. Merkeley.
Time JTP $425 .00 0 .90 $382 .50
8/23/2024
review email from R. Garrison (0.2); review discovery
requests from R. Garrison (0.5); email to R. Garrision (0.2).
Time JTP $425.00 0.40 $170.00
8/26/2024
review email and pleading from M. Duvall re : modified
procedure request to Commission (0.3); email to client re :
same (0.1).
Time JTP $425 .00 0 .40 $1 70.00
8/27/2024
Email to M. Duvall re : settlement conf. (0.2); email to client
(0.2).
. .
Fees
Time JTP
8/29/2024
confer with client re: garrision answers (0 .3); review and
respond to email from Garrison re: discovery {0 .3).
Time JTP
9/10/2024
calls with Jeff Merkeley re : Garrison requests.
Time JTP
9/11/2024
call with Jeff.
Time JTP
9/12/2024
Review and analyze Garrison email to Duval.
Time JTP
9/13/2024
review Garrison correspondence (1.0); confer with client re:
motions and responses to Staff RFP{0.3); call with M. Duval
(0 .1 ).
ALL INVOI CE S ARE DUE UPON R ECE I PT.
$425 .00 0 .60
$425.00 0.40
$425.00 0 .30
$425.00 0 .50
$425.00 1.40
Fees Total 6.10
Total (USO)
Paid
Balance
Total Outstanding
Thank you for your business. Please indicate the Invoice Number and Matter Number with your payment.
Tax ID : 46-0747076
Subtotal
$255 .00
$170 .00
$127.50
$212 .50
$595 .00
$2,592 .50
$2,592 .50
$0 .00
$2,592 .50
$2,592 .50
CREDIT CARD & eCHECK PAYMENT TERMS : There will be a 3% processing fee for the use of any credit card and
a 1% fee up to and never exceeding $10.00 for eCheck (eCheck payments are limited to $10,000 per transaction).
By using either of these forms of payment, you agree to pay the charges referenced, and these charges will be
billed to you during the next billing cycle . To use this service, go to www.py k la wyers.co m and click on the MAKE A
PAYMENT LINK and follow the directions there .
..