20241023Staff to SWS Nos. 1-3.pdf

RECEIVED
Wednesday, October 23, 2024 11:01:57 AM
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 ) COMMISSION STAFF'S
RESPONSE TO THE FIRST
PRODUCTION REQUESTS OF
CDS STONERIDGE UTILITIES,
LLC
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
Michael Duval, Deputy Attorney General, responds as follows to CDS Stoneridge Utilities,
LLC's ("Company") First Production Request to Commission Staff.
REQUEST NO. 1: What are the six entities Staff is referring to that they proposed to
split the total annual premium between?
STAFF RESPONSE NO. 1:
1) Stoneridge Utilities LLC;
2) Stoneridge Land Holdings LLC;
3) Esprit Enterprises LLC;
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
CDS STONERIDGE UTILITIES, LLC 1 OCTOBER 23, 2024

4) CDS Stoneridge Utilities;
5) JD Resort; and
6) CDS Stoneridge Partners LLC.
REQUEST NO. 2: We would like to see the detail on the calculation for
$1,889.00/month over 30 months for the rate case cost amortization.
STAFF RESPONSE NO. 2: Please see Company's application Attachment#L: Exhibit
#2 Schedule B Expenses (PDF pages 35-36) and Attachment AA: Exhibit# 8 Case Cost
Amortization Worksheet (PDF pages 83-84).
REQUEST NO. 3: In August we forwarded to Staff our increase in debt owed by the
Company to Esprit from 2024 transactions. We asked how we treat this obligation for the rate
case—would they recommend it be converted to equity or debt? Staff never responded to our
inquiry. We would appreciate an answer to this question so we can complete the balance of our
Response to Commission Staff Comments.
STAFF RESPONSE NO. 3: In Order No 36084, the Commission rejected the
Company's request to issue debt and ordered the Company to reclassify the debt up to that point
as additional paid-in-capital. Per Idaho Code § 61-901, the Company may only issue bonds or
other debt with Commission approval. Without a filing for authority to issue debt, the Company
may not record debt on its books.
DATED at Boise, Idaho, this 23rd day of October 2024.
Michael Duval
Deputy Attorney General
1:\Utility\UMISC\PRDREQ\SWS-W-24-01 Staffs Response to PR#Ldoex
STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUEST OF
CDS STONERIDGE UTILITIES, LLC 2 OCTOBER 23, 2024

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 23rd DAY OF OCTOBER 2024,
SERVED THE FOREGOING COMMISSION STAFF'S RESPONSE TO THE FIRST
PRODUCTION REQUESTS OF 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: j ip skel@ yklawyers.com
BLANCHARD, ID 83804
E-MAIL: [e-mail]
utilities(cr�,stonerid geidaho.com
jeff(amerkeley com
RANDOLPH LEE GARRISON, PRO SE NORMAN M SEMANKO
76 BELLFLOWER CT. PATRICK M NGALAMULUME
BLANCHARD, ID 83804 PARSONS BEHLE & LATIMER
E-MAIL: garri sonAnngarri son.com 800 W MAIN ST STE 1300
BOISE ID 83702
E-MAIL: [e-mail]
[e-mail]
BRADY L ESPELAND
RAMSDEN, MARFICE, EALY& DE SMET,
LLP
700 NORTHWEST BLVD.
P.O. BOX 1336
COEUR D'ALENE, ID 83816-1336
E-MAIL: [e-mail]
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE