20241030Reply Comments.pdf

RECEIVED
Wednesday, October 30, 2024
IDAHO PUBLIC
JASON T. PISKEL, ISB #7433 UTILITIES COMMISSION
[e-mail]
Piskel Yahne Kovarik, PLLC
612 W. Main Ave., Suite 207
Spokane, WA 99201
Telephone: [phone]
Fax: [phone]
Attorney for CDS StoneRidge Utilities,LLC
IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS STONERIDGE ) Case No.: SWS-W-24-01
UTILITIES, LLC'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES ) CDS STONERIDGE UTILITIES,
AND CHARGES FOR WATER SERVICE ) LLC'S REPLY TO COMMENTS
IN THE STATE OF IDAHO )
CDS Stoneridge Utilities, LLC ("The Company") by and through its attorneys of
record, Jason T. Piskel of Piskel Yahne Kovarik, PLLC, submits the following reply to the
commission staff comments dated Oct 2, 2024, and intervenors'comments dated October
7, 2024.
COMPANY SUMMARY REVIEW OF STAFF ANALYSIS
Commission staff comments are misdirected and their recommendations, if adopted, will
result in reversible error as the requests exceed the delegated authority of the Commission. Staff s
recommendations are arbitrary and capricious, and if adopted, will not withstand judicial
scrutiny.
Legal Authority& Brief Analysis:
• Afton Eneror, Inc. v. Idaho Power Co., 111 Idaho 925, 928 (1986) ("The Commission
generally has jurisdiction to hear matters presented to it regarding the regulation and
supervision of public utilities. But the Commission's jurisdiction is limited and has to be
found entirely in the enabling statutes. Specifically, the Commission has no jurisdiction
to take away a utility's freedom of contract(so long as the contract is not inimical to the
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 1

public interest) and must consider private contracts when involved in the rate-making
process.") (internal citations omitted).
• Utah Power & Light Co. v. Idaho Public Utilities Com'n, 107 Idaho 47, 52 (1984) ("It has
been firmly established that the PUC has no authority not given it by statute. The Idaho
Public Utilities Commission has no authority other than that given to it by the legislature.
It exercises a limited jurisdiction and nothing is presumed in favor of its jurisdiction.")
(internal citations omitted).
• U.S. v. Utah Power & Light Co., 98 Idaho 665, 667 (1977) ("(IPUC's] powers and
jurisdiction derive in entirety from the enabling statutes creating it and nothing is
presumed in favor of its jurisdiction. ... The Idaho Public Utilities Act specifically delegates
rate-fixing authority to the Idaho Public Utilities Commission.") (internal citations
omitted).
• Matter of Strand, 11 Idaho 341, 342 (1986) ("The IPUC is a creature of statute, see LC§
61-201, with limited powers.").
Staff s recommendation will put the Company into a dire financial strait, especially since
its last general rate increase was 17 years ago. Since 2004, the successive owners have invested
over a million dollars to keep The Company operating. Correct analysis by staff is critical to ensure
Company operations are both sustainable and viable going forward. Conversely, an incorrect
analysis may potentially place The Company in distress,which is in everyone's mutual interest to
avoid as it manages a public water system. The Company owes Esprit $194,326 as of October 26,
2024. This accumulated debt has been reflected in every quarterly report that commission staff
has been provided and reviewed without raising an issue.The Company asked how to address this
debt, but staff only recently replied, providing an incomplete answer. To address the
intercompany debt situation (in SWS-W-03-03 IPUC recommended rolling accumulated debt
and interest into additional paid-in capital), The Company thus added the debt to the additional
paid in capital in The Company, as shown in The Company's Excel Attachment X Tabs A-I to
this filing.
This rate case used 2023 financials as the test case year, but staff modified the financials
and used projected 2024/2025 estimates for some items, i.e., Golf Revenue and contracted labor
etc. Following Staff s lead, The Company proposes to roll the 2024 intercompany debt into
additional Paid-In Capital in 2024 as it is important to address all financial shortcomings to set
The Company in a positive go forward position.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 2

The arbitrary and capricious analysis by IPUC staff regarding Company charges and
changes are summarized in the table below with detail explanation and exhibits included after.
The Commission should find The Company's requests as reasonable under the circumstances and
not unjust, unreasonable, discriminatory or preferential, or in any way in violation of any
provision of law. I.C. § 61-502; See also, Boise Water Corp. v. Idaho Pub. Utilities Comm'n, 99
Idaho 158, 161, 578 P.2d 1o89, 1092 (1978) (discussing how the IPUC,which improperly adjusted
cost increase attributable to a 43.7% postal increase as an affiliate-billed expense and disallowed
it to extent that it exceeded consumer price index, and likewise disallowed a portion of customer
accounting cost increase that resulted from a change to a computerized billing system performed
by a nonaffiliate, erroneously disallowed portion of such expenses by treating them as affiliate
billings and then contrasting them with the consumer price index).
The Company also requests a modification to the proposed tariff.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 3

Staff Company
Proposed Reply
(Amounts in
(Amounts
these columns
are changes
REVENUE are the change Comments
from the
from the
Company's
Company's
original
original
application)
application)
Staff assumed new irrigation well
contributed 18.7% reduction when in
Revenue - fact the pump was offline and new
465 $25,457.00 $7,783.00
IRRIGATION improved golf irrigation controllers
utilized 20% less water. The new well
will produce 18 million gallons per year
Staff Company
Proposed Reply
(Amounts in
(Amounts
these columns
a
' EXPENSES re change are the change Comments
from the
from the
Company's
Company's
original
application). original
application)
Staff removed $68,335 and allocated
$24,430 for contract labor. Based on the
last 6-month average billing, the
601.6 Labor- Operations -$68,335 -$68,335 monthly average is $4,243 which totals
$50,916. *The difference of $26,486
needs to be added to the 631.1.34
contract labor
IPUC staff determined Company staff
601.7 Labor- Customer -$18,966 $18,966
makes $1,40o/month - The contract is
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS -4

for $26/hr for 21 hrs/week for The
Water Company
Staff removed bookkeeping — works
8hrs/wk @$3o/hr. Staff proposing
changes to tariff to keep office open M-F
Labor — Admin & -$15,750
601.8 -$31,395 8-5Pm and on call 24/7 — The Company
General
needs general manager time to
accommodate the requested by Staff to
change operation hours.
631.1.34 Contract Service $24,430 $50,916 * See 6oi.6 above.
No property/water rights were
Rental of Property &
transferred out of The Water Company.
Equipment
641.42 -$30,233 $30,233 I.E. Just because the previous owner did
Ground
not charge for the use of the office space
Lease/Water Rights
does not constitute ownership.
See market rate assessment of office
space rental—the lease amount shown is
Rental of Property &
641.42 -$13,614 $13,614 partial rental rate for The Water
Equipment— Office
Company. In fact,the sewer operation is
moving out of this building Jan 1.
Staff claimed we don't have an operator,
and we should just rent a backhoe. We
do have an operator and need for the
backhoe — locating lines, fixing small
Rental of Property &
repair, and primarily snow removal in
641.42 Equipment — -$7,200 $7,200
the winter to access well houses,
Backhoe
reservoir, meters, parking lot etc. 2-day
backhoe rental is $1,l00. Staff showed
no money allocated for backhoe rental
for the alternative.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 5

Staff rejected our lease at 12.5% and
Rental of Property & suggested it was higher than the normal
641.42 Equipment — Well 3 0 $12,480 11%. We recomputed the lease at 11%
Pump/Controller and started on Sept 1. The pump is fully
functional.
Staff made a wrong assumption claiming
a portion of the property and liability
coverage was for workman's comp. No
property/liability covers workman
comp.In fact,the agent provided$7,000
for The Water Company portion but staff
656 Insurance Expense $4,973 $9,000 decided to do its own analysis and claim
$4,973• The current insurance is
dropping coverage for the golf course
because of the utilities, and we perceive
insuring The Water Company
independently. Estimate shown—See
Pages 49-50
Company made an error filing a monthly
amount rather than a total for the year
and Staff ignored attorney's fees — total
legal cost to date is $12,665.
$27,732 The right amount is ($1889+$422) *12
666 Rate Case $1,889
Mo. The Company legal fees going
forward also, need to be
considered as well and factored
into the final rate analysis at the
conclusion of the case.
Staff proposed using longer life
Depreciation 0 0 deprecation schedule than The Company
has been using in its filings—Is Staff
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 6

Recommendation for NAURC Schedule
reasonable?
Golf Irrigation reducing its demand —
Company capacity increase by 40% -
Facility Plan Plan complete by 2030 with no condition
to future rate case.
Treatment of Service Staff propose combining 3/4"and 1"
Connections with 1- service into 3/4". Company disagrees and
inch meters needs to keep these 2 separate services.
With the proposed corrections in conjunction with staff recommendations, The
Company recommends the commission establish a total revenue requirement of$477,193
or a 124.27%increase,which is a$184,398 increase from the staff s recommendation.This
will translate to a base rate of$53.82 vs $24 currently after 17 years. This new base rate is
about average in the surrounding area. See Attachment X, Sheet A Line No. 26. The
revenue requirement is calculated on a net rate base of $282,549 and a recommended
return on equity ("ROE") of 11%.
The ComRa='s reply's to Staff Comments from 10-2-202a are listed
below with title and page # from the Staff Comments Report.
This above table and below portion of the Reply are drafted by the Company principals and
thus uses first person prose.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 7

Company Perception of IPUC's Staff Bias to Protect the Water Customer vs Protect
the Long-Term Viability of the Company
Since our purchase of the Company in the Fall of 2018 we have consistently observed
IPUC's seemingly inherent bias to minimize customers' short-term water rates vs supporting the
long- term viability of the Company. Since the purchase in fall of 2018, the Company has been
exclusively dependent upon water revenues and new connection revenues, and these revenue
sources have not been sufficient to allow the Company to sustainably continue to operate.
Prior to 2015, the previous owner of the Company had run up a deficit of$500,000 from
operations. Since 2018 the Company has incurred an even greater number of operating losses,
along with a loss on every new connection (loo+ since 2018)because IPUC has failed to allow for
a"New Connection Charge"that reflects the costs in the marketplace. These decisions are at odds
with the reality that we are paying $2,500-$3,500 more for connections than we receive in IPUC
connection fees.
Even after two attempts at raising our connection fees to a level equal to our costs,we have
been unsuccessful in getting IPUC approval for a cost above $4,200. Frustratingly, our neighbor
Spirit Lake East has been given staff approval for $5,500 yet they are located 20 minutes closer
to subcontractors than we are. The staff faults our record keeping on new connection costs but
does not acknowledge our negative cash flow records from new connections. Is that a fair and
reasonable standard to hold a newly transferred water company to?Allowing us to carry forward
the loss on connections while blocking an increase to our new connection charges that would allow
us to breakeven on these new connections?There is a definite bias on the part of Staff against the
Company, and it is extremely detrimental to the ongoing operating stability of the Company when
it has to lose money on every new connection it makes with no way to recover those costs from
operating profits in the near future. Again, this will result in the Company having inadequate
working capital to make needed improvements or finance them.
The staffs approach will lead the Company down a path without adequate
capital/profits/reserves until the existing plant and equipment is depleted to the point that the
Company fails and ceases operations and leaves the customers holding the bag. Surely, IPUC
realizes that this strategy will leave the customers with the short end of the stick in the long run.
It has been IPUC's tactics and strategies that-have always placed the customer first, even when in
the long run, the customers will need to find an investor who is willing to buy a company that is
unable to operate profitably with an adequate return on its investment. Staff s recommendations
fail reflect even an attempt to keep up with the consumer price index over the last 17 years—which
CDS STONERIDGE UTILITIES;LLUS REPLY TO COMMENTS - 8

at a minimum to stay even with inflation the rate should be $36.82 or a 49%increase or an $11.61
increase. See Exhibit A). Staff is only providing an increase of $5.91, a number that is wholly
unreasonable.
The long-term consequences of Staff s current strategy are that the Company will not be
able to continue to be a water provider as it is strangled by Staff recommendations totally focused
on the customer's position, rather than balancing it with the long-term viability of the Company.
After 12 years of minimal new connections, in 2020 the new owner of the Company was
overwhelmed with approximately too requests for new connections over the following 4 years.
The new Owners were not the developers of all those lots, many of them were legacy lots whose
infrastructure costs had already been distributed to the prior developer(s)/owners or private
owners of the lots prior to the requests for new water connections. Rather than working with the
Company's new owner, Staff refused to acknowledge the actual cash losses on each new hookup
the Company was experiencing and refused to increase the new connection revenues to an amount
equal to the new Connection Costs (rather took the lowest install cost of 1 install over a period of
time). This led to the Company adding an excess of $300,000 to its Plant & Equipment #331
Services account in the last five years—this was the shortfall over four+ years of the New
Connection Revenue not covering the new connection costs. The Staff s justification for keeping
the new connection fees below costs was that the Company's documentation did not meet the
Staffs requirements—despite the negative cash flow reports confirming these new connections
were creating a large deficit in the Company's financial statements and thus potentially penalizing
the existing customer base to subsidize these new hookups.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 9

Capacity to Meet Current and Future Demands
"Based on the information provided in the IDEQ sanitary survey and lack of
customer complaints, Staff believes the Company has enough capacity to meet its
current demands. However, due to the lack of adequate information, Staff could not
assess the Company's projected growth and associated capacity needed to serve its
future demands. The Company's Facility Plan was documented in 2oo6, and Staff
believes it should be revised with detailed analysis reflecting the Company's current
system capacity and critical parameters (such as average daily demand, maximum
daily demand, peak hourly demand, etc.)for both current and future customers. Staff
recommends the Commission to direct the Company submit its updated Facility Plan
within one year from the date of the final order in this case, or prior to filing its next
general rate case, whichever comes first.
Staff inquired about the Company's system capacity in meeting the current and
future peak demands. The Company responded that its 20o6 Facility Plan study was
limited to average demands, and it does not analyze peak demands. Response to Staff
Production Request Nos. 9 and 23. According to Idaho Administrative Procedures Act
("IDAPA") Rules Section No. 58.o1.o8.50104, a community water system shall be
designed to maintain its maximum daily demand or peak hourly demand with its
largest source being out of service.Although Staff believes the Company's system should
satisfy the current average daily demands, it is critical for Staff to assess the Company's
system in meeting its current and future peak demands, which can be analyzed through
an updated Facility Plan".
Company Reply:
Staff have completed a review of the water system for both the current and foreseeable
future's water supply capacity. In this review, they expressed their belief that the system was
adequate. However,citing a lack of adequate information, Staff claimed and inability to assess the
Company's projected growth and associated capacity needed to serve its future demands. Staff
proposed that the Company have an updated Facility Plan prepared and submitted to IPUC/DEQ
within one year following the date of the final order on this case or before submitting a new case,
whichever occurs sooner. Staff are aware that the golf course's new well is going to result in a
reduction of 40%+ on-demand on the Water System's most recent annual volumes.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 10

There are other more important capital investments that need to be made in the Water
System—Backup Power, Replacement of our 35-year-old Well #1 pump motor,
cleaning/repair/replacement of our 315,00o Gallon Water Storage Tank etc. Despite these facts,
Staff suggests that $60,000-$100,00o be invested in a study to determine future demand when
we know right now that in the next 1-2 years, we are going to increase our supply by 40% due to
the Golf Course building its own supply. Our recent experiences working with DEQ have been very
frustrating as the turn-around times have gone from 6-12 months to 2-3 years. We propose that
we have a more than adequate water supply available for the next few years and there is no need
for an updated Facility Plan, with its attendant time and cost to supersede the other more
important capital investments needed in the system. It is our expectation that a Facility Plan
update be completed by the end of 203o and not be tied to any rate increase, as it is another IPUC
method to stymie the company's financial viability due to the inability to request a rate adjustment
because of economic changes in the market due to the overwhelming cost of a Facility Plan. The
Staff s recommendation to require a Facility Plan in conjunction with the next Rate Case
application should be rejected.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - ii

Staff Comment —Management Issues-Page 5
"Staff believes that the management of the Company is not properly maintaining
ownership and control of assets that are fundamental to the operations of the Company; Staff
believes that some of these crucial responsibilities are abdicated to a related party.For example,
upon purchasing the Stoneridge water system (actually CDS StoneRidge Utilities, LLC), Esprit
transferred the land that the Company's (CDS StoneRidge Utilities, LLC) assets are placed on,
the Right of Way Easements, and the Water rights from the Stoneridge (CDS StoneRidge
Utilities,LLC?)to Esprit, then leased these back to the Company at$2,000 a month. These assets
were originally owned by Stoneridge (CDS StoneRidge Utilities, LLC.?) These assets were
considered contributed capital under IDAPA 31.36.01.102, and Stoneridge (CDS StoneRidge
Utilities, LLC.) was not allowed a return on these assets. These assets have already been paid
for by customers and the Company is now proposing that the customers pay for them again
through a lease agreement with its parent company. This agreement (the lease) effectively
allows the owner of the Company to earn a return on assets determined to have no book value
for ratemaking purposes because they were considered contributed by the original developer"
Company Rekly:
This statement by Commission staff is incorrect and not based upon available information,
rather it shows a lack of understanding of the history of the Company and the realities of
infrastructure development. The use of the word "abdicated" ("fail to fulfill or undertake a
responsibility or duty"), is a strong negative indictment against ownership/management. It also
shows a complete lack of investigation of the facts prior to making an inflammatory incorrect
claim about the history of the Company before and after the purchase of the StoneRidge Golf
Community and related utility company by Esprit Enterprises, LLC, in November 2018.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 12

Commission Staff made the followine claim:
"For example, upon purchasing the Stoneridge water system (actually CDS StoneRidge
Utilities,LLC),Esprit transferred the land that the Company's (CDS StoneRidge Utilities, LLC?)
assets are placed on, the Right of Way Easements, and the Water rights from the Stoneridge
(CDS StoneRidge Utilities, LLC?) to Esprit, then leased these back to the Company at$2,00o a
month."
Company Reply
This Commission Staff statement falsely claims "upon purchasing"land and other assets
were transferred from the Company to Esprit Enterprises, LLC."
Based upon our review of the available records of CDS StoneRidge Utilities, LLC. (corporate tax
returns etc.) along with Bonner County real property records the company CDS StoneRidge
Utilities, LLC., has never owned any real property. Rather the real property parcels constituting
StoneRidge Golf Community and CDS StoneRidge Utilities, LLC.,have been held in separate legal
entities owned by successive investors/developers and were purchased in entirety by Esprit
Enterprises, LLC., in November 2018. So, it would have been impossible for Esprit or any other
entity to make subsequent transfers of land out of the Company to Esprit after Esprit's purchase
in November 2018.
See attached Exhibit B which is a copy of the 2016 filed tax return for the CDS StoneRidge
Utilities, LLC. This was prior to the Karupiah's purchase of the StoneRidge Golf Community.
Note on Page 5 of the return, that Line n Land--has zero balance, indicating that in
2oi6 prior to the Karupiah's purchase the Company did not own any land.
The individual system components above ground—Well pump house, StoneRidge booster
pump station, Happy Valley mid station, and the storage tank at the top of Happy Valley are built
on land acquired by Esprit Enterprises, LLC., in November 2018. There does not appear to have
been any prior ground rent leases for the above ground nor for underground improvements made
by the Company on the parcels now owned by Esprit. Esprit determined that the parcels with the
Company's improvements are burdened by the existence of said improvements and the
implementation of a ground lease was appropriate going forward to compensate Esprit for the use
of its assets.
Given that the Company never owned the land upon which its improvements were built,
then how is it possible that the value of that land has already been "expensed"/paid for by the
Company's customers? Historically the landowner did not charge the Company for its use of the
land for its infrastructure. While the Company and the landowner are currently closely held, it is
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 13

more than likely that in the future the ownership of the Company and the StoneRidge Golf Course
could be sold to independent parties and will no longer be part of the Karupiah family holdings.
In their own self-interest,the Karupiah's have been preparing for these likely transfers by clearing
up issues that were either ignored or of no concern to prior owners. With over 40o equivalent
residential customers and over$200,000 in gross revenues we fail to understand why Staff makes
the point that the Company was not allowed a return on these assets.
In addition to the above, the Company's Balance Sheet shows an excess of$1,200,000 in
plant & equipment assets that appear to have been mostly depreciated over the last 20 years.
Again, which assets are Staff referring to as "contributed capital and Stoneridge was not allowed
a return on"?Certainly not the mostly depreciated$1,200,000+in Plant and Equipment currently
on the books! Filing the first General Rate Case in 17 years has been one of the most significant
steps taken to allow the Company to be an economically independent operation that can provide
both high quality water service to its customers and an adequate rate of return for its current and
future owners.
Regarding the transfer of water rights upon the purchase of the property by Esprit
Enterprises, LLC., all water rights were transferred from the prior owner to Esprit as part of the
purchase/sale agreement CSee Exhibit Q that closed in November 2018. There was no transfer
of any water rights"upon purchasing"by Esprit Enterprises, LLC.
In 2021/2022 an internal review of the existing water rights being used by the Company
revealed the following active water rights:
Right Number Volume Priority Date
1. 95-16411 Active/Decreed Surface water 657.0o AFA 8/3/1910
2• 95-9573 Active Decreed Surface water 394.00 AFA 12/14/1968
3• 95-9587 Active Decreed Groundwater 588.6o AFA 4/26/1972
4• 95-10454 Active License Groundwater 350.7o AFA 5/29/2009
In Exhibit D attached are the IDWR "detailed printouts" of the 4 water rights above. 1-3 were
previously under the name Stoneridge Water Co. and the 4th water right, the newest one, was
previously held under CDS Stoneridge Utilities, LLC.
See Exhibit E for Idaho Secretary of State reports on Stoneridge Water Co. Stoneridge
Water Co. is not the name of a legal entity, rather it appears to be an unregistered name. There
was at one time a STONERIDGE UTILITY COMPANY, INC registered name 4/11/1988 that is
currently"inactive/dissolved" as well as the same name registered again on 10/16/1992 that also
is currently "inactive/dissolved."
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 14

A decision was made after our research in 2023 to consolidate all the water rights under
the parent company-Esprit Enterprises, LLC. The appropriate applications were filed with IDWR
and all four of the water rights now are registered under Esprit Enterprises LLC. These water
rights hold an intrinsic economic value, and the Company gains economic value from their use. It
is only fair and reasonable that the rights holder charges the Company rent for their use of the
water rights. The Company has only ever owned one of the water rights, the newest one from
2009.
A review of"The Leased Ground and Water Rights Lease" See Exhibit F)does not list the
most recent ground water right from May of 20o9 as included in the Water Rights Lease. The
water rights included in the current Water Rights Lease are 3 surface water rights and the ground
water right from 1972 for 588.6 acre feet that was obtained when Well #1 was developed.
We are not aware of any prohibition against transferring a water right from the Company
to a parent company. In any event, it was only one of the four that was transferred in 2023 (and
not upon purchasing)to Esprit from the Company.
Thus, we believe the Staff s accusation of Company mismanagement to be inappropriate.
It is largely incorrect and reflects a unreasonable approach by IPUC Staff to make this statement
based on no collaborating facts supporting this false premise. We request that our ROE rate be
returned to the 11% level reflecting that Staff s claim of mismanagement is not what transpired
regarding property transfers.
Current market rates for water rights rental in the State of Idaho (See Exhibit G) are
$23/acre foot increasing to $33/acre foot January 1,2025,according to IDWR and the Idaho State
Water Bank. The lease of water right 95-9587 from Esprit to the Company at $23/acre foot is
$13,537/year($1,128/month)and will increase January 1, 2025,to$19,423/Year($1,618/month).
Currently the Company is not paying for any of the surface water rights nor the newer 95-10454
ground water right. The balance of the $2,000/month on this lease agreement is "ground rent"
for the 5 locations listed in (See Exhibit F). Staff should return the Water Rights, ROW and
Easement lease expenses back on the books as they have no basis upon which to justify their
recommendation to remove it. The amount in the existing agreement is a fair and reasonable
market rate for use of the real property and personal property rights. On this same subject, Staff
several times seems to have reviewed intercompany lease agreements and failed to note that all
the lease agreements have "escalator clauses" in them and Staff appears to not take those annual
increases into account when they noted that the 2023 test year lease expenses were greater than
the 202o base year.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 15

New Pump Delayed ResRonse Page--g
`Additionally, when the pump (pump motor) on Well No. 3 failed on July 24, 2024, the
Company sent a note to the customers requesting the customers reduce irrigation until a
replacement pump could be installed. The notice also stated that the Company was requesting
expedited review and approval by the Commission for the replacement pump. The Company
further requested its customers contact the Commission in support of the purchase and
expedited recovery of the pump.Staff believes this may have delayed the Company's ordering of
the replacement pump for several days while it waited for the Commission Staff to approve of
the Company performing repairs/replacements that are mandatory to provide safe and reliable
service.
Company Reply
We find this comment by Staff to be inaccurate, upon the failure of the pump motor we
mobilized the replacement process immediately. We were not delayed waiting to hear back from
Staff, we rely on Staff for guidance,but we know that the Commissioners make the final decision.
IPUC auditor,Joseph Terry actually congratulated us on getting the pump back online so quickly.
So, the statement above suggesting that we may have delayed the pump replacement process is
completely inappropriate for IPUC Staff to make. Subsequent issues with the pump controller that
delayed bringing Well #3 back online were a combination of trying to re-use an existing controller
to save money and unanticipated supply chain issues that should not reflect poorly on our efforts
to bring the #3 Well pump back online ASAP.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 16

New Ptimp/Motor Lease From Esprit—Pa c 6_
`Afterwards,Staff requested that Stoneridge provide copies of the invoices for the
well pump that was purchased. The Company's response did not include any evidence
of payment nor copies of any invoices. In its response, Stoneridge stated "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."See Staffs
Attachment D. Staff believes this response was not adequate for several reasons. First,
Esprit and StoneRidge are related parties, and the lease agreement is not an arm's
length transaction. Additionally, per Idaho Code 61610, the Commission has right to
inspect the records of a utility's parent company and any affiliated company . . .that
engages directly in any transaction with the regulated utility which results in expenses
being incurred...Staff has the statutory right and obligation to review invoices to
determine the appropriate recovery of plant investments, and denying Staff access to
the invoices for the new pump violates Public Utilities Law. Third,Mr. Karupiah signed
an affidavit, in Case No. SWS-W-18-o1 stating that he would use his personal funds to
support the capital needs of the Company. A lease purchase agreement may not be in
accordance with that affidavit.
Stoneridge's response included a copy of the lease with terms of$1 ,20o a month
for five years. Based on the initial estimates provided for the price of the pump, Staff
calculated the interest on the lease to be 12.5%, which is above the ROE requested by the
Company in this case. Because it is not fair,just, and reasonable for the Karupiahs to
use its other entities to gain additional profits from Stoneridge customers, recovery of
related party transactions should be at the lower of actual cost or market. Therefore,
any interest on a lease with Esprit is not appropriate to be included in customer rates
and if recovery of the pump were allowed, it must be the actual cost paid by Esprit.As
previously stated, the Company refused to provide invoices for the pump and the actual
cost is unknown.
Importantly, during a September 16, 2024, phone conversation with the
Company, Staff learned that the pump was missing a drive component making the
pump non-functional. This lease agreement has monthly lease payment beginning on
August 1, 2024, before the pump is used and useful. The Company provided a copy of a
check dated August 30, 2024, to Stoneridge Property Management for $2,400, stating
this was for the lease of the pump. Staff recommends that the Commission not include
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 17

the cost of the new pump in rates until it is functional, the proper invoices have been
provided, and Stoneridge has full ownership."
Company Reply
The new pump/motor was installed within 7 days of the original pump/motor failure and
Well #3 was brought back online at that time. In the following week, well #3 repeatedly went
offline due to compatibility issues between the old Controller combined with the new
pump/motor. It was then recommended that we purchase a new control board for Well Pump #3.
We were advised that the necessary equipment was on the shelf, and we ordered the board
immediately expecting it would be installed within 7-10 days. Unfortunately, we had to wait for
an extended period for the board to arrive.The new control board finally arrived and was installed
in September and the pump is now online and running as anticipated.
Staff rejected our proposed$1,20o/monthly lease agreement for the new pump/motor and
control board from Esprit Enterprises. Staff cited the lack of documentation for the costs of the
equipment as well as that their preliminary estimate showed an interest rate of 12.5% what rate
of interest is acceptable, we propose a five year lease at a reasonable interest rate between the
company and Esprit.
Our vendor has been paid for the pump/motor installation based on the original estimate
they provided us. Based on Staff feedback, we have adjusted the interest on the lease to 11% and
we have redrafted the lease agreement and the start date is now September 1, 2024. We are
crediting the Company for the lease payments already received and the next lease payment will
be due on November 1, 2024. The revised monthly lease payment would be approximately
$1,040/month for a 5-year term and 11% interest with a zero-balance due at the end of 5 years.
The alternative option is to convert the lease to additional paid-in capital. To that end, we
provided Staff the original estimate for the new pump and controller as soon as we received them.
The issuance of the final invoices for the pump and controller were delayed until everything was
installed in September, but Esprit had already paid for the new pump and installation in August
as the contractor expected timely payment on their invoices, even if they were not the final
invoices. See Exhibit H). The debt associated with the investment in this equipment by Esprit
would be converted to additional paid-in capital in CDS StoneRidge Utilities, LLC. for Esprit's
account.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 18

Staff Comment-Company Collection Practices-Page-
"Staff is also concerned about the Company's collection practices. Stoneridge has a
reasonable collections policy that dictates first notifying customers who are in arrears of more
than $3oo and increasing efforts to collect until notice of disconnection is given and the
customer is ultimately disconnected. However, Staff notice that the golf course was routinely in
arrears to the Company by more than $3oo, and the Company did not follow its policy. The golf
course is owned by Mr. Karupiah. The Company cannot discriminately apply its policy based
on ownership and Stoneridge must follow its policy in diligently collecting money owed, even if
it means disconnecting service to the golf course."
Company Rely
Staff consistently seems to view the intercompany relationship favorably when it benefits
the customers,but then they view it negatively when it benefits the Company,other than focusing
on whether the costs are reasonable or unreasonable. This issue above was due to late accounting
of intercompany payables rather than actual payment delinquency. Their concerns about the
treatment of the golf course's past due balance seem to ignore the reality that during most of the
last 5 years the Company has owed anywhere from $1oo,000 to over $600,00o to Mr. Karupiah's
interests for his continuing investments in the Company to provide sufficient cash flow to cover
net operating losses. The Company's obligations to Mr. Karupiah's interests have far outweighed
the amounts the Golf Course owed to the Company. In 2024,the Golf Course billing has been kept
current. This issue will be moot soon, with the new rates approved and the Golf Course's new
water supply coming online in 2024 marking the end of the Company providing the Golf Course
with water for irrigation.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 19

Staff Comment—Depreciation Expense—Page-7
"In its Application,Stoneridge included$18,259 in depreciation expense on existing Plant
in Service. Staff reviewed the Company's proposed depreciable lives and depreciation rates for
the various categories of plant, and recommends the Company use the depreciation rates that
align with the depreciable lives provided in the National Association of Regulatory Utility
Commissioners ("NARUC")Depreciation Practices for Small Water Utilities. A summary of the
changes is included in Table No. 1 below:
Company
Plant Life NARUC
Account (years) Life
309 Supply Mains 23.92 50
311 Power Pumping Equipment 20
320 Purification Systems 14.98 20
331 Trans.&Distribution Mains 50
333 Services 20.00 30
334 Meters and Meter Installations 13.99 35
335 Hydrants 31-70 40
339 Other Plant&Misc. Equipment 58.67 10
There are two accounts that the Company did not provide depreciation rates for because
no plant was booked to those accounts. However, Staff proposes the Company capitalize some
of the repair and rebuild expenses, which would create plant assets for those accounts. The
depreciation rates Staff is proposing for those accounts are included in Table No. 1 above.
Additionally, the Company included$1,948 of depreciation expense for plant in Account
334-Meter and Meter Installations, which was completely depreciated in 2023. Therefore,Staff
proposes reducing depreciation expense by $1,948 to account for the fully depreciated items in
Account 334. In total, by using the recommended depreciations rates provided by NARUC, and
removing the depreciation expense on fully depreciated assets, Staffs proposed depreciation
expense is $8,007 less than the Company's requested amount. See Staffs Attachment E"
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 20

CoMaM Reply:
Since assuming ownership of CDS StoneRidge Utilities, LLC., we have filed six (6)Annual
Reports with the IPUC. When we prepared our first annual report, we hired Alden Holm of
Treasure Valley CPA's (Former IPUC Staff member) to advise us on the filing. We specifically
asked him for directions on depreciation schedules for our plant and equipment. We have filed
all 6 reports using his recommendations. Now, when we review the Staff Comments, we see that
for this General Rate Case, staff is recommending the use of the (NARUC) depreciable lives
schedule which significantly reduces our annual depreciation expense.This obviously reduces our
rates by using longer depreciation lives, yet we were not made aware from any prior direction,
comments nor advice from Staff that the rates we have been using in our previous 6 Annual
Reports are inappropriate for a General Rate Case. In that we have never received a single
response from IPUC Staff in the last 6 years regarding our Annual Reports and our depreciation
schedule,we want to ask,under what basis is the Staff recommendation for NARUC's depreciable
lives schedule mandatory in a General Rate Case?
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 21

Staff Comment-Capitalizing Repairs &Rebuilds—Page-8
"The Company recorded three expenses that Staff believes should be capitalized. The first
expense was $6,151 for pump repairs to the Happy Valley Ranchos booster site, the second was
$8,600 to repair water main breaks, and the third was $2,700 for another water main repair.
Because these repairs will extend the life of the assets, they should be capitalized as Plant in
Service.Staff recommend that expense account Maintenance&Supply-Operating be reduced by
$17,451, and that Plant in Service be increased by $6,151 for pumps and accessories in account
311, and an additional $11,300 in account 331 for Transmission & Distribution Mains &
Accessories.
Stoneridge should depreciate the reclassified plant using the depreciation rates in Table
No. 1 above, which increase the test year depreciation expense by $534• See Staffs Attachment
E."
Company Reply:
Making Repairs and Rebuilds to a water system that is already 81%depreciated is a bit like
putting makeup on a dying pig. When the pig dies the makeup will no longer exist. This is the
same situation with capitalizing minor Repairs and Rebuilds to a system which is entering the end
of its life cycle. Those repairs and rebuilds will be torn out at the same time the older system and
replaced--no one is going to tear out all the older system parts and leave the Repairs and Rebuilds
in place (for their remaining depreciable lives) and connect them to a brand new system which is
very likely to be built out of different materials and a design not compatible with the Repair and
Rebuild pieces. The Company believes these Repair and Rebuild expenditures should be treated
as operating expenses and not capitalized, as they represent an insignificant portion of the Plant
and Equipment (less than 1.5% of the total Plant & Equipment in 2023) and expensing them
reflects the immediate cost faced by the Company in keeping the system operating. They are also
a good indicator of the system's health and by tracking them in the Profit and Loss Statement
annually they can guide the Company's planning for rebuilding the Water System. Capitalizing
them on the balance sheet along with other investments will hide this important management
date from ownership. The Company proposes that $17,451 be added back to Repairs &Rebuilds
and removed from the Plant&Equipment accounts.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 22

Staff Comment-Golf Course Revenue—Pate-e
"In its Application,Stoneridge excluded all revenue from the golf course owned by
Chan Karupiah in its rate design. See Exhibit 5, Schedule A. Staff disagrees with the
exclusion of revenue from water sold to the golf course and believes it is reasonable that
the Company will continue serving the golf course at a reduced amount. Staff
recommends that 81.7106 of the golf course's historical consumption be included when
determining the revenue for the Company. Using this estimated amount,Staff proposes
an adjustment to revenue in the amount of$25,457 associated with the consumption
used by the golf course.
In October of 2023, the golf course installed its own well to help provide irrigation
water for the golf course, which will reduce the amount of water provided from
Stoneridge. Stoneridge estimated the golf course would use less than 20 million gallons
in 2024, but through August of 2024 the golf course has used approximately 27 million
gallons. See Response to Staff Production Request Nos. 67, 82, and 102. Based on the
actual golf course consumption through August of 2024, Staff does not believe the
Company's estimate of 20 million gallons is accurate. Some amount of 2024 golf course
usage above the Company's estimate can be explained by the new golf course wellbeing
offline April through June 2024 because of issues with the new well pump. See Response
to Staff Production Request No. 66.
To determine the actual amount of reduced consumption by the golf course, Staff
compared the actual 2024 golf course consumption for the months of July and August to
the historical July August consumption for the years 2022 and 2023. Staff did not
include the other months in 2024 due to the new well pump being offline for April
through June. Table No. 2 shows the comparison of July August 2024 consumption to
2022 and 2023.
Table No 2• July-August 2024 Golf Course Consumption Comparison
Consumption
Line Date
(gallons)
1 July-August 2024 20,529,200
2 July-August 2023 25,384,000
3 July-August 2022 24,844,600
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 23

Average 2022-202
4 Consumption (Avg of Line 2 and 25,114,300
Line 3)
2024 Consumption
5 Reduction (Line 1 minus Line (4,585,100)
3)
2024 July-August Percent
6 Reduction (Line 5 divided by -18.3%
Line 4)
2024 Percent of Historical 7 81.7%
Average (Line 1 divided by Line 4)
Staff determined the amount of golf course consumption to include for
determining revenue by multiplying the 2024 percent of historical average value of
81.7106 by the historical (2022-2023) annual average golf course consumption of
42,705,60o gallons. This calculation results in a golf course test year consumption of
34,908,8691 gallons.
Staffs golf course test year consumption of 34,908,869 gallons was multiplied by
the current approved Schedule 1 commodity charge for the golf course to determine the
consumption revenue. To determine the revenue from the golf course customer charge,
Staff calculated the customer charge based on the golf course using a 1.5" meter for 7
months of the year. In 2023 the golf course had a 6"meter, but in 2024 the meter was
changed to a 1.5"meter. See Response to Staff Production Request No. 103. Starting in
November of 2023 the golf course meter was turned off and was not charged a monthly
charge until April 2024, Staff assumes this practice will continue and the Company will
only receive monthly charge revenue for 7 months of the year. Staffs total test year
revenue including the consumption revenue and the customer charge revenue for the golf
course is $25,457.30. Additional details on this calculation can be found in Staffs
Attachment F."
1 The calculation of this number requires more significant digits for the 2024 percent of historical average value of 81.7%
shown in these comments.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 24

Company Reply:
In its comments, Staff unilaterally rejected the Company's forecast to remove all Golf
Course Irrigation Revenue from Rate Design. Instead, Staff argued that the Golf Course usage
would be 81% of the Golf Course historical use rate based upon 2024 data which was significantly
impacted by ongoing problems with the new Golf Course Irrigation Well.
Staff determined the Golf Course's average usage for July&August 2022 and July&August
2023 = 25,114,300 gallons per month. Staff then compared the 2024 Golf Usage for July&August
= 20,529,200 or 4,585,100 less gallons used in 2024 than the prior two-year average.
4,585,100/25,114,300 they calculated to be 18.3% reduction in volume used in 2024 in July &
August than the prior two-year average for these months.
We do not agree with the approach that Staff used to determine the Golf Course projected
water usage in the Test Case year. The Golf Course has committed to developing their own water
source to be independent of the Company. They brought the new Golf Course Irrigation Well
online in Fall of 2023 with expectations it would provide all necessary irrigation water supply
beginning spring of 2024. Initial well driller estimates for the new well were at 600GPM--more
than enough to supply the Golf Course's annual irrigation demand in the foreseeable future.
Forecasting irrigation water demand for a golf course is dependent upon several factors,
primarily weather based. Staff s simplified two-year, two-month analysis is a statistically
insignificant forecasting model that does not lend any value to forecasting future water usage by
the golf course. We believe Staff significantly overestimated future Golf Course Irrigation usage
of the Company's water based upon two factors that should be reviewed by the Commissioners:
1. In early spring 2024, the Golf Course invested $175,000 to put in new irrigation
controllers to reduce water waste and optimize water usage. The controller supplier
analyzed the golf irrigation system and anticipated a 20%reduction in water usage from
the controller upgrade--regardless of whether the water was being provided by the Golf
Course New Irrigation Well or the Company. It is the Company's belief that the lower
2024 water usage is likely a benefit from reduction of water-use resulting from the new
controllers being installed in 2024.
2. In April-May 2024 the Golf Course New Irrigation Well production level was below the
design capacity for the well. Consequently, in late May the new well was taken off-line
for a "Forensic" evaluation by "Well Development Experts". The Experts concluded
after 4+ months of testing that the well drillers who built the new well, failed to retract
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 25

the last 20' of well casing to uncover the screen at the bottom of the well. This severely
reduced the wells' ability to recharge and resulted in the well's maximum production
dropping from the initial 600GPM estimate to 6o GPM achieved during the most recent
flow tests.
We are negotiating with the original well driller to either repair the existing well by
retracting the casing to expose the screen or drilling a new well in a nearby location. The tests
done this summer on the new Golf Irrigation Well have consistently shown a minimum capacity
above 6o GPM. Staff calculated a test-year consumption of 34,908,869 gallons from its unique 2-
year/2-month forecasting approach. We believe a more realistic analysis should be based upon
the current facts of the monthly capacity of the new Golf Irrigation Well along with the increased
efficiency of the new controllers. At 6oGPM production rate for the golf well and with the 20%
improved efficiency from the new controller we predict the following:
1. Staff predicted Test Year Consumption 34,908,869
2. Less: Projected annual production New Golf Well 18,144,000
3. Less: New Controllers 20% reduction 6.c)81.77--i
Company Projected Test Year Water Volume
This lower corrected Test Year Annual Golf water usage would reduce the commodity
charge for the golf course from $34,365/year to $9,631/year for a total reduction in revenue of
$24,374/Year.
The Golf Course has committed to removing itself from the Company water system for its
primary irrigation ASAP. Failure not to accept these two adjustments and forcing the Company to
go through a subsequent rate case rather than accepting the Company's alternative forecast is
neither fair nor reasonable to the Company. We recommend the Commission accept this
adjustment of $24,374/year as a more accurate accounting of this issue than what the Staff has
come up with.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 26

Staff Comment-Annual Electricity and Chemical Expenses Payze-11-Ll
"Staff calculated a normalized 2023 test year electricity expense of$28,798 and
chemical expense of$8,557 to be included in the revenue requirement. Staff determined
both amounts by calculating a weighted-average cost per gallon for electricity and
chemicals using (1) actual billed amounts for 2022 and 2023 and(2) amounts of water
consumption for both years.
Production/Consumption of Water
Staff first had to determine the Company's actual system-level water production
over the two-year period(January 2022 —December 2023) and estimate the amount of
golf course consumption. The results are shown in Table No. 3 below. The consumption
data provided by the Company was limited to two full years (2022 —2023), which Staff
used in its analysis. See Response to Staff Production Request Nos. 12, 13, and 102.
Table No system-level Water Production and Golf Course Consumption
Year Well No. 1 Well No. 2 Annual Total Actual Golf Course
Production Production Production Consumption
(Gallons) (Gallons) (Gallons) (Gallons)
2023 52,855,300 64,516,100 117,371,400 46,548,200
2022 54,524,000 49,093,700 103,617,700 38,863,000
Staff estimated golf course consumption for test year 2023 (includes reduction in golf
course consumption from its own well): 34,908,869 Gallons.
Annual Electricity Expenses-Pane 11-12
Staff reviewed the power bills provided by the Company to calculate the
annualized power expenses incurred for 2023. See Response to Staff Production Request
No.11. Staff calculated a 2023 annualized electricity expense of$28,798,which is$7,889
more than the Company's test year expense. In its calculations, Staff considered the
weighted average of electricity costper gallon of water produced over a two-year period
(January 2022 —December 2o23)and the estimated golf course water consumption for
2023 test year. Staff analysis of the Company's annualized electricity expense is
summarized in Table No. 4 below.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 27

Table No 4: 202� Annualized Electricityxpense
Year Well HVR Pump Forest Way Total Annual Electricity
Pumps House Water Annual Total Cost/Gallon
Tank Electricity Production Produced
Cost (Gallons) (C =A-B)
(A) (B)
2023 $26,820 $1,655 $2,533 $31,009 117,371,400 $0.000264
2022 $25,443 $1,439 $2,242 $29,124 103,617,700 $0.000281
Weighted average electricity cost/gallon of water produced:
$0.000272. 2023 annualized electricity expenses: $28,798.
Staff accounted for the weighted average electricity cost per gallons of water
produced by weighing it against the total annual electricity cost for respective years
during 2022 —2023 period as shown below:
Weighted average electricity cost/gallon of water produced =
($31,009x$0.000264+$29,124x$0.000281) - ($31,009+$29,124) _ $0.000272.
(Equation No. 1)
According to the Company, the golf course is planned to be disconnected in 2025
as the course will be producing its own water through its well. As a result,the Company's
water system still needs to provide a partial amount of water to the golf course. See
Response to Staff Production Request Nos. 65-67. For the 2023 test year,Staff believes
the golf course is estimated to produce 11,639,331 gallons,which is the difference between
the reported golf course consumption and Staff-calculated consumption (46,548,200 -
34,908,869 =11,639,331 gallons). Staff calculated the actual amount of water produced
by the Company's water system that serves the customers in test year 2023 by
subtracting the expected golf course's production from the Company's total well
production in the same year.
Company's water production less the expected golf course production in test year
2023 = 117,371,400 -11,639,331 =105,732,069 gallons. (Equation No. 2)
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 28

Staff then multiplied the water production amount as calculated in Equation No.
2 with the weighted average electricity cost/gallon of water produced in Equation No. 1
to calculate 2o23 annualized electricity expenses.
2o23 annualized electricity expenses = 105,732,o69 x $0.000272 = $28,798.
(Equation No. 3)
Annual Chemical Expenses
Staff reviewed the past two years (January 2022 —December 2023) of chemical
costs provided by the Company to calculate the annualized chemical expense (liquid
chlorine) incurred for the year 2023. See Response to Staff Production Request No. 15.
According to Staffs calculations, the annualized 2023 chemical expense is $8,557, which
is $52 more than the Company's test year expense.
In its analysis, Staff discovered the average cost of chlorine per gallons of water
in 2023 increased significantly compared to 2022. To calculate a fair and reasonable
annualized chemical expense, Staff performed a weighted average of annual expenses
for the past two years (2022 - 2023) and considered the estimated golf course's water
consumption in 2023. Staffs analysis of 2023 chemical expense is illustrated in Table
No. 5 below.
Table No 1: 202.3 Annualized Chemical Expenses
Year Total Annual Annual Total Chlorine Cost/
Chlorine Cost Production (Gallons) Gallon
(A) (B) Produced
(C =A-- B)
2023 $1o,987 117,371,400 $0.000094
2022 $5,969 103,617,700 $0.000058
Weighted average chlorine cost/gallon of water produced:
$o.000081. 2023 annualized chemical/chlorine expenses: $8,557•
Staff gauged the weighted average chlorine cost per gallons of water produced by
weighing it against the total annual chlorine cost for respective years during 2022 -
2023 period as shown below:
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 29

Weighted average chlorine cost/gallon of water produced =
($1o,987X$0.000094+$5,969x$o.000058) - ($10,987+$5,969) _ $0.000081.
(Equation No. 4)
Staff then multiplied the water production amount as calculated in Equation No.
2 with the weighted average chlorine cost/gallon of water produced in Equation No. 4
to compute 2023 annualized chemical expenses.
2023 annualized chemical expenses = 105,732,069 X $0.000272 = $8,557
(Equation No. 5)
Company Reply
The Company has reviewed Staff s calculations and finds them appropriate,
subject to a final determination of the volume of water that the Golf Course will be
using. Once that has been agreed upon then an update of the Staffs calculations for
Electricity and Chemical expenses will need to be completed.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 30

Staff Comment-Water Testing-Page is
"Water testing requirements follow a nine-year rotation schedule. As has been
the Commission's preferred practice, Staff included an annualized amount to allow
collection of the total amount over the nine-year schedule. Calculation of total testing
costs and the annual adjustment is included in Staffs Attachment G. This adjustment
increases the Company's water testing expense by $1,328 to a total of$1,358•"
Company Renly:
The Company has reviewed the Staff s calculations and finds them appropriate.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 31

Staff Comment-Management Administration &General ("A&G")-PaP-e 14
"Stoneridge included $67,863 in A & G — Labor associated with the management of the
Company. Stoneridge does not have any employees, but instead relies on a staffing contract
with Esprit. Because Esprit is a related party, the prudence of all labor expenses requires
additional scrutiny. Generally, Staff applies a standard of the lower of cost or market as the
basis for all the related party expenses. The only person performing Management A&G labor
for Stoneridge is paid, on average, $3,039 per month,for an annual expense of$36,468. Staff
recommends reducing the Company's Labor —Administrative&General expense by $31,395 to
align with amounts actually paid to the Esprit employee. In addition, the Company included
one payment to the same employee in Contract Services — Professional. Since the total cost of
this employee is already included in Staffs A&G Labor adjustment, Staff recommends this be
removed from rates as well, which reduces Contract Services by $3,168."
Comnanv Reilly:
Staff did not include the Company Accountant in their calculations. This labor category
also covers the Company Accountant who works one 8-hour day per week. $3o/hour with 1.25%
gross up for taxes for 8hours/week. Annual total would be $15,600. We propose reducing
6w.8 only by$15,750 vs $31,395 annually to reflect the accountant's compensation.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 32

Staff Comment-Customer Accounts Labor Expense-Page-la
"Stoneridge included$35,766 in Labor — Customer Accounts for costs associated
with an administrative person who performs billing and payment processing and is the
first response to customer complaints. As with the contract employee discussed in the
A&G Labor section above, this person is not employed by Stoneridge but performs duties
under the staffing contract with Esprit. Staff reviewed documents and discovered that
Esprit paid this person an average of $140o a month, or $16,80o per year. Staff
included an additional 25% increase for payroll taxes for a total of$20,160. However,
this person also performs work for the sewer company which shares an office with the
water company. After discussions with the Company, Staff agrees that about 20% of
this person's time is related to the sewer company, and 80% to the water company.
Therefore, Staff reduced the labor expense by 20% to account for the time spent on
unregulated activities. Staffs adjustment reduces the Company's request by $18,966".
Company Reply:
This position is an hourly position and the hours fluctuate. It is not clear what documents
Staff reviewed to determine that Esprit paid this position an average of $1,40o/month since the
company did not provide this info nor did staff ask us for clarification. This position typically
reports 50-55 hours bi-weekly with 80% to Water and 20% to Sewer at $26/hour. The
employment contract was for 21 hours of weekly support for the water company. Staff included
25% or $6.5o/hour for payroll taxes for a total hourly rate of $32.50. With an average of 52.5
hours biweekly(26per year) @ 80%water equals $35,490 for this position annually.
Furthermore, in the tariff, staff recommends the office hours for Operator reconnections etc. be
expanded from 8 am to 5 pm Mon— Friday.The Tariff also recommends on-call service from 5.01
Pm to 7.59 am Mon thru Friday and weekends. Staff removed funding for our GM's time, and if
the Commission approves these conditions,please advise Staff to put funding back in this category
for after-hours phone coverage.
We propose that this labor expense be increased to $35,490 from $18,966, an
increase of$16,524 per year above the Staffs recommendation or if the Commission
agrees with extended hours per the tariff, revised funding.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 33

Staff Comment Operations &Maint ("O&M") Exense to Actuals-Page-Page 1s
"Stoneridge included $68,355 O&M Expense for a water operator. In 2023, the
Company had a water operator through its staffing contract with Esprit. Stoneridge
now relies on Integrity Water Management for its water operator. Therefore, Staff
recommends removing the O&M expense for a water manager of $68,335 and
increasing Contract Services—Professional by $24,430 to accountfor the amounts paid
to Integrity Water Management."
Company Reply:
The 2023 Base Test Year had both the Water Operator 6oi.1 and an assistant 6oi.2 that
made up its Operations and Maintenance staffing.
In 2023 the resident operator retired and was replaced with an independent Contractor—
Integrity Management—to operate the water plant. His contract includes a base and any
incidental calls, minor repairs, locate etc. See Exhibit I).
Integrity's initial estimate for the monthly contract value was $2,036.A recent review See
Exhibit J) of the 2024 year to date actual Integrity invoices strongly suggests that the average
monthly cost of this contract service is going to be $4,243 monthly or $50,yi6 Annually. The
Company proposes to increase the Staffs increase in annual O&M Expense for contract operators
by $26,486 annually.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS -34

Staff Comments-Tax Preparation Expense-Page-l!
Stoneridge inadvertently recorded a second tax preparation expense, which Staff
recommends be removed. This adjustment decreases Contract Services — Processional
by $875•
Company He
The Company has reviewed this item, and we agree with the IPUC staffs recommendation.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 35

Staff Comments-Misc Expense-Page-is
"Stoneridge included an uncategorized expense to JD Resort of$1,049. In its
response to Production Request No. 43, the Company stated the expense was for interest
on a loan that was later ordered to be classified as equity in Order No. 36084 in Case
No. SWS-W-23-03. Staff recommends removing this expense which reduces
Miscellaneous Expense by $1,049•"
Company Reply:
The Company has reviewed this account and finds this treatment appropriate.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 36

Staff Comments-7B Engineering Expense-Pag-e-lS
"Stoneridge included an expense to 7B Engineering for$5,800. In its response to
Production Request No. 37, the Company stated that this was a sewer expense
inadvertently posted to the books of the water company. Staff recommends that this
expense be removed reducing Contact Services —Professional Expense by $5,800. "
CompanY Rep1Y:
The Company has reviewed this account and finds this treatment appropriate.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 37

Staff Comments-Securities Issuance Application Fee-Pay-e-is
"Stoneridge paid $320 for an application fee for the requested securities issuance Case
No. SWS-W-23-03. Because this expense is not recurring, the Company should not recover this
amount on an annual basis. Therefore, Staff Recommends removing this expense fand reducing
regulatory fee expense by $320."
Company Reply:
The Company has reviewed this account and finds this treatment appropriate.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 38

Staff Comments-Right of Way Lease-Pay-e-16
"As mentioned in the Management Issues section, Stoneridge included a lease
expense totaling $30,233 in 2023 for Right of Way, Water Rights and Easement Leases.
This amount is greater than the $2,000 per month stated in the lease agreement
provided in the response to Production Request No. 39. As stated above, these assets
were considered contributed capital and essentially paid for by customers prior to JD
Resort's acquisition of Stoneridge. It is not reasonable for JD Resort to remove the assets
of Stoneridge and lease them back to the Company at the customers' expense when
customers have previously paid for those assets. Therefore,Staff recommends that these
assets be returned to Stoneridge immediately and the lease agreement be removed from
rates. This adjustment decreases rental expense by $30,233•"
Company Reply:
As discussed under "Management" above, these assets were never owned by the
Company and the Commission has no authority to order Esprit Enterprises, LLC., to
transfer these rights to the Company. Staff also appear to have not read the lease closely,
as they seem to have missed the clause in the PRR. No. 39 response states that the $2,000
base lease from January 2020 shall increase by 8% each year. So, the current 2024 lease
for this bundle of rights is $30,233 annually and the Company requests this amount be
put back in the expenses for this Rate Case.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS -39

Staff Comments-Truck/LTTV Lease-Paue-16
"Stoneridge has a lease contract with Esprit for all its vehicle equipment. During
its audit, Staff reviewed the complete list of equipment and the monthly expense of each
item. Staff believes that much of the leased equipment is not beneficial to customers and
recommends that only the Ford F-15o and Kubota UTV lease expenses should be included
in customer rates.
The Lease contract shows that Stoneridge is paying$600 per month for a backhoe
and $120 per month for a Ford Ranger, plus the costs of licenses,fuel and a yearly
percentage increase. Staff believes that the backhoe should be rented on an as-needed
basis. Additionally, the Company does not have a qualified operator on its staff to
operate the backhoe. The Ford Ranger is not a necessary expense,since there is only one
employee who uses a vehicle, and Staff recommends the lease associated with the F-150
already be included in rates.
Staffs review of the Ford F-15o and the Kubota UTV under the lease agreement
show that these two pieces of equipment would be useful and at least cost to the customer.
This adjustment reduces Rentals — Property & Equipment by $14,663. See Staffs
Attachment H."
Company Reply:
The Ranger is a small boom truck for lifting heavy objects that the Company needs from
time to time.We have operators for the backhoe, and we use it for repair work,location work and
snow removal. Rental of a backhoe would run $340 plus tax per day, removing it from our
equipment is very shortsighted and has the potential to become very costly. See Exhibit K).We
propose putting the Backhoe Lease back into operating expenses for our Test Year as it will allow
significant savings over renting one and having to wait for its delivery vs. having it available on
hand when we need it--especially for snow removal. This will add back $7,200 plus in costs of
licenses, and fuel etc. into expenses each year.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS -40

Staff Comments-Rental of Proper y-age-16
"Staff reviewed the Rental Expense associated with the water company's office
space. The water company shares office space with the sewer company, but records the
entire expense on its books. Staff believes that the monthly rent should be split evenly
between the water company and the sewer company. This adjustment reduces rental
expense by $13,614".
Company Reuly:
Staff were provided with a copy of the office space rental agreement for the
Company. This lease commenced in January 202o and was only for the Company's share
of the rented office space.There are two separate spaces included in the office rental lease.
The primary space is the"Event Center Space".The other smaller space is the Sales Office
where records are stored,the accountant works from, and the conference room is.
Staff is not attentive and precise when reviewing the lease. They assumed the Company
lease was for both the 6o% of the Water Company share and the 40% of the Sewer
Company share. Once again it appears they assumed the lease amount stayed the same
for 4+ years, the lease has an escalator of 8% annually. See Exhibit L for current office
space comp in the area—note this is a flat gross rent with no utilities, other services,
furnishings, etc.
Due to missing the escalator and assuming that the lease was for both water
company and sewer company, Staff concluded that water was taking all of the expense.
The lease amount has always been split 60-40%based upon the relative gross revenues of
the two utilities, and their comparative number of customers. See Exhibit M). The
water company office lease expense for 2023 was $27,228 and all of that goes to the
Company. We propose that the office lease amount increase by $13,614 for the Water
Company for an annual total of$27,228. This is reasonable.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 41

Insurance Expense-Page-17 Insurance
"The Company included $432 in insurance expense in the filing. Upon review of
the insurance,Staff discovered that the Company was included in the umbrella plan that
covered all of the entities owned by Mr.Karupiah. The total cost of this insurance policy
was$29,839•Stoneridge was allocated$7,000 of the total expense. When Staff reviewed
the contract, Staff discovered that much of the insurance policy covered worker's comp
as well as other employee and director related insurance. Stoneridge stated that it
intended to be removed from the policy that covered all of Mr. Karupiah's companies
and instead have its own insurance policy, which would increase the Company's
estimate of insurance expense to $9,000.
Staff does not support either of the proposals, but also believes that the test year
expense of $432 is too low. Reasonable insurance coverage has historically been
considered prudent and recoverable. Staff does not believe that Stoneridge's allocation
of approximately 25% of the total insurance cost is representative of the risk that the
insurance policy is covering. Staff also believes that Stoneridge having its own, more
expensive,policy is not reasonable when it can be included in the umbrella policy of Mr.
Karupiah at a decreased cost. Therefore, Staff proposes splitting the entire insurance
expense of the umbrella policy evenly among the six entities covered under the policy.
This adjustment increases insurance expense by $4,451 to a total of$4,973•"
Company Reuly•
Upon review, the application amount of $432 was for only 1 month. The correct amount
should have been $5,184 ($432*12).
Regarding Worker's Comp, Esprit's employees are covered by the State of Idaho Worker's
Compensation Program which is based upon payroll amounts and are not covered by the existing
insurance policy.
Upon what justification did Staff determine that splitting the Esprit StoneRidge insurance
premium into six equal shares was an equitable solution? Surely, they can distinguish the added
significant risk presented by a Public Water Supplier. Several of the entity names listed in the
Esprit Policy are DBA's and or shell companies that are not active. We have provided Staff a
statement from our Insurance Broker for the Company's insurance coverage of$7,000/year(25%
share of the total Esprit policy premium). In response to a Staff inquiry,we subsequently obtained
a "Stand Alone"Water Company policy coverage estimate of$9,000 annual premium.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 42

Because of the difficulty we have experienced in getting reasonable treatment in Staff
interpretations of our expenses, our reluctance to continue having the Company take advantage
of Esprit's resources without adequate compensation, and our Brokers advice,we are planning to
obtain Insurance Coverage for the water company solely with the most economical "Stand Alone"
insurance policy coverage for the Company we can obtain.
Esprit has recently been informed by their insurance broker that their current insurer is
withdrawing from the market and Esprit will need to obtain coverage from a new provider. With
other ongoing changes in the property and casualty insurance industry, Esprit's broker is
recommending that the Company would be best to establish a separate policy for the Company
going forward. As provided in Discovery, the Company intends to accept the offer of $9,000
annual premium insurance coverage commencing January 1, 2025, and proposes changing our
annual insurance premium expense to $9,000.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 43

Working Capital-Page-17
"Working capital is the amount of money the Company needs to have on hand to
pay its short-term obligations. It is used to bridge utility finances between the time
expenditures are made and revenue is received from ratepayers to cover these costs.
Because it is generally money that is advanced by the Company, it is common to include
working capital in rate base so the Company can earn a return.Staff recommends using
the 1/8th formula method, which equals the sum of total annual operating expenses
divided by eight. The 1/8th method is a common practice for small water utilities without
the capability of performing a more complex analysis.
With this calculation Staff recommends a working capital allowance of$32, 107."
CoMDWy Reply.
The Company has reviewed these calculations and finds them appropriate,but with
updated income/expense ratio.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 44

Return On Equity ("ROE")-Page-18
"Stoneridge proposed a 12% ROE. In the last several rate cases for small water
companies of similar size, the Commission has awarded an ROE. See Case Nos. KHW-
W-23-o1,AWS-W-23-01, MNV-W-19-oi, and GPW-W-17 ol. Staff would recommend a
ROE to be consistent with other small water companies in the state, however, due
to the management issues stated above,Staff believes a reduction in ROE is appropriate
until the Company corrects the issues identified. The Commission has previously
reduced the ROE of a water company for operations and management issues. In Order
No. 30279, Case No. SPL-W-o6-o1, the Commission reduced the ROE from 12% to 6%
until the identified issues in that case were resolved. See Order No. 30279 at 1o.
Additionally, in that Order, the Commission stated once the issues were resolved the
ROE could be reset to 12%.
Staff believes the same treatment is appropriate here. Based on the concerns
stated previously, Staff recommends the Commission apply a too-basis point reduction
to the Company's ROE until these issues are resolved. Therefore, Staff recommends the
Commission approve a so%ROE."
Company Reply:
The Company rejects this Staff proposal because the issues Staff is referring to are not in
fact true as noted in earlier Company Responses. This "treatment" is totally uncalled for and we
propose that the Company's ROE be set at 11% for this case. This is another example of staff
penalizing the company for the company's interpretation of the law for the benefit of the company.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 45

Staff Comments-Cagital Structure-Pate-18
In its Application, the Company stated it has $105,005 in long term debt and
$361,goo in equity,for a capital structure of 22.32% debt, and 77.68% common equity.
See Staffs Attachment L The long-term debt is a state drinking water revolving loan at
2%. Using a 10% ROE and a cost of debt of 2%, Staff recommends an overall rate of
return of 8.21%.
Company Reply:
The Company has reviewed and approves this calculation with the updated additional
equity for 2024 of$194,326 and 11% ROE correction.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 46

Rate Design-Page-18
"In the Application, the Company proposed a uniform percentage increase to the
monthly minimum charge and commodity charge with no major changes in rate design.
Staff supports the proposed rate design albeit using Staffs proposed revenue
requirement. Staffs calculation of revenue at present rates and revenue at proposed
rates is shown in Staffs Attachment F.A comparison of the Company's proposed rates
and Staffs proposed rates is shown in Table No. 6 below.
Table No. 6: Company and Staff Rate Proposals
Meter Size Company Proposal Staff Proposal
(in.) Customer Commodity Customer Commodity
Charge Rate Charge Rate
0.75 $87 $2.94 $29.91 $0.98
1 $154 $2.94 $29.91 $0.98
1.5 $347 $2.94 $119.62 $0.98
2 $616 $2.94 $212.67 $0.98
2.5 $963 $2.94 $332.29 $0.98
3 $1386 $2.94 $478.50 $0.98
4 $2.94 $850.67 $o.98
6 $5546 $2.94 $1913.99 $0.98
To show monthly bill amounts and percentage changes under the different
proposals, with a given level of consumption, Table No. 7 is presented below.
Table No 7 • Comparison of Monthly Bill Amounts and Percentage Increases
Meter Consumption Current Company Proposal Staff Proposal
Size (x1000 Rates
gallons) Percent Percent
(in.) Monthly Bill Monthly Bill Monthly Bill
Increase Increase
0.75 10 $31.90 $116.40 265% $39.71 24%
1 30 $82.14 $242.20 195% $59.31 -28%
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS -47

1.5 50 $135.50 $494.00 265% $168.62 24%
2 70 $225.97 $821.80 264% $281.27
2.5 go $337.77 $1,227.60 263%
3 110 $470.90 $1,709.40 263% $586.30 25%
4 200 $840.67 $3,052.00 263% $1,046.67 25%
6 400 $1,852.00 $6,722.00 263% $2,305.99 25%
Staff evaluated alternative rate design options, including one in which the
percentage increase to commodity charges was larger than the percentage increase to
the monthly minimum charge. This design would shift more revenue recovery to
commodity charges and provide a stronger conservation signal than the uniform
percentage increase. Staff is concerned that this plan could create more revenue
instability for the Company. This is primarily due to the uncertain continuing customer
status of a high consumption customer, the Golflrrigation Pond 6"(Golf Course).Details
surrounding the Golf Course are further discussed below.
The Company and Staff also discussed implementing inverted block tier pricing
for its commodity charge. This design charges a higher commodity rate as
consumption increases and sends stronger conservation signals than a flat commodity
rate. Staff acknowledges the
Company's concern and willingness to send stronger conservation signals to
customers. Staff presently does not support inverted block tier pricing because the
Company does not read meters during winter months and does not have a customer's
specific consumption during these months.
To implement block tiered pricing would require separate winter and summer
rate schedules. However, Staff encourages the Company to explore tiered commodity
rates in a future rate case if it can measure customer consumption on a year-round
basis."
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS -48

Company Reply:
The Company has reviewed the rate design proposed by Staff and intend to wait until Staff
has an opportunity to review the proposed changes from the Company to Revenue and Expenses
to update the proposed prices for service. Currently the Company is proposing a 124.27%increase
in base rate and commodity charges.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 49

Treatment of Golf Course-Page-ao
"The Golf Course service connection provides water to irrigate the Stoneridge
Golf Course and accounts for a large percentage of the Company's water sales. Staff
highlights that the Company and Stoneridge Golf Course share a common owner,Esprit
Enterprises,LLC. Staff performed extensive analysis regarding the commodity rate for
the Golf Course and its consumption of Company water.
Currently, the Golf Course receives a to percent discount on commodity charges.
Staff disagrees with the inclusion of this discounted rate. The discount was established
in Case No. SWS-W-o6-or, per Commission Order 30342. Reasoning for the discount
was based on the concept of interruptible service to the Golf Course. See Case No. SWS-
W-o6-oi, Staff Comments at to and 12. If the Company were to face capacity issues, it
could temporarily stop or interrupt service to the Golf Course.
Staff notes that the Company's application in Case No. SWS-W-o6-ol did not
include a discounted rate for the Golf Course.After reading the Reply Comments filed in
that case, Staff presently believes that the discount was originally included out of
concern that the Golf Course would source its own water and cease being a customer if
its annual cost exceeded$45,000.
Case No. SWS-W-o6-oi Reply Comments at 4.
In its communications with the Company, Staff also notes that the Golf Course
has constructed and begun using its own well to supply a portion of its water needs as
of October 2023. See Response to Staff Production Request Nos. 66-67. As the Golf
Course moves to supplying a larger percentage of its own water, its consumption of the
Company's water will decline. Any benefit the Company derives from interrupting
service to the Golf Course will also decline.
As stated above, the Company indicated the Golf Course's plans to supply a
portion of its own water instead ofpurchasing itfrom the Company. Staff stresses that
consumption changes of a large customer can have large effects on revenue recovery
and rate design.In calculating billing determinants in the case, Staff weighed historical
Golf Course consumption with discovery regarding its own well. Staffs calculation of
Golf Course consumption is explained in detail in the Golf Course Revenue section
above."
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 50

Company Reply:
The Company has responded to Staff s calculation of Golf Course Commodity
Usage,we approve of removing the rate differential.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 51

Treatment of Service Connections with 1-inch meters-Page-21
"Staff believes it is necessary to discuss the monthly minimum customer charge
for customers with 1-inch meters. Under the current tariff, customers with 3/-inch and
1-inch meters pay the same monthly minimum customer charge of$24.00. Typically,
customers with larger meter sizes pay higher monthly minimum customer charges.
Staff investigated past cases of the Company to discover reasoning for an equal monthly
minimum charge for 3/-inch and 1-inch meters.
In its review of Case No. SWS-W-20-01, Staff notes that the Company faced
lower material costs for installing a 1-inch meter compared to a 3/4-inch meter, and that
installing the larger size may be a prudent method of minimizing expenses. See Case No.
SWS-W-20-01, Staff Comments at 3-4. In Commission Order No. 34969, the
Commission stated that customers with 1-inch meters should be charged the same
monthly minimum customer charge as customers with 3/-inch meters. Effectively, the
Company could install a 1-inch meter at its discretion, so long as it charged the same
monthly minimum charge as a 3/-inch meter.
In its Application, the Company proposed to charge 1-inch meter customers a
higher monthly minimum charge than 3/-inch meter customers. See Application Exhibit
No.7, Changes in Rates Table. The Company clarified in its response to Production
Request No. 24 that customers currently connected to 1-inch meters will be billed at the
3/-inch rate indefinitely. Staff supports the Company's stance of continuing to charge
existing 1-inch meter customers the same monthly minimum as 3/-inch meter customers,
as this is consistent with Commission Order No. 34969• Staff disagrees with the
Company introducing a different monthly minimum charge for new 1-inch meter
customers at this time. Allowing a higher monthly minimum charge for these new
customers would put existing 1-inch meter customers at risk of also being charged the
higher monthly minimum amount.
Another issue Staff discovered with regards to 1-inch meter customers is that
there is one specific customer with a 1-inch meter that is being charged a monthly
minimum amount of$82.44—which differs from the Company's current approved rates.
Staff recommends that the Company charge this customer consistent with Commission
Order No. 34969•"
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 52

Company Renly:
Staff s focus over the last few months on the 1"meters in our system has seemingly
become an obsession drawing far more attention that it merits. There are currently only a
handful of customers being billed at a 1"meter rate. However, Staff is aware that in recent
years supply chain factors have resulted in 1" meters being less expensive to buy for new
3/4" meter installs than actual 3/4' meters. The Company chose to install 1" meters and bill
them at the 3/4" residential rate. On our billing systems these accounts all show that they
have a 1" meter but they are billed every month at the 3/4" rate. Staff have had repeated
concerns that somehow these customers will be billed at a 1" rate and none of the
assurances from the Company have seemed to placate Staff.This issue has been addressed
in Commission order No. 34969. In its application the Company proposed a 1"Meter Rate
to allow it to offer this larger service to residences with ADU's with higher demand
requirements as well as larger residential parcels wanting to irrigate above the level of a
normal smaller lot residential customer. Because of their inability to overcome their fear
of a residential customer being charged the wrong rate, Staff recommends not providing
a service that is needed and appropriate in some situations! There is no logical basis for
assuming that the re-introduction of a 1"meter category will lead to residential customers
with 1" meters that are currently being charged at a 3/4" rate, at risk of also being charged
the proposed re-introduced higher 1" monthly rate. Customers are set up in the billing
software and there is almost no reason to review the meter size of a residential customer.
Rather, each month the monthly meter reading is entered into their account and the bill
is generated.A sudden change in their base monthly rate would not escape the customer's
notice. It would take a very specific and meticulous editing of each customer's billing
profile for this to occur, it would not happen accidentally. Allowing the reintroduction of
the separate 1" meter 1" rate category will result in customers who present additional
demand to be provided a serviced priced relative to the demand they place on the system.
Staff has also focused on one 1" customer and their rate of $82.44 and without
much discussion has decided to recommend that the customer be also charged the
scheduled 3/4"base rate. It is not clear if they are talking about a 1" rate or the 3/4" rate. In
any case, this customer's account is quite unique, they are part of a Townhome Plat and
in addition to their residential service there is also water being provided for irrigation
uses. This account was reviewed in recent years by the Company and the HOA/Customer,
and an agreement was reached acceptable to all parties that the monthly base rate would
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 53

be $82.44. This rate has been in place for many years and they (the customer) have no
issues with it nor complaints from any of the parties. The staff s recommendation is rather
overreaching and not appropriate given the history of this account. The Company
recommends this account be left alone and not changed per Staff recommendation.
We continue to request the ability to offer a 1" meter to be charged at a higher rate
than a 3/4 inch meter based upon volumetric capacity.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 54

Happy Valley Rancho Loan Surcharge Reconciliation
We request staff to provide updated accounting as to when the Company needs to cease
collecting surcharge per Exhibit N to align income with the proposed new tariff.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 55

Staff Comments-Tariff-Page-22
"The Company supplemented its application with a proposed tariff. The Company's
supplemental tariff did not match the f led Application. Within the proposed tariff, the Company
included new language and definitions, new recurring rates,and new non-recurring rates.Staff
reviewed the proposed tariff and had many issues with the proposed rates and language
included.During Staffs review, it was apparent there were many duplications of definitions and
language borrowed from other water utilities approved tariffs that were slightly updated.
Through discussions with the Company, the Company agreed to let Staff integrate the proposed
tariff into an updated water utility tariff template to address some of the issues.
One of the issues Staff had concerns with was the Company's office hours and charges
based on those hours. The Company's office hours are lo:oo a.m. to 2:oo p.m.,Monday through
Thursday. Staff believes it is not reasonable to have reconnection charges and call out charges
to be based on the office hours. Standard business hours are 8:oo a.m. to 5:oo p.m., Monday
through Friday and standard after hours are 5:01 p.m. to 7:59 a.m., Monday through Friday
and weekends. Staff recommends the Commission order the Company's tariff use standard
business hours for the reconnection and call out charges.
Below are some of the Company's proposed charges from the Company's tariff and Staffs
review and recommendations.
• Account Transfer Charge — The Company proposed a $65 charge for when there is a
transfer of the ownership or occupancy of a property. Staff disagrees with the proposed
application of this charge as the language is vague. This should be a cost-based charge
and the additional costs incurs to transfer an account is minimal; therefore, Staff does
not recommend the Commission set an account transfer charge.
• Reconnection Charge for 3o days or less—The Company proposed a reconnection charge
for 3o days or less of $5o during office hours and $8o after office hours. Staff
recommends the reconnection charge for 3o days or less remain the same as the currently
approved charge of$18.5o during business hours and$33.5o after business hours. These
charges are comparable with other utilities and are more representative of the cost of an
operator leaving from the Company's local office.
• Reconnection Charge for 31 days or more (MO) — In the Application, the Company
proposed to change the reconnection charge to$5o for all meter sizes during office hours,
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 56

$8o after office hours, and $8o after 31 days. Staff disagrees with the proposed
reconnection charges for disconnections exceeding 3o days.
Disconnections exceeding 3o days are commonly referred to as seasonal
disconnections. The basis for a seasonal reconnection charge is to spread fixed costs more
equitably among all customers.A seasonal customer facing a lower reconnection charge
may be induced to voluntarily disconnect from the system during winter periods of
prolonged vacancy to avoid the monthly minimum charge. This has the effect of shifting
cost recovery to customers who stay connected year-round. A higher seasonal
reconnection charge allows for more equitable recovery of year-round fixed costs
required to operate and maintain the system that all customers benefit from.
Staff reviewed the tariffs of other regulated water utilities that serve resort
communities such as Aspen Creek Water Company and Teton Water and Sewer
Company and notes that seasonal reconnection fees range from three to six months of the
monthly minimum charge.In Case No. SWS-W-02-01, Order No. 291o8, the
Commission authorized a seasonal reconnect fee amounting to slightly more than three
times the monthly minimum customer charge. Order No. 291o8 at 3.
Staff examined the Company's current reconnection charge for disconnections
exceeding 3o days. The present reconnection charge for disconnections exceeding 3o days
is 2.71 times the monthly minimum customer charge. Staff recommends the rate be set at
three times (3x) the monthly minimum customer charge.
• Return Check Charge—proposed tariff included this charge with a rate of$25.According
to Idaho Code 28 22-105, which governs "Checks Dishonored by Nonacceptance or
Nonpayment," a charge may not exceed twenty dollars. Staff recommends the return
check charge be set at$20.
• Late Payment Charge — The Company proposed to include a late Fee of 1o% or $5
minimum on the current month's new charges. Staff compared the fee to several other
tariffs and found the proposed fee to be much higher. Staff recommends the standard
charge of one (1 %)percent monthly applicable to the unpaid balance owning at the time
of the next billing statement. In addition, in a production request, the Company
mistakenly stated that an account is past due after 6o days. They have changed the tariff
language to match the Uniform Customer Relations Rules("UCRR")of 15 days instead of
6o days.
• Certified Mail Charge — The Company proposed to have a $20 fee for certified mail. The
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 57

Company provided no additional information on its need for the charge.Rule 304 of the
UCRR requires notification but does not require notices to be certified. IDAPA
31.21.01.304. Staff does not recommend a charge or a fee for certified mail be set.
• Paper Statement Fee — The Company proposed to include a $10 paper statement fee.
Historically, the Commission has never had a paper statement fee proposed by a
Company. If this fee were to be approved, it would need to be cost based. The Company
would need to show that the savings such a fee would provide to the body of the rate
payers. The costs of printing and mailing statements has not been broken out by the
Company, and the benefits of this extra fee has not been supplied. Therefore, Staff does
not recommend the Commission set a paper statement fee.
• Call Out Charge — The Company proposed a call out charge for the water operator to
inspect/repair the system if the problem was determined to be the Customer's
responsibility for a rate of$5o/hour during office hours and$8o/hour after office hours.
The Company's explanation is not clear as to when this charge would apply and how the
hours applied would be calculated. Staff does not agree with the proposed rate. Staffs
concerns with the Company's limited office hours have been discussed above.
Additionally,Staff does not agree with the per hour rate as the Company's water operator
is not local; this charge was intended to cover the Company's cost for the water operator
o drive to the system, and this charge could be a deterrent for customers to report issues
with the water system. Staff does not recommend a call out charge be set.
• Field Collection Trip Charge — The Company proposed a new field collection trip charge
Of$40. This charge would also need to be cost based, and the Company did not provide
the details of the costs involved for afield collection. The benefits of afield collection
charge are to incent customers to pay their bills on time. Staff recommends no field
collection charge in this case.
• Bulk Water Sold to Contractors Charge— The Company proposed a $too charge for any
contractor needing to fill a water tanker of any kind shall do so at a location designated
by the Company and each truck shall be equipped with an approved and inspected
backflow prevention device as approved by the Company. The Company did not provide
any justification for the proposed rate of$too. Staff does not disagree with this charge;
however, Staff believes the rate is too high. Staff recommends the contractor rent a meter
CDS STONERIDGE UTILITIES, LLUS REPLY TO COMMENTS - 58

(including a backflow device)from the Company to measure usage and charge a meter
rental charge of$26.77(which is comparable to other utilities). Staff also recommends
that all water consumption be billed at the approved Schedule I usage charge.
• Construction Water Charge— The Company proposed a charge for contractors, builders,
or others who wish temporary service from an approved service connection shall apply
to the Company for temporary service. This application may be made in writing, in
person or over the telephone. The Company's proposed rate language is "[t]he requesting
party agrees to pay the minimum monthly rate and commodity charges during time of
use."See Company's Marked-Up Tariff No.5, Schedule No. 5, Sheet 12. Staff supports the
Company's proposal but recommends modified language for the proposed rate that will
help maintain consistent language throughout the tariff. Staff recommends the proposed
rate language read: "The requesting party agrees to pay the approved Schedule 1 metered
water rates including the customer charge for the appropriate meter size and usage
charge for all consumption during the time of use."
Table No. 8 below summarizes Staffs recommendations for the proposed non-recurring
charges.
Company Response Added in column "Company
Revised"
Table No. 8: Non-Recurring Charges
Proposed Charges Company Company Revised
Account Transfer $65 $
Charge
Account Initiation $ o $ o
Charge
Out of Cycle Meter $ o $ o
Read
Charge
Reconnection Charge $5o during office hours $18.5o during business
3o days or less $8o after office hours hours
$33.5o after business hours
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 59

Reconnection Charge $5o during office hours 7 times the monthly
31 days or more $8o after office hours customer charge
Return Check Charge $25 $20
Late Payment Charge 10% or $5 minimum 1 %per month
Certified Mail Charge $20 $ 0
Paper Statement Fee $10 $ 0
Call Out Charge $5o/hour during office $ 5o/hour during office
hours hours
$8o/hour after office $$0/hour after office hours
hours
Field Collection Trip $ 40 $40
Charge
Bulk Water Sold to $100 $26-77 meter rental charge
Contractors Charge and consumption billed a
Schedule 1 usage charge
Construction Water Minimum monthly rate Schedule 1 minimum
Charge and commodity charges monthly rate and
during time of use. commodity charges during
time of use.
Although it is not standard practice for Staff to propose a tariff, Staff believes it is in the
best interest of the customers and the Company. Staffs proposed tariff includes portions of the
Company's proposed tariff, but also is inclusive of all of Staffs recommendations. Staffs
proposed tariff is included as Staffs Attachment J. Staff recommends the Commission order the
Company to submit a compliance filing with Staffs proposed tariff with the approved rates.
Compliance with Order No. 34391 (Case No. SWS-W-18-01)
As part of the conditions in the approval of JD Resort to purchase the Company, the
Commission ordered the Company to comply with the following items:
1. File quarterly reports detailing customer complaints and how they were resolved
along with all non-recurring charges;
2. File balance sheets and income statement every quarter; and
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 60

3. File monthly reports showing an account balance of at least$50,00 or a line of credit
of at least$250,000.
Initially the Company was very slow in filing the quarterly reports. However, since the
Commission order was issued, the Company has filed all required monthly reports on time.
Staff believes the reporting requirements in Order No. 34391 should be discontinued.
The reports provided value after the initial acquisition to ensure the Company was viable as a
regulated utility, but the value of the reports has diminished.
Company Reply
The Company accepted discontinuing the reporting requirements.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 61

STAFF RECOMMENDATION
Staff recommends the Commission:
• Approve a revenue requirement of $292,788, for a 27•0 increase. This revenue
requirement is calculated with a rate base of$264,251 and an ROE of 1o%,with an overall
rate of return of 8.21 %;
• Direct the Company submit its updated Facility Plan by October 30, 2025, or prior to
filing its next general rate case, whichever comes first;
• Order Esprit to transfer all assets included in the original purchase of Stoneridge, and
any asset fundamental to providing service to customers, back to Stoneridge
immediately;
• Order the Company to discontinue the discounted commodity charge for The Golf Course,
and bill at the approved tariff rates;
• Order the Company's tariff use standard business hours for the reconnection and call out
charges;
• Approve the non-recurring charges in Table No. 8;
• Order the Company to submit a compliance filing with Staffs proposed tariff, in
Staffs Attachment J, with the approved rates; and
• Discontinue the reporting requirements in Order No. 34391•"
Company Rej2ly to Staff Recommendations:
• Approve a revenue requirement of$477,193, for a 124.27•o increase. This
revenue requirement is calculated with a rate base of$282,549 and an ROE
of 11%, with an overall rate of return of 11%;
• Direct the Company submit its updated Facility Plan by December 30, 2030;
• Order the Company to discontinue the discounted commodity charge for The
Golf Course, and bill at the approved tariff rates;
• Order the Company's tariff use standard business hours for the reconnection
and call out charges;
• Approve the non-recurring charges in Table No. 8 as Company revised;
• Order the Company to submit a compliance filing with Staffs proposed tariff,
in Staffs Attachment J, with the approved rates; and
• Discontinue the reporting requirements in Order No. 34391.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 62

DATED this 30th day of October 2024.
PISKEL YAHNE KOVARIK, PLLC
i
JASON T. PISKEL
Attorney for CDS StoneRidge Utilities LLC
Company Verification:
The undersigned declares under penalty of perjury pursuant to the law of the State of Idaho
that the foregoing is true and correct.
CDS STONERIDGE UTILITIES. LLC
Its: Manager
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 63

EXHIBITS•
Exhibit A: Table Showing 2007-2024 CPI Increase
Year CPt lomue ad` sted Base Rate CNAdjusted Rate
2007 2.85 0.0285 $ 24.00 $ 2468
2008 3.86 00386 $ 24.68 $ 25.63
2009 -0.36 -0.0036 $ 25.63 $ 25.54
2010 1.64 0.0164 $ 2S.54 25.96
2011 3.16 00316 $ 2S.96 $ 26.78
20121 2.07 0.0207 S 26.78 27.34
2013 1.46 0.0146 $ 27.34 $ 27.73
2014 1.62 0.0162 $ 27.73 $ 28.18
2015 0.12 00012 $ 28.18 S 2822
2016 2.13 0.0213 $ 2822 $ 26.62
2017 2.11 0.0212 $ 29.82 $ 29A3
2018 2.44 0.0244 S 29AS $ 30.16
2019 1.81 0.0181 S 30.15 $ 30.60
2020 123 0.0123 S 30.69 $ 31.07
2021 1.36 0.0136 $ 31.07 $ 31A9
2072 4.70 0.047 $ 31.49 $ 32.97
2023 8.00 0.08 S 32.97 $ 35.61
2024 8.40 0.034 S 35.61 $ 36.82 1 49%Change
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 64

Exhibit B: 2oi6 CDS StoneRidge Utilities LLC Federal Tax Return
Ewan-m-:2olej CM STMER= UTILIT Y ***8633
Analysis of Not k!pW.m(1-ma)
r SOMIJO I( Wv-n I brtiLl rq,f t v -; Nr Y"41"IA K 1%$12 Pn* 4is 1 � 28�05
I.alwf orwr'vl-r NL11%'KA1JW
2 A%#pw vj m""t (40 110-c'um! .1 1 1
to
A"WS
Sch@dLde L 511104ce Sh"IS Per E-4 of ynw
A"81� JAI go) lcl
I 503 ce 9
2m ta*n0w.ww mrs'" 20,102 38,790
m fiom"701 1w Jim Cr4m 204102 796
3 Irwfw"
0 Vs, Rwo-m--f vv;#r-,ne
I omrr*- I - -
See Stmt 4 2,236
To Lmm t orlun V pe-wrt vei M- la pwtw I
b lkg^.0.8a W14 fm*AM OW&
Hy.
sa EW d"05 WV CWV 04UP020-1 ASWU 1 2,151,188
b I &awrt-utw cewmmx .470,060 1 110,0:6 381.1774
US L%7-bgu4t b:m-,
b w,.awwrowlam
III Ak;prec Y a
12m esa q6m swab(mmarimbe wM
b U"A"wnjm&$wrtgwmj
113, J,-t-
114 11fa'%&l d wm
# " #9 .9G1 423,999
Uwme&are G&OW
IS #Ji-U-&IA'.4�00 795,027 708,229
IS Mw*p--cfts bras mVdk v wa Vm I
17 See Stmt 5
284,9,97 264,094
-589,347 5�6A,2 7 2
22 Tc4b otitei wv awt*' W 9=9 9
SctwdLA*)tit-1 Reconatation of kw-mm(Lem)per Books WAh IrZarra-(140114) pw Raturn
Now 1tv Twom,4hp ffwi he fmmv--W-1-111-kn-gnt-(--WN INK rftt-,ekc.-11
1 Net--tare Wnl)pw 1:0100I. 28,0751s mw-t,rrwm—,rr -rmc-ri-ra rw
2 -we MAMV sved.#2 K,w"1.2.111: tr"i'Temm K el-1 wft-11 Vi
S.$1 V k-;. 10.et I fa"comw an 1-tw-WS
bxIm tw yew
3 cortAr"MUNI 91 so*&"a Own I
4 1 *r 6XIL rm y6a X: Mtn
b —4K aid
5 AAO
ttm--r 4 2
5 ,
M-2 AnatMis*(,P*
c-
2 GWrAi GD-Irtim". & Saw b itvp-y
6 prooeft
3 Nir Prow.1%ml pw m-t7 — 28.075
4 Mw
Add Inoa 6 we I
-56;,272,% 272
LAO
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS 65

Exhibit C: Purchase & Sale Agreement Bridge Partners to Esprit Enterprise, LLC
instrument p 931247
t 1 ?: 2Ct$U 39.53 PR.'
When Rer=ded,Taal ro.
Dennis K- Pock, Fsq.
POOLE&ASSOCIATES,L.C.
45.4=3 .gouth 700 East, Suitc 200
Sul(Lakc City, Utah 847 07
. ~pace aisavc fat Cann'v Recoc.itr't;Use
1'NgCj-I_� 1.1), NOS_ tiro F%hihit •-B"
SPECIAL WAR ANTY 1)F F 1)
C I)S S*1()N E.RI D(;h:%Sti(1('I-%1 ES LAN 1),LL(.,a U01ah limited liability company.01'l:1 East
Sege Lily Ihive,Suited!{).Sanely_IJLah 84070,GRANTOlt,hcreby conveys and specially wanauts
to ESPRIT FNITE;RFRISESq.1.11% 'dahu irrzitcd liability company,GRAN rEFwhose address
is 17173 171. Pier Road,Bayview, Idaho 83803
For the sum of TEN DOI LAR'S and other Vood and valuable consideration,the fallowing,described
real property, County of Bott;icr- 10-wit.
;SEE LEC:AI. DESCRIPTION MARKED Exiiiar SA&" ATTACKED HER1:.;TO AND
INCORPORATED ItERE1N BY THIS 1kEFERFNCF.
UBJE(T TO 4uc�and asscssrnents to l ne:year 1018 and all stibsecluent y=%.:aeLtl t1 e�'itlt ally
and at'.exi.sting easements,ngiiis or way,rc.-se-mnt ion )restrictions and tern,-e4 rt,
an}existing tenancies,to all zoning laws and anlmanc:esz a,td m any static of facts an art orate:;c,r►c
or inspection of the premises mould show.
This umvev-snca: shall include any and all appurtcuanct.-s. tenrmentc, hereditaments. rcver.iors.
rcmaindc7 s,rirscmrntr,nelrts of way and water rigW>r a.-tywt sc appertauung to the prolk l:.
described,
i he C,ratttt)r covenants io the Grantce that(irunto, 14 the owncr in fee simple of said pietaist:s,that
the premises are-free from encumbrances crated or st,f)`ered by the Grantor,cxc t.-pns;"hose as may
be herein set forth,and cxccepting ttose of record,and-,hat Orzntor will warrant and defMd tlte sartle
from all lawful claims.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 66

Exhibit D: IDWR Water Right Reports (1/9)
Water Right Report : 95-16411( Decreed/Active)
Water'+Right owners
0~Ty" P"W A"f0*1 city state PmW code
( �or�i}wAMr FSPR1T P4 7F1tP1t 5F5 L,f PD FMX 7?;i RAW FW Irl Riga Q7iD
Cripinr Owner STQI:;R XT WATER CO PO E,3X 298 c,041 aRp ID 8301114
Water Right Status
Pnorq aate:44r3r910
Bases:Maned
Water Source
soum SgwceQ"lll!im Tr utary 'IaWtM QuelKirr
&AWHARDCRzFA CAKH.ARDLAlKF
Points Of Diversion(Locati01T)
soufto Towm%hip Is ig- Sookm 4vvt.Lot QQQ QQ Q Cftkftty Ok raae.TAW
AW14AW)CRFTK 54f, 05W 20 0 Sf Nf Fkm9 "dFv,
81AW"ARn CAFEK 5414 05W 20 0 5f "m WNNER
W.etet LIM
tenel<dW Um Fmm Yo covatIhm Raft Volumst
-,RC-+WN 04?31 -IM +i-'%BCrS 65?:09AFA
NiMAT93NS1C]P" A1101 'mi '350.1AFA
IRFWAT,34d FROM S1IARAGF W1 It /01 �15 00 A ZA
TOTAL 419 f—�5 to TOT A.FA
Plam of use
Pi;ace of We legal Descriptio4.IRRIGATION (BONNER county)
w 10 s•vies 5varch
Tvrwrffrip Pmwe secom Lvt QQQ aQ Q Aa"
54A oqw 19 IVL SF SA
54M abw "'9 U 5E 5U
541i a4.w 20 Sue iWV 2.1.0
54N 0$w a 3t N4!' 44,0
:,4N ti SW iso
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 67

Exhibit D: IDWR Water Right Reports Cont. (2/9)
iurri i1F rdtni qw%( 1w1w tit nsrt�
a,h i:s'�d 'ralf svi 9ti.C1
s�1PJ Clswt •Yj 'M t,C
AN 2 Sw 1^sc
Osw 20 Sw st 2.90
05A, 2u sr K AD
trr gati n T"als
10*1 40..es AX a unit
•'�r0;1
Corditions
CO& cmd"a
r '0 't',z porua ormn is s„t m to :m of"he*F gut«or�or-.fla
.,rSadrrl n49r2tILVj f 2.�0. .3 M 'r�t"-4:e`s rnwi�:- i13'lfrlt� � rCklati'+��tY4tLc-it afar .►bftu Y
inter tNn Irg,,or'u.ry QAi oeaj itfoP,s"L`1eb ,'r.0. S.` It or 4,71 4"!tI V.Idaho Codc
"i-•:r:1ht as a split 4'071 fr'rr-f r t 5!t 9tr•.r:4
Date$ Other Information
Irv! • .
tieveir. ..
lki rrit"A�c:sl Due,Datc : ►►,I, Max FUto- r Ac'rm'0
ce Me-vo�, - t,�A 10
:
P,f rrit Apar+oaa Cirm.
T_.rr"I vr r'ic'r 0-9t-•
ki.vrgrrw. Lher"noMyOwls: Dom*Mit-rbdant.
1 r • r . i Two- 5�.aen NO,Ir.10 er Ww u '
�A�3�icnurr•r�s�:rr+od G�Lr: 5n•nn salt,tnrzrr�s
M ,rgaistal False
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 68

Exhibit D: IDWR Water Right Reports Cont. (3/9)
_.. . .,..:i RECEIVED
It&I't.9t
MPAMMWOF
WATM FVD0~fi
s„,�•.. trg+r t;s -lttl c. e..l l... out tole tc,t. C; OpLetelY and •all
RaLt-ge. :hta Carl- fcv,r ttv_ 1"M by tits "oallne fate ptlttrtad bola. 11 )au rant 1trt/14 t- [hAnge )-ur
r<{iHwe4a:ltc t }t •1 -m t.p lat :tit► kwo tl►at ym aq.fee with lto r--amongst son
TOM pjA=L:.TjK ION jXTtja=KV A of 'J1 XWLY IIt t Ittwteh SO. Z811
oftel rISM aiuntrT
r.Tracy TDult uAlvit tM
IV ow aid
E►iAM"AND 1G $3804
Tvtv&.rn^ KrirMrt 1nt►a)::I10
t Pp&r.r:t» rho portran of tM pn-1 , o4 tueooradaLton I.W4 rc,::li yT.t daugrw Ie.e�4.
trtrzority -Sate period of Use. :
L0ersadr ttte clutrl.E 1'4or+ wzstt to mule ir. itfa yropoaed toco+sundrllcta:
ct•-r a brael a-• ! n .-In am Lr vby yeu dielire* +elh tl.el.t W(Tt{it,sc
.04 I A4RCi w t t -R :rc ",04 -aatusanditticai 000 Chun seed to $t• "do.
Please pt 1 wt Vail .• / 1 _.e ft/t�
Itr-0 tol-ittnrl G6elt;r., 1601. 18 it IkL rTr. 1D ^-DKW. L ALXNK ID /3eI4-114J. 12101 142 '90D
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 69

Exhibit D: IDWR Water Right Reports Cont. (4/9)
Water Might Report: 95.9573( Decreed/Active)
Water might Owners
oM.w1�w Now l Cky suft ftew
CunentOwm ESMEWERPRISESUC C0110)( ?D RAYVIEW ID 838034M
06gr 10wner DOtAN.COROON qu%Wi0*AfkA ID 8"34
00o-41 Ownr dt,'1RICK 6P Jz
Pam•"Ow w- S" IENDGE WATER CO PORGWAA Da AONCAMB IO W04
wrtef Rtht Smus
PiomyDme.1211U' M
Boi a Deveed
?Vif~Source
S*um Sawn grs1mw Trwwwy '!<ribvbwy 1"t
&AWHARD CREEK IS•ANCHARD I AXF
Points Of Dtverrsion(Location)
BLANCOAgD CRUK a4N OSw i9 0 51 Nf NONNER
Water U%fa
RELRFATOY STORAU 01)01 52131 3%JDO AFA
TOTAL 3900 AFA
Ptaars of V"
Plate of Use Legal Description:RECREATION'STORAGE(BONNER t;ounty)
I*Wmmp Rrnve /Octl" tilt QQQ QQ Q
54N LAW 19 Sw NE
54N asw 19 st P.
"N 05w 19 w 5F
S4N 05W `9 NAY 5E
idyl DSet' 19 Sw SF
SAN 05w 19 sf SE
y4N 000 .i►1 sw 5w
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 70

Exhibit D: IDWR Water Right Reports Cont. (g/g)
fewf "w man" !Kuen ikoa mkiv u 4l til rP!
Conditions
Gods Gordtlow
Ll This venal decree s.ib*1 to such general prvv.ior%ecesury fut the f��ut��;a�t t�to r►gnts Of Mt the
e ic'rt ad-aiiistw iw*10t „viper-rs--Rs as wary bt' ini time no
Imer thn*, ervv*f a f no's*vAic poem. +SK l:wo'32-"l4'71f lc$aft4sa tsrt►
CAS Wgrrrt ird ise pum.w,, l+v Section 42.425.twd* Cam.
Dines 00wr Inform2tiorl
k 60"t"d weft SIMB at fsaafa. .
_secreed Wte Wetr District Nur**w %D
Pofmit Prow Duo Dage Ganenc Ma. Rat*Rf Acre :0
Permit Prfxel Made Nte: rwrie nt 41ocr W*jiw aw Acre •G
Pofmit Appr'ovoid Dato Coru Case sli mbor;
Prrmit Mofawirm Cvprfrtivn Dote DKrwr Ptmvfiff
Enlargmiem Use Morny Dana Decree Defenaart
f*+etgemrnt Su'Idte P•ior'y r>etq- Swan Filk Trust a# Nantn,s:
Applocabon Race-led Cate: Swan Falls Dtsmsied
Pre feo Dr rdf'r,•Nte D;F Act Numb+r .
Cary het Numimr:
btt.9t.on Mar, Falw
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 71

Exhibit D: IDWR Water Right Reports Cont. (6/9)
'water Right Report 95-95$7( Decreed,/Active)
Water Right Owpers
t7wlw Ty/* Nun AI dmo Idly shale fWatat tads
Cwrr rt Oww ESPFM ENTERPRISES LLG PO BODE M BAMEW ID "001.0"0
C 1gk1W Dons* S ONFRIOG=WATER Ci7 PO BM'4B B't AWHARD 63Il64
Water Right Staum
Nori y V.e 4120972
soil, Decrcecl
Rims:Adiwe
Water Source
sou"* swo"00~ TMA"►]r TelbutW#Quel rm"
GRWNDWAIR
Points Of Diversion(Wcatiort)
Hearts Trip . .3e06ml "Vt.Lot 400 t?Q Q CowV
CAA ID WAL A UN 05w 20 0 W01 5W Bt')WN
6ACO..'AD WATM WA 0!'w 20 0 NW SW BONf+IA
GV V WATFR r,4k 05W 20 0 KW SW W"JER
Water Uses
0*m0.dA U1 w from To DUrrrAon K&W 1Aflrnm
t,P AK�')M 0%9 12/31 1"C1'S W 60 AFA
TDTAL 109 CFS W IW AFA
Places of Use
T°ts%%Vw wight Olin a 1.Z A Pure ul Use EY
Conditions
Cl a TfNs pAMS,dwr a is Qm)wt w n uh gww s>wa:°unn&wtratary fur the JOrti6on of tree rights or for the
otlrucrrt sdnwa radon at ttv�Katas ngna as rrsaar bt a amat®tr cwwmined by the Court at;mid in title no
later than dm entry of a final,Inroad orcvx.Swion 47 `412�61 Idam Lode.
'24 Plats d ase n a4tt'tri tttr servlcr 8rsa o1 thit Scansr t8go tdNacer Ctfrtttsany drstrsruMonI as provided bo•under
kiaho tarn.
C04 "hr,mWes eecorrctlahed dw+vr^R purome u9 use pu"war t to Staid°42-147k,Who Coc ,
C4I5 Ri4ht.rat Wes accor-yl r'.ry plat,-or use pim a mt to Section 47-1475,idwo Coo
706 To",axrenr nPfoswy Fnr b--.weo points Of ir.of-a`dm to grow,4 waist,and batwaon porxs cm
ft°.0f4otrl tr. u's%4"}woe.0ndhyM' 4ulvf4iy t°,-°Iw"1�4 fur14H frv.+rlfe�. t�r�a.Ir►G SMak�°'rlgf tlrtt dNarto:1 u
this re t°I °,•vry Stonerirkr %ys - Cvrrt+"-y A-'I Nos 1 • L1 2 lotted ivy TTi4tn,WSW,M NNW
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS — 72

Exhibit D: IDWR Water Right Reports Cont. (7/9)
Dates Other linformati on
u ce ned 0w: 9.010 of F*dw'w
(3r(r"d ow t+l8.M19 Nate.Uistna Number .'r6D
Parrot Paoi Due Date: Grq,enc Md•R, o Pw A is .G
Perfr+il NIX)f Mode DOW Generc Max WAyne cef krr.-
Pem A Approved Date� Civil Case Nv"hot
Pe"k Wfrrwfr.•iarr fv;n±pficr `aif. Decree Piantlff
Erlwv-cf-' Use Hro'Ity oat 0Kme Deferdom
rr��•q,,Ys- 1hpa se d�ric3c�ty Swan Fels IruV.or Naf tat
AFs► • .)n Retev cd 3_ Swim iaft p►4M*%4d
Carr At'. Nv-nt)of
104ignbor,Flan: False
IDA-43 r.fPAIMAFNT nF WATER RFSOUKFS
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 73

Exhibit D: IDWR Water Right Reports Cont. (8/9)
Water Right Report : 95-10454( Ucense/Active)
Water Right owrw,s
ovwwTyfr. Nance Add" city sMtt tprata�ltotl.
Curront Ownar ESM—ENMROsIISES UL mu HO.9 770 SAY( Fed• tp 83803-077,1
griprtil owg- COS S70WROGF U:tLMES tiC 3G4 S j0Njg,o;Git'itD BLANC, 4AA ITT 03 04.9542
Water Might Status
primoDee 5r291Avt
Uis:LiOer�+e
Ststus-Actim
Mter Source
Swrm iowrce Qw~ Yrfircrwy T.t'bu4ary QwNtt m
GROUND WA'F8
Points Of tDivemion(Location)
So"" Towmi p RW4* SKbOn csovlt trot QQG GQ 4 OouNft ►TM*
GROUNDWATFR =-N n5w 213 a NW SW BONNER
CAtO-�VDWATFR r44 nsw 213 0 lvw sW bot"&-:
Wator Was
semeww Qx IFrwn 19 06WAP r not valvM0
WAICzOAl 01l4* 12131 ill US 35tt 70 AFA
Tt7[AL 121 CFS 35 ?a 0646
Plasma of tha
This vmter ri"bets a rrt t' or
conditions
Cash CAmdtiam
180 AnW ganaralty dvtuv,rl tt,b�4,ioiop arse Jar this water ngnt at the time trr this mpprwd is alo hed to this
dWinlent too ig VitM-0 F5—P0sai
f•Oe lirm failowirg rirots are dwned tnyo aaF pol^tt(>)of direr,on 6WAbad aaeaau:95 95er a 95 10494,
128 VWce of me rtl lr the axis serwe�d by the PVnR-"ter strf+nty fY f is ID t D9=9 of COS Stonar, 9z tlliltuas.
Cs w
LL(,Tit.-P4Kt at use-•gwwalry kwAed with'-+Seetioro io-sA J%7R-Sq Tawn%NP UN Rwgft OSW and
Sectons 24-25 rawrrxnin Snh,RarQe 06W
)c35 Rights 93-15RI&"-'0454*4*r cnmrr,"chat,not srttaxt a total ra%W-sion-Mee 310 cft and a tool anruai
mst>Trnum C vt+�iart va!�o►S68£et Pt trio+tic•iJ�naarbaatr.
01 Lr After speu:ix m6firatryn by tF,�L Depvtrne oL th.right aohtar thab rifat9 a s,tr k^*±tsunnng tfertce tx steal,
orter into e"eyrev apt wstvi the`>eP-tr"ent 1v+xsee woof #mid[to ttstaumrx the m'3unt of waur mtmf!sil
ono*mil anrualle,relxr•t the rrftxrraWn to the Np ft" 1
004 TFis t+�t+t ttt}C nor gre�r�r r�yht of as 9y nr c�ocPr� :"arrntt ttta land O�ar►htro'
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 74

Exhibit D: IDWR Water Right Reports Cont. (9/9)
Data Othef Information
Lcenw4 or,r, it*fit' sra;M c+, Fpeef*
rto:'. . Dole Watt Vtttm-t lur t it
perm-proof b.- ' �s+9t1e. °, ,del. ri'm see A401 „ A fa:Q
Aennot Aplr„%Td Ore Cidilcom,
Pktmo Witatorium fwi-aliew DWt Die Pia-eaft
Erlargme,n Use Pronty Date: DecMe (Wevice,V
F,d.rryrenr-it Stelvtp Pnority Doe Sewn FAs trust or Norv,. 5t:
Appicaet►an licccv,ed Dale 412412ON Swan iay Dv-wm4
Prol.0 rkdalif,N nine 6N?'J39 VLk Art Numbef:
t;'P� Paz,- NA.r^lbV,
1- inuor F4n: a-,se
ID46- - DI:W-NIF IT MWA-EI►KWURCII-
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 75

Exhibit E: Idaho Secretary of State Business Name Search Reports (1/2)
( Login
Business Search
smt**st"with your entered key"rd,
STONERIDGE WATER CO
AW;MM SWO
No results were found for "STONERIDGE WATER CO"
Try your search again with different filters or a different search
term.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 76

Exhibit E: I�d[aho Secretary of State Business Name Search Reports Cont. (2/2)
f i/ I4 �SI�'fl
BLISlness Search
Sears:;st�.sin+�r�tt►�airre»tered IEe�+rrarid.
r
STONERIDOE UTILITY COMPANY
fibs+a:�:
Farad info Stmus Faint date Agent
�a�fvrFarl`+tttr�i 101161 "2 NO
AGENT
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 77

Exhibit F: Ground,Water Rights, Equipment&Easement Lease (i/6)
ORIGINAL Page I of
GROUND, WA TER RIGHM EQUIPMENT, .-I ND EASEMENT LEASE
This Equipment Lease(this"Lease")is made effective as of January 1,2020,between Esprit
Enterprises,LLC(the"Lessor"),364,Blanchard, Idaho 83804,and CDS Stonelkidge utilities,
LLC-Water(the"L.essW), 12 Holiday Loop, Blanchard, Idaho 93804,and states the agreement
of the parties as follows:
PROPERTY AND RIGHTS SVBJFCT TO IXASE,The Lessor shall lease the ground.water
rights and easements listed on the attached Exhibit"A". The Lessor shalt also tease the
equipment listed on the attached Fxhibit"B"_
PAYMENT TERMS.The Lessee shall make monthly payments of$2,000.00 for the items
listed on Exhibit A and monthly payments of$1,500.00 for the items listed on Exhibit B.
Payments shall be due on the first day of each month,with the first payment due on I/l/2020.
The lease payments shall be due whether or not the Lessee has received notice of a payment due.
Both the monthly payments shall increase 8%annually on January I each year(beginning
January 1.2021)of the lease.unless mutually agreed upon otherwise by both landlord and
tenant
NON-SU FFICTENT FUNDS.The Lessee shall be charged$30.0D for each check that is
returned to the Lessor for lack of sufficient funds.
LEASE TCRM,This lease shall begin on the above effective date and shall terminate on
December 31, 2025,unless otherwise terminated in a manner consistent with the terms of this
Lease-
OPTION TO RENEW If the Lessee is not in default upon the expiration of this lease,the
Lessee shall have the option to renew this Lease for a similar term on such terms as the parties
may agree at the time of such renewal.
OPTION TO PURCRASE.If the Lessee is not in default under this Lease,the Lessee shall
have the first right of refusal option to purchase the real estate,and water rights at the end of the
lease term for a price agreed upon by both parties.
LIABILITY AND INDEMNITY.Liability for injury,disability,and death of workers and
other persons caused by operating,handling,or maintaining the ground and/or water right during,
the term of this Lease is the obligation of"the Lessee,and the Lessee shall indemnify and hold the
Lessor harmless from and against all such liability Lessee shall maintain liability insurance of at
least$1.000,000,00.
Ground, Water Rights,Equipment and Easement lease
TK
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 78

Exhibit F: Ground,Water Rights, Equipment&Easement Lease (2/6)
ORIGINAL Page 2 of b
CASUALTY INSURANCE.The Lessor shall be responsible for maintaining casualty insurance
with respect to lass or damage of the ground and/or water right
DEFAULT.The occurrence of any of the following shall constitute a defaultt under this Lease
A.The failure to maize the required payment under this Lease when due.
R.The violation of any other provision or requirement that is not,corrected within 180
day(s)after written notice of the violation is given.
C. The insolvency or bankruptcy of Lessees
D.The subjection of any oflxssee's property to any levy, seizure,assignment, application
or sale for or by any creditor or government agency.
RIGHTS ON DEFAULT.In addition to any other rights afforded the Lessor by law,if the
Lessee is in default under this Lease:,without notice to or demand on the Less„the Lessor may
take possession of the ground and water right as provided by law,deduct the Corte of recovery
(including attorney fees and legal costs).repair,and related costs, and hold the Lessee
responsible for any deficiency, The rights and remedies of the Lessor provided by law and this
Agreement shall be cumulative in nature.The Lessor shall be obligated to re-lease the ground
and/or water right,or otherwise mitigate the damages from the default.only as required by law.
NOTICE.All notices required or permitted under this Lease shall be deemed delivered when
delivered in person or by mail,postage prepaid,addressed to the appropriate party at the address
shown for that party at the beginning of this Lease.
ASSIGNMENT.The Lessee shall not assign or sublet any interest in this lease or the ground
and/or water right or permit the ground or water right to be used by anyone other than the i,essee
or Lessee's employees,without Lewes prior written consent.Lessor agrees that Lessee may
share the equipment with Blanchard Utility Services, an entity owned by Lessor.
ENTIRE AGREEMENT AND MODIFICATION.This lease constitutes the entire agreement
between the parties No modification or amendment of this I.e m shall be effective unless in
writing and signed by both parties. This Lease replaces any and all prior agreements between the
parties.
GOVERNING LAW.This Lease shall be construed in accordance with the laws of the State of
Idaho.
SEVERAlBIL1TY.If any portion of this Lease shall be held to be invalid or unenforceable for
any reasmt,the remaining pro%isions shall continue to be valid and enforceable If a court finds
Ground,Water Rights, Equipment and Easement Lease
iK
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 79

Exhibit F: Ground,Water Rights, Equipment&Easement Lease (3/6)
ORIGINAL Page of
that any provision of this Lease is invalid or unenforceable, but that by limiting such provision,it
will become valid and enforceable, then such provision shall be deemed to be written, construed,
and enforced as so limited.
WAIVER.The failure of either party to enforce any provision of this Lease shall not be
construed as a waiver or limitation of that party's right to subsequently enforce and compel strict
compliance with every provision of this Lease.
CERTIFJCATION, Lence certifies that the application,statements,trade references, and
financial reports submitted to Lessor are true and correct and any material misrepresentation will
constitute default under this Lease.
IItSPUTE RESOLUTION.1,he parties will attempt to resolve any dispute arising out of or
Mating to this Agreement through friendly negotiations amongst the parties. If the matter is not
resolved by negotiation,the parties will resolve the dispute using the Alternative Dispute
Resolution(ADR)procedure below.
Any controversies or disputes arising out of or relating to this Agrement will be submitted to
mediation in accordance with any statutory rules of mediation. If mediation does not successfully
resolve the dispute,the parties may proceed to seek an alternative form of resolution in
accordance with any other rights and remedies afforded to them by law_
SIGNATORIES.This Lease shall be signed on behalf of Esprit Enterprises, LLC by Teresa
Karupiah.Member,and on behalf of CDS StaneRidge Utilities,LLC-Water by Chan Kerupiah,
Member, and shall be effective as of the date first above written
Ground, g Water Rights,Equipment and Easement Lease
/'K
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 8o

Exhibit F: Ground,Water Rights, Equipment&Easement Lease (4/6)
ORIGINAL Page 4 of 6
LESSOR:
> y _ Gt - , < <_ — Data
Teresa Karupiah
Esprit Enterprises,LLC Member
LESSEE:
sy:�.
Date:
Chan KarupiW
CDS StoneRidge Utilities, LLC Member
Ground, Water Rights,Equipment and Easement Lease
TK� e
Gam''
CK - -
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 81

Exhibit F: Ground, Water Rights, Equipment&Easement Lease (5/6)
ORKANAL Page S of
EXHIBIT A
Description of Leased Ground and Water Rights
Ground Wse L*catioas:
1. Tower Site—East Skyline Drive
2. Happy Valley Ranchos Mid Booster Site-Mtn View Road
3. Forest Way Storage Tank&Booster Site
4. Well Site
5. Rt3V1%Easements for all water/power associated line
Water Rights:
Surface Water Rights
1. 95-9573 Recreational Storage 394 Acre Feet
2.. 95-9659 Irrigations&Storage 5.38 c1s.907 Acre FeK
3. 95-16411 Irrigation&Irrigation Storage.Blanchard Creek
Craund Water Rights
1. 95.9587 Irrigation 1.99 c1s.589.6 acre feet
'Dotal Monthly Payment for the above items leased is$2,000.00 per month
commencing January 1,2020
Ground, later Rights,Equipment and Easement lase r
'TKl
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 82

Exhibit F: Ground,Water Rights, Equipment&Easement Lease (6/6)
ORIGINAL Page 6 of 6
EXHIBIT B
Uescrihtion of Leased Equipment
Monthly Lease Rate
1. rCase Backhoe S600.00
2. Kubota VTV $180.00
3. Ford 1;150 Pickup 5180.00
4. Ford Ranger Pickup t�20..00
SUBTOTAL S11080.00
Add-on Licenses,insurance&fuel S420.0
Not maintenance
Total?Monthly lease Expense.for Equip If 40.90
Leasee has rights to purchase Additional equipment and/or office improvements at Lessm's
prerogative
Ground,Watcr Rights,Equipment and Easement Lease m
TK
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 83

Exhibit G: Current Idaho State Water Right Lease Rates
Vater Right leasing-zany thoughts on what the going rate is?
meaaegea
Wray Markow*ff ley=rP Tue.Oct 22,2024 at 1:29 Pt
5:Luke Balsa 4Wke,baies@k wr.ldWva.gov>
we are working on a Isere agreement with our parent company and is we 25.00 to$35.0ftcra That per year on the State Watar Bank pricing web
page,would you?raw any
other plates to find doe current imarket information in the Panhandie?
thinks Luke!
Jeff
Jaffrey MWkeley
TedWcal A rm Group
20s 9204)M2
Warnerkeley com
abs,t-A*<t*e.Bvt twrkfaho. Tue,Oct 22,2024 at 1A0 Pi
):jdfrey 1Nerkaley<j&ff*ffwke49y.00m>
Mr.Merkeiay,
From the Water Supply Barak literature, htfps:fhdwr ldaho.govrwrblprogmm3Avater-supply-banktpridng!,1 note FY2024 is
S23.00/of and will increase to$33,Waf beginning In 2025.
1 racornrnend contacting Mary Condon who works directly witty the water supply bank to gain particulars.
Contacts,Procadurer,,& Additional info
Board's bank
ti r y Ccnhor
240',; 287
F1a-1ktrdv,.0da 1i _
Reps,
6uka Dates
Sr.Water Resource Agent
Northern Region
P:208-762-2817
1t �11 1 I) iN 1
WATER RESOURCES
7600 N klinern Or. 5..,te 100
Coeur D'Alene, rD 83815 7763
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 84

Exhibit H: Pump Estimates (1/3)
KN•aV `-
ESTIMATE
A&H Well Services LLC andrew®aaidhweliservIces.com
2710 Gushy Browns Lake Rd [phone]
Chewelah,WA 99109
Ship to
Bill to Stone Ridge Water Company
Stone Ridge Water Company
Blanchard,Idaho
Estimate details
Estimate no.:4354
Estimate date:07/23/2024
# Date Product or service Description City Rate Amount
1. Pump Install Install fly-BQC-5&IOOHP SME 8°460V 1 $27,350.00 $27,350.00
Submersible Motor To Original Depth.
Spice IOts at motor and surface wll be
provided.
Assuming reuse of all existing drop pipe
and wire.
Electrical Permit
2. LaborServlces Installing Pump End and shake down. 15 $30D.OD $4.500.00
Subtotal $31,850.00
Sales tax 8.00% $2,548.00
Total $34,398.00
Overdue 08/05/2024
Accepted date Accepted by
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 85

Exhibit H: Pump Estimates (2/3)
ESTIMATE
A&H Wall Services LLC a ndrew®eandhwelismices.mm l
2710 Quarry Browns Lake Rd [phone]B r
Chewelah,WA 99109
Ship to
Bill to Stone Ridge Water Company
Stone Ridge Water Company
Estimate details
Estimate no.-.4356
Estimate date:08/05/2024
is Date Product or service Description City Rate Amount
1. Materials Yaskawa 101000139A 450V Drive 1 $14,500.00 $14.500.00
TCI 125HP Line Reactor
TCI 125HP Load Reactor DV/DT
Mac wire and fittings required to retrofit
Permit
2. Labor Sevlces Removal of existing soft start and 10 $250.00 $2,500.00
installation of new VFD+Programming.
Subtotal $17,000.00
Note to customer sales tax 0.00% $1,360.00
Thank you for your business.
Total $18,360.00
Accepted date Accepted by
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 86

Exhibit H: Pump Estimates (3/3)
�•r'ldD,: Jeffrey Merkeley<[e-mail]
'lease Help--asap Copy of well pump and controller invoices
messages
affray Merkeley<jeff@merkeley com> Tue,Oct 29.2024 at 9:35 PI
):Andrew Peters<[e-mail]>,Falcon Price<[e-mail]>
I think we have the well pump/motor,but not sure we ever got an Invoice for the controller.
we need first thing In aml
thanks
Jeff
Jeffrey Merkeley
Technical Assistance Group
20&920-0"2
[e-mail]
ndrew Peters<[e-mail]> Wed,Oct 30,2024 at 10:34 Al
):Jeffrey Merkeley<[e-mail]>
c:"Falcon Price P.E.'<Falcon@aandhwellservices.00m>
Jeffrey,
The VFW estimates and Invoice are the same @ 17,000 even before tax.
Sent from my iPhone
On Oct 29.2024,at 9:35 PM,Jeffrey Merkeley<[e-mail]>wrote:
[Quoted text hiddm,l
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 87

Exhibit I: Integrity Management Contract (1/3)
integrity Water Management, Inc.
P.O. Box 468
Athol, Idaho 83801
[phone] (208)6R3-1700 fax
[e-mail]
integrity water.net
Water System Management Agreement
Integrity Water Management, Inc., with an address of PO Box 468, Athol, Idaho, 83801; hcrcby
agrees to provide water system management services to the Stoneridgc Utilities,herein referred to as
Stoneridge,with a mailing address of 364 Stoneridgc Rd. Blanchard, ID 83804, beginning April I,
2024,and ending March 31,2025 ,under the following conditions:
1. Primn , orsmjn'services. The water management services of a properly licensed operator
shall be provided.
2. l °liet tcrra_licerrcir� @evel rrf 0Pe0[ ,r,-,. Integrity Water Management agrees to provide a
licensed`responsible in charge person"and maintain proper licensing as defined by the State
of Idaho Department of Environmental Quality (DEQ), with a license level equal to or
greater than the DI:Q requirement necessary to operate the Stoncridge system. A copy of a
valid,licensed operator certificate will be supplied upon request.
3. I1 . Integrity Water Management agr+ecs to provide proper liability insurance and
provide a copy of liability insurance naming the Stoneridgr, as additionally insured. This
insurance also covers water system disinfection procecdures if necessary.
4_ pee Structure. For a fee structure of$3,500, the specified services below will be provided.
Payment is due on the 100 of the month after the mouth for which services are billed.
Balances 30 days or more past due will incur finance charges of 1.5%per month_
5. 5gZified services.Serti ices provided by integrity Water:management;
a. "Responsible in charge"operator services will be provided 24 hours a day. 7 days a
week.The"msponsiblC in charge"operator shall be available by phone,text «r c-
mail.
b. C �tri_ s+Nrvic t a rrll e_ faa ark .weekleov io tbg AT W d csA,dcnr am ►ncludW in The
base price of the said water and sewer system management services. After hours
service calls or work performed, system emergencies, after huurs service
:requested by Stoneridgc management, or lionner County 811 locate service, will
be billed at $75 per hour with a 2 hour minimum. V4'hen needed or requested,
administrative services will be provided at $50 prr hour provided the work can be
performed during normal business hours. After hours (from 5pm to lam
Avetkdays,weekends,&.holidays)work and emergency;service calls will be billed
at$75 per hour with a 2 hour minimum.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 88

Exhibit I: Integrity Management Contract Cont. (2/3)
located at the time of the additional service request in relation to Stoneridge
facilities and returning back to that same location.
c. At the request of Stoncridgc,maintain system hardware,prepare and maintain a
spare parts list with inventories,and/or spare part supplier phone numbers and
days and hours of operation.Prepare a recommended spare parts inventory list
that considers procurement lead time,impact of needed part on water system
operations,and cost. Maintain a spare parts inventory from the list as approved by
Stoneridge. Supplies and materials obtained for the Stoneridge water system in
the course of service will be paid for or reimbursed by the Stoncridge.Any
supplies,materials,or expenses greater than$5000 per item will require prior
approval of Stoneridge.In an emergency situation where a Stoneridge
representative is unavailable to approve an expense over S5000,Integrity Water
Management will exercise prudent judgement as to the necessity of incurring an
expense over$5000. However,Stoneridge will be responsible for reimbursing
Integrity Water h1anagcmcnt or service providers contractLd by Integrity Water
Management for all cmcrgetwy expenses,which includes expenses over$5000.
d. At the request of Stoneridge, water service turn on and turn off services shall be
provided by Integrity Water Management upon request. 24 hour notice shall be
given to Integrity Water Management for such services. For turn on and turn off
services of current or delinquent customer accounts, such services shall be
provided as follows. Posting of"Water Service termination"notices on customer
property shall incur a $25 fee each if such posting occurs during regular service
calls. Turning off a customer's water service will incur a fee 013100 each while
turning on a customer's water service will incur a S100 fee each provided that
these services are rendered during regular service calls_ If a special trip is made
for these services, then the fee structure outlined in 5b applies. These charges
should be added to customer bills.
e. Locating service shall be provided on an as needed basis at the rate designated in
A4 and 5.b above per locate ticket number as designated by the Bonner County
Sl 1 One gall agency. Stoneridge agrees to provide Integrity Water Management
with current system maps for these services if available, If the reaps or
information provided to Integrity Water Management for this purpose are
unavailable or not accurate, or pipe locating tape%%s either not installed when the
water lines were installed or is unavailable, Intulpity Water Management cannot
guarantee the accuracy of the locating service. Banner County One Call requires
that all locate requests be handled within 48 hours, or 2 lours on an emergency
basis. if locate requests art not handled within this time frame, then any
responsible party damaging water system facilities within the area designated by
the locate ticket will not be responsible for repairs. Locate tickets can bae issued at
any time. Integrity Water Management shall make every effort to handle locate
services Within the framework of allowable service calls for the base fee outlined
in #4 above. However, if a locate ticket is issued requiring an emergency service
call,Stoneridge will be billed at the rate outlined in 5b above.
f: At the request of Stoneridge, he the point-of-contact person for a Stoneridge
customer arranging water service to a new dwelling under construction. Arrange
to install to install any additional Water or sewer system facilities accordance with
Stoneridge an&or Dy Q rcquircrncnts if necessary. Inspect the +member-installer!
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 89

Exhibit I: Integrity Management Contract Cont. (3/3)
d. Shall provide a copy of the Stoneridgc customer list if mutually agreed upon.
Integrity Water Management requests the customer list in order to contact
customers in an emergency or to perform maintenance which would effect
Stoneridge customers. Integrity Water h1ar agement respects the privacy of
Stoneridge' customers and agrees not to sell, rent, or otherwise provide this
customer list to a third party unless required by law enforcement agencies.
c. Stoneridge should have accounts setup with vendors such as plumbing supply
companies and labs for direct billing. However. Stoneridge shall rrimbursc
Integrity Water Management for all chemicals (i.e., chlorine) and supplies
obtained for Stoneridge water systern maintenancc which arc not directly billed to
Stoneridge. Such items will be listed on the monthly invoice issued by Integrity
Water Management,
8. Termination. This contract is valid for the time duration outlined above. At the end of the
duration specified in this agreement, this agreement will rollover to another annual term
unless notice,or termination is Riven in writing by either party 30 days prior to the expirdtion
of this agreement.However,this agreement may be terminated by mutual agreement with 30
days written notice. All Stoncridgc water and scwcr system r+ ords obtained during the
course of this agreement will be turned over to Stoneridge at the termination of this
agreement.
9.Wou1j, In the event that either party defaults on any of the tams of this Agreement,then
the non-defaulting party shall have the right to pursue any and all remedies available to the
non-defaulting party at law or in equity, including,without limitation,the rccovcry of
damages from the dci'aulting party and the specific:performance of this Agreement.
]0.Scvcrability_ If any term or provision of this Agrcomcnl shall,to any extent,be
determined by a court of competent jurisdiction to be invalid of unenforceable,the remainder
of this Agreement shall not be affected thereby,and each term and provision of this
Agreement shall be valid and be enforecable to the fullest extent permitted by law. it is the
intention of the parties that ifany provision of this Agreement is capable of two
constructions,one of which would render the provision void and the other of which would
render the provision valid, the provision shall have the meaning which renders it valid.
11.Entire Agmmcnt This Settlement Agreement embodies the entire allccment of parties,
and thcrc are no oral agreements existing relative to the subject matter hereof which arc not
expressly set forth herein.
12.M3 I yef. No covenant, term,or condition or the'hreach thereof shall he deemed waived,
except by written consent of the party against whom the waiver is claimed, and any waiver of
the breach of arty covenant,term or condition shall not be deemed a waiver of any other
covenant.term or aandition herein.
13. Binding Efl"ect. fhc rights and obligations Itereundcr shall cxtend to the heirs,
representatives.successors,andlor assigns of the resp cti►•e parties.
14. inteEMtation. This document shall be interpreted in accordance with the fair meaning of
the working and not construed strictly for or against either party.The parties agree Idaho law
applies to the interpretation and cnfitrccment of this Agreanrnt,
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - go

Exhibit J: 2024 Integrity Management Contract Update
ter.,.-..,
"m.y- Ift 4wfsrMlwlwyAHM
'toneridge'Water System budget estimate for 4th quartet
"w1A
ob Kudwr»kl�babG r%gltgftate "40 'fhlsa 00 17.2tL,4 it 2,56
x Cnwsm"am,n tcnanaan@aw=9.n+w,dc66eray l MODYq�rrr daany
C Tv"OKwupiat =9ksn�ri ltsu'1�°
GhlPM&.fie".
You�askvc rtw to rare w v t*an a Wmaw for manapnq fitar+errd.'4>r aYdabrr Syar, r1 for vo last quarOr of 202A f0dabr,tlbvarrromr 11
Ducnr•tLft?).
i,ame:i upon the par a sonaglur Yftw(r-w4Oaf,mir 9Mom m to 12,IVJ tzr rm do 4ih quormr,or vpprOisknr ,'y$4.43 per 1[110/in
i at ruw kLits;it yot,hewn any e,rr 'Qe,w-
b=c A.c4'K1rch.—wi
..........•..••••••.•..'...-, -..•...
lr,erj--f Wafee 1+rjrnpamcr
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 91

]Exhibit K: Backhoe Rental Contract
SUN RENTAL CDA QUOTE# 4060 -05
7080 N GOVERNMENT WAY DATEl11ME IN:
DALTON GARDENS,ID 83815
208-664-0457 DATEMME OUT:10/30/2024 1:33 PM
Quote Adjustment
RENTED AND/OR SOLD TO ADDRESS AT WHICH EQUIPMENT WILL BE USED
Account#: 4487
STONERIDGE GOLF COURSE
PO BOX 280
BLANCHARD, ID 83804
208-437-3148
WRITTEN BY CHECKED IN BY AUTHORIZED RENTER JOB LOCATION
LEIF DOLAN
CAR LICENSE NO. DRIVER'S LICENSE NUMBER P.O.NO.OR JOB NO. DATE AND TIME DUE IN
XXXXX 11/01/2024 1:33 PM
ITEMS RENTED AND/OR SOLD
Item# Description Quantity Rates M W D H DateBT)me Due Amount
15552-60 TRACTOR 4WD Wl BACKHOE COMPACT 1 24H 340.00 2 11101/2024 1:33 PM 680.00
245.00 Minimum 340.00 Day 340.00 24 Hrs 1190.00 1 Week 3570.00 4 Wks
Serial#61443
-----------------------------------------------------------------------------------------------
"••PLEASE RETURN CLEAN"'•
OUOTE IS FOR TRACTOR WITH 13ACKHOE DELIVERED AND PICKED UP FOR 2 DAYS.
w .sunrentaIcenter.com
Total Rental 680.00
Damage Waiver 68.00
Delivery/Pickup 400.00
Subtotal 1148.00
Sales Tax(ID) 68.88
Total 1216.88
Security Required 0.00
'NO REFUNDS ON CANCELATIONS LESS
THAN 14 DAYS PRIOR TO RENTAL DATE•
CARDMEMBER AGREES TO PAY THE ABOVE
TOTAL AMT ACCORDING TO THE CARD ISSUE
AGREEMENT(MERCHANT AGREEMENT)
Quote Dale:10/30/2024,Last Adj.:10/3012024,Time:13:44
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 92

Exhibit L: Current Office Space Rental Rates
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 93

Exhibit M: Sewer Office Space Lease (i/io)
Origins/
Page 1 of 6
Office Space Lease
This Lease Agreement(this"Lease")is dated January 01,2020,by and between Esprit Enterprises,LLC
("Landlord"),and CDS StoneRidge Utilities,LLC-Water ("Tenant").The parties agree as follows:
PREMISES.Landlord, in consideration of the lease payments provided in this Lease,leases to Tenant
1,200 Square Foot Furnished Office Space in StoneRidge Event Center(the"Premises")located at 12
Holiday Loop,Blanchard,Idaho 83804 and approximately 200 Square Feet Furnished Office Space in
StoneRidge Sales Office(the"Premises")located at 364 StoneRidge Road, Blanchard, Idaho,83804.
TERM.The lease term will begin on January 01,2020 and will terminate on December 31,2025.
LEASE PAYMENTS.Tenant shall pay to Landlord a"base"monthly rent of$1.75/SF/month or$2,100.00.
In addition,tenant shall pay landlord a"Supplemental Services"monthly rent of$.46/SF/Month or$552.00
per month for a total payment of$2,652.00 per month for the 12 Holiday Loop Office Space.In addition,
Tenant shall pay to Landlord a"base"monthly rent of$1.75/SF/month or$350.00 for a total payment of
$350.00 for the Sales Office space.The total Monthly rent for both spaces shall be$3,002.000 per month.
Lease payments shall be made to the Landlord at 364 StoneRidge Road,Blanchard Idaho 83804,which
address may be changed from time to time by the Landlord.See Attached Exhibit A regarding services
and items to be provided by landlord for tenants benefit with all costs included in the base rent and the
"Supplemental Services"rent. Rents shall be increased by eight(8)Percent every 12 months,unless
mutually agreed upon otherwise by landlord and tenant.Landlord and tenant agree that StoneRidge
Water Company will pay 60%of monthly rent and StoneRidge sewer company will pay 40%of rent.
POSSESSION.Tenant shall be entitled to possession on the first day of the term of this Lease,and shall
yield possession to Landlord on the last day of the term of this Lease,unless otherwise agreed by both
parties in writing.At the expiration of the term,Tenant shall remove its goods and effects and peaceably
yield up the Premises to Landlord in as good a condition as when delivered to Tenant,ordinary wear and
tear excepted.Landlord promises to place Tenant in peaceful possession of the Office Space,and
Tenant, by taking possession of the Office Space,will have acknowledged that the Office Space are in
satisfactory and acceptable condition.Landlord promises to place Tenant in peaceful possession of the
Office Space,and Tenant,by taking possession of the Office Space,will have acknowledged that the
Office Space are in satisfactory and acceptable condition.
USE OF PREMISES.Tenant may use the Premises only for Utility Office and related functions The
Premises may be used for any other purpose only with the prior written consent of Landlord,which shall
not be unreasonably withheld.Tenant shall notify Landlord of any anticipated extended absence from the
Premises not later than the first day of the extended absence.
PROPERTY INSURANCE.Landlord and Tenant shall each maintain appropriate insurance for their
respective interests in the Premises and property located on the Premises.Landlord shall be named as an
additional insured in such policies.Tenant shall deliver appropriate evidence to Landlord as proof that
adequate insurance is in force issued by companies reasonably satisfactory to Landlord.Landlord shall
receive advance written notice from the insurer prior to any termination of such insurance policies.Tenant
shall also maintain any other insurance which Landlord may reasonably require for the protection of
Landlord's interest in the Premises.Tenant is responsible for maintaining casualty insurance on its own
property.
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 94

Exhibit M: Sewer Office Space Lease (2/10)
Qri�na!
Page 2 of 5
RENEWAL TERMS.This Lease shall automatically renew for an additional period of 5 Years per renewal
term,unless either parry gives written notice of termination no later than 60 days prior to the end of the
term or renewal term.The lease terms during any such renewal term shall be the same as those
contained in this Lease.
UTILITIES AND SERVICES.See Attached Exhibit Aregarding services and items to be provided by
landlord for tenants benefit with all costs included in the base rent and the"Supplemental Services"rent.
COMMON AREAS OF OFFICE SPACE_Landlord shall make available at all times during the term of this
lease in any portion of the Office Space that Landlord from time to time designates or relocates,
automobile parking and common areas as Landlord shall from time to time deem appropriate.Tenant
shall have the nonexclusive right during the term of this lease to use the common areas for itself, its
employees,agents,customers,clients,invitees,and licensees.Landlord reserves the right to re-
designate a common area for a non-common use or to designate as a common area a portion of the
Office Space not previously designated a common area.
All common areas shall be subject to the exclusive control and management of Landlord or any other
persons or nominees that Landlord may have delegated or assigned to exercise management or control,
in whole or in part,in Landlord's place and stead.Landlord shall have the right to close,if necessary,all or
any portion of the common areas as is deemed necessary by Landlord to effect necessary repairs,
maintenance,or construction,or to maintain the safety of tenants or the general public.Landlord will
maintain the common areas in a clean,orderly,and sanitary manner.Landlord is responsible for all
repairs of the common areas,except those required by the negligence of Tenant.
Landlord and Landlord's nominees and assignees shall have the right to establish,modify,amend,and
enforce reasonable rules and regulations with respect to the common areas and the Office Space.Tenant
shall fully and faithfully comply with and observe the rules and regulations for the common areas and the
Building("the Building Rules and Regulations"),of which the Leased Space is a part,including any
additions or amendments to the Building Rules and Regulations that may be hereafter enacted by
Landlord in Landlord's sole discretion.
COVENANT AGAINST WASTE.Tenant agrees that Tenant will not commit waste in or upon the Office
Space or any portion thereof.The Tenant shall be responsible for the ventilation and cleanliness of the
demised premises and for keeping the waste sewerage lines free from grease stoppages.
TAXES.Taxes attributable to the Premises or the use of the Premises shall be allocated as follows:
REAL ESTATE TAXES.Landlord shall pay all real estate taxes and assessments for the Premises.
PERSONAL TAXES.Landlord shall pay all personal taxes and any other charges which may be
levied against the Premises and which are attributable to Tenant's use of the Premises,along with all
sales and/or use taxes(if any)that may be due in connection with lease payments.
TERMINATION UPON SALE OF PREMISES_Notwithstanding any other provision of this Lease,Landlord
may terminate this lease upon 90 days'written notice to Tenant that the Premises have been sold,Tenant
shall have a first right of refusal on the sale of the premises(which tenant must close within 6 months of
Tenant receiving written notice of their first right of refusal on a pending sale).
r !f
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 95

Exhibit M: Sewer Office Space Lease (3/10)
O�i�ir�a!
Page 3 of 5
DESTRUCTION OR CONDEMNATION OF PREMISES.If the Premises are partially destroyed by fire or
other casualty to an extent that prevents the conducting of Tenant's use of the Premises in a normal
manner,and if the damage is reasonably repairable within sixty days after the occurrence of the
destruction,and if the cost of repair is less than$50,000.00,Landlord shall repair the Premises and a just
proportion of the lease payments shall abate during the period of the repair according to the extent to
which the Premises have been rendered untenantable.However,if the damage is not repairable within
sixty days,or if the cost of repair is$50,000.00 or more,or if Landlord is prevented from repairing the
damage by forces beyond Landlord's control,or if the property is condemned,this Lease shall terminate
upon twenty days'written notice of such event or condition by either party and any unearned rent paid in
advance by Tenant shall be apportioned and refunded to it.Tenant shall give Landlord immediate notice
of any damage to the Premises.
DEFAULTS.Tenant shall be in default of this Lease if Tenant fails to fulfill any lease obligation or term by
which Tenant is bound.Subject to any governing provisions of law to the contrary,if Tenant fails to cure
any financial obligation within 10 days(or any other obligation within 10 days)after written notice of such
default is provided by Landlord to Tenant,Landlord may take possession of the Premises without further
notice(to the extent permitted by law),and without prejudicing Landlord's rights to damages.In the
alternative,Landlord may elect to cure any default and the cost of such action shall be added to Tenant's
financial obligations under this Lease.Tenant shall pay all costs,damages,and expenses(including
reasonable attorney fees and expenses)suffered by Landlord by reason of Tenant's defaults.All sums of
money or charges required to be paid by Tenant under this Lease shall be additional rent,whether or not
such sums or charges are designated as"additional rent".The rights provided by this paragraph are
cumulative in nature and are in addition to any other rights afforded by law.
HOLDOVER.If Tenant maintains possession of the Premises for any period after the termination of this
Lease("Holdover Period"),Tenant shall pay to Landlord lease payment(s)during the Holdover Period at a
rate equal to the normal payment rate set forth in the Renewal Terms paragraph.
CUMULATIVE RIGHTS.The rights of the parties under this Lease are cumulative,and shall not be
construed as exclusive unless otherwise required by law.
NON-SUFFICIENT FUNDS,Tenant shall be charged$50.00 for each check that is returned to Landlord
for lack of sufficient funds.
GOVERNING LAW.This Lease shall be construed in accordance with the laws of the State of Idaho.
ENTIRE AGREEMENT/AMENDMENT.This Lease Agreement contains the entire agreement of the
parties and there are no other promises,conditions,understandings or other agreements,whether oral or
written,relating to the subject matter of this Lease.This Lease may be modified or amended in writing,if
the writing is signed by the party obligated under the amendment.
SEVERABIUTY. If any portion of this Lease shall be held to be invalid or unenforceable for any reason,
the remaining provisions shall continue to be valid and enforceable.if a court finds that any provision of
this Lease Is invalid or unenforceable, but that by limiting such provision,it would become valid and
enforceable,then such provision shall be deemed to be written,construed,and enforced as so limited.
WAIVER.The failure of either party to enforce any provisions of this Lease shall not be construed as a
waiver or limitation of that party's right to subsequently enforce and compel strict compliance with every
provision of this Lease.
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 96

Exhibit M: Sewer Office Space Lease (4/10)
Od final
Page 4 of 5
BINDING EFFECT.The provisions of this Lease shall be binding upon and inure to the benefit of both
parties and their respective legal representatives,successors and assigns.
SIGNATURES AND NOTICE.This Lease shall be signed by the following parties.No notice under this
Lease shall be deemed valid unless given or served in writing and forwarded by mail,postage prepaid,
addressed to the parties below:
LANDLORD:
Esprit Enterprises,LLC
Teresa Karupiah,Member
364 StoneRidge Road
Blanchard,Idaho 83804
TENANT:
CDS StoneRidge Utilities,LLC-Water
Chan Karupiah,Member
12 Holiday Loop
Blanchard,Idaho 83804
Such addresses may be changed from time to time by either party by providing notice as set forth above.
Notices mailed in accordance with the above provisions shall be deemed received on the third day after
posting.
LANDLORD:
Esprit Enterprises,LLC
By: Date:
Teresa Karupiah
Member
TENANT:
CDS Ston Ri ge Utilities, LC-Water
f
By:
- r Date
_
Chan Karupiah
Member
12 Holiday Loop&364 StoneRidge Road Office Lease-Final 1�?
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 97

Exhibit M: Sewer Office Space Lease (5/1o)
QrIA/nal
Page 5 of 5
Exhibit A
Effective 1/1/2020
Supplemental Services to Be Provided by Landlord
In exchange for rental payments described in the"Lease Payments'section,Landlord agrees to provide
the following,at Landlords sole expense the following to Tenant:
1. Telephone system and monthly telephone service,including long-distance calls only for water
company lines.
2. Alarm Service-24-hour coverage.
3. Internet Service for Event Center office lines only
4. Janitorial services weekly,bathrooms,and office space
5. IT Support Technician
6. Landscaping per landlord schedule
7. Power,water,sewer,propane,garbage
8. Parking and snow maintenance(plow when 3+inches new snow)
9. Furnishings in place
10. Office supplies&office equipment
11. Casualty and liability insurance coverage as recommended by Philadelphia Insurance
12. Pest Control Services per vendor recommended schedule.
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 98

Exhibit M: Sewer Office Space Lease (6/1o)
Page 1 of 5
Office Space Lease
This Lease Agreement(this"Lease")is dated January 01,2020, by and between Esprit Enterprises,LLC
("Landlord"),and CDS StoneRidge Utilities,LLC-Water("Tenant").The parties agree as follows:
PREMISES.Landlord,in consideration of the lease payments provided in this Lease,leases to Tenant
1,200 Square Foot Furnished Office Space in StoneRidge Event Center(the"Premises")located at 12
Holiday Loop,Blanchard,Idaho 83804 and approximately 200 Square Feet Furnished Office Space in
StoneRidge Sales Office(the"Premises")located at 364 StoneRidge Road,Blanchard, Idaho,83804.
TERM.The lease term will begin on January 01,2020 and will terminate on December 31,2025.
LEASE PAYMENTS.Tenant shall pay to Landlord a"base"monthly rent of$1,470.00 In addition tenant
shall pay landlord a"Supplemental Services"monthly rent of$331.00 per month for a total payment of
$1,801.00 per month for the 12 Holiday Loop Office and Sales Office space. Lease payments shall be
made to the Landlord at 364 StoneRidge Road,Blanchard Idaho 83804,which address may be changed
from time to time by the Landlord.See Attached Exhibit A regarding services and items to be provided by
landlord for tenants benefit with all costs included in the base rent and the"Supplemental Services"rent.
Rents shall be increased by eight(8)Percent every 12 months, unless mutually agreed upon otherwise by
landlord and tenant.
POSSESSION.Tenant shall be entitled to possession on the first day of the term of this Lease,and shall
yield possession to Landlord on the last day of the term of this Lease,unless otherwise agreed by both
parties in writing.At the expiration of the term,Tenant shall remove its goods and effects and peaceably
yield up the Premises to Landlord in as goad a condition as when delivered to Tenant,ordinary wear and
tear excepted.Landlord promises to place Tenant in peaceful possession of the Office Space,and
Tenant,by taking possession of the Office Space,will have acknowledged that the Office Space are in
satisfactory and acceptable condition.Landlord promises to place Tenant in peaceful possession of the
Office Space,and Tenant,by taking possession of the Office Space,will have acknowledged that the
Office Space are in satisfactory and acceptable condition.
USE OF PREMISES.Tenant may use the Premises only for Utility Office and related functions The
Premises may be used for any other purpose only with the prior written consent of Landlord,which shall
not be unreasonably withheld.Tenant shall notify Landlord of any anticipated extended absence from the
Premises not later than the first day of the extended absence.
PROPERTY INSURANCE.Landlord and Tenant shall each maintain appropriate insurance for their
respective interests in the Premises and property located on the Premises.Landlord shall be named as an
additional insured in such policies.Tenant shall deliver appropriate evidence to Landlord as proof that
adequate insurance is in force issued by companies reasonably satisfactory to Landlord.Landlord shall
receive advance written notice from the insurer prior to any termination of such insurance policies.Tenant
shall also maintain any other insurance which Landlord may reasonably require for the protection of
Landlord's interest in the Premises.Tenant is responsible for maintaining casualty insurance on its own
property.
LIABILITY INSURANCE.Tenant shall maintain liability insurance on the Premises in a total aggregate
sum of at least$300,000.00.Tenant shall deliver appropriate evidence to Landlord as proof that adequate
insurance is in force issued by companies reasonably satisfactory to Landlord.Landlord shall receive
advance written notice from the insurer prior to any termination of such insurance policies.
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 99

Exhibit M: Sewer Office Space Lease (7/io)
Orikinai
Page 2 of 5
RENEWAL TERMS.This Lease shall automatically renew for an additional period of 5 Years per renewal
term,unless either parry gives written notice of termination no later than 60 days prior to the end of the
term or renewal term.The lease terms during any such renewal term shall be the same as those
contained in this Lease.
UTILITIES AND SERVICES.See Attached Exhibit A regarding services and items to be provided by
landlord for tenants benefit with all costs included in the base rent and the"Supplemental Services"rent,
COMMON AREAS OF OFFICE SPACE.Landlord shall make available at all times during the term of this
lease in any portion of the Office Space that Landlord from time to time designates or relocates,
automobile parking and common areas as Landlord shall from time to time deem appropriate.Tenant
shall have the nonexclusive right during the term of this lease to use the common areas for itself,its
employees,agents,customers,clients,invitees,and licensees.Landlord reserves the right to re-
designate a common area for a non-common use or to designate as a common area a portion of the
Office Space not previously designated a common area.
All common areas shall be subject to the exclusive control and management of Landlord or any other
persons or nominees that Landlord may have delegated or assigned to exercise management or control,
in whole or in part,in Landlord's place and stead.Landlord shall have the right to dose,if necessary,all or
any portion of the common areas as is deemed necessary by Landlord to effect necessary repairs,
maintenance,or construction,or to maintain the safety of tenants or the general public.Landlord will
maintain the common areas in a clean,orderly,and sanitary manner.Landlord is responsible for all
repairs of the common areas,except those required by the negligence of Tenant.
Landlord and Landlord's nominees and assignees shall have the right to establish,modify,amend,and
enforce reasonable rules and regulations with respect to the common areas and the Office Space.Tenant
shall fully and faithfully comply with and observe the rules and regulations for the common areas and the
Building("the Building Rules and Regulations"),of which the Leased Space is a part,including any
additions or amendments to the Building Rules and Regulations that may be hereafter enacted by
Landlord in Landlord's sole discretion.
COVENANT AGAINST WASTE.Tenant agrees that Tenant will not commit waste in or upon the Office
Space or any portion thereof.The Tenant shall be responsible for the ventilation and cleanliness of the
demised premises and for keeping the waste sewerage lines free from grease stoppages.
TAXES.Taxes attributable to the Premises or the use of the Premises shall be allocated as follows:
REAL ESTATE TAXES.Landlord shall pay all real estate taxes and assessments for the Premises.
PERSONAL TAXES.Landlord shall pay all personal taxes and any other charges which may be
levied against the Premises and which are attributable to Tenant's use of the Premises,along with all
sales and/or use taxes(if any)that may be due in connection with lease payments.
TERMINATION UPON SALE OF PREMISES.Notwithstanding any other provision of this Lease,Landlord
may terminate this lease upon 90 days'written notice to Tenant that the Premises have been sold,Tenant
shall have a first right of refusal on the sale of the premises(which tenant must close within 6 months of
Tenant receiving written notice of their first right of refusal on a pending sale).
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
TK
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - too

Exhibit M: Sewer Office Space Lease (8/io)
Qrie7ina!
Page 3 of 5
DESTRUCTION OR CONDEMNATION OF PREMISES.If the Premises are partially destroyed by fire or
other casualty to an extent that prevents the conducting of Tenant's use of the Premises in a normal
manner,and if the damage is reasonably repairable within sixty days after the occurrence of the
destruction,and if the cost of repair is less than$50,000.00,Landlord shall repair the Premises and a just
proportion of the lease payments shall abate during the period of the repair according to the extent to
which the Premises have been rendered untenantable.However,if the damage is not repairable within
sixty days,or if the cost of repair is$50,000.00 or more,or if Landlord is prevented from repairing the
damage by forces beyond Landlord's control,or if the property is condemned,this Lease shall terminate
upon twenty days'written notice of such event or condition by either party and any unearned rent paid in
advance by Tenant shall be apportioned and refunded to it.Tenant shall give Landlord immediate notice
of any damage to the Premises.
DEFAULTS.Tenant shall be in default of this Lease if Tenant fails to fulfill any lease obligation or term by
which Tenant is bound.Subject to any governing provisions of law to the contrary,if Tenant fails to cure
any financial obligation within 10 days(or any other obligation within 10 days)after written notice of such
default is provided by Landlord to Tenant,Landlord may take possession of the Premises without further
notice(to the extent permitted by law),and without prejudicing Landlord's rights to damages.In the
alternative, Landlord may elect to cure any default and the cost of such action shall be added to Tenant's
financial obligations under this Lease.Tenant shall pay all costs,damages,and expenses(including
reasonable attorney fees and expenses)suffered by Landlord by reason of Tenant's defaults.All sums of
money or charges required to be paid by Tenant under this Lease shall be additional rent,whether or not
such sums or charges are designated as"additional rent The rights provided by this paragraph are
cumulative in nature and are in addition to any other rights afforded by law.
HOLDOVER.If Tenant maintains possession of the Premises for any period after the termination of this
Lease("Holdover Period"),Tenant shall pay to Landlord lease payment(s)during the Holdover Period at a
rate equal to the normal payment rate set forth in the Renewal Terms paragraph.
CUMULATIVE RIGHTS.The rights of the parties under this Lease are cumulative,and shall not be
construed as exclusive unless otherwise required by law.
NON-SUFFICIENT FUNDS.Tenant shall be charged$50.00 for each check that is returned to Landlord
for lack of sufficient funds_
GOVERNING LAW.This Lease shall be construed in accordance with the laws of the State of Idaho.
ENTIRE AGREEMENT/AMENDMENT.This Lease Agreement contains the entire agreement of the
parties and there are no other promises,conditions,understandings or other agreements,whether oral or
written,relating to the subject matter of this Lease.This Lease may be modified or amended in writing,if
the writing is signed by the party obligated under the amendment.
SEVERABILITY.If any portion of this Lease shall be held to be invalid or unenforceable for any reason,
the remaining provisions shall continue to be valid and enforceable.If a court finds that any provision of
this Lease is invalid or unenforceable,but that by limiting such provision,it would become valid and
enforceable,then such provision shall be deemed to be written,construed,and enforced as so limited.
WAIVER.The failure of either party to enforce any provisions of this Lease shall not be construed as a
waiver or limitation of that party's right to subsequently enforce and compel strict compliance with every
provision of this Lease.
12 Holiday Loop&364 StoneRidge Road Office Lease-Final Ze
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - lol

Exhibit M: Sewer Office Space Lease (9/io)
Ori final
Page 4 of 5
BINDING EFFECT.The provisions of this Lease shall be binding upon and inure to the benefit of both
parties and their respective legal representatives,successors and assigns.
SIGNATURES AND NOTICE.This Lease shall be signed by the following parties.No notice under this
Lease shall be deemed valid unless given or served in writing and forwarded by mail,postage prepaid,
addressed to the parties below:
LANDLORD:
Esprit Enterprises,LLC
Teresa Karupiah,Member
364 StoneRidge Road
Blanchard,Idaho 83804
TENANT:
CDS StoneRidge Utilities,LLC-Water
Chan Karupiah,Member
12 Holiday Loop
Blanchard,Idaho 83804
Such addresses may be changed from time to time by either party by providing notice as set forth above.
Notices mailed in accordance with the above provisions shall be deemed received on the third day after
posting.
LANDLORD:
Esprit Enterprises,LLC
by.: Date:
Teresa Karupiah
Member
TENANT: �
CDS Ston Ri ge Utilities, !LC-Water
I
1 \
' -Q �- J
gY Date
Chan Karupiah
Member
12 Holiday Loop&364 StoneRidge Road Office Lease-Final
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 102

Exhibit M: Sewer Office Space Lease (io fto)
Original
Page 5 of 5
Exhibit A
Effective 1/1/2020
Supplemental Services to Be Provided by Landlord
In exchange for rental payments described in the"Lease Payments"section, Landlord agrees to provide
the following,at Landlords sole expense the following to Tenant:
1. Telephone system and monthly telephone service,including long-distance calls only for water
company lines.
2. Alarm Service-24-hour coverage.
3. Internet Service for Event Center office lines only
4. Janitorial services weekly,bathrooms,and office space
5. IT Support Technician
6. Landscaping per landlord schedule
7. Power,water,sewer,propane,garbage
8. Parking and snow maintenance(plow when 3+inches new snow)
9. Furnishings in place
10. Office supplies&office equipment
11. Casualty and liability insurance coverage as recommended by Philadelphia Insurance
12. Pest Control Services per vendor recommended schedule.
12 Holiday Loop&364 StoneRidge Road Office Lease-Final '
TK�
CK
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 103

Exhibit N: Decision Memorandum Compliance Filing from CDS StoneRidge
Utilities, LLC Happy Valley Surcharge (1/8)
DECISION MEMORAND11M
TO: COMMISSIONER KJELLANDER
COMMISSIONER REDFORD
COMMISSIONER SMITH
COMMISSION SECRETARY
LEGAL
WORKING FILE
FROM: CHRIS HECHT
DATE: FEBRUARY 17,2015
RE: COMPLIANCE FILING FROM CDS STONERIDGE UTILITIES LLC
REQUESTING TO MODIFY ITS TARIFF IN ACCORDANCE
WITH ORDER NO,30342
On January 21,2015,the Commission rcccived a request from CDS Stoneridge Utilities
LLC(Stoncridge)to revise the surcharge applied to customers who live within the Happy Valley
Ranchos Subdivision. The request is to revise the surcharge from$16.83 to S 14.d3. The
Company also requests that the name on its tariff be changed to CDS Stoneridge Utilities LLC tt
be consistent with the utility name as reflected on its Certificate of Public Convenience and
Necessity(CPCN No.395)issued January 2,2004.
BACKGROUND
Surcharge Amount
CDS Stoneridge Utilities,LLC obtained a loan from the State Drinking Water Revolving
Fund to provide service to 107 customers in the I lappy Valley Ranchos Subdivision. In Case
No.S WS-W-06.01,Order No.30342,the Commission authorized collection of the Phase 1 loan
amount of S278,000 from customers located in the Happy Valley Ranchos Subdivision through.
surcharge of$16.83 per month for a period of live years. The surcharge would then be reduced
to S 14.03 per month for another 15 years.
Due to an oversight on the part of the Company,the surcharge was not reduced after the
first live years. In October 2014,a Staff review of approved surcharges determined that the taxi
schedule had not been changed and that the Company was stilt billing the customers in Happy
DECISION MEMORANDUM 1 - FEBRUARY 17,201.5
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 104

Exhibit N: Decision Memorandum Compliance Filing from CDS StoneRidge
Utilities, LLC Happy Valley Surcharge Cont. (2/8)
Valley Ranchos at the S1+6.83 per month rate. When contacted by the Commission Staff,the
Company began billing Happy Valley Rancho customers the reduced surcharge ofS14.03
starting with time November 1,2014 billing statement,prior to submission of the revised tariff:
An audit by Staff"indicates that the Company has over-collected the surcharge for about
two years, The over collection will reduce the amount of time to collect the loan amount from
twenty(20)years to less than eighteen(18)years. Staff%till monitor collection of the surcharge
and determine when the loan amount has been recovered and the surcharge should end.
Staff commends the Company for promptly cor4ecting the problem when it was brought
to its attention. Because the Company is already billing customers at the reduced amount,the
effective date of the tariff will need to be retroactive to November 1,2014 to reflect the
Company's actions.
If the Company should apply for a rate increase between now and the date the loam is
paid off,the over-collection of surcharge funds will be taken into Consideration.
Name Change on Tariff
The Company also requested a change in the name of the Company to CDS Stoneridge
Associates Land,LC,dba StoneRidge Utilities, The Company's current tariff submitted by the
Company in Case No.SWS-W-06-01,incorrectly identified the Company's name as CDS
Stoneridge Associates Land LC dba Stoneridge Water Company. However,the Company
name as reflected on its Second Amended Certificate of Public Convenience Necessity No.
395,issued January 2,2004,is CDS Stoneridge Utilities LLC. The Idaho Secretary of State also
lists the Company's name as CDS Stoneridge Utilities,LLC.
Staff discussed this issue with the Company,and clarified that it wanted to change the
name on its tari ffto CDS'Stoneridge Utilities LLC to be consistent with its Cif- Staff
recommends approval of modifying the Company's tariff to reflect its correct name.
STAFF REC[lMMENDATION
Staff recommends that the surcharge for customers in the Happy Valley Rancho
Subdivision be reduced from S16.$3 to S14,03 per month. Staff recommends that the
Commission approve the revised tariff, including the name change discussed above,as submittei
by the Company,with an effective date of November 1,2014.
DECISION MEMORANDUM -2- FEBRUARY 17,201 S
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 105

Exhibit N: Decision Memorandum Compliance Filing from CDS StoneRidge
Utilities, LLC Happy Valley Surcharge Cont. (3/8)
COMMISSION DECISION
Does the Commission wish to accept the Company's request to reduce its surcharge to
$14.03 with an effective date of November 1,2014? Does the Commission accept the revised
tariff to reflect the Company's name as CDS StoneRidge Utilities,LLC?
Chris Hecht
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[DECISION MEMORANDUM -3• FEBRUARY 17, 2015
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - w6

Exhibit N: Decision Memorandum Compliance Filing from CDS StoneRidge
Utilities, LLC Happy Valley Surcharge Cont. (4/8)
1DAHO PUBLIC UTtIN<.MES COMMISSION
MINUTES OF DECISION MEETING
February 23,2015--1:30 P.M.
In attendance were Commissioners Paul Kjellandc r, Mack Redford and Kristine Raper.
Commissioner Kjellander called the meeting to order.
The first order of business was APPROVAL OF MINUTES FROM PREVIOUS MEETING
on Monday, February 9,2015. The Commission voted unanimously to approve the minutes as
written.
The second order of business was approval of the CONSENT AGENDA:
2. Chris Hecht's February 17,2015 Decision Memor rindum re: Compliance Filing from
CDS Stoneridge Utilities LLC Requesting to Modify Its Tariff'in Accordance with Order
No.30342.
3.Daphne Iluang's.February 19, 2015 Decision Memorandum re: PacifiCorp's Application
for Approval of the First Amendment to Its Power Purchase Agreement with St.Anthony
Hydro,L1,C,Cast No. PAC-F-I."2
4.Don Howell's February 13,2015 Decision Memorandum re: -New Contracts for the
Administrator of the USF and ITSAP Programs.
5. Karl Kleiu's February 20,2015 Decision Memorandum re: Idaho Power's Application
for Approval of New Schedule 82(flex Peak Program),Case No.IPC-E-15-03.
G. Neil Pri+ee's February 20,2015 Decision Memorandum re: Rocky Mountain Power's
Application for Authority to Increase Rates by$10.7'Million to Recover'6Deferred Ket
Power Costs through the Energy Cost Adjustment Mechanism(ECAM),Case No.PAC-E-
15-01.
Commissioner Kjellander welcomed Commissioner paper to the Commission. Regarding item
b, Commissioner Raper asked Mr. Price about scheduling for the case because of the requested
effective date of April 1, Mr. Price replied that the schedule will take into consideration the
effective date, with comments being due Match 13. Ile stated there will also be time for reply
conuncnts as well.
Regarding item 4,Commissioner Redford asked if there is a rNuircment to bid the contract
compctitivcly. Commissioner Kjcllander replied that there is no requirement to do a routine
competitive bid.
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - ion

Exhibit N: Decision Memorandum Compliance Filing from CDS StoneRidge
Utilities, LLC Happy Valley Surcharge Cont. (5/8)
There was no further discussion and Commissioner Kjallander made a motion to approve Staffs
recommendations for items 2 through 6 on the Consent Agenda. A vote was taken on the motion
and it carried unanimously.
There was no further business before the Commission and Commissioner Kjellandcr adjourned
the meeting.
COMM SSICN SECRETARY DATE OF APPROVAL
2
CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - 1o8

Exhibit N: Email Exchange with Commission Staff April 2024 Regarding Their
Monitoring of the Surcharge Collection (6/8)
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - log

Exhibit N: Email Exchange with Commission Staff April 2024 Regarding Their
Monitoring of the Surcharge Collection Cont. (7/8)
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - no

Exhibit N: Email Exchange with Commission Staff April 2024 Regarding Their
Monitoring of the Surcharge Collection Cont. (8/8)
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CDS STONERIDGE UTILITIES, LLC'S REPLY TO COMMENTS - ill

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 7 Cday of October 2024, I caused to be served
a true and correct copy of the foregoing document to the below individuals as follows:
® Email Commission Secretary
Idaho Public Utilities Commission
P.O. Box 83220
Boise, ID 83720-0074
[e-mail]
® Email Norman Semanko, ISB #4761
Patrick M. Ngalamulume, ISB #11200
Parsons Behle &Latimer
Boo W. Main Street, Suite 1300
Boise, ID 83702
[e-mail]
[e-mail]
Attorneys for Stoneridge Property Owners
Association
® Email Brady Espeland
Ramsden, Marfice, Ealy&De Smet, LLP
PO Box 1336
Coeur d'Alene, ID 83816-1336
[e-mail]
[e-mail]
Attorney for Condominium Owners
Association,Inc.
® Email Michael Duval
Deputy Attorney General
P.O. Box 83720
Boise, ID 83720-0074
[e-mail]
Attorney for Commission Staff

® Email Randolph Lee Garrison
76 Bellflower Court
Blanchard, ID 83804
[e-mail]
ASON T. PISKEL