20241106STAFFS MOTION TO ACCEPT CORRECTION.pdf

RECEIVED
2024 November 6
IDAHO PUBLIC
MICHAEL DUVAL UTILITIES COMMISSION
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
[phone]
IDAHO BAR NO. 11714
Street Address for Express Mail:
11331 W CHINDEN BLVD, BLDG 8, SUITE 201-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS STONERIDGE ) CASE NO. SWS-W-24-01
UTILITIES,LLC'S APPLICATION FOR )
AUTHORITY TO INCREASE ITS RATES AND) COMMISSION STAFF'S MOTION
CHARGES FOR WATER SERVICE IN THE ) TO (1) ACCEPT THE
STATE OF IDAHO ) CORRECTION OF A
CALCULATION ERROR; AND (2)
ALLOW THE COMPANY TIME
TO COMMENT ON THE
CALCULATION ERROR
The Commission Staff("Staff') of the Idaho Public Utilities Commission, by and through
its attorney of record, Michael Duval, Deputy Attorney General, submits the foregoing motion to:
(1) accept the correction of a calculation error; and(2) allow the company time to comment on the
calculation error.
PROCEDURAL BACKGROUND
On February 28, 2024, CDS Stoneridge Utilities, LLC ("Company" or "Stoneridge")
applied for authorization to increase its rates and charges for water service ("Application"). The
Company made a separate supplemental filing requesting an April 1, 2024, effective date.I
' In its Application the Company initially requested a July 1,2024,effective date.See Application Attachment G.
COMMISSION STAFF'S MOTION TO(1)ACCEPT THE CORRECTION OF A CALCULATION ERROR;
AND(2)ALLOW THE COMPANY TIME TO COMMENT ON THE CALCULATION ERROR
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On March 13, 2024, the Idaho Public Utilities Commission ("Commission") issued a
Notice of Application, Notice of Intervention Deadline, and Notice of Suspension of Proposed
Effective Date. Order No. 36116. The Stoneridge Property Owners Association, Inc. ("SPOA"),
the Stoneridge Recreational Club Condominium Owners Association, Inc. ("SRCCOA"), and an
individual, Randolph Garrison, pro se, petitioned to intervene (collectively the "Intervenors").
Order Nos. 36144 and 36163.
On September 13, 2024, the Commission issued an order establishing an October 2, 2024,
Staff comment deadline, an October 16, 2024, Intervenor comment deadline, and an October 30,
2024, Company reply deadline. Order No. 36323.
On October 2, 2024, Staff filed comments recommending a 27.1% increase leading to a
proposed revenue requirement of$292,795.
DISCOVERY OF A CALCULATION ERROR
After Staff's comments were submitted, a calculation error was discovered in its proposed
revenue requirement. Staff noticed that the Company used the same model to determine its
proposed revenue requirement which it based its reply comments on. In Attachment A to Staff's
Comments,the formula in Cell GI references Cell G1I which contains the Net Operating Income
Deficiency, and not cell G17 which is the Revenue Needed to Overcome Loss.
Correcting this error reduces Staff's proposed revenue requirement by $21,682 to
$271,113effectively reducing Staff's 27.1%proposed increase to 17.6%. This correction is not
a new adjustment being proposed by Staff, but instead corrects the gross calculation. Fixing this
same error in the Company's model would reduce its proposed revenue requirement by$26,646 to
$450,546—effectively reducing the Company's 124.3%to 111.7%.
Staff believes that Staff's recommendation should be updated to account for the error
resulting in a 17.6% overall rate increase and a revenue requirement of$271,113. However, Staff
and the Intervenors believe that the Company should have until November 13, 2024, to submit
written comments on this matter—as the issue was not known at the time that the Company
submitted its reply comments.
Staff requests expeditious consideration of this matter. Staff notified the Parties that it
planned to file the Motion and requested expeditious consideration of its Motion pursuant to
Commission's Rule of Procedure 256. I DAPA 31.01.01.256.03.
COMMISSION STAFF'S MOTION TO(1)ACCEPT THE CORRECTION OF A CALCULATION ERROR;
AND(2)ALLOW THE COMPANY TIME TO COMMENT ON THE CALCULATION ERROR
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REQUEST FOR EXPEDITIOUS RELIEF
Staff requests that relief be granted in this matter on fewer than fourteen(14) days' notice
pursuant to Commission Rule of Procedure 256. IDAPA 31.01.01.256.02.b. This rule requires that
the moving party provide the other parties actual notice "by telephone or personal delivery of the
motion."IDAPA 31.01.01.256.02. Staff has personally communicated the contents of this motion
by telephone to all Parties; Staff spoke with the Company's counsel, Mr. Garrisson, and the
SRCCOA. Staff also communicated via email with SPOA. All Intervenors have directly voiced
support of the proposed action. Staff thus believes that Staff has fulfilled its notice requirements
under Rule 256. Under Rule 256, the parties can inform the Commission secretary "whether they
desire to be heard on the motion in person, in writing or by telephone."Id.
Given that notice of the correction and subsequent extra reply comment period was
provided to all Parties on November 4, 2024, Staff believes that the Commission may rule on this
matter on November 7, 2024.
CONCLUSION
NOW THEREFORE, Staff respectfully requests that the Commission issue an order:
1. Accepting Staff's new position, due to the correction of the error discussed above;
2. Allowing the Company to file reply comments by November 13,2024,providing that such
comments are narrowly tailored to its position related to the error discussed above; and
3. Provide expeditious consideration of this matter under IDAPA 31.01.01.256.
Respectfully submitted this 6th day of November 2024.
Michael Duval
Deputy Attorney General
I:\Legal\WATER\S W S-W-24-01_rates\S W S W 2401_motion2_md.do cx
COMMISSION STAFF'S MOTION TO(1)ACCEPT THE CORRECTION OF A CALCULATION ERROR;
AND(2)ALLOW THE COMPANY TIME TO COMMENT ON THE CALCULATION ERROR
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CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 6TH DAY OF NOVEMBER 2024,
SERVED THE FOREGOING COMMISSION STAFF'S MOTION TO (1)ACCEPT THE
CORRECTION OF A CALCULATION ERROR; AND (2) ALLOW THE COMPANY
TIME TO COMMENT ON THE CALCULATION ERROR, IN CASE NO. SWS-W-24-
01, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
CHAN KARUPIAH JASON T PISKEL
MANAGING PARTNER PISKEL YAHNE KOVARIK PLLC
CDS STONERIDGE UTILITIES, LLC 612 W MAIN AVE, STE 207
P.O. BOX 298 SPOKANE WA 99201
364 STONERIDGE ROAD jpiskel(&]2yklawyers.com
BLANCHARD, ID 83804
chansan(a,comcast.net
utilities(a,stoneridgeidaho.com
jeffkmerkeley.com
RANDOLPH LEE GARRISON,PRO SE NORMAN M SEMANKO
76 BELLFLOWER CT. PATRICK M NGALAMULUME
BLANCHARD, ID 83804 PARSONS BEHLE &LATIMER
garrison( nngarrison.com 800 W MAIN ST STE 1300
BOISE ID 83702
nsemanko(acrc parsonsbehle.com
pn galamulume(a),parsonsbehle.com
BRADY L ESPELAND
RAMSDEN, MARFICE, EALY&DE SMET, LLP
700 NORTHWEST BLVD.
P.O. BOX 1336
COEUR D'ALENE, ID 83816-1336
bespelandgrmedlaw.com
KERI J. HAWKER
Legal Assistant to Michael Duval
COMMISSION STAFF'S MOTION TO(1)ACCEPT THE CORRECTION OF A CALCULATION ERROR;
AND(2)ALLOW THE COMPANY TIME TO COMMENT ON THE CALCULATION ERROR
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