20251231Staff 1-34 to SWS.pdf

RECEIVED
December 31, 2025
JEFFREY R. LOLL IDAHO PUBLIC
DEPUTY ATTORNEY GENERAL UTILITIES COMMISSION
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83702
[phone]
IDAHO BAR NO. 11675
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS STONERIDGE )
UTILITIES,LLC'S APPLICATION FOR ) CASE NO. SWS-W-25-02
AUTHORITY TO INCREASE ITS RATES )
AND CHARGES FOR WATER SERVICE IN )
THE STATE OF IDAHO ) FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF
TO CDS STONERIDGE
UTILITIES,LLC
Commission Staff("Staff') of the Idaho Public Utilities Commission("Commission"),
by and through its attorney of record, Jeffrey R. Loll, Deputy Attorney General, requests that
CDS Stoneridge Utilities, LLC ("Company")provide the following documents and information
as soon as possible, but no later than WEDNESDAY,JANUARY 21, 2026. All responses
should be filed with the Commission Secretary at [e-mail].
This Production Request is to be considered as continuing, and the Company is requested
to provide,by way of supplementary responses, additional documents that it, or any person
acting on its behalf, may later obtain that will augment the documents or information produced.
Please provide answers to each question, supporting workpapers that provide detail or are
the source of information used in calculations, and the name,job title, and telephone number of
the person preparing the documents. Please also identify the name,job title, location, and
telephone number of the record holder.
In addition to the written copies provided as response to the requests, please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 1 DECEMBER 31, 2025

REQUEST NO. 1: Please provide the most current depreciation schedule for each
capital asset in Excel format with formulas intact. The schedule should include the following
information for each asset:
a. Date asset was placed into service;
b. Original cost of the asset;
c. Depreciable life;
d. Any changes to the depreciable life, including the effective date of such changes;
e. Accumulated depreciation; and
f. Net Plant in Service.
Please provide supplemental responses as updated information becomes available.
REQUEST NO. 2: For all expenses listed in Attachment K, please provide detailed
calculations, in Excel format with formulas intact, of all hardcoded amounts.
REQUEST NO. 3: For all expenses listed in Attachment K, please provide a transaction
detail report, or general ledger listing that includes each individual transaction. For each
transaction,please include the transaction date, amount, and a brief description.
REQUEST NO. 4: Please provide an Excel spreadsheet for calendar years 2023 through
2025 that lists and calculates the following information for each employee:
a. Job title and description;
b. Wage increases during the period;
c. The justification for each wage increase; and
d. Year-end salary for each year.
REQUEST NO. 5: Please provide a copy of the most current loan document for all
loans, which lists the amount withstanding and annual interest rate.
REQUEST NO. 6: Please provide the labor contract as mentioned in Attachment V on
page 153 of the Application.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 DECEMBER 31, 2025

REQUEST NO. 7: Please provide a copy of the office rental agreement and the most
current invoice supporting the new office rental rate listed in Attachment V on page 154 of the
Application.
REQUEST NO. 8: Please explain the basis for the compliance officer receiving free
rent and utilities for the past five years, as identified in Attachment V on page 154 of the
Application.
REQUEST NO. 9: Please provide calculations, in Excel format with formulas intact, for
the Rate Case Cost Expense requested as shown in Attachment V on page 155 of the
Application.
REQUEST NO. 10: Please provide copies of all invoices for rate case expenses
incurred to date for services performed in this case. Please provide supplemental responses as
additional invoices become available.
REQUEST NO. 11: Please explain why an amortization of 30 months was chosen for
the amortization period of rate case expenses.
REQUEST NO. 12: Please provide documentation demonstrating that the golf course
has constructed its own well and no longer requires water service from the Company.
REQUEST NO. 13: Please provide the monthly power bills indicating the amount of
electricity(kWh)used and corresponding electricity cost (in US Dollars) for each well and
booster pump from January 2024 through December 2025. Please provide your responses in
Excel format with formulas intact.
REQUEST NO. 14: Please provide the monthly metered amount of water(in gallons)
pumped from each well from January 2024 to December 2025. Please provide your responses in
Excel format with formulas intact.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 DECEMBER 31, 2025

REQUEST NO. 15: Please provide the monthly metered total customer water usage
data(in gallons) for each customer-by-customer type from January 2024 through December
2025. Please identify the service type, account number, route number, actual meter size, and
billed meter size for each customer. Please provide your responses in Excel format with
formulas intact.
REQUEST NO. 16: Please provide an estimate of total unaccounted water losses due to
leaks, wasted water, etc. by month from January 2024 through December 2025. Please provide
your responses in Excel format with formulas intact.
REQUEST NO. 17: Please provide the total monthly amount of Chlorine used(in
pounds), and total expense for Chlorine purchased(including Sales Tax) for each well from
January 2024 to December 2025. Also please specify whether a solid or liquid form of Chlorine
was used for each well. Please provide your responses in Excel format with formulas intact.
REQUEST NO. 18: Please provide the average monthly pressure data in the main
distribution line from January 2024 through December 2025. Please provide your responses in
Excel format with formulas intact.
REQUEST NO. 19: Please describe the Company's methodology for developing,
managing, executing, and completing Capital Projects in a least cost manner. Please provide a
copy of all Company policies and procedures documenting the process.
REQUEST NO. 20: In reference to the Idaho Department of Environmental Quality
("IDEQ") Sanitary Survey conducted on July 17, 2025, please provide the Company's Corrective
Action Plan to address the five significant deficiencies and one deficiency that require a
Corrective Action Plan identified in the Sanitary Survey. In addition,please provide all
correspondence or documents produced from consulting with IDEQ on these deficiencies.
REQUEST NO. 21: In reference to the Idaho Department of Environmental Quality
Sanitary Survey conducted on July 17, 2025, please provide the Company's plan to address the
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 4 DECEMBER 31, 2025

three deficiencies and the six recommendations identified in the Sanitary Survey. In addition,
please provide all correspondence or documents produced from consulting with IDEQ on these
deficiencies and recommendations.
REQUEST NO. 22: On page 151 of the document attached with the Application, the
Company discusses known changes from the test year for Cap Ex. Investments. Please provide
the following information for the Investment in back up power for Well #1 ($202,400). If any of
the information requested below cannot be provided or is not available,please explain why.
a. Please provide the number of times the Company's system has depressurized to a
point of a health hazard due to a power outage. For each event, please provide details
for each event such as,but not limited to,power outage date and duration, distribution
system pressure levels, and the Company's corrective actions.
b. Please provide the Company's evaluation of standby power versus additional storage
facilities to address the inability to adequately pressurize the system during a power
outage.
c. The July 17, 2025, IDEQ Sanitary Survey listed the inability to adequately pressurize
the system during a power outage as "Other Deficiencies"that must be corrected
when feasible or during modifications of existing processes or facilities. Please
explain the Company's justification for prioritizing this project to be completed in
2026 over other projects, such as the midlevel storage tank lid repair scheduled for
2027 in the Company's Capital Plan, which was identified as a significant deficiency
in the Sanitary Survey.
d. Explain how the Company will ensure the project is completed at least cost.
e. Please provide the proposed detailed project schedule, including expected start and
completion dates.
f. Please provide any additional quotes or estimates obtained for the project. If
additional quotes have not been obtained, please explain why not.
REQUEST NO. 23: On page 151 of the document attached with the Application, the
Company discusses known changes from the test year for Cap Ex. Investments. Please provide
the following information for the Company's reservoir water tank—Clean and Inspect Tank
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 5 DECEMBER 31, 2025

Project($12,260). If any of the information requested below cannot be provided or is not
available,please explain why.
a. Please provide the proposed detailed project schedule including expected start and
completion dates.
b. Please provide any additional quotes or estimates obtained for the project. If
additional quotes have not been obtained, please explain why not.
REQUEST NO. 24: On page 151 of the document attached with the Application, the
Company discusses known changes from the test year for Cap Ex. Investments. Please provide
the following information for the Company's Reservoir Water Tank Bypass Preliminary
Engineering Project($4,950). If any of the information requested below cannot be provided or is
not available, please explain why.
a. Please provide the proposed detailed project schedule including expected start and
completion dates.
b. Please provide any additional quotes or estimates obtained for the project. If
additional quotes have not been obtained, please explain why not.
REQUEST NO. 25: On page 153 of the document attached with the Application, the
Company discusses known changes from the test year for Revenue. Please provide the following
information for the Golf Course Termination of Irrigation Account(-$65,744). If any of the
information requested below cannot be provided or is not available, please explain why.
a. Please explain why the golf course used 50,657,900 gallons in 2024, which is higher
than the historical annual average golf course consumption from 2022-2023, when the
golf course installed a new well in October 2023 to help provide irrigation water and
reduce the amount of water provided by the Company.
b. Please explain why the golf course has a 6"meter when the Company changed out
the 6"meter for a 1.5"meter in 2024.
c. Please explain if the golf course meter was turned off during any months of the test
year(12 months ending 9/30/2025). If so,please explain why and provide the months
the meter was turned off.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 6 DECEMBER 31, 2025

d. Please provide the monthly water consumption for the golf course for the test year(12
months ending 9/30/2025).
e. Please provide all bills and paid receipts for the golf course during the test year (12
months ending 9/30/2025).
f. Please provide an update on the status of the installation of the new 10"well for the
golf course and the expected date the golf course will be completely disconnected
from the Company's water system.
REQUEST NO. 26: Please explain if the Company expects customer growth. If so,
please provide workpapers and documentation including but not limited to the potential number
of customers and type of customers by year for the next five years.
REQUEST NO. 27: Please provide actual monthly water usage broken out by customer,
from 10/1/2024 through 9/30/2025 in Excel format with formulas enabled.
REQUEST NO. 28: In relation to the backup power generator for Well#1 and Well #3,
please provide the following: (1) copies of all bids received for the installation and the generator;
(2) a statement explaining the rationale used to determine the bid selected; and(3) a copy of the
contract selected for the work that includes, if applicable, any amendments or modifications to
the contract.
REQUEST NO. 29: Please provide the estimated cost savings associated with the
termination of the golf course irrigation account, in addition to the annual reductions in
electricity and chemical expenses. Specifically, please identify any additional operation or
maintenance savings, including but not limited to reductions in maintenance labor hours, changes
in Company staff requirements, or the addition of equipment or materials to inventory.
REQUEST NO. 30: Please provide copies of all loan agreements,promissory notes, and
any related amendments or modifications between the Company and Esprit. Please provide a
loan activity schedule for each loan showing the original principal amount, interest rate, payment
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 7 DECEMBER 31, 2025

dates, payment amounts, and the outstanding balance. Please provide the loan activity
schedule(s) in Excel format with formulas intact.
REQUEST NO. 31: Please provide a complete copy of the Company's IDEQ sanitary
survey conducted on July 17, 2025.
REQUEST NO. 32: Please provide a copy of the corrective action plan submitted to
and accepted by IDEQ in response to the Company's sanitary survey conducted on July 17,
2025.
REQUEST NO. 33: Please refer to Company Exhibit 5C, Rate Analysis and Proof of
Revenue. Please explain how the Company calculated or determined the Volumetric Factor for
the different meter sizes served by the Company.
REQUEST NO. 34: Please refer to Company Exhibit 2A, Gross Revenues.
a. Please explain how the Company calculated the $37,039 of revenue in Row 2,
Column B; and
b. Please explain the source of"Other Water Sales Revenue" shown in Row 5.
DATED at Boise, Idaho, this 31st day of December 2025.
Jeffrey- R. Loll
Deputy Attorney General
I:\Utility\UMISC\PRDREQ\SWS-W-25-02 PR#l.docx
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 8 DECEMBER 31, 2025

CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE THIS 31 st DAY OF DECEMBER 2025,
SERVED THE FOREGOING FIRST PRODUCTION REQUEST OF THE
COMMISSION STAFF TO CDS STONERIDGE UTILITIES,LLC, IN CASE NO.
SWS-W-25-02, BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
KYLE KARUPIAH, OFFICE SECRETARY
CDS STONERIDGE UTILITIES, LLC
P.O. BOX 280
BLANCHARD, ID 83804
E-MAIL: utilitieskstoneridgeidaho.com
Attorney for CDS StoneRidge Utilities,LLC
Jason T. Piskel
Piskel Yahne Kovarik, PLLC
612 W. Main Ave., Suite 207
Spokane, WA 99201
E-MAIL: jpiske1gpyklawyers.com
PATRICIA JORDAN, SECRETARY
CERTIFICATE OF SERVICE