20260115Petition to Intervene.pdf

Randolph Lee Garrison, Pro Se RECEIVED
76 Bellflower Ct January 15, 2026
Blanchard Idaho 83804 IDAHO PUBLIC
UTILITIES COMMISSION
[phone]
e-mail: qarrison(@rmgarrison.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
Case No.: SWS-W-25-02
IN THE MATTER OF CDS STONERIDGE
UTILITIES, LLC'S APPLICATION FOR PETITION TO INTERVENE
AUTHORITY TO INCREASE ITS RATES AND
CHARGES FOR WATER SERVICE IN THE STATE
OF IDAHO
PETITION FOR INTERVENTION: Randolph Lee Garrison, Pro Se, hereby petitions the IPUC Commission for an
order granting his Intervention to become a party and participate fully in the matter of CDS Stoneridge Utilities, LLC's
(Applicant)Application for Authority to Increase its Rates and Charges for Water Service in the State of Idaho(Case No.
SWS-W-25-02). This Petition is made pursuant to the Rules of Procedure of the Idaho Public Utilities Commission,
IDAPA 31.01.01 et seq, and the Notice of Application/Notice of Suspension of Proposed effective date/Notice of
Intervention Deadline/IPUC Order No. 36896, issued 31 December 2025.
(1) ADDRESS: The address and Name of this Petitioner is:
Randolph Lee Garrison, Pro Se
76 Bellflower Ct
Blanchard Idaho 83804
[phone]
e-mail: garrison(aD_rmgarrison.com
(2) No ATTORNEY: Randolph Lee Garrison is not represented by counsel. All notices, correspondence, pleadings,
filings, or other communications should be directed to him at the address above.
PETITION TO INTERVENE—Page 1 of 8

(3) STANDING AND IMPACT: Randolph Lee Garrison is a customer of the Applicant. He owns property within
Stoneridge, one of the service areas of the Applicant, CDS Stoneridge Utilities. He is opposes and responds
to the proposed rate increase requested by the Applicant,CDS Stoneridge Utilities. He is significantly impacted
the proposed 43%increase revenues,which includes a 37.61%increase for 1/"meters(from$28.85 to$39.70,
per month). If Stoneridge's Application is granted as proposed, his water rates will increase by 43% (Notice of
Application at pages 1). Garrison intends to show the IPUC Commission that the proposed increase is unjust
and unreasonable and is not be supported by the evidence.
(4) SUBSTANTIAL INTEREST: As such, Randolph Lee Garrison has a direct and substantial interest in the outcome
of the Application pursuant to IPUC Rule 74. Garrison seeks intervention as a full party,to participate regarding
the issues before the Commission, including those presented by the Application, including all attachments and
exhibits thereto,the Notice of Application,and in written comments submitted to the Commission. Randolph
Lee Garrison's intervention will not unduly broaden the issues, as required by IPUC 74.
(5) TIMELY FILED: A petition to intervene is timely, if it is filed by the time provided by order or notice of the IPUC
Commission in accordance with RP 73. The Commission has set an intervention deadline of"not later than
twenty-one (21) days after the service date of this Order", case#SWS-W-25-02. As a result, this petition to
intervene is timely filed.
(6) No PREJUDICE OR BURDEN ON OTHER PARTIES: Randolph Lee Garrison's intervention will allow for active
participation in all aspects of these proceedings, as necessary to protect his interests and to demonstrate that
the proposed rate increase is unjust and/or unreasonable and not supported by the evidence. His intervention
will not disrupt the proceedings, prejudice the parties, or unduly broaden the issues. Garrison was allowed to
intervene in the previous rencent general water rate increase case filed by applicant(see order#36144, case
#SWS-W-24-01, 16 April 2024). The issues presented by and interests of Garrison in Intervention will not be
adequately protected or advanced by other interveners. See also preliminary Statement of issues below.
(7) Preliminary Statement of Issues: The application presents 3 primary reasons forjustifying a water rate increase:
(a) Applicant claims: "Stoneridge Water has a loan from DEQ that is currently in default that was not
addressed in its last rate case."Application, pg 3.
Answer: The IDEA loan (Happy Valley) has been already addressed in case SWS-W-06-01 and the
PETITION TO INTERVENE—Page 2 of 8

IPUC Order (# 36522, 24 March 2025). Because the loan had been paid, the IPUC ordered
discontinuing further collection of the loan from Happy Valley customers, effective April 2025.
Specifically, the IPUC Commission ordered:
(a) " . . . having determined that the requisite amount will be collected earlier than originally
estimated, the Commission finds it fair,just, and reasonable to order the Company to cease
collections of the surcharge currently being charged to the Happy Valley Ranchos Subdivision
customers after the Company' s April 2025 billing cycle."And therefore,
(b) "IT IS HEREBY ORDERED that the Company shall cease collections of the surcharge to
the Happy Valley Ranchos Subdivision customers after the Company' s April 2025 billing."
The Application at page 156 has a number of additional comments. The Application fails to mention
and completely ignores the(unappealed)final order in Case#SWS-W-06-01 stating the loan had been
paid and no further collection should be made.
(b) Next Applicant claims: "Additionally,the neighboring Stoneridge Golf Course has constructed its own
well and therefore no longer relies upon purchasing water from Stoneridge Water Company to service
its large hydrological needs.Water purchased from Stoneridge Golf Course accounted for nearly 40%
of all water sold, and thus rates must be adjusted to account for the deficit so the Company can
continue to service its existing obligations."
Answer: The Utility represented and claimed exactly the opposite position in the prior rate case. For
example: The Utility claimed the net loss of revenue cause by no longer serving the golf course would
be only$6,148.59. Applicant should be Judicially Estopped from claim differently in this proceeding.
See:
"REQUEST NO. 3 [in prior case # case # SWS-W-24-01]: Please provide the costs and
benefits to the system and a narrative to explain why it is necessary for the golf course to be
on its own well, as is stated in Exhibit No. 2, Schedule A.
Applicant's Answer: Any and all customers have the choice to procure water from Stoneridge
Utilities or any other source of their choosing. The primary cost/benefit to the water company
of no longer serving the golf course's irrigation demand,is that the wear and tear on the system
PETITION TO INTERVENE—Page 3 of 8

is reduced. Specifically unexpected breakdowns are less likely. In addition, since the golf
course was on an interruptible contract they paid less for usage than all other customers. The
estimated loss off net revenue is $6,148.59 per the attached Request#4 narrative."
Case # SWS-W-24-01 -StoneRidge Water Company General Rate Case; First Production
Request NO. 3
In the subsequent narrative attached to Response to Request No. 4, the Utility went to great
lengths to justify their$6,148.59 figure:
"StoneRidge Utilities, LLC,
Known Change for Loss of Golf Course Irrigation Sales
Overview: In 2023 4`"Quarter,StoneRidge Golf completed installation of a new water
well and connected this well and supply lines to the golf course's existing water
distribution system that provides all irrigation water to the 18-hole StoneRidge Golf
Course in Blanchard, ID. The Golf Course's 6" irrigation meter was turned off in
October 2023.
In 2023 the 6"meter used 46,548,200 gallons of waterfor the golf course irrigation. For
this
water usage the Golf Course paid $15,360 in monthly minimum fees and $33,049.23
in usage
fees (.71/1,000 gallons). So golf course irrigation used 41.96% of the annual system
volume and paid 16.81% percent of the system revenue.
Removing the golf irrigation meter from the system will reduce total annual revenue by
$48,409.
This change will also reduce the electrical bills by the following amount:
1.$18,882.65 for meter 50867 that provides power to the golf irrigation system pumps
PETITION TO INTERVENE—Page 4 of 8

Only 2. $10,728 for meter 52940 which provides power to the two well pumps that
provide
Water to the entire system ($26,820.34 X 41.96% = 10,728.00 reduction power).
Combining the$18,883.65+$10,728.00 results in a reduction of$29,611.65(58.61%)
in annual power costs with golf irrigation removed vs $50,520.90 actual cost in
2023—i.e.
projected 2024 power costs would be $20,639.25.
And lastly chlorine costs in 2023 were $14,653.47. This is projected to drop by
$6,148.59 (41.96%)to$8,504.88 in 2024.
To list:
Reduction Golf Irrigation Revenue $48,409.00
Reduction in Golf Irrigation Pump Power exp 18,882.65
Reduction in Inland Power Well Pump Power exp 10,728.00
Reduction in Chlorine Expense $6148.59."
(c) Next, Applicant contends: "Applicant believes its proposed increase in rates and charges is justified
due to the urgent need to address significant system deficiencies noted by the Department of
Environmental Quality(DEQ)in its sanitary surveywhich could affect utility service and system up time.
Such safeguards include the installation of a backup power unit at the primary well house, ensuring
constant water availability regardless of outside disturbances, and professional cleaning of water
storage tanks, ensuring public health is protected. Application, pg 2.
Comment: Backup power was specifically addressed in the prior proceeding. For example: The
Commission's final order stated: "Concerns were expressed over the infrastructure of the system,the
systems' lack of back-up power in the event of an outage, and the inability to fight fires during an
outage." Case#SWS-W-24-01, Order#36407, filed 29 November 2024, page 28.
PETITION TO INTERVENE—Page 5 of 8

The issue of"back up power should be a capital expense and capitalized, not a rate payer expense.
For the above reasons, Randolph Lee Garrison's petition to intervene should be granted in this matter and fully
participate in all aspects of the proceedings regarding the Application filed by the Applicant.
DATED and Signed this 15th day of January, 2026.
Fail 4ph Lee Oemrlfon
Randolph Lee Garrison, Pro Se
PETITION TO INTERVENE—Page 6 of 8

CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 15th day of January, 2026, 1 served a true and correct
copy of the foregoing upon each party in this matter by delivering the same to each of the
following individuals by the method indicated below, addressed as follows:
Michael Duval by e-mail only:
Jeffrey R. Loll [e-mail]
Deputy Attorney General [e-mail]
IDAHO PUBLIC UTILITIES COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
CDS STONERIDGE UTILITIES, LLC by e-mail only:
to its Attorney: jpiskel(apyklawyers.com
Jason T. Piskel
Piskel Yahne Kovarik, PLLC
612 W. Main Ave,., Suite 207
Spokane WA 99201
Norman M. Semanko, ISB#4761 by e-mail only:
PARSONS BEHLE & LATIMER [e-mail]
800 W. Main Street, Suite 1300
Boise, Idaho 83702
PETITION TO INTERVENE—Page 7 of 8

Stoneridge Recreational Club Condominium Owner's by e-mail only:
Association, Inc, to its attorney: [e-mail]
Jack A. Mosby
MARFICE, EALY& DE SMET, LLP
P.O. Box 1336
Coeur D'Alene, Idaho 83816
DATED this 15th day of January 2026.
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lom(#h Lee 6wrS, 04
Randolph Lee Garrison, Pro Se
PETITION TO INTERVENE—Page 8 of 8