20260519Comments.pdf

RECEIVED
May 19, 2026
IDAHO PUBLIC
UTILITIES COMMISSION
Randolph Lee Garrison
Pro se
76 Bellflower Ct
Blanchard Idaho 83804
(541 ) 580-4446
garrison(a)_rmgarrison.com
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS ) Case No: SWS-W-25-02
STONERIDGE UTILITIES, LLC'S )
APPLICATION FOR AUTHORITY ) INTERVENOR GARRISON'S
TO INCREASE ITS RATES AND ) COMMENTS
CHARGES FOR WATER SERVICE )
IN THE STATE OF IDAHO )
Randolph Garrison, pro se, makes the following Comments and statemenst
before the Idaho Public Utilities Commission. These comments are pursuant to the
Commission's Order filed on 11 March 2026, Order No. 36962.
INTERVENOR GARRISON'S COMMENTS
Page 1 of 18

(1 ) Staff Comments: IPUC Staff filed their Comments on 7 May 2026.
(2) Background: IPUC Staff's comments and analysis are comprehensive and
thorough. Staff and Intervenors have requested and reviewed several
hundred pages of documents submitted during this proceeding.
(3) Staffs recommendation: While Intervenors would have benefitted from a
more favorable recommendation from IPUC Staff, the recommendations and
analysis of Staff are "fair, just, or reasonable". See: Idaho Code 61-502
which provides that rates must be "just, reasonable or sufficient".
(4) Impact: The IPUC Commission has a duty to and does independently review
and analyze all matters coming before the Commission. At the same time,
Intervenors are mindful that Staff's recommendation plays a large role
informing the Commission's decision-making process.
(5) Applicant's Request was Unjustifiable: Overall, Staff recommends a 0.83
percent in revenue (Staff Comments, page 2). Comparatively, Applicant
requested a "general 43% increase revenues" [which include a 37.61%
increase for 1/4" meters (from $28.85 to $39.70, per month)]. The Application
(fled on 1 December 2025) comes only 5 months after the Final Order filed
(on 2 July 2025) in the previous rate case (Case No. SWS-W-24-01). The
Application comes just 1 year after the conclusion and effective date (29
November 2024) of Applicant's previous general rate increase application.
The amount of Staff's recommended increase in revenue demonstrates
INTERVENOR GARRISON'S COMMENTS
Page 2 of 18

Applicant's requested increase was unjustifiable.
(a) For example, Staff points out (Staff Comments, page 11):
"Staff reviewed the pro forma plant investments the
Company included in its Application. These investments
include: (1 ) a backup generator for the primary well house;
(2) repair, cleaning, and inspection of the main storage
reservoir; and (3) preliminary engineering for the main
storage reservoir bypass. Application, Attachments G and
AD . . . [H]owever, the Company has not shown these
projects have been completed and that they are
currently used and useful." [emphasis added]
(b) For example: One of Applicant's chief claims for an increase was the
loss of Golf Course water:
"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." Application, pg. 3.
However, the Applicant represented and claimed exactly the opposite position
in the prior rate case, Case No. SWS-W-24-01 . For example: The Utility
claimed the net loss of revenue cause by no longer serving the golf course
would be only $6,148.59. Exhibit "A" contains additional information on how
the Applicant previously calculated its deminimus loss of revenue from the
Applicant no longer serving the golf course.
INTERVENOR GARRISON'S COMMENTS
Page 3 of 18

Staff rejected Applicant's Golf Course bloated water loss figures.
Instead (Staff Comments at page 17):
"Staff calculated an annual historical average based on
2023 through 2025 consumption data provided by the
Company and excluded golf course irrigation service.
Company Response to Staff Production Request No. 25.
Staff believes using average consumption over multiple
years better represents water sales under average
conditions than using a single year of data. Staff's average
calculation resulted in a 6.4 million gallon decrease to test
year water sales volumes.
Applicant presented no defensible rational for its golf course water loss
argument.
(6) Applicant Provided Inadequate Information: Staff's recommendation is, in
part, a result of Applicant's poor and insufficient response to Staff's request
for information. As mentioned above, for example, regarding applicants
"backup generator", "repair, cleaning, and inspection of the main storage
reservoir", and "preliminary engineering for the main storage reservoir bypass"
claims, Staff has pointed out (Staff Comments, page 11):
". . . the Company has not shown these projects have
been completed and that they are currently used and
useful." [emphasis added]
INTERVENOR GARRISON'S COMMENTS
Page 4 of 18

Intervenor objects to any other/new factual/evidence submitted by Applicant in
these proceedings. Such new evidence should not be allowed because Intervenors
will not have an opportunity to rebut those claims.
(7) Attorney's Fees: Intervenor also urges the Commission not allow or consider
Applicant's attorney's fees in this proceeding:
(a) As discussed above, Applicant's Application was not justified.
(b) As discussed above, Applicant's response to Staff's request for
information from Applicant was poor and insufficient to justify the
Application.
(c) Applicant's responses to information does not appear to be supervised
or submitted by/through Applicant's attorney, in violation of the
Commissions' orders, e.g. Order No. 36247 in the previous rate case, No.
SWS-W-24-01 . As a result, substantial delays occurred in Intervenors
receiving discovery. Examples are described in the attached exhibits "B",
"C", "D" and "E" [emphasis in yellow added].
(8) Applicant Should Acquiesce: Intervenor also encourages the Applicant to
acquiesce in Staff's recommendation. Further attorney's fees and costs in this
proceeding are not justified and should be avoided for the benefit of all
involved.
INTERVENOR GARRISON'S COMMENTS
Page 5 of 18

Dated and Signed this 191h day of May, 2026.
rmdolrh GjAmw)
Randolph Garrison, Pro se
(541 ) 580-4446
garrison(@_rmgarrison.com
CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19th day of May, 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:
Jeff Merkeley Loll By e-mail: jeff.loll(@_puc.idaho.gov
Deputy Attorney General
IDAHO PUBLIC UTILITIES COMMISSION
P.O. Box 83720
Boise, ID 83720-0074
INTERVENOR GARRISON'S COMMENTS
Page 6 of 18

Jason T. Piskel, Attorney for By e-mail- jpiskel(@_pyklawyers.com
CDS STONERIDGE UTILITIES, LLC
Piskel Yahne Kovarik, PLLC
612 W. Main Ave., Suite 207
Spokane, WA 99201
Norman M. Semanko, ISB #4761 By e-mail: [e-mail]
Attorney for SPOA
PARSONS BEHLE & LATIMER
800 W. Main Street, Suite 1300
Boise, Idaho 83702
DATED this 19t" day of May 2026.
��Vldolrh c4undc2on
Randolph Lee Garrison, Pro se
INTERVENOR GARRISON'S COMMENTS
Page 7 of 18

Exhibit "A"
Supplement to paragraph (5)(b): Additional Information on Effect of New
Golf Course Well:
In the prior rate case # SWS-W-24-01 , REQUEST NO. 3 asked for:
"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.
The Applicant's Answer was: "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 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."
In the subsequent narrative attached to Response to Request No. 4, the
Utility went to great lengths to justify their $6,148.59 figure. Specifically,
the Utility represented:
"StoneRidge Utilities, LLC,
Known Change for Loss of Golf Course Irrigation Sales
Overview: In 2023 4th 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 water for 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
INTERVENOR GARRISON'S COMMENTS
Page 8 of 18

amount:
1 . $18,882.65 for meter 50867 that provides power to the golf
irrigation system pumps. 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."
Judicial Estoppel: The utility is legally prohibited from claiming in this
proceeding that which they denied in the previous proceeding (case #
SWS-W-24-01). "Judicial Estoppel" "precludes a party from gaining an
advantage by taking one position, and then seeking a second
advantage by taking an incompatible position." Heinze v. Bauer, 145
Idaho 232, 235, 178 P.3d 597, 600 (2008) (quoting McKay v. Owens,
130 Idaho 148, 152, 937 P.2d 1222, 1226 (1997)).
`For guidance purposes and to avoid misapplication of judicial
estoppel, it should be made clear that the concept should only be
applied when the party maintaining the inconsistent position either did
have, or was chargeable with, full knowledge of the attendant facts
prior to adopting the initial position. Stated another 12 way, the
concept of judicial estoppel takes into account not only what a party
states under oath in open court, but also what that party knew, or
should have known, at the time the original position was adopted.
Thus, the knowledge that the party possesses, or should have
possessed, at the time the statement is made is determinative as to
INTERVENOR GARRISON'S COMMENTS
Page 9 of 18

whether that person is "playing fast and loose" with the court. Id. at
235-36, 178 P.3d at 600-01 .
Dodd v Jones, No. 50748, 2025 WL 895694, slip pg. 12/13 (Idaho Mar. 3,
2025)
The " . . . the [Idaho Public Utilities] Commission is often described as a
quasi-judicial agency . . ." Madalena vs Idaho Power Company, IPUC case
# IPC-E-24-03, Order Number 36173, pg. 4.
Judicial Estoppel applies to quasi-judicial agency. The scope of appeal
from decisions of the Idaho Public Utilities Commission is set forth in I.C. §
61-629 as follows: "The review on appeal shall not be extended further
than to determine whether the commission has regularly pursued its
authority, including a determination of whether the order appealed from
violates any right of the appellant under the constitution of the United
States or the state of Idaho . . . . "
INTERVENOR GARRISON'S COMMENTS
Page 10 of 18

Exhibit "B"
From: Jeff Merkeley Loll<[e-mail]>
Sent: Friday,April 10, 2026 9:02 AM
To: kyle karupiah; [e-mail];
[e-mail]
Cc: [e-mail];[e-mail];
[e-mail]; [e-mail];[e-mail];
[e-mail]; [e-mail]
Subject: SWS-W-25-02:Service of Discovery Responses
Attachments: 20260202Notice_of_Parties.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
Hello,
It has been brought to IPUC Staff s attention that the Company has not served responses to
Staffs Production Requests on the Intervenors. Commission Rule of Procedure No. 63
requires a discovery respondent to send responses to each party to the proceeding.
For your convenience, I have determined that the Company sent discovery responses to the
Commission Secretary on the following dates:
January 21, 2026
February 26, 2026
March 16, 2026
April 1, 2026
Please forward those responses and send all future responses in this case to each party
listed on the attached Notice of Parties.
Please let me know if you have any questions.
Thank you,
Jeff Merkeley
INTERVENOR GARRISON'S COMMENTS
Page 11 of 18

f Jeffrey Loll I Deputy Attorney General
State General Counsel Division
Office of the Attorney General I State of Idaho
208-334-0357 1 a .idaho. ov
NOTICE: This message, including any attachments, is intended only for the individual(s)
or entity(ies) named above and may contain information that is confidential, privileged,
attorney work product, or otherwise exempt from disclosure under applicable law. If
you are not the intended recipient, please reply to the sender that you have received
this transmission in error, and then please delete this email.
INTERVENOR GARRISON'S COMMENTS
Page 12 of 18

Exhibit "C"
From: kyle karupiah <[e-mail]>
Sent: Friday,April 10, 202610:00 AM
To: Jeff Merkeley Loll
Cc: [e-mail];
[e-mail];[e-mail];[e-mail];
[e-mail]; [e-mail]; [e-mail];
[e-mail]
Subject: Re I Engage: SWS-W-25-02:Service of
Discovery Responses
Attachments: SWS-W-25-02 1st Production Request
Response Final.zip; SWS-W-25-02 Second Production Request Final.pdf; SWS-W-25-02 Fourth
Production Request.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
SWS-W-25-02 3rd Production Request Response.zip
Hello All,
You can find all the past submissions attached below in this email.
On Fri, Apr 10, 2026 at 9:02 AM Jeff Merkeley Loll<jefflollkpuc.idaho.gov>wrote:
Hello,
It has been brought to IPUC Staffs attention that the Company has not served responses to
Staffs Production Requests on the Intervenors. Commission Rule of Procedure No. 63 requires a
discovery respondent to send responses to each party to the proceeding.
For your convenience, I have determined that the Company sent discovery responses to the
Commission Secretary on the following dates:
January 21, 2026
February 26, 2026
March 16, 2026
INTERVENOR GARRISON'S COMMENTS
Page 13 of 18

April 1, 2026
Please forward those responses and send all future responses in this case to each party listed on the
attached Notice of Parties.
Please let me know if you have any questions.
Thank you,
Jeff Merkeley
Jeffrey Loll I Deputy Attorney General
State General Counsel Division
Office of the Attorney General I State of Idaho
208-334-0357 a .idaho. ov
NOTICE: This message, including any attachments, is intended only for the individual(s) or entity(ies)
named above and may contain information that is confidential, privileged, attorney work product, or
otherwise exempt from disclosure under applicable law. If you are not the intended recipient, please
reply to the sender that you have received this transmission in error, and then please delete this email.
INTERVENOR GARRISON'S COMMENTS
Page 14 of 18

Exhibit "D"
From: kyle karupiah <[e-mail]>
Sent: Friday,April 10, 202610:03 AM
To: Jeff Merkeley Loll; [e-mail]
Cc: [e-mail]; [e-mail];
[e-mail];[e-mail]; [e-mail];[e-mail];
[e-mail]; [e-mail]
Subject: Re I Engage: SWS-W-25-02:Service of Discovery Responses
Attachments: SWS-W-25-02 5th Production Request Response.zip.zip
Follow Up Flag: Follow up
Flag Status: Flagged
Hello All,
Attached below are StoneRidge Utilities'responses to staff production request #5.
Thanks,
-Kyle
On Fri, Apr 10, 2026 at 9:59 AM kyle karupiah<kylekl223ggmail.com>wrote:
SWS-W-25-02 3rd Production Request Response.zip
Hello All,
You can find all the past submissions attached below in this email.
On Fri, Apr 10, 2026 at 9:02 AM Jeff Merkeley Loll<jeff.lolIgpuc.idaho.gov>wrote:
Hello,
It has been brought to IPUC Staffs attention that the Company has not served responses to Staff s
Production Requests on the Intervenors. Commission Rule of Procedure No. 63 requires a discovery
respondent to send responses to each party to the proceeding.
For your convenience, I have determined that the Company sent discovery responses to the
Commission Secretary on the following dates:
INTERVENOR GARRISON'S COMMENTS
Page 15 of 18

January 21, 2026
February 26, 2026
March 16, 2026
April 1, 2026
Please forward those responses and send all future responses in this case to each party listed on the
attached Notice of Parties.
Please let me know if you have any questions.
Thank you,
Jeff Merkeley
Jeffrey Loll I Deputy Attorney General
State General Counsel Division
Office of the Attorney General I State of Idaho
208-334-0357 a .idaho. ov
NOTICE: This message, including any attachments, is intended only for the individual(s) or entity(ies)
named above and may contain information that is confidential, privileged, attorney work product, or
otherwise exempt from disclosure under applicable law. If you are not the intended recipient, please
reply to the sender that you have received this transmission in error, and then please delete this email.
INTERVENOR GARRISON'S COMMENTS
Page 16 of 18

Exhibit "E"
From: Kyle Karupiah <[e-mail]>
Sent: Monday,April 13, 2026 3:56 PM
To: Jeff Merkeley Loll
Cc: [e-mail]; [e-mail];
[e-mail];[e-mail];[e-mail]; [e-mail];
[e-mail]
Subject: Re I Engage: SWS-W-25-02:Service of Discovery Responses
Attachments: SWS-W-25-02 6th Production Request Response Final.zip
Follow Up Flag: Follow up
Flag Status: Flagged
Hello All,
Attached below are StoneRidge Utilities'responses to staff production request #6.
-Kyle
On Fri, Apr 10, 2026 at 10:02 AM kyle karupiah< >wrote:
Hello All,
Attached below are StoneRidge Utilities'responses to staff production request #5.
Thanks,
-Kyle
On Fri, Apr 10, 2026 at 9:59 AM kyle karupiah<kylckI223((,gmail.com>wrote:
SWS-W-25-02 3rd Production Request Response.zip
Hello All,
You can find all the past submissions attached below in this email.
On Fri, Apr 10, 2026 at 9:02 AM Jeff Merkeley Loll<jeff.lollgpuc.idaho.gov>wrote:
Hello,
INTERVENOR GARRISON'S COMMENTS
Page 17 of 18

It has been brought to IPUC Staffs attention that the Company has not served responses to Staff s
Production Requests on the Intervenors. Commission Rule of Procedure No. 63 requires a discovery
respondent to send responses to each party to the proceeding.
For your convenience, I have determined that the Company sent discovery responses to the Commission
Secretary on the following dates:
January 21, 2026
February 26, 2026
March 16, 2026
April 1, 2026
Please forward those responses and send all future responses in this case to each party listed on the
attached Notice of Parties.
Please let me know if you have any questions.
Thank you,
Jeff Merkeley
Jeffrey Loll I Deputy Attorney General
State General Counsel Division
Office of the Attorney General I State of Idaho
208-334-0357 a .idaho. ov
NOTICE: This message, including any attachments, is intended only for the individual(s) or entity(ies)
named above and may contain information that is confidential, privileged, attorney work product, or
otherwise exempt from disclosure under applicable law. If you are not the intended recipient, please
reply to the sender that you have received this transmission in error, and then please delete this email.
INTERVENOR GARRISON'S COMMENTS
Page 18 of 18