20200629Staff 1-19 to CDS Stoneridge.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-03s7
IDAHO BAR NO. 5470
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Street Address for Express Mail:
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BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE APPLICATION OF
CDS STONERIDGE UTILITIES, LLC TO
CHANGE RATES FOR NON.REFUNDABLE
HOOK-UP FEE FOR NEW WATER
CONNECTIONS
CASE NO. SWS-W-20-01
FIRST PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO CDS
STONERIDGE UTILITIES, LLC
The Staff of the Idaho Public Utilities Commission, by and through its attorney of record,
John R. Hammond, Jr., Deputy Attorney General, requests that CDS Stoneridge Utilities, LLC
("Company" or "Stoneridge") provide the following documents and information as soon as
possible, but no later than MONDAY, JULY 20,2020.
This Production Request is to be considered as continuing, and Stoneridge 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 identify the name, job title, Iocation and telephone
number of the record holder.
FTRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC
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JUNE 29,2020
In addition to the written copies provided as response to the requests, please provide all
Excel and electronic files on CD with formulas activated.
REQUEST NO. 1: Please provide a subdivision map of the Company's service territory
Please indicate which lots are already connected to the Company's system and which are not.
REQUEST NO.2: In its Application, the Company states rhar the [original] design "[i]t
appears that the plans did not require the installation of corporation stops and service lines into the
lots." Application at l. Please answer the following questions:
A. When did the Company first become aware that it had not installed corporation stops,
and how did the Company become aware of this?
B. Why was the Company unaware that it had not installed corporation stops?C. How many unserved lots in Stoneridge's service territory have corporation stops?D. How many unserved lots in Stoneridge's service territory do not have corporation
stops?
REQUEST NO. 3: For each item below, please confirm or deny that the proposed $9,375
hook-up charge will cover the following. In addition, please list any other work or expense not
listed below that is assumed in the $9,375 hook-up charge.
A. The material and labor costs of tapping the Company,s main.B. The material and labor costs of installing a corporation stop.
C. The material and labor costs of installing a curb stop.D' The costs of installing a 314" (or larger) line from the corporation stop to the curb stop.E. The costs of installing all plumbing necessary to connect the corporation stop to the
meter base, and the cost of the meter base.F. The costs of a meter and meter installation.
G' All excavation, boring, reconstruction, and patching costs needed for items A through
F.
H. All permitting and traffic control cosrs.I. Stoneridge's administrative costs.J, Contingency estimate.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 JUNE 29,2020
REQUEST NO.4: Regarding the 78 Engineers estimate included in rhe Company,s
Application
A' Please provide a break-down of the costs of materials and work that were assumed
when determining the $2,400 meter set-up cost.B' Please provide a break-down of the costs of materials and work that were assumed
when determining the $2,000 Boring/pavement cut and patch cost.C. Please provide a break-down of the work done by Stoneridge operators that was used to
determine the $ 1,200 CDS Utilities operators cost.
REQUEST NO.5: Regarding the estimate from Leo's Excavaring,LLCthat was included
in the Company's Application:
A. Please provide a break-down of the parts used in the $2,500 parts estimate.B. What work is included in the category ,'Bore?"
C. What work is included in the category "Install?"
D. Does this estimate include permitting/traffic controlcosts and the Company's
administrative costs?
E. Does this include a contingency estimate?
REQUEST NO. 6: Regarding the Swank Excavating estimate included in the Company's
Application
A. Please provide a break-down of the costs of materials and work that were assumed
when determining the $3,708 excavation/labor cost.B. Please provide a break-down of the costs of materials and work that were assumed
when determining the $2,000 Boring cost.
C. Does this estimate include the costs of patching?
D. Does this estimate include permitting and traffic control costs?E. Does this estimate include the company's administrative costs?F. Does this include a contingency estimate?
REQUEST NO. 7: Regarding the C&D Dirtworks [nvoice included in the Company's
Application:
A. Does this invoice include all costs charged to the Company for this project? If not,
please provide all pertinent additional invoices.
REQUEST NO. 8: The C&D Dirtworks Invoice includes costs for connecting three
different systems, with an average cost of $3,483. Please explain why it is appropriate to use the
$9,375 estimate instead of the average historical cost of connecting new customers.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILTTIES, LLC 3 JUNE 29,2020
REQUEST NO. 9: Please define "contingencies" as referenced in the Application and
provide a detailed description of what "contingencies', includes.
A' Why are contingencies included in the estimated costs referenced in the Application?
REQUEST NO. l0: For the Engineers Estimates of Probable Costs, please provide wage
rates, hours required, and the job description/function of each person performing work, broken
down for each activity (row) shown in the document.
REQUEST NO. ll: Are rejected bids included in the calculation of the Estimate of
Probable Costs?
A If the rejected bids are included, please recalculate the Estimate of probable Costs withonly accepted bids.
Please provide copies of the rejected bids.
REQUEST No. 12: Does Stoneridge allow customers to solicit bids and subcontracr
some or all the work required for the hook-up? If not, please explain why nor.
REQUEST No. 13: Do any of the Cornpany's owners, managers or directors have a
financial interest in any of the contractors submitting bids? If so, please explain the financial
interest.
REQUEST No. 14: Do any of the Company's owners, managers or directors have a
financial interest in any of the contractors performing the work to connect new customers to the
system? If so, please explain the financial interest.
REQUEST NO. 15: Please provide a schedule showing all cusromers the Company has
connected to the system since JD Resort's acquisition of the Company. For each customer, please
provide the following:
A. The application for that customer.
B. Any bids received to connect that customerC. Invoices for the work done for each of those customers.D. Address and lot number.
B
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITMS, LLC 4 JUNE 29,2020
REQUEST NO. 16: Please provide a list of all current applications the Company has
received for service but has not yet connected to the system.
REQUEST NO. 17: For each of the applications above that are more than two weeks old,
please indicate the reasons the Company has not connected that customer to the system.
REQUEST NO. 18: Please provide a list of all customers the Company has refused to
connect along with an explanation for each refusal.
REQUFST NO. 19: Please provide detail regarding all unmerered connecrions within the
resort' whether service is being provided to the resort itself or to other entities within the resort,
HOAs, commercial entities, or other parties. Also, please identify and provide detail regarding any
unmetered connections that have been disconnected or shut off within the past year or not turned
on this current year. Have any of these entities previously contacted the Company to request
service?
DATED at Boise, Idaho, this o,*-'/ dayofJune2020.
J Hammond
Attomey General
i:umisc:prodreq/swsw20. ljhjtbecwhmm prod req I
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 5 JUNE 29,2020
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAYE THIS 29M DAY OF JUNE 2020, SERVEDTHE FOREGOING FIRST PRODUCTION REQUEST OF TIIE COMIVISSIONSTATF TO CDS STOI{ERIDGE UTILITIES, N.r CESP NO. SWS-W-20-OI, BYE-MAILING A COPY THEREOF, TO THE FOLLOWING:
STEVEN DURBIN
CDS STONERIDGE UTILTTIES
PO BOX 298
BLANCHARD ID 83804
E-MAIL: [e-mail]
CERTIFICATE OF SERVICE