20201228SWS to Staff 1-13.pdf

Preston N. Carter, ISB No. 8462
Blake W. Ringer, ISB No. 11223
Givens Pursley LLP
601 W. Bannock St.
Boise, lD 83702
Telephone: [phone]
Facsimile: [phone]
prestoncarter@ givenspursley. com
blakeringer@ givenspursley. com
Attorneys for the Company
IN THE MATTER OF THE COMMTSSION'S
INVESTIGATION INTO CDS STONERIDGE,
LLC'S HOOK-UP FEE FORNEW
CUSTOMERS TO CONNECT TO ITS WATER
SYSTEM
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BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
CaseNo. SWS-W-20-02
CDS SroxERrDGE, LLC's RrsroNsr ro
Frnsr PnooucrroN REeuosrs oF THE
CouprrssroN SrArr
CDS Stoneridge Utilities, LLC, owned by J.D. Resort, lnc. (collectively the "Company")
through its affomeys of record Givens'Pursley LLP, in response to the First Production Request
for the Commission Staff dated November 9, 2020, submits the information below. Additional
documentation, submitted under separate cover and as confidential, regarding a customer that
requested a hookup fee on April 30, 2019 is provided as well, although this documentation was
not specifically requested.
REQUEST NO. 1: Commission Order No. 34770 ordered the Company to provide an
" . . .itemization and description of labor performed. . . " Please provide a description of the itemized
labor performed by the Operator, Operator Assistant, Laborers, Office Admin, and Backhoe
Operators for each connection. Please also provide the names of the Operator, Operator Assistant,
Laborers and Office Admin.
RESPONSE TO REQUEST NO. 1: In making this request, the Commission Staff is
undoubtedly referring to the Company's invoices, which have been filed with the Commission,
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accompany nearly every customer connection application filed, and list the hours of various
employees (e.g. Operator, Laborer, etc.) for each connection made. Unfortunately, upon more
careful review of these invoices, the Company has discovered that these invoices erroneously
identifu certain costs as "intemal" costs (i.e. costs incurred by the time and labor of the Company's
own employees) when they are in fact "external" costs (i.e. costs incurred by hiring a contractor).
Put another way, in calculating its total costs for each connection, the Company made the mistake
of double-counting certain work performed by hired contractors as both "external" and "internal"
costs.l As a result, the Company is submitting, under separate cover and as confidential, updated
documentation ("Updated Documentation") for the Commission's review.
This Updated Documentation includes the additional supporting documents required to
respond fully to these Production Requests. The Updated Documentation also includes
handwritten edits to the Company's invoices which, as explained, were discovered to inaccurately
quantiff the Company's internal costs.2 Finally, the Updated Documentation includes a
confidential updated table ("Table of Costs") that provides information regarding each service
connection that the Company has performed since Novemb er 2018, as well as the associated costs.3
I Staff noted a possible issue with double-counting in its Reply Comments. Reply atpp.4 ("Staff is also concerned by
the number of instances in which the Company and its contractors provide invoices for identical work."). Thi
Company is appreciative to Stafffor its comment, as it led the Company to discover this discrepancy in its records.
2 Each of the Company's invoices included in the Updated Documentation have been revised to accurately reflect the
internal costs to the Company for the respective service connection. However, the invoice for the service connection
for the customer whose application was submitted on April 17 , 2Ol9 has not been revised as it remains accurate . This
customer's service connection was particularly complex and the Company did not hire an external contractor for the
connection.
3 The handwritten edits to the Company's invoices, as seen in the Updated Documentation, identifr the correct internal
costs incurred by the Company for each service connection. Unfortunately, given the turnover of Company
employees in the last year, as well as the Company's poor recordkeeping, the Company cannot calculate the intirnil
cost for some of the older service connections. The Table of Costs included in the Updated Documentation
summarizes which service connections' internal costs were able to be calculated and which had to be estimated. In
all, the internal costs for only 16 service connections could be calculated by the Company. The intemal costs for the
remaining service connections are presented as estimates and are based on the average intemal cost for the l6 service
connections for which the Company was able to calculate internal costs. Since the Company's internal procedure for
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Given the foregoing, the Company is unable to identify the Laborers and the Operator's
Assistant that are referred to in the Company invoices filed with the Commission. The employees
referred to by these roles were employees of the hired contactors, not employees of the Company.
Generally speaking, the Companyhas three full-time employees: Chan Karupiah (Manager), Steve
Durbin (Operator), and Becca Loughnan (Office Administrator). Thus, the "Operator" and "Office
Admin" referred to in the Company's invoices are Steve Durbin and Becca Loughnan,
respectively. Please refer to the Updated Documentation for a list of the internal staff involved in
each customer connection, the number of hours spent by the staffmembers for each connection,
as well as the external contractor hired.
As to the requested itemization and description of labor performed, the following outlines
the labor performed by the Company's employees and hired contractors in a typical service
connection:
1. The customer makes contact via phone or email inquiring about the process for a service
connection. The Office Administrator delivers the water connection packet to the customer
(by email or hand delivery). The customer returns the completed packet.
2. The Office Administrator creates a file for the customer, noting the date of the application,
and forwards the application to the Operator and Manager for service requirements and
approval of a "will serve" letter. The Operator reviews maps in the office and in county
records, as needed. The Operator performs a preliminary site inspection to determine the
location of the main, whether a stub or curb stop is located on the lot, and whether boring
under the road or cutting and patching asphalt will be necessary. The Operator typically
uses a metal detector and a shovel to try to locate any previous water connection to the lot.
processing a service connection application and completing the connection has not changed since November 2018
(see below for an outline ofthat procedure), these estimates are likely very accurate.
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Many of these details frequently cannot be determined until actual exploratory work is
performed. The Operator then returns a "will serve" letter to the office, which is forwarded
to the customer along with a request for payment.
3. Upon the receipt of payment from the customer, the Offrce Administrator provides the
Operator with an installation checklist (a new step that the Company is implementing to
improve the connection process and maintain better records). The Operator contacts an
approved outside contractor and schedules a date to install the connection.a The Operator
calls 411, identifies the locates for the address, and then physically marks the locates at the
address.
4. On the day of installation, the extemal contractor performs the exploratory work. The
Operator identifies where the main should be, as indicated by the relevant map. However,
exploratory often turns out to be a very laborious and time-consuming project. The
easement under which the main lies is 25 feet wide. On different occasions the main has
been discovered anywhere from 4 feet in from the edge of the pavement and 4 feet down
to 8 feet in and 8 feet down. There are frequently power, phone, and cable lines in the way
and, to avoid damaging them, a Laborer must dig with a shovel by hand. Once a Laborer
has loosened 6-8 inches of gravel, the Backhoe Operator then rernoves the loose gravel.
The excavation proceeds at this slow pace until all utility lines and the main are exposed.
This process has, in the past, taken days to complete and there is always the added risk of
damaging a utility line.5
a Given the immense amount of work in the area and the limited number of qualified contractors, this particular step
often poses a significant hurdle.
5 The primary reason why the Company faces such difficulty with exploratory work is because the majority of lots in
the older development do not have water services stubbed from the main to the lot line. This cost has to then be
absorbed in the service connection fee, which often involves a bore under the road. To date, there are minimal "as
builf' documents for the subdivision and some parts of the subdivision have none at all.
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5. Once the main has been discovered, the contractor either installs a hot tap or performs a
depressurization and cut in. A hot tap is the preferred method. However, when the main is
made of older material, a cut in is the better option. Installing a hot tap involves placing a
water connection saddle on the main, attaching a corp stop to the saddle, attaching a hot
tapping apparatus to the corp stop, and then drilling a hole into the live water main. The
corp stop is then shut off, the hot tap apparatus is removed, and a poly line is attached and
run to the meter set. All parts are sanitized before installation.
6. The other option, performing a depressurization and cut in, requires 24-hour advance notice
to all affected properties that the water systern will be depressurized. This notice is
provided by the Office Administator. Once the main is found, a Laborer bleeds off the
pressure, cuts out a section of the main, and installs a slip repair and tee fitting. A bushing
and a corp stop are added to the tee and a pac joint is added to the corp stop. All parts and
pieces used are chlorinated before assembly by a Laborer. The contactor then performs
the re-pressurization process and flushes the lines to reduce the possibility of contaminates
and air in the system.
7. Once the connection has been made, the contractor performs a leak test.
8. After the connection to the main is complete, the contractor will dig a service line ditch
from the main line to the chosen location for the meter. This ditch varies in length
depending on the connection. At the end of ttre ditch, a hole large enough for multiple
Laborers is excavated. At least two Laborers work in the hole to make the proper
connections to the meter box. For the McDonald coil seter a pipe nipple must be installed
on each side of the seter, a pac joint is added on the customer side and sealed with plastic
and tape. A curb stop and a pac joint is added to the Company side of the seter. The service
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line is connected, the valve can is placed over the curb stop, the meter is installed, and the
connection is pressure tested and backfilled. All parts are sanitized before installation.
9. Using poly pipe and stainless-steel stiffeners, the service line is connected to the main with
a lead-free pac joint. The poly is brought through the ditch to the meter, cut at the
appropriate length, and connected to the pac joint on the curb stop. Once the connection is
complete, it is pressure tested and backfrlled.
10. If, after exploratory work is performed, the main is discovered across the road from the
property to be serviced (which is often the case), the conffactor bores under the road to
install the service line. Boring requires excavation on both sides of the road. This results in
even more exploratory work because the side of the road that is opposite to the main may
also have utility lines.6
11. The Operator is present for the entirety of this work to observe, to be on hand in the case
of emergency (especially during exploratory), and often to actually assist in the work.
12. Once the service connection has been fully installed, the Operator delivers completion
paperwork to the Office Administrator for filing. The Office Administrator creates a file
for the customer in RVS (billing software), Camp Master (customer data storage software),
the Utility log book, and QuickBooks (accounting software). The file includes the
customer's name, service address, mailing address, phone number, email, and other
identifying information. The Office Administrator notifies the customer of installation and
answers questions regarding billing.
Preparer/Sponsoring \[itnesses: Chan Karupiah, Steve Durbin, and Becca Loughnan
6 The Company typically elects to bore in spite ofthese circumstances, as opposed to cutting and patching the asphalt,
because it maintains the integrity of the subdivisions' roads and avoids other costs like flagging and redirecting
traffic.
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REQUEST NO. 2: Please provide supponing documentation including timecards,
cancelled checks, etc. for the Operator, Operator Assistant, Laborers, Office Admin, and Backhoe
Operators used for internal costs.
RESPONSE TO REQUEST NO. 2: All employees of the Company are paid on a salary
basis so no timecards or other wage-related documentation can be provided. For clarification, the
Office Administator spends, on average, 4 hours and 45 minutes on each service connection
application.T But, again, the Company does not have any additional documentation to support these
hours. In the past, neither the Office Administrator nor the Operator kept a detailed log of hours
spent working on each service connection. As far as the extemal labor is concerned8, each
contractor's invoice, which have already been submitted to the Commission, came with a bid that
included all labor and equipment.
More recently, the Company has developed a "Connection Requirements" checklist that
will encourage its employees to track their time more carefully moving forward.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca Loughnan
7 To be more specific, Step I from the outline in Response to Request No. I entails roughly 45 minutes of work for
the Office Administrator. There is typically I hour and 15 minutes of work for Step 2, 45 minutes for Step 3, and2
hours for Step 10.
8 As explained in the Company's Response to Request No. l, "external labor" refers to the hours and costs that were
mistakenly double-counted on the Company's invoices.
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REQUEST NO. 3: Commission Order No. 34770 ordered the Company to provide an
" ... itemization and description of labor performed, equipment and materials installed..." What is
included in the Job Materials and Parts as provided by C&D Dirt Works for the application dated
4/1012019 with extemal costs of $2,398.22?
RESPONSE TO REQUEST NO. 3: In response to this Request, the Company has
provided a parts list invoice from Consolidated Supply Co. The parts list is filed
contemporaneously herewith under sepamte cover and as confidential, and is titled, "Parts List
(Confidential Response to Request No. 3)". This parts list was provided to the Company by C&D
Dirtworks. The list identifies the parts typically used by the Company and its external contractors
for a service connection. As for the 4ll0l20l9 application, the parts identified in the submitted
parts list are the exact parts used for that customer's seryice connection.e
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca Loughnan
e To be clear, while the attached parts list identifies each part used in the service connection for the customer who
applied on 4/1012019, it is not the exact invoice from that customer's service connection. The Company has been
unsuccessful in recovering the parts list for that particular customer. Thus, as Commission Staff will likely note, the
total charges in the submitted parts list ($1,822.77) does not add up to the 52,398.22 charged to the 4110/2019
customer. This discrepancy is due to the fact that the cost of parts was adjusted by third parties over time. The actual
parts list forthe 4/1012019 is otherwise identical to the parts list provided.
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REQUEST NO. 4: Commission Order No. 34770 ordered the Company to provide an
"... itemization and description of labor performed..." For each connection performed by Swank
Excavation, please provide the date or dates the connection was performed, a break-down of all
work performed including any excavation, hot tapping, meter installation, horizontal boring, and
running service lines. Given the work done by Swank Excavation, please explain the work done
by the Company (Stoneridge) for each corurection.
RESPONSE TO REQUEST NO. 4: As explained in its Response to Request No. 1, the
Company has discovered that its own invoices were erroneously accounting for work performed
by Swank Excavation and other hired contractors as "internal" work and costs. Please refer to the
Updated Documentation for more information in response to this request.
Because of poor recordkeeping on the Company's part as well as employee turnover in the
last year, the Company is unable to provide the requested information for more than the 16
connections included in the Updated Documentation. However, at least for those 16 connections,
the Company has provided in the Updated Documentation a break-down of the work performed
by Swank Excavation along with a more accurate explanation of the work done by the Company's
employees for each connection. The Company otherwise refers Staffto the outline provided in its
Response to Request No. I for more detail on the work typically done by the Company for each
connection.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca Loughnan
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REQUEST NO. 5: In the following Applications for Service the Company has an invoice
date that is the same as the Application date. Please explain how the Company was able to
accurately determine and invoice the internal labor that would be required for these connections:
a. lll0l20l9 totaling $3,660;b. 4ll0l20l9 totaling $3,295;c. 3l24ll9 totaling $3,075;d. 312712019 totaling $3,005;e. 3127ll9 totaling $3,600;f. 3127ll9 totaling $800;g. 4ll7l20l9 totaling $5,325;h. 51312019 totaling $10,020;i. 4l16119 totaling $3,005;j. 5ll3ll9 totaling $3,005;k. TllI/2019 totaling $2,559;l. 8/712019 totaling $800;m. lll27l20l9 totaling $3,005;n. 411712020 totaling $2,680;o. 613012020 totaling $3,230;p. 613012020 totaling $3,800; and
q. 512812020 totaling $ 1,193.
RESPONSE TO REQIIEST NO.5: The Company's filing system for each water or sewer
application has historically been organized by the application date. In short, the application date
has been used for everything. Thus, the date listed on the Company's invoices is not the actual
date the costs were incurred or the services performed, but rather, simply, the application date. As
Commission Staff likely suspects, the Company was (and is) unable to predict the exact cost of
each service connection before the work was actually performed.
ln providing this response, the Company has recognized the error of providing an
inaccurate date on its invoices and has revised its filing system to include better documentation
and more accurate dates.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca Loughnan
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REQUEST NO. 6: In the response to the Commission Order No. 34770, the Company
provided a list of Customers connected to the system since November of 2019 with internal costs
calculated for each customer. In the following entries, the breakdown of the intemal costs do not
add up to the total amount stated. Please reconcile these differences:
a. Dated lll30/2019 at 26 Hanaford Rd Total is $2,355 but the sum of the items is
$2,455;
b. Dated ll2l20l9 atLot 1 Block 23 Total is $4,065 but the sum of the items is $4,085;
c. Dated 2lIl20l9 at Lot 6 Block 2Total is $4,005 but the some of the items is $3,805;
d. Dated 312712019 at 1449 Meadowland Road but the total is $3,600 but the sum of
the items is $3,560;
e. DatedTll/20l9 atBlockGLot 18Totalis$2,55gbutthesumoftheitemsis $2,569;
f. Dated 7127/2020 at Block F Lot 10 Total $2,680 but the sum of the items is $2,780;
g. Dated 5/2112020 at Block 7 Lot 10 Total is $4,005 but the sum of the items is
$3,805; and
h. Dated 6/20/2020 at l9l Hanaford Road $3,800 but the sum of the items is $1,193.
RESPONSE TO REQUEST NO. 6: The Company's former bookkeeper prepared each
of these internal invoices. The bookkeeper's employment was terminated on October 20, 2020.
Thus, the Company is unable to account for the mathematical errors made by the bookkeeper.lo
The Company has carefully reviewed each of these intemal invoices and has provided the best,
most accurate data available to it in the Updated Documentation.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca t oughnan
r0 The Company does recognize that, while most of the errors seem to be minor mistakes, the sheer amount of errors
is unacceptable, and the calculation for the l9l Hanford Rd invoice was, inexplicably, way off.
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REQUEST NO. 7: For each of the connection records provided by the Company in
response to Commission Order No. 34770, please identiff what, if any, work was done to extend
the Company's mains. For each main that was extended, please provide a break-down of all costs,
including excavation, materials, equipment rental, and labor. Please explain why each main was
extended.
RESPONSE TO REQIIEST NO. 7: To the best of the Company's knowledge, there have
been no extensions to the main since 2018.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca toughnan
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REQUEST NO.8: For each of the connection records provided by the Company in
response to Commission Order No. 34770, please identiS any out-of-the-ordinary circumstances
that justifred charging customers more than the Commission-approved $1,200 connection charge.
Out-of-the-ordinary circumstances would include any increased service line length or complex
excavation work not normally required for the typical service line installed within the Company's
servrce area.
RESPONSE TO REQTIEST NO. 8: Please refer to the Company's Sur-Reply, filed on
December 4,2020, for the Companyos Response to this Request for Production.
Preparer/Sponsoring Witness: Chan Kanrpiah, Steve Durbin, and Becca l,oughnan
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REQUEST NO. 9: For each of the connections performed by C&D Dirtworks, please
explain the work done by the Company (Stoneridge).
RBSPONSE TO REQUEST NO. 9: The two connections performed by C&D Dirtworks,
were completed on the same day. That particular day was the first day on the job for the Company's
current operator, Steve Durbin. As a result, Mr. Durbin does not have notes or a strong recollection
of the particular work done for these connections. None of the other current employees of the
Company were ernployed at the time that C&D Dirtrvorks was used as an external contactor.
Employee turnover, coupled with the Company's poor records, renders the Company unable to
provide further documentation or a more detailed response. The Company otherwise refers the
Commission Staffto the outline in its Response to Request No. 1 regarding the services typically
performed by the Company for a service connection.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca Loughnan
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REQUEST NO. 10: Please provide a schedule for all new connections since November
2018 to the present day showing the hookup fees charged and paid, with detail on how the hookup
fees were paid.
RESPONSE TO REQUEST NO. L0: Please refer to the Table of Costs filed
contemporaneously herewith. The amounts in hookup fees charged to each customer are equal to
the amounts in hookup fees paid by each customer.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca toughnan
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REQUEST NO. 11: For all new customers with new connections installed since
November 2018 to the present day, please provide their monthly water charges and the amount
paid for each month.
RESPONSE TO REQUEST NO. ll: Please refer to the document titled, "Confidential
Response to Request No. 11" which is provided under separate cover and as confidential.ll The
customers identified in "Confidential Response to Request No. 11" may differ from the customer
names listed in the Table of Costs and the Updated Documentation. This is because many
customers that originally applied for the service connection have since sold their respective lots,
leaving the monthly water charges to a new customer. Comments left in the Table of Costs identiff
the current owners of the lots for the purpose of clarification.
Preparer/Sponsoring Witness: Chan Karupiah, Steve Durbin, and Becca Loughnan
rr The Company has not provided the monthly water charges for every new connection installed since November 2018
because many connections were made to vacant lots. As a result, these lots have yet to use any water. The Company
has not charged customers a monthly minimum fee unless they have been actively using water.
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REQUEST NO. 12: For each customer on the Company's response to Commission Order
No. 34770, please provide documentation showing a building permit or approved building lot.
RESPONSE TO REQIIEST NO. 12: As the Company has come to read its Tariffmore
closely in recent months, it has learned that it is not in compliance with $ 9.3 of the Tariffwhen it
accepts service connection applications that lack a building location permit issued by Bonner
County. The Company directs the attention of Commission Staff to the Company's Sur-Reply,
submitted on December 4,2020, for more on this topic.
Given its recent discovery of the requirement in $ 9.3 of the Tariff, the Company has only
required building location permits to accompany service connection applications since October 1,
2020. Thus, the Company has no documentation to provide in response to this request.
Preparer/sponsoring \ilitness: chan Karupiah, Steve Durbin, and Becca Ioughnan
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REQUEST NO. 13: For each customer on the Company's response to Commission Order
No. 34770, please state if that lot had previous water service from the Company.
RESPONSE TO REQTIEST NO. 13: To the Company's best knowledge, none of the lots
referenced in the Company's Response have ever had previous water service from the Company.
Preparer/Sponsoring \ilitness: Chan Karupiah, Steve Durbin, and Becca Ioughnan
Dated: December 28, 2020.
,"4.-*:*
Preston N. Carter
Blake W. Ringer
Givens Pursley LLP
Attorneys for the Company
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CERTIFICATE OF SERVICE
I certiff that on December 28,2020, a true and correct copy of the foregoing was served
upon all parties of record in this proceeding via electonic mail as indicated below:
COMMISSION STAFF
JanNoriyuki
Idaho Public Utilities Commission
11331 W. Chinden Blvd., Bldg. 8, Ste. 201-A
Boise, lD 83714
EMAIL: j [e-mail]. gov
John R. Hammond, DeputyAttorney General EMAIL: [e-mail]
Idaho Public Utilities Commission
11331 W. ChindenBlvd., Bldg.8, Ste.201-A
Boise, D 83714
/ *----'4--z**
Preston N. Carter
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