20201109Staff 1-13 to SWS.pdf

JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITTES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-007 4
(208) 334-O3s7
IDAHO BAR NO. 5470
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Street Address for Express Mail:
11331 W CHINDEN BVLD, BLDG 8, SUME 2OI-A
BOISE, D 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
INI'VESTIGATION INTO CDS STONERIDGE,
LLC'S HOOK.UP FEE FOR NEW CUSTOMERS
TO CONNECT TO ITS WATER SYSTEM
CASE NO. SWS-W-20-O2
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, NOVEMBER 30, 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, location and telephone
number of the record holder.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC
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I NOVEMBER 9,2020
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: 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.
REQUEST NO.2: Please provide supporting documentation including timecards,
cancelled checks, etc. for the Operator, Operator Assistant, Laborers, Office Admin, and Backhoe
Operators used for internal costs.
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
4llol20l9 with external costs of $2,398.22?
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 connection.
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. llIO|}OL9 totaling $3,660;
b. 4llol20l9 totaling $3,295;
c. 3l24l2OI9 roraling $3,075;
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 NOVEMBER 9, 2O2O
d. 312712019 totaling $3,005;
e. 312712019 totaling $3,600;
f. 312712019 totaling $8OO;
g. 4ll7l20l9 totaling $5,325;
h. 51312019 totaling $10,020;
i. 411612019 totaling $3,005;
j. 5ll3l20l9 totaling $3,005;
k. 7llll20l9 totaling $2,559;
l. 81112019 totaling $800;
m. 1112712019 totaling $3,005;
n. 411712020 totaling $2,680;
o. 613012020 totaling $3,230;
p. 613012020 totaling $3,800; and
q. 512812020 totaling $1,193.
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 2018 with internal costs
calculated for each customer. In the following entries, the breakdown of the internal costs do not
add up to the total amount stated. Please reconcile these differences:
a. Dated lll30l20l9 at26Hanaford Rd Total is $2,355 but the sum of the items is
92,455;
b. Dated ll2l20l9 at Lot I Block 23 Totalis $4,065 but the sum of the items is
$4,085;
c. Dated 2lll20l9 at Lot 6 Block ZTotal is $4,005 but the some of the items is $3,805;
d. Dated 3127/2019 at 1449 Meadowland Road but the total is $3,600 but the sum of
the items is $3,560;
e. Dated 7llll20l9 at Block G Lot 18 Total is $2,559 but the sum of the items is
$2,569;
f. Dated 712712020 at Block F Lot 10 Total is $2,680 but the sum of the items is
$2,780;
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC J NOVEMBER 9, 2O2O
g. Dated 512112020 at Block 7 Lot 10 Total is $4,005 but the sum of the items is
$3,805; and
h. Dated 612012020 at l9l Hanaford Road $3,800 but the sum of the items is $1,193.
REQUEST NO.7: For each of the connection records provided by the Company in
response to Commission Order No. 34770, please identify 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.
REQUEST NO. 8: For each of the connection records provided by the Company in
response to Commission Order No. 34770, please identify any out-of-the-ordinary circumstances
that justified 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
servlce area.
REQUEST NO.9: For each of the connections performed by C&D Dirtworks, please
explain the work done by the Company (Stoneridge).
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.
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.
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.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC NOVEMBER 9, 2O2O4
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.
DATED at Boise,Idaho, this T'auyof Novemb er 2020.
J
Attorney General
i:umisc:prodreq/swsw20.2jhjtchmm prod req I
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILMIES, LLC 5 NOVEMBER9,2O2O
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE 9ft DAY OF NOVEMBER 2020, SERVED
TIIE FOREGOING FIRST PRODUCTION REQUEST OF THE COMMISSION
STAFF TO CDS STONERIDGE UTILITIES, LLC, IN CASE NO. SWS-W-20-O2,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
STEVEN DURBIN
CDS STONERIDGE UTILITIES
PO BOX 298
BLANCHARD ID 83804
E-MAIL: steve.durbin @ stoneridgeidaho.com
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CERTIFICATE OF SERVICE