20210630Staff 14-18 to SWS.pdf

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JOHN R. HAMMOND, JR.
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
PO BOX 83720
BOISE, IDAHO 83720-0074
(208) 334-03s7
IDAHO BAR NO. 5470
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Street Address for Express Mail:
I I33I W CHINDEN BVLD, BLDG 8, SUITE 2OI-A
BOISE, ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S
INVESTIGATION INTO CDS STONERIDGE,
LLC'S HOOK-UP FEE FOR NEW CUSTOMERS
TO CONNECT TO ITS WATER SYSTEM
CASE NO. SWS-W-20-02
SECOND PRODUCTION
REQUEST OF THE
COMMISSION STAFF TO CDS
STONERIDGE UTILITIES, LLC
The Staff of the ldaho 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 WEDNESDAY, JULY 21.'2021.
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 identiff the name, job title, location and telephone
number of the record holder.
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC
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I JUNE 3O,2O2I
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. 14: Please provide evidence of the reimbursement payments clearing the
bank. Evidence could be a bank statement showing the check cleared, or copies of the cancelled
checks.
REQUEST NO. 15: [n the listing of customers provided in response to Order No. 34974,
the Company listed l3 hookups that were charged more than the tariff rate of $1,200 (12 are in
Exhibit B and the last one is found only in the documentation in Exhibit C). Two of those
customers had checks written to them reimbursing them for the overpayment of hookup fees, but
l1 customers were not reimbursed. Please explain the Company's plan for reimbursing those other
l1 hookups.
REQUEST NO. 16: In the list of customers provided in Exhibit B in the Company's
response to Commission Order No. 34974, there are three customers whose application date was
after the Commission Order No. 34770 (91912020) that ordered the Company to only charge the
tariffed rate for hookup ($1,200). The application dates in Exhibit B are 101112020,1213012020,
112612021. On Exhibit C the application dates for those customers are 101112020,613012020 and
112612020. Please explain the difference in application dates and confirm the correct application
date.
REQUEST NO. 17: Please provide an explanation for why the Company charged the
three customers mentioned in Production Request No. l6 above more than the approved hookup
fee after receiving Order No. 34770.
REQUEST NO. 18: Please provide the applications for 51 Bellflower and37 Bellflower
Please include the amount charged to connect these properties.
SECOND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 2 JUNE 30,2O2I
DATED at Boise,Idaho, this ffi,of Jnne zAil,
Auorney General
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sEcoND PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES, LLC 3 JTINE 3O,ZWI
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE 30th DAY OF JUNE 2021, SERVED
THE FOREGOING SECOND PRODUCTION REQI]EST OF THE COMMISSION
STAFF TO CDS STONERIDGE UTILITIES, LLC, IN CASE NO. SWS-W-20-02,
BY E-MAILING A COPY THEREOF, TO THE FOLLOWING:
STEVEN DURBIN
CDS STONERIDGE UTILITIES
PO BOX 298
BLANCHARD ID 83804
E-MAIL : [e-mail]
CERTIFICATE OF SERVICE