20210730Staff 19-21 to SWS-Redacted.pdf

JOHN R.HAMMOND,JR.
DEPUTY ATTORNEY GENERAL o 9:9IDAHOPUBLICUTILITIESCOMMISSION
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.5470
Street Address for Express Mail:
11331 W CHINDEN BVLD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorneyfor the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF THE COMMISSION'S )INVESTIGATION INTO CDS STONERIDGE,)CASE NO.SWS-W-20-02
LLC'S HOOK-UP FEE FOR NEW CUSTOMERS )TO CONNECT TO ITS WATER SYSTEM )
)REDACTED THIRD
)PRODUCTION REQUESTOF
)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 followingdocuments and information as soon as
possible,but no later than FRIDAY,AUGUST 20,2021.
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 identify the name,job title,location and telephone
number of the record holder.
REDACTED THIRD PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC 1 JULY 30,2021
In addition to the written copies provided as response to the requests,please provide all
Excel and electronic files on CD with formulas activated.
For both Production Requests Nos.19 and 20,please reference Confidential Attachment A.
REQUESTNO.19:Following up on Production Request No.16,please reconcile the
application dates from the attached Confidential Exhibit B and part of Confidential Exhibit C
(provided in response to Commission Order No.34974)for which had an
application date of 12/30/2020 in Exhibit B but 6/30/2020 on Exhibit C and
which had an application date of 1/26/2021 in Exhibit B but 1/26/2020on Exhibit C.
REQUESTNO.20:Following up on Production request Nos 16 and 17 and reviewing
the attached Confidential Exhibit B and part of Confidential Exhibit C (supplied in Response to
Commission Order No.34974)it appears the Company charged customers more than the tariff
rate whose application dates were after the service date of Order No.34770 (Sept 9,2020).
Please explain why the Company charged them more than the Tariff rate of $1,200 after being
ordered to cease.
a.(Application Date 10/1/2020)
b.(ApplicationDate 12/30/2020)
c.(application Date 1/226/2021)
REQUESTNO.21:In the Company's response to Production Request No.16,the
Company provided cancelled check no.1200 and 1204 to and
Please explain the purpose of these checks and why these checks were included in
this response but not included in the Company's Report in Response to Commission Order
No.34974.
REDACTED THIRD PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC 2 JULY 30,2021
DATED at Boise,Idaho,this y of July 2021.
J .Hammond '
e uty Attorney General
i:umisc:prodreq/swsw20.2jhjtchmm prod req 3
REDACTED THIRD PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC 3 JULY 30,2021
EX HIBIT B
EXHIBIT B IS
CONSIDERED
CONFIDEN TIAL
AND HAS BEEN
REDACTED
EXHIBIT C
EXHIBIT C IS
CON SID ERED
CONFIDENTIAL
AND HAS BEEN
REDACTED
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE 30"DAY OF JULY 2021,SERVED
THE FOREGOING REDACTED THIRD PRODUCTION REQUESTOF THE
COMMISSION STAFF TO CDS STONERIDGE UTILITIES,LLC,IN CASE NO.
SWS-W-20-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
CHAN KARUPIAH
CDS STONERIDGE UTILITIES
364 STONERIDGE ROAD
BLANCHARD ID 83804
E-MAIL:chansan a comcast.net
waterfcGU7 Lamail.com
SECRETARY
CERTIFICATE OF SERVICE