20231218Staff 1-25 to SWS.pdf

MICHAEL DUVAL
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION 03
PO BOX 83720
BOISE,IDAHO 83720-0074
[phone]
IDAHO BAR NO.11714
Street Address for Express Mail:
11331 W CHINDEN BLVD,BLDG 8,SUITE 201-A
BOISE,ID 83714
Attorney for the Commission Staff
BEFORE THE IDAHO PUBLIC UTILITIES COMMISSION
IN THE MATTER OF CDS STONERIDGE )UTLITIES,LLC'S TARRIFF ADVICE )CASE NO.SWS-W-23-02REQUESTINGAUTHORITYTOINCREASE)ITS NEW CONNECTION FEES;CASE NO.)SWS-W-23-02.)FIRST PRODUCTION
)REQUESTOF THE
)COMMISSION STAFF
)TO CDS STONERIDGE
)UTILITIES,LLC.
Staff of the Idaho Public Utilities Commission,by and through its attorney of record,
Michael Duval,Deputy AttorneyGeneral,requests that CDS Stoneridge Utilities ("Company")
provide the followingdocuments and information as soon as possible,but no later than
MONDAY,JANUARY 8,2024.
This Production Request is to be considered as continuing,and the Company is requested
to provide,by way of supplementaryresponses,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 telephonenumber of
the person preparing the documents.Please also identify the name,job title,location,and
telephonenumber of the record holder.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.1 DECEMBER 18,2023
In addition to the written copies provided as response to the requests,please provide all
Excel spreadsheets and electronic files with formulas intact and enabled.
REQUESTNO.1:Please explain why the cost of a water meter shows a price of
$291.49 but is charged at a billed price of $863.06 and $865.05 in the invoices provided.
See Exhibit labeled "Jade Enterprise Parts List"on Page 13-B of the Applicationpages 10-
C and 10-D,respectively.Additionally,please explain why the meter is separated from
the parts/materials line item into its own line item in these invoices.
REQUESTNO.2:Please provide any adders and/or overhead percentages applied
to the actual cost for each line item on each of the provided contractor invoices included in
the Application.
REQUESTNO.3:Please provide the followinginformation for all the 7B
Engineeringline items from Page 7-A of the Application.
a.Please explain what services the CDS Utilities Office Administration Charge
includes.
b.Please explain specifically what labor or parts are included in the ¾-inch water
meter setup charge of $2,400.00.
c.Please explain specifically what parts or labor description the CDS Utilities
Operators charge estimate of $1,200.00 includes.
REQUESTNO.4:Please provide a copy of the proposed notice to customers as
required by Rule 121.01.c to the IPUC for review prior to sending to customers.
REQUESTNO.5:Please clarify that the 7B Engineering chart found on Page 7-
A is for Water Service connections and not Sewer Construction as stated in the header of
the document.
REQUESTNO.6:Please provide the followinginformation:
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.2 DECEMBER 18,2023
a.A copy of the detailed subdivision map of the Company's service territory
indicating which lots are already connected to the Company's system and which
are not yet connected;
b.The total number of active connections;and
c.The total number of connections the Company is expecting to install in the future.
NOTE:Please provide this map in an electronic PDF format-which can be scaled and
enlarged to identify details for each system.
REQUESTNO.7:In the Application,the Company stated that the typical residential
customer now requests a 1-inch meter instead of ¾-inch meter.For each year in 2021-2023,
please provide a list of all the customers the Company has connected to the system,the size of
meter the customer requested,whether the customer requested 1-inch meters orally or in writing,
and the size of the meter eventuallyinstalled.
REQUESTNO.8:Please provide copies of all written requests from customers who
asked for 1-inch meters in the years 2021-2023.
REQUESTNO.9:Please elaborate whether the Company is planning to recruit a water
system operator who can potentiallyfacilitate in-house installations and new connections.If so,
please indicate an approximate time frame for the recruitment.
REQUESTNO.10:Please provide the followingfor each of the items listed below:1)
at least three invoices;2)estimates from three different subcontractors;or 3)a combination of
both with detailed and itemized list of components or materials used,labor hours needed,and a
breakdown of the costs for each of the followingtype of hook up request.
a.Complete installation;
b.Tap main and install service line to curb stop only;
c.Adder for excavation or horizontal boring across road;
d.Pit setter and meter only;and
e.Install meter and turn-on water only.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.3 DECEMBER 18,2023
REQUESTNO.11:Please provide a detailed description of the scope of work,and a
detailed itemized list of components or materials used for the Company's in-house installations
as mentioned in the Application.
REQUESTNO.12:Please provide the followinginformation for the correspondingline
items of the Swank Excavating's invoices provided in "Exhibit E"of the Application:
a.An itemized breakdown of the $2,187 costs for "Parts"at the address 48 Stewart
Drive;
b.A detailed description of the scope of work and a detailed itemized list of
components or materials and labor used to determine the $4,500 costs to "install
water meter,tap main"at the address 45 Forest Ridge;and
c.A detailed description of the scope of work and a detailed itemized list of
components or materials,and labor used to determine $4,500 costs to "install
water meter,tap main"at the address 55 Parkland Court.
REQUESTNO.13:Please provide the followinginformation for the correspondingline
items of the Swank Excavating's invoices provided in "Exhibit F"of the Application:
a.From the "Swank #0604"invoice:
i.An itemized breakdown of the $2,128.16 costs for "parts/materials;"and
ii.Item details includingmanufacturer,parts,and model number for the line
item:"meter"that costs $863.05.
b.From the "Swank #0603"invoice:
i.An itemized breakdown of the $2,327.66 costs for "parts/materials;"
ii.Item details includingmanufacturer,parts,and model number for the line
item:"meter"that cost $863.05;and
iii.A detailed description of the scope of work,a detailed itemized list of
components or materials,and labor used for the line item:"Bore"that cost
$2,000.
c.From the "Swank 12/22 #6"invoice:
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.4 DECEMBER 18,2023
i.An itemized breakdown of the $2,268.72 costs for "parts/materials;"
ii.Item details includingmanufacturer,parts,and model number for the line
item:"meter"that costs $865.06;
iii.A detailed description of the scope of work,a detailed itemized list of
components or materials,and labor used for the line item:"exploratory"
that costs $450;and
iv.Please explain why the invoice is dated 12/15/2022,where the connection
was received,installed,and why the invoice was paid on 05/19/2022.
d.From the "Swank #0605"invoice:
i.An itemized breakdown of the $2,128.16 costs for "parts/materials;"and
ii.Item details includingmanufacturer,parts,and model number for the line
item:"meter"that costs $863.05.
e.The "Check Number 1298"in Page 10-E:
i.Invoice,an itemized breakdown of costs,parts/materials,and labor
involved for the costs associated with,
f.From the "Swank #0736"invoice:
i.An itemized breakdown of the $2,301 costs for "parts;"and
ii.A detailed description of the scope of work,a detailed itemized list of
components or materials,the labor used for the line item:"Abandon water
service on wrong lot"that costs $750;and
iii.Please explain whether the customer named "Luke Swank"is related to
"Swank Excavating."
g.From the "Swank #001/24"invoice:
i.An itemized breakdown of the $2,268.72 costs for "parts/materials;"
ii.Item details includingmanufacturer,parts,and model number for the line
item:"meter"that costs $865.06;and
iii.A detailed description of the scope of work,a detailed itemized list of
components or materials,and labor used for the line item:"exploratory"
that costs $1494.
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.5 DECEMBER 18,2023
REQUESTNO.14:Please provide the followingrelated to the email bid received from
"Swank Excavating"for "Full Hookup plus boring under road:"
a.All email communications with the vendor,"Swank Excavating"related to the bid
invitation,bid submission,and acknowledgementsfrom the Company;
b.A detailed description of the scope of work,a detailed itemized list of components
or materials,labor associated to the line item "Full Hookup"that costs $6,200;
and
c.A copy of the bid document with a detailed description of the scope of work,a
detailed itemized list of components or materials,and labor associated to the line
item "Boring under road"that costs $3,000.
REQUESTNO.15:Please provide the followingrelated to the email bid received from
"JADE Enterprises"for "Full Hookup plus boring under road:"
a.All email communications with the vendor,"JADE Enterprises"related to the bid
invitation,bid submission,acknowledgements from the Company;
b.A copy of the bid document with a detailed description of the scope of work,a
detailed itemized list of components or materials,and labor associated to the line
item "Full Hookup"that costs $6,500.
REQUESTNO.16:Please provide the followingrelated to the email bid received from
"Swank Excavating"for "Full Hookup:"
a.All email communications with the vendor,"Swank Excavating"related to the bid
invitation,bid submission,acknowledgements from the Company;
b.A copy of the bid document with detailed description of the scope of work,a
detailed itemized list of components or materials,and labor associated to the line
item "Full Hookup"that costs $6,200.
REQUESTNO.17:Please provide the followingrelated to the email bid received from
"JADE Enterprises"for "Full Hookup:"
a.All email communications with the vendor,"JADE Enterprises"related to the bid
invitation,bid submission,acknowledgements from the Company;
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.6 DECEMBER 18,2023
b.A copy of the bid document with detailed description of the scope of work,a
detailed itemized list of components or materials,and labor associated to the line
item "Full Hookup"that costs $2,500.
REQUESTNO.18:Please explain whether the Company owns any equipment related
to excavation.If yes,please provide details including-but not limited to-the make,model and
specifications of the available equipment,and individual purchase dates.
REQUESTNO.19:Please provide a copy of at least one more bid from a 3rd
subcontractor other than Swank Excavating or JADE Enterprise for the two future hookups
included in Exhibit I,page 13 of the Application.In the bid document,please include the
detailed description of the scope of work,a detailed itemized list of components or materials,and
labor associated to the work.
REQUESTNO.20:Of the numerous connections from 2021,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.
REQUESTNO.21:Tariff Sheet 3 -Hookup Charge outlines five options or different
connection charges.Please provide a list of all connections includinghow many times each
connection option was charged to customers connected in 2021,2022,and 2023.
REQUESTNO.22:Please provide invoices,or bills,from the Company that were sent
to each customer that was connected in 2022 and 2023.
REQUESTNO.23:For each in-house connection performed in 2022,please explain
the work done by the Company,and provide calculations of the following:
a.Total hours worked per connection;
b.Hourly wage applied;
c.List of materials and cost of each;and
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.7 DECEMBER 18,2023
d.Other relevant charges.
REQUESTNO.24:Please provide an updated timeline of connecting potential
customers presented in the Application.
REQUESTNO.25:Please provide copies of Swank Excavating invoices for all
connections for 2022.
DATED at Boise,Idaho,this day of December 2023.
Michael Duval
Deputy AttorneyGeneral
i:umisc:prodreq/SWS-W-23-02 PR#1
FIRST PRODUCTION REQUEST
TO CDS STONERIDGE UTILITIES,LLC.8 DECEMBER 18,2023
CERTIFICATE OF SERVICE
I HEREBY CERTIFY THAT I HAVE 18th DAY OF DECEMBER 2023,
SERVED THE FOREGOING CDS STONERIDGE UTILITIES,IN CASE NO.SWS-
W-23-02,BY E-MAILING A COPY THEREOF,TO THE FOLLOWING:
CHAN KARUPIAH JEFFREY MERKELY
CDS STONERIDGE UTILITIES CDS STONERIDGE UTILITIES
17173 E PIER ROAD PO BOX 298
BAYVIEW ID 83603 BLANCHARD ID 83804
E-MAIL:[e-mail] E-MAIL:[e-mail]
Ida Elmasian
CERTIFICATE OF SERVICE