950823.docx

SCOTT WOODBURY
DEPUTY ATTORNEY GENERAL
IDAHO PUBLIC UTILITIES COMMISSION
472 WEST WASHINGTON STREET
STATEHOUSE MAIL
BOISE,  IDAHO  83720-6000
[phone]
ATTORNEY FOR THE COMMISSION STAFF
BEFORE  THE  IDAHO  PUBLIC  UTILITIES  COMMISSION
IN THE MATTER OF THE APPLICATION OF)
UNITED WATER IDAHO, INC. FOR APPROVAL) CASE  NO.  UWI-W-95-2
OF AN AGREEMENT TO EXCHANGE)
SERVICE AREAS AND TO AMEND AND)FIRST PRODUCTION
REVISE CERTIFICATE OF CONVENIENCE)REQUEST OF THE
AND NECESSITY NO. 143.)COMMISSION STAFF
)TO  UNITED WATER
_____________________________________________)IDAHO, INC.
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests United Water Idaho, Inc. provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before WEDNESDAY, SEPTEMBER 13, 1995.
This production request is to be considered as continuing, and United Water Idaho, Inc. 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 produced.
Please provide answers to each question; supporting workpapers that provide detail or are the source of information used in calculations; the name and telephone number of the person preparing the documents; and the name, location and telephone number of the record holder.
Request No. 1:  Please provide a map of the exchanged areas showing existing facilities of United Water and existing facilities of Garden City.
Request No. 2:  Please provide book value for both the Garden City facilities in the North State Area and United Water facilities in the Millstream Area.  How was the Company payment of $593,250 to Garden City determined?  Provide backup to support payment.  How does United Water plan to book and recover any premium?
Request No. 3:  Does United Water intend to separate facilities of the Millstream Area from the rest of its water system on approval of the Exchange Agreement?  Please explain.
Request No. 4:  Does United Water intend to interconnect the current Garden City facilities in the North State Area with existing Company facilities on approval of the Exchange Agreement?  Please explain.
Request No. 5:  What is the estimated cost of exchanging meters between the Millstream Area and the North State Area?  What is the estimated cost of installing 530 new meters in the North State Area?
Request No. 6:  Please provide a breakdown, by meter size of the existing United Water customers in the Millstream Area and existing Garden City customers in the North State Area.
Request No. 7:  How was the rate for water to be purchased from Garden City determined?  Please provide any work papers used to establish the rate.
Request No. 8: Please provide a copy of the Water Purchase Agreement listed under Exchange Agreement ¶ 13 - Existing Agreements.
Request No. 9:  Given that the water rates of 912 customers will be increased, what benefit does the Company believe will be provided to these customers by this transaction?
Request No. 10: What benefit does the Company believe will be provided to existing United Water customers by this transaction?
Request No. 11:  Does the Company expect revenue generated from new customers to cover the revenue requirement associated with this transaction?  Please provide supporting documentation.
Request No. 12:  What notice, if any has been provided to customers affected by the exchange?

DATED at Boise, Idaho, this              day of  August 1995.
______________________________________
Scott Woodbury
Deputy Attorney General
______________________________________
sw/rl:gdk/pr/unw952.#1Randy Lobb
Engineering Section Supervisor