980714.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 JOINT APPLICATION)
OF UNITED WATER IDAHO INC. AND SOUTH) CASE  NO.  UWI-W-98-2
COUNTY WATER COMPANY, INC. FOR AN )
ORDER APPROVING THE SALE AND TRANSFER) FIRST PRODUCTION   
OF THE COMMON STOCK OF SOUTH COUNTY)  REQUEST OF THE
WATER COMPANY, INC. TO UNITED )COMMISSION STAFF
WATER IDAHO INC.)TO SOUTH COUNTY
)WATER COMPANY
________________________________________________)
The Staff of the Idaho Public Utilities Commission by and through its attorney of record, Scott Woodbury, Deputy Attorney General, requests South County Water Company (South County) provide the following documents and information, pursuant to Commission Rule of Procedure 225, IDAPA 31.01.01.225, on or before  TUESDAY, JULY 28, 1998.
This production request is to be considered as continuing, and South County is requested to provide by way of supplementary responses, additional documents that you or any person acting on your 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 showing the location of all South County Water Company wells.
REQUEST NO. 2:  Please provide a map showing South County mainlines adjacent to UWI’s service area that could reasonably be used to interconnect the two systems.
REQUEST NO. 3:  Does South County currently have any unmetered customers?  If so how many are there?
Mr. Stokes at page 7 of his testimony beginning at line 11, discusses a $312,000 investment that he claims the Company was precluded from including in its rate base calculation from inception of the South County Water Company to date.  The following questions relate to that testimony and the Company’s testimony and exhibits submitted in case No. U-1117-1.
REQUEST NO. 4:  What was the Company’s proposed Rate Base Calculation in
Case No. U-1117-1?
REQUEST NO. 5:  What was the Rate Base approved by the Commission in Case
No. U-1117-1?
REQUEST NO. 6:  What was the opening entry made on the books of South County Water to recognize the Commissions approved rate base calculation?
REQUEST NO. 7:  What was the entry on the Company’s books, and when was it made, to recognize the aforementioned $312,000?
REQUEST NO. 8:  Did the Company make any entry to recognize “Contributions in Aid of Construction” coincident with the entry per number 7 above?  If so, what was the entry?  If not, why not?
REQUEST NO. 9:  Please provide a schedule comparing the Company’s proposed rate base calculation in case No. U-1117-1 with the rate base approved by Commission Order
No. 11762 and explain how the $312,000 claimed disallowance compares with the difference?
REQUEST NO. 10:  Who were the original stockholders of South County Water Company and how were they related to the land development activities of Green Acre Properties, Idaho Land Developers and Littletree Development Co.?
REQUEST NO. 11:  How was the initial number of shares issued distributed among the stockholders and how was the distribution determined?
DATED at Boise, Idaho, this              day of July 1998.
________________________
Scott Woodbury
Deputy Attorney General
Technical Staff:Randy Lobb
Bob Smith
SW:RL1-3;Res 4-11:gdk/uwiw982s.swr/umisc/prodreq