980714v1.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 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. (UWI; Company) 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 United Water Idaho Inc. 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:  UWI witness Linam states in testimony that rate of return and expense differences of the two companies will provide additional net operating income of $72,641 to support additional rate base of $744,268. This revenue appears to only cover the return on the rate base. Doesn’t the actual revenue requirement on an additional $744,268 of rate base also include depreciation expense, property taxes and income tax?  Please explain.
REQUEST NO. 2:  UWI Exhibit No. 2 shows that $500,000 needs to be spent on water storage regardless of the sale but a new well would not be required if the sale is approved. Please describe the amount of storage needed for South County under both operating scenarios and why storage is required under UWI operation. Does UWI have sufficient back-up water supply in the South County area during peak demand periods?  How much back-up supply is necessary?
REQUEST NO. 3:  Where will interconnection of the two systems be made and what is the estimated cost?
REQUEST NO. 4:  Setting South County customer rates at 60% of UWI rates as proposed in phase 1 will result in significant rate reductions for 3/4 inch residential customers using less than 500 cft per month. Is it the Company’s intent to set the South County customer charge at 60% of UWI’s customer charge thereby causing phase 1 rate reductions for small users?  Please explain.
DATED at Boise, Idaho, this              day of July 1998.
________________________
Scott Woodbury
Deputy Attorney General
Technical Staff:  Randy Lobb
SW:RL:gdk/uwiw982.swr/umisc/prodreq