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upr000063 84

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upr000063-084
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    \ The evidence already adduced by the Water Company as to the capital investment of the Railroad is more than sufficient to support the finding which we request as to the Railroad Company rate base. It contains both detailed and ultimate figures as to investment cost. It is undisputed. The action of the Commission in failing to follow it is purely arbitrary and unlawful. There is no need for further evidence to justify the Commission in changing its decision upon a reconsideration. It should not be necessary to prove the capital investment of the Railroad Company work order by order. It would serve no useful purpose to hold a further hearing for such purpose. Such hearing would only fur­ther delay giving the relief to which the Water Company is en­titled. Nevertheless, we attach hereto as Schedule I a statement showing by individual Work Orders and classes of facilities the Investment Cost as well as the Original Cost of the water pro­ductions facilities of the Railroad Company as of December 31, 1950* If the Commission orders a further hearing your Petitioner proposes to authenticate and prove the accuracy of the figures shown in the attached schedule. It will be noted that on sheet .'ft: i ( -V V ‘I. . 6 of this schedule is shown the total book value of $792,$75*60 of the water production facilities, including 679.42 acres of water-bearing lands, which has already been shown by other ev­idence in "the record of this case. Retirement Reserve. In reconsidering the Railroad Company rate base the Commission should also reconsider the method by which it computed -34-