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Home My Public Portal AboutExhibit MIEC 41 - Missouri Industrial Energy Consumers First Discovery Request to MSD April 18, 20182018 Stormwater Rate Proposal BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT For Consideration of a Stormwater Rate Change Proposal By the Rate Commission of the Metropolitan St. Louis Sewer District FIRST DISCOVERY REQUESTS OF INTERVENOR MISSOURI INDUSTRIAL ENERGY CONSUMERS Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer District (the "Charter Plan"), Operational Rule 3(5) and Procedural Schedule §§ 1, 17 and 18 of the Rate Commission of the Metropolitan St. Louis Sewer District ("Rate Commission"), Intervenor Missouri Industrial Energy Consumers ("MIEC") requests additional information and answers from the Metropolitan St. Louis Sewer District ("District") regarding the Rate Change Proposal dated February 26, 2018 (the "Rate Change Proposal"). The District is requested to amend or supplement the responses to this Discovery Request, if the District obtains information upon the basis of which (a) the District knows that a response was incorrect when made, or (b) the District knows that the response, though correct when made, is no longer correct. The following Discovery Requests are deemed continuing so as to require the District to serve timely supplemental answers if the District obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. REQUEST NO. 1: Regarding the District's response to the Rate Commission's question on the use of debt financing (Exhibit MSD-30B, Response 44), please answer the following: a. Please explain whether or not any of the proposed capital improvements will be made on private property, and if so who will own the asset. b. How will MSD sponsored capital improvements to private property impact the market value of the property? Please explain answer. c. What are the typical terms (years, repair issues, etc.) of an easement that allows the District to make capital improvements on private property? d. What is the District's justification for using ratepayer rate revenue funds, or equity, for funding assets that cannot be funded by issuing bonds? Please explain why the same restriction on use of bond funding should not also apply to ratepayer revenue funding. RESPONSE NO. 1: 1 2018 Stormwater Rate Proposal REQUEST NO. 2: Regarding Mr. Gee's testimony during the April 4, 2018 Technical Conference (starting on page 163), approximately what percent of the forecasted $562 million would result in assets owned by the District? RESPONSE NO. 2: REQUEST NO. 3: Regarding Mr. Gee's testimony during the April 4, 2018 Technical Conference (starting on page 239), please provide a copy of the latest rating agency reports. RESPONSE NO. 3: REQUEST NO. 4: Please provide an Excel version of Exhibit MSD 31B - CIRP Support Schedule for Rate Model Storm Dashboard Tab. Also, please provide a definition for each four - digit account code in the spreadsheet. RESPONSE NO. 4: REQUEST NO. 5: Please provide additional details about the historical records and engineering studies the District relied on to produce the annual stormwater capital spending forecast that appears on the Storm Dashboard tab of the District's Rate Model. RESPONSE NO. 5: 2 2018 Stormwater Rate Proposal Respectfully submitted, BRYAN AVE LEIGHTON PAISNER LLP By: Liana M. Vuylsteke,'#k 2419 Brandon W. Neuschafer, #53232 Saher Valiani, #69402 211 N. Broadway, Suite 3600 St. Louis, Missouri 63102 Telephone: (314) 259-2543 (Diana) Telephone: (314) 259-2317 (Brandon) Telephone: (314) 259-2050 (Saher) Facsimile: (314) 259-2020 dmvuylsteke@bc1plaw.com bwneuschafer@bc1plaw.com svaliani@bc1plaw.com ATTORNEYS FOR MIEC Dated: April 18, 2018 2018 Stormwater Rate Proposal CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to the following on this 18th day of April, 2018. Ms. Janice Fenton Office Associate Senior Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 jfenton@stlmsd.com Ms. Susan Myers General Counsel Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 smyers@stlmsd.com Ms. Lisa O. Stump Lashly & Baer, P.C. 714 Locust Street St. Louis, MO 63101 lostump@lashlybaer.com 4