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Home My Public Portal AboutExhibit MIEC 49 -MIEC Second Discovery Request to MSD2018 Stormwater Rate Proposal 1 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 ) SECOND 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 Rate Commission regarding the May 2, 2018, written rebuttal testimony provided by Nicole Young of Lion CSG regarding MSD’s February 26, 2018, Rate Change Proposal dated February 26, 2018. The Rate Commission is requested to amend or supplement the responses to this Discovery Request, if the Rate Commission obtains information upon the basis of which (a) the Rate Commission knows that a response was incorrect when made, or (b) the Rate Commission knows that the response, though correct when made, is no longer correct. The following Discovery Requests are deemed continuing so as to require the Rate Commission to serve timely supplemental answers if the Rate Commission obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. REQUEST NO. 1: In her written rebuttal testimony, Rate Commission consultant Nicole Young of Lion CSG identified in the answer to Question 9 that she “reviewed one of the watershed [binders] in detail.” Please identify which of the watershed binders Ms. Young reviewed in detail. RESPONSE NO. 1: REQUEST NO. 2: Ms. Young has identified that she and Lion CSG “have performed wastewater and stormwater projects for MSD.” On an annual basis from 2013 to the present, please identify the total amount that Lion CSG has billed to MSD for such services, as well as how much Lion CSG has incurred but not yet billed. 2018 Stormwater Rate Proposal 2 RESPONSE NO. 2: Respectfully submitted, BRYAN CAVE LEIGHTON PAISNER LLP By: /s/ Brandon W. Neuschafer Diana M. Vuylsteke, #42419 Brandon W. Neuschafer, #53232 211 N. Broadway, Suite 3600 St. Louis, Missouri 63102 Telephone: (314) 259-2543 (Diana) Telephone: (314) 259-2317 (Brandon) Facsimile: (314) 259-2020 dmvuylsteke@bclplaw.com bwneuschafer@bclplaw.com ATTORNEYS FOR MIEC Dated: May 20, 2018 2018 Stormwater Rate Proposal 3 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to the following on this 20th day of May, 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 /s/ Brandon W. Neuschafer