HomeMy Public PortalAboutExhibit MSD 69 - MSD Prehearing Conference ReportExhibit MSD 69
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
JUNE 28, 2018 PRE -HEARING CONFERENCE REPORT
OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT
ISSUE: STORMWATER RATE CHANGE PROCEEDING
WITNESS: THE METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: THE METROPOLITAN ST. LOUIS SEWER DISTRICT
DATE PREPARED: JUNE 28, 2018
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
Exhibit MSD 69
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
JUNE 28, 2018 PRE -HEARING CONFERENCE REPORT OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
Pursuant to §7.280 and §7.290 of the Charter Plan of The Metropolitan St. Louis Sewer
District (the "Charter Plan") and Operational Rule §3(9), The Metropolitan St. Louis Sewer
District ("District") hereby submits its Pre -hearing Conference Report (Exhibit MSD 69).
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Exhibit MSD 69
JUNE 28, 2018 PRE -HEARING CONFERENCE REPORT
SUBMITTED BY THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
INTRODUCTION
The Metropolitan St. Louis Sewer District ("District") submitted the Stormwater Rate
Change Proposal notice to the Rate Commission on February 26, 2018. This is the sixth rate
change notice submitted by the District since the Rate Commission was formed, by voter
approval on November 7, 2000, pursuant to Section 7.040 of the District's amended Charter
Plan. Per the Rate Commission's Operational Rules, Regulations, and Procedures, the first of
four technical conferences was held on April 4, 2018 to question District staff and Raflelis
Financial Consultants, Inc. ("RFC"), the District's rate consultant about their respective
submitted direct testimony. The second technical conference was held on May 17, 2018 to allow
questioning by all parties of the rebuttal testimony submitted by interveners and the Rate
Commission's consultant. The Missouri Industrial Energy Consumers ("MIEC") was allowed to
intervene via the Rate Commission's application process.
The third technical conference required by the Rate Commission's Operational Rules,
Regulations, and Procedures was held on June 7, 2018 to allow questioning of the surrebuttal
testimony submitted by District staff and RFC. No other parties submitted surrebuttal
testimony. A pre -hearing conference was held on June 21, 2018 in which all parties read a pre -
hearing conference summary report. The District submitted its summary as Exhibit MSD 64.
PURPOSE
The purpose of this report is to identify and describe the various issues raised by the
prepared and oral testimony submitted during this rate change proceeding and present the
position of District staff relative to each issue. It should be noted, the positions outlined in this
report represent the opinions of District staff and do not represent acceptance or approval by the
District's Board of Trustees.
ISSUES
The Stormwater Rate Change Proposal ("Rate Proposal") was submitted in support of a
Stormwater Capital Rate to mitigate the impacts of flooding and erosion. During the discovery
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Exhibit MSD 69
process, additional information regarding these and other issues has been requested by the Rate
Commission's consultant and MIEC. During the technical conferences, all parties testified to
their specific issues that directly and indirectly affect a stormwater capital rate. Based on the rate
proceedings to date, the District believes that the pending issues to be considered by the Rate
Commission are as follows:
1. MSD's Stormwater Capital Improvement and Replacement Program (" CIRP")
a. Stormwater Project Identification
b. Stormwater Project Prioritization
c. Stormwater Project Programing
2. Incentives and Credits
3. Use of Debt to Fund the Stormwater CIRP
4. Fair and Reasonable Rate Structure
5. MSD's Position on Zweig
6. MSD's Position on Charging the Stormwater Capital Rate to Tax Exempt Entities
ISSUE 1. MSD's STORMWATER CIRP:
MDS's Position on Issue 1.A. - Stormwater Project Identification
MSD's Stormwater CIRP includes a process for the identification, prioritization, and
programing of projects. Throughout the proceedings, the District has provided direct evidence
that MSD's stormwater project identification, current prioritization system, and programing of
projects is fair and reasonable to all classes of our rate payers. It is the District's position, and
supported by the record, that the proposed Stormwater CIRP is fair and reasonable to all classes
of our rate payers. Evidence has also been provided that the Rate Commission's own technical
consultant agrees with the District's position.
In Exhibit MSD 56, Rich Unverferth (MSD Director of Engineering) testified that there
is a public expectation that MSD respond to stormwater issues based upon "public input
received by MSD during 2016 public information presentations and information provided in
Exhibit MSD 30G — MSD Stormwater Survey Report, as well as the hundreds of calls received
annually from MSD customers requesting assistance in dealing with flooding and erosions
issues." In Exhibit MSD 65, page 100 lines 10-11, Mr. Unverferth further testified that the
District receives between 500-600 calls annually dealing with flooding and erosion issues. He
also testified "... I've been in the district for 31 years and ... spent seven years in our operation
where my primary sole purpose was a team that went out and investigated stormwater problems,
and that number is pretty consistent." See Exhibit 65, page 101 lines 12-16.
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Exhibit MSD 69
Rate Commission's Technical Expert's Position on Issue 1.A. —
Stormwater Project Identification
Nicole Young, the Rate Commission's technical expert, stated that based upon her
understanding of the engineering planning studies and MSD's complaint system that the projects
in MSD's Stormwater CIRP are appropriate. She went on to state that "a substantial amount of
technical work was completed to review each watershed and identify problems, solutions, costs,
benefits, and project priorities." She also concluded that "Based on this the program appears to
have sufficient flexibility to address the highest priority projects in the region as identified by
the District through this program." See Exhibit RC 44.
Intervener MIEC's Position on Issue 1.A. - Stormwater Project Identification
Michael Gorman, MIEC's rate consultant does not agree with the District or Ms.
Young's position. However, as pointed out in Mr. Gorman's testimony, he was not present for
the April 4, 2018 technical conference in which the District provided testimony for and testified
to the types of projects that make up the Stormwater CIRP. See Exhibit MSD 3C. Ms. Young
testified that "based on his (Mr. Gorman's) testimony, I do not believe that he has reviewed the
same information that I have. I would encourage him to look at the 53 plus three binders that are
available." See Exhibit MSD 52, page 97 lines 19-22. Based upon the testimony of the
technical experts, it is evident which experts based their conclusions on known facts and
evidence. Mr. Gorman failed to provide any evidence to substantiate an opinion that MSD's
Stormwater Capital Program is not fair and reasonable to all classes of our rate payers.
MDS's Position on Issue 1.B. - Stormwater Project Prioritization
MSD's Stormwater Projects Prioritization System is an acceptable and appropriate way
to develop a the Stormwater CIRP. The identification and prioritization of projects to be
included in the CIRP is a multi -step process, requiring monitoring and updating to ensure that
the highest priority problems within the District are addressed in a timely manner, given
available funding. The stormwater projects are identified to address flooding and erosion issues
and are prioritized based upon the severity of the flooding and erosion and the overall benefit
provided by the project. In order to maximize the benefits per dollar spent on a project, a
benefit/cost ratio is calculated to determine the project priority ranking.
As explained in Exhibit MSD 50A, when developing the Stormwater Projects
Prioritization System many years ago, the District relied upon the experience and expertise of
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Exhibit MSD fig
staff and its consultants, who were all involved in water industry trend setting activities, and
active in professional organizations. The Stormwater System Master Improvement Plan
(SSMIP) was written by national and local experts at Camp Dresser & McKee (CDM), Horner
and Shifrin, CH2M-Hill and Montgomery Watson. This team won out over five other consultant
teams due to their experience in stormwater planning. Leading experts involved in the process
include: CDM's Jim Hagerty and Dan Lau, Shifrin's Gene Rovak and Bill Clarke, CH2MHill's
Carey Brand, and Montgomery Watson's Ed Tharp and Ron Krusie. This entire process
involved oversight by a Public Advisory Committee with fourteen members, and a Technical
Advisory Committee with nine members. The Technical Advisory Committee was selected due
to their stormwater management expertise and included: a Professor of Hydraulics, the Chief of
Hydrologic Engineering for the US Army Corps of Engineers, four local government
representatives including two Public Works Directors, a Vice President of an engineering
consulting firm, and Associated General Contractor representation.
The prioritization system was upgraded by MSD and Parsons in 2006 to better reflect the
various problem categories with severity refinements, plus points were added to encourage
regional and environmentally beneficial solutions. Parsons won the contract over other
consultants due to their approach, experience, and expertise. Parsons' project manager was Ed
Sweet, and the team contained numerous national and local experts (see Exhibit MSD 50B
Project Proposal). The internal MSD project manager was Gary Moore, who is also an expert in
the water environment field (see Exhibit MSD 50C Moore Resume).
Per the SSMIP Policy Report Section 2.5.1, "Various methods of prioritization from
other urban areas were reviewed and applicable points for the SSMIP prioritization program are
presented in the following sections. Many approaches have been utilized to rank stormwater
related projects that together comprise a continuum of complexity and detail." The approach
taken by federal agencies, for example, was evaluated and rejected as an overly complex and
time-consuming approach. The majority of city and county -wide stormwater prioritization
procedures fell into a weighted benefit point system with cost comparison approach, which was
selected as the most appropriate method. The benefit to cost ratio was modeled after the
approach in Virginia Beach, Virginia. The Parsons team further contributed to the effort with
leading experts all having personal experience and were selected due to their expertise. The
team led the District in developing a prioritization system most appropriate for the District's
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needs. See Exhibit MSD 50A.
The District's current project prioritization system is fair and reasonable to all classes of
rate payers and is supported by the Rate Commission's technical expert. Although, MIEC's
expert does not agree with the District and the Rate Commission's technical expert, the record
suggests that his conclusion was not based on a review of all the information available to him.
Rate Commission's Technical Expert's Position on Issue 1.B. —
Stormwater Project Prioritization
In Ms. Young's Rebuttal Testimony, she states that in her opinion, the prioritization
system is appropriate and agreed that this type of scoring system is commonly used in
infrastructure projects to provide quantification to project prioritization. See Exhibit RC 44.
During the technical conference on May 17, 2018, Ms. Young testified that "MSD has
referenced the 53 binders plus three additional general binders that they have available for
review, and I did come to the District on May 1 to review those documents." See Exhibit MSD
52, page 80 lines 19-22. When asked by Commissioner Palen if MSD's prioritization system
had been created in order to be fair, defensible, objective and consistent, Ms. Young agreed it
had. See Exhibit MSD 52, page 87 lines 13-16.
Intervener MIEC's Position on Issue 1.B. - Stormwater Project Prioritization
Mr. Gorman states that "MSD did not provide a satisfactory explanation for how these
studies were used to calculate its $562 million total cost." See Exhibit MIEC 45. When asked
by Commissioner Goss "are you familiar with MSD's project prioritization system?" Mr.
Gorman answered, "Not in great detail." When asked if MSD used its prioritization system to
rate the various projects it is considering for the Stormwater CIRP, Mr. Gorman testified, "Not
to my knowledge. They have not established priority of these projects." See Exhibit MSD 52,
page 29 line 25 and page 30 lines 2-7. Again, Mr. Gorman does not agree with the District and
Ms. Young's position that MSD's prioritization system is fair and reasonable to all classes of
rate payers and is appropriate. Yet he provides absolutely no evidence to support his opinion.
Mr. Gorman even admits under oath that he was not familiar with the project prioritization
system used by MSD.
MDS's Position on Issue 1.C. - Stormwater Project Programming
The process for scheduling or programming within the annual Stormwater CIRP is an
iterative process impacted by a number of factors. Projects are generally placed in the annual
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Exhibit MSD 69
CIRP according to the benefit/cost ratio, scheduling higher priority projects sooner in the
program. The annual CIRP typically includes a five-year rolling block of projects potentially
being impacted by a number of factors. These factors and this programming process can require
the movement of projects both higher in priority to be delayed or projects of lesser priority to be
expedited in the program. However, it is always the intent to address the highest priority issues
sooner in the program.
Brian Hoelscher, MSD's Executive Director, testified "we did a pretty massive — myself,
my manager of public affairs — communication effort with municipalities interested, civic
groups, other groups trying to find out what their feel was on stormwater, where we need to go,
and what we need to head towards along with some recent polling. And another factor that went
into the size of the program was, what is the ratepayers' appetite for paying for a program at all,
an annual cost?" Exhibit MSD 65, page 84 lines 4-12. He also testified "I think our data shows
that for us to get a program in place, the program size we're proposing, we believe, once
educated, that the voting public will find that that's an appropriate level expenditure to address
those issues." Exhibit MSD 65, page 84 lines 16-21.
MSD has always been receptive to partnering with other entities for them to provide full
or partial funding contributions to stormwater capital projects. MSD plans to continue with this
policy so long as the use of MSD funding does not delay the execution of other scheduled
projects that have a higher priority. As has previously been testified to, the potential use of
outside funding will have no effect in the priority calculation for each project. In calculating the
cost of a project in determining the benefit -cost ratio, cost shall always be the cost to complete
the project, regardless of the source of funding. This process insures that the value of the
stormwater capital dollars from all rate payers will be weighed equally and not be influenced by
the ability of a third party source to provide additional funding to the process. This helps ensure
that the prioritization process is fair and reasonable to all classes of rate payers.
Rate Commission's Technical Expert's Position on Issue 1.C. —
Stormwater Project Proaramming
The Rate Commission's technical consultant, Ms. Young testified that "...the program
appears to have sufficient flexibility to address the highest priority projects in the region as
identified by the District through this program." Exhibit RC 44. She also stated "As civil
engineers, our job is never done. We're here to serve the community in the best way we know
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how. I think that the District has put forward a program that adequately addresses the problems
that they know today, and as Mr. Hoelscher has testified, it is a flexible program that will be
modified over time." See Exhibit MSD 52, page 90 lines 23-25 and page 91 lines 1-3.
Intervener MIEC's Position on Issue 1.C. - Stormwater Proiect Programming
Mr. Gorman does not agree with MSD or Ms. Young regarding the adequacy of MSD's
project programming. He states "...it appears that MSD has simply made approximations on
capital expenditures and stormwater remediation costs that can be paid for by collecting $30
million per year from customers." This statement indicates the lack of understanding that Mr.
Gorman has for project estimating. When asked by Commissioner Toenjes at what level of
estimate does MIEC get comfortable, Mr. Gorman's response was "I think that's a fair question.
I don't know if I can't give you a complete answer on that, but if they had specific projects
which they say they think needs to be done in the next five years, projects need to be done over
the next 10 years, projects that need to be done when they can afford to do them, would be
helpful." See Exhibit MSD 52, page 36 lines 14-21. That is exactly what MSD has and was
provided as Exhibit MSD 30L. Again, Mr. Gorman is forming opinions without the assistance
of facts or evidence.
ISSUE 2: INCENTIVES AND CREDITS
MSD's Position on Issue 2
The Rate Commission's technical expert and MSD are in agreement regarding the
incentive/credit program being proposed. MSD's proposed program is within industry norms.
Rich Unverferth testified that "similar to other stormwater programs across the country the
District has developed a proposed Storm Water Incentive Program that provides customer
incentives for reducing their effective impervious area through the use of constructed features or
low impact development." See Exhibit MSD 3C.
Rate Commission's Technical Expert's Position on Issue 2
Ms. Young testified that "The District's incentive and credit programs provide some
nominal benefit to property owners to provide BMPs (Best Management Practices) without
compromising the CIRP." See Exhibit RC 44. She agrees that the District's program is a
reasonable approach to providing some benefit to BMPs while still maintaining the integrity of
accomplishing the CIRP. When evaluating incentive/credit programs, Ms. Young claims we
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should focus on how effective the incentive/credit program is to reducing impervious area — not
whether the incentive/credit is large enough. Ms. Young further testified that "[BMPs] are
beneficial to the overall system if they are maintained over the long term. However, it is unlikely
that BMPs will have a significant effect in reducing the civil infrastructure investments
necessary in the program. While it is beneficial to install BMPs, MSD needs to collect the funds
in order to build the stormwater infrastructure or undertake buyouts included in the CIRP.
Increasing incentives or credits may increase BMPs, without actually achieving a reduction in
effective impervious area where needed." See Exhibit RC44. In addition, Pamela Lemoine, the
Rate Commission's technical expert, testified that "The District's proposed credit program
enhances equitable cost recovery by providing opportunities for a fee reduction." See Exhibit
RC 43. Ms. Lemoine also stated "..based on the level of the funding, the level of the stormwater
rate, I don't know that there is a lot more that can be done to incentivize." See Exhibit MSD 52,
page 51 lines 3-5.
Intervener MIEC's Position on Issue 2
MIEC did not express an opinion on this issue.
ISSUE 3: USE OF DEBT TO FUND THE STORMWATER CIRP
MSD's Position on Issue 3
The Rate Commission's technical expert and MSD are in agreement that because the
amount of the Stormwater Capital Rate is relatively low, debt funding this program would have
a limited impact and would be further offset by the need for additional capital to cover debt
service payments and build an adequate reserve.
The record supports the District's position that affordability is an important component
in MSD's rate setting practice. Debt funding the Stormwater Capital Program will not improve
affordability of rates in a meaningful way. In fact, debt funding will increase the overall cost of
the program since all borrowed funds need to be paid back with interest. MSD uses debt
funding for a portion of its wastewater capital program because that program is much larger and
funding that program without debt would create charges that threaten or exceed the EPA's
affordability threshold. Debt funding would also create the need to continue to collect the rate
beyond the construction timeline just to service the debt and limit the amount of the rate revenue
that can be used for capital projects, unless the rate is regularly increased beyond the proposed
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rate to cover principal and interest payments that grow with each successive bond issue. In
regards to credit ratings, the rating agencies have expressed concerns in previous reports about
the existing debt burden ratios and the potential deterioration of debt service coverage levels.
These agencies indicated that the District's credit rating could be lowered if it is unable to meet
the required financial metrics.
Rate Commission's Technical Expert's Position on Issue 3
Ms. Lemoine states that "Based upon the Rate Proposal, it appears that the proposed
funding method may generate sufficient revenue to fund the District's projected stormwater
capital costs at the level of spending indicated in its Rate Proposal." See Exhibit RC 43. Ms.
Lemoine agrees with the District when she states "you want to be able to manage and not overly
issue debt for those kind of programs." See Exhibit MSD 52, page 68 lines 23-24
Intervener MIEC's Position on Issue 3
Mr. Gorman states, "MSD has not clearly developed a capital funding plan for allowable
stormwater capital programs to minimize cost on its retail customers." See Exhibit MIEC 45.
However, during the Technical Conference on May 17, 2018, Mr. Gorman admits that 'Well,
the use of debt has an affordability component which the District can only take on so much debt
based on the income strength of its customers, so there is limits to how much debt the
community can afford..." See Exhibit MSD 52, page 22 lines 13-17. Mr. Gorman appears to
acknowledge that because the Stormwater Capital rate is so low to start, debt funding this
program would have a limited impact that would then be further offset by the need for additional
capital to cover debt service payments and build an adequate reserve.
ISSUE 4: FAIR AND REASONABLE RATE STRUCTURE
MSD's Position on Issue 4
The District's position is that the rate structure being proposed is fair and reasonable on
all classes of rate payers. As we heard from the technical experts, there are different rate
structures that entities choose to use based upon their circumstances. MSD's technical expert,
Henrietta Locklear, testified as follows regarding the use of different rate structures: "it's just an
alternative approach to what the District is using. The District is basing the charges on the
amount of impervious area on the property, and that's an accepted rate structure and it's fair and
reasonable. Taking into account some other factors, it's a different rate structure which, you
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know, others have implemented in a way they feel is fair and reasonable. It's just not a part of
this rate structure." See Exhibit MSD 65, page 114 lines 20-25 and page 115 lines 1-3.
Rate Commission's Technical Expert's Position on Issue 4
Ms. Lemoine does not state that MSD's proposed rate structure is not fair and
reasonable. Instead, she simply suggested that there could be some lost revenue by not charging
vacant land. She testified that "Excluding these types of improved vacant land parcels
completely from stormwater billing, could potentially impact equity of cost recovery, as these
types of improved vacant land also contribute some level of stormwater runoff...." Exhibit RC
43. In addition, "There are utilities who assess an effective impervious area based on a runoff
factor for properties such as vacant properties that have compacted soil and things..." See
Exhibit MSD 52, page 64 lines 10-13.
Intervener MIEC's Position on Issue 4
MIEC did not express an opinion on this issue.
ISSUE 5: MSD's POSITION ON ZWEIG
In Zweig v Metropolitan St. Louis Sewer District, 412 S.W.3d 223 (Mo. Banc 2013), the
Missouri Supreme Court included a footnote which states "Ratepayers do not challenge MSD's
authority to levy the stormwater user charge under the Plan or Section 30(b) of the constitution.
The only claim in this case — and the only issue decided here — is whether section 22(a) prohibits
MSD from levying this stormwater user charge without prior voter approval."
Susan Myers, MSD's General Counsel, testified that "the Stormwater Capital Rate is
consistent with the District's Charter. Under Section 3.020(16), the District may "establish by
ordinance a schedule or schedules of rates, rentals, and other charges, to be collected from all the
real property served by the sewer facilities of the District, whether public or private...," See
Exhibit MSD 3B. The District has provided a detailed legal summary of MSD's authority in
Exhibit MSD 30Q.
Ms. Myers also testified that "the proposed Stormwater Capital Rate will be taken to the
voters for approval." See Exhibit MSD 3B.
ISSUE 6: MSD's POSITION ON CHARGING THE STORMWATER CAPITAL RATE
TO TAX EXEMPT ENTITIES
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It is MSD's position and has been testified as such in Exhibit MSD 30Q, that MSD's
Charter allows the District to assess any charge, fee, or tax that is necessary to carry out its
obligations of providing sewer and drainage services. More specifically, under Charter §
3.020(16), MSD has the power "[t]o establish by ordinance a schedule or schedules of rates,
rentals, and other charges, to be collected from all the real property served by the sewer facilities
of the District, whether public or private, and to prescribe the manner in which and time at
which such rates, rentals, and charges are to be paid, and to change such schedule or schedules
from time to time as the Board may deem necessary, proper, or advisable, and to collect or
enforce collection of all such charges." If a statutory exemption were to be applied to the
stormwater capital rate it would create a clear inconsistency between the two provisions, in
which case the Charter would supersede.
In addition, please see Exhibit MSD 37D for the District's detailed legal rationale for
charging the proposed Stormwater Capital Rate to tax exempt entities. As a summary, MSD
considers the Stormwater Capital Rate to be a charge or rate authorized by the Charter and not a
property tax or any other form of tax. Taxes fall into three separate categories: (1) capitation or
poll taxes (assessed to a person); (2) ad valorem property taxes; and (3) excise taxes (such as
sales, use, and licensing taxes and fees). The Stormwater Capital Rate does not fall into any of
these three categories. Therefore, the Stormwater Capital Rate is not a tax and non-profit, tax
exempt, and governmental entities are not exempt from paying it.
Neither the Rate Commission counsel nor MIEC's counsel has expressed an opinion on
this issue.
CONCLUSION
In conclusion, the District believes the issues addressed in this report reflect the most
relevant and representative topics requiring consideration by the Rate Commission. The District
has submitted a substantial amount of testimony and documentation to support this Rate Change
Proposal. The MSD Charter standard is not for MSD to implement the most fair and reasonable
rate structure, just one that is fair and reasonable on all classes of ratepayers. All evidence and
testimony provided by MSD demonstrates that MSD's proposed Stormwater Rate Change
Proposal consisting of a capital rate to mitigate flooding and erosion within our District is fair
and reasonable. MSD believes that based upon all of the information provided during these
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proceedings that MSD's Rate Change Proposal, as submitted on February 26, 2018, is the most
fair and reasonable proposal to be brought to the voters of the District for consideration.
Respectfully submitted,
usan M. Myers
METROPOLITAN ST. LOUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
Tel: (314) 768-6366
Fax: (314) 768-6279
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CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to Lisa O. Stump, Lashly & Baer, P.C., Brian J. Malone, Lashly & Baer, P.C., and Brandon
Neuschafer, Brian Cave, LLP, on this 28th day of June, 2018.
Lisa O. Stump, Esq.
Brian J. Malone, Esq.
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
lostumpAlashlvbaer. com
Brandon W. Neuschafer
Bryan Cave, LLP
211 N. Broadway, Suite 3600
St. Louis, MO 63102
John.kindschuh@,bryancave. corn
Stan M. Myers, General "Couns(e1
METROPOLITAN ST. LOUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
smyers@stlmsd.com
Tel: (314) 768-6366
Fax: (314) 768-6279
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