HomeMy Public PortalAboutJune 21, 2018 - Transcript of Rate Commission Prehearing Conference PREHEARING CONFERENCE 6/21/2018
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6 MEETING OF THE RATE COMMISSION
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8 METROPOLITAN ST. LOUIS SEWER DISTRICT
9 2018 STORMWATER RATE CHANGE PROCEEDING
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13 PREHEARING CONFERENCE
14 JUNE 21, 2018
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1 I N D E X
2 Roll Call . . . . . . . . . . . . . . . . . . .5
3 Statement by Susan Myers . . . . . . . . . . . 5
4 Statement by Brandon Neuschafer . . . . . . . 21
5 Statement by Lisa Stump . . . . . . . . . . . 33
6 Adjournment . . . . . . . . . . . . . . . . . 59
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1 PREHEARING CONFERENCE FOR THE METROPOLITAN
2 ST. LOUIS SEWER DISTRICT, produced and examined on
3 June 21, 2018, between the hours of 9:00 in the
4 forenoon and 10:14 in the forenoon of that day, at
5 the Metropolitan St. Louis Sewer District Offices,
6 2350 Market Street, Room 109, St. Louis, Missouri,
7 before Suzanne M. Zes, a Certified Court Reporter of
8 the State of Missouri.
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1 A P P E A R A N C E S
2 Commissioners:
Leonard Toenjes
3 Paul Brockmann
Mickey Croyle
4 Russell Hawes
Chan Mahanta
5 Stephen Mahfood
Tom Ratzki
6 Mark Schoedel
Jack Stein
7 Brad Goss (Via Telephone)
Paul Ziegler (Via Telephone)
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9 Representing Metropolitan St. Louis Sewer District:
Susan Myers
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11 Representing the Rate Commission:
Lisa O. Stump
12 Brian J. Malone
Lashly & Baer, P.C.
13 714 Locust Street
St. Louis, Missouri 63101
14 314.621.2939
lostump@lashlybaer.com
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16 Representing the Missouri Industrial Energy
Consumers (MIEC):
17 Brandon W. Neuschafer
. Bryan Cave Leighton Paisner, LLP
18 211 North Broadway, Suite 3600
St. Louis, Missouri 63102
19 314.259.2317
314.552.8317 Fax
20 bwneuschafer@bclplaw.com
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Court Reporter:
22 Suzanne Zes, CCR/RPR
Alaris Litigation Services
23 711 North 11th Street
St. Louis, Missouri 63101
24 314.644.2191
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1 P R O C E E D I N G S
2 (Starting time of the Prehearing Conference: 9:00 a.m.)
3 MR. TOENJES: Good morning. Being nine
4 o'clock on June 21st, 2018, we'll call the meeting
5 of the Rate Commission of the Metropolitan St. Louis
6 Sewer District to order. With that, let us start
7 with roll call.
8 Mr. Schoedel, if you would take the roll.
9 MR. SCHOEDEL: Gerry Beckmann? Paul
10 Brockmann?
11 MR. BROCKMANN: Present.
12 MR. SCHOEDEL: Don Bresnan? Mickey
13 Croyle?
14 MR. CROYLE: Present.
15 MR. SCHOEDEL: Brad Goss? Russell
16 Hawes?
17 MR. HAWES: Here.
18 MR. SCHOEDEL: Kennard Jones? Chan
19 Mahanta?
20 MR. MAHANTA: Here.
21 MR. SCHOEDEL: Stephen Mahfood? Lloyd
22 Palans? Tom Ratzki?
23 MR. RATZKI: Here.
24 MR. SCHOEDEL: Mark Schoedel. Jack
25 Stein?
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1 MR. STEIN: Present.
2 MR. SCHOEDEL: Leonard Toenjes?
3 MR. TOENJES: Present.
4 MR. SCHOEDEL: Paul Ziegler?
5 MR. ZIEGLER: Present on the phone.
6 MR. SCHOEDEL: Thank you, Paul.
7 Mr. Chairman, we have a quorum.
8 MR. GOSS: Mr. Chairman?
9 MR. TOENJES: Yes.
10 MR. GOSS: Mr. Chairman, this is Brad
11 Goss. I just got my connection to work, so I am
12 present on the phone.
13 MR. TOENJES: Thank you, Brad. I
14 appreciate it.
15 Good morning, everyone. Welcome to our
16 prehearing conference. My name is Leonard Toenjes
17 and I am the chair of the Rate Commission of the
18 Metropolitan St. Louis Sewer District and will serve
19 as chair of this proceeding.
20 Present are all the names of the folks you
21 just heard, including Paul Brockmann, Mickey Croyle,
22 Brad Goss, Russell Hawes, Chan Mahanta, Tom Ratzki,
23 Mark Schoedel, Jack Stein, Paul Ziegler, delegates
24 of the Rate Commission.
25 The Charter Plan of the District was approved
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1 by the voters of St. Louis and St. Louis County at a
2 special election on February 9th, 1954, and amended
3 at a general election on November 7th, 2000. The
4 amendment to the Charter Plan established a Rate
5 Commission to review and make recommendations to the
6 District regarding changes in wastewater rates,
7 stormwater rates, and tax rates proposed by the
8 District.
9 Upon receipt of a rate change notice from the
10 District, the Rate Commission is to recommend to the
11 Board of Trustees changes in a wastewater,
12 stormwater or tax rate necessary to pay interest and
13 principal falling due on bonds issued to financed
14 assets of the District, the cost and operation --
15 the cost of operation and maintenance, and such
16 amounts as may be required to cover emergencies and
17 anticipated delinquencies.
18 Further, any change in a rate recommended to
19 the Board of Trustees by the Rate Commission is to
20 be accompanied by a statement that the proposed rate
21 change is consistent with constitutional, statutory
22 or common law as amended from time to time, enhances
23 the District's ability to provide adequate sewer and
24 drainage systems in facilities or related services,
25 is consistent with and not in violation of any
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1 covenant or provision relating to any outstanding
2 bonds or indebtedness of the District, does not
3 impair the ability of the District to comply with
4 federal and state laws or regulations as amended
5 from time to time and imposes a fair and reasonable
6 burden on all classes of ratepayers.
7 The Rate Commission received a rate change
8 notice from the District on February 26th, 2018.
9 Under procedural rules adopted by the Rate
10 Commission, any person affected by the rate change
11 proposal had an opportunity to submit an application
12 to intervene in these proceedings. An application
13 to intervene was filed by the Missouri Industrial
14 Energy Consumers.
15 The Rate Commission originally had until
16 June 26th, 2018, to issue its report on the proposed
17 rate change notice to the Board of Trustees of the
18 District. The Rate Commission requested an
19 additional 45 days to issue its report. And on May
20 1st, 2018, the District Board of Trustees granted
21 the Rate Commission's request. The Rate Commission
22 must now issue its report on or before August 10th,
23 2018.
24 Since February 26th, 2018, the MSD Rate
25 Commission has received testimony from MSD staff,
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1 the intervener and the rate consultant. The parties
2 have also engaged in discovery requests. Technical
3 conferences were held on April 4th, 2018, May 17th
4 2018, and June 7th, 2018, where the participants and
5 the Rate Commission were given an opportunity to ask
6 questions of those submitting testimony.
7 The Charter Plan of the Metropolitan St.
8 Louis Sewer District and the operational rules and
9 procedural schedule of the Rate Commission of the
10 Metropolitan St. Louis Sewer District provides for a
11 prehearing conference to identify, define, resolve,
12 or settle the issues raised by the prepared
13 testimony, and to ensure orderly and expeditious
14 proceedings.
15 Each intervener may participate in this
16 prehearing conference conducted on the record to
17 permit counsel for the District, each of the
18 interveners, and the Rate Commission to briefly
19 describe the participant's position, if any, on each
20 of the criteria and factors identified in the
21 Charter Plan.
22 In the event participants are able to resolve
23 or settle any issues or issue raised in the prepared
24 testimony, such participants may also include as
25 part of the prehearing conference report, a joint
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1 recommendation describing each issue, the
2 recommended solution of the issue, and the rationale
3 therefore.
4 The Rate Commission is interested in the
5 views of the participants on the extent to which the
6 District's rate change proposal or any alternative
7 proposed by the participants meets or fails to meet
8 the criteria or factors for recommendations
9 contained in the Charter Plan.
10 To that end, and without requiring any
11 participant to act in a particular manner, each
12 participant is requested to make an oral
13 presentation of the participant's respective
14 position. The parties may also submit a short
15 written summary of the presentation, if desired.
16 The Commission's procedural schedule as
17 amended provides that each participant of the
18 prehearing conference shall submit on or before June
19 28th, 2018, a prehearing conference report
20 describing the issues raised by the prepared
21 testimony together with a brief description of such
22 participant's position, if any, on each issue and
23 the rationale therefore.
24 The Rate Commission has established a public
25 hearing session for the participants to be held on
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1 June 29th, 2018, at 9 a.m. at the District offices.
2 The purpose of this public hearing session will
3 include permitting ratepayers to testify, receiving
4 into evidence any prepared testimony previously
5 submitted to the Commission subject to any valid
6 objections together with discovery responses and
7 transcripts of the technical conferences, permitting
8 the Commission members to ask questions related to
9 any issue addressed by the prepared testimony or any
10 other element of the proposed rate change and
11 permitting closing statements by the District, the
12 intervener, and legal counsel for the Rate
13 Commission.
14 In preparation for the June 29th, 2018
15 hearing, the District will distribute the current
16 list of exhibits to all parties by June 27th, 2018.
17 Are there any procedural matters at this
18 time?
19 Hearing none, Ms. Myers, would you be
20 prepared to address the Rate Commission on behalf of
21 the District?
22 MS. MYERS: Yes, I am prepared to
23 present the District's position today in our
24 prehearing conference summary.
25 MR. TOENJES: Please proceed.
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1 MS. MYERS: Good morning. My name is
2 Susan Myers, and I'm the general counsel for the
3 Metropolitan St. Louis Sewer District. As you all
4 know, the District submitted a stormwater rate
5 change proposal on February 26th, 2018, to mitigate
6 flooding and erosion within our District. This
7 proposal was based upon the wants and the needs of
8 MSD's customers as they were articulated to Brian
9 Hoelscher and Lance LaComb.
10 Brian and Lance spent many months out talking
11 to the community about what additional stormwater
12 services they wanted and how much they were willing
13 to pay for such services. The accumulation of what
14 Brian and Lance learned and previous requests from
15 customers was the basis for this proposal.
16 In addition, as committed by Brian Hoelscher
17 during surrebuttal testimony, MSD staff will
18 continue to listen to the input of its ratepayers to
19 see if any change in scope or size of the program
20 should, in the future, be brought to the Rate
21 Commission for consideration.
22 This proposal is about setting a stormwater
23 capital rate that is fair and equitable to all
24 classes of ratepayers. Upon acceptance by the MSD
25 Board of Trustees, the stormwater capital rate will
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1 be taken to the public for a vote. The public will
2 decide if they want MSD to have a revenue source to
3 fund additional District-wide stormwater services in
4 the form of capital improvements to mitigate the
5 impacts of flooding and erosion.
6 You heard a lot of testimony and received a
7 lot of evidence that supports the District's
8 proposal. You've also heard a lot of thoughts and
9 comments about the methodology used by the District
10 to determine the project list. This includes the
11 methodology MSD uses to prioritize projects, how MSD
12 utilizes cost sharing and how the projects are
13 programmed into the overall Capital Improvement and
14 Replacement Program, CIRP.
15 With these in mind, the task at hand is for
16 the Rate Commission to issue its rate recommendation
17 to the Board of Trustees that meets the five
18 criteria outlined in MSD's Charter Section 7.270.
19 Criteria one of the Charter requires that the
20 proposed rate change is consistent with
21 constitutional, statutory or common law as amended
22 from time to time.
23 The proposed stormwater capital rate complies
24 with this criterion and will be taken to the public
25 to be voted on in Fiscal Year 2019.
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1 Criteria two requires that the proposed rate
2 change enhances the District's ability to provide
3 adequate sewer and drainage systems and facilities
4 or related services.
5 As shown by the District's written evidence
6 and witness testimony the stormwater capital rate
7 complies with this criterion because the main driver
8 for the proposed rate is to provide a funding source
9 via an impervious rate primarily to mitigate
10 flooding and erosion.
11 Criteria three requires that the proposed
12 rate change is consistent with and not in violation
13 of any covenant or provision relating to any
14 outstanding bonds or indebtedness of the District.
15 The District has satisfied this requirement
16 because it is not proposing the use of bonds or
17 other indebtedness and, therefore, the proposed
18 stormwater capital rate will not violate any
19 covenants or provisions of outstanding bonds or
20 indebtedness.
21 Criteria four requires that the proposed rate
22 change does not impair the ability of the District
23 to comply with any applicable, federal or state laws
24 or regulations as amended from time to time.
25 The proposed stormwater capital rate does not
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1 address any particular federal or state law or
2 regulation. The stormwater capital rate is being
3 proposed based upon the MSD ratepayers' needs and
4 wants to address flooding and erosion in our region.
5 Criteria five requires that the proposed rate
6 change imposes a fair and reasonable burden on all
7 classes of ratepayers.
8 The stormwater capital rate, as evidenced
9 through District testimony and also by your own
10 technical consultants, clearly imposes a fair and
11 reasonable burden on all classes of ratepayers.
12 The District has also identified three topics
13 for further discussion. Issue one is MSD's
14 prioritization system. You heard a lot of testimony
15 by both the District and the Rate Commission's
16 technical consultant that MSD's stormwater project's
17 prioritization system is an acceptable and
18 appropriate way to develop a Capital Improvement and
19 Replacement Program.
20 The identification and prioritization of
21 projects to be included in the CIRP is a multistep
22 process requiring monitoring and updating to ensure
23 that the highest priority problems within the
24 District are addressed in a timely manner given
25 available funding.
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1 The stormwater projects are identified to
2 address flooding and erosion issues and are
3 prioritized based upon the severity of the flooding
4 and erosion and the overall benefit provided by the
5 project.
6 In order to maximize the benefits per dollar
7 spent on a project, a benefit cost ratio is
8 calculated to determine the project priority
9 ranking. Your technical consultant agreed that this
10 type of scoring system is commonly used in
11 infrastructure projects to provide quantification to
12 project prioritization.
13 Cost sharing. Cost sharing has been a
14 discussion during the discussion about prioritizing
15 projects. It is the District's goal that the
16 projects with the highest priority are funded first.
17 With that being the case, MSD has always been
18 receptive to partnering with other entities for them
19 to provide full or partial funding contributions to
20 stormwater capital projects.
21 MSD plans to continue this policy so long as
22 the use of MSD funding does not delay the execution
23 of other scheduled projects that have a higher
24 priority. As has previously been testified to, the
25 potential use of outside funding will have no effect
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1 in the priority calculation for each project.
2 In calculating the cost of a project and
3 determining the benefit cost ratio, costs shall
4 always be the cost to complete the project
5 regardless of the source of funding. This process
6 ensures that the value of the stormwater capital
7 dollars from all ratepayers will be weighed equally
8 and not be influenced by the ability of a
9 third-party source to provide additional funding to
10 the process. This helps ensure that the
11 prioritization process is fair and reasonable to all
12 classes of ratepayers.
13 Issue 2: The Capital Improvement and
14 Replacement Program includes projects and
15 programming. Development of the CIRP stormwater
16 program includes a process for prioritization of
17 projects and also programming of those projects.
18 There have been many questions around how projects
19 are prioritized and then how they got programmed.
20 Previously I discussed the prioritization
21 process and how it is fair and reasonable to all
22 classes of ratepayers. You also heard testimony
23 from your technical consultant validating that the
24 projects currently in the CIRP program are
25 appropriate.
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1 In addition, you heard that the
2 prioritization process in place allows the District
3 to have flexibility to include new projects or
4 projects with increasing severity in the program.
5 These statements are all true and support the
6 process that has been in place for many years and
7 allows the CIRP program to be fair and reasonable to
8 all classes of ratepayers.
9 The process for scheduling our programming
10 within the annual CIRP is an iterative process
11 impacted by a number of factors. Projects are
12 generally placed in the annual CIRP according to the
13 benefit cost ratio scheduling higher priority
14 projects sooner in the program.
15 The annual CIRP typically includes a
16 five-year rolling block of projects potentially
17 being impacted by a number of factors. Those --
18 these factors and this programming process can
19 require the movement of projects both higher in
20 priority to be delayed or projects of lesser
21 priority to be expedited in the program. However,
22 as stated earlier, it is always the intent to
23 address the highest priority issues sooner in the
24 program.
25 Mr. Unverferth testified that the cost
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1 estimates were based on historical District bid
2 prices using conceptual design information,
3 technical expertise of consulting engineers and past
4 data on similar District projects. Your technical
5 consultant is in agreement and testified that the
6 District's cost estimates were completed in
7 accordance with common practice for this phase of
8 the program.
9 Issue 3: Incentives and credits. The Rate
10 Commission's technical expert and MSD are in
11 agreement regarding the incentive credit program
12 being proposed. Ms. Young testified that we should
13 focus on how effective the incentive slash credit
14 program is to reducing impervious area, not whether
15 the incentive or credit is large enough.
16 Ms. Young further testified that best
17 management practices are beneficial to the overall
18 system if they are maintained over the long term.
19 However, it is unlikely that BMPs will have a
20 significant effect in reducing the civil
21 infrastructure investments necessary in this
22 program.
23 While it is beneficial to install BMPs, MSD
24 needs to collect the funds in order to build the
25 stormwater infrastructure to undertake buyouts
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1 included in the CIRP. Increasing incentives or
2 credits may increase BMPs without actually achieving
3 a reduction in effective impervious area where
4 needed.
5 MSD testified that similar to other
6 stormwater programs across the country the District
7 has developed a proposed stormwater incentive
8 program that provides customer incentives for
9 reducing their effective impervious area through the
10 use of constructed features or low impact
11 development and the proposed program is within
12 industry norms for such programs with respect to its
13 major features.
14 Your technical consultant testified that the
15 incentive and credit program will provide some
16 nominal benefit to property owners to provide BMPs
17 without compromising the CIRP. Thus, the District's
18 program is a reasonable approach to providing some
19 benefit to BMPs while still maintaining the
20 integrity of accomplishing the CIRP.
21 As I stated at the beginning of my statement,
22 the task at hand is for the Rate Commission to issue
23 its rate recommendation to the Board of Trustees
24 that meets the five criteria outlined in the MSD
25 Charter Section 7.270. Upon review of the complete
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1 record of these proceedings you will be able to
2 determine that the District's proposal does just
3 that.
4 This concludes the District's official
5 summary statement. A copy of our statement will be
6 filed as Exhibit MSD 64. Thank you.
7 MR. TOENJES: Thank you, Ms. Myers.
8 Do any of the Rate Commissioners have
9 questions for Ms. Myers at this time?
10 Hearing none, Mr. Neuschafer, would you like
11 to address the Rate Commission on behalf of Missouri
12 Industrial Energy Consumers?
13 MR. NEUSCHAFER: I would. Thank you.
14 As you're all aware, I'm Brandon Neuschafer
15 and I represent the Missouri Industrial Energy
16 Consumers. I don't intend to rehash all the
17 arguments outlined in the testimony submitted to
18 date and in the reports that will be submitted next
19 week. You'll see a much deeper explanation of our
20 position with support from the record at that point
21 in time. But I do want to make a few points right
22 now.
23 It's MSD's duty to propose a program that is,
24 among other things, fair and reasonable to the
25 ratepayers. The Rate Commission's role in this
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1 proceeding is to hold MSD to that standard.
2 Regrettably, the CIRP as proposed is neither fair
3 nor reasonable to the ratepayers.
4 First, we're concerned that the purported
5 public support for the program has been overstated.
6 MSD's data indicates that in most years from 2012 to
7 2017 they received about 300 calls per year
8 regarding flood and erosion issues. Some years it
9 was higher and in some of those years there was
10 significant flooding events.
11 But given the fact that MSD has approximately
12 425,000 accounts representing a population of 1.3
13 million individuals and will have approximately
14 465,000 accounts if it undertakes this program, that
15 means that about 0.00065 to 0.0007 percent of MSD's
16 accounts are contacting MSD on an annual basis about
17 flooding and erosion issues. That's hardly a clamor
18 from the rate-paying public.
19 Additionally, MSD has relied on a public
20 survey to support the need for the program.
21 Contrary to MSD's assertions, the survey clearly
22 indicates that nearly three-quarters of MSD's
23 ratepayers are not willing to pay the rates being
24 proposed by MSD. Recall that the current proposal
25 imposes a rate of $2.25 per month per ERU and may be
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1 as much as $6.84 for residential properties with
2 large amounts of impervious area.
3 The survey data, however, indicated that only
4 32 percent of respondents would support a monthly
5 rate of $2 per month or more. That's less than what
6 MSD is actually proposing. A full 69 percent of the
7 respondents indicated that they either would not
8 support an increase to manage the stormwater issues
9 or would only support a 1 dollar per month increase.
10 Second, a lot has been made about the minimal
11 amount of engineering analysis and cost estimation
12 to support this program. This is not an
13 insignificant point. Conceptual ideas and, quote,
14 minutes-long analyses often based on information
15 that's decades old is not sufficient.
16 I understand that MSD needs additional
17 resources to do a deeper dive into the size and
18 scope of the program it's proposing, but at the same
19 time MSD owes a duty to the rate-paying public to
20 have confidence that this work needs to be completed
21 and to tailor a program including both rates and
22 duration that is appropriately scoped.
23 It's neither fair nor reasonable to
24 ratepayers to fund a program with deficiencies or
25 ask for ratepayers to write a blank check and let us
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1 figure out what the program will entail later.
2 Additional deficiencies in the design of the program
3 will be identified in our report.
4 For example, despite all the discussion we've
5 had about how MSD prioritizes the projects within
6 the CIRP, MSD seems to have skipped over the
7 question of whether these projects truly justify
8 spending public money in the first instance or
9 whether at some point the costs of a particular
10 project outweigh the benefits.
11 Additionally, the rates and annual revenues
12 appear to have been designed based on what MSD
13 things the public will stomach, not factors such as
14 actual need or urgency of projects. In light of
15 recent and upcoming wastewater rate increases we
16 need to be more cognizant of the impact of quickly
17 rising rates on the public.
18 Third, similar to the inadequate engineering
19 and cost analyses conducted by MSD is the failure to
20 properly consider bond financing. MSD has made it
21 clear that it never considered bond financing for
22 this program and the arguments it presents in
23 opposition to bond financing are merely post hoc
24 rationalizations of that decision.
25 As will be explained more fully in our
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1 post-hearing brief, MSD has a strong financial
2 position and the ability to use debt to fund a
3 competent capital plan. To be clear, MIEC is not
4 arguing that debt absolutely must be used to fund
5 the CIRP, but the rigger and programmatic planning
6 and protection of the customer interest. In other
7 words, the fairness and reasonableness of the
8 program being proposed requires a proper analysis of
9 the use of bond funding. Indeed that's ultimately
10 what MIEC's position entails.
11 The CIRP is based on minimal engineering,
12 aged data, hasty cost estimation and incomplete
13 financial planning, all in the absence of any
14 grounds of public support. As such, the program is
15 proposed as neither fair nor reasonable to any class
16 of MSD's ratepayers.
17 Thank you for your time. We appreciate your
18 careful consideration of our position.
19 MR. TOENJES: Thank you, Mr. Neuschafer.
20 Do any of the Commissioners have questions
21 for Mr. Neuschafer?
22 Hearing none -- we have one. Mr. Brockmann?
23 MR. BROCKMANN: Mr. Neuschafer, you
24 mentioned bonds but does it not cost a considerable
25 amount of money to just go out and prepare and issue
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1 bonds and wouldn't that offset a lot of the cost
2 benefit and the amount of bonds would have to be, I
3 would think, several hundred thousand to be
4 beneficial, we're only talking 30 million per year
5 -- I'm sorry, several hundred million, not thousand.
6 MR. NEUSCHAFER: So we will address that
7 point in our papers because, frankly, our expert is
8 the person who understands the bond issue a bit
9 better. I'm not a financial person, but my
10 understanding is that a bond program could be
11 created and yes, you know, there is debt service
12 that would need to be paid over the years and there
13 is spending involved in issuing the bonds and paying
14 back those bonds over a period of time but those are
15 paid back over a period of time.
16 There are projects within this program that
17 would be more appropriate for bond funding based on
18 the nature of the projects. And, importantly, use
19 of bonds could, at this point in time, minimize the
20 initial impact on ratepayers. Yes, it may result in
21 paying back the bonds over a longer period of time
22 but we're also considering the impact over a short
23 period of time on ratepayers and that is where the
24 use of a bond program could be more beneficial to
25 ratepayers.
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1 MR. BROCKMANN: Will you also be
2 advocating increasing the spending? If you're
3 issuing the bonds you could possibly have more money
4 up front and knock out more of these projects at a
5 faster rate than what's being proposed?
6 MR. NEUSCHAFER: That's not part of our
7 proposal. Should MSD decide that that's appropriate
8 I think we could consider that.
9 MR. TOENJES: Any further questions?
10 Yes, Mr. Schoedel?
11 MR. SCHOEDEL: Is it your organization's
12 opinion that based on the survey data that MSD has
13 gathered that there isn't a flooding and erosion
14 issue in the ratepayers' area?
15 MR. NEUSCHAFER: No. And let me be
16 clear, the position is not that there isn't a
17 flooding and erosion issue. There may be local,
18 regional flooding or erosion issues. Our position
19 is that there's no support from the ratepayers to
20 pay for a program to address these issues.
21 MR. SCHOEDEL: Okay. Thank you.
22 MR. MAHANTA: I have a question.
23 MR. TOENJES: Yes, Mr. Mahanta?
24 MR. MAHANTA: Yes, Mr. Neuschafer, the
25 fact that the numbers of complainants are small,
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1 does it in any way take away the importance to those
2 complainants about mitigating flooding and erosion
3 and things that they are suffering from?
4 MR. NEUSCHAFER: So I have a few points
5 to make in response to that. First, we're not
6 saying that there are no erosion or flooding issues
7 but this is a voluntary program. There's nothing
8 that requires MSD to undertake this program and in
9 order to have a properly I guess scoped program,
10 yeah, we need to do a few things. We need to make
11 sure that we have the data and the support for the
12 program. We need to make sure that the projects are
13 properly prioritized and we also need to make sure
14 that there really is public support for this
15 program. And, yes, there may be a small subset of
16 MSD's customers that are experiencing flooding and
17 erosion issues.
18 I think ultimately the question is: Is it
19 MSD's issue to deal with? Is it the ratepayers --
20 that the rest of the ratepayer pays? Is it
21 something that they should be funding? Is it fair
22 and reasonable for the ratepayers to fund that?
23 So I don't want to leave the impression that
24 we don't think there are any erosion or flooding
25 issues. The ultimate question is: Is this the
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1 right program? Has this program been designed
2 properly? Does the public really support this
3 program? The public as a whole, that's who's paying
4 for it. That's our concern.
5 MR. TOENJES: Yes, Mr. Brockmann?
6 MR. BROCKMANN: Mr. Neuschafer, based on
7 what you just said you're talking about a few number
8 of people that are experiencing problems but I
9 thought we were talking that this is a regional
10 issue. You don't feel it's a regional issue?
11 MR. NEUSCHAFER: It's a regional -- I'd
12 say it's a regional issue in that there are flooding
13 and erosion concerns throughout MSD's region. Some
14 of the flooding or erosion -- the individual
15 flooding or erosion issues certainly affect more
16 than just one or two pieces of property. That -- I
17 don't think there's any dispute about that.
18 I'm not arguing and MIEC is not arguing that
19 there are not erosion or flooding issues. We're not
20 arguing that there are not erosion or flooding
21 issues at many different places throughout MSD's
22 service area. What we are arguing is that there
23 really does not appear to be the level of public
24 support that MSD has argued exists for this program
25 and that the program as designed is not the most
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1 fair and reasonable program for the ratepayers to
2 deal with those issues.
3 MR. BROCKMANN: I guess I struggle a
4 little bit with you're not wanting to say it's
5 regional issue. There was flooding on the streets
6 that didn't affect property two days ago and part of
7 this proposal it says that 30 percent of the
8 impervious surface within MSD's District is not
9 being taxed because it is public streets and
10 right-of-aways and yet people's cars were floating
11 down the streets the other day and that's all on
12 public property and not on private property. How do
13 we address that?
14 MR. NEUSCHAFER: Well, perhaps that's
15 another issue with the design of the program to
16 exempt those impervious areas that are contributing
17 to flooding issues.
18 MR. BROCKMANN: And how would you
19 propose that MSD collect for those areas?
20 MR. NEUSCHAFER: It's not my program to
21 propose. It's MSD's -- you know, frankly, it's
22 MSD's program to propose a fair and reasonable
23 program to the ratepayers.
24 MR. BROCKMANN: That's all I had.
25 MR. TOENJES: Mr. Hawes, you have a
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1 comment?
2 MR. HAWES: Yes. Mr. Neuschafer, you've
3 stated multiple times that there doesn't appear to
4 be the support for this program but isn't part and
5 parcel to this proposal a vote of the people, so is
6 that not how the support would be defined? I mean,
7 if they have what MSD has put together in front of
8 them, do you not feel that the voters can determine
9 what they support and what they don't?
10 MR. NEUSCHAFER: Yeah, ultimately the
11 voters will decide and they'll decide next spring.
12 Nonetheless, we still have an obligation at this
13 point in time to determine whether it's fair and
14 reasonable to take this to the voters and that's --
15 that's the issue that we're raising.
16 MR. HAWES: So the 2.25 -- you mentioned
17 a survey where I think you said that 69 percent do
18 not support increase over $1 a month?
19 MR. NEUSCHAFER: Yes.
20 MR. HAWES: Are you suggesting that they
21 should redesign their program to fit within those
22 parameters, a dollar per month or something along
23 those lines? At what point between a dollar and
24 2.25 does it become reasonable?
25 MR. NEUSCHAFER: And the only data that
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1 I've got is what's in that survey. There were
2 multiple -- I guess there were multiple dollar
3 amounts that were addressed in that survey. We've
4 got more of a breakdown in the paper that we'll file
5 next week. But customers were asked about would you
6 be willing to pay basically anything and there was
7 still a pretty large number, I think it was less
8 than 50 percent, I don't have the numbers in front
9 of me, but less than 50 percent that said, "I don't
10 want to pay a thing," then there was a pretty large
11 number that said, "I don't want to pay more than a
12 dollar."
13 Those two, the groups of people that said, "I
14 don't want to pay a thing," and "I don't want to pay
15 more than a dollar," totaled 69 percent. And then
16 the survey was designed such that they also asked,
17 "Would you pay $2? Would you pay $3? $4? $5?"
18 Those that said, "I would be willing to pay
19 $2 or more," those equated to about 62 -- or I'm
20 sorry -- 32 percent. The numbers are a little off
21 because of rounding but that's ultimately where they
22 came down.
23 MR. HAWES: And this was statistically
24 -- was it polling or what was the methodology of
25 that?
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1 MR. NEUSCHAFER: The actual survey, the
2 final report of the survey is part of the record and
3 we can direct you to that. I don't have the answer
4 to that question right now but it's part of MSD's
5 support for the program, so if it's not
6 statistically significant or if there are other
7 deficiencies in the design of the survey that --
8 MR. HAWES: So this is the same survey
9 that MSD has --
10 MR. NEUSCHAFER: The absolute same one,
11 yeah.
12 MR. HAWES: Okay. I don't have any more
13 questions. Thank you.
14 MR. TOENJES: Thank you, Mr. Hawes.
15 Anything further?
16 Hearing none, thank you, Mr. Neuschafer.
17 Ms. Stump, would you like to address the Rate
18 Commission as our legal counsel?
19 MS. STUMP: I would. Thank you.
20 And as your legal counsel my role in this
21 prehearing conference is a little bit different.
22 Ultimately the Rate Commission is going to have to
23 make a recommendation in its report as to whether
24 the rate change proposal made by the District is
25 consistent with the five criteria and the three
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1 factors that Mr. Toenjes read early in the
2 introduction of this prehearing conference.
3 Most of the issues that we've heard so far in
4 these proceedings have turned on the criteria of
5 whether the proposed rate change is fair and
6 reasonable. You also have to find that the proposed
7 rate change is consistent with the law and there are
8 a couple of issues that pop up, which the Rate
9 Commission will need to address.
10 But my role really here today is to help
11 summarize the issues for you based on the evidence
12 that's in the record and also describe the positions
13 of the parties on the issues. When you get to
14 deliberations you all can discuss in detail the
15 issues and certainly we will be providing more
16 documentation on these in our report that we file
17 next week.
18 So let's go through a few of the questions
19 that have been raised. I think the first issue that
20 the Rate Commission will have to consider is
21 questions relating to the overall program and, as
22 you've heard from both Ms. Myers and Mr. Neuschafer,
23 the first question is really is the $562 million in
24 projects the right amount?
25 The District has proposed that the stormwater
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1 CIRP is prudent and reasonable and established
2 evidence in the record to that effect. As you heard
3 from Mr. Neuschafer, MIEC disagrees with that. The
4 testimony of their expert was that there's
5 inadequate planning to justify 30 million a year of
6 revenue collection from customers. There was a lot
7 of discussion about it because the projects being a
8 preliminary list of projects and there wasn't
9 adequate justification for this amount.
10 And you've also heard testimony from the Rate
11 Commission consultant, Ms. Young, that disagreed
12 with MIEC and in fact says that there is sufficient
13 reasonable planning by the District for the program.
14 Also related to the size of the program you
15 heard questions from the Commissioners themselves as
16 to whether in fact the $562 million is enough. The
17 District says that it is a reasonable start but you
18 did hear discussion about whether that amount is
19 going to be sufficient to address the problem.
20 The second question relating to the overall
21 program is related to the use of debt. As you heard
22 from Mr. Neuschafer, his client asserts that the
23 Rate Commission should at least be considering the
24 use of debt for this rate change.
25 You've heard from the District, however, and
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1 specifically Mr. Gee testified that the District
2 should make improvements in the most affordable way
3 possible and debt funding will automatically
4 increase costs, moreover because the rate is so low
5 debt funding will have limited impact. And you also
6 heard from the District some concern about using
7 debt funding for this proposal when we are
8 presumably facing a wastewater rate change proposal
9 next year.
10 In the debt discussion we also had the issue
11 come up that tax exempt bonds can only be utilized
12 for improvements on facilities owned by the
13 District, which led us to our next issue for the
14 Rate Commission to consider which is whether MSD
15 could make and fund capital improvements on private
16 property.
17 The District, mainly and through
18 Mr. Hoelscher, discussed about how the Charter does
19 give them the authority to provide effective means
20 of ensuring the area within the whole District has
21 adequate sanitary and stormwater drainage and thus
22 they can remediate and provide improvements on
23 private property. You also heard the District
24 discuss that they will be getting easements in order
25 to do so.
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1 And you heard MIEC's expert, however, say
2 that it's also consistent with standard practices
3 for utilities that they don't make investments on
4 private property.
5 Your own rate consultant testified in support
6 of having MSD make improvements on private property,
7 discussing that if the capital program is addressing
8 erosion and flooding issues that are on private
9 property, for instance in the example of a steam
10 erosion -- stream, excuse me, erosion, that runoff
11 is occurring and that erosion is occurring due to
12 runoff through the watershed and so in that regard
13 it's benefiting the entire watershed area and the
14 service area.
15 And then the final issue related to the
16 District's overall program with the proposed capital
17 rate is the one that we've spent probably the most
18 time on and that is should private groups be allowed
19 to contribute funds to move their project up the
20 list. The discussions really revolved around the
21 issue of source of funding versus project cost and
22 you heard both from Mr. Myers and Mr. Neuschafer on
23 this today.
24 MSD has noted that they would be receptive to
25 cost-sharing arrangements but will always, to be
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1 fair and equitable, consider outside funding to be
2 the same as MSD funding in terms of calculating the
3 project score on their scoring sheet. That
4 municipalities and homeowners' associations may
5 participate but it's not going to change the project
6 cost.
7 And the District identified that certainly
8 they are open to and willing to have anyone
9 participate and they did specify that if it was
10 within a year it could move the project up the list
11 but only within the confines of that year.
12 MSD also testified that the process that they
13 have on the check -- the scoring card and the
14 project cost eliminates discrimination for those
15 municipalities with limited insufficient stormwater
16 funding and they also provided evidence that they
17 had a professional opinion that the prioritization
18 system is appropriate.
19 The rate consultant, Nicole Young, spent a
20 lot of time testifying on this issue and engaging
21 with some of the commissioners in a discussion on
22 this issue and also agreed with MSD's approach
23 stating that it would not be fair and equitable to
24 change -- in her opinion, to change the manner in
25 which MSD was doing the scoring and the score card.
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1 So those are pretty much the issues related
2 to the program itself. We also heard discussion
3 related to the method of imposition of the
4 stormwater capital rate and there were some
5 questions that came up in this regard.
6 As we've mentioned, one thing that the Rate
7 Commission has to do is find that the proposed rate
8 change is consistent with the law. We know that the
9 stormwater capital rate will be a rate that's
10 imposed based on impervious area and while we have
11 had discussion in this and prior proceedings that
12 that is the most fair and equitable means in which
13 to do it, there are still some legal issues that
14 remain that the Rate Commission may have to
15 consider. Specifically the footnote in the Zweig
16 case still raises some questions as to whether MSD
17 can do any stormwater rate that is not based on the
18 value of property.
19 The second legal issue with respect to the
20 rate is that MSD, as we've heard, will be charging
21 nonprofits and governmental property the same as
22 other property and there's a question as to whether
23 this is permissible.
24 MSD has testified that in both situations,
25 both of those legal issues, it has a legal opinion
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1 supporting the current method that it's going to be
2 doing with the stormwater capital rate. But that's
3 just something that we're going to have to consider
4 as we go through the process and making a
5 declaration that the rate is consistent with the
6 law.
7 The other issues related to the method of
8 imposition of the rate and there was discussion in
9 the record on -- related to, you know, all parties
10 agree that the impervious area is best but the issue
11 came up should MSD differentiate for compacted dirt.
12 In doing so your consultant believes that utilities
13 can assess an effective impervious area based on a
14 runoff factor for properties such as vacant
15 properties that have compacted soil and things.
16 The MSD expert testified that to do so would
17 be time-consuming and prone to errors and difficult
18 to administer. So, again, that's going to have to
19 be an issue that the Rate Commission considers.
20 And, finally, the other issue related to the
21 rate itself, there was testimony about the incentive
22 programs and whether the incentive programs are
23 adequate incentives and should MSD consider
24 additional programs. The consensus I think seemed
25 to be from all the parties was perhaps the incentive
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1 programs were small but when asked if there were
2 other alternatives there haven't been any that have
3 really been proposed for the Rate Commission to
4 consider.
5 So that's a summary of the issues that we
6 will be able to address more fully with you as we
7 get into the deliberation process and we will
8 summarize the evidence a little bit more in the
9 written document that we submit next week.
10 MR. TOENJES: Do any of the Rate
11 Commissioners have -- Mr. Stein?
12 MR. STEIN: Ms. Stump, you mentioned the
13 legal issues, one of which was the Zweig footnote.
14 Have you had the opportunity to review the legal
15 opinions that the District sought indicating that
16 this proposal will satisfy those legal requirements?
17 MS. STUMP: We have not reviewed the
18 legal opinion that has been provided to this date.
19 MSD has asserted that it's privileged. MSD did
20 submit and has -- on two occasions where it has
21 legal opinions submitted a summary of that into the
22 record. But, no, we have not reviewed the legal
23 opinion.
24 MR. STEIN: Thank you.
25 MR. TOENJES: Yes, Mr. Ratzki?
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1 MR. RATZKI: You stated that the
2 incentives are small and I agree with that, but do
3 you feel like they meet the fair and equitable test,
4 so -- we need to have incentives in a program like
5 that, in my opinion, to make sure that the rate is
6 fair and equitable, but do you feel like size
7 doesn't matter in that case as long as they have
8 one?
9 MS. STUMP: Well, I'm just summarizing
10 it for you, so I'm going to let Pam because she
11 would be the one advising you on that.
12 MS. LEMOINE: No, I do agree that having
13 the incentive and credit program is an important
14 element of a stormwater user fee, having that
15 ability to adjust what you're paying based on
16 actions you're taking on the property. The
17 incentives and the credits are small but the fee
18 overall is small and the overall percentage credits,
19 if you will, are consistent with what others use in
20 the industry.
21 MR. RATZKI: Chair, is Pam going to
22 speak also or is this our only chance to talk to
23 Pam?
24 MR. TOENJES: Continue. Go ahead.
25 MR. RATZKI: I just want to make sure
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1 one of the statements that Ms. Myers made, because
2 there's no bonds involved, that will meet the
3 criteria in the Charter that there's no impact on
4 the District's bond convenants? I think you
5 testified to that earlier.
6 MS. LEMOINE: Yes.
7 MR. RATZKI: Okay. I just wanted to
8 confirm that. Thank you.
9 MR. TOENJES: Yes, Mr. Mahfood?
10 MR. MAHFOOD: Direct this back to Pam,
11 just talking about the incentives issue again, and
12 maybe it does go back to something also Lisa said,
13 are we open to any proposals, let's say from Rate
14 Commissioners, to modify the incentive program to
15 consider them? Is that -- you mentioned we haven't
16 seen anything as an alternative.
17 MS. STUMP: I'm just talking about
18 what's in the evidence so far.
19 MR. MAHFOOD: Gotcha.
20 MS. STUMP: When the Rate Commission
21 makes its deliberations, the Rate Commission has the
22 ability to do whatever the Rate Commission would
23 choose to do. The difficulty is that we haven't had
24 a discussion. We don't know what MSD's reaction
25 would be to those, but certainly they can be
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1 discussed because -- and this is just a reminder
2 too, after the next public hearing, when the Rate
3 Commission gets into its deliberations, that will
4 just be amongst you all, amongst yourselves and
5 you'll have the ability to talk to Pam and I but
6 there will no longer be the ability to talk to any
7 of the other parties.
8 MR. MAHFOOD: Thank you.
9 MR. TOENJES: Mr. Schoedel?
10 MR. SCHOEDEL: And with respect to the
11 incentive program, Pam, is there any way that you
12 can gather more data for us and any other incentive
13 programs that are out there to see if there would be
14 anything else that would be fair and equitable that
15 the Rate Commission could at least consider?
16 MS. LEMOINE: Yes, I could provide you
17 with some examples. I know there's some examples
18 that are in the record already but we could provide
19 you with some other examples as well.
20 MS. STUMP: And perhaps too, in doing
21 this issue in our report, we can cite to you two of
22 the examples that are already in the record.
23 MR. SCHOEDEL: Thank you.
24 MR. TOENJES: Yes, Mr. Mahanta?
25 MR. MAHANTA: Would it be possible for
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1 the Rate Commission members to propose additional
2 measures to the current existing or proposed
3 incentive programs as a part of our deliberations?
4 MS. STUMP: Again, yes, the Rate
5 Commission can propose additional incentive measures
6 to the Board of Trustees in its report.
7 MR. TOENJES: Any further questions?
8 Yes, Mr. Brockmann?
9 MR. BROCKMANN: Lisa, if we look at this
10 process, MSD's presentation to the Rate Commission
11 and each time we do this every other year, so forth,
12 this particular one seems like it wouldn't be all
13 that difficult because it's a service that -- let me
14 rephrase that. It could be difficult or could not
15 be difficult, for one, a service is not being
16 provided, it's not mandated by law, it's not that
17 much money it doesn't seem like at the end of the
18 day.
19 But then so if we look at this as fair and
20 reasonable and let's just assume that everything
21 comes out that this proposal is fair and reasonable
22 and we make this decision recommendation to the full
23 board but later on there's going to be more rate
24 increases that come to the Rate Commission that are
25 going to have to be implemented because of the
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1 Consent Decree, so how do we evaluate this one as an
2 individual thing and not consider everything going
3 forward that might be mandated by the Consent
4 Decree?
5 MR. TOENJES: Mr. Brockmann, I have --
6 I'll jump in here a little bit. I guess from my
7 perception the fair and reasonable discussion, and
8 please correct me, Ms. Stump, but in my view the
9 fair and reasonable discussion is about the
10 distribution of current costs across all classes of
11 ratepayers.
12 The fair and reasonable is not compared to
13 your electric bill and your mortgage and all of your
14 entertainment expenses. Fair and reasonable has to
15 do with is this 562-million-dollar bill being
16 distributed across all classes of ratepayers in a
17 way that is fair and reasonable to all classes of
18 ratepayers.
19 MS. STUMP: And you are correct. I
20 mean, what the Charter specifically says is -- and
21 that's the other thing that's important to consider,
22 is your duty is to look at the proposed rate change.
23 That's what we're looking at today and that is just
24 this one rate and then whether that proposed rate
25 change imposes a fair and reasonable burden on all
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1 classes of ratepayers.
2 MR. BROCKMANN: Okay.
3 MR. TOENJES: I think it's more of a
4 distribution discussion than an amount discussion in
5 that particular regard.
6 MS. STUMP: Right. And we'll get into
7 this more in the deliberations too but I think it's
8 -- I mean, I appreciate knowing whatever you all are
9 thinking so we can address that.
10 MR. SCHOEDEL: I think Mr. Brockmann's
11 comment is valid though. With us knowing that
12 additional rate changes are coming, how do we keep
13 those separate from this one in this whole
14 discussion?
15 MS. STUMP: I think that your obligation
16 is to look at that particular rate change. We may
17 know that other ones are coming. We don't know --
18 and that is in the record. They have said that they
19 are planning on submitting one. We don't know the
20 details of that though, so that's just part of --
21 that's kind of why you guys are sitting where you
22 are to make these policy determinations.
23 MR. TOENJES: Further questions?
24 MR. GOSS: Mr. Chairman?
25 MR. TOENJES: Yes, Mr. Goss?
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1 MR. GOSS: If I might, on the incentive
2 program I understood from MSD that they were looking
3 further into how they might be able to provide
4 incentive -- an incentive program through or to an
5 owner's association, through that kind of pooling
6 concept that we -- that I talked about with them
7 during the hearing.
8 Are we going -- do we know if MSD will get
9 back to us further on that or is that something that
10 we as a Commission can propose if we think that's
11 something that's reasonable to do?
12 Sorry for the compound question, Lisa.
13 MS. STUMP: You are correct that in the
14 record, when you did have that discussion, MSD said
15 they were willing to look into it further. I will
16 let MSD comment but I would assume that should the
17 Rate Commission wish for MSD to do so that would be
18 a part of their report. I don't know if MSD plans
19 on looking at that before the end of this proceeding
20 or not.
21 MR. HOELSCHER: It's Brian Hoelscher
22 with MSD, Brad. I recall a lot of the discussion
23 not being on the record but that's fine. Yes, we're
24 going to send some information to you about pooling
25 as opposed to individual homes.
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1 I think I'd like to point out we're going to
2 provide that because we view it as a -- as an
3 extension or similar to what we do for current
4 homes. So while we've shown you the -- we've shown
5 you the credits, the incentives that we're
6 proposing, there's a lot of detail into the
7 implementation. When we run into situations that
8 look similar to what we're doing, we would do that.
9 In this case, MSD is just viewing it as
10 mechanically if there's a way to provide the credit
11 so it's equivalent to what we're doing for each
12 individual home, we'll do that.
13 I want to make sure the Rate Commission
14 understands that isn't the only time that this kind
15 of thing happens. The one we always talk about, we
16 know there's a property owner, who lives at the top
17 of the hill, whose predecessor built a big pond and
18 all their impervious area goes in that pond and does
19 not leave their property. We're planning on
20 treating those individuals as though they live next
21 to a large river and they're going to get a 70
22 percent credit.
23 Now, you don't see that spelled out. You see
24 us indicating we're going to give credits for next
25 to large rivers or equivalent situations. So we
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1 will provide that and I think we're going to -- I
2 think we're to the point where we think there is
3 mechanically a way we could do that, we could
4 provide that for information, I just don't want to
5 leave the Rate Commission with the idea that we're
6 not going to manage the credit policy. It would be
7 impossible to have a credit policy for how the
8 credit applies in detail to every situation we run
9 into.
10 But I think in answering Mr. Goss' question,
11 yes, we will provide something that shows we think
12 we mechanically have a way that we can pool the
13 individual home credits for capturing 500 square
14 feet of impervious area. We'll get that to you
15 soon.
16 MS. STUMP: So, just to clarify, can we
17 get that in the record then before the 29th?
18 MR. HOELSCHER: Before the 29th? Yes --
19 MS. STUMP: Would you be willing --
20 MR. HOELSCHER: -- we will do that.
21 MS. STUMP: Okay.
22 MR. HOELSCHER: We will forward that to
23 you before the 29th. We'll file it as an exhibit.
24 MS. STUMP: Perfect.
25 MR. GOSS: Thank you.
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1 MR. TOENJES: Any further questions?
2 MR. MAHFOOD: Just kind of adding to our
3 discussion back on the incentive side and talking
4 about the future and our future deliberations and
5 commitments to meeting the Consent Decree, I can
6 tell you that from the -- since runoff from
7 impervious surface winds up collecting toxic
8 pollutants while it moves its way through the system
9 and out into the waterways, I know the Coalition for
10 the Environment sees this program as a really -- a
11 good faith effort to meet the spirit of the Consent
12 Decree, if not directly linked to the Consent
13 Decree. So for us it's very important as we go
14 forward and the importance of meeting the other
15 requirements in the Consent Decree, this seems to be
16 -- again, this is not analyzing -- pre-analyzing
17 where we're going deliberation-wise in determining
18 exactly the fair and reasonable part of this when we
19 make our final decision but in general and as an
20 overview think this whole concept is very important
21 and is in my mind, and this is my personal opinion,
22 this helps even the Coalition and others deal with
23 this issue from a legal perspective and can use this
24 very strongly, if done correctly, this program as a
25 way of meeting our commitment to improving water
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1 quality in the St. Louis area. So I wanted to get
2 that into the record.
3 MS. STUMP: Good.
4 MR. TOENJES: Thank you, Mr. Mahfood.
5 Further questions? Comments?
6 I have one question, Ms. Stump. Going back
7 to the legal issues on the impervious area, how does
8 the fact that this is a public vote impact that -- I
9 guess my question is if the public vote -- the
10 public chooses through a public vote that the use of
11 an impervious area is -- passes by the electorate,
12 what's the legal implication of that?
13 MS. STUMP: Well, if it wasn't going to
14 a vote there would be -- there would be an
15 additional issue, let's put it that way.
16 As far as the remaining issues about the
17 Zweig -- the issue is, and I don't know if you all
18 recall from last time and I'll be happy to re-brief
19 this for you too, but the Zweig opinion had this one
20 footnote where they -- you know, since it went to
21 the vote of the people it was -- or since it was
22 going to go to the vote of the people that was the
23 discussion but there was a discussion in the
24 footnote about whether MSD has the authority to
25 impose a stormwater charge upon -- in an impervious
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1 manner. So it's an authority question, not a does
2 it need to go to the vote question. And, again,
3 it's just this one footnote.
4 MR. TOENJES: So the vote -- would the
5 vote have the potential to grant that authority to
6 MSD?
7 MS. STUMP: It's an unrelated issue.
8 MR. TOENJES: Thank you.
9 MS. STUMP: And that's why it was just a
10 footnote in this decision.
11 MR. TOENJES: Okay.
12 MS. STUMP: And, again, MSD says they
13 have an opinion that says they do have the authority
14 to do it. We'll give you some guidance on that
15 during the deliberation but it's a separate issue.
16 MR. TOENJES: Thank you.
17 Further questions for Ms. Stump?
18 Hearing none, are there any other matters
19 from any of the Rate Commissioners that we should
20 address before we adjourn?
21 MR. RATZKI: Is this our last chance to
22 speak? I have a comment.
23 MR. TOENJES: It is not our last chance
24 to speak but you certainly may make a comment while
25 it's fresh on your mind. If you are like me, say it
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1 now before you forget.
2 MR. RATZKI: Mr. Neuschafer made the
3 comment that this is a voluntary program, the
4 District can or cannot do this and I want to make
5 sure that the Charter is in place that the District
6 -- I know the District has the authority to do
7 stormwater matters and take care of stormwater
8 issues but does the District feel like it's a
9 voluntary obligation, I think is the exact term as
10 Mr. Neuschafer said, to have gone forward with this
11 proposed program?
12 MR. HOELSCHER: So it's a good point to
13 clarify. So when we indicate, we'll use the word
14 "voluntary" because it's coming up, in that context
15 if there is a distinct legal requirement to perform
16 something we consider that not voluntary. If there
17 is a distinct outline of facilities we own that we
18 are required to operate and maintain, therefore
19 collect revenues, I think in this context we're
20 saying that's involuntary. The reason we're calling
21 this voluntary is that it is a power that's
22 available to the District to institute if we move
23 forward.
24 Now, I will and I think with pretty much
25 confidence say most people believe and I think
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1 they're correct if you read the Charter and
2 especially read the preamble to the Charter of the
3 original thought of the freeholders who put the
4 Charter together, the intent was for this to be
5 MSD's responsibility area-wide. So we've been very
6 careful not to say that that's the reason. We've
7 been trying to be absolutely legally correct about
8 when we say mandated or not mandated. But I think
9 that issue is out there and I think a full reading
10 of the Charter may lead you to believe that the
11 intent was for MSD to be the one to address these
12 issues.
13 MR. RATZKI: And in the same spirit that
14 Mr. Mahfood spoke of his organization that he
15 represents, The Engineers Club of St. Louis, when I
16 said my creed as a professional engineer, the
17 highest standard we have to attain is to protect the
18 health and welfare of the public and in my opinion
19 providing regional and localized stormwater capital
20 improvements to prevent and mitigate the flooding
21 that we've seen recently is something that I'll use
22 the word "obligation" of the District since it is
23 empowered to do that and I think this program should
24 be considered -- it should be voluntary, it should
25 be something the District takes as a consideration
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1 of their responsibility and this is a program that
2 you put forward to try to do that and I support it
3 from that standpoint.
4 MR. TOENJES: Thank you, Mr. Ratzki.
5 Any further comments? Mr. Schoedel?
6 MR. SCHOEDEL: That opens up another
7 question because it doesn't seem to be gray that
8 this is MSD's responsibility as you currently
9 require new development to do stormwater control and
10 water quality.
11 MR. HOELSCHER: So one of the regulatory
12 requirements that MSD has from the State of Missouri
13 and the Federal government and that portion which is
14 covered by a different revenue source is a
15 regulatory requirement, for MSD to have a regulatory
16 program and a permitting program to address
17 pollutant runoff from new development. So that
18 would in the -- I guess the language we're using
19 here, that is a mandated service that MSD has to do
20 for regulatory reasons, is providing those permits
21 and that review to make sure we're in line with
22 those regulatory requirements.
23 MR. SCHOEDEL: So to clarify, this
24 question really equates to those areas that are not
25 new development that have never been covered under
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1 any legal requirements --
2 MR. HOELSCHER: Yeah, I think that's not
3 the distinction I meant. If we -- I think quickly
4 three revenue sources for MSD: the regulatory side
5 of stormwater runoff related to the pollutant issue,
6 the impact on the creeks and streams, there's
7 currently a 2 cent property tax where we address
8 that. That's a regulatory requirement.
9 The public storm sewer system that we own and
10 have to operate and maintain by Charter and by
11 policy, that's the 10 cent.
12 This is something else. This is how well
13 those -- the non-public collection systems function
14 whether they are erosion that's occurring next to a
15 subdivision that was built six months ago or whether
16 it's erosion that's newly developed because of the
17 change in weather patterns on a property that has
18 been there for 40 years.
19 It really doesn't have an impact on how new
20 or how old something is. Those regulations that we
21 put on for detention and stormwater quality aren't
22 to leave the situation the same, try not to
23 exacerbate the situation in order to meet regulatory
24 requirements. So they're kind of two different pots
25 and two different services.
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1 MR. SCHOEDEL: It's just there's not a
2 pot for the one right now?
3 MR. HOELSCHER: Correct, the one we're
4 looking for is -- I think we've expressed as being
5 one of the three large services that MSD needs to
6 provide. As I indicated, the first two were
7 mandated regulatory or just if it's our
8 responsibility because of assets we have to own and
9 operate. This is a third one that, like I said, I
10 think going back to the Charter probably envisioned
11 that MSD be the one to provide this service.
12 MR. SCHOEDEL: Thank you. I think that
13 helps clarify it.
14 MR. HOELSCHER: Thank you.
15 MR. TOENJES: I would refer the Rate
16 Commissioners back to either two or our items that
17 we are considering in the rate change proposal which
18 states that this enhances the District's ability to
19 provide adequate sewer and drainage systems and
20 facilities for related services.
21 Any further comments? Questions?
22 Hearing none, we will adjourn at this time
23 until 9 a.m. on June 29th, 2018, for the final
24 public hearing session.
25 And a reminder to the Rate Commissioners that
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1 at that time that will be the final opportunity that
2 we have to ask questions of the parties, all
3 parties, including the District, before we begin
4 deliberations.
5 Thank you. We will stand adjourned.
6 - - - - -
7 (Prehearing Conference concluded at 10:14 a.m.)
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1 CERTIFICATE OF REPORTER
2 I, Suzanne M. Zes, a Certified Court
3 Reporter (MO) and Registered Professional Reporter,
4 do hereby certify that the witness whose testimony
5 appears in the foregoing deposition was duly sworn
6 by me pursuant to Section 492.010 RSMo; that the
7 testimony of said witness was taken by me to the
8 best of my ability and thereafter reduced to
9 typewriting under my direction; that I am neither
10 counsel for, related to, nor employed by any of the
11 parties to the action in which this deposition was
12 taken, and further that I am not a relative or
13 employee of any attorney or counsel employed by the
14 parties thereto, nor financially or otherwise
15 interested in the outcome of the action.
16
17
18 ______________________________
19 Certified Court Reporter
20 within and for the State of Missouri
21
22
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accomplishing
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26:6 27:20
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adjourn 53:20
58:22
adjourned 59:5
Adjournment
2:6
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administer
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adopted 8:9
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advocating
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30:6
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ago 30:6 57:15
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allowed 37:18
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43:16
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analyses 23:14
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48:5
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30:18,24 45:8
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36:8 38:5,24
38:24 39:8
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civil 19:20
clamor 22:17
clarify 50:16
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class 25:15
classes 8:6
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closing 11:11
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30:19 54:19
collecting 51:7
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39:7,14 40:19
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common 7:22
13:21 19:7
commonly 16:10
community 12:11
compacted
40:11,15
compared
46:12
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25:3
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27:25 28:2
complete 17:4
20:25
completed 19:6
23:20
complies 13:23
14:7
comply 8:3
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compound
48:12
compromising
20:17
concept 48:6
51:20
conceptual 19:2
23:13
concern 29:4
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concerned
22:4
concerns 29:13
concluded 59:7
concludes 21:4
conducted 9:16
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10:18,19 11:24
33:21 34:2
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9:3 11:7
confidence
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Consent 46:1,3
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Environment
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fact 22:11 27:25
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failure 24:19
fair 8:5 12:23
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Fax 4:19
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11:19,22 12:1,2
21:7,9 34:22
37:22 43:1
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N 2:1 4:1 5:1
name 6:16 12:1
names 6:20
nature 26:18
nearly 22:22
necessary 7:12
19:21
need 22:20
24:14,16 26:12
28:10,10,12,13
34:9 42:4
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needed 20:4
needs 12:7 15:3
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neither 22:2
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never 24:21
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nine 5:3
nominal 20:16
non-public
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nonprofits
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norms 20:12
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noted 37:24
notice 7:9 8:8
8:17
November 7:3
number 18:11,17
29:7 32:7,11
numbers 27:25
32:8,20
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Okay 27:21
33:12 43:7
47:2 50:21
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old 23:15 57:20
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43:13
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operational 9:8
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38:1
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overstated
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Paisner 4:17
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paper 32:4
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partial 16:19
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people's 30:10
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pot 58:2
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potentially 18:16
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power 54:21
practice 19:7
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37:2
pre-analyzing
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preamble 55:2
predecessor
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prehearing 1:13
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9:11,16,25
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preliminary
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preparation
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prepare 25:25
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present 5:11,14
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presentation
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prioritize 13:11
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priority 15:23
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proceed 11:25
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proceedings
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process 15:22
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produced 3:2
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60:3
program 12:19
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programmatic
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programmed
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programming
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rates 7:6,7,7
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ratio 16:7 17:3
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rationale 10:2
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Replacement
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RSMo 60:6
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Section 13:18
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short 10:14
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side 51:3 57:4
significant
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similar 19:4
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Starting 5:2
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stating 38:23
statistically
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stream 37:10
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subdivision
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subject 11:5
submit 8:11
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subset 28:15
suffering 28:3
sufficient 23:15
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summarize
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summarizing
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summary 10:15
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support 18:5
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25:14 27:19
28:11,14 29:2
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supporting 40:1
supports 13:7
sure 28:11,12,13
42:5,25 49:13
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surface 30:8
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surrebuttal
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survey 22:20,21
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43:11,17 51:3
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tax 7:7,12 36:11
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taxed 30:9
technical 9:2
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Telephone 4:7
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test 42:3
testified 16:24
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testify 11:3
testifying 38:20
testimony 8:25
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PREHEARING CONFERENCE 6/21/2018
www.alaris.us Phone: 1.800.280.3376 Fax: 314.644.1334
ALARIS LITIGATION SERVICES
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