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Home My Public Portal AboutExhibit RC 49A - Rate Commission's Response to Second Discovery Request of the MIEC1 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT RATE COMMISSION’S RESPONSE TO SECOND DISCOVERY REQUEST OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS The Rate Commission’s Response ISSUE: STORMWATER RATE CHANGE PROCEEDING WITNESS: RATE COMMISSION SPONSORING PARTY: RATE COMMISSION DATE: MAY 30, 2018 Lashly & Baer, P.C. 714 Locust Street St. Louis, Missouri 63101 2 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 ) MAY 30, 2018 SECOND DISCOVERY REQUEST OF MISSOURI INDUSTRIAL ENERGY CONSUMERS Rate Commission Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer District (the “Charter Plan”), Operational Rule 3(5) and Procedural Schedule §§ 1, 17 and 18 of the Rate Commission of the Metropolitan St. Louis Sewer District (“Rate Commission”), the Rate Commission hereby responds to the May 20, 2018 Second Discovery Request of Intervenor Missouri Industrial Energy Consumers (“MIEC”) for additional information and answers regarding the Rate Change Notice dated February 26, 2018. 3 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT For Consideration of a Stormwater ) Rate change Proposal By the Rate ) Commission of the Metropolitan ) St. Louis Sewer District ) SECOND DISCOVERY REQUESTS OF INTERVENOR MISSOURI INDUSTRIAL ENERGY CONSUMERS Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer District (the “Charter Plan”), Operational Rule 3(5) and Procedural Schedule §§ 1, 17 and 18 of the Rate Commission of the Metropolitan St. Louis Sewer District (“Rate Commission”), Intervenor Missouri Industrial Energy Consumers (“MIEC”) requests additional information and answers from the Rate Commission regarding the May 2, 2018, written rebuttal testimony provided by Nicole Young of Lion CSG regarding MSD’s February 26, 2018 Rate Change Proposal. The Rate Commission is requested to amend or supplement the responses to this Discovery Request, if the Rate Commission obtains information upon the basis of which (a) the Rate Commission knows that a response was incorrect when made, or (b) the Rate Commission knows that the response, though correct when made, is no longer correct. The following Discovery Requests are deemed continuing so as to require the Rate Commission to serve timely supplemental answers if the Rate Commission obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. 4 REQUEST NO. 1: In her written rebuttal testimony, Rate Commission consultant Nicole Young of Lion CSG identified in the answer to Question 9 that she “reviewed one of the watershed [binders] in detail.” Please identify which of the watershed binders Ms. Young reviewed in detail. Response: Of the 53 watershed binders made available by the District, Ms. Young reviewed the binder related to the Bonhomme Creek watershed, and its associated appendices. Ms. Young examined several other binders and noted that the reports followed the same format and methodology for all watersheds. Ms. Young also reviewed the three general binders for stormwater programs which the District made available. REQUEST NO. 2: Ms. Young has identified that she and Lion CSG “have performed wastewater and stormwater projects for MSD.” On an annual basis from 2013 to the present, please identify the total amount that Lion CSG has billed to MSD for such services, as well as how much Lion CSG has incurred but not yet billed. Response: According to the District’s database, Lion CSG has submitted invoices totaling $177,946.90 from 2014 to the present. Lion CSG did invoice the District in 2013 for any projects. Lion CSG’s portion is less surveying costs and third-party quality assurance/quality control. The below numbers are receipts, not profit, and do not take into account Lion CSG’s costs to perform the work. Calendar Year Invoiced Amount Invoiced to MSD Lion CSG Portion 2014 $73,490.57 $60,900.56 2015 73,988.73 46,985.30 2016 11,611.70 10,562.55 2017 18,855.90 11,536.90 Performed, not received 14,150.10 12,305.96 Respectfully submitted, /s/ Brian J. Malone Lisa O. Stump Brian J. Malone LASHLY & BAER, P.C. 714 Locust Street St. Louis, Missouri 63101 Tel: (314) 621-2939 Fax: (314) 621-6844 lostump@lashlybaer.com bmalone@lashlybaer.com 5 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to Janice Fenton, Office Associate Senior, Metropolitan St. Louis Sewer District; Susan Myers, Counsel for the Metropolitan St. Louis Sewer District; and Brandon Neuschafer, Counsel for the Missouri Industrial Energy Consumers, on this 30th day of May, 2018. Ms. Janice Fenton Office Associate Senior Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 JFENTON@stlmsd.com Ms. Susan Myers General Counsel Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 smyers@stlmsd.com Counsel for the Metropolitan St. Louis Sewer District Brandon Neuschafer Bryan Cave Leighton Paisner LLP One Metropolitan Square, Suite 3600 St. Louis, MO 63102-2750 bwneuschafer@bclplaw.com Counsel for Intervenor Missouri Industrial Energy Consumers /s/ Brian J. Malone Brian J. Malone