HomeMy Public PortalAboutExhibit RC 63 - Rate Commission's Fifth Discovery Request to MSD June 11, 2018BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
FIFTH DISCOVERY REQUEST
ISSUE: STORMWATER RATE CHANGE PROCEEDING
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: JUNE 11, 2018
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
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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 )
DISCOVERY REQUEST
OF THE 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 requests additional information and answers from the Metropolitan St. Louis
Sewer District (“District”) regarding the Rate Change Proposal dated February 26, 2018 (the
“Rate Change Proposal”).
The District is requested to amend or supplement the responses to this Discovery
Request, if the District obtains information upon the basis of which (a) the District knows that a
response was incorrect when made, or (b) the District knows that the response, though correct
when made, is no longer correct.
The following Discovery Requests are deemed continuing so as to require the District to
serve timely supplemental answers if the District obtains further information pertinent thereto
between the time the answers are served and the time of the Prehearing Conference.
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FIFTH DISCOVERY REQUEST
1. Has the District compiled data quantifying/categorizing calls received from
ratepayers regarding flooding/erosion issues? If so, please provide such data for 2012-2017.
RESPONSE:
2. Please produce the EPA affordability guidelines for residential ratepayers which
the District reviewed as referenced in Marion Gee’s surrebuttal testimony (MSD Ex. 55).
RESPONSE:
3. Did the District consult any affordability guidelines/regulations regarding non-
residential ratepayers? Please produce any guidelines/regulations regarding non-residential
ratepayers relied upon or which the District consulted in preparing the Stormwater Capital Rate.
RESPONSE:
4. Please list the titles of the watershed binders associated with MSD Exhibit 37F
which were made available to the Rate Commission by the District.
RESPONSE:
5. With regard to the projects listed in CIRP-2 (MSD Ex. 30L), has the District
pursued grant funding for any of these projects? If the answer is yes, please list any grants for
which the District has applied or for which it intends to apply. If the answer is no, please explain
why not.
RESPONSE:
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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
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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 11th day of June, 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