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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 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 ) 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. 3 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: 4 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 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