HomeMy Public PortalAboutExhibit MIEC 78 - MIEC's Third Discovery Request to MSD - May 16, 2019Wastewater Rate Change Proceeding - 2019
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BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
For Consideration of a Wastewater )
Rate Change Proposal by the Rate Commission )
of the Metropolitan St. Louis Sewer District )
THIRD DISCOVERY REQUEST OF THE
MISSOURI INDUSTRIAL ENERGY CONSUMERS
TO 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”), 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 Metropolitan St. Louis Sewer District (“MSD” or “District”) regarding the
Rate Change Proposal dated March 4, 2019 (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.
REQUEST NO. 18: Please refer to Exhibit MSD 56B, Appendix 7.2.2 Detailed WW
CIRP Project List. In addition to the Financial Year, please update the exhibit to include the
dates for the Bid Year and Achievement of Full Operation as required by the Consent Decree or
any of its amendments.
RESPONSE NO. 18:
REQUEST NO. 19: Please refer to Exhibit MSD 56C, Appendix 7.2.3 Detailed WW
CIRP Project List - Not Regulatory or CD. In addition to the Financial Year, please update the
exhibit to include the date MSD is required to complete each of the non-Consent Decree or
regulatory related projects based on State, Federal and local regulatory obligations.
RESPONSE NO. 19:
Wastewater Rate Change Proceeding - 2019
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REQUEST NO. 20: Please refer to Exhibit MSD 56D - Appendix 7.2.4 Detailed WW
CIRP Project List - Regulatory but not CD. In addition to the Financial Year, please update the
exhibit to include the date MSD is required to complete each regulatory project and all other
timing related milestones required by federal, state or local regulatory requirements.
RESPONSE NO. 20:
REQUEST NO. 21: Concerning the District’s financial model, on the tab “CIRP,” the
source of new revenue bond issuances, please provide the following along with calculations on
electronic spreadsheet with formulas intact:
a. Please provide an explanation and support for the estimated amount of the line
“Revenue Bond Proceeds – Premium” used to estimate the source of additional funds
received from selling new bonds.
b. Please estimate the net interest cost to MSD using the “Revenue Bond Proceeds – Par
Amount” and “Revenue Bond Proceeds – Premium” amount assumptions in its
financial model for issuing new revenue bonds at a coupon rate of 5%, and issue cost
rate of 1%.
c. Please estimate the change in amounts of Revenue Bond Proceeds – Premium from
selling new bonds, if the net interest cost to MSD of new revenue bond issues,
reflecting a 5% coupon and 1% issue cost, would be 3.5%. That is, assume the
MSD’s 5% coupon rate and 1% issue cost, then how much of Revenue Bond
Proceeds – Premium would be generated if the net cost of a new bond issue was
3.5%?
d. Please make the same estimate requested in c. above, but assume the net interest cost
to MSD would be 4%.
RESPONSE NO. 21:
Wastewater Rate Change Proceeding - 2019
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Respectfully submitted,
BRYAN CAVE LLP
By /s/ Brandon W. Neuschafer
Brandon W. Neuschafer, #53232
Kamilah Jones, #71025
211 N. Broadway, Suite 3600
St. Louis, Missouri 63102
Telephone: (314) 259-2317 (Brandon)
Telephone: (314) 259-2151 (Kamilah)
Facsimile: (314) 259-2020
bwneuschafer@bclplaw.com
kami.jones@bclplaw.com
ATTORNEYS FOR THE MIEC
Dated: May 16, 2019
Wastewater Rate Change Proceeding - 2019
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CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to the following on this 16th day of May, 2019.
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
Ms. Lisa O. Stump
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
lostump@lashlybaer.com
Mr. Brian J. Malone
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
bmalone@lashlybaer.com
/s/ Brandon W. Neuschafer