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Exhibit MIEC 87 - MIEC'S First Discovery Request to the Rate Commission June 24, 2019Wastewater Rate Change Proceeding - 2019 1 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 ) FIRST DISCOVERY REQUEST OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS TO 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”), Intervenor Missouri Industrial Energy Consumers (“MIEC”) requests additional information and answers from the Rate Commission’s Consultants regarding the Surrebuttal Testimony dated June 3, 2019. 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 Request is 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. REQUEST NO. 1: Referring to Pamela Lemoine’s testimony at the June 20, 2019, Technical Conference on Surrebuttal Testimony, Ms. Lemoine stated she reviewed the impact of Mr. Gorman’s deferral of $70 million in CIRP spending in both FY23 and FY24. Please provide any analysis or Rate Models Ms. Lemoine relied on to support her Surrebuttal Testimony. RESPONSE NO. 1: Exhibit MIEC 87 Wastewater Rate Change Proceeding - 2019 2 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: June 24, 2019 Wastewater Rate Change Proceeding - 2019 3 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to the following on this 24th day of June, 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