HomeMy Public PortalAboutExhibit MIEC 87 - MIEC'S First Discovery Request to the Rate Commission June 24, 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 )
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
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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: June 24, 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 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