HomeMy Public PortalAboutExhibit MIEC 88 - MIEC's Fourth Discovery Request to MSD 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 )
FOURTH 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. 22: Referring to the ‘CIRP Dashboard’ tab of Exhibit MSD 66C, please
outline the differences between PFM’s inputs and assumptions and MSD’s calculated inputs and
assumptions when the entry in row 89 of the model is switched from “PFM” to “Model” (for all
columns). Please describe the purpose of differences in model inputs and assumptions.
RESPONSE NO. 22:
REQUEST NO. 23: Please provide a copy of Exhibit MSD 66C (the unlocked version
of MSD’s Rate Model) that includes only the following two changes to MSD’s filed wastewater
revenue requirement, which were recommended by Mr. Gorman in his Surrebuttal Testimony:
Exhibit MIEC 88
Wastewater Rate Change Proceeding - 2019
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a. Update the model to reflect an overall PAYGO funding mix of 30% cash funding
and 70% debt funding rather than 60% and 40% proposed by the MSD.
b. Update the ‘CIRP-Input’ tab to reflect Mr. Gorman’s proposed deferral of
$70 million of budgeted CIRP spending in each of FY23 and FY24 to FY25 and
FY26, rather than the annual FY23 and FY24 CRIP budget proposed by the MSD.
c. Identify all changes to the model to make these two changes in forecasting the
MSD revenue requirement, and
d. Provide the revised financial model used for this response with all formula and
calculations intact.
RESPONSE NO. 23:
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