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Exhibit MIEC 88 - MIEC's Fourth Discovery Request to MSD 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 ) 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 2 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 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