HomeMy Public PortalAboutExhibit MSD 56A - MSD's Response to First Discovery Request of the Rate CommissionExhibit MSD 56A
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
MSD'S RESPONSE TO FIRST DISCOVERY REQUEST
OF THE RATE COMMISSION
The Metropolitan St. Louis Sewer District Response
ISSUE: WASTEWATER RATE CHANGE PROCEEDING
WITNESS: THE METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: MARCH 13, 2019
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
Exhibit MSD 56A
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 )
MARCH 8, 2019 FIRST DISCOVERY REQUEST
OF THE RATE COMMISSION
The Metropolitan St. Louis Sewer District
Pursuant to § 7.28u and § 7.290 of the Charter Plan of The Metropolitan St. Louis Sewer District
(the "Charter Plan"), Restated Operational Rule 3(7) and Procedural Schedule § 16 and § 17 of
the Rate Commission of The Metropolitan St. Louis Sewer District ("Rate Commission"), The
Metropolitan St. Louis Sewer District ("District") hereby responds to the March 8, 2019 First
Discovery Request of The Rate Commission for additional information and answers regarding
the Rate Change Notice dated March 4, 2019 (the "Rate Change Notice").
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Exhibit MSD 56A
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 RATE COMMISSION
Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer
District (the "Charter Plan"), Restated Operational Rule § 3(7) and Procedural Schedule §§ 16
and 17 of the Rate Commission of the Metropolitan St. Louis Sewer District (the "Rate
Commission"), the Rate Commission requests additional information and answers from the
Metropolitan St. Louis Sewer District (the "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.
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Exhibit MSD 56A
FIRST DISCOVERY REQUEST
1. Please provide an electronic copy, in Microsoft Excel format, of the Detailed
Capital Improvement and Replacement Program ("CIRP") Project List (FY 21 — FY 24)
identified as Appendix 7.2.2 in Section 7 of the Rate Proposal, Exhibit MSD 1.
RESPONSE: This file has been provided as Exhibit MSD 56B - Appendix 7.2.2
Detailed WW CIRP Project List.
2. Please provide an electronic copy, in Microsoft Excel format, of the Detailed
CIRP Project List — Not Regulatory or Consent Decree ("CD") Related, identified as Appendix
7.2.3 in Section 7 of the Rate Proposal, Exhibit MSD 1.
RESPONSE: This file has been provided as Exhibit MSD 56C — Appendix 7.2.3
Detailed WW CIRP Project List — Not Regulatory or CD.
3. Please provide an electronic copy, in Microsoft Excel format, of the Detailed
CIRP Project List — Regulatory But Not CD Related, identified as Appendix 7.2.4 in Section 7 of
the Rate Proposal, Exhibit MSD 1.
RESPONSE: This file has been provided as Exhibit MSD 56D Appendix 7.2.4
Detailed WW CIRP Project List —Regulatory but not CD.
4. Regarding the "CIRP-Input" tab in the Rate Model, Exhibit MSD 52, please
provide the following unlocked Microsoft excel files that are indicated to be the source files for
the historical and projected CIRP inputs. Please include calculation of final values input into the
model (e.g., engineering estimate, inflation, appropriation delay, and liquidation adjustments):
(a) "WW CIRP3FY17 Oct 23 2017";
(b) "Updated with WW CIRP FY18 plus Oct 10 2017 - file from S. Winer"; and
(c) The file indicated by the note: "Bart Provided FY19-FY40 update on 9/14/2018"
RESPONSE: The following four files have been provided
i. Exhibit MSD 56E — 4-CIRP Adjustments 11.5.18. This file provides the
calculation offinal values input into the model.
ii. Exhibit MSD 56F — 4a-WW CIRP3 FY17 Oct 23 2017.
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Exhibit MSD 56A
iii. Exhibit MSD 56G 4b-WW CIRP RC FY16 to FY18 Report Construction
Engineering Aug 21 2018. This file is provided in place of "WW CIRP
FY18 plus Oct 10 2017." The notation in Exhibit MSD 52, tab CIRP-
Input cell U9 was not updated when the final numbers were inserted into
the model.
iv. Exhibit MSD 56H — 4c-WW CIRP RC Report Construction Engineering
Nov 2 2018. The file indicated by the note in Exhibit MSD 42, tab CIRP-
Input cell V9 is not the file that supports the numbers used in the final
version of the Rate Model. The notation referenced was not updated when
the final numbers were input. Additionally, these represent Engineering
estimates before adjustments for inflation, delays (scorecard), and
liquidations. Please refer to Exhibit MSD 56E — (4-CIRP Adjustments
11.5.18) to see how those adjustments cause the engineering estimate to
change into the number seen in the Exhibit MSD 1.
Respectfully submitted,
Su : M. Myers, General Co el
THE METROPOLITAN ST. OUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
smyers@a,stlmsd.com
Tel: (314) 768-6366
Fax: (314) 768-6279
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Exhibit MSD 56A
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to Lisa O. Stump and Brian J. Malone, Lashly & Baer, P.C., on this 13th day of March, 2019.
Lisa O. Stump, Esq.
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
lostump@lashlybaer.com
Brian J. Malone, Esq.
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
bmalone@lashlybaer.com
L- A/01100
Sui M. Myers, General Counsel
THE METROPOLITAN ST. LOWS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
smyers@stlmsd.com
Tel: (314) 768-6366
Fax: (314) 768-6279
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