HomeMy Public PortalAboutExhibit MSD 80B - Surrebuttal Testimony Tom Beckley, RFCMSD Exhibit No. MSD 80B
2019 Rate Change Proceeding
THOMAS A. BECKLEY
Surrebuttal Testimony
Metropolitan St. Louis Sewer District
June 3, 2019
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Extra Strength Surcharges............................................................................................................. 1
Direct Testimony of Thomas A. Beckley, Raftelis June 3, 2019
2019 Rate Change Proceeding 1 MSD Exhibit No. MSD 80B
Extra Strength Surcharges 1
Q1. What is your response to Ms. Prabha Kuhmar’s rebuttal testimony in Exhibit RC 2
71, page 9, lines 7 through 9 that “the District should consider increasing Surcharge 3
rates in a more traditional "across the board" manner, reflecting the overall 4
increase required for system-wide rate revenues in each year.”? 5
A. While as a general concept I agree with this premise, the problem is it ignores the fact 6
that the proposed increase is necessary because these rates were increased at less than an 7
‘across the board increase’ for fiscal years 2018, 2019, and 2020 based on what turned 8
out to be an inaccurate assumption that the change in these rates would be driven by 9
operation and maintenance expense more than capital. In other words these customers 10
have received the benefit of what turned out to be an inaccurate assumption for those 11
three years. It should be noted that while an across the board increase for the years 2018, 12
2019, 2020 would have been closer to the currently proposed rates it too would have been 13
inaccurate and would have increased surcharge rates more than is now necessary, by 14
approximately 13% for TSS and 4% for BOD. 15
Q2. What is your response to Mr. Michael Gorman’s rebuttal testimony, in Exhibit 16
MEIC 73, page 29, lines 11 through 16 that “MSD’s capital expenditures related to 17
BOD and TSS are primarily associated with the improvement of operating 18
efficiency of wastewater treatment plants because these improvements are expected 19
to reduce the cost of waste disposal. The capital expenditures associated with these 20
improvements are not directly related to an increase in the cost of treating 21
wastewater with BOD and TSS strengths in excess of the normal loadings.”? 22
A. The processes being improved at the treatment plants are directly related to removing 23
BOD and TSS from the wastewater flow, so these capital costs are reasonably allocable 24
Direct Testimony of Thomas A. Beckley, Raftelis June 3, 2019
2019 Rate Change Proceeding 2 MSD Exhibit No. MSD 80B
to BOD and TSS. 1
Q3. Does this conclude your surrebuttal testimony in this matter? 2
A. Yes 3
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