Loading...
Exhibit RC 56 - Rate Commission's First Discovery Request to MSD - March 8, 2019BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT FIRST DISCOVERY REQUEST ISSUE: WASTEWATER RATE CHANGE PROCEEDING WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: RATE COMMISSION DATE PREPARED: MARCH 8, 2019 Lushly & Baer, P.C. 714 Locust Street St. Louis, Missouri 63101 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. 2 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, Ex. MSD 1. RESPONSE: 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, Ex. MSD 1. RESPONSE: 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, Ex. MSD 1. RESPONSE: 4. Regarding the "CIRP-Input" tab in the Rate Model, Ex. 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: 3 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to Janice Fenton, Office Associate Senior, Metropolitan St. Louis Sewer District; Susan Myers, Counsel for the Metropolitan St. Louis Sewer District, on this 8th day of March, 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.corn Brian J. Malone 5 Respectfully submitted, Lisa 0. Stump Brian J. Malone LASHLY & BAER, P.C. 714 Locust Street St. Louis, Missouri 63101 Tel: (314) 621-2939 Fax: (314) 621-6844 lostump@lashlybaer.com bmalone@lashlybaer.com 4