HomeMy Public PortalAboutExhibit 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.
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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:
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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
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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
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