HomeMy Public PortalAboutExhibit RC 77 - Rate Commission's Fifth Discovery Request to MSD May 14, 2019BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
FIFTH DISCOVERY REQUEST
ISSUE:
WITNESS:
SPONSORING PARTY:
DATE PREPARED:
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
WASTEWATER RATE CHANGE PROCEEDING
METROPOLITAN ST. LOUIS SEWER DISTRICT
RATE COMMISSION
MAY 14, 2019
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
FIFTH 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 Preheating Conference.
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FIFTH DISCOVERY REQUEST
1. In his rebuttal testimony on behalf of Intervenor Missouri Industrial Energy
Consumers ("MIEC"), Michael Gorman proposes to defer certain programs until after the FY 2023
— FY2024 period. See Ex MIEC 73, pgs. 16-17. Specifically, he identifies the following projects
as eligible to be deferred: Wastewater solids combustion boiler; Wastewater plant repair; and
Capacity Expansion. Please state whether deferring these projects until after FY 2024 poses risks
to the District, and/or would risk non-compliance with the Consent Decree, state or federal laws,
or regulations.
RESPONSE:
2. Please identify any projects in the CIRP scheduled for FY 2023 — FY 2024 that
could be deferred until after FY 2024 that would not jeopardize compliance with the Consent
Decree, state or federal laws, or regulations.
RESPONSE:
3. Please describe in detail the District's methodology used to develop cost estimates
for projects in the CIRP.
RESPONSE:
4. Please provide any unit costs the District used to develop cost estimates for projects
in the CIRP.
RESPONSE:
5. Please provide detailed scope and cost -estimate information for the following
projects in the CIRP:
a. 12106 (See Ex. MSD 1, p. 7-26);
b. 12472 (See Ex. MSD 1, p. 7-36);
c. 13033 (See Ex. MSD 1, p. 7-20);
d. 12248 (See Ex. MSD 1, p. 7-26); and
e. 12255 (See Ex. MSD 1, p. 7-69).
RESPONSE:
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6. The Rate Change Proposal reflects increases in Compliance Charges and Extra
Strength Surcharges equal to Operations and Maintenance escalation, not the across the board
revenue increases used to set Base and Volume charges. What analytical evidence and/or policy
rationale did the District use to increase Compliance Charges & Extra Strength Surcharges at a
different rate than Base and Volume charges?
RESPONSE:
Respectfully submitte
Lea O. 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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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 14t` day of May, 2019.
Ms. Janice Fenton
Office Associate Senior
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
jfenton@stlmsd.com
Ms. Susan Myers
General Counsel
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
smyersa,stlmsd.com
Brandon W. Neuschafer
Kamilah Jones
Bryan Cave, LLP
211 North Broadway, Suite 3600
St. Louis, Missouri 63102
bwneuschafer@belplaw.com
kami.jones@bclplaw.com
Attorneys for Missouri Industrial
Energy Consumers
Brian J. Malone
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