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Exhibit 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. 2 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: 3 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 4 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 5