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Exhibit RC 89 - Rate Commission's Sixth Discovery Request to MSD June 25, 2019BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT SIXTH DISCOVERY REQUEST ISSUE: WASTEWATER RATE CHANGE PROCEEDING WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: RATE COMMISSION DATE PREPARED: JUNE 25, 2019 Lushly & Baer, P.C. 714 Locust Street St. Louis, Missouri 63101 Exhibit RC 89 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 SIXTH 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 SIXTH DISCOVERY REQUEST 1. Please state the District's proposed capital spending on the Bissell Fluidized Bed Incinerator Project for Fiscal Year 2025 until completion of the project. For each fiscal year, please indicate whether the dollar amount indicated is based on 2019 dollars or is adjusted for inflation. RESPONSE: 2. Please provide a copy of the air permit referenced in Richard L. Unverferth's testimony at the June 20 technical conference. RESPONSE: 3. Please provide the solids handling study, including any updates, referenced in Richard L. Unverferth's testimony at the June 20 technical conference. RESPONSE: 4. Please provide, in Microsoft Excel format (values sufficient), a comparison of ratepayer bills illustrating different rates charged under the District's Rate Change Proposal (See Ex. MSD 1, Table 5-1), and the proposal as modified by MIEC. RESPONSE: 5. Please provide a summary of ratings from Standard and Poor's, Moody's, and Fitch for the District from 2004 to the present. Please provide a copy of each agency's reports for any instance in which the District's rating was increased or decreased. RESPONSE: 6. Please provide calculations demonstrating the impact on rates/surcharges of increasing the amount of anticipated borrowings by $100 million dollars (assuming an extra $25 million would be borrowed for each fiscal year in this rate cycle beyond the amount presently proposed). Please also indicate which additional projects could be completed in each fiscal year with an additional $25 million in debt financing, in addition to the current amount proposed in the Rate Change Proposal. RESPONSE: 3 7. Please provide the percentage premium of Par that should be used in the District's Rate Model, each year, for calculating deposit to construction fund in future years for alternative scenario analysis. RESPONSE: 8. Please provide in Microsoft Excel format (values sufficient) a summary of the fixed assets used in the District's 2015 Rate Change Proposal and a comparison of same with the fixed assets in the current proposal (See Ex. MSD 66C, tab "Plant" columns I through L, lines 1-147), illustrating any depreciation in such assets. RESPONSE: 9. Please provide an analysis of the impact on volume users if Infiltration/Inflow ("I/I") was adjusted from 60% to volume and 40% to customers to 50%/50%. RESPONSE: 10. Please identify the District's annual discretionary expenditures, and their components, for the past three fiscal years, and state the amounts budgeted for discretionary expenditures for the current fiscal year. RESPONSE: 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 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 25th day of June, 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 smyers@stlmsd.com Brandon W. Neuschafer Kamilah Jones Bryan Cave, LLP 211 North Broadway, Suite 3600 St. Louis, Missouri 63102 bwneuschafer@belplaw.com kamijones(&bc1plaw.com Attorneys for Missouri Industrial Energy Consumers Brian J. Malone 5