HomeMy Public PortalAboutExhibit 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.
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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:
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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
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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 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
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