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Home My Public Portal AboutExhibit RC 90 - Rate Commission's First Discovery Request to MIEC June 25, 2019BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT FIRST DISCOVERY REQUEST TO INTERVENOR MISSOURI INDUSTRIAL ENERGY CONSUMERS ISSUE: WASTEWATER RATE CHANGE PROCEEDING WITNESS: MISSOURI INDUSTRIAL ENERGY CONSUMERS SPONSORING PARTY: RATE COMMISSION DATE PREPARED: JUNE 25, 2019 Lashly & Baer, P.C. 714 Locust Street St. Louis, Missouri 63101 Exhibit RC 90 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 FIRSTDISCOVERY REQUEST OF THE RATE COMMISSION DIRECTED TO MISSOURI INDUSTRIAL ENERGY CONSUMERS 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 Intervenor the Missouri Industrial Energy Consumers ("MIEC") regarding the Rate Change Proposal of the Metropolitan St. Louis Sewer District (the "District") dated March 4, 2019 (the "Rate Change Proposal"). MIEC is requested to amend or supplement the responses to this Discovery Request, if MIEC obtains information upon the basis of which (a) MIEC knows that a response was incorrect when made, or (b) MIEC knows that the response, though correct when made, is no longer correct. The following Discovery Requests are deemed continuing so as to require MIEC to serve timely supplemental answers if MIEC obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. 2 FIRST DISCOVERY REQUEST TO MIEC 1. Please provide a copy of the Black & Veatch report regarding Citizens / Indianapolis' Infiltration/Inflow ("I/I") analysis referenced in Michael Gorman's testimony at the technical conference on June 20, 2019, and summarized in Table 5 of Mr. Gorman's rebuttal testimony (Ex. MIEC 73, Table 5). RESPONSE: 2. Please provide a summary table comparing the rates and percentage change in rate revenue Mr. Gorman's adjustments to the Rate Change Proposal would produce, with those contained in Table 5-1 of Ex. MSD 1. Please provide in Microsoft Excel format (values sufficient, formulas not required). RESPONSE: 3. Please explain in detail how Mr. Gorman calculated surcharge rates and compliance charges in his proposal. RESPONSE: 4. Please explain in detail how Mr. Gorman incorporated the allocation factors for I/I within his model, and how rates were designed. 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 3 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to Brandon Neuschafer, Counsel for MIEC, on this 25th day of June, 2019, with copies to those parties listed below. 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@bclplaw. corn kami.jones@bc1plaw.com Attorneys for Missouri Industrial Energy Consumers Brian J. Malone 4