HomeMy Public PortalAboutExhibit RC 10C Intervener Application Barnes-Jewish HospitalExhibit RC 1OC
SAN BE
& VON GONTARD P.C.
Lisa C. Langeneckert
Of Counsel
600 Washington Avenue - 15th Floor
St. Louis, MO 63101-1313
Tel: 314.446.4238
Fax: 314.241, 7604
Ilangeneckert@sandbergphoenix, com
www.sandbergphoenix,com
May 31, 2011
VIA EMAIL
Ms. Nancy Bowser
Secretary
MSD Rate Commission
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
Re: MSD 2011-12 Stormwate ewate
Dear Ms. Bowser:
a
Case Filing
Filed herewith please find the Application to Intervene of Barnes -Jewish Hospital in the
above -referenced case. I would appreciate your bringing this filing to the attention of the Rate
Commission.
Thank you for your assistance. Please contact me with any questions.
LCL/ch
cc/enc: John Fox Arnold, Esq.
John R. Kindschuh, Esq.
2976623\1 Sr. iaou s,
Lisa C. Langeneckert
SANDBERG PHOENIX
CAi o i;.v_r, Il.
VON GONTARD P.C.
EDWARDSSVILLL,. IL
O'FAI, (:)N, ll_
Member of The Nework r,f Trial Law Firm.;
BEFORE THE RATE COMMISSION
OF THE METROPOLITAN ST. LOUIS SEWER MST CT
For Consideration of a Wastewater Rate
Change Proposal by the Rate
Commission of the Metropolitan
St. Louis Sewer District.
Case No.
APPLICATION TO INTERVENE
OF BARNES -JEWISH HOSPITAL
Pursuant to Section 3(4) of the Operational Rules of the Rate Commission of the
Metropolitan St. Louis Sewer District ("MSD"), Barnes -Jewish Hospital (One Barnes -Jewish
Hospital Plaza, St. Louis, MO 63110, 314 747-5664), hereinafter referred to as "Applicant",
hereby applies for leave to intervene in the above -referenced proceeding. In support of this
Application, Applicant respectfully states as follows:
l Applicant is one of several hospitals within the service area of the MSD. Over a
period of many years, Applicant has used the services of MSD for removal of wastewater and
stormwater from its operations.
2. The matters to be considered in this case and the Rate Commission's
determinations thereon, could have a direct significant impact on Applicant's cost of wastewater
service. It is Applicant's position that its interests may be affected by the transactions proposed
herein. As a large -use customer of MSD, the Applicant has a direct and immediate interest in
these proceedings that is different from that of the general public.
3. While Applicant does not at this time have sufficient information to assert a
position on the MSD's rate change or to determine whether it will submit prepared testimony, it
2975175\1
reserves the right to assert positions after it has had an adequate opportunity to examine the
record and attend the scheduled technical conferences herein. If Applicant files testimony, it will
respond to any discovery submitted in connection therewith.
4, Correspondence and communications regarding this application, including service
of all notices and orders of this Commission, should be addressed to:
Lisa C. Langeneckert, Esq.
Sandberg, Phoenix & von Gontard, P.C.
600 Washington Avenue — 15`h Floor
St. Louis, MO 63101-1313
WHEREFORE, having stated the grounds for intervention and the position and interest of
Applicant in these proceedings, Applicant asks that the Commission grant this Application for
Intervention, and thereby entitle said Applicant to have notice and to appear at the taking of
testimony, to produce and cross-examine witnesses, and to be heard in person or by counsel on
the argument, and in all other respects to be made a party to this proceeding.
DATED: MAY 31, 2011
Respectfully Submitted,
SANDBERG PHOENIX & VON GONTARD, P.C.
Lisa C. Langeneckert #49781
600 Washington Avenue -- 15TH Floor
St. Louis, MO 63101-1313
314 446-4238 (Direct Dial)
314 241-7604
llangeneckert@sandbergphoenix,cotn
Attorneys for Barnes -Jewish Hospital
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CERTIFICATE OF SERVICE
I hereby certify that I have this day caused a copy of the foregoing to be served on all
persons on the official service list of record on this 31st day of May, 2011.
Lisa C. Langeneckert
2975175\1