HomeMy Public PortalAboutExhibit CCM 28 Application to Intervene of the Consumers Council of MissouriExhibit CCM 28
John Be Coffman, LLC
Attorney at Law
871 Tuxedo Blvd.
(573) 424-6779 St. Louis, MO 63119 john@johncoffman.net
July 15, 2011
VIA E AIL
Ms. Nancy Bowser
Secretary of the Rate Commission
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
Re: Application to Intervene of the Consumers Council of Missouri
Dear Ms. Bowser:
Enclosed for filing is an electronic copy of the Application to Intervene of the Consumers
Council of Missouri. It is my understanding that, at a recent meeting, the Rate
Commission determined that email service is sufficient. I have endeavored to include
on my email anyone that needs to be on the service list or that would like to be copied.
If anyone at MSD or any party desires hard copies of this filing, I will be more than
happy to provide them.
Please call me if you have any questions. Thank you for your assistance.
Sincerely,
John B. Coffman
cc: MSD & Parties of Record
BEFORE THE 'ATE CO ISSION OF THE
ETORPOLITAN ST. LOUIS SE ER DISTRICT
METORPOLITAN ST. LOUIS SEWER DISTRICT
Proposed Wastewater Rate Increase FY2013-FY2016.
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APPLICATION TO INTERVENE OF THE CONSUMERS COUNCIL OF MISSOURI
COMES NOW the Consumers Council of Missouri ("CCM"), by and through
counsel, pursuant to Subsection 3(4) of the original Operational Rules, Regulations and
Procedures of the Rate Commission, and Section 2 of the July 8, 2011 Revised
Procedural Schedule, and hereby applies for intervention in the currently pending matter
involving the Wastewater Rate Change Proposal submitted to the Rate Commission by
the Staff of the Metropolitan St. Louis Sewer District ("MSD") on May 10, 2011.
In support of this application, CCM states as follows:
1. CCM is a non -governmental, nonpartisan, nonprofit membership
organization that is dedicated to educating and empowering consumers statewide and
to advocating for their interests.
2. CCM is aware that the date set for applications to intervene was May 31,
2011; however, there is good cause to permit AARP's intervention and participation in
this matter at this time. CCM does not plan to submit prepared expert testimony in this
matter, but it believes that the public interest would be served by its intervention and
participation in this matter. CCM has a history of constructive intervention and
participation before the Missouri Public Service Commission, assisting in the
development of a competent and substantial factual record in numerous cases, and
has provided comments and recommendations to MSD and its Rate Commission in a
previous rate proceeding.
No party will be prejudiced by CCM's intervention at this point in the procedural
schedule. CCM agrees to accept the record and procedural schedule as established
up to this date, and will submit to reasonable discovery. CCM further agrees to abide
by the Rate Commission's Operational Rules and to accept service by mail or by
electronic means.
3. Correspondence, communications, orders and the decision in this matter
should be addressed to:
John B. Coffman
John B. Coffman, LLC
871 Tuxedo Blvd.
St. Louis, MO 63119-2044
Ph: (573) 424-6779
E-mail: john johncoffman.net
WHEREFORE, CCM respectfully requests that the Commission grant its
Application to Intervene, entitling it to formally participate in this proceeding.
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Respectfully submitted,
Dated: this 15th day of July, 2011.
MBE #36591
John B. Coffman
John B. Coffman, LLC
871 Tuxedo Blvd.
St. Louis, MO 63119-2044
Ph: (573) 424-6779
E-mail: john(a�johncoffman.net
Attorney for the Consumers Council of Missouri
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