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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. ) ) 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. 2 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 3