HomeMy Public PortalAboutExhibit AARP 27 Application to Intervene of AARPExhibit AARP 27
John B. 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 AARP
Dear Ms. Bowser:
Enclosed for filing is an electronic copy of the Application to Intervene of AARP. 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 TE 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 AARP
COMES NOW AARP, by and through counsel, pursuant to Subsection 3(4) of
the 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, AARP states as follows:
1. AARP1 is a nonprofit, nonpartisan organization that advocates for people
who are 50 years of age and older, seeking to promote their independence, choice and
control in ways that are beneficial and affordable to them and to society as a whole.
Advocacy for reasonable utility rates and service for older persons is one of AARP's
' In 1999, the "American Association of Retired Persons" changed its name to simply "AARP", in
recognition of the fact that people do not have to be retired to become members. AARP is a non-profit
corporation that has been granted tax exempt status under Section 501(c)(4) of the Internal Revenue
Code as a social welfare organization.
priority issues. AARP's interest in this matter relates to how the proposed wastewater
rate increase may burden MSD customers who are 50 years of age and older.
2. AARP 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. AARP 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. AARP has a history of constructive intervention and
participation before public utility commissions throughout the country, assisting in the
development of a competent and substantial factual record in numerous cases.
No party will be prejudiced by AARP's intervention at this point in the
procedural schedule. AARP agrees to accept the record and procedural schedule as
established up to this date, and will submit to reasonable discovery. AARP 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(cr�johncoffman.net
WHEREFORE, AARP respectfully requests that the Commission grant its
Application to Intervene, entitling it to formally participate in this proceeding.
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Respectfully submitted,
John B. Coffman MBE #36591
John B. Coffman, LLC
871 Tuxedo Blvd.
St. Louis, MO 63119-2044
Ph: (573) 424-6779
E-mail: john(a�johncoffman.net
Attorney for AARP
Dated: this 15th day of July, 2011
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