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HomeMy Public PortalAboutExhibit L&B 22 Letter to MSD Board Request for RC Proceeding 45 Day ExtnExhibit L&B 22 THE RATE COMMISSICON OF THE MIETROP®UT1 `I ST. ILOUI[S SIEGE I" DESTRECT June 14, 2011 Mr. Bob Berry Chair, Board of Trustees Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 Re: Rate Commission Proceedings Dear Mr. Berry: The Rate Commission of the Metropolitan St. Louis Sewer District (the "Rate Commission") received from the Metropolitan St. Louis Sewer District (the "District") a Rate Change Notice on May 10, 2011. The Rate Commission, pursuant to § 7.280(f) of the Charter Plan, is to issue its Rate Commission Report to the Board of Trustees and the public no later than September 6, 2011, unless the Board shall, upon application by the Rate Commission, extend the date for a 45 day period. The Rate Commission respectfully requests an extension until October 21, 2011, for the issuance of its report. On August 16, 2001, and under the authority of §§ 7,250 and 7.280(e) of the Charter Plan, the Rate Commission adopted Operational Rules, Regulations and Procedures as amended on March 21, 2002, April 16, 2003, March 2, 2007, January 18, 2008 and March 7, 2011, to govern the activities of the Rate Commission. On May 13, 2011, the Rate Commission, under the authority of § 7.280(e) of the Charter Plan and pursuant to § 3(3) of the Operational Rules, adopted a Procedural Schedule for the current Rate Change Proposal. The Procedural Schedule is based upon the requirements contained in the Charter Plan, and is designed to occur within a 120 -day period. On June 7, 2011, two Intervenors in the proceedings, Missouri Industrial Energy Consumers and Barnes Jewish Hospital, filed with the Rate Commission a Proposal to Revise the Procedural Schedule for the 2011 Rate Case (the "Proposal"), which essentially requests that the additional 45 days be included within the Procedural Schedule, The Proposal argues that there is not sufficient time in the current 120 -day schedule to permit the parties and the Rate Conunission to carefully and completely consider all issues and render a Report to the Board of Trustees by September 6, 2011. The Proposal notes various issues requiring additional time, including: Mr. Bob Berry June 14, 2011 Page 2 o Magnitude of the Proposal — The District is proposing an increase in wastewater revenues of approximately $130 million to take place over a four-year period. This is roughly a 60% increase in wastewater revenue collections. The details of this significant increase must be reviewed in detail by all parties, including the Rate Commission, to protect the public in setting District wastewater rates. o Differences from Previous Rate Proposals — While the District has proposed roughly a 60% increase in wastewater rates in prior rate filings, this rate plan is very different because it includes a significant increase in District debt financing and capital programs. The overall impact on the District's financial standing, capital needs, and ongoing rate structure justifies a careful review of this filing to ensure the integrity of the revenue stream, the District's financial integrity, and the•District's competitive rates. O Extensive Capital Program — The major factor contributing to the substantial increase in wastewater rates is a capital program of $1.3 billion planned to be made over the next four years. All parties need the time to conduct a detailed review of the capital program, the timing, and the funding mechanisms needed to take place in the rate proposal. o Consent Decree — On June 2, 2011, the District agreed to terms of a Consent Decree with EPA. It is important that the details of this settlement agreement be understood by all of the parties and the necessary capital improvement projects and the time frames are consistent with those embedded in the District' s proposed rate plan. The Rate Commission considered the Proposal at the Technical Conference on June 13, 2011. All Intervenors concurred with the Proposal. The District and Rate Commission counsel indicated that they did not object to the Proposal. As a result, after discussion, the Rate Commission voted to ask the Board of Trustees for the 45 -day extension. In order to ensure that the rate review process proceeds as required by the Charter Plan, and is conducted in a manner that is reasonable, appropriate and fair to all parties, I request that the Board of Trustees extend the date for the filing of the Rate Commission Report until October 21, 2011. Sincerely, Leonard Toenjes Chair, Rate Commis of the Metropolitan _ Louis Sewer District cc: Mr, Jeffrey Theerman, Executive Director