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Home My Public Portal AboutExhibit MSD 70A MSD Response to BJH 3rd Discovery RequestBEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 26, 2011 THIRD DISCOVERY REQUEST OF BARNES JEWISH HOSPITAL Metropolitan St. Louis Sewer District Response ISSUE: WASTEWATER RATE CHANGE PROPOSAL WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: BARNES JEWISH HOSPITAL DATE PREPARED: August 30, 2011 Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT For Consideration of a Wastewater Rate Change Proposal by the Rate Commission of the Metropolitan St. Louis Sewer District AUGUST 26, 2011 SECOND DISCOVERY REQUEST OF BARNES JEWISH HOSPITAL Metropolitan St. Louis Sewer District Response Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer District (the "Charter Plan"), Operational Rule 3(2) and Procedural Schedule §§ 1, 14, 15 and 17 of the Rate Commission of the Metropolitan St. Louis Sewer District ("Rate Commission"), Metropolitan St. Louis Sewer District ("District") thereby responds to the Barnes Jewish Hospital August 26, 2011 Third Discovery Request for additional information and answers regarding the Rate Change Proposal dated May 10, 2011 (the "Rate Change Proposal"). The District is requested to amend or supplement the responses to this Discovery Request, if the District obtains information upon the basis of which (a) the District knows that a response was incorrect when made, or (b) the District knows that the response, though correct when made, is no longer correct. The following Discovery Requests are deemed continuing so as to require the District to serve timely supplemental answers if the District obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 26, 2011 SECOND DISCOVERY REQUEST OF BARNES JEWISH HOSPITAL Metropolitan St. Louis Sewer District Response 1. Please provide the names and positions of anyone on MSD's staff (or under MSD's direction) who has reviewed Black & Veatch's electronic rate model with all formulas intact, as described in MIEC' s First Data Request to MSD, Question 1-1 and designated as both Exhibit MSD 15 and Exhibit MIEC 15. RESPONDER: Jan Zimmerman, MSD Director of Finance RESPONSE: No member of the MSD Staff has reviewed Black & Veatch's electronic rate model with all formulas intact, as described in MIEC's First Data Request to MSD, Question 1-1. However as part of the Rate Proposal development, output from the model in the form of Tables, as provided in Exhibit MSD 4, have been reviewed and utilized by MSD Staff. 2. Please provide a copy of any executed Confidentiality Agreement (by that name or any similar name for such purpose) between Black & Veatch and MSD relating to this rate case and the confidential and/or proprietary information provided or to be provided in this rate case. RESPONDER: Susan Myers, MSD General Counsel RESPONSE: No confidentiality agreement has been executed between MSD and Black & Veatch related to this rate case and the confidential and/or proprietary information provided or to be provided in this rate case. However, Section 7 of MSD's July 28, 2010 and July 11, 2011 contracts to engage Black & Veatch rate consulting services, prohibits the District from releasing the Black & Veatch electronic rate model to any third party. These contracts are provided as Exhibit MSD 24B and 24C. Susan Myers, General Counsel METROPOLITAN ST. LOUIS SEWER DISRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 CERTIFICATE OF SERVICE The undersigned certifies that on the 30th day of August, 2011: An electronic copy of the foregoing instrument as e -mailed to the Secretary of the Rate Commission c/o jfenton@stlmsd.com. SECRETARY OF RATE COMMISSION: Ms. Nancy Bowser Secretary of Rate Commission Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 robowser@swbell.net At the request of the Rate Commission Counsel, one paper original and associated Exhibits are held at the Rate Commission office for Commissioner review. An electronic copy of the foregoing instrument was e -mailed to: RATE COMMISSION CONSULTANT: COVIDIEN: ROBERT A. MUELLER: BARNES JEWISH HOSPITAL: Mr. William G. Stannard President Raftelis Financial Consultants, Inc. 3013 Main Street Kansas City, Missouri 64108 wstannard@raftelis.com Mr. Randy Meyer Utility Manager Covidien 3600 North 2nd Street St. Louis, MO 63147 Randy.Meyer@covidien.com Mr. Robert A. Mueller 16 Ladue Crest Lane St. Louis, MO 63124 ramreco@sbcglobal.net Lisa C. Langeneckert, Esq. Sandberg, Phoenix & von Gontard, P.C. 600 Washington Avenue, 15th Floor St. Louis, MO 63101-1313 llangeneckert(a, sandbergphoenix.com MISSOURI INDUSTRIAL ENERGY CONSUMERS: AARP AND CONSUMERS COUNCIL OF MISSOURI: John R. Kindschuh, Esq. Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 Telephone: 314-259-2313 john.kindschuh@bryancave.com and Diana M. Vuylsteke, Esq. Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 dmvuylsteke@bryancave.com John B. Coffman, Esq. John B. Coffman, LLC 871 Tuxedo Blvd. St. Louis, MO 63119 john@johncoffman.net LD Susan Myers, General Counsel METROPOLITAN ST. LOUIS S WER DISRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372