HomeMy Public PortalAboutExhibit MSD 84A MSD Response to BJH 4th DREXHIBIT MSD 84A
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
SEPTEMBER 19, 2011 RESPONSE TO THE FOURTH DISCOVERY REQUEST
OF BARNES JEWISH HOSPITAL TO MSD
METROPOLITAN ST. LOUIS SEWER DISTRICT RESPONSE
ISSUE: WASTEWATER RATE CHANGE PROPOSAL
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: BARNES JEWISH HOSPITAL
DATE PREPARED: SEPTEMBER 19, 2011
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
EXHIBIT MSD 84A
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
SEPTEMBER 19, 2011 RESPONSE TO THE FOURTH DISCOVERY REQUEST
OF BARNES JEWISH HOSPITAL
Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer
District (the "Charter Plan"), Operational Rule 3(5) and Procedural Schedule §§ 17 (b)(i)
and (ii) of the Rate Commission of the Metropolitan St. Louis Sewer District ("Rate
Commission"), the Metropolitan St. Louis Sewer District ("District") thereby submits this
response to the Fourth Discovery Request of Barnes Jewish Hospital, Dated September 8,
2011, regarding the Rate Change Notice dated May 10, 2011 (the "Rate Change Notice").
Metropolitan St. Louis Sewer District Response
1. Please provide the date that Ms. Vanda reviewed the Black & Veatch electronic rate
model with all formulas intact, including: (a) the approximate amount of time she
spent reviewing the full model; (b) the portions of the model that she reviewed with
the approximate amount of time spent on each portion; (c) the location at which she
reviewed the model.
RESPONDER: Jeanne Vanda Answer
RESPONSE: I have not reviewed the Black & Veatch electronic rate model
with all formulas intact.
a. Not applicable.
EXHIBIT MSD 84A
b. A representative of PFM reviewed extracted portions of the model related to
debt service in an excel spreadsheet format. These extracted portions have
previously been provided to all parties in hard copy found in exhibit MSD 4A
& MSD 5. The PFM representative never had access to the Black & Veatch
electronic rate model with all formulas intact. The PFM representative
relayed relevant information to me at my request. I did not spend any time
reviewing this portion of the Model.
c. Not applicable.
2. Please provide any updates to any prior responses to the First, Second, and Third
Discovery Requests of BJH to MSD.
RESPONDER: Janice Zimmerman, MSD Director of Finance
RESPONSE: There are no prior responses of MSD which have been updated in any
material respect at this time. MSD will supplement any prior response if it learns
that a response in any material respect is incorrect or incomplete and if the
additional or corrective information has not otherwise been made known to the
other parties during the discovery process, technical conferences or in writing.
3. As an ongoing request, please provide any additional updates to the First, Second, and
Third Discovery Requests of BJH to MSD Staff, should MSD Staff responses change,
through the close of the discovery period in this matter.
RESPONDER: Janice Zimmerman, MSD Director of Finance
EXHIBIT MSD 84A
RESPONSE: There are no prior responses of MSD which have been updated in any
material respect at this time. MSD will supplement any prior response if it learns
that a response in any material respect is incorrect or incomplete and if the
additional or corrective information has not otherwise been made known to the
other parties during the discovery process, technical conferences or in writing.
Susan Myers, General Counsel
METROPOLITAN ST. LOUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
smyers@stlmsd.com
Tel: (314) 768-6200
Fax: (314) 768-6372
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 19th day of September, 2011:
An electronic copy of the foregoing instrument was emailed 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 63103-2555
robowser@swbell.net
EXHIBIT MSD 84A
At the request of 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 and Exhibits were emailed to:
RATE COMMISSION LEGAL COUNSEL: Lisa O. Stump, Esq.
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
lostump@lashlybaer.com
RATE COMMISSION CONSULTANT: Mr. William Stannard
President
Raftelis Financial Consultants, Inc.
3013 Main Street
Kansas City, MO 64108
wstannard@raftelis.com
COVIDIEN: Mr. Randy Meyer
Utility Manager
Covidien
3600 North 2nd Street
St. Louis, MO 63147
Randy.Meyer@covidien@com
ROBERT A. MUELLER:
BARNES JEWISH HOSPITAL:
Mr. Robert A. Mueller
16 Ladue Crest Lane
St. Louis, MO 63124
ramreco@sbcglobal.net
Ms. Lisa Langeneckert
Sandberg, Phoenix and VonGontard P.C.
One City Centre, Suite 1500
St. Louis, MO 63101
llangeneckert@sandbergphoenix.com
EXHIBIT MSD 84A
MISSOURI INDUSTRIAL ENERGY
CONSUMERS:
AARP & CONSUMERS COUNCIL OF
MISSOURI:
John Kindschuh, Esq.
Bryan Cave, LLP
211 N. Broadway, Suite 3600
St. Louis, MO 63102
John.kindschuh@bryancave.com
Diana M. Vuylesteke, Esq.
Bryan Cave, LLP
211 N. Broadway, Suite 3600
St. Louis, MO 63102
dmvuylesteke@bryancave.com
John B. Coffman, LLC
Attorney at Law
871 Tuxedo Blvd.
St. Louis, MO 63119
john@j ohncoffman. net
Susan Myers, General Counsel
METROPOLITAN ST. LOUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
(E) smyers@stlmsd.com;
(T) (314) 768-6200; (F) (314) 768-6372