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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