HomeMy Public PortalAboutExhibit 26A MSD Response to Discovery Request Barnes-Jewish HospitalEXHIBIT 26A
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
JULY 15, 2011 FIRST 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: JULY 25, 2011
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
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EXHIBIT 26A
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
JULY 15, 2011 FIRST DISCOVERY REQUEST
OF BARNES JEWISH HOSPITAL
Metropolitan St. Louis 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(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 responds to
the Barnes Jewish Hospital July 15, 2011 First Discovery Request for additional
information and answers regarding the Rate Change Notice dated May 10, 2011 (the
"Rate Change Notice").
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EXHIBIT 26A
JULY 15, 2011 FIRST DISCOVERY REQUEST
OF BARNES JEWISH HOSPITAL
Metropolitan St. Louis Sewer District Response
1. Are all customers of MSD customers for both wastewater and stormwater or
are some customers receiving only one of the two services?
RESPONDER: Brian Hoelscher, MSD Director of Engineering
RESPONSE: Most MSD customers receive wastewater services and all
MSD customers receive stormwater services. The stormwater services
provided customers varies however, based on geographic location.
The current funding mechanism for stormwater services is a combination of a
24¢ monthly charge and ad valorem taxes. All customers who pay a
wastewater charge also pay the 24¢ monthly charge. The District has a three
tiered stormwater taxing structure. 2¢ per $100 assessed property valuation is
assessed on all MSD customers within the District's boundaries. This revenue
is used to provide the minimum stormwater services regulatorily required. A
5¢ tax is levied on MSD customers within the District's original boundary,
which is approximately aligned with Interstate 270. In addition to the basic
regulatory stormwater services funded by the 2¢ tax, customers within the
original boundary receive a level of stormwater maintenance and repair
services to the extent revenue generated by the 5¢ tax is available. A portion
of customers also receive a third component of stormwater services. This
consists primarily of capital projects in addition to basic regulatory and
maintenance and repair services. These capital projects are funded by
subdistrict ad valorem tax revenue dedicated for use within the boundaries of
each specific subdistrict. There are currently 16 stormwater subdistricts with
tax levies ranging from 5¢ to 100 per $100 of assessed property valuation. A
0¢ tax is levied on four subdistricts as sufficient fund balances within these
subdistricts are available to fund capital projects without the need for
additional tax revenue. Also note that some MSD customers receive
stormwater service but do not pay for these services due to being tax exempt
or because they fall under the provisions of State Legislation (House Bill
661).
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EXHIBIT 26A
2. If the answer to Question 1 is that there are customers who do not receive both
services:
a. How many of MSD's customers receive only wastewater service and what
percentage is that to total customers and
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: The District currently bills an average of 426,579
wastewater accounts per month. However, during the time the District
charged an impervious rate for stormwater, the total number of billed
MSD customers was approximately 467,593. 41,014 of these customers
received only stormwater service. Based on this information, 91% of MSD
customers receive only wastewater services
b. How many of MSD's customers receive only stormwater service and what
percentage is that to total MSD customers?
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: As stated in the District's response to Question # 2a, at the
time MSD charged an impervous stormwater rate, 41,014 customers
received only stormwater services. This represented approximately 9% of
MSD's total customer base of 467,593 as defined in Question # 2a.
3. Please provide a breakdown of MSD's actual legal fees for each year of FYs
08, 09, 10, 11 by legal vendor and subdivided by type of work performed, for
whom it was performed (e.g. MSD Staff, Rate Commission, etc) and amount
spent per year on each type of work.
RESPONDER: Jan Zimmerman, MSD Director of Finance.
RESPONSE: The requested information is provided as Exhibit MSD 26B.
Susan Myers, General Counse
METROPOLITAN ST. LOUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
smyers@stlmsd.com
Tel: (314) 768-6200
Fax: (314) 768-6372
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EXHIBIT 26A
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 25th day of July, 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
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 was emailed and one paper copy and
associated Exhibits were couriered to:
RATE COMMISSION LEGAL
COUNSEL:
RATE COMMISSION CONSULTANT:
COVIDIEN:
Lisa O. Stump, Esq.
Lashly & Baer, P.C.
714 Locust Street
St. Louis, MO 63101
lostump@lashlybaer.com
Mr. William Stannard
President
Raftelis Financial Consultants, Inc.
3013 Main Street
Kansas City, MO 64108
wstannard@raftelis.com
Mr. Randy Meyer
Utility Manager
Covidien
3600 North 2nd Street
St. Louis, MO 63147
Randy.Meyer@covidien@com
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EXHIBIT 26A
ROBERT A. MUELLER: Mr. Robert A. Mueller
16 Ladue Crest Lane
St. Louis, MO 63124
ramreco@sbcglobal.net
BARNES JEWISH HOSPITAL: Ms. Lisa Langeneckert
Sandberg, Phoenix and VonGontard P.C.
One City Centre, Suite 1500
St. Louis, MO 63101
llangeneckert@sandbergphoenix.com
MISSOURI INDUSTRIAL ENERGY John Kindschuh, Esq.
CONSUMERS: 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
usa ers, General Coun el
METROPOLITAN ST. LO IS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
smyers@stlmsd.com
Tel: (314) 768-6200
Fax: (314) 768-6372
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