HomeMy Public PortalAboutExhibit MSD 101A MSD Response to RC 5th Discovery RequestEXHIBIT MSD 101A
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
SEPTEMBER 28, 2011 FIFTH DISCOVERY REQUEST
OF THE RATE COMMISSION
St. Louis Metropolitan Sewer District Response
ISSUE: WASTEWATER RATE CHANGE PROPOSAL
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: OCTOBER 5, 2011
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63132
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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 28, 2011 FIFTH DISCOVERY REQUEST
OF THE RATE COMMISSION
St. Louis Metropolitan 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"), the Rate Commission
requests additional information and answers from the Metropolitan St. Louis Sewer District ("District")
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.
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1. Looking at all residential customers, what is the amount of the median (not average) bill?
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: The median bill for all residential customers as the August 2011 billings
is $27.29.
2. Looking at the past rate increases, how many customers had accounts in arrears in the year before
the increase and the year after the increase (e.g., rate increase in 2001; want data for 2000 and
2002)?
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: Data is not available prior to July 1, 2005 due to the method of
conversion used to implement the District's billing system in 2004. This response
reflects data for rate increases as of the following dates.
Data
as of
Number of
Delinquent
Accounts
Date of
Rate Increase
6/30/2006
72,440
July 1, 2005
(1)
6/30/2007
74,918
No increase
(1)
6/30/2008
66,047
(3)
No increase
(1)
6/30/2009
82,259
(4)
January 1, 2008
(2)
6/30/2010
84,413
July 1, 2009
6/30/2011
84,540
(5)
July 1, 2010
9/30/2011 (3 months only)
84,205
July 11, 2011
(1) This represents the last rate increase approved per the 2003 rate case. The next Rate Commission
rate recommendation was in August 2007. As a result an increase did not occur on July 1, 2006.
The following Rate Commission rate recommendation was in April 2008. A rate increase did not
occur on July 1, 2007 due to the timing of this recommendation.
(2) Per the 2008 rate case, a mid year rate increase was implemented rather than July 1, 2008.
(3) This decrease primarily represents the elimination of inactive accounts with delinquent balances
less than $25 to facilitate billing system changes associated with the implementation of the
stormwater impervious rate. The dollar impact of this adjustment was less than .01% of total
delinquencies.
(4) This increase primarily reflects the December 2008 implementation of the stormwater
impervious rate which resulted in the addition of delinquent accounts charged for stormwater
services only (i.e. customers with septic tanks, inactive waterlines or non-sewered properties
such as parking lots).
(5) The minimal change in number of accounts from June 30, 2010 reflects the reclassification of
delinquent stormwater accounts to inactive status due to the July 9, 2010 stormwater litigation
court decision.
usan 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
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CERTIFICATE OF SERVICE
The undersigned certifies that on the 5th day of October, 2011:
An electronic copy of the foregoing instrument as e -mailed to the Secretary of the Rate Commission do
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:
COWMEN:
ROBERT A. MUELLER:
BARNES JEWISH HOSPITAL:
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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
johnlindschuh@bryancave.com
and
Diana M. Vuylsteke, Esq.
Bryan Cave, LLP
211 N. Broadway, Suite 3600
St. Louis, MO 63102
dmvuylsteke@biyancave.com
John B. Coffman, Esq.
John B. Coffman, LLC
871 Tuxedo Blvd.
St. Louis, MO 63119
j ohn(cr�j ohn coffman. net
aba, /ix
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
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