HomeMy Public PortalAboutExhibit MSD 19E Amendment to Response to 2nd Discovery Request MIECEXHIBIT MSD 19E
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
JULY 1, 2011 SECOND DISCOVERY REQUEST
OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS
Metropolitan St. Louis Sewer District Response
AMENDMENT
TO
QUESTIONS # 2-6 AND # 2-7
ISSUE: WASTEWATER RATE CHANGE PROPOSAL
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: JULY 12, 2011
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
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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
JULY 1, 2011 SECONDE DISCOVERY REQUEST
OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS
Metropolitan St. Louis Sewer District Response
AMENDMENT
TO
QUESTIONS # 2-6 AND # 2-7
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 amends responses to Questions # 2-6
and # 2-7 to the Missouri Industrial Energy Consumers July 1, 2011 Seconde Discovery Request
for additional information and answers regarding the Rate Change Notice dated May 10, 2011
(the "Rate Change Notice").
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MAY 26, 2011 FIRST DISCOVERY REQUEST
OF THE RATE COMMISSION
Metropolitan St. Louis Sewer District Response
AMENDMENT
TO
QUESTIONS # 2-6 AND # 2-7
Reason for Amendment: The District responses did not correspond with Questions # 2-6 and
# 2-7. This amendment places the responses with the correct associated question.
2-6. During the Technical Conference for District Testimony and Rate Setting
Documents, Jan Zimmerman testified that she would provide information regarding MSD's
anticipated environmental compliance costs for non-residential customers for 2011. Please provide
MSD's anticipated environmental compliance costs for non-residential customers for 2011, 2012,
2013, 2014, 2015, and 2016, and provide any supporting documents, analyses, or reports discussing
the same. (See Exhibit MSD 17, Testimony of Jan Zimmerman, page 156, lines 6 - 15).
RESPONDER Keith Barber, MSD Rate Consultant.
RESPONSE: A portion of costs previously recovered by the environmental compliance charge are
now recovered through the basic wastewater rate structure. Under this reallocation of costs, the
2010 costs directly related to the District's monitoring efforts is estimated to be $1,881,100 as
indicated in Table 3-22 of Exhibit MSD 1. Transitioning the existing uniform compliance charge to
the 2016 cost of service charge will bring the projected 2016 revenue in -line with estimated 2016
costs. Therefore, the compliance monitoring costs can be estimated by interpolating between the
2010 costs and the 2016 projected costs resulting in the following fiscal year estimates:
2010 $1,881,100 per Table 3-22 of Exhibit MSD 1
2011 $1,963,000
2012 $2,044,900
2013 $2,126,800
2014 $2,208,700
2015 $2,290,600
2016 $2,372,500 per Table 3-17 for FY 2016 (Exhibit MSD 19D).
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2-7. During the Technical Conference for District Testimony and Rate Setting
Documents, Jan Zimmerman testified that MSD attempts to recover its compliance costs from each
customer tier level. What portion of MSD's costs are recovered from each customer tier level (i.e.,
Tiers 1 — 5)? (See Exhibit MSD 17, Testimony of Jan Zimmerman, page 156, lines 16 — 25).
RESPONDER Keith Barber, MSD Rate Consultant
RESPONSE: The compliance charge is proposed to transition from a uniform charge in 2012 to a
five -tier cost of service based compliance charge over the four year horizon of the Rate Change
Proposal (Exhibit MSD 1). As a result the percentage distribution of the projected compliance
charge revenue varies by year. Exhibit MSD 19Cprovides a breakdown of the five compliance
charge tiers by number of accounts, existing and projected monthly compliance charge, projected
compliance charge revenue by tier and percentage distribution of projected compliance charge
revenue by tier.
As Exhibit MSD 19C indicates, the percentage of compliance charge revenue generated by Tier 1
customers, decreases from 94.0 percent under existing 2012 charges to 27.6 percent by FY16 as
revenues derived from the four other tiers increase. This shift in the distribution of revenue
continues until the charges are fully transitioned to equal the projected compliance cost of service
level in 2016. At this point the 2016 revenue distribution is approximately equal to the 2010
distribution of costs shown in Column 1 of Table 3-22 of the Rate Change Proposal (Exhibit MSD
1).
Exhibit MSD 19C further indicates, this redistribution of compliance charge revenue results in an
increase in revenue generated by Tier 2 customers from 1.8 percent in 2012 to 9.9 percent in 2016;
compliance charge revenue generated from Tier 3 customers increases from 2.7 percent to 32.7
percent; revenue from Tier 4 customers increases from 0.9 percent to 15.7 percent, and compliance
charge revenue generated by Tier 5 customers increases from 0.6 percent to 14.1 percent.. This
redistribution of revenue results in a more equitable spread of the compliance cost of service across
all customer classes as the monthly compliance charge is more closely tied to the level of compliance
monitoring required for each customer.
Additional compliance charge material is provided by Exhibit MSD 18W and 18X.
ectfully submitted,
ajlit kb
Susan Myers, General ounsel
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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CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 12th 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:
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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
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
Susan Myers, General Counsel
METROPOLITAN ST. LOUIS SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
Email: smyers@stlmsd.com
Tel: (314) 768-6200
Fax: (314) 768-6372
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