The URL can be used to link to this page

Home My Public Portal AboutExhibit MSD 50 MSD August 4, 2011 Supplemental Response To The Second Discovery Request of MIECEXHIBIT MSD 50 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 4, 2011 SUPPLEMENTAL RESPONSE TO THE SECOND DISCOVERY REQUEST OF MISSOURI INDUSTRIAL ENERGY CONSUMERS Metropolitan St. Louis Sewer District Supplemental Response ISSUE: WASTEWATER RATE CHANGE PROPOSAL WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: MISSOURI INDUSTRIAL ENERGY CONSUMERS DATE PREPARED: AUGUST 4, 2011 Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 1 EXHIBIT MSD 50 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 METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 4, 2011 SUPPLEMENTAL RESPONSE TO THE SECOND DISCOVERY REQUEST OF MISSOURI INDUSTRIAL ENERGY CONSUMERS 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 submits this supplemental response to the Second Discovery Request of Missouri Industrial Energy Consumers, Prepared on July 1, 2011, regarding the Rate Change Notice dated May 10, 2011 (the "Rate Change Notice"). 2 EXHIBIT MSD 50 METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 4, 2011 SUPPLEMENTAL RESPONSE TO THE SECOND DISCOVERY REQUEST OF MISSOURI INDUSTRIAL ENERGY CONSUMERS Metropolitan St. Louis Sewer District Response 2-2. During the Technical Conference for the District Testimony and Rate Setting Documents, Brian Hoelscher testified that there are projects, such as the expansion of the ash lagoon, that are listed in Exhibit 9B 1 that are not specifically listed in the Consent Decree. Please identify and describe any projects, including but not limited to the expansion of the ask lagoon, that are listed in Exhibit 9B 1 that are not required by the Consent Decree. (See Exhibit MSD 17, Testimony of Brian Hoelscher, page 89, lines 19 - 25 and page 90, lines 1-18). RESPONDER: Brian Hoelscher, MSD Director of Engineering RESPONSE: Attached as exhibit MSD 50A is a detailed list of projects which are anticipated to be a part of the current Rate Proposal. This Exhibit, MSD 50A, should serve to supplement any response made by MSD to any discovery request previously made by any party related to planned projects as listed within said exhibit. Please note the following regarding Exhibit MSD 50A: 1. The third column titled "CD Section/Para" references the appropriate paragraph of the consent decree (Exhibit MSD 49A) that relates to the specific project as listed. 2. The fourth column titled "CD Board Write-up Para" references the appropriate paragraph of Exhibit MSD 11A-32 (the Board Agenda Detail Sheet) that relates to that specific project as listed. 3. Exhibit MSD 50A maybe used to link the CD to rate proposal tables 3-8, page 3- 14, line 12 and table 3-9 page 3-15 line 9 of the Rate Proposal. m Susan Myers, General Coilnse METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 3 EXHIBIT MSD 50 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 4th Day of August, 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: 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 4 EXHIBIT MSD 50 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 smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 5