HomeMy Public PortalAboutExhibit MSD 24A MSD Response to Third Discovery Request MIECEXHIBIT MSD 24A
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
JULY 13, 2011 THIRD DISCOVERY REQUEST
OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS
Metropolitan St. Louis Sewer District Response
ISSUE: WASTEWATER RATE CHANGE PROPOSAL
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: MISSOURI INDUSTRIAL ENERGY CONSUMERS
DATE PREPARED: July 20, 2011
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
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EXHIBIT MSD 24A
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 13, 2011 THIRD DISCOVERY REQUEST
OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS
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"),
Metropolitan St. Louis Sewer District ("District") thereby responds to the Missouri Industrial
Energy Consumers July 13, 2011 Second Discovery Request for additional information and
answers 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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EXHIBIT MSD 24A
JULY 13, 2011 THIRD DISCOVERY REQUEST
OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS
Metropolitan St. Louis Sewer District Response
3-1. Please provide a complete copy of the July 28, 2010 Rate Consulting Services
Agreement between MSD and Black & Veatch referenced in MSD's response to MIEC Discovery
Request 2-1.
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: The requested information is provided as Exhibit MSD 24B.
3-2. Please provide a complete copy of the July 11, 2011 Rate Consulting Services
Agreement between MSD and Black & Veatch referenced in MSD's response to MIEC Discovery
Request 2-1.
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: The requested information is provided as Exhibit MSD 24C.
3-3. Please provide any correspondence, documents, agreements, e -mails, and/or other
communications from MSD and/or Black & Veatch regarding MSD's decision to designate the
electronic copy, with all formulas intact, of the Black & Veatch May 10, 2011 MSD Wastewater Rate
Proposal as proprietary.
RESPONSE RESPONDER: Susan Myers, MSD General Counsel.
RESPONSE: There are no documents related to this request. MSD's position is as stated in MSD
Exhibit 19B, Question 2-1.
3-4. Please provide any correspondence, documents, agreements, e -mails, and/or other
communications from MSD and/or Black & Veatch regarding MSD's position that if another party,
such as the MIEC, were to request that Black & Veatch run a new scenario with its model, the
MIEC would be responsible for paying Black & Veatch to process this request.
RESPONDER: Susan Myers, MSD General Counsel
RESPONSE: There are no documents related to this request. MSD's position is as stated in MSD
Exhibit 19B, Question 2-1.
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EXHIBIT MSD 24A
3.5. Please provide any correspondence, documents, agreements, e -mails, and/or other
communications from MSD and/or Black & Veatch involving MSD and Black & Veatch
negotiating, drafting, and finalizing the July 28, 2010 and July 11, 2011 Rate Consulting Agreements.
RESPONDER: Jan Zimmerman, MSD Director of Finance
RESPONSE: The requested information is provided as Exhibits 24D and 241)1
1/1/
usan Myers, General Cothsel
ETROPOLITAN 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 MSD 24A
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 20th day of July, 2011:
An electronic copy of the foregoing instrument was emailed to the Secretary of the Rate
Commission c/o jfenton cr,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(&,1ashlybaer.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(2i com
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EXHIBIT MSD 24A
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
langeneckert@sandbergphoenix. corn
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 Couns
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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