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HomeMy Public PortalAboutExhibit MSD 52 MSD 2nd Discovery Request to Rate Commission 080511 (W Stannard)Exhibit MSD 52 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 5, 2011 SECOND DISCOVERY REQUEST OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT ISSUE: WITNESS: SPONSORING PARTY: DATE PREPARED: WASTEWATER RATE CHANGE PROPOSAL WILLIAM G. STANNARD RAFTELIS FINANCIAL CONSULTANTS, INC. METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 5, 2011 Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 1 EXHIBIT 52 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 AUGUST 5, 2011 SECOND DISCOVERY REQUEST OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT 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 Metropolitan St. Louis Sewer District ("District") requests additional information and answers from William G. Stannard, PE, Raftelis Financial Consultants, Inc. (Raftelis) regarding the Rate Change Proposal dated May 10, 2011 (the "Rate Change Proposal"). Raftelis is requested to amend or supplement the responses to this Discovery Request, if Raftelis obtains information upon the basis of which (a) Raftelis knows that a response was incorrect when made, or (b) the Raftelis knows that the response, though correct when made, is no longer correct. The following Discovery Request is deemed continuing so as to require Raftelis to serve timely supplemental answers if Raftelis obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. 2 EXHIBIT 52 AUGUST 5, 2011 SECOND DISCOVERY REQUEST OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT 1. As part of the 2007 Rate Commission proceeding, Mr. Stannard evaluated the District Rate Change Proposal on behalf of the Rate Commission. His evaluation at the time included an alternative rate scenario which assumed a CIRP financing program based on a blend of 50% debt / 50% cash. Mr. Stannard assumed the use of 30 -year bonds at a 5% interest rate. la What was the basis for Mr. Stannard's 5% interest rate assumption? Please provide all documentation and material supporting this assumption. lb. Is this supporting material commonly used as a basis for the cost of debt? 1 c. Is this supporting material commonly used by experts in the wastewater utility rate design field? 1 d. Is this the same supporting material cited as the basis for the District's bond interest rate in its Rate Proposal? 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 3 EXHIBIT 52 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 5th day of August, 2011: An electronic copy of the foregoing instrument was emailed to the Secretary of the Rate Commission c/o j fenton@stlmsd. corn 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 and Exhibits were emailed 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 52 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.com MISSOURI INDUSTRIAL ENERGY John Kindschuh, Esq. CONSUMERS: Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 John.kindschuh@bryancave. corn Diana M. Vuylesteke, Esq. Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 dmvuylesteke@bryancave.com Susan Myers, General Counse METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers a,stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 5