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
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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.
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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
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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
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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
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