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HomeMy Public PortalAboutExhibit L&B 52A Rate Commission Response to MSD 2nd Discovery RequestBEFORE THE RATE COMMISSION OF TFIE METROPOLITAN ST. LOUIS SEWER DISTRICT RATE COMMISSION'S RESPONSES TO METROPOLITAN SEWER DISTRICT'S SECOND DISCOVERY REQUEST DATED AUGUST 5, 2011 ISSUE: WITNESS: SPONSORING PARTY: DATE PREPARED: Lashly & Baer, P.C. 714 Locust Street St. Louis, Missouri 63101 WASTEWATER RATE CHANGE PROPOSAL RATE COMMISSION METROPOLITAN ST. LOUIS SEWER DISTRICT AUGUST 15, 2011 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 RESPONSES TO THE 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"), Operation 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 Rate Commission hereby files its responses to the Metropolitan St. Louis Sewer District's August 5, 2011 Second Discovery Request. 1 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 and 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. RESPONSE: In his Prepared Rebuttal Testimony, dated May 2, 2007, on behalf of the Rate Commission, Mr. Stannard stated beginning on Line 13 of page 12, "I have performed such an analysis, it is presented in Rate Commission Exhibit No. 1F. In performing the analysis I have included the Test Year adjustments for wastewater I discussed previously. I have assumed that the Board will debt finance approximately 50% of its capital program, resulting in $330,000,000 of revenue bonds over the period of FY 2008 through FY 2012. I have assumed that the District will issue revenue bonds with an interest rate of 5% and a term of 30 years which will be repaid in equal annual payments beginning in the year of issue." See Ex. L&B 37-37E in that proceeding. Questions and answers regarding the interest rate assumption used by Mr. Stannard regarding his alternative scenario can be found in the transcript of Second Technical Conference conducted on May 9-10, 2007. It is Mr. Stannard's recollection that he based his testimony on interest rate assumptions used in water and wastewater rate studies involving other clients he was serving, including Suffolk, VA, Baltimore, MD, Northeast Ohio Regional Sewer District, Saginaw, MI, and San Antonio Water and Sewer System. Mr. Stannrd's approach for developing interest rate assumptions for forecasted revenue bond issues includes examination of current interest rate trends including the Bond Buyer Revenue Bond Index, 10 year Treasury Notes, and yield curves on contemporaneous bond issues as well as discussions with fmancial advisors serving various clients. lb. Is this supporting material commonly used as a basis for cost of debt? RESPONSE: Yes, it is commonly used by Mr. Stannard and his Firm. lc. Is this supporting material commonly used by experts in the wastewater utility rate design field? RESPONSE: Yes 2 ld. Is this the same supporting material cited as the basis for the District's bond interest rate in its Rate Proposal. RESPONSE: The District indicated that it used the Bond Buyer Index as its principal basis for its interest rate assumption. Lis O. Stump t LASHLY & BAER, P.C. 714 Locust Street St. Louis, Missouri 63101 Tel: (314) 621-2939 Fax: (314) 621-6844 CERTIFICATE OF SERVICE The undersigned certifies that on the 15`h day of August, 2011: / oL An electronic copy of the foregoing instrument was emailed to jfenton@stlmsd.com and to the Secretary of the Rate Commission: SECRETARY OF RATE COMMISSION: Ms. Nancy Bowser Secretary of Rate Commission Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 robowser@swbell.net At the request of the 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 associated Exhibits were emailed to: DISTRICT LEGAL COUNSEL: RATE COMMISSION CONSULTANT: 3 Susan Myers, Esq. General Counsel Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Mr. William G. Stannard Vice President & Chief Operating Officer Raftelis Financial Consultants, Inc. 3013 Main Street Kansas City, Missouri 64108 wstannard@raftelis.com COVIDIEN: Mr. Randy Meyer Utility Manager Covidien 3600 North 2nd Street St. Louis, MO 63147 Email: Randy.Meyer@covidien.com ROBERT A. MUELLER. Mr. Robert A. Mueller 16 Ladue Crest Lane St. Louis, MO 63124 Email: ramreco@sbeglobal.net BARNES JEWISH HOSPITAL: Lisa C. Langeneckert, Esq. Sandberg, Phoenix & von Gontard, P.C. 600 Washington Avenue, 15th Floor St. Louis, MO 63101-1313 Email: llangeneckert@sandbergphoenix.com MISSOURI INDUSTRIAL ENERGY CONSUMERS: John R. Kindschuh, Esq. Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 Telephone: 314-259-2313 Email: john.kindschuh@bryancave.com AARP AND CONSUMERS COUNCIL OF MISSOURI: 4 and Diana M. Vuylsteke, Esq. Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 Email: dmvuylsteke@bryancave.com John B. Coffman, Esq. John B. Coffman, LLC 871 Tuxedo Blvd. St. Louis, MO 63119 Email: john@johncoffuian.net