HomeMy Public PortalAboutExhibit MSD 42 MSD 1st Discovery Request to RC 072911EXHIBIT 42
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
JULY 29, 2011 FIRST DISCOVERY REQUEST
OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT
ISSUE: WASTEWATER RATE CHANGE PROPOSAL
WITNESS: THE RATE COMMISSION OF THE METROPOLITAN
ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: METROPOLITAN ST. LOUIS SEWER DISTRICT
DATE PREPARED: JULY 29, 2011
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
EXHIBIT 42
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 29, 2011 FIRST DISCOVERY REQUEST
OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT TO
THE RATE COMMISSION 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 The Rate Commission
of The Metropolitan St. Louis Sewer District (the "Commission") 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 The
Commission obtains information upon the basis of which (a) The Commission knows that a response was
incorrect when made, or (b) the Commission knows that the response, though correct when made, is no
longer correct.
The following Discovery Request is deemed continuing so as to require the Commission to serve
timely supplemental answers if the Commission obtains further information pertinent thereto between the
time the answers are served and the time of the Prehearing Conference.
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EXHIBIT 42
DEFINITIONS
A. As used herein, the terms "you", "your" and "Consultant" mean the Commission,
William G. Stannard, PE, Raftelis Financial Consultants, Inc. (Raftelis), Inc. and, any representative,
agent, contractor or other person or entity acting or purporting to act for or on behalf of the
Commission.
B. As used herein, the term "MSD" means The Metropolitan St. Louis Sewer
District, and any attorney, representative, agent, contractor or other person or entity acting or
purporting to act for or on behalf of The Metropolitan St. Louis Sewer District.
C. As used herein, the term "document" or "documents" means any writing,
drawings, graphs, charts, photographs, phonograph records, electronic records, reports,
correspondence and other data compilations from which information can be obtained, translated,
if necessary, by the requesting party through detection devices into reasonably usable form, that
are in your possession, custody or control.
D. As used herein, the terms "refer to" or "relate to" mean in any way concerning,
containing, contained in, referring to, evidencing, pertaining to, embodying, or connected to or a
part of, in whole or in part.
E. As used herein, the terms "and" and "or" shall be construed disjunctively or
conjunctively as necessary in order to bring within the scope of an individual, document or
information which might otherwise be construed to be outside the scope of an interrogatory.
F. As used herein, the term "communication" means any oral, written, mechanical,
electronic or other transmission of words, symbols, numbers or depictions to a person, entity, file
or repository of data or information.
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EXHIBIT 42
JULY 29, 2011 FIRST DISCOVERY REQUEST
OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT
1. Does the Consultant perform utility rate design consulting work? Please provide a
list of all clients for which this type of consulting work was performed since 2002.
1.a Please indicate the type of rate design development performed for each client
and indicate if the client provides natural gas, electric, water/wastewater
combined and/or stand alone wastewater.
1.b Please indicate the type of rate analysis and review performed for each client
and indicate if the client provides natural gas, electric, water/wastewater
combined and/or stand alone wastewater.
1.c Please indicate which clients listed are currently managing capital project
programs or similar initiatives and the dollar size of each program.
1.d Please indicate which clients listed have issued bonds, total outstanding
bonds to date, anticipated dollar size of future issuances through June 30,
2016 and breakdown by types of bonds (general obligation, revenue, State or
Federal bond programs).
2. Please describe the tools and methods used by Raftelis to design wastewater rates.
Please describe if and/or how these tools and methods were used by Mr. Stannard to
analyze the basic requirements and assumptions utilized in MSD's May 10, 2011 Rate
Proposal (Exhibit MSD 1).
3. Please describe Mr. Stannard's experience representing clients, developing and
facilitating credit presentations with the major rating agencies Moody's, Fitch, Standard &
Poors and Eagan Jones.
3.a Please provide a list of these clients indicating the dollar size of presented
bond issuance and resulting bond ratings.
3.b Please indicate the key issues addressed by the rating agencies during the
listed client credit presentations and their impacts in the resulting bond
ratings.
4. Describe Mr. Stannard's experience in handling the issuance of bonds for clients.
Please provide a list of these clients and Mr. Stannard's involvement in the issuance of
these bonds.
4.a Please describe Mr. Stannard's role in the issuance of bonds for each of the
listed clients.
4.b Please describe Mr. Stannard's experience with the underwriting of bonds?
4.c Please describe Mr. Stannard's experience in the development of bond
feasibility studies including your involvement in such studies for the clients
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EXHIBIT 42
listed.
5. Please provide all analyses performed to support Mr. Stannard's findings and
recommendations as stated in his rebuttal testimony, Page 3, Lines 4 through 28, and Page
4, Lines 1 through 7. Provide all paper and electronic copies, related correspondence,
documents, agreements, e -mails, and/or other communications related to this analysis.
Su sMn 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 42
CERTIFICATE OF SERVICE
The undersigned hereby certifies that on the 29th day of July, 2011:
An electronic copy of the foregoing instrument was emailed to the Secretary of the Rate
Commission c/o ifenton@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 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(cr�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 42
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@sandbergaphoenix.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
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