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Home My Public Portal AboutExhibit MSD 46 MSD 1st Discovery Request to BJH Amendment to Question #2 080111EXHIBIT MSD 46 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT JULY 15, 2011 FIRST DISCOVERY REQUEST OF ARNES JEWISH HOSPITAL Metropolitan St. Louis Sewer District Response AMENDMENT TO QUESTION # 2 ISSUE: WASTEWATER RATE CHANGE PROPOSAL WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: BARNES JEWISH HOSPITAL DATE PREPARED: AUGUST 1, 2011 Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 1 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 15, 2011 FIRST DISCOVERY REQUEST OF BARNES JEWISH HOSPITAL Metropolitan St. Louis Sewer District Response AMENDMENT TO QUESTION # 2 Pursuant to §§ 7.280 and 7.290 of the Charter Plan of the Metropolitan St. Louis Sewer District (the "Charter Plan"), Operational 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 Metropolitan St. Louis Sewer District ("District") thereby amends response to Question # 2 and to the Barnes Jewish Hospital July 15, 2011 First Discovery Request for additional information and answers regarding the Rate Change Notice dated May 10, 2011 (the "Rate Change Notice"). 2 JULY 15, 2011 FIRST DISCOVERY REQUEST OF BARNES JEWISH HOSPITAL Metropolitan St. Louis Sewer District Response AMENDMENT TO QUESTION # 2 2. If the answer to Question 1 is that there are customers who do not receive both services: a. How many of MSD's customers receive only wastewater service and what percentage is that to total customers and RESPONDER: Jan Zimmerman, MSD Director of Finance RESPONSE: No MSD customers, or 0 %, receive only wastewater services. The table below provides the breakdown of MSD customers receiving stormwater only, wastewater only, and both services. Brian Hoelscher's tandem response below provides additional detail. Customers SW Only WW Only Both SW & WW Total Number 41,014 0 426,579 467,593 Percent 9 % 0 % 91 % 100 % RESPONDER: Brian Hoelscher, MSD Director of Engineering RESPONSE: This response is provided to correct MSD's misinterpretation of this question. All MSD customers receive stormwater services. The District's response to Question # 1 provides an explanation of the stormwater funding mechanism currently available to MSD. Based on this explanation, all MSD customers receive stormwater services, however only 91 % of the District's customer base also receive some level of wastewater services. The remaining 9 % of MSD customers receive only stormwater services. This 9 % represents 41,014 customers identified at the time the District was able to charge customers an impervious based stormwater fee as receiving only stormwater services. These customers are not provided sanitary sewer services because they are either not connected to MSD's sanitary sewer system, provided services by a private entity, are served by private septic systems that are regulated by local health departments, or may be properties that do not generate sanitary waste. 3 Respectfully submitted, Susan Myers, General Co selu METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 4 CERTIFICATE OF SERVICE The undersigned hereby certifies that on the 1st day of August, 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 was emailed and one paper copy and associated Exhibits were couriered 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: 5 Mr. Randy Meyer Utility Manager Covidien 3600 North 2nd Street St. Louis, MO 63147 Randy.Meyer(a�covidien@com 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@sandbergphoenix.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 dmvu_ylesteke@bryancave.com Susan Myers, General Co sel METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 Email: smyers@stlmsd.com Tel: (314) 768-6200 Fax: (314) 768-6372 6