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Home My Public Portal AboutExhibit HBA 110A - HBA Response to First Discovery Request of MSD1 Wastewater and Stormwater Rate Change Proceeding — 2015 Response of Intervenor Home Builder Association of St. Louis & Eastern Missouri to MSD’s First Discovery Request BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT For Consideration of a Wastewater and Stormwater Rate Change Proposal by the Rate Commission of the Metropolitan St. Louis Sewer District RESPONSES OF INTERVENOR HOME BUILDERS ASSOCIATION OF ST. LOUIS & EASTERN MISSOURI TO THE FIRST 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(5) and Procedural Schedule § 17 of the Rate Commission of the Metropolitan St. Louis Sewer District ("Rate Commission"), the Intervenor Home Builders Association of St. Louis and Eastern Missouri ("HBA") hereby responds to the May 21, 2015, First Discovery Request of the Metropolitan St. Louis Sewer District ("MSD"). DISCOVERY REQUEST 1. In his Rebuttal Testimony, Michael Boerding generally describes his experience as it relates to wastewater and stormwater management and design. See Ex. HBA 103, p. 1, 11. 15-19. Please, (a) describe in detail your experience in determining how entities providing public stormwater services recover their costs; (b) provide the names of whom you performed such work for. RESPONSE: a) Mr. Boerding’s experience with public stormwater services is limited to those aspects traditionally related to the engineering profession, including the design and review of Storm Water Pollution Prevention Plans (SWPPP), Erosion and Sediment Control Plans, Grading Plans, Flood Plain Studies, Storm Water Drainage Design, BMP Design, Sanitary Sewer Design, Pumping Station and Force Main Design, and Water Supply System Design. As a professional engineer, Mr. Boerding has no experience related to the recovery of costs for entities providing public stormwater services. b) Not applicable. 2 Respectfully submitted, SmithAmundsen, LLC By: __/s/_John Bradford Goss_____ John Bradford Goss, #36266 Nicholas L. Burkhart, #65816 120 S. Central Avenue, Suite 700 St. Louis, MO 63105 314.719.3702 – Telephone 314.719.3703 – Facsimile bgoss@salawus.com nburkhart@salawus.com ATTORNEYS FOR HBA OF ST. LOUIS AND EASTERN MISSOURI Dated: June 2, 2015 3 CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to the following on this 2nd day of June, 2015. Ms. Janice Fenton Office Associate Senior Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 jfenton@stlmsd.com Ms. Susan Myers General Counsel Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 smyers@stlmsd.com Mr. John Fox Arnold Lashly & Baer, P.C. 714 Locust Street St. Louis, MO 63101 i farnold@lashlybaer.com Ms. Lisa O. Stump Lashly & Baer, P.C. 714 Locust Street St. Louis, MO 63101 lostump@lashlybaer.com Ms. Diana M. Vuylsteke Mr. Brandon W. Neuschafer Bryan Cave LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 dmvuylsteke@bryancave.com bwneuschafer@bryancave.com