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Home My Public Portal AboutExhibit MIEC 94 - First Discovery Request of Intervenor MIECExhibit MIEC 94 Wastewater and Stormwater Rate Change Proceeding — 2015 First Discovery Request of Intervenors MIEC 2. Referring to Exhibit MSD-1, Table 4-7 — Wastewater Capital Improvement and Replacement Program, please provide a description of any change in the Projected Needs in FY 2015 and FY 2016 filed in this Rate Change Proposal versus the amounts budgeted for FY 2015 and FY 2016 filed in the 2011 Rate Change Proposal. Please provide a detailed explanation for changes to budgeted items. RESPONSE: 3. Referring to Exhibit MSD-1, Table 4-8 — Capital Improvement and Replacement Program Financing Plan, please provide a variance analysis for each line on the table with projected sources and projected uses of funds versus actual sources and uses of funds from fiscal years 2011 through 2014 in electronic format with all formulas intact. Please provide a detailed explanation for the difference in projected versus actual for each line item. RESPONSE: 4. For each category of capital improvement program, please identify the long-term capital improvement program for each category which is needed to respond to the EPA mandated programs as part of the Consent Decree agreement between MSD and the EPA. For each system retrofit required by the EPA, please identify the following: a. Planned capital budget by year up until the retrofits are completed. b. Identify the time period MSD has available to make the system retrofits to remain in compliance with its agreement with the EPA. c. Please explain MSD's system plan in the event it must extend the capital program in order to successfully comply with all system improvements and modifications to comply with the EPA mandates. RESPONSE: 5. Please provide a detailed description of MSD's management plan for increased capital expenditures in FY17 through FY20. Please provide a detailed description of MSD's plans for the following: 2 4534221.1 Wastewater and Stormwater Rate Change Proceeding — 2015 First Discovery Request of Intervenors MIEC a. Assurance that it is able to enter into qualified contracts to meet an increased construction program as forecasted by MSD. b. MSD's plan to ensure that it has qualified inspectors and engineers on staff to ensure contractors are complying with the detailed specifications of the system retrofits. c. A complete description of performance failure requirements MSD is requiring on contractors to ensure that any system improvements that are not designed according to MSD specifications will be the responsibility of contract failure and not MSD and its customers. d. Please provide an estimate of the maximum capital program that MSD can effectively manage each year. e. Please identify the accounting standards MSD will put in place to ensure that the expenditures it makes to contractors and third -party vendors meet those vendors' requirements to make system improvements and retrofits in line with MSD's need for such improvements to comply with EPA mandates. RESPONSE: 6. Referring to Exhibit MSD-1, Table 4-8 — Capital Improvement and Replacement Program Financing Plan, please provide a variance analysis of the projected sources and uses of funds in FY 2015 and FY 2016 filed in this Rate Change Proposal versus the projected sources and uses of funds in FY 2015 and FY 2016 filed in the 2011 Rate Change Proposal in electronic format with all formulas intact. Please provide a detailed explanation for each line item. RESPONSE: 7. Please provide all credit reports pertaining to MSD issued by Standard & Poor's, Moody's and Fitch over the last two years. RESPONSE: 8. At the Technical Conference on April 8, 2015, Mr. Richard Unverferth testified that contractors are subject to a prequalification process to demonstrate that they have the capability to perform the work for which they are bidding. Please identify and provide copies of 3 4534221.1 Wastewater and Stormwater Rate Change Proceeding — 2015 First Discovery Request of Intervenors MIEC the District's contractor prequalification policies and procedures, including, but not limited to, the District's policies and procedures for reviewing and confirming information submitted to by contractors. RESPONSE: 9. Please identify the interest rates for current senior and subordinated bonds, as well as the projected interest rates for future senior and subordinated bonds. RESPONSE: 10. Please identify whether and how MSD will ensure that, if the actual annual spend for FY2017-2020 is below the projected spend, any difference will be used to accelerate projects required under the Consent Decree. RESPONSE: 11. At the Technical Conference on April 8, 2015, Mr. William Stannard indicated that there is additional supporting data and analysis on which the Vertex forecasts included in the Rate Proposal at Appendices 7.1.2 and 7.1.3 were based. Please provide a copy of such additional supporting data and analyses. RESPONSE: 12. At the Technical Conference on April 8, 2015, and in his prepared testimony, Mr. William Stannard indicated he relied on his experience with other urban utilities throughout the United states to support his conclusions on projections for number of customers and volume of flow per customer. Please provide copies of all utility forecasts and trends in wastewater flows for the other urban utilities that were considered in reaching this conclusion. RESPONSE: 4 4534221.1 Wastewater and Stormwater Rate Change Proceeding — 2015 First Discovery Request of Intervenors MIEC 13. Please provide an explanation of how costs for common wastewater and storm water costs are allocated between MSD's wastewater and storm water costs of service. RESPONSE: Respectfully submitted, BRYAN CAVE LLP By: Dina M. Vuylsteke, #42419 Brandon W. Neuschafer, #53232 211 N. Broadway, Suite 3600 St. Louis, Missouri 63102 Telephone: (314) 259-2543 (Diana) Telephone: (314) 259-2317 (Brandon) Facsimile: (314) 259-2020 dmvuylsteke@bryancave.com bwneuschafer@bryancave.com ATTORNEYS FOR MIEC Dated: April 10, 2015 5 4534221.1 Wastewater and Stormwater Rate Change Proceeding — 2015 First Discovery Request of Intervenors MIEC CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to the following on this loth day of April, 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 j farnold@lashlybaer.com Ms. Lisa O. Stump Lashly & Baer, P.C. 714 Locust Street St. Louis, MO 63101 lostump@lashlybaer.com Mr. Brad Goss Smith Amundsen, LLC 120 South Central Avenue, Suite 700 St. Louis, MO 63105-1794 bgoss@salawus.com 6 4534221.1