HomeMy Public PortalAboutExhibit MSD 110 - First Discovery Request of MSD to Interveners HBA May 21, 2015EXHIBIT MSD 110
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
FIRST DISCOVERY REQUEST
ISSUE: WASTEWATER AND STORMWATER RATE
CHANGE PROCEEDING
WITNESS: INTERVENOR HOME BUILDERS ASSOCIATION
OF ST. LOUIS & EASTERN MISSOURI
SPONSORING PARTY: METROPOLITAN ST. LOUIS SEWER DISTRICT
DATE PREPARED: MAY 21, 2015
Metropolitan St Louis Sewer District
2350 Market Street
St. Louis, Missouri 63103
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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
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(2) and Procedural Schedule §§ 1, 17 and 18 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 Home Builders Association of St. Louis & Eastern Missouri ("HBA") regarding the
Rebuttal Testimony of Michael Boerding on behalf of HBA dated May 13, 2015.
HBA is requested to amend or supplement the responses to this Discovery Request, if the
HBA obtains information upon the basis of which (a) the HBA knows that a response was
incorrect when made, or (b) the HBA knows that the response, though correct when made, is no
longer correct.
The following Discovery Requests are deemed continuing so as to require the HBA to
serve timely supplemental answers if the HBA obtains further information pertinent thereto
between the time the answers are served and the time of the Prehearing Conference.
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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:
4aievti. Myers
METROPOLITAN ST. LOUIS SEWER
DISTRICT
2350 Market Street
St. Louis, Missouri 63103
Tel: (314) 768-6366
Fax: (314) 768-6279
Respectfully submitted,
k/K
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to Janice Fenton, Office Associate Senior, Metropolitan St. Louis Sewer District; Lisa Stump,
Counsel for the Rate Commission; and Brad Goss, Counsel for Intervener Home Builders
Association of St. Louis & Eastern Missouri, on this 21st day of May, 2015.
Lisa O. Stump, Esq.
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
Brandon W. Neuschafer
Bryan Cave, LLP
211 N. Broadway, Suite 3600
St. Louis, MO 63102
John.kindschuh@bryancave.com
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