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Home My Public Portal AboutExhibit MSD 95A - MSD's Response to Request by Intervenor MIEC to Seek Modification of the Procedural Schedule and to Stay Current ProceedingsExhibit MSD 95A BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT MSD'S RESPONSE TO REQUEST BY INTERVENOR MIEC TO SEEK MODIFICATION OF THE PROCEDURAL SCHEDULE AND TO STAY CURRENT PROCEEDINGS ISSUE: WASTEWATER AND STORMWATER RATE CHANGE PROCEEDING WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: RATE COMMISSION DATE PREPARED: APRIL 16, 2015 Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, Missouri 63103 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 MSD'S RESPONSE TO REQUEST BY INTERVENOR MIEC TO SEEK MODIFICATION OF THE PROCEDURAL SCHEDULE AND TO STAY CURRENT PROCEEDINGS The Metropolitan St. Louis Sewer District ("District") hereby responds to the Request by Intervenor Missouri Industrial Energy Consumers to Seek Modification of the Procedural Schedule and to Stay Current Proceedings dated April 10, 2015. The Metropolitan St. Louis Sewer District wishes to correct the factual misstatements made in the request and proposes a revision to the Intervenor's proposed revisions to the 2015 Rate Case Procedural Schedule, that if adopted, will enable the Rate Commission additional time to submit the Rate Commission Report to the District's Board of Trustees. 1. Section III, paragraph 1, page 5, the Rate Change Proposal proposes to increase stormwater revenue approximately $12 million over a four-year period, not $91 million as indicated by the Intervenors. See Table 5-3 of the Rate Change Proposal. 2. Section II, Schedule proposed by MIEC, page 3, the Proposed Schedule Dates provided by MIEC only identified dates for seven Public Hearings, the Procedural Schedule adopted by the Rate Commission on March 4, 2015 identified dates for nine public hearings. If the Rate Commission decides to consider the Intervenor's proposed modification of the procedural schedule, the District recommends the modification include nine public hearing dates. 3. If the Rate Commission decides to consider the Intervenor's proposed modification of the procedural schedule, the District recommends that the Prehearing Conference be scheduled for June 22, 2015 as opposed to the Intervenor's proposed date of June 26, 2015 with the Prehearing Conference Reports due on June 26, 2015 as opposed to the July 3, 2015 as proposed by the Intervenors. This will allow ample time after the Surrebuttal Technical Conference for all parties to be prepare for the Prehearing Conference, it will allow all testimony proceedings to be finished before the July 3, 2015 holiday week to avoid any conflicts with holiday travel, and will allow the Rate Commission the flexibility of using 24 days to develop the Rate Commission Report instead of the 17 days allowed by the Intervenor's proposed schedule. The District appreciates your attention to correcting the record in this proceeding and to considering the proposed modifications to the procedural schedule, if, the Intervenor's proposed modification is being considered. Respectfully submitted, san M. Myers METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 Tel: (314) 768-6366 Fax: (314) 768-6279 2 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; Brad Goss, Counsel for Intervener Home Builders Association of St. Louis & Eastern Missouri, and Brandon Neuschafer, Counsel for Intervener Missouri Industrial Energy Consumers on this 16th day of April, 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 .gtozn /41 Susan M. Myers, General Couns METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6366 Fax: (314) 768-6279 1