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HomeMy Public PortalAboutExhibit MSD 99A - MSD Response to Fourth Discovery Request of the Rate CommissionEXHIBIT MSD 99A BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT APRIL 27, 2015 FOURTH DISCOVERY REQUEST OF THE RATE COMMISSION Metropolitan St. Louis Sewer District Response ISSUE: WASTEWATER AND STORMWATER RATE CHANGE PROCEEDING WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: RATE COMMISSION DATE PREPARED: MAY 7, 2015 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 and Stormwater Rate Change Proposal by the Rate Commission of the Metropolitan St. Louis Sewer District APRIL 27, 2015 FOURTH DISCOVERY REQUEST OF THE RATE COMMISSION Metropolitan St. Louis Sewer District Response 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 responds to the Rate Commission April 27, 2015 Fourth Discovery Request for additional information and answers regarding the Rate Change Notice dated February 26, 2015 (the "Rate Change Notice"). 1 APRIL 27, 2015 FOURTH DISCOVERY REQUEST OF THE RATE COMMISSION Metropolitan St. Louis Sewer District Response 1. The Charter Plan provides that the Board of Trustees shall, by ordinance, identify the Rate Commission Representative Organizations, and that each Representative Organization shall designate an individual to represent it and serve on the Rate Commission. See Charter Plan § 7.230. Please (a) provide copies of all ordinances identifying the current Rate Commission Representative Organizations; and (b) provide a copy of the designation letter from each Rate Commission Representative Organization stating the individual representing the Organization during these proceedings. RESPONSE: (a) See Exhibit MSD 99B, MSD Ordinance No. 13978 (b) See Exhibit MSD 99C, Oath of Office. Due to staff changes, the District was unable to locate the individual designation letters. In response to the request, the District is providing the Oath of Office documents for each individual rate commissioner. 2. During the Technical Conference for Direct Testimony and Rate Setting Documents, Commissioner Stein requested information regarding the intergovernmental agreements among the District and municipalities within or adjacent to the District. Please provide copies of each such agreement currently in force. RESPONSE: The Sewerage System Agreement between MSD and the City of Arnold, dated December 11, 2008, is the only long term intergovernmental agreement that could possibly impact the District financially. See Exhibit MSD 42. 3. During the Technical Conference for Direct Testimony and Rate Setting Documents, Richard L. Unverferth testified that seven levee districts are located within St. Louis County. See p. 60,1. 24; p. 61,11. 1-3. Please (a) name each such levee district; and (b) provide a copy of any current agreement between the District and any such levee district. 2 RESPONSE: Please note that there are actually six levee districts within St. Louis County and MSD. They are: Earth City Levee District, Missouri Bottoms Levee District - Bridgeton Subdistrict, Missouri Bottoms Levee District — Hazelwood Subdistrict, Riverport Levee District, Howard Bend Levee District, and Monarch - Chesterfield Levee District. As stated in the response to the first discovery request Exhibit MSD 84A, question 21, there are no current agreements with these entities. 4. During the Technical Conference for Direct Testimony and Rate Setting Documents, Commissioner Tomazi requested information concerning the extent of District debt. Please provide (a) the total bond debt which may be issued by the District while maintaining a AA credit rating; (b) state the extent to which the District intends to use debt as a major component of future CIRP funding; and (c) when the District expects that continued use of debt as a major component of CIRP funding will become no longer prudent. RESPONSE: (a) The District and its financial advisor used experience and statements from the rating agencies in developing the funding plan for the District in an effort to maintain AA -category ratings. With respect to the financial planning model, debt capacity is based on several interdependent variables such as amount of revenues, amount of operating expenses, desired debt to PAYGO ratios and capital improvement plan amounts and spending timing. As any one of these ratios change, debt capacity is impacted. As noted in Ms. Pugh's testimony (Exhibit MSD 3F), the level of debt in the Rate Proposal was determined in consideration of maintaining fund balances and coverage ratios consistent with AA -category ratings given the District's projected operating expenses, CIRP, desired debt to PAYGO ratio and revenue increase parameters. (b) The District cannot, at this time, determine the extent that debt will be used as a major component of CIRP funding in future rate cycles. Future proposals will be evaluated within the context of the environment existing at that time and requests for additional debt authorization, if any, will be subject to voter approval. (c) See response to (b). 5. The Stormwater CIRP Project List in the Rate Change Proposal identifies projects scheduled for completion in FY2017 through FY2023. See Exhibit MSD Appendix 7.5.2. Figure 5-2 in the Rate Change Proposal describes the Stormwater Capital Improvement & Replacement Program for FY2015 through FY2020. Please quantify (a) the CIRP projects to be completed; (i) FY2015 and FY2016, (ii) in FY2017 through FY2020 inclusive, (iii) in the following fiscal years; and (iv) the remaining backlog of Stormwater CIRP; and (b) provide a schedule for the issuance of the remaining existing bond authorization. 3 RESPONSE: (a) The requested information has been provided below. (a)(iii) (a)(iv) Fiscal Year Total Budget # FY15 $8, 368, 000 29 FY16 $20, 805, 500 58 Total $29,173,500 87 Fiscal Year Total Budget # FY17 $16,370,200 57 FY18 $10, 422, 000 58 FY19 $16,112,000 59 FY20 $6, 999, 000 63 Total $49, 953, 200 237 Fiscal Year Total Budget # FY21 $4,195,000 24 FY22 $3, 980, 000 18 FY23 $1, 525, 000 5 Total $8,175,000 47 Remaining Backlog Stormwater Identified Issues Total Total Conceptual Cost # $296,170,000 443 (b) There are no bonds being issued for stormwater capital improvement projects. 6. On page 37 of the District's 2014-2015 Budget (MSD 19), the District states the "Debt Capacity per MSD Co -Financial Advisors" of $1,400. Please indicate (a) current debt capacity used by the District in determining CLRP financing, and (b) information supporting the current debt capacity limit. 4 RESPONSE: (a) In its 2014-15 Operating Budget (Exhibit MSD 19), the District published an estimated debt capacity of $1,400 per capita. That limit was not set by current District staff or the District's current financial advisors. Furthermore, MSD is not aware of any statutory debt limits or absolute capacity constraints. The District built its CIRP financing plan to achieve a certain balance of PAYGO and debt financing and to maintain AA -category ratings based on expectations communicated by the rating agencies in their rating reports. The District seeks to achieve current and long-term affordability of rates while providing necessary services and meeting EPA CD requirements. Please also see 4(a) above. (b) See response to (a). 7. For each of the bond issuances included in MSD 94M, please provide a summary of Outstanding Par during FY2015-FY2020. RESPONSE: See Exhibit MSD 99D, Outstanding Bond Principal - Existing Bonds 8. For each of the bond issuances included in MSD 94N, please provide a summary of Outstanding Par during FY2015-FY2020. RESPONSE: See Exhibit MSD 99E, Outstanding Bond Principal — Proposed Bonds 9. Exhibit MSD 1, Table 4-8 of the Rate Change Proposal provides projections for the Capital Improvement and Replacement program during FY2015 throligjh FY2020. Please state (a) the total amount of outstanding debt on June 30, 2021; (b) the ratio of debt to operating revenues; (c) total outstanding long-term debt per ratepayer; (d) total outstanding long-term debt per capita; and (e) the ratio of debt to equity. RESPONSE: (a) Per Exhibits MSD 99D and MSD 99E, total outstanding debt at June 30, 2020 is expected to be $2,090.4 million. (b) Given total outstanding debt from (a) and Wastewater Revenue from Exhibit MSD 1, Table 4-10 (page 4-22), line 6, the ratio of debt to wastewater operating revenue at June 30, 2020 is projected to be 4.55 : 1.00. (c) The number of customer accounts is listed in Table 4-2 of Exhibit MSD 1 (page 4-4), line 12. Debt per ratepayer is projected to be $4,969. (d) Using the 2014 "Population" number from Exhibit MSD 25 (page 91), debt per capita is projected to be $1,585. 5 (e) MSD does not project a full Statement of Net Position for future periods so cannot project a debt to equity ratio for June 30, 2020. 10. The Master Bond Ordinance requires the District to provide wastewater rates that are sufficient to pay all operating and maintenance expenditures and provide net operating revenues together with investment earnings that will at least equal 125% of the annual debt service requirement on all senior bonds and at least equal 115% of the annual debt service requirement on all outstanding bonds, loans and other obligations. Table 4-9 — Projected Wastewater Debt Service Requirements (MSD Ex. 1, p. 4-19) describes the Proposed Debt Service Requirements for FY2015 and FY2016 and the Projected Debt Service Requirements for FY2017-FY2020. Please provide (a) the ratio of the projected level of Net Wastewater Revenues (revenue less operation & maintenance expense) to the annual debt service obligation for each fiscal year from FY2015 to FY2020 inclusive; (b) the projected ratios for debt service coverage on senior lien debt and all outstanding debt for each fiscal year from FY2015 to FY2020 inclusive; (c) the projected minimum level of net revenues to meet the minimum debt service requirements for the Additional Bonds test on Total Debt and the annual Rate Covenant Debt Service requirement for each fiscal year from FY2015 to FY2020 inclusive; and (d) the projected amount and percentage of cumulative cash financing and current debt authorization at the end of each fiscal year from FY2015 through FY2020 inclusive. RESPONSE: (a) See Exhibit MSD 1, Table 4-10, line 28. (b) See Exhibit MSD 1, Table 4-10, lines 27 and 28. (c) A basic estimate of the revenue requirements necessary for meeting the Rate Covenant can be calculated by multiplying total debt service (Exhibit MSD 1, Table 4-10, line 28) by 1.15X (the Rate Covenant) and adding Operating Expenses (Exhibit MSD 1, Table 4-10, line 7). The resulting level of revenues necessary for this requirement ranges from approximately $240 million in FY2015 to almost $360 million in FY2020. It is important to note that this level of revenues would not be sufficient to meet all of the projected expenses of the District, i.e. non - operating expenses such as PAYGO capital would not be sufficiently funded Based on this analysis, the annual deficit ranges from $42 million to $101 million in FY2015 and FY2020, respectively, even before accounting for minimum operating reserve requirements. Negative annual deficits would lead to a rapid depletion of cash on hand Raising the minimum level of revenues only sufficient to meet coverage would have negative ratings implications, significantly increasing the District's cost of capital and potentially eliminating the District's access to the capital markets. (d) See Exhibit MSD 99F Cumulative Cash Financing and Debt Authorization 6 11. Please provide a summary of assumptions regarding term, interest rate, issuance costs, bond reserve requirements, etc. for the Debt Service Requirements shown in MSD Ex. 1, Table 4-9, page 4-19. RESPONSE: See Exhibit MSD 1 Section 4.6.2, "Existing and Projected Wastewater Debt", and Exhibits MSD 94M and 94N. Debt reserve deposits are listed in Table 4-8 of Exhibit MSD 1 (page 4-16), Line 12. 12. Please state whether the District's Financial Advisor and/or Rate Consultant believe that the relative proportion of debt and cash financing of the CIRP proposed by the District is reasonable. RESPONSE: Both the District's Financial Advisor and Rate Consultant believe that the relative proportion of debt and cash financing of the CIRP proposed by the District is reasonable. 13. During the Technical Conference for Direct Testimony and Rate Setting Documents, Bethany Pugh testified that the financial plan provides for minimum cash on hand of 550 days. See page 6, lines 22-23.Please describe (a) how 550 was determined to be the minimum; and (b) how does the model incorporate this criteria to ensure that the financial plan meets or exceeds the minimum, compared to the calculations in the Rate Model, and as described in William Stannard's testimony regarding minimum operating fund balances. See page 10, line 22 and page 19, line 8. Please state (a) each revenue source and beginning balance at FY2015; and (b) the current day's cash on hand as of the most recent date. RESPONSE: (a) The District worked with its financial advisor to determine a minimum level of funds on hand based on feedback from the rating agencies and in consideration of prudent financial management. The financial model's calculation of days cash on hand for FY2014 was 626 days. Consequently a 550 day projected target is 12% below current levels. We believe this is a reasonable deduction relative to current figures that generally maintains the District's financial position —a point that was emphasized to be important by the rating agencies. (b) It is important to note that the financial model and days' cash on hand targets relate to wastewater exclusively. The financial model was developed based on the District's audited financial statements, including unrestricted cash and investments and other balance sheet items. The rating agencies rely on audited financial statements for the vast majority of their metrics. The rate proposal is developed on a cash needs basis. To ensure the Rate Proposal is consistent with the outcomes of the financial plan, we have cross checked input assumptions, like operating expenses and CIRP, and ensure comparable output, i.e. revenue requirements, are consistent. 7 (c) The financial planning model calculated fiscal year end 2014 days cash on hand at 626 days. Days cash on hand is calculated by taking total unrestricted cash and investments divided by total operating expenses (not including depreciation) divided by 365. Unrestricted cash and investments would generally consist of District operating revenues. 14. Exhibit MSD 75 is a delinquency Agency Schedule for FY2012 to FY2014. Please provide a schedule for the period FY2000 to FY2012. RESPONSE: Exhibit MSD 840 includes delinquency Aging Schedules for FY2010 and FY2014. Please refer to Exhibit MSD 99M for Aging Schedules for FY2006 through FY2009. Aging information for the District was not reported and tracked in this fashion prior to FY2006 due to the District's transition from the legacy billing system. 15. Please provide a copy of the Approval of the State Fiscal Year 2015 Clean Water State Revolving Fund Intended Use Plan. RESPONSE: See Exhibit MSD 99G, Original Fiscal Year 2015 Clean Water SRF Intended Use Plan and Exhibit MSD 99H, Amended Fiscal Year 2015 Clean Water SRF Intended Use Plan. 16. The Rate Change Proposal, Exhibit MSD 1, compares wastewater bills with and without the authorization of $900 million in revenue bonds. See Figure 4-9, p. 4-41. Please provide for each alternative the projected (a) average monthly residential wastewater bill on July c1, 2016; (b) the average annual residential wastewater bill as a percentage of median household income on July 1, 2016; and (c) the percentage average annual increase for residential wastewater bills for July 1, 2017, 2018, 2019, and 2020. RESPONSE: (a) Table 6-2 in the Rate Proposal presents projected wastewater bills based on the authorization of $900 million in revenue bonds. The typical customer bill of 7 ccf per month is shown on line 3, with the annual percentage change on line 4. Table 4-25 presents the same information with the assumption of no further bond authorization. (b) The US Census Bureau reports that the MHI for St. Louis City (2009-2013) is $34,582 and St. Louis County (2009-2013) is $58,910. Approximately 21% of MSD customers live in the City and 79% live in the County. These data correspond to a weighted average MITI of $53,801 for the MSD service area. Assuming no increase in these MHI values, the wastewater bills as a percentage of MHI on July 1, 2016 would be the following: 8 MSD Service Area Median Household Income $ 53,801 With $900M Bond Authorization July 1, 2016 Typical Customer Bill (per month) $ 44.72 x 12 months 12 Annual Wastewater Bills $ 536.64 Annual Bil as %of MHI 1.00% Without $900M Bond Authorization July 1, 2016 Typical Customer Bill (per month) $ 44.72 x 12 months 12 Annual Wastewater Bills $ 536.64 Annual Bill as 0/0 of MHI 1.000/0 Since the existing bond authorization is not depleted until FY 2018, the rate scenario under each alternative is the same on July 1, 2016. When the current authorization is depleted in FY2018, the scenarios for rates effective on July 1, 2017 would calculate the following: MSD Service Area Median Household Income $ 53,801 With $900M Bond Authorization July 1, 2017 Typical Customer Bill (per month) $ 49.56 x 12 months 12 Annual Wastewater Bills $ 594.72 Annual Bill as %of MI•II 1.11% Without $900M Bond Authorization July 1, 2017 Typical Customer Bill (per month) $ 73.80 x 12 months 12 Annual Wastewater Bills $ 885.60 Annual Bill as %of MHI 1.65% (c) Table 6-2 in the Rate Proposal presents projected wastewater bills based on the authorization of $900 million in revenue bonds. The typical customer bill of 7 ccf per month is shown on line 3, with the annual percentage change on line 4. Table 4-25 presents the same information with the assumption of no further bond authorization. 9 17. During the Technical Conference for District Testimony and Rate Setting Documents, William Stannard testified that the proposed Wastewater Revenue increase was 10.75%. Please (a) state the proposed percentage increase in Residential and Tier One ratepayer bills for each year from FY2015 to FY2020; (b) provide copies of any memorandum, report, work paper, summary, analysis, or schedule that supports the District's determination; and (c) state the amount of the median residential bill for each such year. RESPONSE: The increase in residential customer bills varies based on the level of water consumption. Table 6-2 in the Rate Proposal presents the estimated bills for customers with varying levels of water usage based on the proposed rates and charges. Each bill is based on Tier One compliance charges. The District does not have the information required to provide the median residential bill. 18. Table 4-4 — Wastewater User Charge Revenue Under Approved Rates, Exhibit MSD 1, pp. 4-9, shows the historic growth in user charge revenue for FY2013 and FY2014 and the projected growth in user charge revenue for FY2015 to FY2020. The District conducts a program for customers to apply for a reduction of sewer charges for non -severed water. Please state for each fiscal year from FY2005 to date the sanitary charges waived under this program. RESPONSE: Sanitary charges waived as a result of reduction factors were as follows: Fiscal Year Dollars FY2005 $8,034,423.24 FY2006 $9,050,209.96 FY2007 $8,624,123.29 FY2008 $9,116,626.10 FY2009 $7,516,111.88 FY2010 $7,400,065.92 FY2011 $9,004,867.10 FY2012 $8,765,155.22 FY2013 $10,104,727.44 FY2014 $8,743,612.50 FY2015* $9,105,340.08 *FY2015 represents activity through April, or 10 months. 10 19. William Stannard described in Direct Testimony certain cost increases due to inflation for the District's wastewater expense projections for FY2016 through FY2020. See Exhibit MSD 3H at page 9, lines 8-18. Please provide (a) the annual percentage increase experienced by the District for each of these items for each of FY2011 to FY2014 inclusive; (b) the individual components of the index used by the District as a basis for the future inflation allowances; (c) a detailed estimate of the pension costs for the District under the new defined contribution plan for each fiscal year from FY2016 to FY2020 inclusive; and (d) the percentage increase in annual salary, wages and overtime, and personnel service expense approved by the Board of Trustees for FY2012 to FY2015 inclusive. RESPONSE: (a) Refer to Exhibit MSD 991,, Year over Year Variance Tables. (b) As indicated in Appendix 7.1.1 of the Rate Change Proposal, Exhibit MSD 1, the District used multiple sources for developing the inflation assumptions used in the Rate Change Proposal projections. As that appendix explains, most accounts were inflated using the Core PCE Price Index as published by the Congressional Budget Office in their work entitled The Budget and Economic Outlook: 2014 to 2024. This index, according to the Bureau of Economic Analysis (www. bea.gov) can be defined as follows. "The `core' PCE price index is defined as personal consumption expenditures (PCE) prices excluding food and energy prices. The core PCE price index measures the prices paid by consumers for goods and services without the volatility caused by movements in food and energy prices to reveal underlying inflation trends." Appendix 7.1.1 of the Rate Change Proposal, Exhibit MSD 1, also provides an explanation of the inflation factor calculation for salary increases, and notes the source of our information for Group Insurance assumptions. Inflation factors for utilities and Bond & Liability Insurance were based on management's estimates. (c) Annual estimates for pension costs for the District can be found in the Rate Model, MSD Exhibit 79, in the O&M Summary tab between rows 835 and 2647. Rows within this range labeled '51230 — Pension Contribution' include the projections. The analysis done to estimate pension costs was combined to include both the Defined Benefit (DB) and Defined Contribution (DC) plans. The DB plan was closed to new participants in 2011 and has shown steady declines each year after. The assumption was made that continued decreases in the DB plan will be offset by future cost increases in the DC plan due to increased participation. (d) Refer to Exhibit MSD 99I, Year over Year Variance Tables. 11 20. Please provide a table summarizing the allocation of the District's fixed assets to functional cost components, indicating the date of such fixed asset data, as referenced on page 4- 26, first sentence of second paragraph. RESPONSE: The allocation of the District's fixed assets to functional cost components can be found in the electronic rate model on the Plant-Funct' worksheet. The fixed asset value is the estimated net book value for June 30, 2016 based on current asset cost, depreciation, and useful life information. 21. Please provide Appendix 7.2.2 and 7.5.2 in Excel format. In addition, please provide a) necessary detail to indicate to which category (e.g., SSO, CSO, treatment plant, etc.) each project is assigned; and breakdown by cost component (e.g., design, construction, property acquisition, ROW acquisition, etc.). RESPONSE: The requested tables have been provided as MSD Exhibit 99.I - Revised Appendix 7.2.2 and MSD Exhibit 99K - Revised Appendix 7.5.2. Please note that the Stormwater CIRP projects are not categorized as SSO, CSO, treatment plant, etc. as these are wastewater designations only. 22. Please provide a summary of assumptions used in determining the incremental additional O&M included in the financial plan Ogg MSD1, Table 4-6, line 22). RESPONSE: The Additional O&M amounts that appear on line 22 of Table 4-6 in Exhibit MSD 1 originate from the Budget -Input tab of the Rate Model, Exhibit MSD 79, in rows 2012 through 2165. From those inputs, the values can be traced to the O&M Summary tab on row 139 of the spreadsheet. The original numbers developed by District management have had inflation applied to them in the same manner as all other O&M expense projections in the model. Additionally, those expenses that are unallocated, meaning they are not specific to either wastewater or stormwater, have been allocated between wastewater and stormwater based on the projections of continued O&M expenses. Below are some general reasons for the incremental expenses by department. I. Executive Director a. 2 Additional full-time equivalents (FTE's) in the Public Information division b. Community outreach programs c. MSD website revamp d. Transfer of Project Clear consultant from Operations 12 IL Engineering a. 12 Additional FTE's; to perform work in Construction Management (8); Design (3); and Environmental Compliance (1) including one-time purchases of equipment for these employees and on -going uniform and mileage expenses in some cases III. Finance a. 7 Additional FTE's; in Accounts Receivable (2) to support water shut-off for delinquent accounts; Financial Planning (2) for Big Data predictive analytics; Accounting (2) to support financial reporting and increased stormwater CIRP; and General Purchasing (1) to handle increased workload from the Consent Decree b. Increased postage and printing expenses for new full page bill and increased monthly hosting expenses for billing system and software upgrade project currently underway c. Predictive analytics IV General Counsel a. I Additional FTE V. Information Systems a. 1 Additional FTE b. Enterprise Document Management system (hardware/ software/professional services) c. Data Center Colocation Initiative hardware refresh and professional services d. Title quote system re -write (in support of Billing System Upgrade) VI. Operations a. 33 Additional FTE's; due to increased service levels i. Yards (27) ii. Pump Stations (2) iii. Garage and Shops (2) iv. Treatment Plant (I) v. Technical Services (1) b. Asset management services c. Fleet additions for increased stormwater service levels VII Secretary -Treasurer a. Election expenses 23. A summary of projected wastewater expenses for Operations and Maintenance for FY2015 through FY2020 is presented in Table 4-6 of Exhibit MSD 1. These projections are based on certain financial assumptions: (i) Customer and Water Usage growth/Decline; (ii) Customer Impacts; (iii) Inflation Rates; (iv) Bad Debt and Collection Efforts; (v) Customer Assistance Project; (vi) Overhead Rates; (vii) Basis for cost of service indirect/direct cost allocation; (viii) Average Water/Wastewater Utility Bill Comparison; (ix) Salary Projection; (x) Wastewater/Stormwater Segmentation; and (xi) Infiltration/Inflow Assumptions. Please describe how the District will manage each of these factors if the anticipated conditions, events, and circumstances do not occur. 13 RESPONSE: The financial assumptions used to project the expenses in Exhibit MSD 1, Table 4-6 were made using information available at the time. If these anticipated conditions, events, and circumstances do not occur, the District will respond accordingly by adjusting the budget in the appropriate expense and/or revenue accounts to maintain a balanced budget each fiscal year. 24. Please indicate when the historical impervious area data included in the Rate Model was compiled (see MSD79, Tab "Demand -Input", lines 503-586). RESPONSE: The historical impervious area data was compiled as part of the 2011 Rate Proposal, Exhibit MSD 9. 25. Jonathan C. Sprague testified during the Technical Conference regarding service level expectations of the ratepayers and identified customer surveys conducted in 2014 (See Exhibit MSD 3D, p. 4, 1. 6) and a customer service survey regarding stormwater services in the "Red Area" (see MSD 3D, p. 6, 1. 20). Please provide copies of each of these and any other customer surveys conducted since January 1, 2013. RESPONSE: See Exhibit MSD 99L - 99L2, Customer Surveys. 26. Please describe (a) the District's policy regarding billing of wastewater services (e.g., billing in arrears), and (b) the adjustment factor applied in calculating projected revenue under proposed increases in the first year of the increase. RESPONSE: (a) The District issues a monthly bill to approximately 424,000 commercial and residential accounts. The bill has a Wastewater User Charge which includes a base charge and a volume charge based on either the amount of water used at an address or, if no water meter is in use, the number of rooms, baths water closets, and showers in the building. Commercial properties are also billed a Compliance Charge based on the type of wastewater discharged to the public sewer system. The District policy to bill customers for services provided in the previous month can be found in the Wastewater User Charge Ordinance which is included in Exhibit MSD 19, page 348; section 6. (b) The Rate Proposal does not include an adjustment factor for billing in arrears because unbilled revenue is recorded as an accrual in the month the service was provided 14 Respectfully submitted, Susan M. Myers METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 Tel: (314) 768-6366 Fax: (314) 768-6279 15 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 7th 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 bgossAsalawus.com Brandon W. Neuschafer Bryan Cave, LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 Jolm.kindschuh@brvancave.com Susan M. Myers, General Cunsel METROPOLITAN ST. LOUIS SEWER DISTRICT 2350 Market Street St. Louis, Missouri 63103 smyers@stlmsd.com Tel: (314) 768-6366 Fax: (314) 768-6279 16