The URL can be used to link to this page

Home My Public Portal AboutExhibit RC 82 - Application to Intervene Home Builders Association of St. Louis & Eastern MissouriSmith~mundsen March ll, 2015 VIA FIRST CLASS MAIL & E-MAIL MSD Rate Commission Ms. Pam Bell Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 Abell cr,stlmsd.com Consultant — MSD Rate Commission Ms. Pam Lemoine Mr. Tom Ratzki Black &Veatch 16350 Swingley Ridge Road, Suite 230 Chesterfield, MO 63017 lemoinepr(a~bv.com ratzkitj cr,bv.com Legal Counsel — MSD Rate Commission Mr. John Fox Arnold Ms. Lisa Stump Lashly &Baer 714 Locust Street St. Louis, MO 63101 ,a farnold(~lashlybaer.com lostum ,lashlybaer.com Brad Goss Ph 314.719.3702 Fax 314.719.3703 bgoss@salawus.com Re: Application to Intervene - MSD 2015 StorinwaYe►• acid Wastewater Rate Change To Whom It May Concern: Filed herewith please find the Application to Intervene for the Home Builders Association of St. Louis &Eastern Missouri in the above-referenced matter. I would appreciate your bringing this filing to the attention of the MSD Rate Commission. Thank you for your assistance. Please contact me with any questions Very truly yours, Smit un n, LLC By: Brad Goss 120 South Central Avenue ~ Suite 700 ~ St. Louis, MO 63105-1794 ~ 314.719.3700 r E ~ ~ 314.719.3710 Fax ~ www.salawus.com ✓/( 6.. CHICAGO, IL INDIAN4 GO L15, IN MIL WAUNEE, WI ROGKFORD, IL ST. CHARLES, IL ST. LOUIS, MO WOO DSTOCK, IL C~SL/SW .~~_D Exhibit RC 82 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT APPLICATION TO INTERVENE Pursuant to Section 3(4) of the Operational Rules of the Rate Commission of the Metropolitan St. Louis Sewer District ("MSD"), as amended, the Home Builders Association of St. Louis &Eastern Missouri (hereinafter referred to as "Applicant"), hereby applies for leave to intervene in the above-referenced proceeding. In support of this Application, Applicant respectfully states as follows: 1. Applicant submits the following information: Name: Home Builders Association of St. Louis &Eastern Missouri Contact: Emily Schwartze Post Address: 10104 Old Olive Street Rd., St. Louis, Missouri 63141 Telephone: (314) 994-7700 E-mail: schwartzee a,hbastl.com 2. Applicant is represented by counsel, and submits the following information of counsel below: Law Firm: SmithAmundsen LLC Contact: Brad Goss /Nicholas Burkhart Address: 120 S. Central Ave. Ste. 700, St. Louis, Missouri 63105 Telephone: (314) 719-3700 E-mail: bgoss~~salawus.com / nburkhart~salawus.com 3. Applicant represents snore than 600 members in promoting and protecting the viability of the home building industry in the geographic areas of St Louis City and 1 the Counties of St. Louis, St. Charles, Jefferson, Lincoln, Pike, Montgomery, Franklin, Warren, and Washington. 4. The home building industry is a key economic engine of MSD, and the matters to be considered in this case and the Rate Commission's determinations thereon will have a direct and disproportionate economic impact on the members of Applicant, and the home building industry in general in the St. Louis region. 5. In the St. Louis region, for each single-family home constructed, the home building industry on average produces 3.33 full-tune jobs, over $210,000 in local income, and over $15,500 in taxes and other revenue for local governments for each single-family home constructed. 5. Increased regulation, without a method of off-setting cost, has a direct and disproportionate effect on the home building industry. A 2011 study conducted by the National Association of Home Builders found that, on average, 25% of the cost of a single-family home is attributable to government regulation. The same study found that in Missouri, for every $1,000 increase in a home's price 4,287 households are priced out of the market for that locally constructed home. 6. As home builders are required to undertake extraordinary efforts to mitigate stormwater impacts in the design of subdivisions and the construction of homes, including the over-detention of water to mitigate existing conditions not created by new construction, the cost of construction increases and results in the further stalling of economic growth and recovery in Missouri. 8. While Applicant does not at this time have sufficient information to assert a position on MSD's proposed rate change, Applicant does plan on submitting prepared 2 testimony on this matter. If Applicant does submit prepared testimony, Applicant agrees to respond to discovery that is submitted in connection with the prepared testimony which Applicant has submitted. WHEREFORE, having stated the grounds for intervention and the position and interest of Applicant in these proceedings, Applicant asks that the Rate Commission grant this Application for Intervention, and thereby entitle said Applicant to have notice and to appear at the taking of testimony, to produce and cross-examine witnesses, and to be heard in person or by counsel on the proceedings, and in all other respects to be made a party to this proceeding. DATED: MARCx 9, 2015 Respectfully Submitted, SMITH,AMUNDSEN LLC John Bradford Goss #36266 Nicholas Burkhart #65816 120 S. Central Avenue, Suite 700 St. Louis, MO 63105 (314) 719-3702 —Direct Dial (314) 719-3703 —Fax bgoss(a,salawus. com nburkhart@sal awes. com Attorneys for Home Builders Association of St. Louis &Eastern Missouri CERTIFICATE OF SERVICE I hereby certify that a copy of the above and foregoing was served on all persons on the official service list of record on this 11 day of March, 2015 John r d o d Go 3