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HomeMy Public PortalAboutExhibit RC 85 - Rate Commission Second Discovery Request to MSD March 30, 2015Exhibit RC 85 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 SECOND DISCOVERY REQUEST OF THE RATE COMMISSION 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 Rate Commission requests additional information and answers from the Metropolitan St. Louis Sewer District ("District") regarding the Rate Change Proposal dated February 26, 2015 (the "Rate Change Proposal"). The District is requested to amend or supplement the responses to this Discovery Request, if the District obtains information upon the basis of which (a) the District knows that a response was incorrect when made, or (b) the District knows that the response, though correct when made, is no longer correct. The following Discovery Requests are deemed continuing so as to require the District to serve timely supplemental answers if the District obtains further information pertinent thereto between the time the answers are served and the time of the Prehearing Conference. SECOND DISCOVERY REQUEST 1. Commissioner Stein has requested that with respect to each of the three referenced stormwater collection areas (red, green, and yellow) that the District please describe and delineate the District's a) current and b) proposed maintenance, repair, replacement, and improvement responsibilities for the following stormwater collection and conveyance elements: (i) catchbasins; (ii) ditches; (iii) culverts under roadways; (iv) retention basins; (v) storm sewers in road and street rights of way; (vi) storm sewers in public easements; (vii) river pumping stations (combined sewer); (viii) intermittent creeks and streams (natural water courses); (ix) normally flowing creeks, streams, and rivers; and (x) the removal of refuse or obstructions in natural watercourses. RESPONSE: 2. Commissioner Stein asks does the District propose to relieve any municipal, county, or state agency of its current responsibilities for stommwater system (including natural drainage ways) maintenance, repair, inspection, replacement, or improvement? If so, please elaborate. RESPONSE: 3. Commissioner Stein has requested that the District provide, for the last fiscal year of the imposition of the impervious fee, (a) the revenue collected system wide; and (b) the 2 percentage of this revenue collected from governments, schools, religious organizations, non- profit hospitals, and the other tax-exempt property owners. RESPONSE: Respectfully submitted, Lisa O. Stump LASHLY & BAER, P.C. 714 Locust Street St. Louis, Missouri 63101 Tel: (314) 621-2939 Fax: (314) 621-6844 3 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; Susan Myers, Counsel for the Metropolitan St. Louis Sewer District; Brad Goss, Counsel for Intervener Home Builders Association of St. Louis & Eastern Missouri; and Brandon Neuschafer and Diana Vuylsteke, Counsel for Intervenor Missouri Industrial Energy Consumers on this 30th day of March, 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. Brad Goss Smith Amundsen, LLC 120 South Central Avenue, Suite 700 St. Louis, MO 63105-1794 bgoss a salawus.com Mr. Brandon W. Neusehafer Ms. Diana M. Vuylsteke Bryan Cave LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 bwneuschafer@bryancave.com dmvuyIsteke@bryancave.com bryancave.com Lisa O. Stump 4