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
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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
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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
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