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HomeMy Public PortalAboutExhibit RC 99 - Rate Commission's Fourth Discovery Request to MSD April 27, 2015Exhibit RC 99 BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT For Consideration of a Wastewater and Stoiinwater Rate Change Proposal by the Rate Commission of the Metropolitan St. Louis Sewer District FOURTH 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. 2 FOURTH DISCOVERY REQUEST 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: 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: 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. RESPONSE: 3 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 finding will become no longer prudent. RESPONSE: 5. The Stormwater CIRP Project List in the Rate Change Proposal identifies projects scheduled for completion in FY2017 through FY2023. See MSD Exh. 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. RESPONSE: 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 CIRP financing, and (b) information supporting the current debt capacity limit. RESPONSE: 4 7. For each of the bond issuances included in MSD 94M, please provide a summary of Outstanding Par during FY2015-FY2020. RESPONSE: 8. For each of the bond issuances included in MSD 94N, please provide a summary of Outstanding Par during FY2015-FY2020. RESPONSE: 9. Exhibit MSD 1, Table 4-8 of the Rate Change Proposal provides projections for the Capital Improvement and Replacement program during FY2015 through 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: 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: 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: 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: 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 6 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: 14. Exhibit MSD 75 is a delinquency Agency Schedule for FY2012 to FY2014. Please provide a schedule for the period FY2000 to FY2012. RESPONSE: 15. Please provide a copy of the Approval of the State Fiscal Year 2015 Clean Water State Revolving Fund Intended Use Plan. RESPONSE: 16. The Rate Change Proposal, Ex. 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 1, 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: 7 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: 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-sewered water. Please state for each fiscal year from FY2005 to date the sanitary charges waived under this program. RESPONSE: 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 MSD Exh. 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 8 increase in annual salary, wages and overtime, and personnel, service expense approved by the Board of Trustees for FY2012 to FY2015 inclusive. RESPONSE: 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: 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: 22. Please provide a summary of assumptions used in determining the incremental additional O&M included in the financial plan (see MSD 1, Table 4-6, line 22). RESPONSE: 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; (Hi) Inflation Rates; (iv) Bad Debt and Collection Efforts; (v) Customer 9 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. RESPONSE: 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: 25. Jonathan C. Sprague testified during the Technical Conference regarding service level expectations of the ratepayers and identified customer surveys conducted in 2014 (see 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: 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: 10 Respectfully submitted, 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 27th day of April, 2015. Ms. Janice Fenton Office Associate Senior Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 JFENTON@sthnsd.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(th,salawus.com Mr. Brandon W. Neuschafer Ms. Diana M. Vuylsteke Bryan Cave LLP 211 N. Broadway, Suite 3600 St. Louis, MO 63102 bwneuschaferna,bryancave.com dmvuylsteke a,bryancave.coin 12