HomeMy Public PortalAboutExhibit RC 68- Rate Commissions First Discovery Request to MSD 04042023BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
FIRST DISCOVERY REQUEST
ISSUE: 2023 STORMWATER & WASTEWATER RATE
CHANGE PROCEEDING
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: APRIL 4, 2023
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
Exhibit RC 68
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BEFORE THE RATE COMMISSION
OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT
For Consideration of a Stormwater & )
Wastewater Rate Change Proposal )
by the Rate Commission of the )
Metropolitan St. Louis Sewer District )
FIRST 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”), Restated Operational Rule § 3(7) and Procedural Schedule §§ 16 and
17 of the Rate Commission of the Metropolitan St. Louis Sewer District (the “Rate Commission”),
the Rate Commission requests additional information and answers from the Metropolitan St. Louis
Sewer District (the “District”) regarding the Rate Change Proposal dated March 24, 2023 (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.
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DISCOVERY REQUEST
1. How does the District allocate “District-Wide” costs (e.g., Board of Trustees, Rate
Commission, Finance, HR, etc.) between Stormwater and Wastewater?
RESPONSE:
2. Please provide a copy of the most recent revenue bond official statement?
RESPONSE:
3. Please state whether the District’s financial plan reflects 100% of the Operations
and Maintenance (“O&M”) budget.
RESPONSE:
4. In Table 4-8 (See Ex. MSD 1; p. 4-17), Capitalized Internal Labor is listed as a
source of funds. Please describe how this is a source of revenue for the District.
RESPONSE:
5. Regarding Line 6 of Table 4-7 (See Ex. MSD 1; p. 4-16), please explain what
“Other” Capital Improvement and Replace Program (“CIRP”) costs are included.
RESPONSE:
6. Regarding Lines 11 & 12 of Table 4-7 (See Ex. MSD 1; p. 4-16) please explain the
reductions in CIRP for Asset Management and Non-Recurring Projects.
RESPONSE:
7. In Line 7 of Table 4-8 (See Ex. MSD 1; p. 4-17), please state the source(s) of Grants
and Contributions.
RESPONSE:
8. Please provide a listing of all extra strength surcharge customers, including billed
volume, strength for Suspended Solids, BOD, and COD, and excess strength surcharge revenue
for each customer for FY 2020, FY 2021, and FY 2022.
RESPONSE:
9. Please provide in Microsoft Excel or csv format, the detailed billing data for
unmetered customers, including the number of attributes for each account.
RESPONSE:
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10. What is the basis for projected contributed volume? Was the volume per customer
analyzed and projected and the projected volume calculated based on such along with projected
customers? If yes, please explain how these calculations were made.
RESPONSE:
11. What are the assumptions made by the District for the Low Income Customer
Assistance Program participation?
RESPONSE:
12. How is the City of Arnold charged for wastewater service? How was this revenue
projected over the Rate Change Proposal period?
RESPONSE:
13. Please provide the FY 2023 beginning fund balance for the Stormwater Regulatory
Fund, Districtwide Stormwater Fund, and Stormwater OMCI Funds.
RESPONSE:
14. Please explain how parcels were classified as Residential and Non-Residential for
purposes of Stormwater taxes/charges. Please state whether multi-family parcels are considered
Residential or Non-Residential.
RESPONSE:
15. Please provide a summary of the number of parcels, gross area (lot size) and
impervious area for Residential and Non-Residential properties.
RESPONSE:
16. How was bad debt for the proposed stormwater revenues determined? Has the
District’s experience been 100% payment of ad valorem assessments? What is the District’s
proposed enforcement mechanism for the Non-Residential impervious area capital charge?
RESPONSE:
17. Please provide a summary of annual revenue by OMCI district for the last 10 years
and projected over the Rate Change Proposal period.
RESPONSE:
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18. Please describe the process for activating the OCMI tax rates? Who determines
when/whether to resume collection of the ad valorem taxes within the OMCI districts?
RESPONSE:
19. Please provide a summary of the number and estimated total cost of projects
completed within each OMCI district over the past 10 years and projected over the Rate Change
Proposal period.
RESPONSE:
20. What was the District’s estimated cost of completion and compliance with the
Consent Decree as of the District’s 2019 wastewater Rate Change Proposal presentation to the
Rate Commission?
RESPONSE:
21. What is the District’s estimated cost of completion and compliance with the
Consent Decree today?
RESPONSE:
22. How was the estimated cost of completion and compliance of the Consent Decree
prepared?
RESPONSE:
23. Who prepared the estimated cost of completion and compliance for the Consent
Decree?
RESPONSE:
24. For each capital project in the Consent Decree, specify the estimated cost of
completion, the cost components, the time of completion, and the methodology used by the District
to determine the feasibility of completion of each such capital project by 2039.
RESPONSE:
25. What capital projects (if any) were identified as of 2019 to be completed prior to
April of 2023 during the District’s 2019 wastewater Rate Change Proposal presentation to the Rate
Commission?
RESPONSE:
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26. Of the capital projects (if any) identified in Request No. 25, have all such projects
been completed as the date of this discovery request? If yes, please identify all projects completed.
If no, please identify the projects which remain to be completed, and the estimated time and costs
for completion for each such project.
RESPONSE:
27. What is the reasonable likelihood that the District will complete and fully comply
with the Consent Decree by 2039?
RESPONSE:
28. What is the reasonable likelihood that the District will complete and fully comply
with the Consent Decree at the currently estimated cost of completion by 2039?
RESPONSE:
Respectfully submitted,
/s/ Brian J. Malone
Lisa O. Stump
Brian J. Malone
LASHLY & BAER, P.C.
714 Locust Street
St. Louis, Missouri 63101
Tel: (314) 621-2939
Fax: (314) 621-6844
lostump@lashlybaer.com
bmalone@lashlybaer.com
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CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to Stephanie DeJarnette, Office Associate Senior, Metropolitan St. Louis Sewer District; Susan
Myers, Counsel for the Metropolitan St. Louis Sewer District, on this 4th day of April, 2023.
Ms. Stephanie DeJarnette
Office Associate Senior
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
sdejarnette@stlmsd.com
Ms. Susan Myers
General Counsel
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
smyers@stlmsd.com
/s/ Brian J. Malone
Brian J. Malone