HomeMy Public PortalAboutExhibit MSD 70A- MSD's Response to Rate Commission's Second Discovery RequestExhibit MSD 70A
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
MSD’S RESPONSE TO THE SECOND DISCOVERY REQUEST OF
THE RATE COMMISSION
SPONSORING PARTY: RATE COMMISSION
ISSUE:2023 STORMWATER & WASTEWATER RATE
CHANGE PROCEEDING
WITNESS:METROPOLITAN ST. LOUIS SEWER DISTRICT
DATE PREPARED:APRIL 17, 2023
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Exhibit MSD 70A
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 )
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”), 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 Metropolitan St. Louis Sewer District (the “District”) hereby responds to the April 7, 2023
Second Discovery Request of the Rate Commission for additional information and answers
regarding the Rate Change Proposal dated March 24, 2023 (the “Rate Change Proposal”).
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Exhibit MSD 70A
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 )
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”), 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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Exhibit MSD 70A
DISCOVERY REQUEST
1. The Rate Change Proposal states that it is consistent with constitutional, statutory or
common law as amended from time to time. See MSD Ex.l, p. 4-40, 4-41 and 5-7, 5-8. Please
(a) describe the analysis that was performed to reach this conclusion; (b) provide copies of any
memorandum, report, work paper, summary, analysis, or schedule that supports this conclusion;
and (c) describe the rationale for such conclusion.
WASTEWATER RESPONSE: See MSD Exhibit 1, Section 4.11(1) -pg. 4-40.
STORMWATER RESPONSE: See MSD Exhibit 1, Section 5.5(1) -pg 5-7.
2. The Rate Change Proposal states that it enhances the District’s ability to provide
adequate sewer and drainage systems and facilities or related services. See MSD Ex. 1 p. 4-41, 5-
8. Please (a) describe the analysis that was performed to reach this conclusion; (b) provide copies
of any memorandum, report, work paper, summary, analysis, or schedule that supports this
conclusion; and (c) describe the rationale for such conclusion.
WASTEWATER RESPONSE: See MSD Exhibit 1, Section 4.11(2) -pg. 4-41
STORMWATER RESPONSE: See MSD Exhibit 1, Section 5.5(2) -pg 5-8
3. The Rate Change Proposal states that it is consistent with and not in violation of
any covenant or provision relating to any outstanding bonds or indebtedness of the District. See
MSD Ex. 1, p. 4-41, 5-8. Please (a) describe the analysis that was performed to reach this
conclusion; (b) provide copies of any memorandum, report, work paper, summary, analysis, or
schedule that supports this conclusion; and (c) describe the rationale for such conclusion.
WASTEWATER RESPONSE: The Rate Change Proposal was developed to comply with the
covenants of outstanding bonds or indebtedeness. Section 6 1 of the Master Bond Ordinance
(Exhibit MSD 15) requires the District to'
(i) prescribe, fix, maintain, and collect rates, fees, and other charges for the services,
facilities, and commodities furnished by the System fully sufficient at all times to provide
for 100% of operation and maintenance expenses andfor the accumulation of a reasonable
reserve
(ii) produce Net Operating Revenues in each fiscal year that will equal at least 125%)
(1.25x) of the Debt Service Requirement on all Senior Bonds then outstanding and 115%
(1.15x) of the debt service requirement on all bonds outstanding for the year of
computation
(Hi) meet the costs of major renewals, replacements, repairs, additions, betterments,
and improvements to the System, necessary to keep the same in good operating condition
or as is required by any governmental agency having jurisdiction over the System
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Exhibit MSD70A
The Wastewater Financial Plan (Table 4-10) in the Rate Change Proposal shows that the
proposed rates are expected to be sufficient to cover operating expenses, maintain an adequate
reserve (see section 4.7, pg 4-20, of the Rate Change Proposal), and fund the CIRP while
maintaining debt coverage ratios above the required minimums
Senior and Subordinate Bonds
Sections 5.3 and 5 4 of the Master Bond Ordinance specify additional bond tests for new issuances,
requiring.
(i) a report by an Independent CPA to the effect that historical net operating revenues and
investment earnings for a period of 12 consecutive months of the most recent 18
consecutive months prior to the issuance of either Senior Bonds or Subordinate Bonds
were equal to at least (a) 125% of the Maximum Annual Debt Service Requirement on
all Senior Bonds which will be Outstanding immediately after the issuance of the
proposed Subordinate Bonds and (b) 115°/o of the Maximum Annual Debt Service
Requirement on all Bonds which will be Outstanding immediately after the issuance
(such calculations may include proforma adjustments to historical net operating
revenues equal to 100%o of the increased annual amount attributable to any revision in
the schedule of rates, fees, and charges for the services, facilities, and commodities
furnished by the System, adopted prior to the date of delivery of the proposed
Subordinate Bonds and not fully reflected in the historical Net Operating Revenues
actually received during such 12-month period), or
(ii) a report by a Consultant to the effect that the forecasted net operating revenues and
investment earnings for each year in the forecast period are expected to equal to at
least (a) 125% of the Maximum Annual Debt Service Requirement on all Senior Bonds
which will be Outstanding immediately after the issuance of the proposed Subordinate
Bonds and (b) 115%> of the Maximum Annual Debt Service Requirement on all Bonds
which will be Outstanding immediately after the issuance
The net operating revenues and debt service totals projected in the Rate Change Proposal and
Rate Model show that the proposed rates are expected to be sufficient to meet this test.
Reasonable Charges
Section 6.7 of the Master Bond Ordinance requires that “none of the facilities or services afforded
by the System will be furnished to any user without a reasonable charge being made therefor ”
The Rate Change Proposal does not assume or propose that any service be provided for free.
STORMWATER RESPONSE: See MSD Exhibit 1, Section 5.5(3) -pg 5-8
4. The Rate Change Proposal states that it will not impair the ability of the District to
comply with applicable federal or state laws or regulations as amended from time to time. See
MSD Ex. 1, p. 4-41,4-42 and 5-9. Please (a) describe the analysis that was performed to reach this
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Exhibit MSD 70A
conclusion; (b) provide copies of any memorandum, report, work paper, summary, analysis, or
schedule that supports this conclusion; and (c) describe the rationale for such conclusion.
WASTEWATER RESPONSE: See MSD Exhibit 1, Section 4.11(4) -pg. 4-41.
STORMWATER RESPONSE: See MSD Exhibit 1, Section 5.5(4) -pg. 5-8 & 5-9
5. The Rate Change Proposal states that it considers the financial impact on all classes
of ratepayers in determining a fair and reasonable burden. See MSD Ex. 1, p. 4-42, 5-9. Please (a)
describe the analysis that was performed to reach this conclusion; (b) provide copies of any
memorandum, report, work paper, summary, analysis, or schedule that supports this conclusion;
and (c) describe the rationale for such conclusion.
WASTEWATER RESPONSE: See MSD Exhibit 1, Section 4 11(5) In addition, please
see MSD Ex 1, p ES-4 for discussion on cost-of-service analysis. MSD Ex 1, §4 9 - §4 10provide
further discussion of the analysis Additional analysis details can be found in MSD Ex. 60 and in
testimony provided by Thomas Beckley in MSD Ex. 3K, pp. 4-9.
STORMWATER RESPONSE: See MSD Exhibit 1, Section 5.5(5) -pg 5-9
6. Please identify any covenants with which the Rate Change Proposal must comply.
Please describe any loans, grants, or provisions of the Consent Decree which were considered in
formulating the Rate Change Proposal.
WASTEWATER RESPONSE: In addition to the Senior Bonds contemplated in the Rate
Change Proposal, the District also assumes the use of State Revolving Fund (SRF) loans and a
Wastewater Infrastructure Finance and Innovation Act (WIFIA) loan Debt covenants are
described in the answer to Question 3 above and the loans are generally described in Tim Snoke’s
Direct Testimony (Exhibit MSD 3H) and expected to be structured substantially simdar to previous
debt agreements. The District also expects to receive $3 million in American Rescue Plan Act
(ARPA) grants through the state in FY25 for a sanitary relief project
STORMWATER RESPONSE: The District expects to receive almost $19 million in
American Rescue Plan Act (ARPA) grants through the state in the FY25-FY28 rate cycle for
various projects
7. Please describe how the District’s affordability metrics compare to similarly
situated utilities.
RESPONSE: Please see Exhibit MSD 70B
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Exhibit MSD 70A
8. Please describe any facts and circumstances which demonstrate whether the Rate
Change Proposal and all portions thereof is necessary to pay interest and principal falling due on
bonds issued to: (a) finance assets of the District; (b) necessary to enable the District to provide
for the costs of operation and maintenance; and (c) such other amounts as may be required to cover
emergencies and anticipated delinquencies, as required by § 7.040 of the Charter Plan.
WASTEWATER RESPONSE: See MSD Exhibit 1, Section 4 8, pages 4-21 to 4-27.
STORMWATER RESPONSE: Not applicable - the District is not proposing funding
the stormwater capital plan with bonds and stormwater revenue is not pledged for repayment of
the District’s outstanding debt
9. Please describe any other facts and circumstances which demonstrate whether and
to what extent the Rate Change Proposal and all portions thereof is necessary to enable the District
to comply with any covenant or provision relating to outstanding bonds or indebtedness of the
District, together with a specific quantification of the amount of the Proposed Rate Change is
necessary for such purposes, as required by § 4(2)(c) of the Operational Rules.
WASTEWATER RESPONSE: There are no additional facts and circumstances.
STORMWATER RESPONSE: There are no additional facts and circumstances.
10. Please describe any facts and circumstances which demonstrate how the Rate
Change Proposal considers the financial impact on all classes of ratepayers in determining a fair
and reasonable burden, including whether and how cost of service considerations, have been
factored into such determination as required by § 4(2)(e) of the Operational Rules.
WASTEWATER RESPONSE: Please see Exhibit MSD1 (Rate Change Proposal), item
5 on page 4-42
STORMWATER RESPONSE: Please see Exhibit MSD1 (Rate Change Proposal), item
5 on page 5-9.
11. Please describe any facts and circumstances which demonstrate how the Rate
Change Proposal considers the financial impact on all classes of ratepayers in determining a fair
and reasonable burden, including whether and how cost causation principles, have been factored
into such determination as required by § 4(2)(e) of the Operational Rules.
WASTEWATER RESPONSE: See MSD Exhibit 1, item 5 on page 4-42 and §4.9 -§4.10
starting on page 4-25
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Exhibit MSD70A
STORMWATER RESPONSE: Please see Exhibit MSD1 (Rate Change Proposal), item
5 on page 5-9
12. Please describe any facts and circumstances which demonstrate how the Rate
Change Proposal considers the financial impact on all classes of ratepayers in determining a fair
and reasonable burden, including whether and how customer impact data has been factored into
such determination as required by § 4(2)(e) of the Operational Rules.
WASTEWATER RESPONSE: See MSD Exhibit 1, item 5 on page 4-42. In addition,
customer impact data can be found in Section 6 of MSD Exhibit 1, starting on page 6-1
STORMWATER RESPONSE: Please see Exhibit MSD 1 (Rate Change Proposal), item
5 on page 5-9. In addition, customer impact data can be found in Section 6 of MSD Exhibit 1,
starting on page 6-4
13. Please describe any facts and circumstances which demonstrate how the Rate
Change Proposal considers the financial impact on all classes of ratepayers in determining a fair
and reasonable burden, including whether and how economic development considerations have
been factored into such determination as required by § 4(2)(e) of the Operational Rules.
WASTEWATER RESPONSE: See MSD Exhibit 1, item 5 on page 4-42 and §4.9-§4 10
starting on page 4-25. The Rate Change Proposal does not consider economic development.
STORMWATER RESPONSE: Please see Exhibit MSD 1 (Rate Change Proposal), item
5 on page 5-9. The Rate Change Proposal does not consider economic development
14. Please describe any facts and circumstances which demonstrate how the Rate
Change Proposal considers the financial impact on all classes of ratepayers in determining a fair
and reasonable burden, including whether and how environmental effects have been factored into
such determination as required by § 4(2)(e) of the Operational Rules.
WASTEWATER RESPONSE: The core ofMSD’s business is regulated by the Clean
Water Act (CWA) The Rate Change Proposal was developed by reviewing all the known
regulatory needs that will have to be met over the next four years. That includes compliance with
existing regulations and the consent decree. See MSD Exhibit 1, Section 4 6, pg 4-15.
STORMWATER RESPONSE: No improvements will negatively impact the
environment while many will improve the environment (i e erosion control) See MSD Exhibit 1,
Section 5 1(3) - pg 5-8
15. Please describe any other facts and circumstances which demonstrate how the Rate
Change Proposal considers the financial impact on all classes of ratepayers in determining a fair
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Exhibit MSD70A
and reasonable burden, including whether and how any other factors have been factored into such
determination as required by § 4(2)(e) of the Operational Rules.
WASTEWATER RESPONSE: There are no additional facts and circumstances.
STORMWATER RESPONSE: There are no additional facts and circumstances
16. Please (a) describe any other facts and circumstances which demonstrate that the
measures taken by the District to ensure that the cost of constructing and maintaining the District’s
facilities and providing related services are being incurred in a reasonable and efficient manner;
and (b) include copies of all internal or external audit reports that address such matters as required
by § 4(2)(f) of the Operational Rules.
WASTEWATER RESPONSE::
a. There are no additional facts or circumstances.
b. The following audit reports have been provided as Exhibits MSD 70C thru 70L. The
exhibits include audit reports prepared within the current MSD Rate cycle
STORMWATER RESPONSE:
a. There are no additional facts or circumstances.
b. The following audit reports have been provided as Exhibits MSD 70C thru 70L The
exhibits include audit reports prepared within the current MSD Rate cycle.
17. Please describe any other facts and circumstances which demonstrate how, whether
and to what extent the Rate Change Proposal and all portions thereof, will affect, impact and
comply with the Consent Decree, as required by § 4(2)(g) of the Operational Rules.
WASTEWATER RESPONSE: There are no additional facts or circumstances.
STORMWATER RESPONSE: The Stormwater Proposal will have no impact on
compliance with the Consent Decree.
18. Please provide copies of the CIRP, for both stormwater and wastewater, in
Microsoft Excel format.
RESPONSE: See MSD Exhibits 70Mand 7ON
19. With regard to the Stormwater CIRP, please describe in detail how projects are
prioritized or scored. Has the District performed a District-wide study of stormwater capital
improvement needs and/or priorities? If yes, please provide a copy of the study.
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Exhibit MSD 70A
RESPONSE: The identification and prioritization ofprojects to be included in the Capital
Improvement and Replacement Program is a multi -step process, requiring monitoring and
updating to ensure that the highest priority problems within the District are addressed in a timely
manner, given funding available These stages include project identification, conceptual solution,
preliminary study, final design, and construction At each step in the process, the project scope is
reevaluated to verify that it continues to meet regulatory requirements and customers' needs. The
project cost is updated, and the project's priority is assessed with the goal that the highest priority
projects are funded first
Stormwater projects are identified to address flooding and erosion issues and are prioritized based
upon the severity of the flooding and erosion and the overall benefit to the property. Types of
stormwater flooding problems listed in order of severity include: structure flooding, roadway
flooding, and yard flooding Types of erosion problems listed in order of severity include, stream
erosion threatening a structure, stream erosion threatening a road, and yard erosion. Benefit
points for a flooding problem are assigned based on the severity of the problem and the frequency
of the flooding. For example, chronic flooding of a house would be assigned more benefit points
than infrequent flooding of a yard. Benefit points for an erosion problem are assigned based on
the height of the streambank and the distance to the structure For example, a house that is 20 feet
from a 10 foot high streambank would be assigned more benefit points than a structure that is 50
feet from a 5 foot high streambank
In order to maximize the benefits per dollar spent on a project, a benefit/cost ratio is calculated to
determine the project priority ranking. Benefit points are totaled for the properties that benefit
from the project, and the points are divided by the cost of the project in thousands to determine
the project priority ranking For example, a project with 100 benefit points divided by lOOKproject
costs would have a priority ranking of 1.00. Prioritization Worksheet Guidelines as Exhibit MSD
700 and the Prioritization Worksheet as Exhibit MSD 70P have been provided.
The most recent District-wide Stormwater study has been provided as Exhibit MSD 70Q.
20. With regard to the Stormwater impervious surface charge for non-residential
properties, has the District analyzed the business impact on large properties [such as big-box
stores, strip malls, industrial facilities] with large amounts of impervious surface? If yes, please
provide a copy of such analysis.
RESPONSE: Please see Exhibits 30C and 30D below that were included in the 2018
Stormwater Rate Proposal The “Stormwater Capital Rate Annual Charges ” column of these
reports will be 15-20% larger than shown here due to the increase in overall revenues being
requested in the 2023 Rate Proposal, assuming these properties still consist of the same amount
of impervious area MSD is not privy to the financial information relating to these customers, but
do not believe that the proposed changes would represent an undue hardship
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Exhibit MSD70A
2018 Stormwater Rate Proposal
Exhibit MSD 30C
Potential Annual Charges from SW Capital Rate
2018 Stormwater Rate Proposal
Exhibit MSD SOD
Customer Address
Impervious
Area
SW Capital Rate Annual
Charge
Before
FY22
FY22and
After
WEST COUNTY MALL CMBS LLC 4 WEST COUNTY CTR DES PERES, 63131 959,326 $ 6,642 $ 9,963
LOWES HOME CENTERS INC 3180 N HIGHWAY 67 ST FLORISSANT, 63033 514,640 $ 3,564 $ 5,346
CORTEX INNOVATION DISTRICT Multiple 4,337,966 $ 30,024 $ 45,036
WALMART REAL ESTATE BUSINESS TRUST 10741 W FLORISSANT AVE FERGUSON, 63136 409,782 $ 2,844 $ 4,266
PARKWAY CONSOLIDATED SCHOOL DISTRICT 347 N WOODS MILL RD CHESTERFIELD, 63017 1,713,318 $ 11,862 $ 17,793
25 Largest Customers by Impervious Area
Customer Impervious Area
Annually Total Impervious
and Real Property
Taxes2
SW Capital Rate Charges Regulatory Tax |O&M Tax
Before FY22 FY22 and After Calendar Yea r2017
CITY OF ST LOUIS 29,383,754 $203,418 $305,127 $-$-$305,127
CITY OF ST LOUIS FOREST PARK 13,320,683 $92,214 $138,321 $-$-$138,321
MCDONNELL DOUGLAS CORPORATION 10,768,276 $74,556 $111,834 $13,190 $68,124 $193,148
CHRYSLER CORPORATION 10,568,755 $73,170 $109,755 $267 $1,378 $111,400
BOARD OF EDUCATION CITY OF ST LOUIS 7,935,612 $54,936 $82,404 $-$-$82,404
DUKE REALTY LIMITED PARTNERSHIP 7,138,789 $49,428 $74,142 $17,314 $89,427 $180,884
BOEING 6,358,580 $44,028 $66,042 $286 $1,479 $67,808
CITY OF ST LOUIS-MSDAIR 5,628,483 $38,970 $58,455 $993 $5,127 $64,575
ANHEUSER BUSCH 5,410,088 $37,458 $56,187 $6,627 $34,226 $97,040
CHAPTER 100 ST LOUIS COUNTY 4,740,939 $32,814 $49,221 $9,898 $51,122 $110,241
ST LOUIS COUNTY WATER COMPANY 4,603,664 $31,878 $47,817 $2,304 $11,902 $62,023
MANHEIM SERVICES CORPORATION 4,287,900 $29,682 $44,523 $949 $4,900 $50,371
SAINT LOUIS UNIVERSITY 4,272,708 $29,574 $44,361 $-$-$44,361
STATE OF MISSOURI 3,853,366 $26,676 $40,014 $-$■-$40,014
MSCI 2007-IQ13 RETAIL 5555 LLC 3,764,971 $26,064 $39,096 $6 $30 $39,131
MONSANTO COMPANY 3,618,253 $25,056 $37,584 $13,853 $71,550 $122,987
WASHINGTON UNIVERSITY 3,339,606 $23,112 $34,668 $-$-$34,668
THF CHESTERFIELD DEVELOPMENT LLC 3,314,810 $22,950 $34,425 $5,794 $29,926 $70,145
SCHNUCK MARKETS INC 3,305,991 $22,896 $34,344 $1,869 $9,654 $45,867
ST LOUIS COUNTY 3,165,233 $21,906 $32,859 $-$R $32,859
LHRET ST LOUIS THE LLC 3,065,041 $21,222 $31,833 $663 $3,426 $35,922
TARGET CORPORATION 2,968,081 $20,556 $30,834 $3,395 $17,534 $51,763
GKN AEROSPACE NORTH AMERICA INC 2,707,515 $18,738 $28,107 $508 $2,624 $31,239
BARNES-JEWIISH HOSPITAL 2,680,666 $18,558 $27,837 $-$-$27,837
HUSSMANN CORPORATION 2,477,228 $17,154 $25,731 $720 $3,721 $30,172
1. The customer is identified as tax exempt.
2. Total for SW Capital Rate Charges (FY22 and After) plus Regulatory Tax and O&M Tax,
Where possible, the District grouped customers by like name. Where customer names were similar but not the same (e.g. City of St. Louis, City of St. Louis
City Hall, and City of St. Louis Water Department) they were grouped together. This process is not perfect, and could result in customers mistakenly being
left out of a group in which they belong or added into a group where no association really exists.
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Exhibit MSD 70A
21. Brian Hoelscher states in his testimony that the District determined that residential
customers “are willing to pay $2/month (or $25/year”) for a stormwater capital improvement
program. See Ex. MSD 3 A, p. 3; 11.19-20. Please explain how the District made this determination.
Provide a copy of the results of any survey or study supporting this conclusion.
RESPONSE: See Exhibit MSD 7 OR for the survey data for our customers from 2021 Q3
and Q4 of calendar year 2021 showing that the acceptable median monthly charge for stormwater
services is $2/month. Note that the results of the last election held for this service, that was set at
this same monthly charge, was voted down 53% - 47%.
22. Please explain why the stormwater impervious surface charge does not qualify as a
“tax” under Missouri law. Please provide a copy of any legal analysis relied upon by the District
to make such conclusion.
RESPONSE: See Susan Myers ’ Direct Testimony, Exhibit MSD 3B, answer #8.
23. Two legal memoranda were provided to the Rate Commission by the District; one
relating to the ad valorem stormwater tax (Ex. MSD 3B1) and another related to applying the
stormwater capital rate to governmental entities and non-profits (Ex. MSD 3B2). Please provide a
copy of any other legal memoranda or analysis relied upon by the District to conclude that the
stormwater impervious surface charge applies to governmental entities and non-profit entities that
are exempt from taxation.
RESPONSE: All public documents have been provided Any other documents are
considered Closed Records under the Missouri Sunshine Law RSMo §610.021(1).
24. Would the presence or availability of third-party funding affect a particular
project’s scoring/prioritization under the stormwater CIRP? Please explain why or why not.
RESPONSE: No. Prioritization is not impacted by local contributions. This provides a
fair and equitable use of all of the taxpayer supplied revenue regardless of the financial/economic
situation of a particular area of the District The proposed local grant program provides a funding
source that can be used in conjunction with funding from local communities who are able to
provide additional local funding for a project
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Exhibit MSD 70A
Respectfully submitted,
Brian Stone
THE METROPOLITAN ST. LOUIS
SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
Tel: (314)768-6366
smyers@stlmsd.com
bstone@stlmsd. com
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Exhibit MSD 70A
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to Lisa O. Stump and Brian J. Malone, Lashly & Baer, on this 17th day of April, 2023.
Lisa O. Stump
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
lostump@lashlybaer.com
Brian J. Malone
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
bmalone@lashlybaer. com
Susan M. Myers /
Brian Stone
THE METROPOLITAN ST. LOUIS
SEWER DISTRICT
2350 Market Street
St. Louis, Missouri 63103
Tel: (314) 768-6366
smyers@stlmsd.com
bstone@stlmsd. com
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