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HomeMy Public PortalAboutExhibit MIEC 76- Application to InterveneBEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT In the Matter of the Metropolitan St. Louis ) Sewer District’s 2023 Wastewater & Stormwater ) Rate Change Proceedings ) APPLICATION TO INTERVENE OUT OF TIME OF THE MISSOURI INDUSTRIAL ENERGY CONSUMERS COMES NOW the Missouri Industrial Energy Consumers (“MIEC”) and pursuant to Section 4 of the Operational Rules, Regulations and Procedures of the Rate Commission of the Metropolitan St. Louis Sewer District files its Application to Intervene Out of Time (“Application”) in these proceedings. In support of its Application, the MIEC states as follows: 1.The MIEC is an association representing large industrial customers of the Metropolitan St. Louis Sewer District (“MSD”). 2.All communications and pleadings in this case should be directed to: Diana Plescia Curtis, Heinz, Garrett & O'Keefe, P.C. 130 S. Bemiston, Suite 200 Clayton, Missouri 63105 (314) 704-8444 (314) 725-8789 (Fax) dplescia@chgolaw.com 3.As an association of MSD’s large industrial customers, the MIEC’s interest is different from that of the general public and will be affected by the Rate Commission’s decision in these proceedings. 4.The MIEC intends to submit written testimony of its expert witness and is in agreement to respond to discovery submitted in connection with this testimony. Exhibit MIEC 76 5. Good cause exists to grant the MIEC’s Application, which was delayed due to the need for client consultation. This case is at an early stage, and no party will be prejudiced if this Application is granted. The MIEC accepts the record as it stands, including the Rate Commission’s procedural schedule, pursuant to the Rate Commission’s decisions in these proceedings. 6. Granting the MIEC’s Application will serve the public interest by enabling the District’s largest customers to be heard by the Rate Commission regarding the issues in these proceedings and will assist the Rate Commission’s record for decision. WHEREFORE, the MIEC respectfully requests that the Rate Commission grant this Application to Intervene Out of Time. Respectfully submitted, Curtis, Heinz, Garrett & O’Keefe, P.C. By: /s/ Diana M. Plescia_____________ Diana M. Plescia #42419 130 S. Bemiston, Suite 200 St. Louis, Missouri 63105 Telephone: (314) 725-8788 Facsimile: (314) 725-8789 E-mail: dplescia@chgolaw.com Attorney for the Missouri Industrial Energy Consumers