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