HomeMy Public PortalAboutExhibit MSD 80- MSD's First Discovery Request to Rate CommissionExhibit MSD 80
BEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
MSD’S FIRST DISCOVERY REQUEST TO
THE RATE COMMISSION
DATE PREPARED:
ISSUE:2023 STORMWATER & WASTEWATER RATE
CHANGE PROCEEDING
WITNESS:RATE COMMISSION
SPONSORING PARTY:MSD
MAY IS, 2023
Exhibit MSD 80
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
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FIRST DISCOVERY REQUEST OF MSD
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”) requests additional information and
answers from the Rate Commission Consultants regarding their Rebuttal Testimony dated May
12, 2023.
The Rate Commission Consultants are requested to amend or supplement the responses to
this Discovery Request, if they obtain information upon the basis of which (a) they know that a
response was incorrect when made, or (b) they know that the response, though correct when made,
is no longer correct.
The following Discovery Requests are deemed continuing so as to require the Rate
Commission Consultants to serve timely supplemental answers if they obtain further information
pertinent thereto between the time the answers are served and the time of the Prehearing
Conference.
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Exhibit MSD80
DISCOVERY REQUEST
1. Regarding Pam Lemoine’s testimony in Q. 41 page 27, would the phasing in of the
District’s proposed surcharge rate result in additional charges to customers that did not
generate these costs? If so, would this impact the Rate Commission’s objective to
determine if the Rate Change considers the financial impact on all classes of ratepayers in
determining a fair and reasonable burden?
RESPONSE:
2. Regarding Anna White’s testimony in Q. 7 page 5, please provide the analysis of the
inflated costs related to the Consent Decree that was provided to the Rate Commission.
RESPONSE:
3. Regarding Anna White’s testimony in Q. 17 page 9, what is the basis of your statement
that “These operation, maintenance and construction improvement (“OMCI”) property tax
rates are currently set to zero at the request of the OMCI communities?”
RESPONSE:
4. Regaining Anna White’s testimony in Q. 18 page 10, you reference the March 2023
MARIS Housing Report. Please explain why the appraised values reported by St. Louis
City and St. Louis County for tax purposes is not the appropriate data to use for the
purpose of calculating property taxes.
RESPONSE:
5. Regarding Anna White’s testimony in Q. 27 page 14-15, will the inclusion of a reserve
increase stormwater capital rates or reduce the amount of capital projects that could be
constructed?
RESPONSE:
6. Regarding Anna White’s testimony in Q. 30 page 17-18, and considering the information
provided in Black and Veatch’s 2021 Stormwater Survey (specifically survey results 28,
37, 42, and 47), is Anna White recommending the use of parcel lot size charge for
“parcels that do not have any impervious area features but may have surfaces including
compacted dirt, ...”? If so, why?
RESPONSE:
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Exhibit MSD80
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 80
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 15th day of May, 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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