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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 ) ) ) ) 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. 2 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: 3 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 4 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 5