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HomeMy Public PortalAboutExhibit RC 81- Fifth Discovery Request to MSD 05182023BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT FIFTH DISCOVERY REQUEST ISSUE: 2023 STORMWATER & WASTEWATER RATE CHANGE PROCEEDING WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT SPONSORING PARTY: RATE COMMISSION DATE PREPARED: MAY 18, 2023 Lashly & Baer, P.C. 714 Locust Street St. Louis, Missouri 63101 Exhibit RC 81 2 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 ) FIFTH 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 Comm ission”), 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. 3 DISCOVERY REQUEST 1. Please provide the “2023 Compliance Charge Tiers.xlsx” file referenced in Ex. MSD 60, tab ‘Demand’, Cell L129. RESPONSE: 2. Please explain how the compliance equivalent differentials were determined. What factors led to a change in the differentials used to determine compliance charges compared to the prior rate study? RESPONSE: 3. Please provide the data source for the median household appraised value of $175,000. See Ex. MSD 74, p. 79, ll. 6-10. RESPONSE: 4. Please provide the geodatabase file containing the following information for each OMCI subdistrict: a. Parcel map and attribute data with impervious surface square footage, parcel square footage, residential status, and other attributes; b. OCMI Tax Districts map and attributes; and c. Municipality map and attributes. RESPONSE: 5. Please provide the data used to calculate the acceptable median monthly charge of $2.00 per month for stormwater services. RESPONSE: 4 Respectfully submitted, /s/ Brian J. Malone Lisa O. Stump Brian J. Malone LASHLY & BAER, P.C. 714 Locust Street St. Louis, Missouri 63101 Tel: (314) 621-2939 Fax: (314) 621-6844 lostump@lashlybaer.com bmalone@lashlybaer.com CERTIFICATE OF SERVICE The undersigned certifies that a copy of the foregoing was sent by electronic transmission to Stephanie DeJarnette, Office Associate Senior, Metropolitan St. Louis Sewer District; Susan Myers, Counsel for the Metropolitan St. Louis Sewer District, on this 18th day of May, 2023. Ms. Stephanie DeJarnette Office Associate Senior Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 sdejarnette@stlmsd.com Ms. Susan Myers General Counsel Metropolitan St. Louis Sewer District 2350 Market Street St. Louis, MO 63103 smyers@stlmsd.com /s/ Brian J. Malone Brian J. Malone