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
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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.
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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:
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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