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Home My Public Portal AboutExhibit MSD 81A- MSD's Response to Rate Commission's Fifth Discovery RequestExhibit MSD81A BEFORE THE RATE COMMISSION OF THE METROPOLITAN ST. LOUIS SEWER DISTRICT MSD’S RESPONSE TO THE FIFTH DISCOVERY REQUEST OF THE RATE COMMISSION SPONSORING PARTY: RATE COMMISSION ISSUE:2023 STORMWATER & WASTEWATER RATE CHANGE PROCEEDING WITNESS:METROPOLITAN ST. LOUIS SEWER DISTRICT DATE PREPARED:MAY 24, 2023 Exhibit MSD81A 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 Commission”), The Metropolitan St. Louis Sewer District (the “District”) hereby responds to the May 18, 2023 Fifth Discovery Request of the Rate Commission for additional information and answers regarding the Rate Change Proposal dated March 24, 2023 (the “Rate Change Proposal”). 2 Exhibit MSD81A 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 Commission”), 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 Exhibit MSD81A DISCOVERY REQUEST 1. Please provide the “2023 Compliance Charge Tiers.xlsx” file referenced in Ex. MSD 60, tab ‘Demand’, Cell L129. RESPONSE: Please see Exhibit MSD 81B 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: Please see Exhibit MSD 81B, row 40 for the calculation of the compliance equivalent differentials. The differentials are determined by taking the projected compliance cost of tiers 2 thru 5 and dividing these amounts by the projected tier 1 compliance cost. For example, the tier 1 compliance cost is projected to be $4 13 compared to the projected tier 2 cost of $60 87 which results in a tier 2 multiplier of 15 ($60.87 divided by $4 13). The projected cost calculations are contained in Exhibit MSD 81B. 3. Please provide the data source for the median household appraised value of $175,000. See Ex. MSD 74, p. 79,11. 6-10. RESPONSE: The District obtained this information from the City and County Assessor’s Office for the tax year 2021 which was the latest available information at the time that the District was preparing its Rate Change Proposal The District then calculated a weighted average median household appraised value of $176,579 as reflected in the table below Tax Rate Needed to Produce $25.00 Annual SW Bill St. Louis City St. Louis County Service Area Median SF Home Assessed Value $96,579.00 $192,200.00 $176,579.27 Tax Assessment -7.451 cent $13.67 $27.21 $25.00 Monthly Amount $1.14 $2.27 $2.08 St. Louis City Single Family Homes St. Louis County Single Family Homes Total 67,677 16.3% 346,602__________83.7% 414,279 100.0% 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; 4 Exhibit MSD81A b. OCMI Tax Districts map and attributes; and c. Municipality map and attributes. RESPONSE: Due to the size of the files related to this request, MSD downloaded the information to a site provided by the Rate Commission’s Rate Consultant These files are collectively referred to as Exhibit MSD 81C For item a, MSD has provided a file geodatabase showing all the parcels in the City and County of St. Louis Those within the MSD Service Area will contain the following attributes. Parcel ID, Parcel Address, Parcel City, Parcel Zip, LUTYPE (Residential, Commercial, etc), Total Impervious Area, Parcel Area (SHAPE AREA) For item b, MSD has provided a file geodatabase showing all the 0MC1 Districts and Subdistricts in the MSD Service Area with the following attributes' District, Subdistrict, Status. For item c , MSD has provided a file geodatabase showing all the Municipalities in the MSD Service Area with the following attributes. Municipality. This file includes areas in St. Louis County that are Unincorporated It does not include the City of St Louis which is a single entity 5. Please provide the data used to calculate the acceptable median monthly charge of $2.00 per month for stormwater services. RESPONSE: See MSD response to the Rate Commission’s 4th Discovery Request, Question 5. Additional information was provided to the Rate Commission prior to the formal start of proceedings that the public voted no, 47-53, on the previous proposed Stormwater Rate Proposal to address flooding and erosion based on a median monthly charge of $2 per month. The policy goal for this proposal is to establish an initial voter approved program that can be expanded in the future if decided so by the voters Respectfully submitted, ■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 Exhibit MSD 81A 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 24th 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.'SSusan 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 6