HomeMy Public PortalAboutExhibit RC 83- Rate Commission's Sixth Discovery Request to MSDBEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
SIXTH DISCOVERY REQUEST
ISSUE: 2023 STORMWATER & WASTEWATER RATE
CHANGE PROCEEDING
WITNESS: METROPOLITAN ST. LOUIS SEWER DISTRICT
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: JUNE 15, 2023
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
Exhibit RC 83
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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 )
SIXTH 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 explain the District’s methodology for identifying stormwater customers as
residential or non-residential.
RESPONSE:
2. Appendix 8.9 of Ex. MSD 1 (Rate Change Proposal) categorizes impervious
surface features as Building Main Structure Footprints, Paved Roads, Driveways, Sidewalks, and
others. Please provide examples of “other” impervious surface features.
RESPONSE:
3. Please state whether the proposed non-residential impervious area rate is based on
the 2020 or 2022 aerial photography.
RESPONSE:
4. Please state whether tax-exempt residential properties will be assessed the proposed
stormwater capital tax.
RESPONSE:
5. Please state whether tax-exempt non-residential properties be assessed the
proposed stormwater capital charge.
RESPONSE:
6. Please provide the total gross area at the parcel level for all non-residential parcels
currently designated as “vacant”.
RESPONSE:
7. Appendix 8.15 of Ex. MSD 1 indicates that the proposed stormwater capital tax
($0.0745 cent) would apply to residential personal property. Does the District currently bill the
Regulatory ($0.02 cent) tax and O&M ($0.1000 cent) tax to personal property as well?
RESPONSE:
8. In Ex. MSD 73I, the cost of the Fluidized Bed Incinerator (“FBI”) project was
estimated to be $477,300,000 in 2018. In Ex. MSD 73K, the estimated cost is listed as
$951,200,000. Please explain the factors contributing to the increase in total project cost. How
certain is the District that the current cost estimate will not increase further?
RESPONSE:
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9. Please state the amount that the District has spent to date on the FBI project?
RESPONSE:
10. Please provide a layman’s summary of all sludge management options evaluated in
Ex. MSD 73G (Tech Memo 3), along with a summary of why each solution was or was not
selected.
RESPONSE:
11. Kansas City’s sludge management solution is Thermal Hydrolysis. Did the District
consider this technology? If so, what factors led the District to not select it? If not, why did the
District not consider it?
RESPONSE:
12. Since the District selected the FBI technology for sludge handling, there have been
developments such as federal incentives for energy recovery, potential regulation of PFAS, etc.,
that would have impacts on a sludge management program. Has the District conducted any recent
review of the selected technology and plan to confirm that the FBI solution remains the best
alternative for the District, given the many technical, financial, and environmental considerations?
RESPONSE:
13. What risk would the District take if it were to move away from the FBI project to a
different solution at this time? How much time would be required to undertake the necessary
studies and design to reach the stage the District is currently at with the FBI project? How much
cost would be incurred in conducting the necessary studies and design to reach such stage?
RESPONSE:
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
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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 15th day of June, 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