HomeMy Public PortalAboutExhibit MSD 84B - Surrebuttal Testimony Thomas Beckley
MSD Exhibit No. MSD 84B___
2023 Rate Change Proceeding
THOMAS A. BECKLEY
Surrebuttal Testimony
Metropolitan St. Louis Sewer District
June 21, 2023
Table of Contents
Page
Extra Strength Surcharges …………….…………………………………………………………1
Stormwater Charges . .................................................................................................................... 1
Surrebuttal Testimony of Thomas A. Beckley, Raftelis June 21, 2023
2023 Rate Change Proceeding 1 MSD Exhibit No. MSD 84B
Extra Strength Surcharges 1
Q1. In Exhibit RC 78, p. 27, ll. 21-23, Ms. Lemoine proposes ‘phasing-in’ the proposed 2
increases to the extra strength surcharge rates over a period of at least two years 3
instead of in the first year of the rate proposal. What would the impact of such a 4
phase-in be on the District’s customers? 5
A. If the proposed rate increases that are based on the District’s cost of service analysis are 6
phased-in rather than congruent with the timing of the proposed rate changes, other 7
customers not subject to those extra strength surcharges, including residential customers, 8
will bear a greater portion of those costs which will create a subsidy by those customers 9
to the extra strength customers. The impact of the proposed phase-in would be to shift 10
approximately $1.2 million from extra strength surcharges to all customers of which 11
$750,000 would be charged to residential customers. I believe the Rate Proposal’s 12
recommendation to increase those charges in the first year is appropriate to reflect the cost 13
of service analysis. 14
Stormwater Charges 15
Q2. In Exhibit RC 77, p. 19, ll. 20-22, Ms. White states she does not believe the proposed 16
stormwater charges are equitable, do you agree with this assessment. 17
A. No, I do not agree with Ms. White’s assessment. I believe the charges are equitable in that 18
they recover the stormwater capital funding requirement from the residential and non-19
residential classes in proportion to their impervious area (57% residential & 43% non-20
residential), which achieves inter-class equity. As Ms. White acknowledges in her 21
testimony (RC 77, P. 10, ll. 11-18) this proportion of costs between residential and non-22
residential classes is fair and reasonable which supports a finding it also equitably achieves 23
inter-class equity. 24
Surrebuttal Testimony of Thomas A. Beckley, Raftelis June 21, 2023
2023 Rate Change Proceeding 2 MSD Exhibit No. MSD 84B
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Q3. Does this conclude your testimony? 3
A. Yes 4