HomeMy Public PortalAboutLetter forwarding Rate Recommendation Report 09-05-2023THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
September 5, 2023
Board of Trustees of the
Metropolitan St. Louis Sewer District
c/o Mr. Brian L. Hoelscher, Executive Director
2350 Market Street
St. Louis, Missouri 63103
Dear Trustees:
I have been authorized and directed by the Rate Commission of the Metropolitan St. Louis Sewer
District to deliver to you the Rate Recommendation Report regarding the Wastewater and
Stonnwater Rate Change Proposal submitted to the Rate Commission on March 24, 2023.
Accompanying the Report are (a) four minority reports and (b) the Resolution adopted by the
Rate Commission on August 25, 2023.
The Proceedings of the Rate Commission at which the Rate Recommendation Report was
considered were held in accordance with all requirements of law and procedural rules of the Rate
Commission. The transcript of the Proceedings may be found on the website at
https://insdprojectclear.org/about/rate-commission/2023-rate-proposal. The Rate Recommen-
dation Report was approved at a meeting on August 25, 2023, at which a quorum was present
and acted throughout.
I particularly call your attention to the Statement of Rate Commission on the Potential Rate
Impact on Ratepayers found on pages 119-120 of our Report; and the Statement of Rate
Commission on the Ston-nwater Municipal Grant Program found on pages 136-138 of our
Report.
Potential Rate Impact on Ratepayers. The Rate Commission is concerned with the potential
rate impact on ratepayers already facing multiple utility rate increases, and believes that the
District should consider expansion of existing assistance programs. Further, the Rate
Commission recommends that the District take a leading role in the establishment of a task force
on utility ratepayer financial impact issues, including other entities and impacted parties within
the District's service areas, to consider issues relating to utility ratepayer financial impact. Such
issues may include expansion of metering at a reduced cost to assist individuals in older homes —
particularly in St. Louis City, where the number of rooms and bathrooms determines rates, rather
Board of Trustees of the
Metropolitan St. Louis Sewer District
September 5, 2023
Page 2
than usage — to allow individuals to reduce their utility costs; or pursuing the access of funds
from the City of St. Louis and St. Louis County, Missouri from the NFL settlement, as set forth
in the Resolution approved by the Rate Commission, attached to the Rate Commission Report as
Exhibit B.
Stormwater Municipal Grant Program. The Rate Commission supports the District's decision
to allocate thirty percent of the generated stormwater funds to a municipal grant program.
However, members of the Rate Commission recognize that grouping municipalities solely by
population to determine grant eligibility could pose problems, including that doing so:
(i) does not take into account the actual stormwater needs of each community;
(ii) does not consider the cost/benefit of each project;
(iii) could lead to arbitrary classifications and divisions of communities';
(iv) that the smallest municipalities by population may lack the appropriate staff and
infrastructure to adequately assess and plan for their stonnwater needs; and
(v) the size of grants ($30,000) for the smallest municipalities by populations could
be inadequate to address stormwater problems which may extend beyond the
boundaries of a particular municipality.
The Rate Commission recommends that the District modify the proposed grant program to
account for factors other than population, such as:
(i) the amount of impervious area in a community,
(ii) the extent to which a community has done long-term planning for stormwater
needs,
(iii) whether the municipality has engaged in an appropriate cost -benefit analysis;
(iv) whether a community has municipal or third -party funding available; and/or
(v) the degree to which a municipality has considered collaborative or
intergovernmental cooperation to address stonnwater needs.
The Rate Commission suggests that the District also consider equalizing funding availability
over a period of years, such that communities may receive different amounts each year
(depending on their needs), but would receive equal funding over a longer period of time. In
For instance, certain communities, such as Dellwood and Ellisville would miss eligibility
for additional funds through a higher classification by only a few residents. See Ex.
MSD73D, p. 1.
Board of Trustees of the
Metropolitan St. Louis Sewer District
September 5, 2023
Page 3
sum, the Rate Commission recommends that the District seek input from the Municipal League
of Metro St. Louis and other interested parties and develop a municipal grant program that
considers these factors in addition to population.
We appreciate all the time and effort the District staff contributed to the Rate Commission
Proceedings.
Very truly yours
Leonard Toenjes
Enclosures
cc: (w/encs.) Office of the Secretary of the Rate Commission