HomeMy Public PortalAboutExhibit MSD 56 - Surrebuttal Testimony of Richard Unverferth, MSDMSD Exhibit No. MSD 56
2018 Stormwater Rate Proceeding
RICHARD L. UNVERFERTH
Surrebuttal Testimony
Metropolitan St. Louis Sewer District
May 25, 2018
Table of Contents
Page
Stormwater Capital Rate ............................................................................................................... 1
Credits and Incentives…………………………………………………………………………...1
Surrebuttal Testimony of Richard L. Unverferth, MSD May 25, 2018
2018 Stormwater Rate Proceeding 1 MSD Exhibit No. MSD 56
Stormwater Capital Rate 1
Q1. Does MSD have an obligation and does the Public have a desire to fund a 2
Stormwater Rate to address drainage, flooding, and erosion within the District? 3
A. Yes, MSD has the power and authority by its Charter to address stormwater and drainage 4
issues throughout the District. MSD’s ratepayers and the general public have a vested 5
interest in MSD addressing these issues. This interest was reflected in public input 6
received by MSD during 2016 public information presentations and information provided 7
in Exhibit MSD 30G – MSD Stormwater Survey Report, as well as the hundreds of calls 8
received annually from MSD customers requesting assistance in dealing with flooding 9
and erosion issues. There is a public expectation that MSD respond to these issues. 10
Additionally, the public will have the opportunity to express their desires through a 11
public vote on this Stormwater Rate. 12
13
Credits and Incentives 14
Q2. Is the purpose of the residential incentive program to provide an incentive to reduce 15
the effective impervious area within the service area by using volume reducing 16
stormwater BMPs? 17
A. Not specifically. There are not regulatory or engineering initiatives to reduce effective 18
impervious area within the service area at this time. Yes, it is an objective to provide 19
customers a way to reduce their stormwater bill while benefiting the community. 20
However, as discussed by Nicole Young, see Exhibit RC 44 – Question 12, and Pamela 21
Lemoine, see Exhibit RC 43 – Questions 22 & 23, reducing the effective impervious area 22
by using volume reducing stormwater BMPs is simply not practical given the current 23
scope of the rate proposal and the solutions necessary to solve the stormwater problems 24
Surrebuttal Testimony of Richard L. Unverferth, MSD May 25, 2018
2018 Stormwater Rate Proceeding 2 MSD Exhibit No. MSD 56
currently being conveyed to MSD by its ratepayers. 1
Q3. If the MSD Rainscaping Small Grants Program met the needs of the wastewater 2
program, why doesn’t it meet the needs of the proposed stormwater program? 3
A. The Rainscaping Small Grants Program does not meet the needs of the proposed 4
stormwater program because the money attributed to a grant program will reduce the 5
money available to do projects. Please remember that the Rainscaping Small Grants 6
Program is a component of a regulatory submittal approved by EPA to comply with a 7
Consent Decree to address combined sewer overflows tributary to the Mississippi River. 8
In the CSO Green Infrastructure Program (CSO GI), a component of the Consent Decree, 9
EPA requires MSD to spend $100 million on green infrastructure to accomplish this task. 10
The justification for the Small Grants Program as part of the CSO GI program was 11
largely based on public education and outreach to support green infrastructure 12
implementation in the community. 13
The proposed stormwater rate is intended to provide capital funding to address 14
flooding and erosion and not any specific regulatory requirement. In addition, as stated 15
in previous testimony and discovery, the District provides public education on the 16
benefits of green infrastructure as part of its stormwater regulatory program. 17
Q4. Does this conclude your surrebuttal testimony? 18
A. Yes. 19