HomeMy Public PortalAboutExhibit MSD 57 - Surrebuttal Testimony of Henrietta Locklear, RFCMSD Exhibit No. MSD 57
2018 Stormwater Rate Proceeding
HENRIETTA LOCKLEAR
Surrebuttal Testimony
Metropolitan St. Louis Sewer District
May 25, 2018
Table of Contents
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Determination of imperviousness ................................................................................................. 1
Surrebuttal Testimony of Henrietta Locklear, Raftelis May 25, 2018
2018 Stormwater Rate Proceeding 1 MSD Exhibit No. MSD 57
Determination of Imperviousness 1
Q1. Are you aware of any utilities whose rate structures differentiate among pervious 2
land cover types to determine charges for each property, or for each property of 3
certain types (e.g., all commercial properties) without relying upon average or 4
assumed characteristics of properties? 5
A. Ms. Lemoine provided an example of a utility, Wilmington, DE, where an individualized 6
fee determination of this type is available to customers. This determination is available by 7
application. I am not aware of any utilities that apply such a methodology to a significant 8
portion of their properties. Such an approach would be complex, time-consuming, and 9
more prone to errors because of the greater work to classify areas on properties. Overall 10
it would be more expensive to administer relative to the common approach of classifying 11
area as either pervious or impervious. 12
Q3. Pam Lemoine, in her rebuttal testimony (Exhibit RC 43) discusses that the proposed 13
methodology does not account for surfaces that may cause runoff (e.g., “compacted 14
dirt”) and that properties without impervious area will still have runoff during 15
heavier rain events. Do you think charging properties without impervious area 16
would be fair and appropriate? 17
A. Assessing whether a specific lot had “compacted soil” or some other condition that made 18
it less pervious than other similar vacant lots would be time-consuming and expensive, 19
particularly in comparison with administration of an impervious area rate structure. An 20
impervious area rate structure is equitable, as Ms. Lemoine agrees. She suggests that 21
properties without impervious area could also be assessed a fee, but under an impervious 22
area rate structure, it is fair and appropriate that properties without impervious area are 23
not assessed the fee. Many utilities implement impervious area rate structures and do not 24
Surrebuttal Testimony of Henrietta Locklear, Raftelis May 25, 2018
2018 Stormwater Rate Proceeding 2 MSD Exhibit No. MSD 57
charge vacant land. 1
Q4. Does this conclude your surrebuttal testimony? 2
A. Yes. 3