HomeMy Public PortalAboutExhibit RC 44 - Rebuttal Testimony of Nicole YoungBEFORE THE RATE COMMISSION OF THE
METROPOLITAN ST. LOUIS SEWER DISTRICT
REBUTTAL TESTIMONY
ISSUE: STORMWATER RATE CHANGE PROCEEDING
WITNESS: NICOLE YOUNG
SPONSORING PARTY: RATE COMMISSION
DATE PREPARED: MAY 2, 2018
Lashly & Baer, P.C.
714 Locust Street
St. Louis, Missouri 63101
Rebuttal Testimony Nicole A. Young, P.E.
Lion CSG
915 Olive Street
Suite 902
St. Louis, MO 63101
2
Q1. Please state your name and business address.
A. My name is Nicole Young. My local business address is 915 Olive Street, Suite 902, St. Louis,
Missouri 63101.
Q2. By whom are you employed and in what capacity?
A. I am the Managing Principal and a Lead Engineer with Lion CSG LLC.
Q3. Please describe the firm of Lion CSG LLC.
A. Lion CSG LLC (“Lion CSG”) is a civil infrastructure, environmental engineering, and construction
management firm. The majority of Lion CSG’s business is focused on wastewater and stormwater.
Q4. Please describe your educational background and work experience.
A. I received a Bachelor of Science in Civil Engineering from Purdue University, a Masters of Science in
Environmental Engineering from Washington University in St. Louis, and a Masters of Business
Administration from Pennsylvania State University.
I started my career in early 1997 with a company called Dames & Moore, which is now a part of
AECOM. While at Dames & Moore, I performed environmental assessments across the United
States. In late 1998, I moved to Sverdrup to focus on wastewater engineering. Sverdrup was
purchased by Jacobs Engineering in 1999. From 1998 through 2004, I focused on wastewater
and stormwater projects including planning, engineering, and construction management on
projects from conveyance through treatment. I also provided assistance on rate studies
evaluating capitol improvement programs, cost estimation, and the financial analysis for rate
setting. During my tenure at Jacobs, I spent several years working on the Sverdrup, Kwame,
Metcalf & Eddy project known as the SKME project, which was the planning program for the
MSD program that is currently being implemented. Included in the SKME project was an
evaluation and modeling of MSD’s stormwater system. The initial prioritization worksheet was
also developed during this program. In 2004, I took an opportunity with Jacobs Engineering in
Europe with responsibilities in Italy, Germany and England, with secondary responsibilities in
Spain and Portugal. While in Europe, I worked with the United States Department of Defense on
meeting the legal requirements of their Status of Forces agreements with local governments
and providing environmental assistance to the bases. In 2007, I returned to St. Louis to refocus
on providing infrastructure solutions to the St. Louis region working for Camp, Dresser & McKee
(known as “CDM”), now CDM Smith. While at CDM, I provided municipal solutions focusing on
wastewater in Illinois and Missouri, with the exception of Chicago and Kansas City. CDM held
the contract for the initial implementation of the stormwater rate structure, which I became
tangentially involved with towards the end of the project. Lion CSG was started in May 2011;
Rebuttal Testimony Nicole A. Young, P.E.
Lion CSG
915 Olive Street
Suite 902
St. Louis, MO 63101
3
and in 2012, I left CDM to focus full time on Lion CSG. At Lion CSG, I have performed
wastewater and stormwater projects for MSD. I have also worked for private developers on
stormwater issues including the development of BMPs.
Q5. Are you a registered Professional Engineer?
A. Yes, I am a registered Professional Engineer in the state of Missouri and Illinois with inactive
registrations in Indiana and Tennessee. I am registered with the National Council of Examiners
for Engineering and Surveying, known as the NCEES.
Q6. Do you belong to any professional organizations or committees?
A. Yes. I am a board member of the Engineers’ Club of St. Louis. For the Engineering Center of St.
Louis, I serve as the liaison for the Science, Technology, Engineering & Math (or “STEM”)
education and outreach in the St. Louis region including participation in the STL STEM
Ecosystem. I am the newsletter committee person for the Missouri Water Environment
Association, which is the local chapter for Water Environment Federation. For the St. Louis
Economic Development Partnership (known as “STL Partnership”), I serve on the Business
Retention and Expansion Committee, now known as StXL.
Q7. Have you previously testified before the Rate Commission of the St. Louis Metropolitan Sewer
District?
A. No.
Q8. Please describe your role in this proceeding?
A. The scope of my assignment in this proceeding includes the review of the District’s 2018
Stormwater Capital Rate Proposal, to assist the Rate Commission to gain a better understanding
of the District’s proposal, to advise the Rate Commission on the Capitol Improvement and
Replacement Program (or “CIRP”), to assist legal counsel in the examination of witnesses, and to
prepare testimony and exhibits setting forth my findings and recommendations.
I believe it is my responsibility to advise the rate commission on the CIRP, and MSD processes
including the MSD Stormwater Projects Prioritization System. The scope of my assignment is
limited to relying on the record in this proceeding, statements, data, information and reports
provided by the District and intervenors and their respective consultants and advisors as well as
data and information available in the public domain.
Rebuttal Testimony Nicole A. Young, P.E.
Lion CSG
915 Olive Street
Suite 902
St. Louis, MO 63101
4
I also rely on my over 20-years of experience in the wastewater industry working on CIRP
programs, setting prioritization for projects, working with stormwater projects, and developing
rate structures.
Capitol Improvement & Replacement Program
Q9. Has the District taken the appropriate steps in identifying CIRP projects?
A. With an understanding of the engineering planning studies and MSD’s complaint system, I
believe the projects in the program are appropriate. The District allows for flexibility in the
program for new projects or projects with increasing severity.
On Page 6-9 of the Rate Proposal (MSD Ex. 1), MSD states that the CIRP is primarily made up of
projects identified from historical records and previous engineering studies to address customer
complaints about flooding and erosion. In MSD’s Response to First Discovery Request of the
Rate Commission (MSD Ex. 30B) – Question 2, Mr. Unverferth delineates work that has been
done previously: in 1981 the Phase I Stormwater Management Plan was prepared to identify
problem areas for 14 watersheds in the original area of the District; in 1984, the Annexed Area
Stormwater Study was prepared to identify problems areas in the newly annexed area; in 1989,
the District conducted a District-wide study to verify problem areas from the previous studies; in
1995-2000, the Stormwater System Master Improvement Plan was prepared for 23 watersheds
including modeling performed to establish release rates for future development and to identify
problem areas; in 2006-2010, the District conducted an overall review of known problem areas
to verify project viability.
The District also provided copies of several stormwater studies including: Stormwater System
Master Improvement Plan, performed by Horner & Shifrin and CDM in 1995 (Exhibit 37F); and
Wastewater and Stormwater Rate Proposal, performed by CDM and Black &Veatch in 2007
(Exhibit 5). Additional historical studies were available for viewing at the District’s office.
On May 1, 2018, I did view the 53 binders of technical data on each watershed and 3 general
reports on the overall stormwater program. The District made the reports available for viewing
in hard copy form at the their headquarters location, electronic versions were not available. I
reviewed the 3 general reports in detail. I reviewed one of the watershed reports in detail, the
rest of the reports contained similar information for the other watersheds. A substantial
amount of technical work was completed to review each watershed and identify problems,
solutions, costs, benefits, and project priorities.
Rebuttal Testimony Nicole A. Young, P.E.
Lion CSG
915 Olive Street
Suite 902
St. Louis, MO 63101
5
In MSD’s Response to Third Discovery Request of the Rate Commission (MSD Ex. 37A) –
Question 27, it is stated that newly identified projects through customer complaints or as
identified by municipalities will be added to the District’s list of identified stormwater capital
needs; it is also stated that projects increasing in severity will be evaluated and updated. Based
on this the program appears to have sufficient flexibility to address the highest priority projects
in the region as identified by the District through this program.
Q10. Are the District’s cost estimates for projects sufficient for the proposed projects?
A. I believe the District’s cost estimates were completed in accordance with common practice for
this phase of the program. The District has a long history of historical bid prices, which provides
a good basis for cost estimation.
On Page 6-10 of the Rate Proposal (MSD Ex. 1), MSD states that the current project list is based
on minimum amount of detailed information available regarding geotechnical conditions, utility
relocation requirements, easement requirements, and other site-specific issues that have the
potential to significantly affect the project’s eventual construction cost. Mr. Unverferth
testified that the storm sewer cost estimates were based on historical District bid prices using
conceptual design information; channel and green infrastructure improvements estimates were
based on the technical expertise of consulting engineers and past data on similar District
projects; property buyouts estimates are based on St. Louis City or St. Louis County assessed
values plus cost for relocation and demolitions.
Q11. Is the District’s Prioritization System common practice and is it appropriate?
A. It is my opinion that this system is appropriate. The District should consider continuing to model
the solution side of this worksheet as projects are completed to determine if scoring should be
adjusted.
The MSD Stormwater Projects Prioritization System, Revised Benefit Points Allocation Schedule
(MSD Ex. 30K) is unique to the District. This type of scoring system is commonly used in
infrastructure projects to provide quantification to project prioritization. The District has
modeled a number of projects with the algorithm from the scoring, and provided slight
adjustments to ensure the prioritization was appropriate. The Stormwater System Master
Improvement Plan, performed by Horner & Shifrin (H&S) and CDM in 1995 (MSD Ex. 37F)
reviewed the existing scoring sheet which at the time a priority ranking system based on 1-9
scale of threat. H&S and CDM recommended inclusion of project cost and number of people
benefited in the scoring, as well as increasing the scale to allow for greater differentiation. The
Stormwater Facility Planning, prepared by Parsons Water & Infrastructure Inc. (Parsons) in 2010
Rebuttal Testimony Nicole A. Young, P.E.
Lion CSG
915 Olive Street
Suite 902
St. Louis, MO 63101
6
(MSD Ex. 37G) reviewed the prioritization point system used at the time and suggested revisions
to include additional “Solution Points”, and additional modifications were included to increase
the weights of flooding severity.
Q12. Do the District’s proposed incentive and credit program provide sufficient incentive to achieve
a reduction in effective impervious area within the service area?
A. The District’s incentive and credit programs provide some nominal benefit to property owners
to provide BMPs without compromising the CIRP. I believe this is a reasonable approach to
provide some benefit to BMPs while maintaining the integrity of accomplishing the CIRP. As
testified by Pam Lemoine, the District may want to consider other programs, which provide
ongoing incentives for operations and maintenance of the BMPs.
Much of the discussion surrounding the incentive and credit program has been around the
question of the sufficiency of the incentive, however I would focus on the question of
effectiveness in reduction of impervious area. BMPs are beneficial to the overall system if they
are maintained over the long term. However, it is unlikely that BMPs will have a significant
effect in reducing the civil infrastructure investments necessary in the program. While it is
beneficial to install BMPs, MSD needs to collect the funds in order to build the stormwater
infrastructure or undertake buyouts included in the CIRP. Increasing incentives or credits may
increase BMPs, without actually achieving a reduction in effective impervious area where
needed. Additionally, BMPs are expensive to build and maintain. In my experience, the amount
of incentive or credit that would need to be provided to gain interest from residential or
commercial property owners would need to equal the cost to the property owner to inspire
participation that is not regulated, to gain a green certification, or altruistic.
Q13. Does this conclude your testimony?
A. Yes.
CERTIFICATE OF SERVICE
The undersigned certifies that a copy of the foregoing was sent by electronic transmission
to Janice Fenton, Office Associate Senior, Metropolitan St. Louis Sewer District; Susan Myers,
Counsel for the Metropolitan St. Louis Sewer District; and Brandon Neuschafer, Counsel for the
Missouri Industrial Energy Consumers, on this 2nd day of May, 2018.
Ms. Janice Fenton
Office Associate Senior
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
JFENTON@stlmsd.com
Ms. Susan Myers
General Counsel
Metropolitan St. Louis Sewer District
2350 Market Street
St. Louis, MO 63103
smyers@stlmsd.com
Counsel for the Metropolitan St. Louis
Sewer District
Brandon Neuschafer
Bryan Cave Leighton Paisner LLP
One Metropolitan Square, Suite 3600
St. Louis, MO 63102-2750
bwneuschafer@bclplaw.com
Counsel for Intervenor Missouri Industrial
Energy Consumers
/s/ Brian J. Malone
Brian J. Malone