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MSD Exhibit No. MSD 3E
2023 Wastewater Rate Change Proceeding
RICHARD L. UNVERFERTH
Direct Testimony
Metropolitan St. Louis Sewer District
March 24, 2023
Table of Contents
Page
Witness Background and Experience ........................................................................................... 1
Wastewater Capital Improvement & Replacement Program (CIRP) ........................................... 2
Future Wastewater Regulatory Requirements .............................................................................. 6
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 1 MSD Exhibit No. MSD 3E
Witness Background & Experience 1
Q1. Please state your name, business address, telephone number, and email address. 2
A. Richard L. Unverferth, 2350 Market, St. Louis, Missouri 63103, (314)768-6204, 3
rlunve@stlmsd.com 4
Q2. What is your occupation? 5
A. I am the Director of Engineering for The Metropolitan St. Louis Sewer District (District or 6
MSD). 7
Q3. How long have you been associated with the District? 8
A. I have been associated with the District for 36 years. 9
Q4. What is your professional experience? 10
A. I have been with the District since January 1987. I held numerous staff-level engineering 11
positions early in my career, I was promoted to Engineering Manager in September 1993, 12
was transferred to the Operations/Maintenance Department from 1995 through 2001 as an 13
Associate Director responsible for the Operations Technical Division, returned to the 14
Engineering Department in 2001 as a Program Manager in the Planning Division, and 15
promoted to Assistant Director of Engineering/ Planning in 2006 overseeing the long range 16
planning of the Consent Decree (CD) and the District Capital Improvement and 17
Replacement Program (CIRP) currently being implemented. I was promoted to my present 18
position of Director of Engineering on May 18, 2013. Prior to joining the District, I held 19
staff-level engineering positions with the City of St. Louis and the City of St. Charles. 20
Q5. What is your educational Background? 21
A. I hold a Bachelor of Science degree in Civil Engineering from the University of Missouri 22
– Rolla (Missouri University of Science and Technology). 23
Q6. Are you a registered Professional Engineer? 24
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 2 MSD Exhibit No. MSD 3E
A. Yes, I am a registered Professional Engineer in the state of Missouri. 1
Wastewater Capital Improvement & Replacement Program (CIRP) 2
Q7. What is the purpose of MSD’s wastewater CIRP? 3
A. The wastewater CIRP provides a listing, schedule, and cost of needed repairs, additions, 4
and improvements to the wastewater system to maintain the system in operating order and 5
to ensure the system operates in a manner that complies with all State and Federal 6
Regulatory requirements and the Consent Decree. 7
Q8. Why is the CIRP needed? 8
A. The CIRP is needed to provide the project identification, planned fiscal year and 9
anticipated annual costs associated with system improvements. This will then provide the 10
basis for required annual revenue and resources needed to plan, design, and construct these 11
improvements. 12
Q9. Does the District have a list of projects that comprises the wastewater CIRP? 13
A. Yes, it has been provided as appendix 8.2.2 in the Wastewater Rate Change Proposal. 14
Q10. What is the size of the wastewater CIRP reflected in the Wastewater Rate Change 15
Proposal? 16
Approximately $1.65 billion in improvements over the four fiscal years 2025 to 2028. 17
Q11. Are all of the wastewater CIRP projects necessary? 18
A. Yes, almost entirely pursuant to the Consent Decree or regulatory requirements. 19
Q12. Do all of the improvement projects shown in the wastewater CIRP need to be 20
constructed in the timeframe shown or could some of the projects be delayed? 21
A. Both the scope and timing of all the projects in the wastewater CIRP are designed to meet 22
system needs, defined regulatory schedules, and schedules required by the Consent Decree. 23
Q13. What are the ramifications of projects being delayed? 24
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 3 MSD Exhibit No. MSD 3E
A. Any delays could result in fines or penalties due to system failure or inability to meet 1
Consent Decree or other regulatory deadlines. These fines or penalties are clearly defined 2
within the Consent Decree and applicable statutes and regulations. 3
Q14. How much of the wastewater CIRP is required to comply with State or Federal 4
requirements? 5
A. The wastewater CIRP is almost entirely composed of projects required to comply with the 6
Consent Decree or other regulatory requirements. There are other asset management 7
related projects and improvement projects planned that are not specifically listed in the 8
Consent Decree or required to meet regulations. These projects typically upgrade and 9
renew wastewater assets or support systems to prevent failure, improve operational 10
efficiencies, or lower risks. Without upgrades and system renewal there is inherent risk of 11
system failure, which could lead to State or Federal regulatory violations. A listing of the 12
non-CD and non-regulatory related projects has been provided as Appendix 8.2.3. The 13
cost of these non-CD projects within the proposed rate cycle is $35 million (of the $1.65 14
billion total). 15
Q15. What are the components of the CIRP? 16
A. Nearly 98% of the CIRP is made up of projects required to meet the Consent Decree or 17
other regulatory requirements. The Consent Decree requires the District to make 18
investments in the wastewater system to ensure it has adequate capacity and is properly 19
maintained (Asset Management); to eliminate sanitary sewer overflows (SSO); to 20
eliminate, reduce, and control combined sewer overflows (CSO); and to reduce the risk of 21
flooding in the combined sewer area (Cityshed). This multi-decade effort is estimated to 22
cost approximately $7.2 billion (in 2023 dollars), with approximately $2.5 billion 23
appropriated from FY13 through the end of FY22. 24
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 4 MSD Exhibit No. MSD 3E
The CIRP will provide for the elimination of SSOs in the separate sewer system, address 1
system capacity issues causing building back-ups in the separate sewer system, and reduce 2
or eliminate CSOs in the District’s combined sewer system. The program also includes 3
Green Infrastructure solutions to reduce stormwater flow to the combined sewer system to 4
reduce overflows to the Mississippi River. Cityshed projects will be built to reduce local 5
structure flooding and building back-ups in the combined sewer area primarily in the City 6
of St. Louis and near North and South St. Louis County. The program also includes Asset 7
Management projects to address infrastructure renewal and upgrades at our Wastewater 8
Treatment Plants, Pump Stations, and Collections systems to provide operational 9
efficiencies and to meet O&M requirements of the Consent Decree. Major treatment plant 10
work includes new fluidized bed incinerators at the Bissell and Lemay treatment plants, 11
and phosphorus removal at all treatment plants. 12
The CIRP is the primary cost driver for the District’s financial plan, representing about 13
two-thirds of anticipated expenditures in the FY25 to FY28 period. The estimated CIRP 14
needs for the next 6 years are presented in Figure 4-3 and Table 4-7. The anticipated CIRP 15
for the next 4-year rate cycle period, FY25 through FY28, is approximately $1.65 billion 16
in 2023 dollars. The largest components of the CIRP over this period will be capital 17
investment related to capacity improvements in the wastewater system, and sewage sludge 18
incineration. The CIRP includes improvements necessary to comply with the Consent 19
Decree, with permit and regulatory requirements outside of the Consent Decree, and asset 20
management renewal projects. A project listing and additional project detail is presented 21
in Section 8 of the Wastewater Rate Change Proposal. 22
Q16. How are costs for the Wastewater CIRP determined? 23
A. For sewer work, cost estimates are based on historical District bid prices using conceptual 24
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 5 MSD Exhibit No. MSD 3E
and preliminary design information. For facility work, estimates are based on the technical 1
expertise of consulting engineers and past data on similar District projects and similar work 2
throughout the region and U.S. These unit prices are updated annually based on bids 3
received. 4
Q17. Does the District have the resources to successfully plan, design, and manage 5
construction of the CIRP presented in the Wastewater Rate Change Proposal? 6
A. Yes. The Engineering Department has developed a program delivery model that utilizes 7
multi-year consulting contracts to assure proper resources are maintained to provide 8
engineering design and construction management services based on various watershed 9
locations, facility types, and engineering disciplines. Program and contract management 10
is being handled by District Design and Construction Management staff. The combined 11
in-house and contracted resources for construction management and construction 12
inspection provides for early project bid document and constructability review to identify 13
potential issues, identify risks, and avert potential change orders prior to bidding and 14
construction. 15
Q18. Has the District been successful in meeting the budget and schedule of prior 16
wastewater CIRPs? 17
A. Yes. The District anticipates successfully completing the FY21-24 CIRP as presented in 18
the previous Wastewater Rate Change Proposal. This is following the successful 19
completion of the four previous CIRP programs and rate cycles. The District has managed 20
the program within budget and on schedule while complying with a number of specific 21
deadlines for early action projects, program implementation, and significant reporting 22
required by the Consent Decree. During this current rate cycle the District has achieved 23
several milestones including the completion of the Maline Creek CSO Control Measures 24
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 6 MSD Exhibit No. MSD 3E
with the Local Storage Facility for Bissell Point Outfalls 051 and 052, the removal of 106 1
Separate Sanitary Sewer overflows required by the SSO Master Plan, and all continuing 2
milestones related to the Capacity Management Operations and Maintenance (CMOM) and 3
Green Infrastructure programs. 4
Q19. What steps have been taken by the District to reduce program costs? 5
A. The District has structured construction contracts for bidding in an efficient manner, 6
bundling together like work in bid package sizes that are efficient to build and manage. 7
The District structures its bid opening schedule to allow adequate time for bidders to 8
develop competitive pricing. On occasion, the District will rebid a project if submitted 9
bids are substantially greater than construction estimates. The District at times phases 10
construction contracts with multiple bid packages when it benefits the District to do so. 11
The multi-year consultant contracts mentioned earlier have led to an efficient and 12
expeditious design process for the program. 13
Q20. Have wastewater related capital improvements been delayed recently due to lack of 14
funding? 15
A. No. 16
Future Wastewater Regulatory Requirements 17
Q21. What additional future wastewater regulatory requirements may be anticipated? 18
A. The Missouri Department of Natural Resources has begun rulemaking to require major 19
wastewater treatment plants to remove Total Phosphorous (TP) to help meet the state’s 20
commitment to address gulf hypoxia. To address this new requirement, MSD will need to 21
invest in capital to remove Total Phosphorus (TP) from its wastewater discharges. Within 22
this rate cycle, new treatment technology is planned at various treatment plants to comply. 23
This new treatment technology will also require ongoing material and maintenance costs 24
Direct Testimony of Richard L. Unverferth, MSD March 24, 2023
2023 Wastewater Rate Proceeding 7 MSD Exhibit No. MSD 3E
in future rate cycles. Although not anticipated within this Rate Cycle, there are several 1
other pending regulatory requirements on the planning horizon. The following regulations 2
would primarily impact our Wastewater Treatment Plants and Processes: New EPA 3
ammonia limits to protect freshwater mussels; requirements for enhanced Nutrient 4
treatment to meet future limits on Total Nitrogen (TN) from our discharges; new limits on 5
certain viruses; and new limits on discharges and emissions of per- and polyfluoroalkyl 6
substances (PFAS). Future regulatory impacts on the Collections system could include a 7
requirement for further CSO controls on the Mississippi River and River Des Peres beyond 8
the current approved Long Term Control Plan to meet instream bacteria, virus, and 9
dissolved oxygen criteria. 10
Q22. Does this conclude your prepared direct testimony in this matter? 11
A. Yes, it does. 12