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Page | 1 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Assessing the SWBNO Water & Sewerage System Improvement Plan: Recommendations for Improving Efficiency, Quality & Sustainability
New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
April 2012
Integrate ♦ Cut Smart ♦ Reorganize ♦ Invest ♦ Grow
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Page | 1 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Water and Sewerage Treatment & Delivery
The City’s fractured water and sewerage systems require the $1.19 billion infrastructure investment
proposed by the Sewerage and Water Board of New Orleans (SWBNO). Furthermore, SWBNO’s
proposed water and sewer rate increases are the only timely and feasible means for generating the
revenue needed to underwrite the $737.3 million in bonds needed to finance these repairs.
SWBNO’s plan is a starting point that reestablishes baseline services and is a first step in creating
longer-term safe, reliable, and sustainable drinking and wastewater systems. Proposed infrastructure
repairs undo years of deferred maintenance, correct lingering hurricane damage, and help meet time-
mandated federal standards for reducing existing wastewater safety hazards. These infrastructure
failures are wasting SWBNO customers and taxpayers hundreds of millions of dollars as costs increase
to power water and sewage through sieve-like pipes and billions of gallons of leaking water undermine
streets and private property. Failure to meet federal deadlines for correcting the city’s wastewater system
will exacerbate this impact to customers with fines that could exceed tens of thousands of dollars per day.
Nonetheless, for SWBNO’s plan to spur more reliable and sustainable service, proposed infrastructure
repairs need to be complemented with more detailed action plans for improving operational efficiency,
staff capacity, and financing longer term, proactive water system infrastructure upgrades. SWBNO’s rate
increase request should be supported by specific proposals for reducing wasted revenue from
inconsistent water auditing, broken meters, inefficient collection practices, and antiquated policies and
operating procedures. Annual savings from correcting these inefficiencies will not close the enormous
infrastructure funding gap that currently plagues SWBNO customers. However, such improvements
should be a minimum return on ratepayers’ considerable added investment. In addition, while SWBNO’s
proposed repairs are needed, they are reactive to deferred problems and available funds. Looking
ahead, SWBNO should articulate a vision for using consistent and transparent planning processes to
finance more proactive, sustainable investments that anticipate evolving service needs that must be met
by the city’s water distribution and sewer collection systems.
Pathway for Achieving a Safe, Reliable, and Affordable Water & Sewerage System
SWBNO Water & Sewerage Improvement Plan
Detail Plans for Improving Rate Structure, Metering, Collections & Water Loss Controls
Outline Processes for Increase Staff Capacity & Expertise Based on Performance Goals
Invest in More Sustainable Delivery & Treatment Infrastructure
Establish Procedures to Expedite Procurement & Coordinate Street/Pipe Financing
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Recommended Reforms to Augment SWBNO’s Proposed
Water & Sewerage Improvements
I. Achieve Ratepayer Fairness & Operational Savings through Phased Rate Structure Changes, Water Loss Audits, Advanced Metering and Collections & Narrower “Free Water” Policies…………..Pages 12-19
Recommended Action Items
Establish timeframe for adjusting water rates to more equitably reflect varied meter and
“readiness to serve” costs among customer classes and incentivize conservation measures.
Invest in water loss control initiatives that include advanced metering, annual water audits,
and a performance goal of replacing at least 10% system meters annually
Improve ratepayer collection practices through improved data analysis, increased staffing
capacity, and utilized legal authority to enforce payment
Narrow the categories of public entities that are eligible for free water and sewer services
and require that all public entities maintain functional water meters and pay marginal
production costs and a share of customer account management expenses
II. Expedite SWBNO Capital Improvements Using Fast-Track Procurement & Coordinated Intergovernmental Infrastructure Investment.……………….Page 20
Recommended Action Items
Establish permanent SWBNO-City DPW Unit to implement roadway and subsurface
distribution improvements using shared procurement and project management processes
Continuously coordinate joint financing and construction planning among City, SWBNO, RPC,
and other relevant entities to ensure concurrent surface and subsurface improvement work
III. Increase Staff Operating Capacity & Expertise………………………Pages 21-22
Recommended Action Items
Identify optimal operational and technical staffing capacity and expertise requirements in each
SWBNO department relative long-term performance goals
Develop a staff succession and training program
Revise civil service rules to increase SWBNO autonomy in filling technical positions
IV. Conduct Comprehensive Investment Planning to Finance Proactive, Sustainable Drinking Water and Sewerage Systems……Pages 23-26
Recommended Action Items
Institute regular comprehensive capital investment planning that emphasizes decentralization,
advanced treatment and sustainable distribution and collection systems
Strategically plan for completing citywide rehabilitation of the water distribution system
Fully develop Bienvenue Central Wetland Unit Assimilation Project by securing increased funding
and formalizing needed partnerships with St. Bernard Parish
Page | 3 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Assessment of SWBNO’s Proposed Capital & Operations Improvements
Drinking Water System
SWBNO’s water system needs include nearly $1.4 billion in improved infrastructure, increased
operations and maintenance (O&M), debt repayments, and other expenses between 2012 and 2020.1
If current rates are maintained, SWBNO estimates it will only have $826.9 million to meet these
expenses.2 As such, SWBNO proposes to generate an additional $384.6 million through rates that
will increase 15% on average annually between 2012 and 2016 and 6.5% on average annually
between 2017 and 2020.3 Ratepayer’s average water bill will be 159% more in 2020 than currently.
Foremost, SWBNO’s proposed investment is aimed at achieving approximately $568.8 million in
infrastructure improvements to the city’s water system.4 These prioritized5 projects are mostly
reactive investments to intake, treatment, and distribution systems plagued by long-standing deferred
maintenance needs or Hurricane Katrina-related damage. More proactive investments include
increasing treatment plant security, implementing advanced “raw” water treatment technology, and,
via FEMA funding and planning, the replacing of existing water distribution pumps with more modern
variable-speed pumps to reduce “water hammer” shockwaves that are deteriorating an already fragile
1 “SWBNO Financial Plan & Rate Study 2011-2020,” pgs.23, 33 (Table 6-1, Lines 19, 22-25), Appendix C: ”Capital Programs
Review Report,” (September 28, 2011) (Hereinafter SWBNO Rate Study) (Actual estimated total is $1,352,102,716). 2 Id at pgs. 23, 33 (Table 6-1, Lines 1, 3-6, 8-9). (Actual estimated total is: $844,595,572).
3 Id at p. 33 (Table 6-1, Line 2).
4 The city’s water system consists of two treatment plants: Carrollton Water Purification Plant, which collects and treats about
140 million gallons per day of Mississippi River water from 7 intake pipes on the east bank; and the Algiers Plant, which collects and treats about 10 million gallons per day of river water from 4 intake pipes on the west bank. Treated water is then pumped through more than 1,590 miles of underground pipe mains to more than 124,725 service connections. 5 Proposed investments were scored and ranked by SWBNO using nine point-weighted criteria: regulatory compliance
(0.17), system replacement/rehabilitation (0.13), system reliability (0.12), operation flexibility (0.12), customer service (0.10), system security (0.10), system benefits/efficiency (0.09), project benefit/impact (0.09), and system growth (0.08).
Anticipated Resources (2012-2020)
$826,995,572
Water System Needs (2012-2020)
$1,352,102,716
$384MM New Revenue (Rate Increase)
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water distribution system. These shockwaves occur when pressure inside distribution pipes suddenly
drops incident to pump or power failures then rises again upon reactivation producing destructive
energy waves within pipe walls, valves, and fittings.
Among all proposed improvements, however, the most pressing and long-term water system need is
to repair the city’s underground distribution pipes. In 2010 alone, through a potent combination of
deferred maintenance, Hurricane Katrina damage, and operational inefficiencies, at least 56% of the
water pumped for use by New Orleans – 29 billion gallons -- leaked or otherwise went unaccounted
for before ever reaching a paying customer’s faucet.6 Put another way, just about 44% of the revenue
to supply water to the city is instead lost to the earth and underwrites degraded water quality,
inefficient energy consumption, and a myriad of potholes.7 SWBNO’s proposed capital improvement
plan directs just over $202 million towards partial replacement of the water distribution system.
SWBNO estimates complete replacement of the system will cost $3.2 billion.8
General Repairs & Modifications to Pumps, Pipes & Equipment $90,995,000
Water Distribution Pipe System Replacements $111,250,000
Modifications to Mississippi River Intake Pumps & Equipment $27,025,000
Upgrade raw water filter system to better remove pathogens, contaminants, and prevent backflow $29,900,000
Improvements to Chemical System $4,150,000
Feeder Main Extensions to Increase Neighborhood Water Pressure $6,000,000
Reimbursement to DPW for Water Main Repairs $32,000,000
Water Plant security Improvements $21,690,000
Advanced Water Treatment (Carrollton) $17,572,000
Advanced Water Treatment (Algiers) $17,750,000
Hurricane Related Repairs $118,160,000
Water System share of power generation $13,669,750
Water System share of general budget items $78,675,476
Power and General Maintenance $92,345,226 16%
Advanced Water Treatment $35,322,000 6%
Replacement / Rehabilitation $202,245,000 36%
Hurricane Recovery Repairs $118,160,000 21%
Other Improvements $120,765,000 41%
Total Proposed Water System Investment $568,837,226
Source: SWBNO Rate Study (2011), Appendix C.
To finance these improvements, SWBNO seeks to pair $261.6 million from the Federal Emergency
Management Agency (FEMA)9 with $381.1 million in new revenue bonds that would be collateralized
by increased rates and other local sources, including state revenue sharing, fees, interest, and other
income.10 SWBNO’s proposed revenue increase is intended to cover the multiple years of inflation-
adjusted debt service on these issued bonds,11 the cost of issuance, and the goals of maintaining at
least $32 million in annual “pay-as-you-go” funding for construction and a debt service reserve fund
6 SWBNO Rate Study, Appendix A: “Water Audit FY 2008-2010,” p.A-7, A-26.
7 Id.
8 Sewerage and Water Board of New Orleans: Report on Current and Future Capital Needs (December 2006)
9 Id at p.23.
10 Id at p.31-33 (Table 6-1, Lines 3-6,8). Bond terms are 20 years, 6.00% interest. Debt service will be $79.5MM(2012-2020).
11 Id at p.31. SWBNO assumes an annual 3.0% capital escalation rate between 2012 and 2020.
Page | 5 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
that is at least 1.5 times greater than the amount needed to service the bonds.12 These latter two
aims would greatly improve SWBNO’s current water system financial liquidity and debt service
coverage ratios, which are ranked last by considerable margins among comparable utilities,
nationwide, and a bond rating that is ranked second to last.13 Those are all factors that the bond
market considers in deciding whether to finance SWBNO improvements.
SWBNO also seeks sufficient revenue “to restore staffing levels, training activities, and preventative
maintenance programs that were eliminated following Hurricane Katrina.”14 SWBNO estimates that
new infrastructure and operational changes will add an additional $80.5 million to O&M water system
costs for a total of over $704.6 million between 2012 and 2020.15 This estimate reflects over $14
million in savings from unspecified reforms that SWBNO asserts will result in “improved efficiency
associated with capital improvements and reduced water loss.”16 However, SWBNO does not detail
specific staffing levels or operational changes in support of its O&M cost estimates.17 Instead, the
proposed O&M increase is in part intended to close a sizeable gap between existing funding levels
and what comparable utilities ranked in the top quartile of operational efficiency invest in O&M.18
Among the greatest challenges for SWBNO in closing this O&M funding gap is doing so with at least
25,000 less rate-paying customers than before Hurricane Katrina.19 In large part, SWBNO is relying
heavily on FEMA for O&M contributions totaling over $39 million through 2015.20 The remainder of
increasing O&M costs would need to be met through rate-based revenue and other funding sources.21
Finally, SWBNO’s proposed water rate increase will help finance $35.1 million in outstanding revenue
bonds,22 approximately $25 million in subordinate obligations to the federal government,23 $7 million
to the City of New Orleans Department of Public Works (DPW), and $11.7 million to other entities.24
12
Id at pgs.31-32. (Debt service coverage is the ratio of net operating income [Operating Revenues less Operating
Expenses] divided by debt service requirements.). 13
Id at 48-50. SWBNO’s water system liquidity ratio (ratio of assets in-hand to liabilities) is 0.51. The recommended
minimum is 1.0. SWBNO’s debt service ratio is -3.11, which is 4 times lower than the next ranked comparable utility. SWBNO’s Drinking Water System bond credit rating is BAA2(Moody’s), which is considered sub-par investor grade. Benchmark utilities against which SWBNO‘s liquidity and debt service ratios are compared, respectively, are: Central Arkansas Water (1.92/2.78), Louisville Water Company (1.07/3.6), Greater Cincinnati Water Works (1.65/1.37), Birmingham Water Works Board (1.34/1.22), Des Moines Metropolitan (1.53/1.2), and City of St. Louis Water Division (1.28/1.75). 14
Id at p.2. 15
Id at p.17, 33 (Table 6-1, Line 11-13). 16
Id at p.2. 17
Id. (While staffing goals are not provided, SWBNO states: “the General Superintendent incurs over two-thirds of the water system O&M expenses; almost 15% of expenses are incurred by…Management Services…; and the remaining expenses are distributed roughly equally across the Divisions of the Executive Director, Support Services, and Payroll Related.”). 18
Id at pgs.17-18, 30-31. 19
Id at p.49. 20
Id at p.33 (Table 6-1, Line 9). 21
Id at pgs.17-18, 31. 22
Id at p.33 (Table 6.1, Line 15). 23
Id (Table 6.1, Line 19). 24
Id (Table 6-1, Line 22-25).
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Sewerage System
SWBNO’s estimated sewer system needs include approximately $1.4 billion in improved
infrastructure, increased O&M costs, debt repayments, and other expenses between 2012 and
2020.25 Assuming current sewer rates and expected FEMA contributions, SWBNO estimates it will
only have approximately $806 million to meet these expenses.26 As such, SWBNO proposes to
generate an additional $453.3 million through a flat rate change that increases 14% on average
annually between 2012 and 2016 and increases 5% on average annually between 2017 and 2020.27
As such, a ratepayer’s average water bill will be 159% more in 2020 than current rates.
SWBNO’s proposed sewerage infrastructure investment is aimed at achieving approximately $595.8
million in prioritized infrastructure improvements to the city’s water system.28 Among these projects,
listed below, the most pressing are time-mandated improvements to wastewater treatment and
collection pursuant to a 2010 modified federal court consent decree with the U.S. Environmental
Protection Agency (EPA) (41% of total investment). Failure to timely meet construction timelines and
wastewater safety standards imposed in the consent decree could result in millions of dollars in fines
passed through to SWBNO ratepayers.29 The remainder of SWBNO’s proposed investment will target
deferred maintenance to the city’s network of sewer pipes and treatment capacity (28%); repairs of
damage related to Hurricane Katrina (17%); and upgrades to SWBNO power generation systems and
general maintenance (14%). Two projects specifically highlighted by SWBNO in its rate study to
illustrate the need for the proposed sewerage improvement plan receive small percentages of the
25
Id at 23, 37 (Table 6-3, Lines 13-15, 19, 22, 26-27) , Appendix C (Actual estimated total is $1,397,620,767). 26
Id at 35, 37 (Table 6-3, Lines 1-2, 4-11, 28). (Actual estimated total is: $779,814,141). 27
Id at p,35, 37 (Table 6-3, Line 2). 28
See Note 5. The city’s sewerage system consists of the East and West Bank Sewage Treatment Plants, which can treat up to 239 and 50 million gallons per day of wastewater, respectively, which is collected through a system of 83 pump and lift stations that utilize 1,350 miles of gravity lines and 100 miles of pressurized force mains. 29
U.S. V. Sewerage and Water Board of New Orleans, No. 93-cv-3212 (E.D. La 2010). Stipulations 61-85 detail potential fines and other penalties if SWBNO does not meet mandated timelines and standards. Available at: http://www.swbno.org/documents/Consent%20Decree/2010ConsentDecree.pdf.
Anticipated Resources (2012-2020)
$806,114,141
Sewerage System Needs (2012-2020)
$1,397,620,767
$453.3MM New Revenue (Rate Increase)
Page | 7 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
overall investment: an East Bank Sewage Treatment Plant levee ($2.7 million, 0.4%); and routing
treated wastewater to help rebuild wetlands near Bayou Bienvenue along Orleans and St. Bernard
Parish ($10 million, 0.6%).30
Rehabilitation of damaged and aging citywide “gravity” mains $67,100,000
Extension and replacement of damaged and aging sewer mains in Algiers $22,875,000
Normal Extensions and system replacements at East and West Bank Treatment Plants $58,674,000
Expansion of West Bank Treatment Plant $19,029,000
Capacity Analysis of East Bank Treatment Plant $10,000
Extension and replacement of pump stations as required by federal Consent Decree $28,656,578
Reimbursement to DPW for repairs to wastewater mains as required by federal Consent Decree $35,300,000
Wetland Assimilation Project $10,000,000
Extension and replacement of pressurized mains as required by federal Consent Decree $13,500,000
Extension and replacement of gravity mains as required by federal Consent Decree $159,400,637
Hurricane Related Repairs to Sewer System $100,660,000
Sewer System share of power generation $10,781,250
Sewer System share of general budget items $69,715,476
Engineering Inspections $135,000
Power and General Maintenance $80,631,726 14%
Sewer Consent Decree Related Improvements $247,857,215 41%
System Replacement and Rehabilitation $167,688,000 28%
Hurricane Recovery Repairs $100,660,000 17%
Total Proposed Sewerage System Investment $595,836,941
Source: SWBNO, October, 2011.
SWBNO estimates that its share of the cost for proposed infrastructure improvements will be
approximately $432.1 million when adjusted for inflation through 2020.31 FEMA and other federal
sources are expected to contribute an estimated $219.1 million.32 To finance its share, SWBNO
proposes to use current revenues from rates and other sources paired with the issuance of $356.2
million in revenue bonds that would be collateralized by increased rate-based revenue.33 As with
SWBNO’s water system investment, proposed sewer-related revenue increases are intended to cover
the multiple years of inflation-adjusted debt service on these issued bonds, the cost of issuance, and
the goals of maintaining at least $18.5 million in annual “pay-as-you-go” funding and a debt service
reserve fund at least 1.5 times greater than the amount needed to service the bonds.34 This latter aim
would greatly improve SWBNO’s current wastewater system debt service coverage ratio and bond
credit rating, which are ranked last by a considerable margin among comparable utilities,
nationwide.35
30
See, SWBNO Rate Study, p.9. 31
Id at p.35. SWBNO assumes an annual 3.0% capital escalation rate between 2012 and 2020. 32
Id. 33
Id at p.36-37 (Table 6-3, Lines 4-9, 28). Bonds will be issued for a term of 20 years at an interest rate of 6.00%. Debt service on these issued bonds will total $79,534,522 between 2012 and 2020. 34
Id at p.36-37 (Table 6-3, Line 25). 35
Id at 48-50. SWBNO’s wastewater system debt service ratio is 0.48, which is two times lower than the next ranked
comparable utility. SWBNO’s Wastewater bond credit rating is BAA1(Moody’s), which is considered a sub-par investor grade rating. Benchmark utilities against which SWBNO‘s wastewater system debt service ratios is compared are:
Page | 8
In addition to financing new infrastructure, SWBNO also seeks additional revenue to expand
operations and meet anticipated increases in O&M costs related to sewerage system investments.
According to SWBNO, required sewer system upgrades add $135.2 million in related O&M costs for a
total of over $590.2 million between 2012 and 2020.36 This figure reflects an estimated $10 million in
savings during that time through unspecified operational reforms.37 As with the water system O&M,
FEMA heavily subsidizes sewerage systems operations through 2015, contributing approximately
$23.9 million 38 Rate-based and other revenue will supply the remainder and will be the sole source of
O&M funding after FEMA’s offerings dissipate.
According to SWBNO, at current levels it is “spending less than the most efficient quartile of utilities in
terms of O&M expenses on a per-million gallons basis of sewerage treated.”39 However, as with its
explanation for increasing water system O&M, SWBNO does not offer specific staffing levels or
operational changes to support proposed increases.40 Instead, SWBNO’s estimates a $145.2 million
O&M cost increase based on the “goal of aligning the O&M expenditures for the sewerage system to
the most efficient quartile benchmarking, meaning that the Board would be spending more than 25%
of comparable utilities on a cost per million gallons basis.”41
Finally, SWBNO’s proposed water rate increase will finance $171.9 million in currently outstanding
water system revenue bonds42 as well as approximately $25 million in subordinate obligations to the
federal government for hurricane recovery related loans.43 Lastly, SWBNO owes other parties over
$14.5 million from the water system budget, including approximately $9.7 million to the City-DPW.44
Proposed Rate Structure
SWBNO intends to apply its rate increase uniformly among all types of customers. SWBNO’s
rationale for this is because system leakages to be repaired from added rate-based revenue are
neither attributed nor beneficial to certain customer classes versus others.
Similarly, SWBNO intends to maintain its current rate structure format. This includes a Water Service
Charge that differs based on meter size and is intended to cover billing, meter maintenance, and
being able to meeting customer capacity (“readiness to service”).45 In addition, SWBNO employs an
“increasing block/decreasing block” water volume rate structure that charges a monthly rate per
Little Rock Wastewater (1.06), Louisville and Jefferson County (1.03), Metropolitan Sewer, District of Greater Cincinnati (1.36), Jefferson County Environmental Services Department (1.01), Des Moines Metropolitan Wastewater Reclamation Authority (1.05), The Metropolitan St. Louis Sewer District Metro Water Services (1.48), and Baton Rouge City-Parish Department of Public Works (1.74). 36
Id at p.17, 33 (Table 6-3, Line 11-13). 37
Id at p. 37 (table 6-3, Line 15). 38
Id (Table 6-3, Line 10-11). 39
Id at p.19. 40
Id. While specific staffing goals are not provided, SWBNO details that the General Superintendent incurs almost 40% of sewerage system O&M expenses; over a quarter of the expenses are incurred by the Treatment Division; over 20% of the expenses are incurred by the Management Services Division; and the remaining expenses are distributed roughly equally across the Divisions of the Executive Director, Support Services, and Payroll Related. 41
Id at p.19, 37 (table 6-3, Line 14). 42
Id (Table 6-3, Line 18). 43
Id (Table 6-3, Line 22). 44
Id (Table 6-3, Line 26-27). 45
Id at pgs.27-28. SWBNO’s water service charges range from $4.05 per month for its smallest (5/8”) meters to $333.00 for its largest (16”) meters.
Page | 9 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
thousand gallons of water used that is $2.69 for 0-3,000 gallons); $4.60 for 3,001-20,000 gallons;
$3.62 for 20,001-1,000,000 gallons; and $3.04 above 1 million gallons used in a month.46 SWBNO
does not presently intend to differentiate water rates based on residential or commercial customer
sizes nor are there stated plans for conservation credits that could be applied to water rates.
For sewerage service, SWBNO intends to maintain a monthly service charge that varies by meter size
and a uniform volume-based charge of $4.04 per thousand gallons.47 In contrast to its water rate
structure, SWBNO does employ a “sewerage return factor” that allows customers to reduce its
sewerage rates by demonstrating that not all metered water is discharges to the sewerage system. In
addition, SWBNO charges a surcharge for certain commercial customers that discharge sewerage
with higher levels of organic material and/or other solids.48
46
Id at p,28. 47
Id at pgs.28-29. SWBNO’s sewerage service charges range from $11.60 per month for its smallest (5/8”) meters to $1,550
for its largest (16”) meters. 48
Id at 29.
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Rationale for Increasing Rates to Achieve SWBNO’s Proposed Water & Sewerage Capital and Operations Improvements
The New Orleans Citizen Sewer, Water & Drainage System Reform Task Force believes that
SWBNO’s proposed drinking and wastewater system investments are a timely and important starting
point towards achieving redundant capacity that can meet the city’s peak demands, reliably,
sustainably, and cost-effectively. Given the enormous cost of these investments relative to available
funds, the Task Force further recommends increasing rates to finance SWBNO’s improvement plan.
SWBNO’s proposed infrastructure improvements address remaining hurricane damage and decades
of deferred maintenance that hamstring the growth of New Orleans into a modern, more sustainable
city. At present, ratepayers are financing a system that pours billions of gallons of drinking water –
nearly three-fourths of what is pumped from the river – into the earth before reaching their homes and
a wastewater system that for a generation has been playing catch-up to meet minimum federal
safeguards for public health and environmental quality. SWBNO’s proposed investments help
staunch further degradation of these systems and establish a foundation for more sustainable,
proactive water system investments that both SWBNO and City-DPW should begin framing through
comprehensive water management planning and investment strategies (See, New Orleans Citizen
Sewer, Water & Drainage System Reform Task Force: Assessing the Sewerage & Water Board of
New Orleans: Recommendations for Enhancing Governance, Management & Strategic Planning).
SWBNO’s requested rate increases to help finance these infrastructure investments, while
substantial, are, nonetheless, on scale with the improvements being sought and necessary to
collateralize the $730.1 million in bond financing that is the lifeblood for these infrastructure upgrades.
SWBNO’s effort to secure that amount of bond financing is already hampered by a skittish bond
market and SWBNO’s below-par bond rating. Failure to enter the bond market with the collateral that
would come from proposed rate increases will likely be an insurmountable hurdle.
Furthermore, the timeliness of these improvements and related rate increases is important in staving
off even greater costs to New Orleans citizens. The city’s ever-worsening water distribution system is
requiring increasingly expensive power generation to maintain pressure, while leaking water
undermines street improvements even before completion. Equally pressing, several crucial
wastewater system corrections in New Orleans East and the Lower Ninth Ward need to begin in 2012
pursuant to federal consent decree or risk massive penalties if decree deadlines are not met. Missing
such deadlines further hinders SWBNO’s bond rating when trying to finance similar projects, citywide.
The Task Force supports SWBNO’s request for additional rate-based revenue to finance expanded
O&M. Given New Orleans’ unique challenge of having to overpower gravity to move drinking and
wastewater through a sieve-like and ancient distribution system, it is unfathomable that SWBNO
spends less on O&M than the most efficient 25% of utilities of similar size. Moreover, SWBNO’s
continued substantial reliance on FEMA for operational funding – budgeted through the tenth
anniversary of Hurricane Katrina – is not the hallmark of a thriving, self-sufficient municipal entity.
SWBNO, rightly, prides itself in treating and distributing water with limited disruptions despite existing
infrastructure and funding handicaps. However, such ingenuity and commitment will only go so far in
an increasingly unsustainable system. SWBNO’s most persistent shortcomings in customer service,
Page | 11 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
system repairs, collections, etc., stem from chronic and deep understaffing, antiquated technology,
and operational inefficiencies.49 Unchecked, these maladies will increasingly overpower SWBNO’s
noble efforts to reliably provide New Orleans with safe and affordable water services.
Finally, the Task Force concurs with SWBNO that the massive cost for needed infrastructure repairs
cannot be covered solely by annual savings from improved collections, narrowing or eliminating free
services to other public entities, and reducing unaccounted for water loss. While improvements
relative to these latter issues and other systemic inefficiencies must be addressed, immediately
known operational savings only total approximately $24 million between 2012 and 2020. That amount
is just 2% of SWBNO’s water and sewer system infrastructure plan just to reestablish baseline service
levels (See above figure).
.
49
See, Sewerage & Water Board of New Orleans 2011-20220 Strategic Plan (Adopted September 21, 2011). Available online at: http://www.swbno.org/documents/reports/StrategicPlan2011.pdf) (Acknowledged “weaknesses” include, among
others: again workforce, difficulty in hiring experienced technical employees, information technology systems which have exceeded their design life, insufficient documentation of work processes, and collection practices.).
Sewerage System
Drinking Water System
$10,030,382
$14,028,628
$617,806,628
$508,207,044
SWBNO Estimated Operational Savings Relative to Total 2012-2020 Additional Revenue Need
2012-2020 Savings from Improved Operations & Reducing "Free Water"
Total Additional 2012-2020 Revenue Needed Above Current Rates
(2.7 % of Total Revenue Needed)
(1.6 % of Total Revenue Needed)
Page | 12 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Recommended Additional Water & Sewerage System Reforms
While SWBNO’s proposed improvements are needed, the Task Force is greatly concerned that the
full benefit and return on ratepayers sacrifice will not be realized without SWBNO also presenting
more specific and measurable performance goals, action steps, and timelines to improve rate
fairness, minimize water loss, modernize metering and revenue collection, expand staff capacity and
expertise, and institute proactive, comprehensive infrastructure and operations investment planning
processes. As such, the Task Force recommends that the following operational improvements ne
achieved concurrent with SWBNO’s proposed improvement plan, beginning with SWBNO presenting
a framework of goals and proposed action-steps to achieve these additional reforms.
Establish Timeframe for Adjusting Water Rates to Equitably Reflect Varied Meter and
“Readiness to Serve” Costs Among Customer Classes and Incentivize Conservation
SWBNO should devise a more specific timeline and process for modifying its rate structure to
accurately reflect usage demand, rate impact disparity, and conservation practices impact among its
residential and commercial customer classes. The Task Force concurs with SWBNO that, at present,
the potential gain in rate equity by further differentiating water service and volume-based rates is
outweighed by the benefit shared equally among all customer classes from system leak repairs
financed by increased rates.50 However, SWBNO should outline a timeline and/or a leakage repair
threshold upon which it adjusts its rate structure to better address disparities among residential and
commercial rates. This mirrors recommendations in SWBNO’s rate study which states:
As the system leakage is reduced and reaches an equilibrium, RFC recommends that the Board evaluate whether a modification in the rate structure is then warranted. The Board might also consider having a separate rate schedule for residential and non-residential customer classes. This modification would allow the Board to move away from an IB/DB rate structure, which can be confusing to the ratepayers.51
50
Id at p.27. 51
Id at p.28.
Goal: Achieve Ratepayer Fairness & Operational Savings through Phased Rate Structure Changes, Water Loss Audits, Advanced Metering, Improved Collections, and Narrower “Free Water” Policies
Recommended Action Items
Establish timeframe for adjusting water rates to more equitably reflect varied meter and
“readiness to serve” costs among customer classes and incentivize conservation.
Invest in water loss control initiatives that include advanced metering, annual water audits,
and a performance goal of replacing at least 10% of system meters annually
Improve ratepayer collection practices through improved data analysis, increased staffing
capacity, and utilized legal authority to enforce payment
Narrow the categories of public entities that are eligible for free water and sewer services
and require that all public entities install functional water meters and pay marginal
production costs and a share of customer account management expenses
Page | 13 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Looking ahead, SWBNO should link rate adjustments among customer classes to leak index
measurements made through an annual water system audit, discussed in the following section.
Revisiting rate structures when “leakage is reduced and reaches an equilibrium” does not provide
customers with sufficient certainty as to when the issue will be addressed nor any reliable means for
measuring return on their investment. By SWBNO’s own acknowledgement, reducing system
leakages to within national utility averages is not likely within the next ten years.52 Given this, a
timeline is recommended for restructuring rate structure that reflects obtainable and measurable
progress in leak reduction that occurs within the timeframe of SWBNO’s improvement plan.
In revising its rate structure, the Task Force recommends the following adjustments be considered:
Simplify water service charges by identifying total monthly charge revenue requirements and divide
by the meter equivalents based on meter flow. This calculation more accurately reflects SWBNO’s
“readiness to serve” costs, while increasing service charge equity among customer classes,
particularly smaller commercial customers
Adjust service and volume-based charges to more accurately mirror consumption and rate impact
among residential, small commercial, and large commercial customers. Possible recommended
strategies include adding additional volume-based rate blocks between existing rate blocks of
3,001-20,000 gallons; 20,001-1,000,000 gallons; and above 1 million gallons.
Incentivize water conservation by enabling broader rate credits beyond the existing “sewerage
return factor” to reward a wider array of conservation practices among customers, including use of
low-consumption appliances.
Similar to the sewerage system surcharge used in certain instances, require separate metering or
an additional surcharge for water consumption above a threshold amount for landscaping and other
property exterior purposes.
Invest in Water Loss Control Initiatives that Include Advanced Metering, Annual Water
Audits, and a Performance Goal of Replacing at Least 10% of System Meters Annually:
At several points, SWBNO’s Rate Study alludes to the need reduce lost and free water as well as
improve revenue collections through improved metering. While this is an encouraging
acknowledgement, SWBNO’s massive rate increase request should more appropriately be paired with
specific action plans for how it intends to achieve these aims and its budgeted costs savings. In that
framework, the Task Force recommends the following specific action items.
Advanced Metering Investment
SWBNO’s meters are its cash register and for ratepayers they should be a reliable and fair gauge of
services delivered for the asking price. SWBNO is working towards this aim but bolstered investment
in expediting the modernization of its meters and increasing related staff capacity is recommended.
52
Id at Appendix A: “Water Audit FY 2008-2010”, p.A-11.
Page | 14
SWBNO estimates that it utilizes 116,146 meters for billed and unbilled water in its service area,
including over 99.2 thousand residential meters and 15.5 thousand large meters among multifamily,
commercial, and industrial users.53 SWBNO uses these meters to charge for water volume used
within a range of $2.69 to $4.60 per 1,000 gallons, and for wastewater volume, a set charge of $4.04
per 1,000 gallons.54 In addition, SWBNO collects monthly service charges that currently range from
$4.05 to $333.00 for water and $11.60 and $1,550.00 for wastewater services based on the size of
the meter.55 In all, over $115 million in current annual revenue – and the fairness and effectiveness of
proposed rate increases – hinges on the functionality of SWBNO meters and the timeliness and
accuracy with which they are read.56
At present, SWBNO is plagued by thousands of non-working or otherwise defective meters and
critical staff and resource shortages that prevent adequate meter reading and repairs. The dominant
meter model in use is a circa 1956 “Sensus SR” manual-read model fitted with solid brass that
SWBNO cites as having a 20-year lifespan. According to a recent SWBNO water audit, in 2010
alone, metering defects and inaccuracies resulted in over 450 million gallons of consumed water
being unmetered for a loss of over $2.3 million in net revenue.57 This lost revenue is particularly
problematic among SWBNO’s aging large meters, which can lose up to 3% of accuracy per year after
10 years of operation.58 Given limited operating funds, SWBNO does not presently have a large-
meter replacement program.59 When its smaller “Sensus SR” models become defective, SWBNO
fixes them internally, however, that effort is hamstrung by meter repair staffing levels staff levels that
are nearly 40% below optimal levels.60
Compounding this, thousands of bills are merely estimated, often for several months consecutively,
due to staff deficiencies among SWBNO’s meter-reader corps. Optimally, a system comprised of
such meters requires 18-21 personnel each reading 300 meters per day –performance benchmarks
that are not being met by SWBNO.61
SWBNO acknowledges in its Rate Study that a “[c]hange-out of existing manual-read meters with
electronic meters and installation of an automated meter reading system would allow all meters to be
read electronically.”62 As such, SWBNO’s improvement plan includes the “purchase of new meters”63
Also, SWBNO is beginning to retrofit its manual SR models with electronic encoders that will allow the
meters to be read remotely. Related to this, SWBNO’s improvement plan calls for investment in
“mobile automatic meter readers installation,” which would allow for remote meter reading “by driving
through city in a van equipped with an antenna and laptop computer.”64 Ultimately, SWBNO envisions
53
SWBNO Rate Study, Appendix B: “O&M Review Report,” p.B-2 (Table 2.1). 54
Id at p.28-29. 55
Id. 56
Id at p.33 (Table 6-1, Line 1); and p,37 (Table 6-3, Line 1). 57
Id at Appendix A: “Water Audit FY 2008-2010,” p.A-24. 58
Id at Appendix B, B-3. 59
Id. 60
Id at B-13. Optimal meter repair staffing should be 13 personnel. SWBNO currently employs 8 persons. 61
Id. 62
Id at p.9. 63
Id at Appendix C:”Capital Programs Review Report,” p.C-W-13. 64
Id at p.C-W-19.
Page | 15 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
using a network of fixed towers by 2017 in lieu of drivers to remotely read meters.65 Whether by driver
or tower, multiple thousands of meters per day can be read by remote electronic readings.66
While these investments are encouraging, the Task Force recommends that SWBNO also develop an
action plan for increasing staff capacity to increase meter replacement and readings. Equally
important, the Task Force recommends that SWBNO dedicate more resources to purchasing new
meters than retrofitting its older SR models with electronic encoders. Interviews with several water
meter experts suggest that SR models may be discontinued in the near future making it difficult or
impossible to secure encoders for that model.
Based on the above, the Task Force recommends the following specific action-items for SWBNO to
incorporate in a more detailed strategy for meter system improvements that includes budgeting,
timelines, and performance metrics for improving its metering system:
“Big Meters for Big Bucks.” The Task Force recommends that meter inspection and replacement
prioritize larger meters, of which there are fewer but generate considerable revenue. In this, the
Task Force echoes a recent consultant O&M assessment, which recommends data logging large
meters to verify the accuracy of these meters based on industry-accepted accuracy standards.67
Achieve a performance goal of replacing 10% of SWBNO’s entire meter system each year and
develop an operational plan that allows SWBNO to achieve the goal of inspecting all meters every
7 years per current industry best-practices.68
Replace existing meters with next-generation electronic meters mobile or fixed network meter
reading systems The Task Force recommends that SWBNO provide more detail as to the number
of meters to be replaced within set time periods and invest in related towers sooner than 2017.
Increase meter system staffing levels and develop a related succession and training program to
expedite staff readiness to utilize a new meter system, while increasing overall reading accuracy
and repairs to existing meters in the interim.
Install electronic meters on all public assets to better assess the amount of unbilled water provided
to local governmental entities.
Coordinate with the New Orleans Redevelopment Authority and the City’s Office of Code
Enforcement to assess the status of meters present on vacant lots and structures.
Articulate a specific plan, timeline, and performance metrics for reducing data transfer errors
between meters and billing system and improving transparency of meter-billing process.
65
Id. 66
See, http://www.sensus.com/documents/10157/31008/WP-
100_Licensed%20vs%20Unlicensed%20Spectrum_Sensus_2010.pdf. 67
Id at B-2. 68
See, American Water Works Association, M6 Standards.
Page | 16
Annual Water Audits
The Task Force strongly recommends that SWBNO conduct annual water audits as part of standard
business practice. Ratepayer fairness and efficiency demand that SWBNO regularly track apparent
and real water losses and the annual cost impacts of these losses to ratepayers, SWBNO
functionality, and the city’s overall economic health.69 Moreover, an annual audit is the most effective
means for SWBNO to gauge the success of planned improvements in stemming wasteful water loss.
The Task Force is encouraged that SWBNO commissioned an independent 2008-2010 Water Audit in
preparing its proposed improvement plan.70 While the results of this audit are sobering, the process
conducted nonetheless positions SWBNO to continue evaluating and correcting non-revenue water
losses that are diminishing SWBNO effectiveness.
The starting point from which successive annual water audits must track progress is startling. The
most recent audit in 2010 revealed the following:71
42,524 gallons of water leaked daily day along every mile of water pipe (1,590 mi of pipe in system)
71.3% of water pumped for use is never billed due to leaks, public use, or theft
47.2% inefficiency in the use of water as a resource
44.5% of the annual cost associated with processing drinking water is not reimbursed
8.82% of water pumped for use is “apparent loss” due to broken meters, billing errors, and theft
3.02% of the annual cost associated with processing drinking water (at least $11MM) is “free water”
Similarly, industry-standard performance indicators based on these audit measurements also
strikingly reveal how dire SWBNO’s water system is relative to comparable utilities and the gap to be
traversed to reach more sustainable service delivery. First, SWBNO’s Infrastructure Leakage Index
(ILI), an international performance indicator that measures the ratio of “real losses” in a water
distribution system with a theoretical “Unavoidable Annual Real Loss” value, is 36.7.72 According to
the American Water Works Association, an ILI score of 8.0 or above is “not an effective use of water
as a resource.”73 Indeed, SWBNO’s third-party water audit concludes “ILI performance (score) greatly
exceeds any other large water utility in the United States currently performing water auditing.”74
Second, SWBNO’s amount of non-revenue water (NRW),75 as a percent of volume (71.3%) and cost
(44.5%) are also “extremely high for municipal water utilities.”76 SWBNO’s audit attributes this “in part
to the significant amount of free water that is contributed by SWBNO for public purposes.” By
69
Apparent Losses are “paper” losses of water that are attributed to billing errors, defective meters, ineffective collection processes, and unauthorized use of water such as theft. Real Losses are annual volumes of water lost through leaks, bursts
and overflows on pumps, mains, and service connections, up tothe point of customer metering. 70
See, generally, SWBNO Rate Study, Appendix A: “Water Audit FY 2008-2010” Freeman, LLC prepared the analysis
according to American Water Works Association Water Loss Control standards. 71
Id at A-6. 72
Id. 73
Id at A-10. 74
Id at A-7. 75
Non-revenue water enters the distribution system but does not result in revenue gained because of real and apparent losses as well as unbilled authorized consumption (free water), which includes water for firefighting, flushing of mains and sewers, public hydrants, street cleaning, watering of municipal gardens, public fountains, and in the instance of New Orleans, the provision of free drinking water to local governmental entities, including public schools. 76
SWBNO Rate Study at Appendix A, p.A-8.
Page | 17 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
comparison, the Philadelphia Water Department, a utility comparable to SWBNO in age, size,
demographics and infrastructure, averaged 34.2% NRW by volume between 2000 and 2008.77
SWBNO’s Rate Study recommends that it “annually monitor and manage water loss based on the
approach outlined as part of the audit.” 78 The Task Force agrees and recommends that, concurrent
with seeking its rate increase approval, SWBNO provide a more detailed action plan for conducting
these annual water audits. In so doing, the Task Force recommends the following action-items to
address in a water audit strategy plan that includes budgeting, timelines, and performance metrics:
Develop a water loss reduction and audit plan that includes a robust leak detection system and a
performance goal of achieving an annual 4-point reduction in SWBNO’s ILI to achieve an ILI score
of 16.7 by 2015 and a score below 4.0 by 2020.
Establish an interdisciplinary Water Audit Unit consisting of in-house staff from distribution
operations, treatment plant operations, billing and customer service, finance, information
technology and engineering to conduct the annual audit.
Prepare and present the Water Audit Report to the Board and New Orleans City Council alongside
SWBNO’s annual Financial Audit and a recommended annual Infrastructure Investment Plan.
Include within the annual Water Audit, recommendations for policy, operational, and infrastructure
changes and investments based on factors contributing to lower than optimal ILI and NRW scores.
Develop procedures and performance metrics to more accurately measure unbilled and unmetered
water loss due to public uses, collections inefficiencies, and unauthorized consumption or theft.
Improve Ratepayer Collection Practices through Improved Data Analysis, Increased
Staffing Capacity & Utilized Legal Authority to Enforce Payment:
In addition to reducing meter inefficiencies and water loss, SWBNO’s ratepayer-strategy for financing
infrastructure improvements turns on SWBNO’s ability to collect what is owed them. Apparent water
losses due to inadequate collection processes needlessly burden compliant ratepayers, while
depriving SWBNO of much-needed revenue. Despite this, SWBNO offers no details as to how it
might improve its collection process as part of its water system improvement plan. As such,
concurrent its rate increase request, the Task Force recommends that SWBNO present a detailed
action plan for improving and monitoring its collections processes, including the following action-items:
Develop methodologies for measuring revenue loss due to billing and administrative errors,
procedures for improving transparency and reliability, and metrics to gauge progress.
Install restricted water service devices in non-paying customer meters to restrict water flow to an
amount sufficient for basic needs (cooking, drinking water, toilet flushing) but precludes larger
volume use until payment is rendered. The Task Force recommends that SWBNO research similar
initiatives conducted in Atlanta, Las Vegas, San Francisco, and New Jersey.
77
Id. 78
Id at p.7.
Page | 18
Narrow the Categories of Public Entities that are Eligible for Free Water and Sewer
Services and Require that All Public Entities Install Functional Water Meters & Pay
Marginal Production Costs and a Share of Customer Account Management Expenses:
The Task Force strongly recommends that SWBNO’s governing legislation be revised to eliminate or
significantly narrow the amount of free water and sewer services to local government institutions and
the types of government institutions that receive free or discounted services.
SWBNO estimates that it provided just over $5.5 million in water and sewer services to public entities
beyond itself in 2010.79 While that portion of SWBNO’s “non-revenue water” generation is miniscule
compared to overall revenue needs, this policy of providing free water and sewer services without any
return compensation, hampers SWBNO’s financial liquidity, shifts added burden to ratepayers, and
disincentivizes water conservation and accountability among local public entities. This practice is all
the more egregious given that few, if any, utilities, nationwide, provide free water and SWBNO ranks
among the bottom in national comparisons of water utility financial strength and non-revenue water
waste. In short, “free water” is a luxury that SWBNO and its ratepayers cannot afford.
Pursuant to La R.S. 33:4096 and 33:4121, SWBNO’s “free water and sewer” policy includes:
Audubon Park, City Park, and the New Orleans Museum of Art are only charged for annual
consumption in excess of their respective 1981 usage.
The City of New Orleans and its public institutions from which no revenue is derived shall be
exempt from service charges and rates based on usage.80
Schools and non-school facility belonging to the Orleans Parish School are exempt from charges
for all water service charges and rates for water consumed that do not exceed four gallons per day,
per enrolled student, in a calendar year.
As structured above, this policy relies on inefficient estimates of the amount of free water provided,
utilizes 30-year old usage caps that are out of synch with current day water conversation and
operation needs, and lacks reliable assurances as to accurate, functioning meters among those
entities benefitting from this generous policy. Specifically, it is speculative that SWBNO ratepayers
only sacrifice $5.5 million in annual free water to local government given that SWBNO’s free service is
based solely on billing receipts. Many public building meters and distribution pipes still need to be
repaired or replaced since Hurricane Katrina, making it difficult to more accurately track what services
are provided and enforce any established volume caps. Moreover, using fixed and dated
consumption caps ignores current-day water conservation techniques and changing usage demands
that should reduce or eliminate such revenue caps
For its part, SWBNO has informally committed to reducing the amount of free water and sewer
services provided to local governmental entities.81 The Task Force concurs. Reforming this policy
79
See, “Water Contributed During 2010 for Public Purposes.” SWBNO. (2010). (Hereinafter “Water Audit”). 80
Emphasis added. 81
See, Krupa, Michelle. “Doubling water rates debated as S&WB gives away millions of gallons for free.” Times-Picayune [New Orleans] February 16, 2012. Available at: http://www.nola.com/politics/index.ssf/2012/02/doubling_water_rates_debated_a.html.
Page | 19 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
should be an important facet of SWBNO reducing wasteful non-revenue water and strengthening its
overall financial stability. As such, the Task Force recommends that, concurrent with seeking
approval for rate increases, SWBNO present a detailed action plan for revising applicable law and
operating policies to narrow or otherwise eliminate its free water policy. The Task Force recommends
the following action-items to be included:
Eliminate “free water” to all local public institutions. If some discount in lieu of full service charges
and rates is maintained, then require at that all entities pay a minimum amount for production
costs, meter installation, and customer account management expenses, with such fees being
adjustable annually relative to inflation and other relevant indices. Relative to usage by the City of
New Orleans, a “services in lieu of payment” arrangement should also be considered given the
amount of services for reimbursement that SWBNO and City-DPW perform for each other.
Eliminate revenue caps based on consumption amounts. If such caps are to be maintained, then
structure them so that the cap is established based on an adjustable annual index that considers
actual consumption and related SWBNO costs.
Transparently enforce any maintained discounted water policy caps to ensure that any public entity
that generates its own revenue is not eligible for discounted water service.
Install and regularly verify meters are functioning and being accurately read on all public buildings.
Conduct routine leak detections within water and sewerage pipes in all public buildings.
To the extent a discounted water policy is maintained, clarify in applicable statutes whether and to
what extent the policy applies to all public schools, including those under the jurisdiction of the
State’ Recovery School District and other charter-based systems.
Page | 20
Establish Permanent SWBNO-City DPW Unit to Implement Roadway and Subsurface
Distribution Improvements Using Shared Procurement & Project Management
Processes:
The Task Force recommends that SWBNO and City-DPW permanently establish a joint
intergovernmental unit that is empowered with a single set of procurement and project management
authorities and processes to coordinate construction of all roadway and subsurface improvements.
SWBNO’s proposed improvement plan includes approximately $600 million in subsurface
improvements to the city’s drinking and wastewater distribution systems. Combined with
approximately $208 million in City-DPW street improvements planned in 2012, alone,82 this collective
investment in the city’s surface and subsurface infrastructure is a massive and time-critical
undertaking that warrants establishing fast-track protocols that marry SWBNO and City-DPW
procurement, project management, and construction processes.
At present, SWBNO, City-DPW, and FEMA conduct monthly sessions to coordinate timing and
phasing for FEMA-funded surface and subsurface projects only. These consultations are a marked
improvement from a prior lack of routine coordination between SWBNO and City-DPW. However,
while these sessions provide important opportunities to prioritize investment areas and streamline
some construction activities, actual implementation remains hamstrung by the omission of protocols
that would unify and streamline procurement, design, site prep, and complete project execution.
Given this, the Task Force recommends that SWBNO and the Mayor execute a joint agreement that
transforms the existing FEMA-project coordination effort into a permanent surface-subsurface repair
intergovernmental unit with stand-alone procurement and project management authorities, timelines,
and processes to enable large-scale, expedited implementation.
Annually Coordinate Joint Financing and Construction Planning Among City, SWBNO,
RPC, and Other Entities to Ensure Concurrent Surface and Subsurface Improvements:
The Task Force recommends that City, RPC, and SWBNO establish cooperative endeavor
agreements or other effective instruments to formalize transparent and consistent procedures for
annually aligning funding resources, bond issuances, construction timelines, and related
administrative and procurement processes to better coordinate proposed water and sewerage system
repairs with the Administration’s overlapping Capital Improvement Plan, RPC’s Transportation
Improvement Program, and other public infrastructure initiatives.
82
See, 2012 Annual Operating Budget, City of New Orleans (October 2011), p.70.
Goal: Expedite SWBNO Capital Improvements Using Fast-Track
Procurement & Coordinated Intergovernmental Infrastructure Investment
Recommended Action Items
Establish permanent SWBNO-City DPW Unit to implement roadway and subsurface
distribution improvements using shared procurement and project management processes
Annually coordinate joint financing and construction planning among City, SWBNO, RPC, and
other relevant entities to ensure concurrent surface and subsurface improvement work
I.
Page | 21 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Large-scale staffing losses in the aftermath of Hurricane Katrina paired with large numbers of
anticipated retirements is diminishing SWBNO’s ability to be a self-performing entity. Increasingly,
SWBNO is a management entity that oversees system designs made by third-party contractors and
stretches in-house operations and maintenance among increasingly sparse crews.
SWBNO’s improvement plan and more ambitious water management systems it must next achieve
require increasing its ranks of proficient staff and passing along SWBNO’s proud institutional
knowledge to those individuals. The Task Force recommends the following action items to assist in
that endeavor:
Identify Optimal Operational and Technical Staffing Levels and Expertise
Requirements in Each SWBNO Department:
The Task Force recommends that SWBNO reinforce its requested rate increase with more details for
how it proposes to increase operational capacity and bolster staff expertise with increased revenue.
While the Task Force concurs that O&M spending should increase – and that rate increases are the
most sustainable means for achieving this – SWBNO and its customers would benefit from an outline
of the organizational structure, skill-sets, and personnel levels that are needed to improve operations.
SWBNO’s Rate Study estimates that at least 66 staff positions remain open among O&M-related
departments compared to pre-Hurricane Katrina levels.83 However, details as to a strategy for filling
those positions or how departments might be restructured are lacking. At a minimum, the Task Force
recommends that SWBNO present an Operational Strategic Plan that includes the following:
Organization Structural Assessment: Outline of how O&M departments should interrelate with each
other as well as management, and the Board. Recommended emphasis should be on bolstering
staff expertise in lieu of overreliance on consultants. Further, training emphasis should be placed
staff dual-expertise in water and sewerage systems to consolidate staffing needs.
Operations Review: Articulate current operational shortcomings, including offline or damaged
systems, personnel inefficiencies, technology shortfalls, and limited collection/enforcement
capabilities; and recommend resources and processes to address these shortcomings.
83
See, generally, SWBNO Rate Study, Appendix B: “O&M Review Report.”
Goal: Increase Operational and Technical Staff Capacity & Expertise
Recommended Action Items
Identify optimal operational and technical staffing levels and expertise requirements in each
SWBNO department relative long-term performance goals
Develop staff succession and training program
Revise civil service hiring rules to better meet SWBNO technical staffing needs
Page | 22
Service Levels Assessment: Assess current and desired levels of system efficiency and survey-
based customer service and address how intended operational reforms address those aims.
Timelines for O&M Investments: Outline proposed sequencing for operational improvements and
staff improvements relative to forecasted O&M investment.
Sustainability Practices: Evaluate and specify specific cost savings and efficiency goals based on
proposed O&M investment increases and performance metrics to gauge success.
Develop Staff Succession Program & Revise Civil Service Rules for Increase SWBNO
Autonomy in Defining and Filling Technical Positions:
Staff Succession & Training
The Task Force strongly also recommends that SWBNO reinforce its request for increased rates with
a strategic plan for staff succession and training relative to increasing O&M investment. As with the
recommended Operations Strategic Plan, SWBNO and its rate payers would benefit from an outline of
how SWBNO intends to address anticipated large-scale retirements among its existing O&M staff and,
more generally, assure that personnel are properly trained to facilitate planned system improvements.
SWBNO’s Rate Study estimates that over 33% of current O&M personnel have 20 years or more
service time with SWBNO, including critical management and supervisory positions.84 As such, the
Study concludes that “the development of a succession plan is an urgent need.”85 However, no
details are provided as to a strategy for developing such a plan. At a minimum, the Task Force
recommends that SWBNO outline a plan for succession and training that includes the following:
Department Needs Assessment: Identify specific updated skill-sets needed in each department and
functions currently handled by personnel with more than 20 years of SWBNO service.
Training Content Needs Assessment: Identify content and material resource needs, select staff
liaisons, and structure ongoing training programs relative to specific departmental operation goals.
Implementation Timelines: Outline sequencing for training relative to forecasted O&M investment.
Revise Civil Service Hiring Rules to Better Meet SWBNO Technical Staffing Needs
The Task Force recommends that SWBNO be afforded greater autonomy in hiring technical and
engineering positions. Current rules, which uniformly define technical positions across all local
governmental entities, ignore highly specialized skill-sets that SWBNO needs to conduct operations
and contribute to SWBNO’s diminished in-house expertise, innovation, and operational flexibility. As
such, SWBNO should granted greater flexibility to define the scope and compensation of specialized
positions that are needed to accomplish its mission.
84
See, generally, SWBNO Rate Study, Appendix B: “O&M Review Report.” 85
Id at B-3.
Page | 23 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Institute Comprehensive Capital Investment Planning Emphasizing Decentralization,
Advanced Treatment & Sustainable Distribution and Collection Systems:
The Task Force recommends that SWBNO complement planned infrastructure improvements with a
regularly conducted infrastructure planning processes to achieve more proactive infrastructure
investment. SWBNO’s proposed improvements are a necessity but more a function of deferred
maintenance and available federal monies, than the outcome of goal-oriented process for achieving a
sustainable and integrated New Orleans water system.
SWBNO’s proposed infrastructure improvements and the criteria used to prioritize those projects
provide a suitable foundation upon which it should commence inclusive annual planning that sets forth
projects based on anticipated service needs, community growth and input, and opportunities for
increased integration and sustainability. At a minimum, the Task Force recommends that SWBNO
develop a comprehensive sustainable infrastructure planning process that accomplishes the following:
Invest in System Improvements that Reflect Anticipated Service Area Conditions & Community
Growth Patterns: Design distribution and collection systems based on land use, population,
hydrologic, and water consumption changes within the service area over a defined period
Integrate Water System Design with Regional Transportation and Stormwater Management Aims:
Conduct formal inter-parish planning and investment strategies to develop systems that are more
fully integrated with regional transportation, public space, and stormwater protection initiatives.
Maximize Sustainable Infrastructure Investment Opportunities: Define SWNBO’s long-term
sustainability aims and establish performance metrics for gauging success in achieving those aims.
Investments should increase local watershed quality, meet or exceed federal requirements for
water treatment, minimize energy consumption, decrease treatment residuals, decentralize
treatment processes, and facilitate effluent reuse options.
Strategically Plan for Completing Citywide Restoration of Water Distribution System:
The Task Force recommends that SWBNO develop a long-term Distribution System Asset
Management Plan to establish a reasonable time frame and transparent prioritization process for
complete restoration of the city’s water distribution system. SWBNO’s proposed $202 million in
Goal: Conduct Comprehensive Investment Planning to Finance Proactive
& Sustainable Drinking Water and Sewerage Systems
Recommended Action Items
Institute regularly scheduled comprehensive capital investment planning that emphasizes decentralized, advanced treatment and sustainable distribution and collection systems
Strategically plan for completing citywide restoration of the water distribution system
Fully develop Bienvenue Central Wetland Unit Assimilation Project by securing increased
funding and formalizing needed partnerships with St. Bernard Parish
Page | 24
improvements is an effective initial investment. However, complete restoration will cost approximately
another $3 billion and require years to complete. Restoration of this system is the only direct means
of stemming the billions of gallons of water that are leaking before ever being used and related
millions in O&M costs needed in attempts to stabilize a fractured system.
A 2003 study by the consulting firm MWH, recommended that SWBNO commence a 27-year plan to
repair the distribution system.86 Hurricane related pipe corrosion and breakages greatly exacerbated
the system’s failure such that city functionality might not be able to afford that lengthy timeframe. As
such, a comprehensive replacement program should be developed to address the following:
Develop non-intrusive tools and metrics for identifying leakage areas, including a acoustic leak
detection system and financial and consumption modeling within geographical areas.
Develop a prioritization system for component repairs based on surrounding community need and
hydraulic, structural, and water quality assessments as the probability and consequences of failure,
Assess repair options that maximize sustainability, benefit for cost, and minimize public disruption.
Estimate the amount of years needed to complete system restoration, total funding needed, and to
the extent feasible, classify areas of the city in terms of the probability and consequences of failure,
Coordinate funding streams and repairs with other local governmental entities and projects that
overlay or otherwise impact completing repairs.
Establish transparent means for citizens, businesses, and objective professional organizations to
provide input and track overall program progress.
Fully Develop Bienvenue Central Wetland Unit Assimilation Project by Securing
Increased Funding and Formalizing Needed Partnerships with St. Bernard Parish:
SWBNO’s Central Wetland Unit Assimilation Pilot Project presents SWBNO and its customers with an
innovative lower-cost means for meeting increasingly stringent and expensive wastewater regulations,
while restoring Bayou Bienvenue wetlands – a 30,000 acre natural defense that is critically important
to protecting New Orleans and St. Bernard Parish from storm surge. With a pilot phase and related
feasibility study near completion, fuller implementation of this important opportunity will require
effective collaboration between SWBNO, the City, St. Bernard Parish, and their state and federal
partners to secure needed funds and property rights, and implement the project in a timely manner.
Looking ahead, SWBNO and its customers will pay increasingly more to treat wastewater in
compliance with existing federal environmental regulations and more stringent controls that are being
developed. Notwithstanding lower-cost options, this will require expanding existing tertiary treatment
methods and additional expensive filtration methods. For example, SWBNO must now comply with
Federal Clean Water Act rules that limit the amount of nutrients that can be released into the
86
Sewerage and Water Board of New Orleans: Report on Current and Future Capital Needs (December 2006), p.22.
Page | 25 New Orleans Citizen Sewer, Water & Drainage System Reform Task Force
Mississippi River watershed to within a “total maximum daily load” that the State must establish for
that watershed and other impaired waterways pursuant to Section 303(d) of the Clean Water Act.87
Several wetland assimilation projects have already been completed in Louisiana as alternate means
for recycling treated wastewater, including in Thibodaux, Breaux Bridge, Amelia, St. Martinville,
Mandeville, Luling, and Hammond. The Central Wetland Unit Assimilation Project would allow
SWBNO to similarly meet increasingly stringent federal rules by releasing nutrients from secondarily
treated wastewater into the Bayou Bienvenue wetlands in lieu of the Mississippi River.
Utilizing an active management system that continuously tracks nutrient flow, this project would allow
SWBNO to reduce costly tertiary treatment with a more efficient, natural alternative that adds soil
building materials into the wetlands and ultimately reestablish productive wetlands and cypress forest.
The project is also estimated to create over 680 direct and indirect jobs and broader economic and
recreational value for the region88
At present, SWBNO is investing $10 million in state grant funds to conduct this assimilation on a 20-
acre portion of the Bayou and is near completion of its feasibility study, which suggest that fuller
implementation of the project is possible.89 For its part, St. Bernard Parish is implementing a similar
project to assimilate wastewater into the Poydras-Verret Wetlands, which comprise the Central
Wetlands Unit, along with Bayou Bienvenue. As required by state regulations, the next step for
SWBNO is to conduct a baseline study that analyzes current vegetation, sedimentation, and water
quality characteristics within the Central Wetlands Unit.
Concurrent with this study, however, it is recommended SWBNO and the City partner with St. Bernard
and applicable state and federal agencies perform the following action items to ensure timely and
cost-effective project implementation:
Secure property rights to the land comprising Bayou Bienvenue: Bayou Bienvenue is comprised of
numerous privately owned tracts harkening back to a not too distant past when the area was dry
and contemplated for residential development. Now completely submerged under an average of
12 feet of water, a cohesive property rights strategy is needed by which SWBNO and its
governmental partners can access and develop the Bayou into a thriving wetland.
Full-scale wetland assimilation will require a range of rights during the course of project
development, beginning with limited entry during planning and design, longer term occupancy
during construction, and a permanent right to occupy once the project is completed, allowing both
for the introduction of effluent and ancillary public uses of reclaimed wetlands.90
87
33 U.S.C. §1313 (Water Pollution Control Act); 40 CFR §130.7. 88
See, http://blogs.edf.org/restorationandresilience/2010/05/03/profiles-in-restoration-the-central-wetlands-unit-part-vi/ 89
For an outline of issues that must be studied in a feasibility study pursuant to state regulations before a full wetland assimilation project is approved by the Louisiana Department of Environmental Quality, please see: http://www.deq.louisiana.gov/portal/DIVISIONS/WaterPermits/WetlandAssimilationProjects.aspx 90
Davis, Mark. Bayou Bienvenue Restoration: “A Summary of Property Rights Issues and Options.” Tulane Institute on
Water Resources Law and Policy (December 1, 2009).
Page | 26
The Task Force recommends that SWBNO and the City commence a property right/acquisition
strategy in partnership with the State and U.S. Army Corps of Engineers through which appropriate
possessory and nonpossessory property rights are secured in a timely and affordable manner such
that implementation of the assimilation project is not needlessly delayed. At a minimum, the
following strategies should be considered separate or in conjunction with each other:
Claim state ownership to all areas that are now submerged and tidally influenced
Exercise eminent domain over all privately owned tracts using either state or federal authority
Buy-out of privately owned tracts by public entities
Secure long term dedication or lease of privately owned tracts by public entities for defined uses
Secure Long-Term Funding for Complete Implementation: SWBNO, the City and their state and
federal governmental partners should begin coordinating efforts to secure long-term funding
beyond SWBNO’s current $10 million in the pilot phase of the Central Wetland Unit Assimilation
Project. Beyond that amount, SWBNO’s proposed improvement plan does not include any
additional investment in the project nor detail a process for securing additional funds.
The Task Force specifically recommends that a long-term financing strategy be developed that
includes SWBNO funding paired with state and federal coastal restoration funding, including an
apportionment from any federal Clean Water Act penalties related to the Deep Water Horizon oil
spill that are directed to Louisiana.
Establish Public-Private Working Group to Commence Project Design and Implementation: Upon
the completion of its feasibility study, SWBNO and the City should immediately establish a public-
private working group to finalize design and implementation strategies for the Central Wetland Unit
Assimilation Project. At a minimum, this group should identify a suitable scale of wetland
restoration based on the amount of nutrients that can be safely released and the amount of
additional fill and land needed. In addition, a long-term tracking system is needed whereby wetland
restoration progress is measured. Finally, long-term strategies for economic, community, and
recreational uses should be developed in conjunction with reestablishing the area as a wetland and
cypress forest.
♦♦♦
SWBNO Water & Sewerage System Solutions
CHECKLIST FOR CHANGE
Recommended Reform Lead Entity Partner Entities
Applicable Policies Applicable
Funding
Recommended Next Steps
Develop
Comprehensive
Planning &
Investment Process
to Ensure Proactive
and Sustainable
Water and
Sewerage Systems
Institute comprehensive capital
investment planning that emphasizes
decentralized assets, advanced
treatment and sustainable distribution
and collection systems
SWBNO
Board Bylaws, SWBNO Strategic Capital, Operational & Financial Plans
Bonds, water & sewer rates
Within Next Year: (1) Revise Board Bylaws to establish a Strategic Planning Committee; (2) adopt a transparent, customer-inclusive framework for researching and prioritizing short-, mid-, and long-term infrastructure investments; (3) outline an organizational and funding structure for a permanent Strategic Policy and Planning Department.
Strategically plan for completing
citywide rehabilitation of the water
distribution system
SWBNO City, City Council, and RPC
Same as above.
Bonds, water & sewer rates, disaster-recovery funding, other funding sources
Within Next Year: (1) Identify and map outstanding major leakages within distribution system; (2) prioritize components of the system for repair based on the probability and consequences of failure); (3) assess estimated costs, available funding sources, and a realistic timeline for completing system rehabilitation; and (4) institute joint planning protocols with City and RPC for long-term coordination of funding and street and subsurface project procurement and construction.
Fully develop Bienvenue Central
Wetland Unit Assimilation Project by
securing increased funding and
formalizing needed partnerships with
St. Bernard Parish
SWBNO City, St. Bernard Parish
SWBNO Strategic Capital, Operational & Financial Plans; Coastal Master Plan; Regional Integrated Stormwater Management
SWBNO bonds, water & sewer rates, other funding sources
Within Next Year: (1) Commence baseline study and finalize nutrient load based on regulations and SWBNO treatment needs; (2) establish intergovernmental working groups to secure long-term property rights and funding streams; and (3) develop an implementation timeline and public-private working group to coordinate project development with other community aims.
Achieve Greater
Operational Savings
through Advance
Metering, Improved
Collection Practices
and Narrower “Free
Water” Policies
Establish timeframe for adjusting water
rates to more equitably reflect varying
meter and “readiness to serve” costs
among customer classes and
incentivize conservation measures.
SWBNO City Council water & sewer rates
Concurrent with Rate Increase
Request: Present a proposed
threshold/ timeframe based on
regular system leak audits upon
which rate structure could be
modified
Within Next Two Years: (1)
Research options for modifying
rate structures to reflect
disparate consumption and rate
impact between small and large-
scale residential and commercial
customers; (2) conduct customer
outreach to solicit input and
feedback relative to rate
structure proposals.
Invest in advanced metering, with a
goal of replacing at least 10% system
meters annually
SWBNO City, NORA
SWBNO Strategic Capital, Operational & Financial Plans; Code Enforcement
water & sewer rates
Within Next Year: (1) Identify
staffing and funding needs to
upgrade at least 10% of
SWBNO’s entire meter system
annually and reasonable annual
targets for meter inspection; (2)
investigate continued reliability of
existing SR meter models amid
pending large-scale industry
phase-out of that model and
identify alternative solutions; (3)
present a timeline and funding
process for installing network
towers sufficient for entire
system by 2017; (4) develop
protocols with NORA and City
Code Enforcement to inspect
meters on vacant lots and
structures; and (5) develop a
transparent process by which
customers can track meter
replacement progress.
Conduct annual transparent water
audits
SWBNO City Council SWBNO Strategic Capital, Operational & Financial Plans;
Same as above.
Within Next Year: (1) Develop
operating plan for conducting
regular water loss audits and
establish realistic performance
goals and benchmarks by which
progress can be tracked by
customers; (2) develop an
organizational structure for an
interdisciplinary Water Audit Unit
consisting of in-house staff
among relevant departments; (3)
establish a format and protocols
for preparing and presenting
water audit reports to the Board
and New Orleans City Council, at
least annually; and (4) develop
procedures and performance
metrics to measure unbilled and
unmetered water loss due to
public use, collections
inefficiencies, and unauthorized
consumption or theft.
Achieve Greater Operational Savings through Advance Metering, Improved Collection Practices and Narrower “Free Water” Policies
Improve ratepayer collection practices
through improved data analysis,
increased staffing capacity & legal
authority to enforce payment
SWBNO SWBNO Strategic Capital, Operational & Financial Plans
water & sewer rates
Within Next Year: (1) Develop
methodologies for measuring
revenue loss due to billing and
administrative errors, procedures
for improving transparency and
reliability, and metrics to gauge
progress; (2) research cost and
technical feasibility for installing
restricted water service devices
in non-paying customer meters
to restrict water flow to an
amount sufficient for basic
needs; and (3) as feasible,
develop enforcement procedures
and an implementation plan and
timeline for installing restrictor
devices.
Narrow public entities eligible for free
water and sewer services and require
that all public entities install functional
water meters and pay marginal
production costs and share of
customer account management
expenses
SWBNO
State Legislature, Orleans government entities
Same as above. Same as above.
Within Next Year: (1) Draft
legislation to amend La R.S.
33:4096 and 33:4121 to require,
at a minimum, (a) that all Orleans
Parish public entities pay a
minimum amount for production
costs, meter installation, and
customer account management
expenses, with such fees being
adjustable annually relative to
inflation and other relevant
indices and (b) eliminates rate for
public entities based on fixed-
year consumption amounts; and
(2) develop protocols for
regularly verifying that meters on
public buildings are functioning
and monitoring for leakages.
Expedite Capital
Improvements
Using Fast-Track
Procurement &
Formalized
Intergovernmental
Investment
Coordination
Establish permanent SWBNO-City
DPW Unit to implement roadway and
subsurface distribution improvements
using shared procurement and project
management processes
SWBNO, City RPC
SWBNO Strategic Capital, Operational & Financial Plans; City Capital Projects; Regional Transportation Implementation Plan
SWBNO and City bonds, water & sewer rates, other funding sources
Within Next Year: (1) Execute a
joint agreement between City
and SWBNO to establish a
permanent surface-subsurface
repair intergovernmental unit; (2)
develop unified procurement
processes and consolidated
project management roles and
responsibilities; and (3) establish
a unified online resource to allow
public tracking of project
selection and progress timelines.
Annually coordinate joint financing and
construction planning among City,
SWBNO, and RPC for surface and
subsurface improvement work
SWBNO, City, RPC
Same as above. Same as above.
Within Next Year: (1) Establish
formal agreements among City,
RPC, and SWBNO and related
procedures for aligning existing
budget funding processes and
any future planned bond
issuances; (2) develop
administrative and procurement
processes to better coordinate
proposed water and sewerage
system repairs with regular
updates to the City’s Capital
Improvement Plan, RPC’s
Transportation Improvement
Program, and other public
infrastructure initiatives.
Increase Staff
Operating Capacity
& Expertise
Identify optimal operational and
technical staffing capacity and
expertise requirements in each
SWBNO department relative to long-
term performance goals
SWBNO SWBNO Operational Plan
Concurrent with Rate Increase
Request: Present an outline of
internal performance and
customer-satisfaction indicators
that will be used to guide the use
of increased investment in
operational capacity and staffing.
Within Next Year: (1) Conduct
customer surveys and internal
operations audit to quantify
current and optimal levels of
system efficiency; (2) present to
SWBNO Board, City Council,
and customers how operational
departments will be restructured
or otherwise bolstered based on
performance assessments; and
(3) outline proposed sequencing
for operational improvements
and staff improvements relative
to forecasted O&M investment.
Increase Staff Operating Capacity & Expertise
Develop staff succession and training
program
SWBNO
SWBNO Operational Plan
Within Next Year: (1) Identify
specific updated skill-sets
needed in each department and
functions currently handled by
personnel with more than 20
years of SWBNO service; (2)
identify content and material
resource needs, select staff
liaisons, and structure ongoing
training programs relative to
specific departmental operation
goals; and (3) outline sequencing
for training relative to forecasted
O&M investment.
Revise civil service rules to increase
SWBNO autonomy in defining an filling
technical positions
SWBNO, Civil Service Commission
Civil Service Rules
Within Next Year: (1) Define
positions for which revised hiring
rules would be preferred and the
rationale; and (2) collaborate with
Civil Service Commission staff to
finalize position definitions,
compensation, and related hiring
processes.
Water & Sewerage System Advisory Group
Members:
Billy Burk, Managing Partner, Burk Property Investments, LLC (Chair)
Michael Guiza, Senior Project Manager, Weston Solutions
Louis Jackson, Senior Project Manager, CDM
Kerwin Julien, President, Julien Engineering & Consulting, Inc.
Sarah Mack, PhD, President, Tierra Resources, LLC
Douglas Olson, Barriere Construction Co., LLC
Jeffrey Thomas, Principal, Thomas Strategies, LLC
Greta Zornes, PhD
Organizational Contributors:
City of New Orleans
Horizon Initiative, Water Management Subcommittee
Raftelis Financial Consultants, Inc.
Regional Planning Commission
Sewerage and Water Board of New Orleans
Thomas Strategies, LLC ♦ 917 Washington Avenue, Suite C New Orleans, LA ♦ 504.237.4736