Label
Councilman Sarantou
Agenda Review
Black & Veatch Legislation
12/9/2025
Title
From: Councilman Sarantou Response Requested: asap
How much have we paid Black and Veatch the last 5 years to oversee the Consent Decree w/EPA?
Body
Referral Response:
What the Black & Veatch Contract Does for Toledo
1. Program Management of the EPA Consent Decree & Waterways Initiative
Black & Veatch acts as the program manager for Toledo’s long-term Consent Decree compliance program (often referred to as the Toledo Waterways Initiative). This is a multi-year, multi-hundreds-of-millions-of-dollars infrastructure program to bring the city’s sewer system and wastewater treatment into compliance with federal and state law.
A few of the program management tasks they provide:
• Planning, monitoring and modeling of system performance and wet weather flows.
• Technical analysis of alternatives, including engineering and technology choices.
• Coordination with federal/state regulators (EPA & Ohio EPA) to document compliance.
• Financial analyses and funding strategy to leverage federal/state funds.
• Oversight of design and construction of major sewer upgrades and wastewater treatment improvements.
This isn’t simply periodic reporting - it is full program oversight required to make sure the city meets the milestones and deadlines spelled out in the Consent Decree. In some cases, the actual Consent Decree requires periodic approved plans, modeling results and updates to the EPA/OEPA.
2. Engineering and Construction Oversight
Black & Veatch provides:
• Detailed engineering design for major capital improvements.
• Construction management services on dozens of projects across the sewer and treatment plant system.
For a program of this size ($400M+ in improvements over decades), that means managing multiple simultaneous construction projects, ensuring they meet technical specifications, staying on schedule, and complying with regulatory (EPA/NPDES) requirements.
Why This Work Is Specialized
A. Highly Specialized Technical Capabilities
Black & Veatch brings:
• Deep engineering expertise in wastewater hydraulics, sewer system modeling, treatment plant technology, and regulatory compliance.
• Experience managing federal-enforced programs in other cities and jurisdictions.
This is not general public works maintenance or routine city engineering - it is technical professional engineering, regulatory coordination, risk modeling, long-term planning, and highly nuanced regulatory compliance oversight.
B. Regulatory Risk and Liability
Under the Consent Decree the city must prove (with documentation and EPA-approved plans) that it is implementing the required program. Experts like Black & Veatch help ensure:
• Submissions are technically sound;
• Monitoring and modeling meet EPA standards;
• Changes or amendments to plans are negotiated correctly;
• EPA/OEPA approvals are obtained without triggering enforcement actions.
If these tasks are done incorrectly, the city could face fines, litigation, or orders for additional corrective actions. The Consent Decree actually requires formal reporting and approved plans to regulators.
City engineers and utility staff typically handle operations and maintenance, not complex, federal-enforced program implementation at this scale.
C. Project Scale and Duration
This program spans decades, with hundreds of millions of dollars of infrastructure upgrades - far beyond what typical municipal staff can program manage internally. Contracting a firm like Black & Veatch:
• Provides continuity of technical knowledge over multiple project phases;
• Adds capacity that otherwise isn’t in the city budget or expertise;
• Transfers complex compliance risk to a firm whose specialty is regulatory oversight and engineering on these issues.
The Cost: The City has spent $263,514 per year for the last five years.