Framework for Integrated Municipal Planning Approach

Urban Water Sustainability Leadership Conference

Cincinnati, OH

October 16, 2012

What is an Integrated Approach?

Municipalities evaluate how best to meet all of their CWA requirements within their financial capability

Municipalities sequence wastewater and stormwater projects in a way that allows the highest priority environmental projects to come first

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Why an Integrated Approach?

Addresses most serious water quality problems sooner

More cost-effective, may lower overall cost of compliance

Fosters innovative approaches, such as green infrastructure, that are more sustainable

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Stakeholder Input

§ Stoner/Giles Memo to Regions (October 27, 2011)▪ EPA developing integrated planning framework with feedback from Stat

es, local governments, utilities and environmental groups

§ EPA workshops (Jan - Feb 2012)▪ Atlanta, GA - January 31, 2012▪ New York City, NY - February 6, 2012▪ Seattle, WA - February 13, 2012▪ Kansas City, KS - February 15, 2012▪ Chicago, IL - February 17, 2012

§ NACWA workshop – Washington, DC – December 17, 2011

§ Conference of Mayors workshop - Monrovia, CA – February 27, 2012 4

Stoner/Giles Memo to RegionsJune 5, 2012

Transmits final Integrated Planning Framework to EPA Regions

Encourages Regions to work with States and communities to identify opportunities to implement the integrated planning approach

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Outline of Framework

BackgroundPrinciples Overarching Principles Guiding PrinciplesElements of an Integrated PlanImplementation Permits Enforcement

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Overarching Principles forIntegrated ApproachMaintains existing regulatory standards th

at protect public health and water quality

Allows a municipality to balance various CWA requirements in a manner that addresses the most pressing public health and environmental protection issues first

The responsibility to develop an integrated plan rests with municipalities

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Guiding Principles for Plan Development

Reflect State requirements and planning efforts

Use existing flexibilities in the CWA and its implementing regulations

Maximize effectiveness of infrastructure dollars through analysis of alternatives and the selection and sequencing of actions

Incorporate innovative technologies and practices (green infrastructure)

Evaluate and address community impacts and considers disproportionate burdens

Technology-based and core requirements are not delayed

Financial strategy is in place

Opportunity for meaningful stakeholder input 8

Integrated Plan Elements Element 1: Water Quality, Human Health, Regulatory Issues

An assessment of existing CWA challenges - current and

projected future regulatory requirements

Identification and characterization of human health threats

Identification and characterization of water quality impairment and threats - TMDLs or an equivalent analysis

Identification of sensitive areas and environmental justice concerns

Metrics for evaluating human health and water quality objectives

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Integrated Plan Elements Element 2: Existing Systems and Performance

Identification of municipalities and utilities that are participating in the planning effort

Characterization of wastewater and stormwater systems

Characterization of flows in the wastewater and stormwater systems under consideration

Identification of deficiencies associated with existing assets

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Integrated Plan Elements Element 3: Stakeholder Involvement

Opportunities for meaningful input during development and selection of alternatives

Making new information available during plan implementation and providing meaningful input into developing proposed modifications

Public involvement in evaluating the effectiveness of green infrastructure approaches

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Integrated Plan Elements Element 4: Evaluating and Selecting Alternatives Sustainability planning to provide information for prioritizing

investments Consideration of green infrastructure and other innovative m

easures Identification of criteria to be used for comparing alternative

projects Identification of alternatives cost estimates, projected p

ollutant reductions and other benefits Analysis of alternatives the criteria used, the projects sel

ected and why Proposed implementation schedules For each entity participating in the plan, a financial strategy

and capability analysis122

Integrated Plan Elements Element 5: Measuring success

Proposed performance criteria and measures of success

Monitoring program to address the effectiveness of controls, compliance monitoring and ambient monitoring.

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Integrated Plan Elements Element 6: Improvements to PlanA process for identifying, evaluating and s

electing proposed new projects or modifications to ongoing or planned projects and implementation schedules based on changing circumstances; and

Where the municipality is seeking a modification, they must collect the appropriate information to support the modification.

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Integrated Plan Implementation Role of Permits

Incorporate all or part of an integrated plan into NPDES permit where legally permissible

Considerations for incorporating integrated plans into permits

Compliance schedules for meeting WQBELs need to be consistent with the requirements in 40 CFR 122.47

Green infrastructure approaches and related innovative practices

Appropriate water quality trading 155

Integrated Plan Implementation Role of Enforcement

All or part of an integrated plan may be able to be incorporated into the remedy of an enforcement action

Considerations for incorporating integrated plans into enforcement actions

All parties needed to effectuate a remedy are involved History of compliance Where extended time is necessary to achieve compliance Using permitting and enforcement action in conjunction Enforcement orders should allow for adaptive management Green infrastructure approaches and related innovative pra

ctices

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Next Steps

Work with interested municipalitiesRecognize municipal leaders who come for

ward Share information about lessons learnedDevelop a Q & A documentManagement of Process Ongoing discussions with Regions and States Work with municipal associations to advance int

egrated planning177

Questions to DateGeneral

Why is EPA limiting its ‘integrated approach’ to the Clean Water Act when communities are facing similar challenges with their drinking water obligations?

How can communities proactively ensure that the plan they develop will be acceptable to regulators?

Who determines what the most pressing water quality needs of a community are?

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Questions to DateNPDES Permits

Will the agency consider issuing one permit that addresses MS4 and POTW requirements? How will it work?

Why not utilize permits instead of enforcement for compliance schedules?

Would it help to extend permit terms to 10 years?

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Questions to DateEnforcement

For a municipality that already has an existing enforcement action or agreement, can the approach and its affordability be reexamined, under the integrated approach?

Is this integrated approach laying the foundations for EPA to expand enforcement actions and the role of enforcement (as alleged in the Nov 7th inside EPA article)?

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Questions to DateFinancial Capability

When a community is preparing a Financial Capability Assessment, can it now include both the municipal wastewater and stormwater costs?

Are all communities going to be required to spend 2% of the median household income (MHI) of the community in order to participate in the integrated planning process?

Can a municipality include the ongoing need for infrastructure rehabilitation and improvements in an integrated planning approach?

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Questions?

Moving forward with implementation of the Integrated Planning Framework

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