1. Framework for Integrated
Municipal Planning Approach
October 16, 2012
Urban Water Sustainability
Leadership Conference
Cincinnati, OH

2. 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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3. 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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4. Stakeholder Input
§ Stoner/Giles Memo to Regions (October 27, 2011)
▪ EPA developing integrated planning framework with feedback from States,
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
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5. Stoner/Giles Memo to Regions
June 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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6. Outline of Framework
Background
Principles
 Overarching Principles
 Guiding Principles
Elements of an Integrated Plan
Implementation
 Permits
 Enforcement
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7. Overarching Principles for
Integrated Approach
Maintains existing regulatory standards that
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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8. 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
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9. 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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10. 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
100

11. 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
111

12. Integrated Plan Elements
Element 4: Evaluating and Selecting
Alternatives
 Sustainability planning to provide information for prioritizing
investments
 Consideration of green infrastructure and other innovative
measures
 Identification of criteria to be used for comparing alternative
projects
 Identification of alternatives  cost estimates, projected
pollutant reductions and other benefits
 Analysis of alternatives  the criteria used, the projects selected
and why
 Proposed implementation schedules
 For each entity participating in the plan, a financial strategy and
capability analysis
122

13. 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.
133

14. Integrated Plan Elements
Element 6: Improvements to Plan
A process for identifying, evaluating and
selecting 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.
144

15. 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

16. 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
practices
166

17. Next Steps
Work with interested municipalities
Recognize municipal leaders who come
forward
Share information about lessons learned
Develop a Q & A document
Management of Process
 Ongoing discussions with Regions and States
 Work with municipal associations to advance
integrated planning
177

18. Questions to Date
General
 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?
188

19. Questions to Date
NPDES 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?
199

20. Questions to Date
Enforcement
 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)?
200

21. Questions to Date
Financial 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?
211

22. Questions?
Moving forward with implementation of
the Integrated Planning Framework
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