This document discusses the benefits of an integrated planning approach for managing wet weather obligations in Euclid, Ohio. It provides examples from other cities that implemented integrated plans through negotiations with EPA to refine consent decrees, reduce costs by over $100 million in some cases, and prioritize green infrastructure. The document recommends Euclid develop an integrated plan to evaluate control levels, affordability, potential cost savings through regionalization and optimized controls, and inclusion of green infrastructure. It identifies initial issues with Euclid's plan and opportunities through an integrated approach.

1. Value of an Integrated
Planning Approach for
Euclid, Ohio

2. EPA Policy Evolution since 2011
“A comprehensive and integrated
planning approach to a municipal
government’s CWA waste- and
storm-water obligations offers the
greatest opportunity for identifying
cost-effective and protective
solutions and implementing the
most important projects first.”
“The OW and the OECA are
committed to working with
interested communities and water
resource managers to successfully
incorporate green infrastructure
into NPDES permits, as well as
remedies designed to address
non-compliance with the CWA, to
better manage both stormwater
runoff and sewer overflows.”
Attachment A
Recent (2011) Examples of
Enforcement Actions with Green
Infrastructure
 Cincinnati, OH
 Cleveland, OH
 Kansas City, MO
 Louisville, KY

3. EPA’s Integrated Planning Framework can
refine the program, saving $ and extending
the compliance timeline
•MBR Upgrades
•Headworks
Upgrade
Ongoing
System
Improvements
•Cost Savings
through
regionalization
•Optimize CSO /
SSO Controls
•Add Green
Infrastructure
Integrated
Planning
Regionalization
Affordability
•Optimized
Storage
•Pro-Business GI
and Economic
Development
projects
Refined
Program
Pause
Point Extend Compliance Schedule
Address Affordability Concerns

4. Initial Review of Euclid Consent Decree
and Wet Weather Plan
 Euclid’s Control Levels are high and are not connected to
water quality standards
 Program Affordability is not aligned with best practices to
protect Euclid ratepayers
 Significant Schedule and Future Cost Risks of program
 Ensuring Regional Buy-in with rising compliance costs
 Ruling out Green Infrastructure (GI) is inconsistent with National
practice and EPA Policy

5. Euclid’s Control Levels are high and
cost/benefits not considered
 CSO Activation limit of 4 per year arbitrary in context of water
quality benefits
 Exceeds CSO Policy which allows 6 or more if benefits from fewer
activations cannot be cost justified
 Unclear if Euclid using Presumptive or Demonstrative Approach –
this could impact potential alternatives and costs
 No clear linkage of program investments to water quality benefits
 Lake Erie TMDL evolving and would likely change plan emphasis
and costs
 EPA Region 5 imposing “new” interpretation of CSO Policy

6. Program Affordability is not
aligned with best practices to
protect Euclid ratepayers
 Cost escalation changes affordability
of the CD driven plans
 Schedules and cash flow impacts
need to be more closely evaluated
 Plant work, CSO work, SSO work being
forced to overlapping timelines
 Huge cash flow needs in 2015-2018
creates unbalanced program
 May cause unanticipated rate stress
and loss of customer support
 At a minimum, Euclid needs more
time to comply

7. Cost Escalation - total program cost risk
0
20
40
60
80
100
120
140
160
180
Sep-11 Mar-12 Oct-12 Actual
?

8. Consent Decree Issues and
Opportunities: Penalty Avoidance
 Consent decree heavy on
penalty provisions for small
city
 More than NEORSD and
other large cities in some
cases
 Euclid should be careful
with penalty liability if
dispute resolution needed
to get CD plan and
schedule changes
 STIP risks can be reduced
City STIPS – Maximum Daily
Penalty
Euclid, Ohio $4,000/day after 60 days
Chicago MWRD $5,000/day after 60 days
St. Louis $4,000/day after 60 days
Cleveland (NEORSD) $2,000/day after 30 days
DeKalb $3,000/day after 120 days
Honolulu $2,000/day after 60 days
Kansas City $4,000/day after 60 days
HRSD $3,000/day after 60 days
Nashville $5,000/day after 6 months
Louisville $5,000/day after 120 days
Baton Rouge $10,000/day after 60 days
EPA now assessing STIPS in some
Regions

9. Rationale for considering an integrated
planning and program refinement phase
 Save Money
 Affordability picture has changed due to CSO/SSO and Separate
stormwater (MS4) issues need to be considered
 CD requires overlapping CSO/SSO and Plant work
 There is precedent - Other cities reopening CD negotiations based on
excessive costs and integrated planning opportunities
 Integrated plan can assess schedule impacts and balanced approach
 Adapting the program to enable Greener Communities; currently green
is at the back end of schedule, which does not help Euclid achieve
community improvements or benefits soon enough
 Plan would address increasing public opposition to program costs and
clarify program benefits
 Better program controls are necessary to enable more transparency in
terms of understanding of projects / budgets / value / status

10. Examples of Integrated and Adaptive
Wet-Weather Plans
 Louisville, KY
 Spokane, WA
 Cincinnati, OH
 Columbus, OH
 Akron, OH
 Lancaster, PA
 Onondaga County, NY

11. Louisville, KY
 Negotiated option to do integrated planning in multi phased CD
 Allowed prioritization of competing CSO, SSO, and stormwater expenditures
over extended timeline ($800 million program)
 Provided mechanism for substituting green projects if equal or better than
grey projects identified resulting in significant green projects and stronger
public support for rate increases
 Has innovative incentives to maximize private green investments
 Has resolved technical issues with EPA Region 4 to “measure” green project
performance and compare to grey projects

12. Spokane, WA
 Integrated Clean Water Plan utilizing the USEPA’s
Integrated Planning Framework focused on the
City’s goal of achieving a cleaner Spokane River
faster
 Developed of a CSO Plan Amendment that re-sized
CSO tanks and saved the City $120 million
 Evaluated applicability and cost-effectiveness of
pollutant reduction approaches (in addition to
discharge reduction) including Green Infrastructure
 Collaboration with Spokane area stakeholders and
the Washington State Department of Ecology was
essential for integrated planning success
 Re-prioritized projects based on removal of
pollutants, meeting water quality requirements, and
on other objectives important to the residents of
Spokane including economic development and
aesthetics
“We spent a year re-evaluating
our work to reduce combined
sewer overflows and stormwater
runoff going to the Spokane
River, along with plans to
improve treatment at our
wastewater facility. We
identified a path forward that
would reduce the cost by about
$150 million and vastly improve
the health of the river.” - David
Condon, Mayor, Spokane, WA

13. Cincinnati, OH
 Metropolitan Sewer District of Greater Cincinnati (MSDGC) entered into CD
in August, 2010
 Multi-billion dollar program comprised of wet weather, capacity assurance,
and asset management improvements
 Negotiated the opportunity to conduct a 3-year study to develop and
evaluate a cost competitive alternative to the default CD solution (tunnel)
 Program incorporates integrated planning approaches to address
Stormwater and wastewater issues while yielding enhanced economic,
environmental, and social benefits for community
 CH2M HILL professionals provided technical expertise to support MSDGC
Office of the Director (OOD) in the development of a sustainable
watershed evaluation planning process (SWEPP) aligned
with the USEPA Integrated Planning Framework that was
officially adopted in June 2012
St Francis bioinfiltration basin early success project
completed by MSDGC in Lick Run watershed

14. Columbus, OH
 Proactively addressing their stormwater challenge as part of their SSO
mitigation
 Have pilot program to implement GI to provide water quality treatment of
stormwater runoff in their sanitary sewer service area
 This pilot program also includes private property rehabilitation of service
laterals, which are thought to be a significant source of I/I in the sanitary
sewer system
 Columbus owes the EPA a report with monitoring and modeling based
findings on effectiveness and published cost effectiveness by September,
2015

15. Lancaster, PA
Integrated Plan that
provides the following
benefits:
 Lower Life Cycle Cost
 Community Impacts
(Triple Bottom Line)
 CSO Volume Reductions
 Water Quality
(Pollutant Load Reduction)
 Flood Risk Reduction
“The purpose of this analysis is to demonstrate
how accounting for the multiple benefits of
green infrastructure can provide a more
complete assessment of infrastructure and
community investments” US EPA
“CH2M HILL has been a tremendous partner throughout the
development and implementation of our regulatory compliance
program for an update to our long term control plan and MS4
programs and helping us meet our goals for the TMDL. We have
great local resources from the firm and we have also benefitted
from their global reach and experience.”
Charlotte Katzenmoyer, Director of Public Works,
City of Lancaster, PA

16. Onondaga County, NY
 Consent Judgment was agreed to clean up “America’s most
polluted lake” – but stakeholders were not satisfied with the
stipulated approach
 Prolonged public opposition increased cost and delayed
implementation
 New County Executive leadership convinced Judge to consider
Greener, Balanced approach; given 1 year pause to develop
new control plan
 Revised program moves Green Infrastructure to front of program,
implements a smarter gray program, Extended compliance
schedule by 5 years
 Saving over $20M+ in capital cost while reducing life cycle costs
even more; improves other community assets immediately
(roads, parking lots, roofing systems, vacant lots, parks, schools)
 Community sees the benefits to the lake, tributaries, and public
assets; able to appreciate why their sewer rates have increased

17. Euclid, Ohio
Next: Two - Step Revision Strategy
1. Develop consensus to proceed with a review and
update process
Work with City staff and legal counsel to identify benefits of
a refinement phase and integrated plan
2. Develop a road map
 Build technical, regulatory, and financial case to support
plan revision
 Build team (internal staff and external consultants)
 Develop strategy to negotiate and implement a revised
consent order and wet-weather plan

18. Integrated Plan Roadmap
 Affordability analysis / FCA requires more sophistication
 Review current investments being implemented at this time, specifically
those at the treatment facility/equalization storage
 Identify the gap remaining to satisfy all existing and imminent regulatory
requirements (point and non-point sources, MS4, TMDL, and others)
 Integrate GI solutions with existing/proposed gray infrastructure, as well as
identify where proposed gray infrastructure may be replaced with
equivalent green options
 Better utilization of planning tools such as geographic information systems
(GIS) and stormwater management model (SWMM)
 Evaluate CSO/SSO capture assumptions based on national experience
 Utilize modeling tools and the monitoring data effectively to support revised
program and build consensus with regulators and stakeholders
 Prioritize community opportunities/impacts

19. Questions ?

20. Onondaga County, NY
Original Consent Order planned to build four (4)
Regional Treatment Facilities (RTFs)
in neighborhoods and business districts
(1 of the 4 was built costing $79.1 million;
significantly over budget)
RTFs required large
conveyance
pipelines with
significant
community disruption
(over budget and
behind schedule)
Initial Projects Opposed by
Community Residents and Businesses

21. Onondaga County, NY ~ Balanced Approach
Syracuse becomes
one of first ten EPA
Green Cities
County Executive Mahoney Announces “Project 50!”
“Onondaga County will construct fifty distinct green
infrastructure projects to return rain water and snow
melt to the ground instead of our sewer system.”
Joanne M. Mahoney, State of the County Address,
March 1, 2011

22. Onondaga County, NY
Over 165 projects completed
100,000,000 gallons of runoff reduction

23. Onondaga County, NY
Benefits to County Facilities
OnCenter Convention Center
66,000 Square Foot Green Roof
New 30 year roof installed under CSO program;
study underway quantifying heating and cooling
benefits in addition to runoff reduction
Before

24. Onondaga County, NY
Green Streets Installed Adjacent To No-Standing Lanes
Add Aesthetic Value Without Impacting Traffic or Pedestrians
BEFORE: Stormwater enters catch
basins and is directly connected to
sewer
PROPOSED (Photo Simulation):
Stormwater is diverted to Green
Streets and only overflows to
sewer when necessary
AFTER (Actual Photo): Project
has been adopted* by local
business to pick up litter, weed,
and mulch (provided by County)
Adopt-A-GI Project program was created based on common Adopt-A-Highway format

25. Onondaga County, NY
Benefits to County Facilities
OnCenter Convention Center
290 Parking Space Surface Lot
(porous asphalt perimeter with subsurface
storage and infiltration system)
Lot had many potholes and significant cracking; resurfacing
paid for through CSO program. Improved safety through
smarter layout, LED lighting, as well as electric vehicle
charging station (separate funding source)
Before

26. Onondaga County, NY
Benefits to County Facilities
Surface Parking Lot next to
Everson Art Museum
Previously a puddle-ridden gravel lot, new
standard asphalt pavement drains to Bio-
retention designed to store, slowly infiltrate,
and provide evapotranspiration of runoff
due to poorly draining soils; large storm
events overflow to sewer
Vegetated
Bio-retention
System, including
90 new Trees
Before

27. Onondaga County, NY
Benefits to City Streets
Award
Winning
Water Street
Green
Gateway
Project
Completely new City Street (City paid for asphalt mill and
paving, County program paid for all other work)
Before

28. Onondaga County, NY
Benefits to City Streets – Typical Residential
Stone
Trench
New City Street
Storage and Infiltration Trench no longer visible

29. Onondaga County, NY
Benefits to City Streets
Otisco Street
Residential Green Street
with Bioswale
• New Curbs, asphalt,
and sidewalks
• Traffic Calming
(Bump Outs)
• Added green space

30. Onondaga County, NY
Benefits to City Commercial Districts
Westcott Street Commercial District
• New Curbs, Sidewalks, and Asphalt
• Improved Pedestrian Experience
Before

31. Onondaga County, NY
Benefits to City Streets
West Onondaga Street
Commercial District
Before

32. Onondaga County, NY
Benefits to City Streets
West Onondaga Street
Commercial District
• New Curbs, Sidewalk, Asphalt
• Improved Traffic Pattern
• Added Green Spaces Before

33. Onondaga County, NY
Addressing the Vacant Lot Challenge
701 Oswego
Street Vacant
Lot Project
The CSO Abatement Program has utilized
multiple vacant lots in the City to manage
stormwater runoff while investing in new curbs,
sidewalks, and putting these properties to
beneficial use as nurseries and gardens
Before

34. Onondaga County, NY
Utilizing Park Space
Leavenworth Park Bio-infiltration System
Project included new roadside granite curbs and
carriage walk; plantings compliment park setting
(County program has also resurfaced basketball courts,
parking lots, and supported other park amenities)
Spring
Summer Bloom

35. Onondaga County Green Improvement Fund
A Public Private Partnership Grant Program
Incentivizing GI on Private Property
 130 Applications Submitted (Mar 2014)
 59 Projects Completed
(27 in 2013)
 25 million gallons of
Stormwater Runoff captured
for $6.1 million
 21.5 million more gallons contracted
 Average rate = $0.25/gal for program
The County also has a program that has distributed over 1,000 free
Rain Barrels, and has planted over 2,500 street trees (8,500 planned)
Monroe Building
Green Roof