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Framework for IntegratedMunicipal Planning ApproachOctober 16, 2012            Urban Water Sustainability                 ...
What is an IntegratedApproach?Municipalities evaluate how best to meet all of their CWA requirements within their financi...
Why an Integrated Approach?Addresses most serious water quality problems soonerMore cost-effective, may lower overall co...
Stakeholder Input§ Stoner/Giles Memo to Regions (October 27, 2011)▪ EPA developing integrated planning framework with feed...
Stoner/Giles Memo to RegionsJune 5, 2012Transmits final Integrated Planning Framework to EPA RegionsEncourages Regions t...
Outline of FrameworkBackgroundPrinciples Overarching Principles Guiding PrinciplesElements of an Integrated PlanImpl...
Overarching Principles forIntegrated ApproachMaintains existing regulatory standards that protect public health and water...
Guiding Principles for Plan Development  Reflect State requirements and planning efforts  Use existing flexibilities in ...
Integrated Plan ElementsElement 1: Water Quality, Human Health, Regulatory Issues   An assessment of existing CWA challen...
Integrated Plan ElementsElement 2: Existing Systems andPerformance Identification of municipalities and utilities that ar...
Integrated Plan ElementsElement 3: Stakeholder Involvement Opportunities for meaningful input during development  and sel...
Integrated Plan ElementsElement 4: Evaluating and SelectingAlternatives  Sustainability planning to provide information f...
Integrated Plan ElementsElement 5: Measuring success Proposed performance criteria and measures of  success Monitoring p...
Integrated Plan ElementsElement 6: Improvements to PlanA process for identifying, evaluating and selecting proposed new p...
Integrated Plan ImplementationRole of PermitsIncorporate all or part of an integrated plan into NPDES permit where legall...
Integrated Plan ImplementationRole of Enforcement All or part of an integrated plan may be able to be  incorporated into ...
Next StepsWork with interested municipalitiesRecognize municipal leaders who come forwardShare information about lesson...
Questions to DateGeneral Why is EPA limiting its ‘integrated approach’ to  the Clean Water Act when communities are  faci...
Questions to DateNPDES PermitsWill the agency consider issuing one permit that addresses MS4 and POTW requirements? How w...
Questions to DateEnforcement For a municipality that already has an existing  enforcement action or agreement, can the  a...
Questions to DateFinancial Capability When a community is preparing a Financial Capability  Assessment, can it now includ...
Questions? Moving forward with implementation of  the Integrated Planning Framework                                       ...
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EPA HOW DO WE IMPLEMENT A FRAMEWORK FOR INTEGRATED WASTEWATER AND STORMWATER MANAGEMENT?

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EPA HOW DO WE IMPLEMENT A FRAMEWORK FOR INTEGRATED WASTEWATER AND STORMWATER MANAGEMENT?

  1. 1. Framework for IntegratedMunicipal Planning ApproachOctober 16, 2012 Urban Water Sustainability Leadership Conference Cincinnati, OH
  2. 2. What is an IntegratedApproach?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 2
  3. 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 3
  4. 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 4
  5. 5. 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 5
  6. 6. Outline of FrameworkBackgroundPrinciples Overarching Principles Guiding PrinciplesElements of an Integrated PlanImplementation Permits Enforcement 6
  7. 7. Overarching Principles forIntegrated 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 7
  8. 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 8
  9. 9. Integrated Plan ElementsElement 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 9
  10. 10. Integrated Plan ElementsElement 2: Existing Systems andPerformance 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. 11. Integrated Plan ElementsElement 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. 12. Integrated Plan ElementsElement 4: Evaluating and SelectingAlternatives  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. 13. Integrated Plan ElementsElement 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. 14. Integrated Plan ElementsElement 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. 15. Integrated Plan ImplementationRole 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. 16. Integrated Plan ImplementationRole 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. 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. 18. 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? 188
  19. 19. 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? 199
  20. 20. 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)? 200
  21. 21. 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? 211
  22. 22. Questions? Moving forward with implementation of the Integrated Planning Framework 222

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