5. Elements of CWA Compliance
• 100 % Compliance with
CWA Goals
Endpoints
• No more than 20 years
Schedule
• At least 2% MHI
Affordability
6. Endpoints
NPDES Permit needed to discharge pollutants to
waterways
NPDES Permit conditions require waterways to be:
Fishable
Swimmable
Drinkable
NPDES Permit conditions must be met at all times
Ultimate goal is to eliminate pollutant discharges
7. Affordability – CWA and SDWA Needs
Can we afford
fishable,
swimmable,
drinkable, at all
times?
Lack of Federal
Investment
Future needs
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10. The Elements of Integrated Planning
• Description of challenges to be addressed
• Identification of human health threats, WLAs, TMDLs, etc.
Water Quality, Human
Health & Regulatory Issues
• Description of existing wastewater and stormwater systems
• Evaluation of current performance
Existing Systems and
Performance
• Open channels of communication with relevant stakeholders
• Allows for public input
Stakeholder Involvement
• Prioritizing investments and renewal of systems
• Green infrastructure for more sustainable solutions
Evaluating and Selecting
Alternatives
• Identified performance criteria
• Monitoring and evaluation program
Measuring Success
• Identification of new projects or modifications
• Changing circumstances
Improving the Plan
11. Elements of CWA Compliance - Revisited
• Adaptive Management
Endpoints
• Low-hanging fruit
addressed first
Schedule
• Consider economic
burden on community
Affordability
12. Integrated Planning Endpoints
Coordination between State and federal NPDES permit
and enforcement authorities
Communities can determine how to maximize the
environmental benefit of their CWA actions given limited
resources
Reopener provisions to better facilitate adaptive
management
Sustainable solutions for wet weather control (Green
Infrastructure)
Flexibility
Water Quality Trading
13. Integrated Planning Affordability
FCA can include wastewater and stormwater costs
Not required to spend 2% of MHI to use Integrated
Planning
Can use SRF funding for planning
Consider infrastructure rehabilitation/improvement costs
Consider lifecycle costs and sustainability for alternatives
evaluation
Weighted Average Residential Index
Affordability Assessment Tool for Federal Water
Mandates
14. Integrated Planning Schedule
Extended Compliance Schedules
Compliance schedules that prioritize the most significant
human health and environmental needs
Longer timeframes
Non-CWA projects can be considered when evaluating
overall financial health and burden
16. EXAMPLE: Lima, Ohio
Population = 38,355
(2013)
Sewer Service
Population = 47,920
Sewer Accounts =
16,000
13.80 mi2
MHI = $26,943
Industrial history
17. Lima, Ohio
Wastewater Utility
Wastewater Treatment Plant
18.5 MGD dry weather, tertiary treatment
96.0 MGD wet weather treatment (under construction)
Sewer Collection System
20 CSOs
32 CSOs
251 miles of sewers
60% combined
25 pump station
Stormwater Utility
Water Supply System
18. LTCP Timeline
1998 – Original LTCP Submitted to OEPA
1999 – OEPA Approves LTCP
2005 – USEPA R5 Rejects LTCP
2009 – Original LTCP would have been complete
2011 – Lima submits revised LTCP
2012 – Lima Presents Integrated Planning Approach to
USEPA, HQ
2012 – USEPA Visits Lima (April)
2012 – City Submits Revised LTCP (May)
2015 – Consent Decree Approved
19. Consent Decree Reopeners
Economic Reopeners
Significant cost increases
Increased costs as a percentage of median household
income
Service area poverty levels
Increasing unemployment
Decreasing population
Changes in service area size
Decreases in revenue due to water conservation efforts
Closure of major industrial accounts
Increases in operational costs
20. Additional Consent Decree Reopeners
New Clean Water Act obligations
TMDL or NPDES permit changes
Incorporation of Green Infrastructure
If equal or better environmental results
can be achieved through adaptive
management
21. Economic
Declining population:
38,838
Wastewater utility service
area population ~47,920
City MHI $26,943 and
declining
MHI below Ohio Very Low
Income Threshold
34.7% of City residents
below the poverty level
Unemployment 20.2%
Clean Water Act
CSOs
Ottawa River TMDLs
Ottawa River – Multiple
stressors
Low-head dams
Lake Erie drainage basin
Lima’s Challenges
22. Economics of the Consent Decree
0
500
1,000
1,500
2,000
2,500
3,000
Annual Household Income Distribution in Lima, Ohio
“Anyone who has ever struggled
with poverty knows how
extremely expensive it is to be
poor.” – Mayor Berger
July 24, 2014, Water Resources Subcommittee
Testimony
26. The Study
Flow balance
Document pollutants
Data Evaluation
Model Development
Evaluate dam
modifications
Develop Realistic goals
for the Ottawa River
The Questions
Can the habitat in the
Ottawa River be
improved?
Can the dams be
managed in a manner to
improve habitat?
Can the drinking water
system be managed to
improve the habitat in the
river?
The Ottawa River Feasibility Study
29. Baseline Flow Predictions
1
10
100
1,000
5/1/2010 5/6/2010 5/11/2010 5/16/2010 5/21/2010 5/26/2010 5/31/2010
Daily
Average
Flow,
in
cfs
Date
Estimated Ottawa River Flow Record Adjustment
USGS Gage Station, May 2010
Original Ottawa River Flow
Ottawa River Flow Adj. for Intakes
31. Next Steps
Field Survey
Flow Monitoring
Modeling of Existing Conditions
Alternatives Analysis
Options – Low-head dam modification, channel
modification, flow augmentation
Criteria: Water depth, velocity, aquatic habitat impacts,
aesthetics/appearance
32. The Future
What does this tell us about realistic expectations for the
Ottawa River?
Can Lima achieve equal or better environmental results
through adaptive management
Dam modification
Flow management
Responsible use of rate-payer dollars
Wise investment of private funds