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Elizabeth Toot-Levy, Integrated Planning--Is it Here to Stay, Missouri Water Seminar, September 10-11, 2015, Columbia, MO

This document discusses integrated planning approaches to comply with the Clean Water Act. It describes the elements of integrated planning, including stakeholder involvement, evaluating alternatives, and measuring success through adaptive management. Integrated planning allows communities to prioritize requirements, consider affordability, and develop longer compliance schedules. The document also provides an example of how the city of Lima, Ohio is using integrated planning to address their water quality and infrastructure challenges in a more flexible and affordable way.

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Integrated Planning – Is it here to stay? 2015 Missouri Water Seminar September 10 & 11, 2015 Elizabeth Toot-Levy Adrienne Nemura, PE
12 Angry Mayors - 2009
Why were they so angry?
CWA Compliance Triangle Endpoints
Elements of CWA Compliance • 100 % Compliance with CWA Goals Endpoints • No more than 20 years Schedule • At least 2% MHI Affordability
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
Affordability – CWA and SDWA Needs  Can we afford fishable, swimmable, drinkable, at all times?  Lack of Federal Investment  Future needs [CATEGORY NAME] [VALUE] [CATEGORY NAME] [VALUE] [CATEGORY NAME] [VALUE] [CATEGORY NAME]s [VALUE] [CATEGORY NAME] [VALUE]
Schedule
Integrated Planning Framework – Principles June 5, 2012 Maintain existing regulatory standards Prioritize CWA requirements Municipality driven Innovative technologies
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
Elements of CWA Compliance - Revisited • Adaptive Management Endpoints • Low-hanging fruit addressed first Schedule • Consider economic burden on community Affordability
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
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
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
CWA Compliance Triangle Endpoints
EXAMPLE: Lima, Ohio  Population = 38,355 (2013)  Sewer Service Population = 47,920  Sewer Accounts = 16,000  13.80 mi2  MHI = $26,943  Industrial history
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
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
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
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
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
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
Economics of the Consent Decree
The Players
The Ottawa River – Lima, OH
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
The Ottawa River Feasibility Study
The Ottawa River Feasibility Study
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
Low Flow Conditions 4.3 33.0 41.6 48.4 4.3 33.0 33.1 39.9 0.2 10.2 20.2 30.2 40.2 50.2 60.2 Reach 3 Reach 4 Reach 5 Reach 6 Daily Average Flow, cfs Low Flow Condition Results Design Flow With Husky Without Husky 38.3 PCS @ 3.3 MGD
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
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
Dam Removal
Questions Elizabeth Toot-Levy etoot-levy@geosyntec.com 440-227-9181