The document discusses the U.S. EPA's Integrated Planning Framework (IPF) which allows municipalities flexibility in completing projects that provide the greatest environmental benefits first while balancing regulatory requirements. It provides an overview of MWH's IPF development process, benefits of the approach, and case studies of its use in Indianapolis, Atlanta, Baltimore, and Lima. The IPF prioritizes infrastructure improvements based on a multi-criteria model to create greater benefits while maintaining affordability.

1. INTEGRATED
PLANNING
FRAMEWORK
MARCH 2013

2. ISSUES
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3. The U.S. EPA’s new Integrated Planning Framework (IPF) is an encouraging sign that
regulators may finally be recognizing the financial limitations associated with
implementing consent decree and increasingly stringent permit limitations. Under
pressure from the U.S. Conference of Mayors, NACWA and other professional
associations, U.S. EPA Headquarters issued guidance in 2012 encouraging
flexibility in completing projects with greater environmental benefit first.
MWH has developed an IPF approach following the U.S. EPA’s guidance document
that is designed to provide a cost effective road map to a sustainable utility that can
be applied both to utilities with or entering consent decrees and to utilities facing
completing financial pressures.
2
The following list suggests client needs or
drivers that may prove conducive to development
of an IPF approach for that client.
• Capital Improvement Program (CIP) projects
are being driven by consent decree or Long
Term Control Plan (LTCP) mandates rather than
by community needs.
• Rate affordability is becoming a limit for project
implementation.
• Asset management, especially proactive
maintenance, is being side-tracked due to
either funding limitations or overwhelming
reactive maintenance needs.
• High profile asset failures are affecting the
utility’s reputation.
• Storm water MS4 permits and Total Maximum
Daily Load (TMDL) allocations require project
implementation, but minimal funding is
available.
• National Pollutant Discharge Elimination System
(NPDES) permits with stringent nutrient removal
limitations are coming, but minimal funding is
available.
• Community is faced with divergent views of
multiple utility or infrastructure needs and the
utilities (e.g., water, wastewater, storm water,
power, etc.) require a unified road map.
MOVIE 1.1 Robyn McGuckin: Integrated Planning Framework

4. THE MWH IPF
DEVELOPMENT
PROCESS
2

5. The MWH Integrated Planning Framework (IPF) methodology is based on a triple bottom line
(TBL) approach that evaluates and prioritizes the City’s wide ranging financial obligations for
drinking water, wastewater and storm water infrastructure improvements. This approach is
adaptable to other utilities if for example a community also runs an electric utility or a gas utility
as do a few of our clients. MWH’s IPF approach prioritizes infrastructure operations and
improvements creating greater benefits as measured by a multi-criteria prioritization model.
4
The key steps in an IPF approach are
illustrated in Figure 1.

6. The IPF projects to be prioritized are based on our clients existing Capital Improvement Program (CIP), but must be augmented with those
projects that had historically been rejected or not considered due to budget constraints. The benefit criteria, and associated importance
weights, are designed to be customized to the needs and desires of each client.
5
Tap the graphs for
more information

7. In Baltimore, our project team evaluated the
various TBL accounting measures designed to
evaluate benefits and selected score-based
quantification in light of the ability to customize
Baltimore’s benefit criteria to the City’s needs
and the relative simplicity of the method when
compared to a monetized method. Detailed
scoring plans were established for each of
Baltimore’s 21 benefit criteria. Wherever
possible, these scoring plans were quantifiable
and were based on benefit calculations in
quantifiable terms. The City (minus consultant
members) team members weighted the relative
importance of the diverse criteria. Expert Choice
software was used to conduct pair-wise
comparisons evaluating the relative importance
of one criteria against another and repeating the
process until all criteria could be presented on
the same scale. These pair-wise comparison
weightings were then used as the basis for
developing a team consensus across the
drinking water, wastewater and surface water
divisions. Importance weights are a critical part
of a prioritization process because each change
to the importance weight has the potential to
result in a different prioritized project list that
would be needed to evaluate multiple scenarios.
Multiple scenario evaluation is needed to
demonstrate the advantages of the City’s
desired importance weights versus a regulatory-
drive scenario as illustrated in Figure 2.
6
Baltimore scenarios
evaluated under the
IPF model

8. Because the IPF is likely to result in completing higher benefit
projects before regulatory mandated projects with lower benefits,
existing consent decrees and potentially permits will need to be
revised. Federal consent decrees are increasingly using an
adaptive management approach, which is well-suited to meeting
the needs of an IPF process.
However, revising existing consent decrees or permits will require
significant negotiation with regulatory agencies. Thus the IPF
process must be scientifically based and must clearly
demonstrate benefits accrual. An example of the type of
negotiating argument to be made under an IPF approach is
illustrated in Figure 3.
Further, since the IPF approach is designed to facilitate a
sustainable approach for the communities CIP, the IPF must be
repeatable, must be adaptable to continuous improvement as
conditions change, and must be integrated into the financial
planning process.
7
IPF Sustainability and Affordability
Versus Benefit Accrual Illustrations

9. BENEFITS
3

10. In late 2011 the U.S. Environmental Protection Agency (U.S. EPA)
Headquarters announced an innovative new approach for
communities that are faced with large expenditures to meet
regulatory requirements for wastewater and storm water systems
and issued the final guidance June 5, 2012 (see Figure 1). In the
past, the U.S. EPA had largely been unwilling to accept a
community’s unaffordability arguments when raised as part of
consent decree negotiations except when related to Long Term
Control Plans (LTCPs) for combined sewer communities. Even in
LTCP communities, costs were only considered inside the
wastewater “vacuum”. The proposed Integrated Planning
Framework (IPF) initiative has the potential to change the U.S. EPA’s
historic negotiating position.Essentially, the IPF is designed to allow
community’s to choose to implement projects at a schedule that is
based on achieving the greatest benefit rather than on a solely
regulatory-driven project selection and scheduling process. The
U.S. EPA’s IPF initiative stated goals are to:
• Maintain existing regulatory standards that protect public health
and water quality
• Allow a municipality to balance various Clean Water Act (CWA)
requirements (U.S. Congress, 1972) in a manner that addresses
the most pressing public health and environmental protection
issues first
• Allow the municipality to choose to pursue the IPF approach,
which may include developing requirements and schedules in
enforceable documents
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11. While U.S. EPA limits the IPF to wastewater and storm water, some MWH clients, most notably the City of Baltimore, Maryland, have
incorporated drinking water, regulated under the Safe Drinking Water Act (SDWA) rather than the CWA, into the IPF approach.
The U.S. EPA’s IPF was developed after intensive lobbying and dialogue with the U.S. Conference of Mayors (USCM) and the National
Association of Clean Water Agencies
(NACWA). MWH was active with both groups throughout this effort as were the mayors from three MWH clients, the Cities of Baltimore,
Indianapolis and Lima.
The U.S. EPA’s guidance document on
the IPF approach lists six required
elements as illustrated in Figure 1.
10
U.S. EPA IPF Elements

12. The IPF-type approach has already
demonstrated benefits to several MWH
clients.
Indianapolis. Obtained a modified
consent decree that saved the City $444
million from the original consent decree
by developing an “Enhancement Plan” to
implementing technologies with “green”
solutions and partial sewer separations
that will still achieve the goals of the
original consent decree. The modified
consent decree also includes “off
ramps” that gives the City the
opportunity to renegotiate under certain
economic conditions.
Atlanta. Obtained a 13-year consent
decree extension utilizing an asset
management based approach that
focused on the capital and operating
budget requirements to continue
environmental and operational
improvements while balancing user rates
and affordability with a 20-year financial
model.
Lima. While not yet approved by U.S.
EPA Region V, Lima submitted a revised
draft LTCP using affordability
considerations combined with project
scheduling to maximize improvement in
water quality of the Ottawa River.
Specifically, the LTCP is based on a 28-
year implementation schedule that
pushes the lesser water quality benefit
SSO work out to the end in favor of
higher water quality benefit CSO work
and includes off ramp language for
assumptions relating to household
incomes and income growth rates.
Baltimore. While the Baltimore IPF has
not yet been finalized or submitted,
informal conversations with U.S. EPA
Region III and Maryland Department of
Environment (MDE), including on the
inclusion of drinking water projects in the
process, have been favorable although
still non-committal at this early point in
the project. Under the IPF prioritization
the top 50 projects are no longer
dominated by wastewater projects, but
contain significantly more storm water
projects as well as some additional
drinking water projects, particularly for
the distribution system.
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Top to bottom:
Indianapolis, Lima, Atlanta

13. CASE STUDIES
4

14. MWH has been involved in the Integrated Planning Framework (IPF)
process prior to inception by U.S. EPA. Our efforts supporting the
City of Indianapolis, Indiana, who was working both alone and in
conjunction with U.S. Conference of Mayors and the National
Association of Clean Water Agencies (NACWA) lobbying efforts,
were instrumental in obtaining regulatory agency concurrence with
incorporation of Low Impact Development (LID) projects and
significantly reducing consent decree compliance costs.
The Clean Water Atlanta Program Management Team (PMT) was
similarly instrumental in supporting the City of Atlanta efforts to
obtain a 13-year extension for on-going federal consent decree
project implementation.
With issuance of the U.S. EPA IPF guidance, the Baltimore Wet
Weather Compliance PMT partnered with City staff to develop a
formal IPF following EPA’s six-step process. At the same time,
MWH’s Cleveland Office adapted the LTCP for the City of Lima,
Ohio, to provide an IPF-based argument for prioritizing the City’s
LTCP project obligations.
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15. Indianapolis, Indiana
MWH serves as part of the leadership of the Indianapolis Clean
Stream Team responsible for development of their $3 billion capital
program. The Clean Stream Team (CST) is transitioning to an
integrated public/private partnership organization that features city
employees and consultants working together and co-located in City
offices. The current schedule anticipates that the capacity for
delivering projects must ramp up so that over $1 billion of projects will
be completed in the next 10 years. Recognizing that the cost of the
program puts a heavy burden on its citizens, the City challenged the
CST to find ways to reduce costs.
In support of this challenge, MWH provided regulatory assistance to
the City that resulted in a precedent setting modified consent decree.
The modified consent decree provided the City savings of $444
million from the original consent decree by developing an
“Enhancement Plan” that includes implementing technologies with
“green” solutions and partial sewer separations that will still achieve
the goals of the original consent decree. The modified consent
decree also includes “off ramps” that gives the City the opportunity to
renegotiate under certain economic conditions.
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16. Atlanta, Georgia
The City of Atlanta drinking water and wastewater utilities provide
retail or wholesale services to a five county region. These utilities
were historically organized as separate enterprise funds with
separate departments and operations. Storm water operations were
organized as a general fund in the public works department. In 2002
Mayor Shirley Franklin formed the City’s Department of Watershed
Management (DWM) with the express purpose of consolidating the
drinking water, wastewater and storm water operations.
The City’s aging wastewater system, comprised of 2,200 miles of
sewer transmission lines, four wastewater reclamation centers and
14 pump stations, in particular, needed significant improvements to
sustain a growing population; comply with two federal consent
decrees. One consent decree concentrated on the combined sewer
system and the second consent decree concentrated on the
separate sewer system. Both federal consent decrees were
designed to improve water quality throughout the metro area.
15
Atlanta, Georgia

17. Beginning in 2001, the City of Atlanta, Georgia, retained the joint
venture of MWH and KHAFRA to provide program management
services for its wastewater system improvement program. To date the
program has completed all required projects on time and within
budget. In the words of the federal judge, performance under the
consent decrees has been “a remarkable success.” However that
success produced several unsustainable conditions. The acute focus
on wastewater capital projects created underfunding in the drinking
water utility due to the approximately 6 to 1 capital spending ratio.
Essential asset management requirements in drinking water were not
being funded. Funding of the consent decrees required a tripling of
water and sewer rates to the point the rates were demonstrably greater
than the U.S. EPA’s affordability criteria. The fund was highly leveraged
with debt service coverage accounting for approximately 40 percent of
DWM’s annual budget.
The City initiated conversations with U.S. EPA Region IV regarding a
modification of the consent decrees to facilitate a balanced,
sustainable operation and funding of the comprehensive utility system.
The City and MWH developed an asset management based approach
that focused on the capital and operating budget requirements to
continue environmental and operational improvements while balancing
user rates and affordability with a 20-year financial model. The process
used in the consent decree modification directly parallels the IPF
guidance published by U.S. EPA in June 2012.
The outcome was an integrated plan for drinking water and
wastewater operations and investment that was based primarily on the
cash funding of capital programs, annual rate increases restricted to
the 2 to 3 percent range, a gradual improvement in service
affordability, and a 13-year extension of the consent decree. The
regulatory agencies and the Department of Justice agreed to the
proposed modification with the U.S. District Court’s approval received
in September 2012. 16

18. Lima, Ohio
The City of Lima, with a service area population of approximately
44,000 people, owns a wastewater collection system consisting of
over 200 miles of combined and sanitary sewers tributary to a 53
MGD wastewater treatment plant, with the inner ring of the City
consisting primarily of combined sewers while the separate sanitary
sewers are predominantly in the outer ring areas of the City. In the
combined sewer area, the City operates five regulating structures
that control the majority of CSOs that discharge to the Ottawa River.
In the separate system, there are 32 constructed SSO structures for
which the City is under Administrative Orders to develop an
abatement plan. MWH is leading the City’s LTCP development and
providing support in regulatory negotiations.
The City submitted their original LTCP to Ohio EPA in July 1998 and
it was subsequently approved in December 1999. At that time the
City proceeded with a series of steps towards implementing both
Nine Minimum Control measures, such as installation of fine screens
on the five major Ottawa River CSOs, as well the early stages of the
17
Lima, Ohio

19. LTCP itself. One such step was purchasing the land slated for construction of a large CSO storage tank, the cornerstone of the overall plan.
Well on their way toward implementing what was intended to be a 10-year program of CSO control improvements, the City was notified in the
spring of 2005 by U.S. EPA that the original LTCP would have to be updated to better comply with CSO Policy and the City should refrain
from doing any further improvements. Six years later, after a painstaking, iterative process of piecemeal submittals of various LTCP
components, following U.S. EPA’s preferred “Develop and Implement” approach to the LTCP/consent decree process, the City has submitted
a revised draft LTCP that leans heavily on affordability provisions allowed under U.S. EPA’s recently issued IPF guidelines.
By any reasonable measure, the economic wherewithal of Lima is financially stressed:
• Unemployment has been increasing and
recently was over 16 percent when the
national unemployment rate was nearly nine
percent lower.
• Median Household Income (MHI) in the City of
Lima is less than $30,000, which is only about
58 percent of national MHI.
• In 2009 in the United States, 15.1 percent of
the population earned less than poverty level
while Lima had 32.2 percent of the population
earning below poverty level and 16.8 percent
earning below ½ of the poverty level.
• The estimated population of Lima has steadily
shrunk every decade since 1970.
• Residential, commercial and industrial
wastewater flow has steadily decreased for several years, severely limiting the operating revenue the City can collect to pay wastewater
costs.
• As population, jobs, and incomes have declined over recent years, the City of Lima has significantly reduced its manpower by 28 percent
citywide to balance its budget to ensure its ability to fund its most critical needs.
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20. Irrespective of the above issues, Lima has
never been in default on bond payments nor
been significantly downgraded on its
outstanding financial obligations. On the
contrary, Lima has demonstrated strong
political will in passing sewer rate increases
even when costs have not increased or
increased only nominally, but the City cannot
afford to take on financial burdens of such
magnitude that would risk municipal
insolvency or receivership.
These affordability considerations, combined
with project scheduling to maximize
improvement in water quality of the Ottawa
River, resulted in a revised draft LTCP
incorporating the following key elements:
• Lima is recommending both CSO and SSO
control goals in their LTCP/Consent Decree
process in order to take advantage of
affordability considerations now and to
avoid having to face a costly separate
consent decree negotiation process
focusing solely on SSO issues at a later
date.
• Lima’s affordability-based proposed plan
consists of a nine overflow per year control
level for CSOs and a 5-year control level for
SSO abatement.
• Lima is proposing a 28 year implementation
schedule which pushes SSO work out to the
end (prioritizing the water quality benefits of
CSO control measures).
• Lima is pursuing “off ramp” language in their
consent decree related to the validity of
assumptions regarding household incomes
and income growth rates over the course of
the implementation period.
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Scenes from
Lima, Ohio

21. Baltimore at night Baltimore
The City of Baltimore, Maryland, is operating
under the terms of a 2002 Consent Decree with
the U.S. EPA and the Maryland Department of
the Environment (MDE). The MWH/LBWS Joint
Venture is currently leading the Wet Weather
Compliance Program for the City. In addition to
the challenges in meeting the terms of the
consent decree, the City faces major
challenges in maintaining compliance for the
water and surface water (e.g., storm water)
infrastructure systems. The City’s two oldest
water filtration plants were placed in service in
1915 and 1926 with the City’s “new” plant
placed in service in 1956. In the near future, the
City must begin construction on a new, more
expensive membrane filtration plant to provide
additional reliability and source water
diversification for the City’s raw water supply as
well as to take one of the older plants off-line for
20

22. much needed rehabilitation. Meanwhile, the City’s water transmission and distribution system consists predominantly of cast iron pipe that is
aging and increasingly prone to leaks and breaks. The City’s two wastewater treatment plants have been upgraded to incorporate higher
levels of nutrient removal to each receiving stream. However, it is expected that additional more stringent effluent limitations will be required
in the future. Future, he City is subject to municipal separate storm sewer system (MS4) permits and total maximum daily load (TMDL) waste
load allocations. Compliance with the MS4 best management practices (BMP) and TMDL requirements will require the City to either treat
storm water or reduce runoff from more than 20 percent of the City’s impervious areas. These are aggressive goals for a largely developed
urban area like Baltimore with a number of urban streams that have been turned from natural drainage ways into paved and channelized
streams. Returning these streams to a natural state that can buffer and protect the environmental from pollution is neither easy nor cheap.
Faced with these costly projects, restrictive budgets and a rate base with limited capacity to afford water and sewer rate increases, the City
wants to ensure financial expenditures provide real benefits to City citizens and customers. Roughly 26 percent of the City’s residents have
income levels that are below the federal poverty line, with 12 percent below half of the federal poverty line. The EPA’s new IPF approach was
viewed as a possible mechanism to facilitate this goal.
In 2012, MWH, in partnership with top level
managers in the Bureau of Water and Wastewater
and with the LBWS JV team members, developed
the City’s IPF to integrate not only the wastewater
and storm water obligations under the Clean
Water Act (CWA), but the drinking water
obligations under the Safe Drinking Water Act
(SDWA). The resulting IPF is a multi-criteria model
is based on a triple bottom line (TBL) approach
such that all projects are evaluated against
economic, environmental and social criteria.
21
When we applied this approach in Baltimore, the City’s projects were re- distributed in
a more balanced manner - while still meeting their financial, technical, regulatory, and
community requirements

23. Baltimore’s IPF evaluated various scenarios that are evaluated
across 21 criteria, which were categorized into a modified TBL
categorization with the addition of a Project Delivery category for
what is in effect a Quadruple Bottom Line (QBL) approach. The
scoring processes for the 21 defined criteria includes both
quantitative data and qualitative information. Scenarios developed
by stakeholder input and regulatory requirements model different
infrastructure configuration schemes. Criteria are weighted
differently in the various scenarios to allow for each scenario to
generate different “what-if” project implementation sequences.
Financial modeling is overlaid to consider various possible funding
scenarios and rate payer impacts. The process is designed to
promote innovative solutions such as green infrastructure and
adaptive management allowing municipalities to address more
serious water quality and public health problems sooner.
Based on the preliminary CIP project prioritization results prior to
entering into the full stakeholder input process, the City has
achieved a significant redistribution of project types. The current to
50 CIP project list is dominated by wastewater projects while the IPF
top 50 project list significantly increases the storm water projects
and has an increased number of drinking water projects, particularly
for the distribution system.
Implementation of the IPF prioritization process will require approval
of both MDE and U.S. EPA Region III and a renegotiation of the
existing consent decree. Additional changes to the City’s NPDES
permits may also be required.
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24. CONCLUSION
5

25. MWH is a leader in implementing the U.S. EPA’s new Integrated
Municipal Stormwater and Wastewater Planning Approach
Framework. The EPA’s Integrated Planning Framework (IPF) is an
innovative response to increasing pressure from municipalities (and
utilities) relating to the financial pressure on the regulated
community particularly for Clean Water Act permits and enforcement
initiatives. This is the first time the U.S. EPA has formally
acknowledged affordability issues exist since the guidance on
affordability for Long Term Control Plans (LTCPs) for combined
sewer overflow (CSO) abatement and may well be considered a
historic “turning point” event should the potential associated with
this regulatory initiative come to fruition.
In our role as Program Manager for the Baltimore Wet Weather
Compliance Program, MWH (and our Joint Venture partner, Louis
Bregger Water Services) was sole sourced to complete what will be
one of the first IPFs to be completed in the country. Further, MWH, in
our role on the Indianapolis Clean Stream Team, was instrumental in
helping the City of Indianapolis achieve a modified consent decree
and associated cost savings that served as one of the first turning
points in achieving U.S. EPA’s noteworthy change in regulatory
posture. Similarly, MWH (and our joint venture partner KHAFRA) was
instrumental in assisting the City of Atlanta in achieving a 13-year
consent decree extension with arguments that paralleled portions of
the new IPF guidance. Additionally, MWH, as lead on the LTCP
team, revised the draft LTCP for the City of Lima (Ohio) based on
benefit-related arguments as allowed under the IPF guidance.
Mayors from both Indianapolis and Lima, assisted by MWH as
needed, worked closely with the U.S. Conference of Mayors (USCM)
and with the National Association of Clean Water Agencies
(NACWA) in exerting political pressure on the U.S. EPA both to
negotiate favorable terms for their communities as well as to change
historic regulatory positions related to Clean Water Act enforcement
throughout the country.
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26. For further information, please contact the following
MWH staff:
Bob Woodhouse +1 415 430 1809
Robyn McGuckin +1 303 533 1976
Lynette Cardoch +1 786 553 6633
Sean Searles +1 404 688 1083