At any given time, municipal wastewater and stormwater managers may be subject to an array of different regulatory requirements under the Clean Water Act. All too often, however, permit language may require different types of water managers to operate in a vacuum, investing in solutions that address only one water stream even when opportunities may exist to meet multiple permit obligations with a single project.
Intending to create greater regulatory flexibility and to make capital-intensive infrastructure projects more viable for municipalities, the U.S. Environmental Protection Agency (EPA) has promoted an approach called integrated planning since 2012. Using an integrated plan, municipalities can fast-track solutions to the most pressing water quality problems facing their community while minimizing costs and maximizing cooperation.
The integrated planning concept has gained considerable momentum in recent years. In 2019, the Water Infrastructure and Improvement Act became law, which amended the Clean Water Act to specify integrated planning as a viable option to meet regulatory requirements. In June 2021, EPA issued a report to U.S. Congress describing existing uses of integrated planning among municipalities as well as ways to further promote its adoption. Meanwhile, experts with the University of North Carolina (UNC; Chapel Hill) Environmental Finance Center have been working with the University of Maryland (College Park) and EPA to introduce a new resource that aims to facilitate and expedite the integrated planning process for interested municipalities.
“Integrated planning allows a community to take a very holistic approach to their regulatory compliance,” explained Evan Kirk, acting senior project director at the UNC Environmental Finance Center, during an August 17 Water Environment Federation (WEF; Alexandria, Virginia) Words on Water podcast interview. “Not only does integrated planning help these municipalities balance their Clean Water Act goals, but also, every dollar spent on addressing Clean Water Act goals is achieving more than it would under the traditional approach.”
A Fit for Communities Large and Small
EPA’s Integrated Planning Framework, released in 2012, facilitates the integrated planning process by specifying six steps municipalities can take to develop plans that meet multiple water quality goals, involve a diversity of relevant stakeholders, and remain adaptable to changing regulatory requirements.
The first three steps involve taking stock of existing wastewater and stormwater infrastructure, as well as its current ability to meet regulatory requirements specified by wastewater treatment permits, MS4 permits, CSO and SSO reduction programs, nutrient-emission regulations or TMDLs, and/or consent decrees. Kirk emphasized that the best candidates for integrated planning are municipalities subject to several of these different regulatory requirements — but that the practice can be a valuable decision-support tool for communities of all sizes.
“Basically, the more complicated a community is, the more they might benefit from integrated planning,” Kirk said. “But small communities can benefit as well, and we’re trying to highlight that.”
Step four involves developing, evaluating, and selecting infrastructure options that advance multiple permit obligations, which is where the work spearheaded by Kirk and his colleagues comes into play. Beginning with a questionnaire about permit requirements, the team consults with municipalities to explore cost-effective options such as green infrastructure that address both stormwater and wastewater issues. After the consultation, municipalities will be better equipped to proceed to steps five and six — measuring performance and adapting the plan based on new regulatory requirements.
“We’ll have an in-depth conversation with you, we’ll point you to resources, we’ll exchange emails if you have questions, and we’ll get to see what the integrated planning process can do for you,” Kirk said.
After its release in the coming months, the tool will be available on the UNC Environmental Finance Center website, Kirk said.
Lagging Adoption Despite Wide Applications
Several U.S. municipalities have already adopted integrated plans in order to optimize their wastewater and stormwater management programs, including Springfield, Massachusetts; Lima, Ohio; Oxnard, California; and Virginia Beach, Virginia. According to EPA’s report to Congress, however, only 27 U.S. municipalities have taken advantage of integrated planning to meet their permit obligations since the framework’s 2012 release.
In Akron, Ohio, for example, incorporating an integrated plan into a federal consent decree to increase wastewater treatment volumes entailed revised project sequencing, a greater focus on green infrastructure, and partial sewer separation. According to the EPA report, adopting the plan saved the city about $158 million USD in capital costs between 2015 and 2019 compared to pre-integrated plan projections, while treating an additional 3.1 billion L (826 million gal) of wastewater beyond the volume required by the consent decree.
In Richmond, Virginia, water managers sought to use integrated planning to satisfy bacteria, nitrogen, phosphorus, and sediment control requirements mandated by three separate water quality permits focused on the city’s water resource recovery facilities, CSOs, and stormwater discharges. With a focus on green infrastructure, the city’s plan champions pollutant source control rather than discharge management. Since the city began implementing the plan, according to the EPA report, it has installed enough green infrastructure to keep runoff generated throughout nearly 8 hectares (20 acres) from reaching its sewer systems, keeping costs minimal while maximizing pollutant control.
Top image courtesy of ds_30/Pixabay