First Things First: Framework Provides Integrated, Priority-Driven Approach to Wet Weather Management
EPA's relatively new integrated planning framework sets the stage for a common sense approach to meeting water quality objectives.
Here's what you, as wastewater professionals and stewards of the environment, already know: meeting the obligations of the Clean Water Act, protecting your community from public health threats, maintaining your current infrastructure, and fxing unexpected failures - all while simultaneously trying to keep rates affordable for your customers - is a Herculean task.
Here's what you may not know: U.S. EPA is listening.
Last June, the agency released its Integrated Municipal Stormwater and Wastewater Planning Approach Framework. You may have heard it called the Integrated Planning and Permitting Policy (or IP3), or perhaps simply referred to as integrated planning. Myriad monikers aside, it lays out a strategy for EPA regional offces, states, and local governments to work together to develop integrated stormwater and wastewater management plans based on a prioritized critical path.
Traditionally, the regulatory approach has been quite rigid. "EPA and the state would typically allow 20 years maximum for combined sewer overfow compliance," explained Amanda Waters, Government Affairs Counsel for the Water Environment Federation (WEF). Sanitary sewer overfows would have a fxed deadline as well. "In essence, the traditional plan would set a deadline in advance of even looking at the engineering and the utility's specifc data," she said.
"The idea with integrated planning is to take a holistic look at all your obligations in the clean water context, lay those out, and fgure out which ones are the most important," said Waters. "Those should be done frst. And those that don't have a big environmental return on investment can be pushed out to later in the year."
The integrated planning framework doesn't revise the Clean Water Act or affect any statutes, laws or guidance. Rather, it builds fexibility into the existing statutory framework.
"At some point we need to be able to prioritize our work," said Howard Neukrug, Water Commissioner for the City of Philadelphia. "Unfortunately, we can't snap our fngers to spend unlimited money to solve so many problems. The problems are just too big."
Philadelphia is an early adopter of the integrated planning approach and one of its biggest supporters. But to Philly, the concept is not new.
"Integrated planning and these frameworks are something we've been trying to pull EPA towards for 15 years," he said. "We are so in favor of this. And clearly EPA has been in favor of it for a long time, too. They just haven't been able to fgure out how to do it within their legislative and regulatory constraints." Until now.
"It allows communities the ability to prioritize and sequence projects based on an analysis of which will give the most signifcant environmental return on investment," explained Waters.
The program is completely voluntary. "Utilities don't have to do it," said Waters. "But we think there's a place for this type of planning and common sense approach in every utility."
There's certainly been a place for it in Philadelphia, where the CSO remediation program has become what Neukrug called "a super MS4 program on steroids."
Philly's goal is simple: keep water out of the sewer rather than expand the system.
"What we're looking to do with our CSO program is along the same the philosophy as the MS4 program," he explained, "which is to manage stormwater runoff before it gets into the system to keep manageable levels of water going into the streams."
"So it's very much the same thing with the CSO program," he continued. "Our 'integration' is taking the MS4 program, expanding it, and also laying it over the CSO program."
Lima, Ohio, Mayor David Berger has been intimately involved in the issue of integrated planning. He and his peers at the U.S. Conference of Mayors (USCM) have actively pursued discussions with the U.S. EPA for many years, driven by their concern with the agency's traditionally heavy-handed approaches to compliance.
"At the beginning of the process," he said, "we wrote a series of white papers on half a dozen different topics describing what we believe are the fexibilities that already exist in the Clean Water Act and Safe Drinking Water Act." USCM maintained that the laws inherently provided fexibility that EPA's policies and implementation practices ignored. "The discretion is there. Let's use it for the kind of fexibility that these cities need."
"We argued that the agency needed to rethink its policies," he explained. And so they did, in the form of the integrated planning framework.
For the City of Lima, OH, it was an opportunity that couldn't have come soon enough. "We've been in the process for nearly a decade now trying to get approval on our Long Term Control Plan," he explained. "We had one approved by Ohio EPA in the late 90s, but fve years later, U.S. EPA preempted it. We've been engaged in this ongoing discussion since."
Lima originally agreed to about $60 million dollars in a variety of CSO-related improvements. Today, the price tag hovers at around $100 million.
"Our perspective of course has been that there's only so much we can afford to do," he said. "It affects people on fxed incomes and poor households grievously so we've resisted committing to something that we don't believe could be done.
"When the opportunity for the integrated plan came along, we decided that we would pursue it."
Lima and Philadelphia are two of only a handful of cities that have, as of yet, ventured forth to take advantage of the new framework. Part of the reason is simply that the program is so new.
"Not everybody knows about this opportunity," said Waters. "Even amongst state regulators, many of them may have heard of it but they don't know what it looks like or what to do with it."
And they also have decades of experience working against them. After all, water and wastewater systems were developed based on historical trends and not necessarily best planning trends. "Because of the segmented way that the laws and regulations have been written and the segmented way the utilities have been formed," Neukrug observed, "it's very diffcult to back off all that and say, 'Let's do integrated planning.'"
But that shouldn't deter utilities. His advice: Be persistent with regulators to ensure that they carry out what the EPA has always understood to be the most important objective - holistic total water management. "It is so clearly the direction that the industry and the regulators need to move in," he said.
FIRST AND FOREMOST
The frst step, Neukrug suggested, is for utilities to fully recognize the value and importance of integrated planning in their own work.
Mayor Berger agreed. "It's worthwhile for all cities who are struggling, even if they are in the middle of implementing projects, to step back and take a look at whether this integrated approach doesn't offer them some real opportunities for saving money and for accomplishing the goals of the CWA and SDWA in a quicker and more affordable way."
"It takes leadership, education, and vision to do it," said Neukrug. "Cities, utilities, and regulators need to take the lead and show how this is done."
Once a champion steps forward, the next step is crucial: Know your system.
"If you don't, you're not going to be able to effectively take advantage of this opportunity," said Waters, "because you're not going to be able to show how you're impacting water quality unless you know what's already happening in your streams and water bodies."
Some questions to consider: What is the state of your asset management program? What do you know you need to do with regard to infrastructure, replacement, or upgrade? How are you dealing with population growth? What is on the horizon with regard to stormwater and nutrients? When you do have an overfow event, are you exceeding water quality standards? Were you already exceeding water quality standards, even in dry conditions? How long is that lasting?
"EPA is providing fexibility," said Seth Brown, WEF's Stormwater Program and Policy Manager, "but they are doing so in a way that says you have to come to the table with all of your ducks in a row. You need to be able to make the case pretty strongly as I understand it."
"Utilities need to have a good, holistic understanding of their world," agreed Waters. "If they don't have some baseline monitoring of their streams then they need to hook up with an organization like USGS that might have data," she suggested.
Having this information is what enables the integrated framework to be so fexible. Consider, for example, a sewer overfow in an area with a high-density population, where there are signifcant public health risks, versus a larger overfow in a very remote area with more opportunity for dilution and minimal population impact. Spending money to control the former may rise up on the list of priorities despite the fact that the latter is a larger overfow - but you can't really make an informed decision without the pertinent analysis.
Making this informed decision involves more than just the water or wastewater utility: All stakeholders need to be brought into the discussion.
"To plan for new water treatment plants, a new storm food relief program, a CSO program," Neukrug said, "you really need to have all the players dealing with water issues - and sometimes land and regulatory issues - at the table talking and fguring out what the best strategy is for integrating everyone's needs."
Be forewarned: talk ain't cheap. In Lima, OH, nearly $8 million has been spent over the past decade on attorney and engineering fees to develop its proposed CSO control plan. "It's a very expensive process for us," he said. "And that expenditure has not cleaned one additional drop of water."
Regardless, Mayor Berger still views integrated planning as a very positive step in the right direction. "Folks really do need to take it seriously as an opportunity," he said.
One of its strongest features is that it allows for adaptive iterative management - or do-overs, if you will.
Let's say you have a plan in place that you're executing, but at some point, you fnd it's not achieving the results you expected. Under the integrated planning framework, you should be able to reopen and reprioritize. Similarly, if something comes down the pike - perhaps a new regulation comes into play that is higher priority or is mandatory - you could, theoretically, reopen your planning process.
"It's a much more collaborative, iterative process," said Waters, "that takes into account changing circumstances, new technology, and innovation."
That's a big deal for Lima, OH, where the local economy had experienced signifcant decline. "We've struggled and we've lost population," explained Mayor Berger. "We are proposing a plan that has decades-long implementation schedules, but if we should continue to lose population at the rate that we have, then there won't be any way to accomplish what's now laid out in the plan," he said. "We are willing to do all that we can in the spirit of good stewardship," he said, "but, if necessary, we have to be in a position to reopen the plan and reset the timetable and the scope of what's intended."
"You can't know in 2013 everything that you're supposed to do in 2030," said Neukrug. "Economies get better, get worse, climate changes, demographics change, development happens, new innovations come along. We need to be adaptive and fexible moving forward." This really is something that could not only save utilities money," Waters pointed out, "but also ensures their money is spent more effciently and effectively on behalf of their rate payers. It's something that every utility should be analyzing."
A Plan Tinged with Green
"A big difference with this integrated planning framework is the real encouragement to incorporate green infrastructure and sustainable practices where applicable," said Waters. Green doesn't always mean cheaper, Waters acknowledged, but when you consider all the added benefits - onsite stormwater management, aesthetics, heat island reduction - "it's the smarter approach to deal with the increasingly urbanized world that we live in," she said.
Green infrastructure is a big part of the solution for a city like Philadelphia, where a $2 billion partnership agreement with EPA supports the city moving forward with green infrastructure as a solution for CSO challenges. "And it's doing it within the perspective of the integrated planning program," said Neukrug.
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