The US Integrated Planning Bill: 10 steps municipalities can take to reap the benefits
January 21, 2020
January 21, 2020
Recent legislation will enable municipalities to develop integrated approaches to wastewater and stormwater management
The Clean Water Act (CWA) of 1972 was a pivotal moment in the fight to protect public waters in the United States. But rising populations and aging infrastructure have made it harder for municipalities to keep up with the regulations set forth by the CWA.
Responding to advocacy from the US Conference of Mayors, the National Association of Clean Water Agencies, and other industry groups, the U.S. Environmental Protection Agency (EPA) introduced the Integrated Municipal Stormwater and Wastewater Planning Approach Framework (IPF) in 2012, which offered flexibilities to municipalities struggling to meet their CWA obligations.
In late 2018, the U.S. Congress passed the Water Infrastructure Improvement Act (WIIA), or the Integrated Planning Bill. That essentially codifies the EPA’s 2012 framework into law and provides municipalities with the opportunity to develop integrated approaches to wastewater and stormwater management.
This added flexibility allows municipalities to prioritize projects and investments based on water quality effects, making CWA compliance more holistic and potentially reducing the overall costs of compliance. What’s more, the bill directs the EPA to work with other federal agencies, state and local governments, and the private sector to create integrated plans that consider innovative projects to reclaim, recycle, or reuse water and promote the use of green infrastructure, which can be an effective solution to complement and extend the life of our current gray infrastructure.
The following step-by-step guide captures comprehensive services/tasks that may be required, including due diligence tasks when creating an integrated plan (IP).
1. Perform an impact evaluation on current wastewater, stormwater, and drinking water compliance programs: An initial investigation will help a municipality or utility to understand its current regulatory obligations under state and federal permits and how the development of an integrated plan may help reprioritize compliance requirements.
2. Conduct stakeholder workshop sessions: Facilitate an in-depth stakeholder-coordination process to develop a shared vision on potential benefits from the provisions of the new IP rule; develop strategies for building public support; and identify organizational collaborations necessary to successfully develop an integrated plan.
3. Develop a comprehensive action plan: Identify drivers for development of an integrated plan; determine overall strategy with specific goals and necessary tactical actions; and define anticipated outcomes of the plan’s implementation.
4. Assess organizational alignment needs: Determine internal and external stakeholder involvement necessary for effective integrated plan development; identify organizational “ownership” for leading plan development; and define internal levels of commitment and responsibility for plan development and implementation thereafter.
5. Perform integrated financial evaluations: Identify current and future financial resources and constraints necessary to meet all utility obligations in an integrated fashion. Perform—or update—a financial capability assessment given current priorities, commitments, and state and federal regulatory obligations for all water, wastewater, and stormwater programs.
6. Assist regulatory coordination: Develop a strategic plan to address existing and potential future regulatory obligations as part of the integrated planning process. Develop a plan for engagement of regulatory authorities around benefits and goals/outcomes of the integrated plan.
7. Develop an integrated systems model: Evaluate efficacy of existing hydraulic and water quality models for integrated systems analyses to support envisioned integrated plan development. Identify improvements, enhancements, and upgrades required to develop data inputs for plan development; and prepare an integrated systems model.
8. Conduct an integrated performance assessment of wastewater and stormwater systems: Apply the integrated systems model to conduct performance evaluations against CWA requirements and customer-driven service level commitments.
9. Assess integrated capital improvement needs: Determine integrated systems improvements collectively to address CWA requirements. Assess benefits of an integrated plan and what changes/modifications are needed to the current capital improvement plan (CIP) definitions. Review/evaluate existing capital and operation and maintenance (O&M) investment programs and asses enhancement needs. Review/evaluate/update existing and future funding investment scenarios for capital and O&M planned expenditures.
10. Apply the integrated framework analysis for CIP implementation prioritization/schedule: Identify all ongoing and planned capital and O&M requirements for wastewater, stormwater, and drinking water systems to meet regulatory and service level commitments. Utilize a triple bottom line (or similar) scoring model to prioritize capital and O&M projects. Identify financial, operational, regulatory, and other constraints. Build a constrained optimization model to create a prioritized plan and schedule for CIP implementation with affordability at the core.
Once this analysis is complete, a utility can be best prepared to develop a plan consistent with the EPA’s IPF that includes an implementation schedule compliant with regulatory obligations. It’s also important to ensure that the plan contains balanced investments to ensure sustainable utility operations for the long term. If the plan identifies a need to reexamine existing regulatory commitments and compliance schedules, engage the appropriate regulatory agencies on how best to address modifications to existing enforcement actions or permit obligations.
Since the EPA introduced the IPF guidance in 2012, Stantec has been an integral partner in projects big and small across the country, working through a six-element strategy that mirrors the steps outlined above.
In Baltimore, Maryland, we stepped in as the City was facing significant challenges maintaining compliance for water wastewater and stormwater infrastructure systems. With tight budgets and a rate base with limited capacity to afford water and sewer rate increases, the City wanted to ensure that any financial expenditures provided real benefits to citizens—many of whom are below the poverty line.
Many wet-weather programs are reaching a point where they need to demonstrate overall efficacy of the projects completed in achieving target water quality improvements.
Stantec worked with the City to develop an integrated plan to combine wastewater and stormwater obligations under the CWA with drinking water obligations under the Safe Drinking Water Act. The resulting plan was a multi-criteria model employing, in effect, a quadruple bottom line approach. The quadruple bottom line approach included assessing project benefits using social, environmental, financial and project delivery. Innovative solutions like green infrastructure and adaptive management were incorporated into the plan, which resulted in savings of over $300 million to the City.
The City of South Bend, Indiana, while not utilizing all aspects of the IPF, recently integrated its smart sewer system into its CSO long-term control plan to ensure enhanced operation and maintenance of the system and to maximize both the use of the collection system for storage and the flow to the treatment plant. Our team assisted the City with this plan, which resulted in the elimination of dry weather overflows and considerable improvement to river water quality. The City is now utilizing their integrated plan in working with the EPA and the State of Indiana to modify its existing Consent-Decree.
In Springfield, Massachusetts, our financial services team prepared long-term financial planning scenarios following IPF guidelines to evaluate the rate increases necessary to meet the City’s financial metrics and fund its CSO long-term control plan. By using actual billing data for all water services, the latest census information, geographic mapping tools, and our collective industry experience, we are better able to understand what is affordable and assist in developing the approach that impacts ratepayers the least.
Many wet-weather programs are reaching a point where they need to demonstrate overall efficacy of the projects completed in achieving target water quality improvements—and integrated planning is thought to be the mechanism to get us there.
We envision technology and practices advancing to support a more holistic watershed management approach that considers capture of stormwater resources for beneficial reuse. Integrated plans will further evolve to make better/optimal use of existing infrastructure and planned capital works.
We also believe the future evolution of integrated planning needs to go beyond the current WIIA/IP framework and formally integrate all utility asset infrastructure in the development of a truly integrated plan. To ensure long-term sustainability of utility operations, decision-makers must be able to evaluate competing priorities and financial obligations to make balanced investments across their asset base.