by Matt Harrison
The U.S. Environmental Protection Agency (EPA) released an updated ‘Integrated Municipal Stormwater and Wastewater Planning Approach Framework’ on June 12. The framework is designed to assist states and municipalities in prioritizing projects and ensuring compliance with Clean Water Act requirements. This framework is the outcome of a long process involving stakeholder feedback at workshops across the country, the initial draft, and additional stakeholder feedback. The draft framework and stakeholder process were described in a WOWW post earlier this year.
The framework engenders an approach to planning and prioritization that integrates various aspects of resource management including regulation, finance, evaluation of alternatives, and stakeholder engagement. The intent of this framework is to provide a more flexible approach to water quality issues and to facilitate the implementation of best management practices or other innovative solutions.
Like the draft framework issued in January of this year, the updated version released last month establishes the overarching and guiding principles of integrated planning, six elements of an integrated plan, and two means of implementation. As noted in the previous WOWW post, about the draft version, “[t]he overarching principles indicate that the process will maintain existing regulatory standards, will address the most pressing health and environmental issues first, and will give the municipality the responsibility to develop an integrated plan, if desired.” The updated version goes on to state that innovative technologies, including green infrastructure projects, may be “fundamental” aspects of integrated planning solutions. As in the draft iteration, the eight principles guiding integrated planning are: state involvement, flexibility, sequencing, innovation, community impacts, existing regulations, financial strategies, and stakeholder input. However, the language about innovation included exhortations to implement green infrastructure solutions “where they provide more sustainable solutions for municipal wet weather control.”
The elements of the integrated plans include: 1) a description of issues the plan will address; 2) a description of wastewater and stormwater conditions; 3) a process for community involvement; 4) a process for evaluating and selecting alternatives and an implementation schedule; 5) approaches to measuring success; and 6) improvements to the plan. Most of these elements contain substantive updates from the draft version that are likely to enhance the environmental and social utility of the framework. For example, descriptions of wastewater and stormwater conditions were updated to consider flows in and from the systems under consideration, which will result in a much more accurate project overview with significant potential impacts to the prioritization function of the framework. The process for community involvement now includes recommendations to make relevant new information available to the public and provide opportunities for feedback on modifications of the plan, which may potentially result in a more collaborative municipal project that incorporates the interests and needs of various stakeholders. The process for evaluating and selecting alternatives and an implementation schedule was updated to recommend that the description of project priorities describe how those priorities may adversely impact public health, water quality, and municipal financial capability. This addition increases the likelihood that projects will be evaluated on both their merits and liabilities. Measurements of success were updated to recommend the evaluation of innovative measures, including green infrastructure, to ascertain best design and management practices as well as identify barriers to wider implementation, which may ultimately lead to the scaling up of green infrastructure and other innovative solutions. Finally, the revised framework included an additional element to the draft version, “Improvements to the Plan.” Here, the updates include recommendations to evaluate modifications to ongoing projects and schedules. All of these updates serve the framework by making sure it is more comprehensive, more collaborative, and ultimately more effective.
The most significant changes to the framework are to its “Implementation” section, which, as noted in the earlier WOWW post, seemed to be the weakest part of the draft framework. However, most of the updates in this area pertain to considerations for incorporating integrated plans into enforcement actions. While these updates remain somewhat abstract—it is not clear that these considerations will necessarily translate to effective enforcement—the list is a notable improvement that was responsive to many of the concerns about the draft, and will guide decision-making through the implementation phase.
Here in Northeastern Illinois, the Village of Lake Zurich is on the ground leading the way in looking at integrated planning for its municipal and wastewater systems. The Metropolitan Planning Council, in partnership with Chicago Metropolitan Agency for Planning, the Center for Neighborhood Technology, and Illinois-Indiana Sea Grant, just released a report detailing recommendations for an integrated water resources planning process for the Village. The report provides a real-life example of the framework’s utility. However, many municipalities lack the human and capital resources to implement such innovative solutions absent new homegrown revenue streams or federal financial assistance.
This framework is an important tool for encouraging innovation and strategic planning, and it is clear that the EPA listened to a lot of the feedback provided by stakeholders during the comment period. However, without linking funding to application of the framework, it remains unclear whether communities will have sufficient incentive to apply the framework to compliance decisions.