In October 2014, the EPA provided technical assistance funding to five communities across the United States to help those municipalities “develop components of integrated plans for wastewater and stormwater management.” One of those communities, Springfield, Missouri, recently had their sewer overflow control plan, which uses an integrated planning approach, approved by their state’s Department of Natural Resources. This is an important step forward for communities interested in cost-saving and alternative approaches to clean water compliance. Many communities are in the planning stages with their integrated approaches, but few have succeeded in getting integrated plans reflected in their various NPDES permits.
Still, it is inevitable that the future will include more integrated planning and permits. Traditional approaches to solving water quality problems are increasingly unaffordable for municipalities with many communities focusing significant time and resources on actions with minimal water quality benefit while significant pollutant discharges go unaddressed. Integrated water resources planning offers communities an opportunity to break down siloed approaches and instead define an alternative and affordable path to meeting water quality requirements and restoration of waters by focusing on the most cost-effective and environmentally beneficial projects first.
Recently, I published an article in WE&T Magazine, titled “The Promised and the Practical: A New England Perspective on Integrated Planning and Permitting,” which I co-authored with William Taylor, a partner at Pierce Atwood LLP. The article (WEF membership login required) explores in detail the potential for implementing integrated planning approaches to create actionable and sustainable clean water permits and goals, particularly in Durham, New Hampshire and Portland, Maine. (Durham was one of the communities that received technical assistance funding from the EPA in 2014.)
Integrated planning in New England faces significant challenges. Unique town-based jurisdictions and Home Rule, aged infrastructure, the public’s lack of understanding of utility services and rate structures and limited cost-benefit analysis guidance will likely slow the development of integrated plans. However, as the article explains, the promise of integrated planning can be realized with clear guidance from regulators on the benefit of nontraditional pollution abatement actions, which are typically required in MS4 General Permits, but often with uncertain pollutant load reduction benefits.
What is Integrated Planning?
Typically, governing agencies regulate stormwater and wastewater through largely separate frameworks with independent permitting, requirements for measureable results, and reporting obligations. The US Environmental Protection Agency has provided an alternative planning approach, the Integrated Municipal Stormwater and Wastewater Planning Approach Framework, to meet the complex operational, regulatory, and environmental stormwater and wastewater challenges facing municipalities across the country. Fundamentally, the Integrated Planning and Permitting Policy, known as IP3, offers a way to examine water resource pollution holistically. Under IP3, a community can define an alternative path to implement the most cost-effective solutions to address pollution. To learn more about the basics of integrated planning, see this previous entry on our blog.