What Is Integrated Planning? An Intelligent Approach to Receiving Water Quality

What Is Integrated Planning? An Intelligent Approach to Receiving Water Quality

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 challenges facing municipalities across the country. Wastewater and stormwater utilities are operating with tighter budgets and struggling to maintain assets while confronting increased regulatory pressure and rising costs to comply. Despite these obstacles, communities strive to create healthy and safe environments.

In this first of a three-part series, we’ll answer the question on the minds of many city and utility managers: What is Integrated Planning and Permitting?

Fundamentally, the Integrated Planning and Permitting Policy, known as IP3, offers a way to examine water resource pollution holistically. Today, stormwater and wastewater are regulated through largely separate frameworks with independent permitting, requirements for measureable results, and reporting obligations.

Under IP3, a community can define an alternative path to implement the most cost-effective solutions to address pollution. Discrete regulatory drivers under various NPDES permits; sanitary sewer and combined sewer overflows (SSOs and CSOs); municipal separate stormwater sewer systems and publically owned treatment works discharges; and capacity, management, operations, and maintenance (CMOM) performance efforts can be integrated into one manageable plan and, ideally, one permit.

An integrated plan and permit does not waive or reduce Clean Water Act requirements, but it allows a municipality the flexibility to prioritize compliance efforts over an alternative timeframe. If addressing pollution from non-point sources provides greater environmental benefits for a lower cost than continuing to invest in reductions at point sources, an integrated plan would allow a community to avoid expensive projects that in balance contributes less to overall water quality improvement. Ultimately, all wastewater and stormwater planning can be based on a cost-per-unit pollutant removed and could be considered across NPDES obligations.

An integrated plan should include an early discussion with state or federal agency input on setting implementation priorities. Additional strategies for developing a plan include:

  • the consideration of community impacts and disproportionate burdens;
  • an assessment of core technology-based requirements within existing NPDES permits; and
  • gathering meaningful stakeholder input to assist in defining “swimmable and fishable” priorities.

The EPA has opened the door to breaking down siloed approaches to compliance. Creating an IP3 framework is voluntary, and the state or EPA is not compelled to approve an integrated plan. But it offers communities a real opportunity to create actionable and sustainable clean water permits and goals.

For more information about the IP3 framework and the EPA’s thinking on this approach, contact Paul Hogan or Zach Henderson.

In a part two of this this series, we’ll explore examples of how Woodard & Curran is helping Durham, NH develop and implement an integrated plan. Later we’ll investigate the results of those plans and several studies that quantify the value of an integrated approach.


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