Richmond, Virginia
Richmond's business district seen from the south bank of the James River,
just above the river's fa!! line. Photo courtesy of West Cary Group.
Richmond is the capital of Virginia, home to about 227,000 people. The James River,
Virginia's largest river and the largest tributary to the Chesapeake Bay, runs through the
capital. The James River cuts through the heart of the city and has rapids that are popular
with boaters and Whitewater rafters.
The city of Richmond manages three water utilities: wastewater, stormwater, and drinking
water. Flows from Richmond's combined and separate sanitary sewer systems are treated
at the city's wastewater treatment facility1, which discharges into the James River. About
two-thirds of Richmond is served by a storm sewer system2. Stormwater discharges and
combined sewer overflows (CSOs) also flow into the James River, as well as its tributaries.
Stormwater, discharges from the wastewater treatment facility, and sewage overflows
contribute bacteria, sediment, and nutrients into Richmond's local waterways and
ultimately the Chesapeake Bay. Requirements to control and reduce pollutant discharges
to the James River and its tributaries historically were defined in many separate permits,
orders, and regulations. These separate water quality requirements included waste load
allocations associated with total maximum daily loads for bacteria, nitrogen, phosphorus,
and sediment in three separate permits: a permit for wastewater treatment facility
discharges, a wastewater treatment facility general permit for nutrients, and a permit for
stormwater discharges. Richmond also agreed to a 2005 consent order from the Virginia
Department of Environmental Quality to better regulate CSOs through a long-term control plan (LTCP).
EPA Region 3
227,000 population
Integrated Planning in Action
In 2014, Richmond began a stakeholder-driven integrated planning process to gain efficiencies in managing multiple water quality
requirements and make progress toward its clean water goals. This process emphasized stakeholder involvement because of
the importance of water quality to many groups and the general public, and because of the need to collaborate to achieve goals.
Another primary driver for Richmond was to develop a single integrated permit that complies with an aggregated waste load
allocation for the city's wastewater treatment facility, CSOs, and stormwater discharges. Both the city's and the community's goals
guided a list of comprehensive water protection-based strategies for the plan. In addition, the city evaluated the impact the existing
regulations would have on residents' water and sewer rates. Based on this evaluation, Richmond determined that it. needed to
maximize the effectiveness of funds through analysis of alternatives and sequencing of actions to address human health and water
Richmond engaged the public extensively throughout the planning process. The city developed an outreach plan and established
a technical stakeholder group that included environmental non-governmental organizations, utilities, community coalitions, city
planners, park and river protection organizations, universities, and state regulators. The city used a third-party facilitator to build a
trusting relationship with stakeholders and gather useful input. Richmond also created an outreach campaign to promote the city's
progress and educate the community about pollution prevention.
1	"Wastewater treatment facilities" (WWTFs) is a generic term for facilities that treat or manage wastewater, including publicly owned
treatment works.
2	Storm sewers and storm sewer systems can also be referred to as municipal separate storm sewer systems (MS4s). Stormwater
discharge permits can be referred to as MS4 permits.

Estimated Five-Year Costs of Richmond's Proposed Strategies
Capital Cost
Operation and
(Five Years)
Total Cost
Riparian restoration
Storm sewer green
Combined sewer
green infrastructure
Stream restoration
Planting native
Planting trees
Land conservation
Water conservation
Pollutant reduction
in storm sewer areas
* The city did not estimate costs for the land conservation strategy.
f The city will estimate operation and maintenance costs for street sweeping
and catch basin deanout activities for each of the five years of the permit.
The city's water quality managers and stakeholders produced
a common set of integrated planning goals (see box below).
For each goal, the stakeholders developed multiple objectives,
then evaluated the strategies to achieve these objectives (see
table above). For example, the pollutant reduction strategy
included illicit discharge special studies and best management
practice performance modeling to reduce pollutant discharges
in the storm sewer areas.
The city then modeled the strategies to see how effective they
would be in meeting Richmond's permit requirements, water
quality standards, and other integrated planning objectives.
The planning team developed specific metrics and associated
targets for each strategy, such as pounds of pollutant removed,
linear feet of stream restored, and acres of tree canopy planted.
The city estimated the costs of nine strategies for the first five
years of implementation would be about $39 million (see table
above). Richmond estimated a longer-term schedule for CSO
projects based on its LTCP. Capital, operation, and maintenance
for Richmond's LTCP CSO infrastructure projects would cost
more than $392 million over 30 years.
Richmond's final integrated plan describes a process the city
will use to implement individual projects to help meet its targets
while keeping affordability in mind.
In 2018, the Virginia Department of Environmental Quality
issued Richmond an integrated permit covering the wastewater
treatment facility, CSOs, and stormwater discharges. This permit
includes aggregate annual waste load limits and monitoring
requirements for all systems Richmond manages. The permit
holistically considers stormwater and combined sewer system
focused projects in light of the benefit-cost ratio and pollution
reduction benefits when choosing and implementing projects
and practices. Richmond's integrated permit implements the
RVA Clean Water Plan, which the city published in 2017 as final
documentation of the integrated planning process.
Since it began implementing the RVA Clean Water Plan,
Richmond has made significant progress toward its targets. As
of January 2020, the city had reached:
	66 percent of its target for building LTCP CSO projects.
	623 percent of its stream restoration target, restoring
13,080 more linear feet of stream than planned.
	23 percent of its green infrastructure target for the
combined sewer system.
	12 percent of its green infrastructure target for the storm
sewer system.
	30 percent of its tree planting target.
	950 percent of its land conservation target, conserving 103
more acres than planned.
Richmond's Integrated Planning Goals
	Manage wastewater and stormwater to improve the quality and
quantity of groundwater and surface water
	Protect and restore habitats to support balanced aquatic and
terrestrial communities
	Eliminate redundant activities; be more efficient and effective in
addressing wet weather impacts and improving water resources
	Work to identify projects to encourage public participation in
reducing water pollution
	Implement land conservation and restoration practices to
improve water quality
	Create partnerships to minimize costs and identify the most
environmentally beneficial projects
	Maximize water availability through efficient management of
drinking water, stormwater, and wastewater
	Provide safe, accessible, and ecologically sustainable water-
related recreational opportunities for all
	Collaborate to gather consistent high-quality data to
characterize the status and trends of water resources to gauge
the effectiveness of restoration efforts
For more information, visit EPA's integrated planning Report to Congress webpage at:
EPA-832-F-21-022 I June 2021