S DA Report to Congress on
Integrated Plans to Comply
with the Water Infrastructure
Improvement Act of 2019
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This document was prepared by the United States Environmental Protection Agency (EPA).
Neither the United States government nor any of its employees, contractors, subcontractors,
or their employees make any warrant, expressed or implied, or assume any legal liability
or responsibility for any third party's use of or the results of such use of any information,
apparatus, product, or process discussed in this report, or represent that its use by such
party would not infringe on privately owned rights.
Questions about this document should be directed to:
&EPA
U.S. EPA Office of Wastewater Management
1200 Pennsylvania Avenue NW (4201M)
Washington, DC 20460
(202) 564-0748
Cover: Elliott Bay with Seattle skyline. Photo courtesy of Seattle Parks and Recreation.
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Contents
n
Contents I
Glossary and Abbreviations II
Executive Summary IV
1 Introduction 1
2 Background and Purpose of EPA's Integrated Planning Framework 3
3 Benefits of Integrated Planning 5
4 Integrated Plans Implemented Through
Permits, Orders, or Judicial Consent Decrees 7
New Bedford, Massachusetts 8
Springfield, Massachusetts 10
Richmond, Virginia 12
Atlanta, Georgia 14
Akron, Ohio 16
Columbus, Ohio 18
Lima, Ohio 20
Boone, Iowa 22
Johnson County, Kansas 24
Lawrence, Kansas 26
Columbia, Missouri 28
Springfield, Missouri 30
Seattle, Washington 32
Appendix A: Summary of Municipalities with Integrated Plans Implemented
Through Permits, Orders, or Judicial Consent Decrees A1
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D
Glossary and Abbreviations
Administrative Order—An enforcement document from EPA or a state that directs a municipality to take action to
come into compliance and does not involve the judicial process.
Bypass —The intentional diversion of waste streams from any portion of a treatment facility
Clean Water Act—The federal law passed by the U.S. Congress to control water pollution; it is officially titled the
Federal Water Pollution Control Act Amendments of 1972.
Combined sewer overflow (CSO)—A discharge of untreated wastewater from a combined sewer system at a point
prior to reaching the publicly owned treatment works treatment plant.
Combined sewer system—A municipal wastewater collection system owned by a state or municipality (as defined
by Section 502(4) of the Clean Water Act) that conveys sanitary wastewaters (i.e., domestic, commercial, and
industrial) and stormwater through a single pipe system to a publicly owned wastewater treatment plant.
Consent decree—A legal agreement entered into by the United States (through EPA and the Department of
Justice) and a municipality. Consent decrees are lodged with a court.
Dissolved oxygen —The oxygen freely available in water, vital for sustaining fish and other aquatic life as well as
for preventing odors. Dissolved oxygen levels are one of the most important indicators of a waterbody's ability
to support desirable aquatic life. Secondary treatment and advanced waste treatment are generally designed to
ensure adequate dissolved oxygen in waste receiving waters.
Gray infrastructure—Piped drainage and water treatment systems designed to move urban stormwater away from
the built environment.
Green infrastructure—The range of measures that use plant or soil systems, permeable pavement or
other permeable surfaces or substrates, stormwater harvest and reuse, or landscaping to store, infiltrate, or
evapotranspirate stormwater and reduce flows to sewer systems or to surface waters (Clean Water Act
Section 502).
Infiltration —Stormwater and groundwater that enter a sewer system through such means as defective pipes, pipe
joints, connections, or manholes. Infiltration levels can be higher in older sewer systems where the infrastructure
has deteriorated and where the original design, materials, and workmanship might have placed less emphasis
on minimizing infiltration. Infiltration does not include inflow, though in some systems its flow characteristics can
resemble those of inflow (i.e., flow increases rapidly during and immediately after a rainfall event, due, for example,
to a rapidly rising groundwater table).
Infiltration and inflow—The total quantity of water from both infiltration and inflow. Common strategies for
reducing infiltration and inflow can include sewer main replacements, sewer main lining, manhole upgrades, lateral
replacements, and elimination of illicit connections.
Inflow—Water, other than wastewater, that enters a sewer system from sources such as roof leaders, cellar
drains, yard drains, area drains, foundation drains, drains from springs and swampy areas, manhole covers,
cross-connections between storm drains and sanitary sewers, catch basins, cooling towers, stormwater, or other
drainage. Inflow does not include infiltration.
Long-term control plan (LTCP)—A water-quality-based CSO control plan that is ultimately intended to result in
compliance with the Clean Water Act. LTCPs consider the site-specific nature of CSOs and evaluate the cost-
effectiveness of a range of controls.
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Glossary and Abbreviations
Municipal separate storm sewer system (MS4)—A conveyance or system of conveyances (including roads with
drainage systems, municipal streets, catch basins, curbs, gutters, ditches, man-made channels, or storm drains):
(i) Owned or operated by a State, city, town, borough, county, parish, district, association, or other public body
(created by or pursuant to State law) having jurisdiction over disposal of sewage, industrial wastes, storm water, or
other wastes, including special districts under State law such as a sewer district, flood control district or drainage
district, or similar entity, or an Indian tribe or an authorized Indian tribal organization, or a designated and approved
management agency under Section 208 of the Clean Water Act that discharges to waters of the United States; (ii)
Designed or used for collecting or conveying storm water; (iii) Which is not a combined sewer; and (iv) Which is not
part of a publicly owned treatment works (40 CFR § 122.26).
Publicly owned treatment works—A treatment works as defined by Section 212 of the Clean Water Act, which is
owned by a State or municipality (as defined by Section 502(4) of the Clean Water Act). This definition includes any
devices and systems used in the storage, treatment, recycling and reclamation of municipal sewage or industrial
wastes of a liquid nature. It also includes sewers, pipes and other conveyances only if they convey wastewater
to a publicly owned treatment works treatment plant. The term also means the municipality as defined in Section
502(4) of the Clean Water Act, which has jurisdiction over the indirect discharges to and the discharges from such a
treatment works (40 CFR § 403.3(q)).
Publicly owned treatment works treatment plant—That portion of the publicly owned treatment works which is
designed to provide treatment (including recycling and reclamation) of municipal sewage and industrial waste
(40 CFR § 403.3(r)).
Sanitary sewer overflow (SSO)—An untreated or partially treated sewage release from a sanitary sewer system
prior to reaching the publicly owned treatment works treatment plant.
Sanitary sewer system—A municipal wastewater collection system that conveys domestic, commercial, and
industrial wastewater (as well as limited amounts of infiltrated groundwater and stormwater) to a wastewater
treatment facility. Areas served by sanitary sewer systems often have separate storm sewer systems to collect and
convey stormwater from rainfall and snowmelt.
Sewer separation —The practice of separating a combined sewer system into separate sewers for sanitary and
stormwater flows.
Storm sewer system—A municipal stormwater collection system that conveys stormwater, separate from sewage.
Total maximum daily load (TMDL) —The calculation of the maximum amount of a pollutant allowed to enter
a waterbody so that the waterbody will meet and continue to meet water quality standards for that particular
pollutant. A TMDL determines a pollutant load reduction target and allocates the necessary pollutant load
reductions to the source(s) of the pollutant.
Waste load allocation —The portion of a receiving water's loading capacity that is allocated to one of its existing or
future point source discharges of one or more pollutants. Waste load allocations constitute a type of water quality-
based effluent limitation (40 CFR § 130.2(h)).
Wastewater treatment facility (WWTF)—A generic term for facilities that treat or manage wastewater, including
publicly owned treatment works treatment plants.
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IV
Executive Summary
Congress enacted the Water Infrastructure Improvement Act (H.R. 7279) on January 14, 2019. The law directed
the U.S. Environmental Protection Agency (EPA) to develop a report to Congress on the implementation of
EPA's 2012 Integrated Municipal Stormwater and Wastewater Planning Approach Framework (EPA's Integrated
Planning Framework). The Integrated Planning Framework was designed to help municipalities address
competing clean water infrastructure investment needs and choose the most beneficial approaches for setting
priorities and taking effective actions for achieving water quality goals. This report to Congress is a culmination
of a nationwide scan, from March 2019 until July 2020, to determine how many municipalities have developed
plans and which ones are implemented through permits, orders, or judicial consent decrees since EPA's
Integrated Planning Framework was released on June 5, 2012.
Key findings:
¦ Twenty-seven municipalities have developed integrated plans in accordance with EPA's Integrated
Planning Framework.
¦ Thirteen municipalities' integrated plans are being implemented through a permit, order, or judicial consent
decree.
— Six integrated plans are being implemented through permits.
— One integrated plan is being implemented through an administrative order.
— Six integrated plans are being implemented through consent decrees or consent orders.
Congress also directed EPA to report the costs, control measures, level of controls, and compliance schedules
for each integrated plan implemented through a permit, order, or judicial consent decree. EPA's reading of
integrated plans and conversations with the 13 municipalities found the following:
¦ Proposed budgets to implement integrated planning projects ranged from $15 million to $2 billion, with an
average of $745 million.
¦ Integrated plans evaluated controls to prevent untreated sewage, partially treated sewage, and stormwater
from entering waterways. They included controls for combined sewer overflows, sanitary sewer overflows,
stormwater discharges, and wastewater treatment facilities.
¦ The schedules proposed in the integrated plans ranged from 5 years to 30 years, with an average
of 21 years.
Municipalities are using EPA's Integrated Planning Framework to analyze existing wastewater and stormwater
controls, gather stakeholder input throughout planning, and synchronize their goals with capital improvement
plans. With the analyses, they can make smart investments for water resources management. Importantly, they
can also create innovative and affordable ways to address the most serious water quality impairments first.
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1 Introduction
The Clean Water Act passed by Congress in 1972 had a profound
impact on reducing municipal water pollution by expanding and
improving wastewater treatment across the country As municipalities
continue to improve their clean water infrastructure, they must
successfully navigate and address issues, such as changing rainfall
patterns and intensities, population growth and expanding service
areas, aging infrastructure, competing priorities for public funds, and
increasingly disparate impacts on their full range of ratepayers.
To help municipalities address competing issues and choose the most
beneficial infrastructure approaches, the U.S. Environmental Protection
Agency developed a voluntary approach for setting priorities and
taking effective actions for achieving water quality goals. Launched in
2012, the Integrated Municipal Stormwater and Wastewater Planning
Approach Framework (EPA's Integrated Planning Framework) is a
tool to help municipalities achieve clean water requirements, better
manage water resources, and enhance the quality of life for their
residents.
EPA's Integrated Planning Framework was designed to present a
flexible yet comprehensive process. Municipalities that have used it
have benefited from the process for evaluating existing wastewater
and stormwater controls, gathering stakeholder input throughout
planning, and finding ways to address the most serious water quality
impairments first. They have reported a range of benefits including
cost savings, improved community buy-in, and greater pollutant
load reductions than they would have achieved using traditional
planning and scheduling techniques and siloed public works project
management.
The Water Infrastructure
Improvement Act,
Section (3)(c), states:
REPORT TO CONGRESS.—Not
later than 2 years after the date
of enactment of this Act, the
Administrator shall submit to the
Committee on Environment and
Public Works of the Senate and
the Committee on Transportation
and Infrastructure of the House
of Representatives, and make
publicly available, a report on
each integrated plan developed
and implemented through a
permit, order, or judicial consent
decree pursuant to the Federal
Water Pollution Control Act since
the date of publication of the
"Integrated Municipal Stormwater
and Wastewater Planning
Approach Framework" issued
by the Environmental Protection
Agency and dated June 5,
2012, including a description of
the control measures, levels of
control, estimated costs, and
compliance schedules for the
requirements implemented
through such an integrated plan.
Recognizing the benefits of this approach, Congress enacted the
Water Infrastructure Improvement Act (H.R. 7279) on January 14, 2019.
This Act provides greater certainty that integrated planning offers
municipalities a comprehensive, voluntary path to meeting Clean Water Act requirements. It directed EPA to
develop a report to Congress on the implementation of integrated planning.
From March 2019 until July 2020, EPA reviewed integrated plan documentation nationwide to determine which
municipalities developed integrated plans that have been implemented through a permit, order, or judicial
consent decree since June 5, 2012, pursuant to the Integrated Planning Framework (refer to the map on page
2). This report is divided into the following sections:
¦ Section 2 offers details on the background and purpose of EPA's Integrated Planning Framework.
¦ Section 3 summarizes the benefits municipalities gain from using EPA's Integrated Planning Framework.
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2
Introduction
¦ Section 4 offers a separate profile of each integrated plan that have been implemented through a permit,
consent decree, or administrative order. These profiles also describe the water quality impacts and
community benefits achieved.
¦ Appendix A provides a summary table of proposed costs, levels of controls, control measures, and
compliance schedules for all the municipalities with integrated plans that are implemented through
permits, consent decrees, or administrative orders as called for by the Water Infrastructure
Improvement Act.
Washington
County, OR
| Spokane, WA
I Santa Maria, CA
^ Los Angeles, CA
San Diego, CA
Integrated Planning in Action
fExeter/Stratham/
o
Springfield, Fall River, MA
Lakewood, OH Hartford, CT" |
New Bedford, MA
Akron, OH
^ Lima,OH+ „
Burlington, IaQ ^ Harrisburg, PA
Lawrence, KS
Columbia, MO
~ik *
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Johnson County,
Springfield, MO
~
Hamilton
County, OH •Co|'mbuJi0H
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Hampton Roads, VA
~
Atlanta, GA
Key
~ Municipalities with completed integrated plans that have been
incorporated in a permit, consent decree or administrative order
Municipalities with a completed integrated plan
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3
2 Background and Purpose of EPA's Integrated
Planning Framework
Over the past nearly five decades, EPA, states, and municipalities have made significant progress protecting
our waters through implementation of the Clean Water Act. However, challenges remain. As the nation faces
population growth, aging infrastructure, limited resources, and increasingly complex water quality issues,
new approaches to plan for and invest in infrastructure improvements are needed. Municipalities managing
wastewater treatment facilities, sewer systems, and stormwater infrastructure must prioritize their investments.
They must also evaluate different approaches and options for improving their systems, including gray
green, and data infrastructure investments. Focusing on each infrastructure need individually may constrain
a municipality from addressing its most serious water quality issues first. To address this challenge, EPA
developed the Integrated Planning Framework, a voluntary approach that municipalities can use to identify
efficiencies and sequence investments to meet multiple wastewater and stormwater requirements by pursuing
the highest-priority projects first. Integrated planning also promotes innovative solutions to improving water
quality, such as green infrastructure, which not only helps to meet Clean Water Act obligations but also
provides other benefits that can enhance a community's livability.
The integrated planning process is a comprehensive planning process that seeks to address a municipality's
Clean Water Act-related obligations while prioritizing those with the greatest human health and environmental
consequences. An assessment of existing water quality challenges in an integrated plan may identify multiple
pollutants that impair water quality (e.g., pathogens, nutrients, suspended solids) and multiple sources for
these pollutants {e.g., wastewater, stormwater). In such cases, a plan should describe the relative priorities of
the projects chosen, including how those priorities reflect the relative importance of adverse impacts on public
health and water quality. If a municipality's integrated plan addresses water quality impairments caused by
pollutants from multiple regulated municipal wastewater and/or stormwater discharges, that plan can help the
municipality articulate for its permitting authority the proposed sequencing and prioritization of projects.
EPA's Integrated Planning Framework lays out a flexible process and includes overarching principles and
essential elements that integrated plans should address.
New Bedford's
wastewater treatment
facility at Fort Rodman.
Photo courtesy of
Shoreline Aerial
Photography LLC,
provided by CDM Smith.
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¦¦ Background and Purpose of EPA's Integrated Planning Framework
Six Elements Identified in EPA's Integrated Planning Framework
A description of the water quality, human health, and regulatory issues to be
addressed in the plan.
A description of existing wastewater and stormwater systems under consideration
and summary information describing the systems' current performance.
A process that opens and maintains channels of communication with relevant
community stakeholders to give full consideration of the views of others in the
planning process and during implementation of the plan.
A process for identifying, evaluating, and selecting options and proposing
implementation schedules.
A process for evaluating the performance of projects identified in a plan, which can
include evaluating monitoring data, information developed by pilot studies, and other
studies.
A process for identifying, evaluating, and selecting proposed new projects or
modifications to ongoing or planned projects and implementation schedules based
on changing circumstances.
Since 2012, EPA has provided integrated planning
technical assistance to five municipalities around the
country. The assistance piloted EPA's Integrated Planning
Framework for communities with different sizes, water
quality goals, and infrastructure challenges. Feedback
from the five projects provided practical examples and
demonstrated benefits for communities interested in
launching an integrated planning process.
EPA has also developed a variety of reports and
associated tools to support communities. These tools
focus on effective approaches for engaging the public,
gathering valuable stakeholder input, and methods for analyzing data to estimate benefits to water resources.
By providing technical assistance, developing tools to help communities, and carrying out research for this
report, EPA has gathered the knowledge and experience it needs to foster broad adoption of integrated
planning.
®'
Public Outreach for
Integrated Wastewater
and Stormwater
Planning
Integrated Planning:
Characterizing the Value
of Water to Inform
Decision-Making
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5
3 Benefits of Integrated Planning
Integrated planning offers municipalities a holistic, long-term way to achieve their Clean Water Act goals.
With a process for bringing all partners and stakeholders to the table, a municipality can synchronize
its community's goals with capital improvement plans to ensure smart investments for water resources
management. It can set priorities—for example, stormwater capture, drinking water source protection,
wastewater reuse, or streambank restoration—that help meet Clean Water Act regulatory requirements and
improve amenities that can make its community a great place to live and work.
Holistic planning with extensive stakeholder engagement is leading to the following major benefits for the
communities highlighted in this report:
¦ Faster water quality improvements and health protections.
¦ More cost-effective and affordable infrastructure investments.
¦ Consideration of investments that support other community objectives.
¦ Innovative long-term solutions that reduce pollution sources rather than just controlling or treating
discharges.
Faster Water Quality Improvements and Health Protections
The consent decree for Seattle, Washington—requiring the city to limit combined sewer overflows
(CSOs) to one per outfall per year—allowed the city to develop an integrated plan if that plan resulted
in significant water quality improvements beyond what the CSO projects alone would achieve under
a long-term control plan. During the integrated planning process, Seattle identified, ranked, and
compared potential stormwater projects to the lowest-ranking CSO projects based on water quality
impacts and other community benefits. The resulting integrated plan featured three stormwater
projects that modeling showed would remove larger quantities of polychlorinated biphenyls (PCBs), fecal coliform,
total suspended solids, phosphorus, and other pollutants than the CSO projects alone. This projection proved to
be correct. For example, a 2018 expanded stormwater arterial street sweeping project in
Seattle removed nearly 60 tons of total suspended solids and 90 pounds of phosphorus—
about 90 times as much total suspended solids and 4.5 times as much phosphorus as the 6
CSO projects deferred to 2028-2030 in the plan, though fecal coliform reduction was only
15 percent of the deferred CSO projects.
More Cost-Effective and Affordable Infrastructure Investments
Akron, Ohio, pursued integrated planning to address projects required by a consent decree, which totaled $1.14
billion in capital costs. Through revised project sequencing, implementation of green infrastructure, and partial
sewer separation, the city:
a
Saved $158 million in
project costs between
2015 and 2019.
Treated an additional 826 million gallons
of wastewater beyond what the consent
decree required.
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6
Benefits of Integrated Planning
Considering Investments That Support Other Community Objectives
Springfield, Missouri; Greene County; and the area's public utility company developed a "citizen-focused approach"
to address water quality impairments and community priorities. The city organized an Environmental Priorities
Task Force of community members, city and county staff, and technical experts to holistically examine the city's
environmental resources and identify challenges important to the community This group worked together to:
Set goals, such as reducing polycyclic aromatic hydrocarbons in stormwater to
improve water quality
Identify affordable solutions to wastewater and stormwater challenges.
Meet objectives for solid waste and air quality.
To achieve its goal of reducing polycyclic aromatic hydrocarbons (PAHs) in stormwater, the city implemented a
"Clean Pavement Initiative" to encourage businesses and residents to voluntarily choose sealants for parking lots
and driveways that are lower in polycyclic aromatic hydrocarbons.
Innovative Long-Term Solutions That Reduce Pollution Sources Rather Than Just Controlling
or Treating Discharges
Richmond, Virginia, initiated an integrated planning process to gain efficiencies in managing multiple water quality
requirements and make progress toward its clean water goals. A primary driver for Richmond was to develop
a single integrated permit that complies with pollutant load allocations for bacteria, nitrogen, phosphorus, and
sediments in three separate permits. After Richmond engaged the public extensively throughout the planning
process and completed the integrated plan, the Virginia Department of Environmental Quality issued Richmond
an integrated permit covering the wastewater treatment facility, CSOs, and stormwater discharges. This
permit includes the city's integrated plan as documentation of the integrated planning process. Since it began
implementing the plan, Richmond has installed green infrastructure practices that treat stormwater discharges from
nearly 20 acres in the combined and separate sewer areas.
Received
integrated
permit
Completed
integrated
plan
Installed green
infrastructure
Treats
discharges
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7
4 Integrated Plans Implemented Through
Permits, Orders, or Judicial Consent Decrees
EPA reviewed planning documents from municipalities across the country and identified nearly 27 that used
the integrated planning process outlined in EPA's Integrated Planning Framework. Out of the 27 municipalities
that completed integrated plans in accordance with the Integrated Planning Framework, 13 municipalities
implemented their plans through permits, administrative orders, or judicial consent decrees, which is what the
Water Infrastructure Improvement Act referred to in its requirement for EPA's Report to Congress. This section
presents profiles of these 13 municipalities, with details on their challenges, integrated planning processes,
and results as described in their integrated plans, as well as associated permits, orders, or judicial consent
degrees. Appendix A includes a table with further plan-specific details.
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LIMA, OHIO
^ CITY OF ATLANTA DEPARTMENT OF
watershed
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JOHNS. N COUNTY Cityo/Lawrence
Wastewater
Springfield - Greene County, Missouri
Integrated Plan
for the Environment
A great blue heron looks for its next meal on the James River as rafters paddle by in
Richmond's downtown rapids. Photo courtesy of RVA Paddlesports.
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8
New Bedford, Massachusetts
EPA Region 1
m
inew
=1? bedford
2017 Long Term CSO Control
and Integrated Capital
Improvements Plan
100,000 population
CSO (J MS4 II SSO llWWTF
Core Issues Addressed Through
the Integrated Planning Process
¦ Water quality impairments
¦ Public health and safety
¦ Existing infrastructure reliability
¦ Climate change
¦ Sustainability
¦ Need for economic development
Located on Buzzards Bay in southeastern Massachusetts, New Bedford
is a city with a rich maritime history and a population of nearly 100,000.
New Bedford owns and operates combined and separate sanitary
sewers that transport wastewater to the city's wastewater treatment
facility, which discharges into Buzzards Bay. The city's storm sewers and
CSO outfalls discharge into the Acushnet River estuary, Clarks Cove,
and New Bedford Harbor. Buzzards Bay supports tourism, marinas, and
recreational fishing.
Challenges
In 1987, New Bedford agreed to reduce CSOs and build a new secondary
wastewater treatment facility under a consent decree with EPA and the
Massachusetts Department of Environmental Protection. The consent
decree was updated in 1990 and 1995 to address cited affordability
constraints and allow the city to prioritize wastewater treatment facility
improvements and delay CSO abatement activities.
By 2012, New Bedford had reduced CSO volumes by 91 percent since
1990, but it still discharged 284 million gallons of sewage into waterways
that year. That same year, EPA issued an administrative order that
required the city to address sanitary sewer overflows (SSOs) and develop
a scope for updating its long-term control plan (LTCP) for managing
CSOs. In addition to these requirements, New Bedford anticipated
new nitrogen effluent limits that could require costly upgrades to its
wastewater treatment facility. The city also has a stormwater discharge
permit that includes a total maximum daily load (TMDL) for pathogens in
Buzzards Bay.
Integrated Planning in Action
By 2016, New Bedford met all the deadlines in EPA's 2012 administrative
order and submitted a scope of work to integrate the LTCP with a
capital improvement plan in lieu of the more traditional LTCP that the
order required. The city asked to use the proposed integrated planning
approach to prioritize projects that would address overarching issues.
New Bedford staff held meetings with various stakeholders, city
departments, and the public and identified more than 150 concerns and
impacts. For example, bacteria reduction and system failure prevention
were the city's priorities in addition to CSO abatement. The city then
distilled this input into six core issues to address through integrated
planning (see box at left) and established goals for each. For example,
the city set the following six project goals for addressing water quality
impairments: 1) address management goals in the TMDL; 2) reduce
nitrogen and phosphorus to increase dissolved oxygen concentrations;
3) control/reduce discharges of oil, grease, and trash; 4) ensure the
wastewater treatment facility is operated to reduce nitrogen discharges;
5) prioritize control of CSOs in sensitive areas; and 6) meet the
requirements of the city's stormwater permit.
New Bedford identified locations within the city where systems were
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9
Projected Distribution of 20-Year Integrated
Capital Plan Costs by Category
| Wastewater treatment facility
Wastewater pumping
stations
Combined sewer overflow
| Wet weather sewer
| General sewer
Stormwater
Flood control structures
Organizational/institutional
Approach to Project Implementation and Monitoring
Monitor and
evaluate
performance
\
Adjust plan
as needed
not performing optimally or needed improvement to
meet plan goals through a series of internal workshops,
public meetings, document reviews, modeling, system
assessments, and site investigations. The city proposed
projects to address all identified problems in these
specific locations; however, the full suite of projects
would have cost $1.2 billion, which the city deemed
unaffordable. Therefore, the planning team focused on
how best to prioritize and select projects to include in
the integrated plan.
New Bedford first divided the full suite of projects into
eight categories (see box below). It then prioritized the
projects within each category, considering how critical
the associated infrastructure was, the water quality
benefits, how well each project supported compliance
with permits and the administrative order, social
impacts, administrative considerations, and anticipated
construction costs. The city also conducted modeling
to determine how much wastewater treatment facility,
pumping station, and CSO control projects would
reduce CSO volume and flooding, as well as how much
infrastructure would be renewed.
From the prioritized category-specific lists, New
Bedford then chose projects for its integrated plan
based on affordability, alignment with other city
initiatives or projects, and necessity for maintaining
reliable operation of the sewers and wastewater
treatment facility. The city selected projects from all
Project Categories
¦ Wastewater treatment
facility
¦ Pumping stations
¦ CSO controls
¦ Wet weather sewer
¦ General sewer
Stormwater controls
Flood control structures
Organizational/
institutional
eight categories. The city also proposed a schedule that
equitably distributed projects across 20 years (2017—
2036) to avoid large rate increases in any given year.
The capital budget for New Bedford's final
recommended plan totaled about $260 million over 20
years (see graphic above). More than half of the total
cost (i.e., $143 million) was for combined sewer projects;
another third was for wastewater infrastructure renewal
projects. The schedule focused first on infrastructure
repair and renewal to eliminate illicit connections to
the storm sewer system, reduce infiltration and inflow
into the combined sewer system, and eliminate a CSO
outfall. New Bedford's recommended plan included
optimizing the existing wastewater treatment facility
to maintain low nitrogen effluent levels, rather than
installing new equipment.
New Bedford projected that the plan would reduce
CSO volume by an additional 82 million gallons from
the city's 2016 levels, resulting in a 97 percent reduction
from its 1990 levels. It prioritized CSO reduction to
Clarks Cove, which is the most sensitive receiving water.
At the time of plan completion, New Bedford expected
to achieve a 48 percent reduction in total nitrogen
discharge and a substantial reduction in bacteria
discharged during rain events to the Acushnet River,
Clarks Cove, and New Bedford Harbor.
Results
New Bedford submitted its Long Term CSO Control
and Integrated Capital Improvements Plan to EPA in
2017. A 2019 consent order formally implemented the
first phase of the plan that included projects for the first
seven years. The city started several integrated plan
projects before the 2019 order, including equipment
upgrades at the wastewater treatment facility, two
sewer separation projects, two pumping station
upgrades, and a flow monitoring program.
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10
Springfield, Massachusetts
EPA Region 1
sewep
155,000 population
a
2014 Springfield Water and
Sewer Commission Integrated
Wastewater Plan
Springfield is the third largest city in Massachusetts, with a population
of about 155,000. The Springfield Water and Sewer Commission
is an independent regional public utility that operates combined
and separate sanitary sewer systems that transport wastewater
to a wastewater treatment facility. This facility and portions of the
city's storm sewer system discharge into the Connecticut River—the
longest river in New England and one of only two American Heritage
Rivers in New England. The Connecticut River in Springfield is a
popular recreational venue. Along with fishing and boating, the
Connecticut River Walk and Bikeway includes a 4-mile stretch along
the Springfield riverfront that is popular for walking, jogging, biking,
and rollerblading.
Riverfront Park with Memorial Bridge
in the background. Photo courtesy
of Jaimye Bartak, SWSC.
Challenges
Springfield is an older post-industrial city with aging infrastructure.
Springfield has experienced frequent CSOs, which discharge sewage
into the Connecticut, Chicopee, and Mill Rivers. During heavy rain
events, stormwater enters the Commission's combined and separate
sanitary sewer system, causing CSOs and SSOs because of lack
of system capacity. The Commission had reduced SSOs by 70
percent between 2006 and 2013 and wanted to further reduce these
discharges. Springfield's wastewater treatment facility is also the
largest contributor to the Connecticut River Watershed's total nitrogen
loading. In 2001, a TMDL (established for Long Island Sound, into
which the watershed drains) required the facility to reduce nitrogen
loading. Without a long-term plan to maintain aging infrastructure and
meet Clean Water Act requirements, the Commission struggled with
prioritizing projects that address CSO and SSO events, as well as
future nutrient reduction requirements at the wastewater treatment
facility.
The Commission invested $100 million between 2000 and 2012 to
reduce CSOs as required by a series of administrative orders and
based on a draft 2000 LTCP. The administrative order issued by
EPA in 2008 required the Commission to finalize its LTCP to reduce
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11
Springfield Dragon Boat Festival on the
Connecticut River. Photo courtesy of Mark M. Murray.
CSO volume by 85 percent. Understanding the
competing needs of CSO compliance projects and
other infrastructure renewal projects, the Commission
recognized that the Integrated Planning Framework
would allow for an adaptable approach to prioritize all
the utility's wastewater needs.
Integrated Planning in Action
Between 2012 and 2014 the Commission
performed comprehensive evaluations and
condition assessments of all its wastewater assets
by implementing a robust asset management
program. That program's data-driven strategy helped
create a prioritized list of needs based on risk and
consequence of failure. In 2014, the Commission
began the integrated planning process in order to
address the high-risk infrastructure and renewal
projects while also meeting CSO obligations faster
and more cost-effectively. The Commission began
by prioritizing the 2012 LTCP CSO projects and
wastewater capital improvement projects based on
CSO volume reduction and human health benefits.
The Commission sequenced the highest-volume,
most cost-effective CSO projects first, thereby
reducing financial burden on ratepayers. This allowed
Springfield the financial flexibility to implement
wastewater capital improvement projects to improve
the resiliency and reliability of its system. Projects
such as sewer rehabilitation and a pumping station
renewal project could be implemented more quickly
to help the Commission achieve CSO reduction
milestones and improve operational performance at
the wastewater treatment facility.
The Commission's proposed integrated plan
schedule included six phases of CSO projects
over 20 years and 11 phases of wastewater capital
improvements over 40 years. The CSO projects
were sequenced to reduce projected CSO volume
by over 50 percent within the first two phases-
more quickly than what would have been achieved
by implementing the original LTCP. Integrated plan
projects proposed later in the schedule balanced
further CSO reductions with capital improvements
necessary to maintain infrastructure and
address SSOs.
The broader system understanding achieved through
the integrated planning process, along with a better
understanding of financial conditions, capabilities,
and rate impacts, allowed the Commission to better
evaluate a variety of alternatives and choose projects
with multiple benefits across key metrics. The box
below shows the secondary benefits the Commission
expected to gain.
The total cost of the integrated plan through
2035 was projected to be $447.2 million. The
plan estimated an 89 percent annual CSO volume
reduction upon completion.
Results
The Commission's Integrated Wastewater Plan was
implemented in a 2014 administrative order from
EPA, which required Springfield to complete the
second and third phases of CSO improvements.
Initial projects reduced CSO discharge volume and
SSO events: CSO volume dropped 56 percent from
baseline levels in 2017 and the number of SSO events
decreased by 47 percent from 2014 to 2019. In 2018,
based on outcomes from its asset management
ranking system, the Commission completed
rehabilitation of a major interceptor sewer project.
Secondary Benefits from the Integrated
Planning Process
¦ Risk reduction
¦ Better system reliability
¦ Better performance
¦ More resiliency
¦ More long-term rate stability
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12
Richmond, Virginia
EPA Region 3
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 facility, which
discharges into the James River. About two-thirds of Richmond is served by
a storm sewer system. Stormwater discharges and CSOs also flow into the
James River, as well as its tributaries.
Challenges
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 TMDLs 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 an LTCP.
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 quality.
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.
The city's water quality managers and stakeholders produced a common set of integrated planning goals (see
box on page 13). For each goal, the stakeholders developed multiple objectives, then evaluated the strategies
to achieve these objectives (see table on page 13). For example, the pollutant reduction strategy included illicit
RVA
H2£
Q
2017 RVA Clean Water Plan
227,000 population
CSO II MS4 IIWWTF
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13
Estimated Five-Year Costs of
Richmond's Proposed Strategies
Strategy
Capital Cost
Operation and
Maintenance
Cost
(Five Years)
Total Cost
Riparian restoration
$900,000
$200,000
$1,100,000
Storm sewer green
infrastructure
$10,500,000
$2,000,000
$12,500,000
Combined sewer
green infrastructure
$2,600,000
$750,000
$3,350,000
Stream restoration
$1,700,000
$1,200,000
$2,900,000
Planting native
species
$70,000
$95,000
$165,000
Planting trees
$1,600,000
$600,000
$2,200,000
Land conservation
.
.
.
Water conservation
$220,000
$50,000
$270,000
Pollutant reduction
in storm sewer areas
$16,385,000
+
$16,385,000
Total
$33,975,000
$4,895,000
$38,870,000
* 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 cleanout activities for each of the five years of the permit.
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.
Results
In 2018, the Virginia Department of Environmental
Quality issued Richmond an integrated permit covering
the wastewater treatment facility, CSOs, and stormwater
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
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.
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14
Atlanta, Georgia
EPA Region 4
^TCITY OF ATLANTA DEPARTMENT OF
watershed
management
2019 Integrated Plan for the
City of Atlanta
-Q
500,000 population
CSO 11 MS4
Atlanta's Performance Criteria
¦ Risk mitigation
¦ Regulatory compliance
¦ Operational efficiency
¦ Durability/resiliency
¦ Sustainability initiatives
¦ Visibility
¦ Safety and reliability
Atlanta is the capital of Georgia, home to approximately 500,000
people and the center of a metropolitan area of more than 6 million
people. The city operates separate sanitary and combined sewer
systems, which connect to three wastewater treatment facilities that
discharge to the Chattahoochee River. The combined sewer system
also includes remote treatment facilities that provide partial treatment
of CSOs during heavy storms. In addition to these wastewater sewer
systems, Atlanta operates a storm sewer system that discharges to
the Chattahoochee and Ocmulgee Rivers. The Chattahoochee is
popular for tubing, paddle boarding, and canoeing, and was the first
U.S. river to be named a National Water Trail.
Challenges
Excess stormwater entering Atlanta's combined sewer system during
storms causes CSOs. The wastewater treatment facilities may also
reach maximum capacity because of excess flows from the combined
sewer or inflow into the sanitary sewer system during these storms.
The CSO remote treatment facilities are designed to reduce pollution
from these overflows; they go into operation at certain CSO points
when the wastewater treatment facilities are at maximum flow
treatment capacity. In 2015, some of these remote "partial treatment"
facilities did not treat to levels that met water quality standards for
metals, so the Georgia Department of Natural Resources issued
Atlanta two combined sewer system permits that required the city
to develop an integrated plan to address discharges from the partial
treatment facilities. The permits specified that green infrastructure
and innovative technology should be considered as mechanisms to
protect human health and improve water quality in the integrated
plan. In addition, the city must comply with permits for its wastewater
treatment facilities and a stormwater permit for discharges from the
storm sewer system.
Integrated Planning in Action
In 2015, Atlanta began an integrated planning process to meet permit
requirements and reduce the use of its remote partial treatment
facilities. The city developed a process for identifying projects that
would reduce runoff volumes and pollutant loadings, then evaluated
these projects based on cost {i.e., whether they were possible under
available funding) and how well they met performance criteria (see box
at left). Atlanta's final integrated plan did not identify specific projects
but rather committed to pursue projects through the proposed
evaluation and selection process that protect the environment,
support economic development, and improve quality of life as
priorities for implementation.
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15
Results
The Georgia Department of Natural Resources approved the Integrated Plan for the City of Atlanta in 2019,
Using the project selection process outlined in the integrated plan, the city designed the Rodney Cook Sr.
Park, a green infrastructure project designed to alleviate flooding by capturing and storing up to 10 million
gallons of stormwater using rain gardens, stormwater planters, and constructed wetlands. The plan called
for this project to be completed in 2020, and to date it has helped mitigate CSOs.
Cook Park capacity relief project. Photo courtesy of J. Cory Rayburn.
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16
Akron, Ohio
EPA Region 5
AkronWaterways
Renewed!
2015 Integrated Plan
200,000 population
a
CSO IIWWTF
Cuyahoga River Homecoming, June 2020.
Photo courtesy of City of Akron.
The City of Akron, in northeastern Ohio, has a population of about
200,000. Akron operates combined and separate sanitary sewer
systems in addition to storm sewers. The combined and separate
sanitary sewer systems transport wastewater to the city's wastewater
treatment facility, which discharges to the Cuyahoga River, while the
storm sewer system discharges to the Ohio Canal and Little Cuyahoga
River. These tributaries flow to the Cuyahoga River, which is the southern
gateway to the Cuyahoga Valley National Park. In 2019, the national river
conservation organization American Rivers named the Cuyahoga River
its "River of the Year" to celebrate the environmental progress made
during the prior 50 years.
Challenges
Akron historically has discharged an estimated 1.2 billion gallons of CSOs
per year. Also due to excess flows during heavy rainfall events, the city's
wastewater treatment facility discharged an average 1.2 billion gallons
of partially treated wastewater per year into the Cuyahoga River and its
tributaries resulting from bypasses of the secondary treatment units. The
Cuyahoga River is impaired by bacteria, nutrients, and dissolved oxygen.
In 2014, a U.S. District Court entered a consent decree with EPA, the
Ohio Environmental Protection Agency, and Akron that required Akron
to implement its LTCP (as updated in 2011). At the time of the consent
decree, Akron had already reduced its CSO volume to 816 million
gallons per year. The LTCP included separating a portion of its combined
sewers, installing 10 storage basins and 2 wastewater storage tunnels,
upgrading the wastewater treatment facility, and completing collection
system projects. The city estimated it would cost more than $1.14 billion
to implement the required projects by 2027 to meet the required level of
control of zero untreated overflows in a typical year and zero bypasses
of secondary treatment at the wastewater treatment facility. Akron raised
sewer rates significantly between 2005 and 2015 but determined that
current sewer rates were not high enough to pay for the consent decree
projects and meet other Clean Water Act obligations, such as stormwater
requirements.
Integrated Planning in Action
In December 2013, Akron began an integrated planning process to
consider green infrastructure and other innovative solutions that might
improve water quality faster and more cost-effectively than the existing
LTCP projects. The city involved the public throughout this process
through educational events, meetings, and a stakeholder group it formed.
Akron also communicated with stakeholders through newspaper articles,
utility bill mailers, and a website. The city rebranded its CSO program
as Akron Waterways Renewed! to better communicate the benefits of
improving water quality to the public.
-------
Akron first chose projects to include in the integrated
plan and prioritized them based on environmental,
economic, and social benefits (graphic below). The
prioritization process identified which projects would
be implemented first. The city scored projects based on
weighted criteria (see chart below). The highest-scoring
projects included some of the original LTCP projects as
well as alternatives to LTCP projects. These included
improvements to the wastewater treatment facility, the
use of green infrastructure to attenuate CSO flows and
capture stormwater in the separate storm sewer areas,
dam removal, streambank restoration, flood mitigation,
and sanitary sewer rehabilitation.
The city used a financial model to compare integrated
plan project scenarios with the original LTCP projects.
The model was able to prioritize and sequence projects
based on funding availability, rate requirements, cost,
affordability, and construction schedules. Once the
modeling framework was set up, Akron assessed
alternative scenarios to estimate costs, future
schedules, affordability, and rate increases. The city
modeled scenarios with construction completion by
2027 and 2040. Akron concluded that the integrated
plan projects would require a cumulative lower rate
increase through 2040 compared to the original LTCP
projects.
As part of the integrated planning process, Akron also
modeled the environmental benefits of the integrated
plan projects compared to the original LTCP projects.
Akron concluded that the integrated plan would reduce
the same CSO and bypass volume as the original LTCP,
through a suite of projects carried out earlier than in the
original LTCP schedule. Proposed green infrastructure
would reduce total suspended solids and bacteria
in stormwater while providing additional community
benefits.
Results
Akron submitted the City of Akron Integrated Plan
in 2015. In 2016 and 2019, EPA agreed to amend
the consent decree to require Akron to complete
some of the projects in the integrated plan by 2027.
These included some green infrastructure projects,
partial sewer separation, and a bypass treatment
technology at the wastewater treatment facility—
along with revised project sequencing. As of 2019,
sue-
1 s A
Uhler conveyance project and Little Cuyahoga River stream
bank restoration. Photo courtesy of City of Akron.
the city had completed or started 92 percent of the
projects required under the consent decree, and it
had saved an estimated $158 million on project costs
through integrated planning since 2015. In addition,
by prioritizing bypass treatment technology at the
wastewater treatment facility, Akron was able to expand
secondary treatment capacity faster than anticipated,
resulting in secondary treatment of 826 million gallons
of wastewater above what the consent decree required.
In March 2020, Akron accepted the Outstanding
Achievement Award from the American Council of
Engineering Companies for one of the integrated plan
projects: the Aqueduct Street Green Improvement
project, completed in 2018. Akron also received Gold
Level recognition in the Ohio EPA's Encouraging
Environmental Excellence program.
Triple Bottom Line Weighted Criteria Based on
Economic, Social, and Environmental Categories
Cooperative funding sources
Local jobs
Revenue growth
Operational efficiency
Recreational opportunities
Quality of life
Public health protection
Community engagement
and stewardship
Habitat enhancement
and restoration
Pollutant reduction
Sustainability initiatives
Regulatory compliance
Economic criteria
Social criteria
10% 15% 20%
Environmental criteria
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18
Columbus, Ohio
EPA Region 5
Columbus is the capital of Ohio and has a population of nearly
900,000. The city operates separate sanitary, combined, and storm
sewers that discharge to the Scioto and Oientangy Rivers. The
separate sanitary and combined sewer systems connect to two
wastewater treatment facilities that discharge into the Scioto River.
The river runs through the middle of downtown Columbus. In 2015,
Columbus opened the "Scioto Mile"—a massive project to rehabilitate
the river that included habitat restoration, miles of trails, and 33 acres
of new parkland.
Challenges
During heavy storms, stormwater and groundwater enter Columbus's
sanitary sewer system through cracks and improper connections
(i.e.. infiltration and inflow). This leads to sewage releases in the
form of SSOs and backups into basements. In addition, large storms
cause CSOs and bypasses at the wastewater treatment facilities.
These overflows and bypasses lead to the discharge of sewage and
partially treated wastewater into the Scioto and Oientangy Rivers.
Both wastewater treatment facilities have permits that require the city
to control these discharges. Columbus also has a stormwater permit
that requires the city to implement a management plan to improve
stormwater quality. All three permits implement TMDLs for bacteria,
nutrients, sediment, and total suspended solids.
Columbus agreed to eliminate SSOs and basement backups and to
address CSOs in two separate consent orders, filed with the Ohio EPA
in 2002 and 2004. To meet all the consent order requirements, the
city developed a combined Wet Weather Management Plan (WWMP)
;ost of $2.5 billion over 30 years.
Integrated Planning in Action
In 2012, the city began an integrated planning process to update the 2005 WWMP and consider more
beneficial and cost-effective solutions to address SSOs, CSOs, and stormwater pollution. Columbus used a
city-wide engagement approach, called Blueprint Columbus, to educate residents about sewer overflows, get
feedback on proposed options, and improve outreach to homeowners. The city also created a community
advisory panel to provide guidance during the development of the plan.
Planners developed and analyzed two options for updating the
2005 WWMP:
¦ A "Blueprint" option that focused on reducing the sources of
infiltration and inflow and implementing green infrastructure in
certain areas of the city (see box on page 19).
¦ A "gray" option that focused on managing a likely increase
of flows over time. This option would use tunnels for excess
storage, increase the size of sewer pipes, and clean and iine
pipes to transport and minimize sewer overflows.
BIKJE
PRINT
COLUMBUS
Clean streams.
Strong neighborhoods.
Integrated Plan and 2015
WWMP Update Report
.Q
900,000 population
in 2005, which had an implementation c
The Scioto River with Columbus skyline.
Photo courtesy of City of Columbus.
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Blueprint rain garden in the Clintonviile neighborhood of
Columbus. Photo courtesy of City of Columbus.
Columbus first compared how well the options could
achieve compliance goals, additional water quality
improvements, regional economic benefits and job
creation, neighborhood benefits, and sustainability.
In addition to meeting all water quality compliance
obligations, green infrastructure in the Blueprint
option would achieve a greater reduction in overflows
and remove an estimated 342 tons of sediment
each year. Columbus also estimated that the city's
investment in maintaining private laterals would save
homeowners $453 million, and that the Blueprint
option would create more than 700 jobs over 20
years.
Next, Columbus evaluated how the cost of the
two options would affect water and sewer bills,
particularly for households with lower income.
Analysis showed that even with a faster 20-year
implementation schedule, the Blueprint and gray
options would require lower rate increases than the
2005 WWMP, which had a 30-year schedule.
After considering implementation schedules,
Columbus tabulated how much each option would
cost in total over 20 years. The city determined that
the Blueprint option would be more expensive than
the gray option. However, it chose to invest the
additional funds because of the stormwater quality
benefits and the larger reduction in overflows that the
Blueprint option would achieve.
Columbus estimated that revising the 2005 WWMP
using the Blueprint option would require capital
costs of $1.74 billion, with an estimated operation
and maintenance cost of $60 million over 20 years
(through 2035). The capital cost estimate includes
$400 million for some projects identified in the 2005
WWMP, including adding a process to partially treat
bypasses at the wastewater treatment facility, and
$1.3 billion for new green infrastructure and infiltration
and inflow reduction projects.
Results
In 2015, Columbus finalized its Integrated Plan
and 2015 WWMP Update Report. The Ohio EPA
approved the plan that same year and incorporated
it into one of the city's existing wastewater treatment
facility permits. Columbus has made significant
progress in implementing the plan's "pillars," which
include installing more than 400 rain gardens along
roadways and parking lots, more than 30,000 square
feet of porous pavement, and 350 private sump
pumps—along with assessing more than 670 homes
(25 percent of the target number) for improvements
to reduce infiltration and inflow. As a result, the
city experienced 30 percent fewer SSOs in 2019
than in the previous year, despite above-average
precipitation.
BI*UE
PRINT
COLUMBUS
Four Pillars of the Blueprint Option
¦ Installing green infrastructure (rain gardens and
porous pavement) to help slowly filter water
¦ Redirecting downspouts so runoff from roofs goes
into the storm sewer
¦ Installing sump pumps to direct excess groundwater
to the storm sewer and keep it from getting into the
sanitary sewer
"¦ Lining pipes (specifically, "laterals" that connect
homes to the sewer main) to reduce infiltration
through cracks
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20
Lima, Ohio
EPA Region 5
LIMA, OHIO
2014 Integrated Plan
37,000 population
a
The City of Lima, in northwestern Ohio, is home to about 37,000
people. A combined sewer system serves about 60 percent of the
city. The other 40 percent is served by separate sanitary sewers and
storm sewers. Wastewater from the combined and separate sanitary
sewers is conveyed to the city's wastewater treatment facility. Treated
wastewater from this facility and stormwater discharges flow into
the Ottawa River, a central feature for the town. The 4.2-mile Ottawa
River Bikeway winds alongside the river and connects the city's parks,
the downtown business district, and the local high school.
Challenges
Lima experiences SSOs and CSOs mainly due to inadequate capacity
at the wastewater treatment facility during storms. Under a 2015
consent decree with EPA and the state of Ohio, the city agreed to
make major structural improvements to control CSOs and to eliminate
sewage overflows from the sanitary sewer system. Lima also must
comply with permit limits for nutrients, sediment, and bacteria
entering the Ottawa River. The potential cost to address these issues
traditionally exceeded the financial capability of the city and its
residents.
Bike path over the Ottawa River. Photo courtesy of City of Lima.
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Ottawa River Bridge bike
path. Photo courtesy of
City of Lima.
Integrated Planning in Action
City leaders thought it was not feasible to rapidly
raise utility rates to quickly accomplish the needed
improvements agreed to in the consent decree,
particularly in light of Lima's declining population
and other economic challenges. Lima decided to
develop an integrated plan to change the sequence
of projects to achieve the greatest environmental
benefits first while avoiding large rate increases.
Lima modeled a variety of control options within
the collection systems, at pump stations, and at the
wastewater treatment facility to determine which
sequence of controls would achieve the greatest
environmental benefits at an affordable cost. The city
devised a draft plan, then engaged the public. Lima
updated the public on its draft and final proposals
through city council meetings, neighborhood
association meetings, chamber of commerce
meetings, and meetings with other stakeholder
groups.
The resulting integrated plan proposed first
expanding treatment capacity at the wastewater
treatment facility, then installing controls [i.e.. sewer
separation, real-time control, tank and pump station
improvements) that would capture more than 97
percent of CSO volume, and finally conducting
separate sanitary system upgrades such as pump
station improvements to reduce SSOs. Lima
prioritized the CSO projects over SSO projects
because CSO volume was substantially higher than
SSO volume and the CSOs had a greater potential for
direct human contact.
The total capital cost of the integrated plan projects
was estimated at $147.6 million over 28 years:
substantially less than the city would have had
to spend without using an integrated planning
approach, while still meeting the performance criteria
contained in the consent decree. By expanding
capacity at the wastewater treatment facility first,
the city was able to reduce CSOs faster and at a
lower cost than if it had not developed an integrated
plan as part of its consent decree. Through the
implementation of the integrated plan, Lima
anticipated it would significantly reduce the amount
of bacteria, nutrients, organic matter, and suspended
solids entering the Ottawa River.
Results
Lima's integrated plan was included in an EPA
consent decree in 2015. in 2018, Lima increased
its wastewater treatment facility's wet weather
capacity from 53 million to 70 million gallons per day
and eliminated untreated bypasses. The city also
designed a storage basin that is expected to further
reduce CSOs to the Ottawa River when construction
is completed.
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Boone, Iowa, is home to nearly 13,000 people. The city operates
sanitary and storm sewer systems. Most of the sanitary sewer system
was installed more than 100 years ago and has not been replaced.
Boone's wastewater treatment facility and storm sewer system
discharge to Honey Creek, a tributary to the Des Moines River, the
largest river in Iowa. The river supports tourism and recreation,
including boating on the 100-mile Des Moines River Water Trail, which
follows the river as it winds through Boone County.
Challenges
During heavy storms, stormwater and groundwater enter Boone's
sanitary sewer system through cracks and improper connections
(i.e., infiltration and inflow). This causes SSOs at one pump station and
sewage backups into basements. These SSOs lead to the discharge
of sewage, which contains high concentrations of pollutants, such
as bacteria, to the Des Moines River. In addition, the city's 2014
wastewater treatment facility permit required the city to install
disinfection equipment to meet more stringent bacteria effluent
limits by 2018. As a small community, Boone has faced challenges in
balancing environmental compliance with financial capabilities.
Integrated Planning in Action
Boone decided to use an integrated planning approach to prioritize
projects to achieve the greatest environmental and human health
benefits using existing rate revenue to avoid short-term rate spikes.
The city conducted an open process: it engaged the community
through civic organizations and open house meetings and educated
the city council about the importance of preventing less polluted
stormwater and groundwater from entering the sanitary sewer system.
Boone also kept the public informed throughout the planning process
using a wide variety of media, including radio shows, newsletters, a
website, social media, and the local newspaper.
The city's plan indicated that reducing infiltration and inflow first
would result in the highest human health and water quality impacts by
reducing basement backups and SSO discharges. The integrated plan
included a project schedule that delayed the installation of disinfection
equipment by five years while the city focused on addressing
infiltration and inflow. The integrated plan projects cost $15.4 million
over 16 years (2016-2033), including about $10 million in capital costs
and $5.4 million for operation and maintenance.
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23
Results
In 2016, the city submitted the Integrated Wastewater Plan to the Iowa Department of Natural Resources. The
Department approved the plan that same year. In 2018, Boone's City Council passed an ordinance that gave
Boone's Sewer Department authority to inspect and disconnect sump pumps and roof drains from residences
connected to the sanitary sewer system or require that they pay a monthly fee on their utility bill. One year
later, in 2019, the Department of Natural Resources issued a wastewater treatment facility permit that allowed
the city to delay installing disinfection equipment to meet new bacteria limits by five years in order to more
quickly reduce SSOs and reduce infiltration and inflow.
Since plan approval, Boone has installed flow meters in 1 of the 4 pilot project areas and disconnected 60
sump pumps from the sanitary sewer to reduce inflow. The city reports that this has reduced the amount
of wastewater flowing to the wastewater treatment facility by 30 percent, which is more than half of the
50 percent flow reduction goal. Sequencing the infiltration and inflow work first led to less water flowing
to the wastewater treatment facility, thus reducing the size of the disinfection system needed and saving
the city about $500,000 to $750,000. In 2019, the city also has received no basement backup complaints
from residences in the pilot area, down from the 15-20 complaints it had received before disconnecting the
residents' sump pumps.
Kate Shelley High Bridge, crossing over the Des Moines River.
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24
Johnson County, Kansas
EPA Region 7
Johns® n county
* KANSAS
Wastewater
2019 Integrated
Management Plan
600,000 population
SSO IIWWTF
.Q
I
A paddle boarder enjoying the lake
at Shawnee Mission Park. Photo
courtesy of Donna Daugherty.
With a population of about 600,000 people, Johnson County is the
most populous county in Kansas. Located just west of Kansas City,
Missouri, Johnson County is home to several growing suburbs and
two of the four largest cities in Kansas (Overland Park and Olathe).
Johnson County Wastewater operates a sewer system that collects
and transports wastewater to six wastewater treatment facilities that
discharge to tributaries of the Kansas and Blue Rivers. One of these
tributaries, Little Bull Creek, flows into Hillsdale Lake, which is the
centerpiece of a popular local state park.
Challenges
During heavy storms, stormwater and groundwater enter Johnson
County's sanitary sewer system through cracks and improper
connections (i.e., infiltration and inflow). Under these conditions, the
capacity of the sewer system and treatment facility may be exceeded,
resulting in SSOs. In some parts of the county, satellite facilities
partially treat a portion of these SSOs before they are released.
However, in other areas, SSOs discharge sewage directly into the Blue
and Kansas Rivers.
In early 2019, Johnson County made plans to tackle complex
challenges associated with Clean Water Act requirements. The county
needed to protect water quality in local waterways by addressing
eight TMDLs as implemented in six separate wastewater treatment
facility permits. The county expected two additional TMDLs to be
incorporated into the permits during the next permit term. It also
anticipated new ammonia limits at two of the wastewater treatment
facilities, which would require major capital improvements to comply
with such limits.
In addition to meeting water quality requirements, the county wanted
to explore increasing land application of biosolids and cogeneration
of methane at wastewater treatment facilities. This would use
resources more efficiently and reduce operating costs and adverse
environmental impacts caused by chemicals in the biosolids.
Integrated Planning in Action
To address water quality challenges and pursue these other
environmental priorities, the county created a multi-phased 25-year
schedule to address immediate compliance requirements and then
refine the plan as appropriate based on additional data.
Johnson County began the first phase by identifying ongoing projects
and necessary infrastructure improvements based on previous
planning efforts and wastewater system assessments. The county
then reviewed existing capital improvement projects and chose
possible solutions to water quality challenges, such as wastewater
-------
25
treatment facility upgrades and collection system
repair and replacement. The county prioritized these
projects based on their ability to achieve three main
objectives: environmental protection, customer
service, and community enhancement. They also
identified seven sub-objectives (see details in the
box below).
Based on this analysis, the county developed
its 25-year schedule of projects. The schedule
included as many of the highest-priority projects
as possible, while maintaining affordability for rate
payers. The county addressed collection system
challenges by including projects to increase storage
and conveyance capacity, reduce public and private
sources of infiltration and inflow, and rehabilitate the
existing infrastructure. The county sequenced these
projects so the ones that met the most objectives,
such as expansion and treatment upgrades at three
wastewater treatment facilities and the elimination
of satellite facilities, would occur within the first
10 years. Projects that did not address multiple
objectives, such as resource recovery and expansion
of two other wastewater treatment facilities, fell
later in the schedule. Johnson County estimated
that the projects in this first phase of the integrated
plan would have a total capital cost of $2.07 billion
over the 25-year planning period (2020-2044) (see
graphic to right).
The second phase of planning will refine the 25-year
schedule using more detailed planning studies and
a more comprehensive assessment of community
priorities. After the second phase ends in late
Sub-Objectives for Prioritizing Projects in
Johnson County
¦ Improve water quality
¦ Meet regulatory obligations
¦ Efficiently use and protect natural resources
¦ Minimize human health and property impacts
¦ Achieve financial benefits
¦ Be a good neighbor
¦ Foster responsible growth and important
development
Projected Distribution of 25-Year Integrated
Management Plan Costs by Category
16% WWTF and pump
station renewal ($336M)
4% Planning and
support ($86M)
Total
Program 5% Collection system
Costs renewal ($108M)
2020-2044
9% System capacity and
/ peak excess flow
13% System expansion and / treatment facility
misc. projects ($268M) / elimination ($190M)
,
13% System expansion and
misc. projects ($268M)
1 Cost includes $173 million expenditure for Tomahawk Creek WWTF prior to 2020.
2022, Johnson County plans to monitor project
performance and update the integrated plan at least
every five years to achieve the greatest benefits.
The county used existing community engagement
programs and input from the Board of County
Commissioners to solicit feedback on the first
phase of planning. The first-phase Integrated
Management Plan indicates that the second phase
will include broader engagement to support a more
comprehensive assessment of community priorities.
Results
In 2019, Johnson County submitted the Integrated
Management Plan to the Kansas Department of
Health and Environment (KDHE), which implemented
the plan through a consent order that same year. The
consent order included implementation schedules
for nitrogen and phosphorus removal at two of
the wastewater treatment facilities, and eventual
elimination of satellite facilities as the county
increases collection and full treatment capacity.
KDHE issued amended permits for these two
wastewater treatment facilities in 2020. The permits
acknowledged the receipt of the integrated plan and
indicated that KDHE would use the plan when making
future regulatory decisions. The county expects to
complete the prioritized wastewater treatment facility
expansion project by spring 2022.
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26
Lawrence, Kansas
EPA Region 7
^ City of Lawrence
.Q
Integrated 2012 Wastewater
Utilities Plan
100,000 population
SSO IIWWTF
3,
Kansas River and the Bowersock Dam in
downtown Lawrence. Photo courtesy of
Josh Carson, City of Lawrence.
Lawrence, Kansas, has a population of nearly 100,000 and lies
between the Kansas and Wakarusa Rivers. Lawrence operates a
separate sewer collection system along with a storm sewer system.
Before 2018, it had one wastewater treatment facility that discharged
to the Kansas River. This river was historically used for steamboat
traffic but is now a popular location for recreation and culture. The
portion that flows through Lawrence is literally a work of art: an
internationally known earth artist created a rock mural on the bank of
the river near downtown.
Challenges
During heavy storms, stormwater and groundwater entered
Lawrence's sanitary sewer system through cracks and improper
connections {i.e., infiltration and inflow). This led to SSOs that
discharged sewage to the Kansas River. Meanwhile, more stringent
effluent limits were about to be set for the wastewater treatment
facility due to concerns about nutrient pollution in the Kansas River.
The city had just one wastewater treatment facility and Lawrence's
growing population required the city to plan for a second wastewater
treatment facility to avoid exceeding the existing facility's capacity.
Integrated Planning in Action
Lawrence used an integrated planning approach to identify affordable
projects to increase wastewater treatment and flow capacity. The
city created project categories and prioritized projects from these
categories based on improvements needed to meet current capacity
requirements, followed by those that provided capacity for future
growth in the service area. The city then performed a cost-benefit
comparison between the projects and calculated the rate impacts on
customers under different scenarios. Finally, Lawrence city officials
sought public input on the population projections used to develop
the wastewater master plan through capital improvement planning
hearings and a public comment process.
Project Categories
¦ Existing collection system improvements
¦ Existing collection system rehabilitation
¦ New wastewater treatment facility
¦ Existing wastewater treatment facility improvements
¦ Annual wastewater utility maintenance
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27
Lawrence considered all of these data and
documented the selected projects in the integrated
plan:
¦ The EcoFlow Rapid Rainwater Reduction
Program, designed to reduce infiltration and
inflow by 35 percent in the defined project area.
The program would reduce the flows entering the
collection system during wet weather, decreasing
the need for collection system capacity projects.
¦ Construction of new sewer infrastructure to
convey flows during large storms to the existing
wastewater treatment facility.
¦ Infrastructure for and construction of a new
wastewater treatment facility.
¦ Improvements to the existing wastewater
treatment facility to comply with anticipated
nutrient limits.
The cost of the integrated plan was estimated at
$161.2 million through 2030—$148.3 million for
existing system improvements and $12.9 million for
service to future growth areas.
Results
In 2014, the Integrated 2012 Wastewater Utilities
Plan was implemented through a memorandum of
understanding between the city and KDHE; in 2019,
KDHE issued permits for both wastewater treatment
facilities that incorporated the memorandum. This
agreement included a 20-year implementation
schedule for integrated plan projects. In 2014, the city
implemented the EcoFlow Rapid Rainwater Reduction
Program to reduce infiltration and inflow. As of 2020,
Lawrence had completed over 1,900 private property
infiltration and inflow repairs, over 600 manhole
repairs, and over 400 sanitary sewer repairs, as
weii as lining approximately 200,000 iinear feet of
sanitary sewer pipe to reduce infiltration and SSO
events. The city finished building its new wastewater
treatment facility in the spring of 2018.
Kansas River above the Bowersock Dam, looking south toward Burcham Park Trail.
Photo courtesy of Josh Carson, City of Lawrence.
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28
Columbia, Missouri
EPA Region 7
GjjQ city of
Columbia
Sewer & Stormwater Utilities
Columbia Wastewater and
Stormwater Integrated
Management Plan
-Q
120,000 population
SSO IIWWTF
Columbia is Missouri's fourth largest city, with a population of about
120,000. It is located near the geographic center of the state and is
well known for its urban streams and lakes. Columbia manages its
wastewater through a separate sanitary sewer that the city owns and
operates. It transports sewage to the city's wastewater treatment
facility, which discharges to the Eagle Bluffs Conservation Area—a
large wetland that eventually drains into the Missouri River. Columbia
also operates a storm sewer system that is permitted jointly with
Boone County and the University of Missouri. The storm sewer
system discharges to Missouri River tributaries, including Hinkson
Creek, which runs through Columbia and features several trails and
parks along its path.
Challenges
During heavy storms, stormwater and groundwater enter Columbia's
sanitary sewer system through cracks and improper connections
(i.e., infiltration and inflow). This leads to SSOs that discharge sewage
to the city's waterways, and it causes sewage to back up into
basements. In 2011, the Missouri Department of Natural Resources
(MDNR) initiated enforcement negotiations with the city to address
SSOs. Around the same time, MDNR and EPA developed a TMDL for
Hinkson Creek for biological impairment, an indication that pollution is
negatively affecting aquatic life in the water body. This is in part due to
stormwater discharges from Columbia, the University of Missouri, and
Boone County. In 2013, the city invested $64 million to expand and
upgrade its wastewater treatment facility to meet new permit limits
for ammonia. The city anticipated that more nutrient, bacteria, and
dissolved oxygen limits would be incorporated into the wastewater
treatment facility permit during future permit terms that would cost
another $40 million.
Triple Bottom Line Weighted Criteria Developed
Through Community Outreach
0.25
0.20
0.15
0.10
0.30
0.20
0.20
0.15
0.15
Protect public Improve quality Provide Improve water Comply with
health and safety of life sustainable service quality regulations
for the future
| Social objectives
| Economic objectives
Environmental objectives
Integrated Planning in Action
In 2017, Columbia and MDNR
agreed that the city would develop
an integrated plan to prioritize
wastewater and stormwater
improvements for consideration in
future regulatory decisions (graphic
to left). The city hosted a two-day
workshop with representatives
from various city departments,
the University of Missouri, Boone
County, and the Boone County
Regional Sewer District to develop
goals for the integrated plan and
-------
Hinkson Creek shows off its autumn colors.
Photo courtesy of City of Columbia
strategies to meet those goals. The city kept the
public engaged throughout the planning process by
distributing fact sheets, developing a project website,
issuing press releases, posting updates on social
media, developing an online survey, and conducting
community workshops. Through these workshops,
the city developed community objectives to be used
when evaluating plan options (see box to right).
Columbia developed three funding levels, each with
a combination of sanitary sewer collection system,
wastewater treatment facility, and storm sewer
system projects that met or exceeded existing Clean
Water Act obligations. The funding levels represented
incremental amounts of infrastructure service,
community expectations, and anticipatory project
commitments:
¦ Level 1: Projects to meet community expectations
and current Clean Water Act requirements.
¦ Level 2: All projects from Level 1 plus other
infrastructure commitments to meet known future
Clean Water Act requirements.
¦ Level 3: All projects from Level 2 plus additional
projects that meet all anticipated future
infrastructure needs and Clean Water Act
requirements.
After outlining the three funding levels, city staff
calculated a total benefit score for each suite of
projects that represented the anticipated value
they would produce for the community. Community
priorities established throughout the outreach
program formed the basis for the scoring criteria
and process. The city then conducted a benefit-cost
Community Objectives for Columbia's Integrated
Planning Process
¦ Meet Clean Water Act requirements
¦ Protect important regional waterbodies
m Protect or improve water quality in city streams
¦ Provide services to growing areas
¦ Improve services to underserved and
redeveloping areas
¦ Renew systems beyond effective life
¦ Reduce potential for property damage
» Provide community-wide benefits
¦ Reduce safety hazards from system failures
analysis for each suite of projects under each level.
Based on this comparison, the city determined that it
would be most cost effective to create an optimized
suite of alternatives composed of wastewater
treatment facility and collection system projects from
Level 1 and stormwater projects from Level 2.
Columbia preferred this optimized program portfolio
for its integrated plan. The city estimated that its plan
would require $1.02 billion over 20 years for capital
and programmatic costs. To ensure affordability and
produce the greatest possible benefits to human
health and water quality, the plan proposed revising
assumptions every 5-10 years for project costs,
implementation dates, socioeconomic conditions, and
regulatory requirements.
Results
The Columbia Wastewater and Stormwater
Integrated Management Plan was adopted by the
Columbia City Council in 2019 and implemented in
the wastewater treatment facility and storm sewer
permits MDNR issued in July 2020. In the permits,
MDNR committed to using the plan when making
future regulatory decisions. Columbia's wastewater
treatment facility permit required an annual progress
report on any proposed updates to the plan, the
past year's implementation activities, and the
implementation activities proposed for the
following year.
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30
Springfield, Missouri
EPA Region 7
Springfield - Greene County, Missouri
Integrated Plan
for the Environment
Integrated Plan for the
Environment
.Q
167,000 population
MS4 II SSO IIWWTF
Paddle boarders enjoying Lake Springfield.
Photo courtesy of Springfield Convention
and Visitors Bureau.
Located in the heart of the Ozarks, Springfield is the third largest city
in Missouri, with a population of more than 167,000. The city manages
a separate sanitary system as well as a storm sewer system and
operates two wastewater treatment facilities. One of these discharges
to the James River Watershed and the other discharges to the Sac
River Watershed. Springfield's storm sewer system discharges to
tributaries of the James River. The James River is a popular recreation
destination and features a 6-mile "water trail" for canoeing and
kayaking that flows through Springfield and connects to the Trail
of Honor—a riverside walking trail that winds through the Missouri
Veterans Cemetery.
Challenges
During heavy storms, stormwater and groundwater enter Springfield's
sanitary sewer system through cracks and improper connections
(i.e., infiltration and inflow). This leads to SSOs and bypasses at the
wastewater treatment facilities. In 2012, Springfield agreed to address
SSOs and reduce bypasses under an amended consent judgment
with MDNR. This judgment required the city to spend $50 million and
complete Early Action Plan projects in the first seven years while it
developed an overflow control plan.
Springfield must also comply with two wastewater treatment facility
permits and a stormwater permit that implement TMDLs for bacteria in
the Little Sac River and nutrients in the James River. Some local rivers
and streams are also impaired by polycyclic aromatic hydrocarbons in
stormwater runoff from driveways and parking lots.
Integrated Planning in Action
The city, Greene County, and city utilities developed a "citizen-
focused approach" to address water quality impairments and other
community priorities using local knowledge to holistically examine the
city's environmental resources. The city organized an Environmental
Priorities Task Force of community members, city and county staff,
and technical experts to address these challenges and identify other
priorities important to the community. This group set goals and worked
together to identify affordable solutions to wastewater and stormwater
challenges, as well as to meet solid waste and air quality objectives,
using four key elements (see box on page 31). The task force
identified and ranked sources of pollution based on the impact on
the environment. They then identified possible strategies to address
these sources and conducted a cost-benefit analysis to determine
which strategies would provide the most social and environmental
benefit per dollar spent. Using this process, Springfield determined
that the most cost-effective strategies to pursue were stormwater
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31
detention basin retrofits, enhanced nutrient removal
at one of the city's wastewater treatment facilities,
programs to reduce polycyclic aromatic hydrocarbons
in stormwater, and SSO controls to reduce infiltration
and inflow of water into the sanitary sewer system.
Springfield did not select specific projects during the
planning process, but rather committed to pursue
projects that align with the selected strategies.
Results
In 2015, Springfield released its Integrated Plan for
the Environment. That same year the city completed
an SSO control plan that—based on findings from
the integrated planning process—identified and
compared solutions to control SSOs. The approved
overflow control plan included $200 million in SSO
improvements to be completed over 10 years (by
2025). MDNR approved Springfield's integrated
plan and referenced it in the city's 2017 municipal
stormwater permit and 2020 wastewater permits.
These permits require that Springfield identify cost-
effective solutions to address the most significant
sources of pollution as proposed in the integrated
plan. Since the stormwater permit was issued,
Springfield has implemented a "Clean Pavement
Initiative" that encourages businesses and residents
to voluntarily choose sealants for parking lots and
driveways that are lower in polycyclic aromatic
Key Elements
¦ Prioritizing the most significant pollution sources
¦ Prioritizing cost-effective solutions
¦ Capturing community priorities
¦ Assessing financial capability
Approach for Ensuring a Sustainable Return on
investment, Using the Four Key Elements as Guidance
Identify and
prioritize
the most
significant
problems
Assess community's
financial capability
hydrocarbons. Several businesses and citizens
have committed to choose asphalt-based sealant
and received signage showing their commitment.
Springfield also implemented a pilot voluntary
detention basin retrofit program, completing the first
project in 2019.
community's priorities
Identify and
prioritize
the most
significant
solutions
Kayakers on the James River. Photo courtesy
of Springfield Convention and Visitors Bureau
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32
Seattle, Washington
EPA Region 10
Seattle
N Public
Utilities
Q
2015 Plan to Protect
Seattle's Waterways
700,000 population
Seattle, Washington, is the largest city in the Pacific Northwest, with
a population of more than 700,000. This seaport city is located in
King County, sandwiched between Puget Sound—the second largest
estuary in the United States—and Lake Washington. Seattle operates
a combined sewer system and a separate storm sewer system. The
combined sewer system brings stormwater and sewage to one of
the six wastewater treatment facilities owned and operated by King
County. The storm sewer system discharges about 13 billion gallons
of stormwater per year. These facilities and systems discharge to
Puget Sound, Elliott Bay, Lake Washington, and the Lower Duwamish
Waterway.
Challenges
Between 2007 and 2010, about 200 million gallons of sewage
entered Seattle's local water bodies every year through CSOs and
unauthorized discharges. Both CSOs and stormwater discharges
add metals, total suspended solids, nutrients, bacteria, and organic
compounds to local waterways. In 2013, the city agreed to reduce
CSO discharges to meet the Washington Department of Ecology's
limit of one overflow per outfall per year. The consent decree required
Seattle to develop a CSO LTCP and complete construction of CSO
projects by 2025. It also gave Seattle an alternative: develop an
integrated plan and potentially extend the CSO project construction
deadline, but only if the integrated plan results in significant water
quality improvements beyond what the CSO projects under the LTCP
would have achieved alone.
Integrated Planning in Action
In 2013, Seattle began to develop two plans: an LTCP with CSO projects and an integrated plan with both
CSO and stormwater projects. The city engaged the public throughout the planning process. Seattle made
information available through community updates, briefings, animations, visualizations, website videos and
updates, and an email listserv. The city solicited input through public information meetings, scoping sessions,
online questionnaires, and emails.
Seattle identified potential stormwater projects to include in the integrated plan, then ranked these projects
based on water quality impacts and other criteria (see details in the box on page 33). The city then compared
the highest-ranking stormwater projects with the lowest-ran king CSO projects.
Using this analysis, Seattle developed an integrated plan with three stormwater projects that it determined
would provide better public health and environmental benefits than the CSO projects alone. Modeling showed
that these stormwater projects would remove larger quantities of PCBs, fecal coliform, phosphorus, and other
pollutants. They include:
¦ Reconstructing city rights-of-way to include bioretention basins (a green infrastructure practice) that
infiltrate stormwater to reduce the amount discharged and remove pollutants.
¦ Building a facility to treat stormwater from a largely industrial area.
¦ Increasing street sweeping on major roads to minimize stormwater contamination.
CSO I MS4
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33
The integrated plan also included several large,
more effective CSO projects—such as sewer system
improvements, CSO storage facilities, and a new
tunnel—that were expected to lead to significant
reductions in pollution. The plan deferred completion
of six other small CSO projects beyond 2025.
Seattle's analysis concluded that the integrated
plan would achieve greater water quality benefits
than the LTCP. Even with certain CSO projects
deferred, the stormwater projects would treat a
much larger volume of stormwater than the deferred
CSO projects, resulting in greater reductions of
total suspended solids, metals, bacteria, and other
pollutants. For example, Seattle estimated that the
integrated planning projects would remove 110 more
pounds of zinc per year than the LTCP projects alone.
The city projected that enhanced street sweeping
would keep an estimated 40 tons of total suspended
solids out of waterways every year.
Seattle estimated that the integrated plan would
cost a total of $592 million over 20 years, including
both capital and operation and maintenance costs.
Stormwater projects accounted for $88 million—
about 15 percent of the total cost. The integrated plan
included $450 million in non-deferred CSO projects
and proposed to defer $54 million in CSO projects
until 2028-2030, which is later than the consent
decree and LTCP. The integrated plan was ultimately
more expensive than the LTCP option, but it extended
CSO project implementation by four to five years, and
the proposed stormwater projects were predicted
to achieve greater water quality benefits than the
deferred CSO projects.
Results
EPA and the Washington Department of Ecology
approved the Plan to Protect Seattle's Waterways
in 2015. The city's CSO discharge permit, issued in
2016, required two of the three proposed stormwater
projects {i.e., bioretention in city rights-of-way and
street sweeping) and deferred the six small CSO
projects in accordance with the schedule identified in
Seattle's integrated plan.
Elliott Bay with Seattle skyline. Photo courtesy
of Seattle Parks and Recreation.
Seattle's Selection Process for Integrated
Plan Projects
To choose projects for the integrated plan, Seattle:
¦ Modeled pollutant reduction of each project
¦ Estimated each project's effectiveness at reducing
human and animal exposure to bacteria and other
harmful pollutants
¦ Determined how close each project wouid be to
planned stormwater projects
m Ranked stormwater and CSO projects based
on water quality impacts, proximity to existing
stormwater projects, performance risk, operation and
maintenance costs, and community values
¦ Compared the benefits of prioritized stormwater
projects and lower-volume CSO projects to ensure
that the stormwater projects would achieve
significantly higher benefits
As of 2018, the city reduced CSO discharges by 41
percent. During 2018, the street sweeping program
removed nearly 60 tons of total suspended solids.
Seattle finished constructing right-of-way bioretention
in one area in 2017 that was designed to reduce
CSO discharge volume by one million gallons per
year. This green infrastructure project also benefits
the community by increasing pedestrian activity,
calming traffic, improving aesthetics, and increasing
public awareness of how impervious surfaces
affect stormwater. In April 2020, Seattle Public
Utilities received a $192 million Water Infrastructure
Finance and Innovation Act loan to help finance an
underground storage tunnel recommended in the
plan. This storage tunnel is designed to reduce CSOs
at 6 outfalls, and its construction is expected to
create over 1,000 jobs.
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34
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A1
Appendix A: Summary of Municipalities with
Integrated Plans Implemented Through Permits,
Orders, or Judicial Consent Decrees
Richmond's business district seen from the south bank of the James River,
just above the river's fall line. Photo courtesy of West Cary Group.
fnimtn
-------
Permittee
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of New
Bedford,
Massachusetts
1
Long
Term CSO
Control and
Integrated
Capital
Improvements
Plan
2017
Consent Order
Docket No. CWA-
AO-R01-FY20-15
issued in 2019
CSO, MS4,
SSO, WWTF
Yes
The consent order
includes both CSO
and non-CSO
projects in lieu of
the traditional LTCP
required by the 2012
order.
The consent order
includes a modified
schedule composed
of WWTF, stormwater,
wet weather sewer,
and general sewer
projects within the
first six years (2017—
2023).
The plan included
a budget of $260M
over 20 years:
¦ $28.3M for WWTF
¦ $49.3M for
pumping stations
¦ $143.2M for CSO
improvements
¦ $0.2M for wet
weather sewer
¦ $22M for general
sewer
¦ $5.1 M for
stormwater
¦ $5.8M for flood
control structures
¦ $6.7M for vehicles,
equipment, and
administration
City of
Springfield,
Massachusetts
1
Springfield
Water and
Sewer
Commission
Integrated
Wastewater
Plan
2014
Administrative
Order No. 14-007
issued in 2014
CSO, SSO
No
The administrative
order required
completion of two
phases of CSO
improvement
projects.
The administrative
order required
one phase of CSO
improvements to be
completed by the
end of 2020, and the
other by the end of
2021.
The plan included a
budget of $447M in
total estimated costs
over 20 years:
¦ $183M for CSO
improvements
¦ $294M for
wastewater
projects
¦ $14.8M for shared
cross-utility
projects
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
-------
Permittee
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of
Richmond,
Virginia
3
2017 RVA
Clean Water
Plan
2017
VPDES Permit
No. VA0063177
issued in 2018
CSO, MS4,
WWTF
Yes
The permit includes
aggregated load
reduction targets
(based on MS4,
WWTF, and
CSO waste load
allocations) for
total nitrogen, total
phosphorus, total
suspended solids,
and bacteria. The
permit establishes
factors, including
adequate funding,
a benefit-cost
ratio, and pollution
reduction benefits
when choosing
and implementing
stormwater and
combined sewer
system focused
projects.
The city's permit
requires that projects
described in the RVA
Clean Water Plan be
implemented in the
five-year permit cycle.
The plan included a
budget of $431M:
¦ $34M over five
years for green
infrastructure
capital
¦ $5M over five
years for green
infrastructure
operation and
maintenance
¦ $392M over 30
years for CSO
infrastructure
City of Atlanta,
Georgia
4
Integrated
Plan for the
City of Atlanta
Draft
completed
2019
NPDES Permit
Nos. GA0037168
and GA0038644
issued in 2015
CSO, MS4
Yes
The two permits
required the city to
develop an integrated
plan, and in 2019, the
Georgia Department
of Natural Resources
determined that the
plan satisfied the
permit conditions.
The permits do not
include a compliance
schedule.
A project list and
budget have not
been proposed.
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
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Permittee
EP
Reg
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of Akron,
Ohio
5
Integrated
Plan
2015
NPDES Permit
No. OH0023833
issued in 2020
OEPA Consent
Decree 5:09
cv 00-272
amendments
issued in 2016
and 2019
CSO, WWTF
Yes
The two consent
decree amendments
allow for revised
sequencing of
projects and controls.
The first amendment
modified the design
of an interceptor
project and revised
sequencing of two
projects, allowing
for an increase in
secondary treatment
capacity ahead of the
original schedule. The
second amendment
revised the side-
stream treatment to
add storage capacity
and replace gray
infrastructure with
green infrastructure.
The first consent
decree amendment
required the
installation of
additional secondary
treatment capacity
to be completed by
April 30, 2019, and
side-stream treatment
is required by the end
of 2021.
The plan included a
budget of $1.4B over
25 years:
¦ $502M for
annual projects
(e.g., renewal,
monitoring)
¦ $857M for CSO
projects
- $773M for
collection
system
improvements,
including
$330M for
alternative
projects
(e.g., green
infrastructure,
sewer
separation)
- $84M for
WWTF capacity
improvements
¦ $79M for non-CSO
projects
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
-------
Permittee
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of
Columbus,
Ohio
5
Blueprint
2035
2015
OEPA Consent
Order Case Nos.
02-CVH-05-5768
and 04-CVH-05-
5336 issued in
2015
NPDES Permit
No. OH0024741
issued in 2017
CSO, SSO
Yes
OEPA approved the
plan and indicated
it met consent order
requirements. The
plan included CSO/
SSO reduction
through green
infrastructure and
infiltration and inflow
reduction in addition
to a revised set of
collection system
improvements.
The approved
Blueprint plan
includes an
implementation
schedule ending in
2035.
The plan included
a budget of $1.74B
over 20 years:
¦ $400M for gray
infrastructure
projects identified
in the 2005
Wet Weather
Management Plan
¦ $1.33B for green
infrastructure and
infiltration and
inflow reduction
projects
¦ $60M for
operation and
maintenance
City of Lima,
Ohio
5
Integrated
Plan
2014
Consent Decree
Case No. 3:14 CV
2551 issued in
2015
CSO, SSO,
WWTF
Yes
The project list
from the plan is
included in Appendix
A of the consent
decree. Projects
include WWTF
improvements, CSO
control measures,
and SSO control
measures.
The consent decree
required submittal
of a WWTF Flow
Maximization Plan by
July 1, 2018, and full
operation of all CSO
control measures by
August 30, 2024.
The plan included
a budget of $148M
over 28 years:
¦ $40.7M for CSO
improvements
¦ $29.2M for WWTF
improvements
¦ $30.3M for
SSO abatement
improvements
¦ $30.8M for asset
management
¦ $16.5M for
stormwater
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
-------
Permittee
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of Boone,
Iowa
7
Integrated
Wastewater
Plan
2016
NPDES Permit
No. IA0079421
issued in 2019
SSO, WWTF
No
The permit allows
the city additional
time to install
WWTF disinfection
equipment in order to
prioritize completion
of infiltration and
inflow projects.
The permit revises
the final compliance
date for established
bacteria limits to
March 1,2023. The
original deadline was
May 1, 2018.
The plan included
a budget of $15.4M
over 16 years:
¦ $10M in capital
costs
¦ $5.4M for
operation and
maintenance
Johnson
County, Kansas
7
Integrated
Management
Plan
2019
Consent order
Case No. 19-E-5
BOW issued in
2019
SSO, WWTF
No
The consent
order requires
implementation
of the integrated
plan, including
implementation
schedules for
nitrogen and
total phosphorus
removal at two of
the WWTFs and
an implementation
schedule to address
satellite facility
discharges.
The consent order
requires that the
city implement the
proposed 25-year
schedule in the
integrated plan, which
includes satellite
facility upgrades in
the first 6 years and
2 WWTF upgrades in
the first 10 years.
The plan included
a budget of $2.07B
over 25 years:
¦ $1.08B for major
facility upgrades
¦ $336M for WWTF
and pump station
renewal
¦ $86M for planning
and support
¦ $108M for
collection system
renewal
¦ $190M for system
capacity and
satellite facility
elimination
¦ $268M for system
expansion
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
-------
Permittee
EP
Reg
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of
Lawrence,
Kansas
7
Integrated
2012
Wastewater
Utilities Plan
2012
Kansas River
WWTF Permit
No. KS0038644
issued in 2019
Wakarusa River
WWTF Permit
No. KS0099031
issued in 2019
SSO, WWTF
No
Each permit includes
a supplemental
information section
that references
the integrated
plan the Kansas
Department of Health
and Environment
reviewed and
approved. It also
cites a Memorandum
of Understanding
between the
Department and the
city that requires
the wastewater and
stormwater collection
system improvements
in the plan per the
established schedule
as well as annual
reporting.
The Memorandum
of Understanding
establishes the
18-year schedule
proposed in the
plan, which includes
collection system
rehabilitation and
construction of
a new WWTF to
start in 2013. Other
collection system
projects are projected
to start between
2013 and 2030. The
Kansas River permit
requires efforts to
reduce nitrogen and
phosphorus through
mechanical methods
and report the results
to the Department
by February 1, 2017.
The Wakarusa River
permit outlines a
phased-in approach
for future plant
expansion.
The plan included
a budget of
$161M for capital
improvements:
¦ $148M for
existing system
improvements
¦ $12.9M for service
to future growth
areas
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
-------
Permittee
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of
Columbia,
Missouri
7
Wastewater
and
Stormwater
Integrated
Management
Plan
2018
NPDES Permit
Nos. M00097837
and MO0136557
Issued in 2020
MS4, SSO,
WWTF
No
The city's WWTF
permit required
an annual
implementation
progress report
that includes any
proposed updates
to the plan,
the past year's
implementation
activities, and
the planning
implementation
activities for the
following year.
The approved plan
includes a 20-year
implementation
schedule.
The plan included
a budget of $1.04B
for capital and
programmatic costs
over 20 years:
¦ $227M for
stormwater
improvements
¦ $816M for
wastewater
improvements
City of
Springfield,
Missouri
7
Integrated
Plan for the
Environment
Draft
completed
2015
NPDES Permit
No. MO0126322
issued in 2017
MS4, SSO,
WWTF
No
The MS4 permit
states that it is the
intent of the Missouri
Department of
Natural Resources
for the city to
continue to identify
affordable and
effective solutions
in accordance with
the integrated plan.
In addition, the MS4
permit indicates that
the permittee may
submit an integrated
plan as an approach
for implementing its
TMDL assumptions
and as an attainment
plan if one is
required.
The permit does not
include a compliance
schedule.
A project list and
budget has not been
proposed.
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
-------
Permittee
EP
Reg
Plan Name
Year Plan
Completed
Implementation
Mechanism(s)
Discharges
Addressed
Green
Infrastructure
Proposed
Integrated Control
Measures/Levels
of Control
Compliance
Schedule for
Requirements
Proposed Costs in
Plan
City of Seattle,
Washington
10
Plan to
Protect
Seattle's
Waterways
2015
NPDES Permit
No. WA0031682
issued in 2016
Consent Decree
Case Number
2:13-cv-00678
issued in 2013
CSO, MS4
Yes
The permit requires
completion of the
non-deferred LTCP
and two of the three
proposed stormwater
projects. The consent
decree allowed the
city to submit an
integrated plan to
meet consent decree
requirements and
required the city to
implement the plan
upon approval.
The permit lists
required LTCP and
integrated plan
projects and specified
completion dates.
The permit required
construction of
natural drainage
systems to begin
by July 2019 and
post-construction
monitoring of
street sweeping
expansion arterials
to be complete by
September 2019.
The plan included a
budget of $592M for
capital improvements
and operation and
maintenance over 16
years:
¦ $450M in non-
deferred LTCP
costs
¦ $54M in deferred
LTCP costs
¦ $88M in
stormwater project
costs
Abbreviations
CSO: combined sewer overflow; LTCP: long-term control plan; MS4: municipal separate storm sewer system; NPDES: National Pollutant Discharge Elimination System; OEPA: Ohio Environmental Protection
Agency; SSO: sanitary sewer overflow; VPDES: Virginia Pollutant Discharge Elimination System; WWTF: wastewater treatment facility
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