Integrated Planning in Action

Adapting for Success

EPA's Integrated Municipal Stormwater and Wastewater Planning Approach Framework helps
municipalities meet clean water goals while prioritizing infrastructure investments with the greatest water
quality improvements and community benefits. The Framework lays out a comprehensive, yet flexible
planning process based on a set of overarching principles. EPA created a series of fact sheets—including
this one—to inform municipalities interested in integrated planning.

This fact sheet provides recommendations for developing a process to adapt for success. Adapting
is critical for any infrastructure investment in an integrated plan—particularly investments that span a
long period during which a municipality may encounter changing conditions such as population growth,
increased storm intensity and frequency, land-use changes, or new permit requirements. Through
adaptive management, a municipality evaluates progress regularly and can pivot if projects are not
performing as expected or circumstances change.

Each integrated plan should describe how adaptive management will be used during implementation,
as described in Elements 5 and 6 of the Framework. Integrated plans should be assessed at a
predetermined frequency to ensure that the selected projects continue to align with overall community
goals and achieve the desired water quality and human health benefits.

Determine performance metrics.

Early in the integrated planning process, the
municipality should develop objectives that
describe how it will achieve broader plan goals
within a particular timeframe and the metrics to
meet these objectives. These objectives should be
SMART—specific, measurable, attainable, realistic,
and time-based. Developing SMART objectives
will help the municipality achieve infrastructure
and water quality goals to be addressed through
integrated planning.

The municipality should also develop SMART
metrics to track progress over time. Examples of
SMART metrics include:

¦	Annual pollutant load reductions from installed
stormwater control measures

¦	Percentage or volume of combined sewer
overflows (CSOs) reduced

Goal

A broad, qualitative statement of desired
achievements

Example: reduce the number of CSOs

Objective

A specific, measurable statement of what will be
done to achieve goals within a particular time frame

Example: reduce the discharged CSO volume by
50 percent by 2025

Strategy

A general approach or method: how the municipality
plans to achieve objectives and resolve issues

Examples: eliminate connected roof drains to reduce
infiltration and inflow, install green infrastructure to
retain runoff, build underground storage


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¦	Acres of land conservation or reforested land cover planted

¦	Acres of disconnected impervious areas that are treated by green infrastructure

¦	Reduction of bacteria/nutrients/sediment loading compared with an established baseline

Develop an approach for monitoring progress.

As described in Element 5 of the Framework, the municipality should
develop a monitoring plan to gather data it needs to calculate
progress or update and fine-tune pollutant ioading models that can estimate
progress toward objectives. The plan should establish:

¦	Monitoring parameters associated with metrics

¦	Monitoring location and frequency

¦	Sampling protocols

¦	Analytical methods

¦	A quality assurance project plan

Determining the appropriate monitoring and/or modeling approaches will depend on the types of
regulated sources in the plan, permit requirements, types of projects being implemented in the plan, and
the staff and budget available. For more guidance on how to develop a monitoring plan, visit:

¦	Discharge monitoring report guidance for stormwater general permit holders

¦	Industrial Stormwater Monitoring and Sampling Guide

¦	POTW's Procedures for Conducting Compliance Monitoring

¦	Guidance for Quality Assurance Project Plans

¦	Combined Sewer Overflows: Guidance for Monitoring and Modeling

¦	CSO Post Construction Monitoring Guidance

¦	Reviews of Representative Stream Assessment and Mitigation Protocols

¦	Rapid Assessment Protocols for Use in Streams and Wadeable Rivers

The municipality should make a plan that addresses training requirements for staff, safety during
monitoring, and ensuring an adequate budget. It may be useful to spread responsibilities across
departments or recruit external help (e.g., from local universities). The municipality should develop a
realistic monitoring frequency, one that will gather enough data while fitting the budget.

-Q

It seems absolutely
fundamental to be
able to adjust your
priorities as findings
change and new
priorities arise

—Dave Stewart,
Director of Engineering,
Harrisburg, Pennsylvania,
Capital Region Water

\

Identify and prevent any barriers to implementation.

Implementing an integrated plan requires
time and resource investments over the entire
plan schedule. When developing the plan, the
municipality should anticipate barriers to evaluating
it and updating it in the future. Factors to consider
include resources, staffing, and communication
between departments or outside entities—if
multiple groups are collecting and analyzing
monitoring data and writing plan updates, they will

Columbus, Ohio

The City of Columbus, Ohio,
partnered with Ohio State
University to measure the
water quality and quantity
impacts from its green
infrastructure projects in a
control area.


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need to coordinate with each other. For example,
they could hold periodic check-ins and use a
shared drive or online database. The municipality
should account for these types of challenges when
designing the adaptive management process.

Once the municipality has started implementing
the integrated plan arid monitoring approach, it
should continuously evaluate the approach and be
prepared to make changes if needed. This could
include checking periodically that the plan is on
schedule, holding regular staffing meetings, and
tracking budget closely throughout the process.
Adjustments may include changing sampling
locations, providing more training for staff, or
updating standard operating procedures.

Characterize progress.

A municipality should have a plan for evaluating monitoring data and using these data to describe
progress toward goals or to estimate progress with appropriate models. If the municipality used modeling
to evaluate projects or choose alternatives when developing the plan, it should consider how it will
update the models throughout the plan period and use the data to adapt. Post-construction monitoring
data can be used to recalibrate models and compare actual outcomes with anticipated outcomes. The
municipality should prepare a strategy to update the plan if the benefits are not comparable or the
models show that goals have not been met.

EPA has several publicly available tools that a municipality can use to estimate progress:

¦	Storm Water Management Model

¦	National Stormwater Calculator

¦	Watershed Management Optimization Support Tool

¦	Green Infrastructure Modeling Toolkit

¦	Assessment, Total Maximum Daily Load Tracking and Implementation System (ATTAINS)

¦	Water Quality Portal Data Discovery Tool

Seattle, Washington

The City of Seattle, Washington, developed a four-step
monitoring approach to determine pollutant reduction
effectiveness of bioretention facilities:

1 Continuously monitor flow

2.	Monitor water quality by sampling during storm
events

3.	Use flow data to model flow volumes for facilities not
monitored

4.	Calculate an average pollutant load reduction for all
facilities



Adapt and communicate integrated
plan implementation.

As described in Element 6 of the
Framework, the municipality should have a
process for improving the plan over time. It should
consider how to use monitoring data to adapt the
plan's projects and schedule to continue working
toward goals. Additional inputs, such as changes
in rainfall intensities or population density, should
also factor into updates to the projects or schedule
as appropriate. The municipality may also want
to consider updating stakeholders on progress

Johnson County, Kansas

Johnson County, Kansas, began its 25-year schedule with
a five-year action plan to implement near-term projects
while gathering more data to guide future improvements.
The county will use these project phases to keep
stakeholders engaged and incorporate their feedback in
future plan iterations.


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Richmond, Virginia
The City of Richmond,
Virginia's integrated permit
consolidated annual
reporting requirements
for the city's combined
sewer system and storm
sewer into a single annual
report submitted to the
Virginia Department of
Environmental Quality.
The report must include
activities and monitoring
results for the past year, as
weil as projects planned for
the next year.

to sustain support and solicit input on how the
integrated plan should be revised. Permitting
authorities typically require annual updates
on plan progress, but it may be appropriate
to do more in-depth assessments less often
depending on the schedule of projects. Some
integrated plans will have extended planning
horizons, so it is important that municipalities
incorporate adaptive management activities
into project implementation that may not align
with permit terms. The municipality should make
sure to communicate updates to the plan with
the permitting authority, either through required
reporting or additional meetings for more
substantive or longer-term changes.

Determine
performance metrics

Monitor progress

Prevent barriers to
implementation

Characterize
progress

Adapt

For more information, please visit EPA's Integrated Planning website.
EPA-832-F-22-007 I July 2022

&EPA


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