Leveraging the
Integrated Planning
Framework for
Advancing Climate
Resilience and
Environmental Justice

June 2022

|3j| ^	SCHOOL OF GOVERNMENT

Environmental Finance Center

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The Environmental Finance Center at the University of North Carolina at Chapel Hill | 1

Acknowledgments

Written by Omid Barr. Editorial assistance provided by Evan Kirk, Garrett Basnight, and
Christy Ihlo.

This report is made possible by the Environmental Protection Agency (US EPA). A special
thanks to Lead of the Green Infrastructure Program, Robyn DeYoung. We would also like
to thank those that gave us their valuable time in interviews to help us develop these case
studies including:

Nancy Gallinaro

Water Resources Manager

Department of Public Works, Portland, Maine

Jim Pletl, PhD

Director of Water Quality
Hampton Roads Sanitation District

Cissy Ma, PhD, PE

US EPA ORD

Center for Environmental Solutions and Emergency Response Water Infrastructure
Division

Grace LeRose

Program and Operations Supervisor
Department of Public Utilities, Richmond, VA

Marlene Feist

Director of Public Works

Department of Public Works, Spokane, WA

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Contents

INTRODUCTION	3

INTEGRATED PLANNING FRAMEWORK, CLIMATE CHANGE,
AND ENVIRONMENTAL JUSTICE CONSIDERATIONS	4

Portland, Maine: Heavier Rains and Water Quality
Mandates	4

Hampton Roads Sanitation District (HRSD): Adapting to
the Impacts of Sea-Level Rise	7

The Kickapoo River Watershed: A Cost-Effective Approach
to Climate Adaptation and Mitigation	9

Richmond, Virginia: Addressing Inequities Through
Stakeholder Involvement	11

Spokane, Washington: Delivering a Cleaner River for the
Community	13

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Introduction

Climate change is causing increases in both total precipitation volume and precipitation
intensity. A warming climate also causes seawater to expand and ice over land to melt,
contributing to sea level rise. These changes in global patterns increase the frequency and
severity of storm surges and coastal flooding, causing serious damage to critical public
water infrastructure. For both municipal separate stormwater systems (MS4) and combined
sewer systems, increased rainfall will produce increased storm runoff, which can exacerbate
existing or introduce new pollution problems. Stormwater can overwhelm storm sewer
systems, especially in an era of faster, more frequent, and more intense wet weather events.
Uncontrolled stormwater runoff can cause urban flooding and threats to the human-built
environment.

Lower income communities, particularly communities of color, already face
disproportionate impacts of stormwater flooding including sanitary sewer backups in
basements flood exposures, disaster damage outcomes from heavy rainfall events, economic
impacts, and efforts to build resilience. Those impacts are only expected to worsen with
climate change.

EPA's Integrated Planning Framework offers great opportunities for municipalities to
incorporate climate change and/or environmental justice concerns into a holistic long-
term plan. The stakeholder engagement, alternatives selection, and project prioritization
processes that are central to the framework allow local governments to incorporate equity,
resiliency, and climate change into a plan designed to address Clean Water Act goals.

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^¦

INTEGRATED PLANNING
FRAMEWORK, CLIMATE CHANGE,
AND ENVIRONMENTAL JUSTICE
CONSIDERATIONS
Portland, Maine:

Heavier Rains and Water Quality
Mandates

Carol Highsmith, Aerial View of Portland Maine, Retrieved from
https ://thenounp roject.com

The City of Portland, Maine has a population of
about 68,000 and is the economic capital of the
state. Portland operates a combined sewer
system and since 2014, a separate stormwater
system as well. Both these systems transport
effluent into Casco Bay, an important natural,
cultural, and economic resource for Maine.

Impacts of Climate Change:

As a coastal city, Portland is vulnerable to sea level
rise, warming ocean temperatures, and increasing
storm activity related to climate change. Greater
Portland communities have been experiencing
recurrent tidal and storm-related flooding and
erosion. Flooding events are intensifying and
becoming more common. Flooding is most
severe when tidal flooding coincides with intense
precipitation events. Portions of the city are already
observing tidal inundation during the highest of
high tides. Tidal inundation is causing stormwater
and combined sewer systems to backup and flood

streets, damaging homes and businesses and
significantly increasing the amount of discharge
into Casco Bay.1 While the City has been using a
variety of stormwater management practices, the
infrastructure of the current combine sewer system
has proved insufficient to handle recent flood events
and the problem will only worsen over time.

Summary of Recent Predictions of Climate
Change Effects in Casco Bay1

Stressor

Past
Statistic

Future
Estimate

Potential
Impacts

Temperature
Increase

Average
Annual
Temp has
warmed by
~3.0 °F since
1895

Average
Annual
Temp is
predicted to
increase by
-3.0-5.0 °F
by 2050

Increased

energy

consumption

due to air

conditioning

use;

increased
irrigation needs

Precipitation
Increase

Annual

precipitation

total

increased by
-6 inches or
13% since
1895

Annual

precipitation

total

to increase
by 4-5% or
-2-3 inches
by 2050

Increased
stormwater
volumes
leading to more
frequent
flooding of
streets and
increased CSOs
and SSOs

Sea Level
Rise

Sea level has
been rising
at a rate of
0.01-0.04"
per year for
the last
1,000 years

Recent sea
level rise
rate

at 0.07" per
year leading
to -0.5-2,0'
by 2050

Increased flood

frequency in

Back

Cove and

Portland's

downtown

Ocean

Temperature
Increase

Average
surface
water temp
increased
0.05 °F per
year since
1982

Warming
rate has
accelerated
to 0.41 "F
per year
(faster than
99% of the
world's
oceans)

Potential for
increased HABs,
nuisance algae
and invasive
species; may
place greater
emphasis on
nutrient
reductions
and may affect
tourism

[l] City of Portland Water Resources Division. (December 2020). Integrated Water Resources Management Plan.

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Post Efforts to Address Stormwoter Issues:

Portland is subject to Clean Water Act regulatory
requirements, including a consent decree for
combined sewer overflows (CSO) and a wastewater
treatment plant permit. In response to the consent
decree, Portland developed a Long-Term Control
Plan (LTCP) in 2013 to reduce the volume of CSOs
through the construction of wet weather storage
tanks to reduce overflows, installation of tide gate
valves at the end of storm drain systems, and other
gray infrastructure improvements. The overall
cost to implement the plan was approximately
$200 million over the 15-year planning period.
Concurrently, the wastewater utility worked with
regulators to improve its capacity through permit
renewal processes. A separate initiative to expand
the stormwater management system (MS4) was
also ongoing.

In 2016, Portland established a stormwater
utility fee to generate revenue for stormwater
management. This stormwater fee is designed to
distribute the costs of stormwater management
more equitably by charging customers based
on impervious surface area. Moreover, Portland
instituted a fee credit program that allows
customers to reduce or eliminate their stormwater
utility fee by implementing approved green
infrastructure projects on the property. This
stormwater fee played an important part in setting
the stage for their Integrated Plan, providing a
source of financing and an understanding of green
infrastructure to the public.

Addressing Climote Challenges Through
Stakeholder Engogement:

In 2018, Portland's Department of Public Works
(DPW) began the integrated planning process
with the aim of improving the city's water quality
while also enhancing the Portland community in
other ways. They placed particular emphasis on
the stakeholder involvement component of the

framework through a series of workshops and
public meetings. Six workshops were held with
the aim of developing informed recommendations
for city officials about management strategies to
both improve water quality and provide ancillary
benefits to the environment, the economy, and
public health. At these events, DPW discussed the
city's wastewater and stormwater priorities with
advocacy groups, local businesses, fishermen,
aquaculture growers, and academic institutions.
The workshops were designed to help the city
develop a plan that balances the needs and services
of residents and local businesses with those used
to support transient populations and the summer
tourism-based economy. The stakeholders raised
concerns such as the adverse effects of warming
temperatures in Casco Bay on the viability of
lobster, an economically critical native species. The
workshops generated recommendations for metrics
and a draft implementation strategy that took into
consideration stakeholder concerns regarding
climate change and environmental justice.

Bringing in stakeholders into the project
prioritization process "gave a literal
and figurative weight to climate change
concerns," said Nancy Gallinaro,
Portland's Director of Water Resources.

v	y

The resulting Integrated Plan improved Portland's
resiliency by providing an opportunity for
community stakeholders to bring their concerns to
the table. Climate change impacts, such as flooding
risks for waterfront businesses and increasing
pollution in Casco Bay, were a top priority. Part
of the planning process included an evaluation
of where the city's at-risk population, including
low-income, non-white, and senior citizens, lives.
DPW generated a map to contribute to its analysis,
particularly looking at instances of overlap between
environmental and demographic indicators. Effects

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on burdened communities was also a part of the
qualitative screening for scoring projects.

The city detailed a public outreach and engagement
approach as part of its integrated plan, to
better promote meaningful involvement of all
relevant stakeholders during the development
and implementation stages. Comprehensive
representation during this process was ensured
by compiling a list of community organizations,
consisting of constituents that are often under-
represented in the public planning process. Outreach
methods included distributing flyers in languages
other than English, choosing public meeting
times and locations with the greatest access, and
attending community events such as walking tours
and races to answer questions about the integrated
plan.

Stakeholder input ultimately fed into a multi-
objective decision framework that informed the
final plan document. Previous efforts to reduce CSOs
focused on improving the infrastructure in specific
areas affected by flooding. Portland is now seeking
the flexibility to develop innovative solutions to
reduce CSOs while also addressing issues raised by
residences and businesses. Using the Integrated
Planning Framework facilitated a more holistic
approach to address flooding and water quality
challenges. While Portland awaits State approval
to incorporate the Integrated Plan into its permits
and LTCP, the plan has informed the 2021 and 2022
budgets and the current capital improvement plan.

Some recommended climate resilience
projects and policies that may not
necessarily have been a part of the LTCP
without using the Integrated Planning
Framework include:

Building living shoreline demonstration
sites for estuarine restoration;

Developing a wetland protection
ordinance to improve the protection of
wetlands in the city from development
impacts; and

Developing a hydraulic model to better
understand the hydraulic conditions and
assess the effects of flood mitigation
projects.

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Hampton Roads Sanitation District
(HRSD):

Adapting to the Impacts of Sea-Level Rise

Megan Starr, Norfolk Virginia, Retrieved from https://virginiatraveltips.com/

Hampton Roads is a region in Southeastern Virginia
with a population of approximately 1.8 million people.
Across the region, stormwater runoff flows into the
Chesapeake Bay and Atlantic Ocean. The Hampton
Roads Sanitation District (HRSD) includes city and
county owned local sewer collection systems and
pumping stations as well as HRSD owned regional
sewer pipelines, pumping stations, and treatment
plants. The HRSD system is designed to only handle
sewage. Each Hampton Roads locality has a separate
system for handling stormwater runoff.

Environmental Justice and Sea Level Rise
in the Hampton Roads Region:

Hampton Roads is experiencing the highest rate
of sea - level rise along the entire Atlantic seaboard
and is one of the largest U.S. population centers at
risk, second only to New Orleans. As sea levels rise,
shorelines retreat and the magnitude and frequency
of near-shore coastal flooding increases. Sea level
rise dramatically compounds the effects of storm
surge, causing flooding resulting from extreme
weather to be more frequent and costly. Some areas
are already experiencing permanent inundation,
while others have seen more frequent flooding.

As sea levels continue to rise, some previously
unaffected areas will be flooded, resulting in
major infrastructure impacts. Low-income and
person of color communities in Hampton Roads
are particularly vulnerable to the impacts of storm
surge scenarios. Norfolk, the most populous city
in Hampton Roads, is unlike most major American
cities in that a significant percentage of its
population, /, 3%, identifies as black, and 19% of the
city currently falls within the 5-year floodplain.2

Hampton Roads is also affected by the shrinking
of the Potomac aquifer. Homes and industries in
eastern Virginia remove approximately 155 million
gallons of groundwater from the Potomac aquifer
daily, contributing to land subsidence and saltwater
intrusion. Land subsidence amplifies the region's
vulnerability to sea level rise by contributing to
steady but dramatic increases in tidal flooding as
the land sinks.

Creating Resiliency Through Prioritization:

In 2010, the EPA issued a Wet Weather Consent
Decree, requiring HRSD to implement measures to
reduce the discharge of pollutants. The vast array
of issues facing the Hampton Roads region led
HRSD to develop an integrated Plan. HRSD sought
to prioritize projects that best address the region's
main concern, the shrinking Potomac aquifer,
through cost effective solutions that reduce wet
weather overflows while maximizing environmental
benefits. The Integrated Planning Framework's
processes for prioritizing alternatives and iterative

[2] Boyer, Michael and Penn, Erica, "Tidal Turmoil: Environmental Justice and Sea Level Rise in Hampton Roads: Norfolk Case Study" (2013). Virginia Coastal Policy Center.
Retrieved from https://law.wm.edu/academics/programs/jd/electives/clinics/practicum_list/vacoastal/documents/march20i4.reports/tideturmoil2.pdf

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Innovative Components of the
Integrated Plan:

SWIFT:

Under a $225 million WIFA loan issued by the
EPA, HRSD will inject millions of gallons of
highly treated water into the Potomac aquifer
to reduce saltwater intrusion caused by sea-
level rise. This system serves 1.7 million people
and has created 1,4.12 jobs for the area. HRSD
estimates to be recharging at least 100 million
gallons per day of SWIFT Water into the Potomac
Aquifer by 2030.

Regional Wet Weather Management
Projects:

Regional Wet Weather Management Projects:
A Sanitary Sewer Overflow (SSO) storage tank
was constructed underground beneath a new
skate park. The Integrated Planning Framework
emphasizes the use of innovative solutions to
reduce overflows. Conventional construction
would involve installing the tank above
ground. Underground storage combined with
new urban development reduces the amount
of excess flow to be treated at a WWTP and
enhances environmental, social, and economic
sustainability.

decision-making made it an ideal approach.

Using the framework, HRSD prioritized Sustainable
Water Initiative for Tomorrow (SWIFT), a plan to
reduce the impact of sea-level rise by injecting
treated wastewater effluent into the aquifer,
suspending aquifer compression and promoting
aquifer rebound. SWIFT's goal is to reduce the
impact of sea-level rise by 25 percent over the
next 50 years.3 However, a key benefit to the
framework's approach is that it does not force users
to select between alternatives; instead, users can
prioritize in the sequence that makes the most sense
to the community.

Along with SWIFT, HRSD's Integrated Plan also
prioritizes a Regional Wet Weather Management
Plan (RWWMP), which features an adaptive
management approach to address the impacts of
climate change on Hampton Roads. Highlighted
in the Integrated Planning Framework, adaptive
management incorporates iterative decision-
making to manage uncertainty in addressing
environmental challenges. As Jim Pletl, the former
Director of the Water Quality Department at HRSD,
described in an interview, "Before the framework
was written in 2012, people expected to write a
plan and stick to it." The Integrated Planning
Framework allows for flexibility through iterative
decision-making to adapt to changing conditions.
An important component within HRSD's Integrated
Plan is the Adaptive Regional Plan, which directs the
utility to revisit the wet weather projects every five
years. If new data shows that different service areas
have an increased susceptibility to flooding, plans
to address pump station upgrades may change.
Revisiting the plan every five years ensures local
government level policy decisions are responsive to
changing climate conditions.

[3] Hampton Roads Sanitation District. (2017, September 28). Integrated Plan/Regional Wet Weather Management Plan. Retrieved from https://www.hrsd.com/sites/default/files/
assets/Documents/pdfs/EPA/IntegratedPlan/HRSD_IP_RWWMP_20l7_0 9_28_DIGITAL_FOR_VIEWING.pdf

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I

The Kickapoo River Watershed:

A Cost-Effective Approach to Climate
Adaptation and Mitigation

Carol M. Highsmith, Dells Mill, a gristmill in Augusta, Wisconsin Retrieved from
https ://thenounp roject.com/

The Kickapoo River Watershed is situated in the
southwestern corner of Wisconsin. The region
encompasses approximately 490,000 acres, beginning
north of Wilton in Monroe County and flowing south-
southwest through Vernon, Richland, and Crawford
counties. The watershed is very rural with just over
20,000 residents, most of whom live in small villages.

Intensive Flooding in the Kickapoo River
Watershed:

The Kickapoo region's unique topographic features
including upland plateaus, steep valley sides, and
dendritic stream systems contribute to flooding
events occurring every few years. However, severe
one-hundred-year flooding events are becoming
more frequent. The watershed is dominated by
silt loam soils that lie over bedrock. While the
moderate permeability and high-water capacity of
these soils make the land ideal for farming, they
also endanger the water quality of the region. Silt
loam soils are easily dislodged and suspended in
runoff. This combination of high nutrient pollution
from streambank erosion with flooding affects the
communities' drinking water.

Runoff also reduces future agricultural production,
as water with high phosphorus loads can result in
slow crop growth and disease propagation amongst
livestock. The Kickapoo River is a tributary of the
Wisconsin and Mississippi Rivers, so its nutrient
loading and the resulting poor water quality
contribute to the eutrophication and deterioration
of water quality in these watersheds. Agriculture,
as well as other industries that depend on clean,

reliable water such as food processing, tourism, and
outdoor recreation, are crucial to the local economy.
In terms of per capita income, the watershed is
one of Wisconsin's poorest areas. Wages, as well as
the growth rate of income, are generally lower in
the region than in the rest of the state. Similarly,
poverty rates are higher compared to many other
regions of the state. Rural areas of the region have
experienced slow population growth rates of less
than 1% per year over the last several decades.4 Gays
Mills Village, a community of 4.90 people with a
declining population, has seen six major flood stage
events since 1950, five of which occurred during
or after 2007.5 In 2009, approximately half of the
homes in Gays Mills were slated to be demolished
or elevated and the government center was moved
to higher ground.5 After a flood event in 2018, the
Village considered relocating government and
downtown properties once again.

[4.] Wisconsin Department of Natural Resources. (2013, February). Regional and Property Analysis for the development of a master plan for Department of Natural Resources'
properties along Trout and Smallmouth Bass streams in the Driftless Area.

[5]	LA Crosse Tribune. (2017, August 18). A tale of two Gays Mills: Flooding inspired part of village to move to higher ground. Retrieved from https://lacrossetribune.com/news/
Iocal/a-tale-of-two-gays-mills-flooding-inspired-part-of-village-to-move-to-higher/article_8e62f653-bf59-5f64-9fb4-74a905e5fece.html

[6]	U.S. Department of Agriculture. (2017, February 21). Apple capital of Wisconsin, Gays Mills, begins move with USDA support. Retrieved from https://www.usda.gov/media/
blog/2010/05/13/apple-capital-wisconsin-gays-mills-begins-move-usda-support

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Addressing Flooding and Water Quality
Issues:

In 2019, Readstown Township, located within the
Kickapoo River Watershed, reached out to the EPA
Region 5 office requesting information on cheaper
alternatives for compliance with the Wastewater
Treatment Plant (WWTP) nutrient permit.
Readstown explored the cost of various mechanical
upgrades to their wastewater treatment plant to
comply with nutrient limits but came to understand
that they would place a high burden on their
ratepayers. Compliance with phosphorous and other
nutrient limits commonly puts disproportional
pressure on often rural and economically distressed
communities. In addition, 'end-of-pipe' treatment
upgrades alone may not achieve the required
effluent quality improvement outcome and can
impose an economic burden on individual rural
communities that cannot afford it. Originally, the
township requested technical assistance to create
a constructed wetland for nutrient treatment and
polishing effluent. However, because the WWTP
was determined by EPA Region 5 scientists to be in
a floodplain, an artificial wetland WWTP would not
be a viable option. In response, with similar issues
facing the other nine WWTPs, EPA staff worked with
communities in the region to develop a watershed-
based integrated plan.

The plan consists of two stages with the goals of
reducing nonpoint source pollution, mitigating
the impacts of flooding, establishing regenerative
agriculture, recharging the aquifer/groundwater,
and improving water quality. Stage 1 addresses
the alternative approach for NPDES wastewater
discharge compliance through water quality
trading. Water quality trading provides flexibility to
meet nutrient requirements offsite by purchasing
credits from non-point sources within the
watershed. Communities can pay for agricultural
best management practices, such as converting
corn crops into prairie grass and thereby reducing
the nutrient loss in soil erosion, instead of more

costly wastewater treatment plan upgrades. Stage 2
expands the project beyond wastewater treatment
plants and compliance issues to the watershed level,
considering broader land use change and flooding
mitigation potential, nutrient and sediment
loading potential trade-offs, and the impacts to
downstream rivers such as the Wisconsin and
Mississippi.

The Kickapoo River Watershed Integrated
Management Plan consists of the following
goals7:

Water quality trading between the
village and nearby agricultural
landowners

Green or natural infrastructure such
as land use changes or streambank
restoration to reduce non-point source
runoff

Encourage regenerative agriculture and
land use change to mitigate flood risks

Increase soil infiltration and storage
for baseflow, carbon sequestration and
aquifer recharge.

Agricultural best management practices, such
as no-till or conservation tilling for minimal soil
disturbance, mulching, composting, rotating
livestock, and using cover crops can increase the
soil's ability to sequester carbon. The WWTF and
community worked together to actively seek a wide
variety of cost-effective best management practice
that improved water quality faster. The Integrated
Planning Framework also provides more ancillary
environmental benefits such as carbon sinks, flood
retention, and riparian and habitat improvement,
which further improves water quality.

[7] U.S. Environmental Protection Agency. (2021, September 14.). Kickapoo River Watershed Integrated Management Study.

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Richmond, Virginia:

Addressing Inequities Through
Stakeholder Involvement

Sean Pavone, Richmond Virginia, Retrieved from https://www.dreamstime.com/

Founded in 1737, Richmond is the capital of the
Com monwealth of Virginia, As of 2019, Richmond
hosts a population of approximately 230,000. Between
2010 and 2017, Richmond's diverse population grew
by 11 percent, outpacing surrounding counties' growth
rates during the same period.

Inequitable Impacts of Climate Change:

Located at the fall line of the James River, Richmond
is experiencing increasingly severe flooding
impacts intensified by climate change. Two of the
wettest years on record have occurred in the last
4. years (2018 and 2020). Extreme rainfall events
that overwhelm drainage systems and lead to
severe street flooding, once uncommon, have been
occurring more than twice a year in Richmond
recently. The most recent IPCC report found that
it is likely that heavy precipitation events will
intensify and become more frequent in most
regions with additional global warming.8 Changing
rainfall patterns are not just limited to Virginia's
coastline—more intense and more frequent storms
will happen across the state. In a localized study
that examined data from locations across Virginia
between 194.7 and 2016, researchers found that both

average annual precipitation and heavy rainfall
frequency increased statewide.9 Richmond's
drainage system is inadequately prepared to handle
these recurring superstorms and street flooding
is becoming more common. These events occur
most frequently in the oldest parts of the city and
in disadvantaged communities, increasing the
vulnerability of individuals living below the poverty
level, some 20 percent of Richmond residents.10
In some neighborhoods of South Richmond, the
struggles of managing increased and more intense
rainfall are already apparent in frequent flooding
that leaves streets and yards waterlogged for days.

With a high concentration of people of color,
Richmond's disadvantaged neighborhoods reflect
the legacy of racist policies. Contemporary maps
for flood risk strongly resemble New Deal- era maps
used by the federal government to assess risk for
mortgage lending in a practice known as redlining.
Data collected by the Office of Sustainability show
that areas of the city with higher proportions of
people of color also face higher rates of poverty,
chronic illness, crime, and other factors that
increase overall social vulnerability. These
neighborhoods also lack critical infrastructure,
tree canopy and green space, modern stormwater
infrastructure, and energy efficient buildings,
increasing their vulnerability to climate change.

[8]	Eyring, V. (202l).Human Influence on the Climate System. In Climate Change 2021: The Physical Science Basis. Contribution of Working Group I to the Sixth Assessment Report
of the Intergovernmental Panel on Climate Change

[9]	Allen, M.J., & Allen, T.R. (2019). Precipitation trends across the commonwealth Virginia (1947-2016)" Virginia Journal of Science. Volume 70, Issue 1 & 2.

[10]	U.S. Census Bureau (2020). Selected economic characteristics, 2016-2020 American Community Survey 5-year estimates. Retrieved from https://www.census.gov/quickfacts/
richmondcityvirginia

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Prioritizing Vulnerable Populations
Through Integrated Planning:

Richmond's Department of Public Utilities (DPU)
utilized the University of Virginia's Institute for
Equitable Engagement and Negotiation (IEEN) to
facilitate stakeholder engagement. The academic
institute helped to improve coordination between
stakeholder groups and DPU and created the space
for stakeholders to develop potential approaches
for prioritizing projects. DPU began developing
the RVA Clean Water Plan in 201/(, using the
Integrated Planning Framework not as a roadmap,
but as a checklist. Stakeholder involvement was
paramount and incorporated throughout the entire
process. Stakeholders included wildlife and animal
advocates, boaters, residential, commercial, and
business interest groups, and groups representing
environmental justice issues. DPU tailored the
engagement process to the technical expertise of
the stakeholders, breaking them into two groups.
For future environmental justice stakeholder
roundtables, DPU will pay participants to share their
experiences and thoughts on project prioritization.
Paying community members to travel to these
meetings will ensure residents who cannot afford to
take off work will be able to have their voices heard.

DPU carried out a public outreach effort, including
several open houses held in local parks to lay a
foundation of understanding before engaging in
the more technical conversation around watershed
integration. Through both online and offline
communication strategies, the city's Public
Outreach Plan, strived to reach 20% of the city's
population in the MS4. area by 2018.11 Progress
towards this goal was tracked by Facebook and
Twitter traffic, email campaign engagement, and
flier distributions and the goal was ultimately
achieved.

An example of integrated planning in action is the
expansion of green infrastructure in the Shockoe
Bottom neighborhood. Shockoe Bottom was an
epicenter of the domestic slave trade in the mid
1800's, second only to New Orleans,12 This low-Tying
area near downtown Richmond on the banks of the
James River faces an extreme risk of flooding due
to its built infrastructure. Richmond's combined
sewer system infrastructure was designed to direct

overflow from the West, North, and Eastside areas
into Shockoe Bottom, draining water into this valley
populated with homes and businesses. Economic
investment and infrastructure improvement in
the area have been inconsistent. While a floodwall
protects the neighborhood from floods from the
river itself, storage and conveyance are needed to
solve the CSO problems. Before the introduction
of the Integrated Plan, green infrastructure would
typically be built only in the MS4 as developers
cannot get credit in the combined area. Due to the
involvement of stakeholders during the strategy
prioritization process, there is now a considerable
effort to take flow out of the combined area with
green infrastructure.

Morgan Riley ,View north on 17th Street at the Farmers' Market, in Shockoe Bottom,
Richmond, Virginia.

The Integrated Plan was a necessary precursor
to Richmond's Green Infrastructure Master Plan
within their combined sewer sheds because it
demonstrated how green infrastructure can be
leveraged to meet Clean Water Act requirements.
With the Integrated Plan, the city is given the
freedom to say that pollution reduction anywhere is
a good idea, using green infrastructure development
as a primary strategy to improve the quality of
ground and surface water. DPU is in the planning
process of constructing green streets and adding
parks in another historically African American
neighborhood, Fulton Bottom, east of Shockoe. The
city is also working with community stakeholders,
the Partners Alliance for the Chesapeake Bay,
and the National Fish and Wildlife Foundation
to finalize a project selection process using its
Green Infrastructure Master Plan, which includes
neighborhood equity as a criterion.

[11]	RVA H20. (2017, September). 2017 RVA Clean Water Plan. Retrieved from https://j3n7eAb9.stackpathcdn.com/wp-content/uploads/2020/02/Final_RVA_Clean_Water_Plan.pdf

[12]	Ebony Walding Consulting. (2019, August) Shockoe Bottom Equitable Economic Redevelopment Resource Guide. Retrieved from https://preservationvirginia.org/wp-content/
uploads/2019/ll/Shockoe-Bottom-Equitable-Economic-Development-Resource-Guide.pdf

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The Environmental Finance Center at the University of North Carolina at Chapel Hill | 13

Spokane, Washington:

Delivering a Cleaner River for the
Community

Benedek, photograph of the downtown Spokane, Retrieved fromhttps://www.
istockphoto.com/

The City of Spokane, Washington is the second largest
city in the state, home to about 220,000 people. The
Spokane River runs through the downtown area and
flows into Lake Spokane. The city has more than
300 miles of separate storm sewers that discharge
stormwater and more than 400 miles of combined
stormwater and wastewater sewers.

Unequal Burden of Climate Change and
Flooding on Vulnerable Residents:

The Spokane River receives untreated overflows
and stormwater runoff during heavy rainstorms
and rapid snowmelt. Additionally, discharge of
treated effluent from the city's WWTP is directed
to the river. For the Spokane Tribe of Indians, the
river flows through the heart of their ancestral
homeland.13 Members of the Tribe have historically
relied on the river for nourishment, medicinal, and
spiritual purposes. Today, the Tribe works to protect
and improve the river's water quality and fisheries.
Toxins that enter the river bioaccumulate in fish,
presenting a public health issue when consumed by
people. This problem is more concentrated in some

of the low-income and minority populations in
Spokane that rely on the river for food.

While Spokane's flooding issues are not overly
significant, individual rainfall event intensity is
likely to rise, with a 13 percent increase in number
of days with over an inch of precipitation expected
by 2050,1'' Higher levels of precipitation influenced
by climate change are expected to have a greater
impact on the lower elevation neighborhoods
in Spokane, which tend to house lower-income
communities.

These communities face the highest risk of flooding
issues while also hosting the city's CSO systems.
Some of these low-elevation neighborhoods also
have below average tree canopy cover. With climate
projections predicting future temperature increases
of two to five degrees Fahrenheit by 2050 in the
Spokane region , these low-income communities
will also face higher risks of exposure to heat-
related illnesses. Protecting and expanding tree
cover is an important strategy for both minimizing
the effects of heat and protecting watershed
health. The city's Integrated Plan includes coupling
investments in green infrastructure with other
public infrastructure projects, which will result in
long-term reductions in CSO frequency and volume,
stormwater charges, and uncertainties associated
with climate change.

[13] Northwest Power and Conservation Council, (n.d.). Spokane River. Retrieved from https://www.nwcouncil.org/reports/columbia-river-history/spokaneriver

[14.] U.S. Census Bureau (2020). Selected economic characteristics, 2016-2020 American Community Survey 5-year estimates. Retrieved from https://www.census.gov/quickfacts/
spokanecitywashington.

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The Environmental Finance Center at the University of North Carolina at Chapel Hill | 14

Integrated Planning Prioritizes
Environmental Justice and Resiliency:

Before considering an integrated strategy, the city
planned to spend $300 million as part of its Long-
Term Control Plan (LTCP) to address overflows to
the river from its combined sewers. However, that
investment would not have addressed other sources
of pollution to the river, including stormwater.
Reductions in pollutants like PCBs and heavy metals
would have been minimal. Spokane's median
household income is 70 percent of the statewide
median household income and about 78 percent
of the U.S. median household income.15 With this
financial consideration, the city decided to develop
a plan that would not significantly raise wastewater
rates for its customers while still improving the
health of the Spokane River. In 2014., Spokane
completed its Integrated Clean Water Plan, with a
primary focus on improving the water quality of
the Spokane River. All clean water planning efforts
are integrated into the plan, including those for
CSOs, stormwater, and the addition of tertiary
treatment at its Wastewater Treatment Plant. Most
of the projects in the Plan—including the CSO work
and improving its wastewater treatment—have
been completed. The city is currently undertaking
a project to manage stormwater from its largest
stormwater basin, the Cochran Basin, which
contributes about half the annual stormwater to the
river.

Using an Integrated Planning Framework instead of
an LTCP enabled the city to incorporate broader and
more inclusive community stakeholder engagement
in the planning process. The City's Department of
Public Works (DPW) reached out to special interest
stakeholders, including environmental advocates,
users of the Spokane River, owners of property
along the river's shores, and neighborhoods where
construction projects would be implemented.
The city also kept staff from regulatory agencies
and members of the Spokane Tribe engaged and
informed. Initial communications with the public

focused on the basics—what is a combined sewer,
how is stormwater managed throughout the city,
what do flows from combined and stormwater
sewers bring to the Spokane River, and what is
"green" infrastructure. DPW also explained that it
was striving to make the changes more affordable
and provide greater value to citizens for the dollars
spent.

The Plan clearly outlines the inclusion of
environmental justice principles with respect to
the implementation of stormwater management
and CSO reduction projects. Both the selection
of projects and siting of facilities are required
to provide maximal benefits to the surrounding
community. Due to the nature of the locations
of CSOs and stormwater outfalls, many of the
recommended projects are sited near the shore of
the Spokane River, potentially impacting locations
of cultural significance to the Spokane Tribe. The
Plan explicitly requires the city to coordinate with
the Tribe on the siting of projects throughout
the planning process. In addition, the city's
comprehensive approach to addressing toxins in
the Spokane River is of particular importance to the
Tribe.

The city recognized the following opportunities
for environmental justice and climate resilience in
siting the following projects:

The West Broadway Spokane Urban Runoff
Greenway Ecosystem (SURGE) is located in the
West Central Neighborhood, which has a low-
income population. The SURGE project benefits
this neighborhood by providing education, low
impact development stormwater facilities, and
enhancements of trees and plants in storm
gardens.

Construction of CSO storage tanks are paired
with park and trail development, providing new
trees, and river views and other streetscape
improvements. The reduction of untreated
sewage discharge provides a cleaner river for
everyone.

[15] U.S. Census Bureau (2020). Selected economic characteristics, 2016-2020 American Community Survey 5-year estimates. Retrieved from https://www.census.gov/quickfacts/
spokanecitywashington.

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The Environmental Finance Center at the University of North Carolina at Chapel Hill | 15

The following are several statistics on the
City's stakeholder involvement process:

More than 4.0 presentations to
interested stakeholders and citizen
groups, reaching nearly 14.00 people

More than 30 meetings with regulators,
Spokane Tribe representatives, and
elected officials

City elected officials were updated
through twice-monthly public works
meetings

The city has adopted an adaptive management
process for CSO reduction, stormwater
reduction, and sizing the Membrane Filtration
facility. Adaptive management, which consists
of monitoring the plan and adaptive future
actions based on observable results, allows
the city to account for sources of uncertainty,
including climate change.

Spokane also included an alternative evaluation
process, a component of the Integrated Planning
Framework that considers environmental justice
and social equity and uses a multi-objective decision
analysis (MODA) process. The MODA process is a
useful tool to capture the environmental and social
justice impacts of projects because projects that
provide higher benefits in metrics such as integrated
benefits, environmental outcomes, and lower cost
will score higher.

Out of the city's integrated planning efforts for
clean water improvements grew its new "Integrated
Streets" concept, which addressed both utility
and street needs. The Integrated Streets concept
involves replacing all the above and below ground
infrastructure as needed, prioritizing streets using
a matrix that looks at pavement condition, traffic
volumes, the need for utility upgrades, connection
to the pedestrian generators, and economic
development opportunities. Completing all work
at once minimizes the disruption caused to the
neighborhood. A citizen committee examines
how projects are scored according to proximity to
schools, economic development opportunities, and
overall, how investments can produce the greatest
impact. The committee then recommends projects
to elected officials for investment. To complete the
street projects, the city passed a $5M per year street
levy and committed $5M a year match of utility
funds. The street levy funds the street projects
and the matching utility funds pay for removing
stormwater from the system and other integrated
benefits as part of the street project.

The Integrated Planning Framework allowed
Spokane to consider their multiple challenges—
CSOs, water treatment, and stormwater
management—in a holistic manner. The original
plan to spend $300 million just to address CSOs was
far too expensive and did not comprehensively cover
all the water related issues that the community
cared about. By using an integrated planning
process, Spokane has created an approach that is
both affordable and feasible while satisfying its
stakeholders' main concerns.

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The Environmental Finance Center at the University of North Carolina at Chapel Hill | 16

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School of Government
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University of North Carolina at Chapel Hill
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