Is an Integrated Planning Approach Right for Your Agency?

Understanding the Integrated Planning and Permitting Approach

Today’s municipal utilities are facing an evolving regulatory landscape to address past, present and future drivers. These regulatory drivers range from implementing previous wet weather agreements and upcoming nutrient reduction goals to strategies that deal with emerging contaminants, such as PFAS. Utilities are challenged to meet overlapping obligations such as aging infrastructure, public health protection, flood control and climate change impacts.

The 2019 Water Infrastructure Improvement Act directed the U.S. Environmental Protection Agency to develop a report to Congress on the implementation of EPA’s 2012 Integrated Municipal Stormwater and Wastewater Planning Framework. The Integrated Planning Framework provides municipal utilities the unprecedented opportunity to 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.

Using the Integrated Planning Framework helps municipalities engage with the EPA and local regulators to develop sustainable water quality compliance programs that address existing obligations and help them plan for and adapt to future challenges. The framework also allows municipal utilities to make smart investments for managing their water resources. 

Questions to Get the Process Started

Flexibility & Prioritization

• Do my current planning efforts provide the flexibility I need to address ever-evolving Clean Water Act obligations?
• Do I have a clear picture of my future regulatory drivers related to both the Clean Water and Safe Drinking Water Acts?
• Do I have opportunities to balance the costs and benefits of combining all my utility plans — drinking water, wastewater, stormwater, and even power — into one holistic plan for my community and customers?

Capital Improvement Prioritization

• Can I achieve greater water quality impacts with potential wastewater or stormwater system improvements, compared to previous wet weather commitments, to address combined or separate sanitary sewer overflows?
• Are there alternative solutions that can achieve multiple environmental and community benefits?

Regulatory Compliance

• Does my existing enforcement agreement align with current or upcoming competing needs?
• Do new or upcoming wastewater or MS4 NPDES permits require large investments or potential unforeseen regulatory risk?

Community & Stakeholder Outreach

• Do I need to build community support for much-needed revenue increases?
• Are my community’s priorities reflected in currently scheduled regulatory obligations?
• Does my community understand the value of the service that we provide to address wastewater and stormwater needs?

Financial Affordability

• Do we have current or future affordability challenges, particularly for low-income customers?
• Do I have a solid understanding of potential rate impacts due to current and potential regulatory drivers and other competing demands, like aging infrastructure?
• Do I need to consider customer financial impacts across all of my programs?