Integrated Planning Offers A Better Way to Comply With the Clean Water Act

Last January, President Trump signed bipartisan legislation to benefit cities, towns, and villages with municipal storm sewer systems (MS4s) and publicly owned treatment works (POTWs). The Water Infrastructure Improvement Act codifies the U.S. Environmental Protection Agency’s (EPA) integrated planning framework in the Clean Water Act (CWA). The legislation is short – just 6 pages – but very powerful.

Local governments can now prioritize their stormwater and wastewater projects and make the case for an affordable capital improvement program, including one that relies on green infrastructure or other innovative projects to reclaim, recycle, or reuse water. Integrated planning can provide much needed regulatory relief for cities, towns and villages and result in greater environmental and public health benefits with ratepayer investments.

What is Integrated Planning?

Integrated planning is a voluntary opportunity for municipalities to balance multiple CWA requirements and defer low or marginal benefit projects. Without integrated planning, permit writers may need to require that the city commits to long-term capital projects, regardless of whether there will be noticeable water quality improvements in local streams and rivers. Integrated planning need not be complex – EPA only requires that a plan include six elements:

  1. water quality, human health, and regulatory issues;
  2. summary of the existing wastewater and stormwater systems;
  3. stakeholder process;
  4. alternatives selection process, including proposed implementation schedules;
  5. project prioritization process; and
  6. plan modification process.

Is Integrated Planning different than comprehensive planning?

Yes. Integrated planning is distinct from comprehensive planning, but it offers great opportunities for local governments that want to incorporate their wastewater, stormwater, and drinking water master planning into a comprehensive plan. These projects are often significant components of a city’s overall budget, so making the projects serve multiple purposes makes sense. The stakeholder, alternatives selection, and project prioritization processes inherent to integrated planning also allow local governments to incorporate sustainability, resiliency, and climate change planning into both plans.

Are Local Governments Required to do an Integrated Plan?

No. The law requires EPA or a state to inform a local government of its opportunity to pursue integrated planning under a National Pollutant Discharge Elimination System (NPDES) discharge permit or a CWA enforcement order. Local governments do not, however, have to do an integrated plan. It would be good practice to consider whether integrated planning is right for your community several years in advance of a NPDES permit renewal or if your city faces potential CWA enforcement actions. Integrated planning should also be considered if a local government is undertaking a comprehensive plan. Cities, towns, and villages should also consider integrated planning as a potential “best practice” to obtain stakeholder support or to stretch ratepayer dollars for the most beneficial projects.

Where Can I Learn More About Integrated Planning?

If you don’t know much about integrated planning, you are not alone. Research conducted for The Water Research Foundation (WRF) indicates that even though EPA adopted the integrated planning policy in 2012, obstacles still remain for its widespread implementation. These obstacles include lack of knowledge, institutional memory, and other factors.

Local governments interested in considering integrated planning can consult WRF’s Users’ Guide (download instructions below) to see if integrated planning is right for their community.  The Users’ Guide includes a simple excel-based tool that will help local governments decide if integrated planning is right for their community. It also includes several case studies, including communities that considered integrated planning and decided not to pursue it (Peoria, Illinois) to those that fully embraced integrated planning (Oxnard, California; Lima, Ohio; Springfield, Massachusetts; Santa Maria, California). The Users’ Guide also includes resource pages on each of the six EPA elements and recommendations for going through the integrated planning process.

Ohio was the first state to host an integrated planning workshop to inform municipalities about integrated planning, including several case studies (see this video and this presentation). Additionally, EPA recently conducted a webinar entitled “The Straight Scoop on Integrated Planning,” which contains two community examples.

Four Local Examples: How Has Integrated Planning Been Used?

The City of Oxnard, California pursued integrated planning to develop a cohesive plan for all of its water resource departments. Oxnard had outdated, individual plans for water, wastewater, potable water, and recycled water. The city expects lower operation cost and efficiencies, better coordination of capital projects, and better internal and external planning. The city also expects to be able to spread costs to later years when financially necessary and to improve communication with council when budgeting.

The City of Lima, Ohio developed an integrated plan to prioritize treatment plant, combined sewer overflow, and sanitary sewer overflow improvements as part of a federal consent decree. Integrated planning was an important tool to prevent the diversion of funds on low priority projects and to be able to invest in existing infrastructure. Lima hopes to obtain much needed flexibility in required rate increases with respect to financial impacts on low income families.

Integrated planning allowed the City of Springfield, Massachusetts to determine the true condition of their wastewater collection and treatment systems. Springfield also undertook a maintenance program while developing the plan that allowed them to reduce their sanitary sewer overflows and make their operations and maintenance more efficient.

Hampton Roads Sanitation District in Virginia Beach used integrated planning to protect the environment, enhance sustainability of long-term groundwater supplies, and to address environmental pressures such as restoration of the Chesapeake Bay, sea level rise, and saltwater intrusion. Their program, Sustainable Water Initiative for Tomorrow (SWIFT), treats wastewater to drinking water standards to replenish the Potomac Aquifer avoiding discharge to three different rivers.

How Do I Get Started?

Integrated planning does not need to be a complicated, long, expensive process. It does, however, require leadership and support from the community and the regulatory agencies. The first step is to consider whether integrated planning might be right for your community and to define your preliminary objectives. The second step would be to inform your permit writer (or enforcement staff from the state agency or EPA) that you want to develop an integrated plan. The third step would be to assemble the resources needed to complete the plan, including internal resources and consulting and legal resources.

Integrated planning provides the opportunity for local governments to control their CWA regulatory future and maximize environmental and public health benefits in an affordable manner. EPA intentionally made the framework simple and flexible so that communities of all sizes could benefit. It is a new approach to utility planning which shows great promise.

Want to learn more about integrated planning? NLC’s upcoming Congressional City Conference will feature a workshop titled, “One Water: How Integrated Planning Can Address Affordability and Promote Community Resilience” on Tuesday, March 10.

For free download of the WRF Users’ Guide, please follow the following steps:

  1. Click here;
  2. Click “Log in” in the top right corner of the page;
  3. Click “CREATE AN ACCOUNT” and enter contact info including email address;
  4. After creating the account, the user can log into the web site and download the report for free.


About the Author: Adrienne Nemura is a water resources engineer and a Principal of Geosyntec Consultants, based in the Cleveland/Akron region. For 35 years, she has helped municipalities identify cost-effective and sustainable solutions to meet their water quality goals and comply with the Clean Water Act. Adrienne was the principal investigator for the Users’ Guide on Integrated Planning for The Water Research Foundation. Contact Adrienne at