3
S
ince the U.S. Environmental Protection Agency (EPA) issued
its Integrated Planning Framework in June 2012, NACWA’s
focus has been on implementation and ensuring that clean
water utilities have the information they need to begin tap-
ping into the flexibility EPA appears willing to provide through inte-
grated planning. The success of the Integrated Planning Framework
hinges on whether communities take advantage of it to put EPA’s
offer of greater flexibility and prioritized investment to the test.
NACWA is maintaining its clear focus on a number of fronts to en-
sure this happens.
Implementation Workshops Garner Considerable Interest
As a central component of its ongoing advocacy, NACWA has com-
mitted to hosting, together with the Association of Clean Water
Administrators (ACWA) and the Water Environment Federation
(WEF), a series of workshops to help facilitate implementation.
While the Framework is already being used successfully in the en-
forcement context, some of the most challenging aspects of inte-
grated planning – dealing with pre-1977 water quality standards
and handling sanitary sewer overflows, for example – have yet to be
addressed in the permitting context. Enforcement negotiations have
always provided EPA with more flexibility to be creative with sched-
uling and sequencing, but the true value of integrated planning is
the control it gives local governments to plan their own clean water
investments before they face an enforcement action.
Based on the format of a workshop held in Region 3 in October
2012, NACWA, ACWA and WEF kicked off a busy spring season with
a workshop in Region 7 on March 12 in Olathe, Kansas. Hosted
by NACWA member Johnson County Wastewater, more than 70
representatives from utilities, state regulatory agencies, EPA, and
the consulting engineer community participated in the work-
shop. Additional workshops are scheduled for April 3 in Portland,
Oregon (Region 10) and May 1 in Indianapolis, Indiana (Region 5).
Workshops for Regions 1 and 8 are also in the early planning stages.
Link between Integrated Planning and Financial Capability
Underscored in EPA Memo
After EPA released its June 2012 Integrated Planning Framework, it
NACWA Shines Spotlight on Integrated Planning,
Financial Capability
2
W
ith the 113th Congress up and running, NACWA has
resumed efforts on Capitol Hill to address afford-
ability concerns communities around the country
are facing as they attempt to upgrade aging wastewa-
ter infrastructure and meet increasingly stringent EPA regulations.
The Association’s focus is two-fold – secure seed money to help early
adopters of integrated planning succeed, and seek authorizing lan-
guage to codify integrated planning and support more cost-effective
methods for treating wet weather flows.
In line with NACWA’s
Money Matters...Smarter Investment to Advance
Clean Water™
campaign, the Association is hoping to secure fund-
ing in the Fiscal Year 2014 U.S. Environmental Protection Agency
(EPA) appropriations bill for integrated planning pilot projects,
which would provide support to communities that want to pursue
integrated planning locally. NACWA’s proposal includes $5 million
in grants to clean water utilities or stormwater agencies to develop
and seek approval for integrated plans. Three to five communities
in each of EPA’s 10 regions would be selected, with the funds award-
ed on a fifty percent cost-share basis with the federal government.
NACWA is hopeful that this pilot program will spur greater adop-
tion of integrated planning and provide communities who are inter-
ested in the approach with useful examples of successful plans and
model programs. Spearheading the effort in the Senate is Senator
Sherrod Brown (D-OH).
Introduction of Key Legislation Anticipated this Spring
The Association is also working to advance two pieces of legislation
central to its affordability work:
The Clean Water Affordability Act
(CWAA), which was introduced last Congress by Senator Brown, and
The Wet Weather Community Sustainability Act
.
The CWAA would do four things: 1) reauthorize the Wet Weather
Grants Program to provide funding to wastewater treatment plants
to deal with sewer overflow issues; 2) codify integrated planning and
extend EPA permit terms up to 25 years for communities with an
approved plan in place; 3) encourage use of green infrastructure for
managing wet weather; and, 4) require EPA to revise guidance on
determining a community’s financial capability to meet CWA obli-
gations. Representative Bob Latta (R-OH) is working on similar leg-
islation by the same name in the House of Representatives. NACWA
hopes to see both of these bills introduced this spring and will be
working to mobilize broad support.
Affordability is a NACWA Top Priority at
Start of 113th Congress
The Region 7 Integrated Planning Workshop, presented by NACWA in
collaboration with ACWA and WEF drew over 70 people representing utilites,
states, EPA and the consulting community. Future Workshops are planned in
Region 10 and 5.
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