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As was made clear during NACWA’s Strategic Leadership Retreat in Charleston, S.C., earlier this month, the U.S. Environmental Protection Agency’s (EPA) initiative on integrated planning and regulatory prioritization pursuant to our Money Matters. . . Smarter Investment to Advance Clean Water™ campaign is the top advocacy priority for the membership at this time.  This Advocacy Alert outlines the Association’s suite of advocacy efforts related to EPA’s integrated planning initiative and provides an update on NACWA’s broader Money Matters-related efforts.

NACWA Leads Effort to Influence EPA Integrated Planning Initiative

NACWA has taken the lead on this issue for more than a year with numerous high level meetings with EPA’s Office of Enforcement and Compliance Assurance (OECA), Office of Water, and other key political and administrative offices at EPA.  NACWA public agency members also met last month with Nancy Stoner, Acting Assistant Administrator for the Office of Water, and Mark Pollins, Director of OECA’s Water Enforcement Division, in Milwaukee, to discuss the integrated planning effort and to begin to provide policy and technical input into this effort.  These meetings culminated in an October 28 memorandum from Cynthia Giles, Assistant Administrator for OECA and Nancy Stoner to the EPA Regions announcing the intention to develop a framework for integrated Clean Water Act (CWA) planning and permitting.

In order to ensure our members are driving this process, EPA will be meeting with NACWA public agency leaders and other representatives of key stakeholder groups in Washington, DC, on December 13.  Nancy Stoner and Cynthia Giles will both be attending the meeting, along with other key EPA policy and enforcement office staff.  Meeting participants will provide EPA with technical input into the elements that need to be included in an integrated planning framework going forward.  NACWA plans to help organize similar regional meetings with our members and EPA across the country starting in early 2012 — in line with a series of listening sessions EPA plans to hold on this initiative — to make sure that this effort fully accounts for the municipal perspective.

NACWA’s Legal Affairs Committee has also been actively looking at this issue and plans to establish a small working group of member legal experts to further NACWA’s efforts with EPA going forward.  Considerations associated with the treatment of existing consent decrees, potential reopener provisions, as well as complex permitting and compliance schedule issues will require significant attention as EPA develops its framework, making this working group’s role extremely significant and timely.  The NACWA Legal Affairs Committee also has an array of key resources available to help this effort, including an online consent decree library and a wealth of information on consent decree implementation.  The issue of how to reopen existing decrees to obtain additional flexibility and project prioritization was also directly addressed at NACWA’s 2011 Developments in Clean Water Law Seminar two weeks ago.

Money Matters Task Force Continues Work on Related Legislation, Overall Strategy, and Messaging

In addition to these meetings, NACWA’s Money Matters Task Force, headed by George Hawkins, the General Manager of DC Water, continues to take the lead in developing and implementing the Association’s legislative and regulatory strategy regarding this effort. NACWA is poised to introduce legislation that would create a CWA integrated permitting approach that would allow clean water agencies to prioritize the ever-expanding suite of CWA regulations cost-effectively and with maximum water quality improvement guiding this process.  The Task Force will also continue its role in helping to craft a clear message related to regulatory prioritization and all documents to date on this effort can be found on the Association’s Money Matters™ webpage.  If you are interested in joining the Task Force, please contact Thea Graybill at This e-mail address is being protected from spambots. You need JavaScript enabled to view it .  A complete list of Task Force members is available online .

Speaking with One Voice Is Critical to Shape the Integrated Planning Initiative

All of these activities and efforts on this integrated planning/regulatory prioritization initiative are part and parcel of your existing NACWA membership dues and come at no additional cost to your agencies.  NACWA helped shape this debate through initial public agency member contributions to the Money Matters™ campaign last fiscal year but this effort is now a priority within NACWA’s general fund budget.   As you know, the purpose of the integrated planning initiative is to stretch ratepayer dollars and maximize municipal revenue — NACWA believes that the suite of advocacy initiatives the Association is providing fully accounts for the needs of its public agency members.   The issue of integrated planning is national in scope, technical in nature, and policy-driven, which is precisely the reason why EPA has turned to NACWA for a leadership role.

NACWA will continue to work closely with the U.S. Conference of Mayors on this issue; undoubtedly their voice brings this effort added legitimacy and political clout. NACWA will also partner and share its recommendations with key stakeholder groups, including the Mayors, the American Public Works Association, the Water Environment Federation, and the Association of Clean Water Administrators, among others, and seek their thoughts and input as this effort progresses.  The integrated planning/permitting initiative, however, is simply too important to risk diluting our clear and consistent message and the clean water community must speak with one voice to maximize a successful outcome.

Please feel free to call or email Adam Krantz at This e-mail address is being protected from spambots. You need JavaScript enabled to view it or 202-833-4651 if you have any concerns with regard to this Advocacy Alert or NACWA’s integrated planning/permitting initiative more broadly.