Integrated Planning Opens The Doors For Long-Term Success

Missouri cities are facing unprecedented water, wastewater and stormwater challenges that will require significant infrastructure investments. Planning investments to address these challenges is complicated by known and unknown drivers such as evolving regulatory compliance needs, increased construction and materials costs, understaffing, supply-chain issues and unanticipated service needs. Solving these challenges requires a novel approach to thinking about water. Using the integrated planning approach provides an exciting opportunity to develop a strategic and adaptable long-term plan that unlocks a future of affordable and equitable water access.

In 2011, the U.S. Environmental Protection Agency (EPA) released the Integrated Municipal Stormwater and Wastewater Planning Approach Framework (Framework) to give municipalities flexibility to cost-effectively address wastewater and stormwater issues and make environmental improvements aligned with community priorities. This Framework was promulgated into the Clean Water Act (CWA) through the Water Infrastructure Improvement Act of 2018. The final bill received overwhelming bipartisan support because it enables communities to take control of infrastructure spending and develop prioritized and affordable capital plans while maintaining compliance with the CWA.

Adopting an integrated approach to CWA obligations is a voluntary and locally driven process, requiring a collaborative effort between the permitted entity, the Missouri Department of Natural Resources (DNR), the EPA and local enforcement officials. DNR has been a strong supporter of integrated planning. As a result, several Missouri municipalities have successfully used this approach to reshape their capital programs, negotiate affordable and achievable compliance schedules, and build community support for rate increases needed to support new investments. In a recent letter supporting an Integrated Plan, DNR states, “The Department’s Water Protection Program (WPP) has reviewed the city’s Integrated Management Plan (IMP) and agrees to use it when making future wastewater and stormwater regulatory decisions affecting the city. As decisions related to regulatory schedules will be based on the timelines set in the IMP, the WPP may reference the IMP as justification for regulatory decisions relating to the city’s wastewater and stormwater permits, and enforcement schedules.” This letter provides the City with future opportunities to adapt the plan as necessary to maintain permit compliance while prioritizing investments based on changing community needs.

In addition to these important water and wastewater utility benefits realized through integrated planning, cities can also use the process to provide important community enhancements. Integrating all needed water infrastructure investments into one long-term schedule allows your community to move away from the siloed approach of traditional infrastructure planning and move towards a tailored, prioritized and adaptable long-range investment strategy that delivers high-value projects.

Developing An Integrated Plan

Developing an integrated plan may seem daunting at first, but EPA’s Framework provides a logical, stepwise process that outlines the basic structure needed to build an iterative and adaptive plan that engages your community to define affordable infrastructure solutions. It is important to remember that integrated planning is a CWA flexibility that is available to cities and utilities of all sizes. In fact, at least two small (<15,000 population) Missouri

In a recent letter supporting an Integrated Plan, the Missouri Department of Natural Resources states, “The Department’s Water Protection Program (WPP) has reviewed the city’s Integrated Management Plan (IMP) and agrees to use it when making future wastewater and stormwater regulatory decisions affecting the city. As decisions related to regulatory schedules will be based on the timelines set in the IMP, the WPP may reference the IMP as justification for regulatory decisions relating to the city’s wastewater and stormwater permits, and enforcement schedules.” communities have successfully applied the Framework to establish alternative infrastructure and compliance plans. A summary of how municipal water and wastewater agencies can apply EPA’s six planning elements of an integrated plan is briefly described below. is to discuss costs associated with the infrastructure investments and how the integrated plan provides flexibility to schedule those investments to maintain affordable utility rates over time.

Element 4: Evaluate Alternative Solutions. In this element, cities should identify and evaluate a broad range of potential programmatic and project alternatives, including asset management and renewal strategies, green infrastructure solutions, and innovative technologies. Through this process, cities provide planning transparency to the public and lay the groundwork for developing an optimized long-term investment strategy.

Element 5: Develop Solutions and Schedules. Once alternatives are identified, cities should schedule the identified solutions combined with the information gathered in Elements 1 through 4. The goal is to create an optimized schedule that is affordable for the community and maintains compliance with the Clean Water Act.

Element 1: Build the Vision. This initial step provides the opportunity for community leaders to come together and develop goals and priorities for the integrated plan. It is a time for assessing and understanding the existing and anticipated challenges within the water, wastewater and stormwater utilities. Discussions should focus on current and anticipated needs and actions to address regulatory requirements while meeting customer expectations.

Element 2: Evaluate System Performance. A thorough understanding of existing system performance provides the basis for understanding current and future needs. Master plans are a great place to start and will drive the planning process forward. This will assist community leaders in developing meaningful communications strategies (Element 3) and infrastructure alternatives (Element 4).

Element 3: Engage Community Stakeholders. Cities should engage their citizens at a level that is appropriate for the types of projects and needs of the community. The goal is to establish and build support for the community’s infrastructure planning priorities. An important component of the engagement process

Element 6: Implement, Measure and Adapt. The nature of creating a sustainable capital improvement plan requires periodic progress monitoring, updating needs assessments, and mechanisms for applying new data and information to adapt or revise plans over time. Element 6 is one of the most valuable in EPA’s Framework, as it allows the plan to be adaptive as new regulatory drivers, unexpected costs, and new information becomes available over time. It is important to track implementation success through performance metrics and report the successes, enhanced system understanding, revised community goals, and changing conditions back to DNR periodically.

Maintaining a Successful Integrated Plan

Municipal utilities can achieve several benefits of the integrated planning approach to tackle the multiple and diverse drivers facing today’s utilities:

• Balances and prioritizes regulatory obligations into a streamlined, integrated strategic plan.

• Emphasizes stakeholder empowerment to establish clear investment priorities.

• Considers the end-user affordability and the city’s financial capability.

• Provides a clear path to project implementation.

An integrated plan is not meant to be another report that collects dust on a shelf. It should be actionable, implementable and flexible enough to adapt to changing needs and drivers over time. Cities can divide long-term plans into shorter, 5-year segments to align with traditional capital improvement plans and permit timeframes. The 5-year plan should outline the City’s commitment to addressing the identified infrastructure challenges, filling data gaps, and performing detailed studies, as needed. These 5-year plans, combined with routine updates to community leaders and regulatory agencies, provide your community with an actionable roadmap to integrated planning success.

Lacey Hirschvogel and David Carani lead HDR's Missouri and Kansas water quality and regulators support team out of Columbia, Missouri. They have more than 30 years of combined experience assisting water and wastewater utilities to comply with new and evolving regulatory requirements and have been involved in developing most of the approved integrated plans in both Missouri and Kansas. For more information, contact them at lacey. hirschvogel@hdrinc.com or david.carani@ hdrinc.com.

by Carl Lumley