NACWA is pleased to announce the U.S. Environmental Protection Agency (EPA) finalized its Report to Congress on Integrated Plans to Comply with the Water Infrastructure Improvement Act (WIIA) of 2019 on July 12. The Report was sent to both the Senate’s Committee on Environment and Public Works and the House’s Committee on Transportation and Infrastructure and is also now publicly available on EPA’s Integrated Planning website.

As a result of NACWA’s advocacy efforts alongside other municipal and water sector partners, Congress codified Integrated Planning (IP) into the Clean Water Act (CWA) in January 2019—a monumental revision to the Act that can significantly help communities prioritize actions with the most meaningful water quality benefits while simultaneously recognizing a community’s affordability constraints.

Congress directed EPA to develop this Report to track nationwide IP implementation and to further examine the costs, control measures, and compliance schedules of those communities that have effectively pursued IP. EPA highlights in the Report a total of 27 municipalities that have developed an integrated plan, including 13 integrated plans that are part of a CWA National Pollutant Discharge Elimination System (NPDES) permitting scheme, an administrative order, or a consent decree.

While there is tremendous variability between community needs and specific CWA drivers, EPA’s Report notes that on average the cost to implement an integrated plan can range from $15 million to $2 billion, with an average of $745 million. EPA also highlights in the Report that, of the integrated plans that are part of a CWA obligation and not a volunteer effort, communities are mostly using an integrated plan to address CSOs and SSOs and further progress on stormwater management. It is important to note that the compliance schedules for those integrated plans EPA discusses are long-term, with an average compliance schedule of 21 years.

EPA’s Report exemplifies how an integrated plan can present a community with considerable cost-saving opportunities as well as provide significant water quality improvements beyond what a singular improvement project could achieve.

NACWA would like to thank each of the clean water communities—including NACWA members—that are highlighted in EPA’s Report to Congress, and the meaningful progress they have made on IP. This information will be tremendously helpful to other municipalities looking to integrate a more flexible process to address water quality challenges in their community and best prioritize key dollars accordingly. At the same time, it is clear that more can by done at the local, state and federal level to continue promoting IP and make it easier for more communities to take advantage of it. 

Since publishing its 2012 Integrated Planning Framework, EPA has demonstrated its continued support for municipal clean water utilities seeking to develop and implement an integrated plan. NACWA is encouraged by EPA’s work done to date and supports EPA providing critical communication and assistance as communities begin to conceptualize an IP framework.

To help further IP progress across the country, EPA has partnered with the Environmental Finance Centers of the University of Maryland and University of North Carolina to provide a complimentary technical assistance program to review integrated plans and provide critical feedback. NACWA encourages communities seeking feedback on developing an integrated plan to take advantage of this technical assistance through the end of August 2021.

If members have questions on EPA’s Report to Congress or what is ahead for EPA’s IP program, please contact Emily Remmel, NACWA’s Director of Regulatory Affairs.