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National Pollutant Discharge Elimination System (NPDES)

Integrated Planning for Municipal Stormwater and Wastewater

What's New

Integrating Planning Overview

Over the past 45 years, EPA, states, and municipalities have made significant progress protecting our waters through implementation of the Clean Water Act (CWA). However, challenges remain. As the nation faces population growth, aging infrastructure, limited resources, and increasingly complex water quality issues, new approaches to address CWA requirements are being explored.

Focusing on each CWA requirement individually may constrain a municipality from addressing its most serious water quality issues first. Recognizing the limits of this approach, in 2012, EPA developed an integrated planning framework that offers a voluntary opportunity for a municipality to develop an integrated plan to meet multiple CWA requirements.

On January 14, 2019, the Water Infrastructure and Improvement Act (WIIA) (H.R. 7279) became law. WIIA added a new Section 402(s) to the CWA to amend the CWA to include the 2012 Integrated Municipal Stormwater and Wastewater Planning Approach Framework. See the discussion below on WIIA for details. 

Integrated Planning Elements

An integrated plan is a process that identifies efficiencies from separate wastewater and stormwater programs to best prioritize capital investments and achieve our human health and water quality objectives. This approach can also lead to more sustainable and comprehensive solutions, such as green infrastructure, that improve water quality and provide multiple benefits that enhance community vitality.

The six elements of an integrated plan from the 2012 Integrated Planning Framework:

Element Description
1 A description of the water quality, human health and regulatory issues to be addressed in the plan.
2 A description of existing wastewater and stormwater systems under consideration and summary information describing the systems’ current performance.
3 A process which opens and maintains channels of communication with relevant community stakeholders in order to give full consideration of the views of others in the planning process and during implementation of the plan.
4 A process for identifying, evaluating, and selecting alternatives and proposing implementation schedules.
5 A process for evaluating the performance of projects identified in a plan, which may include evaluation of monitoring data, information developed by pilot studies and other studies.
6 A process for identifying, evaluating and selecting proposed new projects or modifications to ongoing or planned projects and implementation schedules based on changing circumstance.

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Water Infrastructure and Improvement Act (WIIA)

The Water Infrastructure and Improvement Act (WIIA) (HR 7279), enacted on January 14, 2019, added a new Section 402(s) to the CWA to amend the CWA to include the 2012 Integrated Municipal Stormwater and Wastewater Planning Approach Framework. WIIA provides greater certainty that integrated planning provides a comprehensive path a municipality can take voluntarily to meet CWA requirements.

The new amendments require NPDES permitting authorities to inform municipalities that they can develop voluntarily an integrated plan that may be incorporated into permits, consent decrees, or administrative orders.

WIIA stated that EPA must establish an office headed by a Municipal Ombudsman in the Administrator’s Office to provide outreach and technical assistance. In March 2020, EPA hired a Municipal Ombudsman to meet these requirements. The law also requires EPA to write a report to Congress by January 2021 that identifies completed integrated plans incorporated in permits, consent decrees, or administrative orders since June 5, 2012.
On September 26, 2019, EPA issued a memorandum to ensure consistent implementation of WIIA for enforcement actions and modifications.
On December 3, 2019, EPA issued a memorandum to highlight new provisions in WIIA, describe how EPA will support implementation of WIIA, and provide a preliminary list of integrated plans.

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