Richmond's Story of Integrated Planning, Integrated Permitting, and CSO Compliance

The City of Richmond, Virginia, has been working on CSO improvements since before the enactment of the Clean Water Act and completed its first CSO Long Term Control Plan (LTCP) four years before US EPA finalized federal CSO policy in 1994. The most recent LTCP was completed in 2002 and included a list of projects that were incorporated in a state special order by consent (consent order). Since that time, the City had been continuing to implement these approved projects, while staying within specified consent order spending guidelines. In anticipation of needing to update the standing LTCP, the City finalized its RVA Clean Water Plan in 2017 (City of Richmond 2017), which provides a comprehensive understanding of the City's watersheds and associated water resources. The Plan identified the goals and objectives and associated metrics that would guide the City moving forward, and in particular identified the need to continue the implementation of Combined Sewer Overflow (CSO) control projects, as the most cost effective method of reducing bacteria in the receiving waters. In 2018, the City worked with the Virginia Department of Environmental Quality (DEQ) to develop a truly integrated discharge permit that included wastewater effluent, combined sewer overflows, and stormwater discharges. The integrated permit provides the City the opportunity to manage their water resources as one and provides the flexibility to implement projects necessary to achieve the goals and metrics identified in the RVA Clean Water Plan. In 2020, the City was swept up in a legislative effort to finalize CSO compliance across the state of Virginia. Ultimately, the City's consent order for CSOs was amended to conform with the new legislative action, that required the City to develop an Interim and Final Plan for CSO compliance with specific deadlines. The projects identified in the Interim CSO Plan, finalized and submitted to the state in June 2021, were focused on the use of real time controls and other methods to optimize the use of the City's existing infrastructure. These projects were found to be an extremely cost-effective method of reducing CSO volume. The Interim Plan has been submitted on schedule, the recommended projects are being implemented, and the Final Plan is under development and due by mid-2024. According to the amended consent order, implementation of the Interim Plan projects must be completed by 2027, and the Final Plan projects must be completed by 2035. Benefits of Presentation The audience will hear a case study of Integrated Planning, Integrated Permitting, water-quality-based CSO compliance planning, use of emerging technology to maximize use of existing infrastructure to cost-effectively control CSOs, and innovative stakeholder involvement throughout a pandemic.