Integrated Planning from West Coast to East Coast to WEF's Newly Released Roadmap

The Integrated Planning Framework was issued by EPA in 2012, but the concept and use of many of the tools stretches back almost a full decade earlier. Integrated planning is a voluntary approach to prioritize Clean Water Act (CWA) obligations for stormwater and wastewater and to account for drinking water obligations under the Safe Drinking Water Act. Integrated planning provides great promise for municipalities, regulatory agencies, and other stakeholders to achieve better water quality faster than traditional capital improvement planning. Even though the Framework has been around for almost 15 years, relatively few communities have embarked on integrated planning. This fact was the catalyst for the Water Environment Federation's (WEF's) forming of the Integrated Planning Task Force, numerous webinars, and the recently published Roadmap. Subsequent workshops for WEF Member Associations (MAs) are planned to help communities confidently proceed down the road of integrated planning. In October 2011, EPA issued a memorandum recognizing that a 'comprehensive and integrated planning approach to a municipal government's CWA wastewater and stormwater obligations offers the greatest opportunity for identifying cost-effective and protective solutions and implementing the most important projects first' (USEPA 2011). The memorandum provides guidelines for local governments to assess their stormwater and wastewater requirements, and then develop priorities based on locally derived environmental benefit. That memorandum was followed by a Draft Integrated Planning Approach Framework in January 2012 and issuance of the Framework in final form in June 2012 (USEPA 2012). The discussion on the best way to address how municipal CWA programs could be better integrated on a watershed basis has been ongoing for close to 30 years (see USEPA 1994; USEPA 2002; USEPA 2003; USEPA 2007). Pursuant to the CWA, municipalities are required to manage wastewater treatment plant discharges, collection system operation and maintenance, sewage sludge disposal and/or reuse, industrial wastewater via the pretreatment program, and municipal and industrial stormwater. Stormwater discharges are intermittent, somewhat unpredictable, and not easily characterized, making it difficult for municipalities to manage the discharges, and for National Pollutant Discharge Elimination System (NPDES) permitting authorities to set control requirements. In order to assist municipalities and NPDES authorities accomplish their missions in an economical yet responsible manner, the EPA has proposed a number of strategies over the years to address management of all of these programs in a holistic manner (USEPA 2002; USEPA 2003; USEPA 2007). Section 402(s) was added to the CWA in January 2019 as part of the Water Infrastructure Improvement Act (WIIA) (H.R. 7279) and included the 2012 Integrated Municipal Stormwater and Wastewater Planning Approach Framework. This provision requires NPDES permitting authorities to inform municipalities that they have the option to develop an integrated plan that may be incorporated into permits, consent decrees, or administrative orders. In 2004, Clean Water Services (CWS), a public water resources management utility in Oregon, was issued the nation's first integrated, municipal watershed-based NPDES permit which included Oregon's first approved and implemented water quality trading program. This permit has been very successful at generating environmental improvement because it allows the District to focus resources on issues that have the potential for the greatest beneficial impact on the environment. In 2014, the City of Richmond began working on the RVA Clean Water Plan. Richmond applied EPA's Integrated Planning Framework and Watershed Management concepts to form an integrated water resources management framework that is documented in the Clean Water Plan. A product of extensive public outreach, the Plan outlines a process that allows the City to efficiently evaluate, manage, and implement water quality programs and work toward their goals and objectives. These efforts culminated in the first integrated permit in the state that encompasses the City's wastewater, combined sewer overflows, and stormwater discharges. In 2025, WEF published the Integrated Planning Roadmap, designed to be a user-friendly guide for integrated planning. The Roadmap provides guidance to those who are just starting on an integrated planning effort and to help those who might be struggling with full implementation of their planning goals. Divided into chapters which focus on practical real-world advice, the Roadmap outlines nine steps to planning an integrated plan. This presentation and manuscript will examine the evolution of Integrated Planning through a discussion of the development of the Framework and the addition of Integrated Planning to the CWA through an amendment of section 402(s) to provide clear legal authority for integrated plans and Congressional support for use of the integrated plan process on a long-term basis. An additional part of the amendment required EPA to report on each integrated plan developed and implemented through a permit, order, or judicial consent decree since the issuance of the Framework, and this 2021 Report to Congress will also be discussed. Finally, the presentation will include discussion of case studies including Clean Water Services in Oregon and the RVA Clean Water Plan in Richmond and conclude with an overview of the Roadmap.