EPA's Integrated Planning Framework Approach: Opportunities and Challenges in Broadening the Scope

In May 2012, the US Environmental Protection Agency (EPA) released the “Integrated Municipal Stormwater and Wastewater Planning Approach Framework” (IPF). The Framework was developed jointly by the Office of Water (OW) and Office of Enforcement and Compliance Assistance (OECA). The IPF is not intended to change the underlying regulatory requirements. It is intended to allow communities to balance CWA requirements and address most pressing public health and environmental projection first. It is a voluntary process and the community is responsible for developing the integrated plan. The IPF encourages the use of innovative technologies, including green and sustainable options. An integrated plan can be incorporated into a compliance or enforcement action, with enforceable actions and schedules. Since late 2012, a number of communities have begun work using the IPF, either as part of an NDPES permit process or a Consent Decree driven process. These efforts are leading to further discussion about how to balance the parameters of the various regulatory requirements. The recently released WEF 2013 Guide to Municipal Wet Weather Strategies provides a strategy and process to navigate these regulatory hurdles.