Value of an Integrated

Planning Approach for

Euclid, Ohio

CH2M Hill

EPA Policy Evolution since 2011

“A comprehensive and integrated

planning approach to a municipal

government’s CWA waste- and

storm-water obligations offers the

greatest opportunity for identifying

cost-effective and protective

solutions and implementing the

most important projects first.”

“The OW and the OECA are

committed to working with

interested communities and water

resource managers to successfully

incorporate green infrastructure

into NPDES permits, as well as

remedies designed to address

non-compliance with the CWA, to

better manage both stormwater

runoff and sewer overflows.”

Attachment A

Recent (2011) Examples of

Enforcement Actions with Green

Infrastructure

Cincinnati, OH

Cleveland, OH

Kansas City, MO

Louisville, KY

CH2M Hill

EPA’s Integrated Planning Framework can

refine the program, saving $ and extending

the compliance timeline

• MBR Upgrades

• HeadworksUpgrade

Ongoing System

Improvements

•Cost Savings through regionalization

•Optimize CSO / SSO Controls

•Add Green Infrastructure

Integrated Planning

Regionalization

Affordability

•Optimized Storage

•Pro-Business GI and Economic Development projects

Refined Program

Pause Point Extend Compliance Schedule

Address Affordability Concerns

CH2M Hill

Euclid: Initial Review of Consent

Decree and Wet Weather Plan

Euclid’s Control Levels are high and are not connected to

water quality standards

Program Affordability is not aligned with best practices to

protect Euclid ratepayers

Significant Schedule and Future Cost Risks of program

Ensuring Regional Buy-in with rising compliance costs

Ruling out Green Infrastructure (GI) is inconsistent with National

practice and EPA Policy

CH2M Hill

Euclid: Control Levels are high and

cost/benefits are not considered

CSO Activation limit of 4 per year arbitrary in context of water

quality benefits

Exceeds CSO Policy which allows 6 or more if benefits from fewer

activations cannot be cost justified

Unclear if Euclid using Presumptive or Demonstrative Approach –

this could impact potential alternatives and costs

No clear linkage of program investments to water quality benefits

Lake Erie TMDL evolving and would likely change plan emphasis

and costs

EPA Region 5 imposing “new” interpretation of CSO Policy

CH2M Hill

Euclid: Program Affordability is

not aligned with best practices

to protect ratepayers

Cost escalation changes affordability

of the CD driven plans

Schedules and cash flow impacts

need to be more closely evaluated

Plant work, CSO work, SSO work being

forced to overlapping timelines

Huge cash flow needs in 2015-2018

creates unbalanced program

May cause unanticipated rate stress

and loss of customer support

At a minimum, Euclid needs more

time to comply

CH2M Hill

Euclid: Cost Escalation - total cost risk

0

20

40

60

80

100

120

140

160

180

Sep-11 Mar-12 Oct-12 Actual

?

CH2M Hill

Euclid: Consent Decree Issues and

Opportunities: Penalty Avoidance

Consent decree heavy on

penalty provisions for small

city

More than NEORSD and other large cities in some

cases

Euclid should be careful

with penalty liability if

dispute resolution needed

to get CD plan and schedule changes

STIP risks can be reduced

City STIPS – Maximum Daily

Penalty

Euclid, Ohio $4,000/day after 60 days

Chicago MWRD $5,000/day after 60 days

St. Louis $4,000/day after 60 days

Cleveland (NEORSD) $2,000/day after 30 days

DeKalb $3,000/day after 120 days

Honolulu $2,000/day after 60 days

Kansas City $4,000/day after 60 days

HRSD $3,000/day after 60 days

Nashville $5,000/day after 6 months

Louisville $5,000/day after 120 days

Baton Rouge $10,000/day after 60 days

EPA now assessing STIPS in some Regions

CH2M Hill

Euclid: Rationale for Integrated Plan

Save Money

Affordability picture has changed due to CSO/SSO and Separate

stormwater (MS4) issues need to be considered

CD requires overlapping CSO/SSO and Plant work

There is precedent - Other cities reopening CD negotiations based on

excessive costs and integrated planning opportunities

Integrated plan can assess schedule impacts and balanced approach

Adapting the program to enable Greener Communities; currently green

is at the back end of schedule, which does not help Euclid achieve

community improvements or benefits soon enough

Plan would address increasing public opposition to program costs and

clarify program benefits

Better program controls are necessary to enable more transparency in

terms of understanding of projects / budgets / value / status

CH2M Hill

Euclid: Two - Step Revision Strategy

1. Develop consensus to review and update process

Work with City staff and legal counsel to identify benefits of

a refinement phase and integrated plan

2. Develop a road map

Build technical, regulatory, and financial case to support

plan revision

Build team (internal staff and external consultants)

Develop strategy to negotiate and implement a revised

consent order and wet-weather plan

CH2M Hill

Euclid Integrated Plan Roadmap Affordability analysis / FCA requires more sophistication

Review current investments being implemented at this time, specifically

those at the treatment facility/equalization storage

Identify the gap remaining to satisfy all existing and imminent regulatory

requirements (point and non-point sources, MS4, TMDL, and others)

Integrate GI solutions with existing/proposed gray infrastructure, as well as

identify where proposed gray infrastructure may be replaced with

equivalent green options

Better utilization of planning tools such as geographic information systems

(GIS) and stormwater management model (SWMM)

Evaluate CSO/SSO capture assumptions based on national experience

Utilize modeling tools and the monitoring data effectively to support revised

program and build consensus with regulators and stakeholders

Prioritize community opportunities/impacts

CH2M Hill

Examples of Integrated and Adaptive

Wet-Weather Plans

Onondaga County, NY

Louisville, KY

Spokane, WA

Cincinnati, OH

Lancaster, PA

CH2M Hill

Onondaga County, NY

Balanced Approach>165 green projects completed100,000,000 gallons of runoff reduction

Consent Judgment to clean up “America’s most polluted lake”

Public opposition increased cost and delayed implementation

Balanced approach; given 1 year pause to develop new control plan

Green Infrastructure to front of program,

smarter gray program: Extended compliance schedule by 5 years

Saving over $20M+ in capital cost while reducing life cycle

Community sees the benefits to the lake, tributaries, and public assets

CH2M Hill

Louisville, KY

Negotiated option to do integrated planning in multi phased CD

Prioritized expenditures over extended timeline ($800 million program)

Substitute green projects if equal or better than grey projects

Innovative incentives to maximize private green investments

Measure green project performance and compare to grey projects

CH2M Hill

Spokane, WA Integrated Clean Water Plan utilizing the USEPA’s

Integrated Planning Framework

CSO Plan Amendment to save $120 million

Evaluated cost-effectiveness Green Infrastructure

Collaboration with Spokane area stakeholders and

the Washington State Department of Ecology

Prioritized to meet water quality requirements, and

provide economic development and aesthetics

“We spent a year re-evaluating our work to reduce

combined sewer overflows and stormwater runoff

going to the Spokane River, along with plans to

improve treatment at our wastewater facility. We

identified a path forward that would reduce the cost

by about $150 million and vastly improve the health

of the river.” - David Condon, Mayor, Spokane, WA

CH2M Hill

Cincinnati, OH

Metropolitan Sewer District of Greater Cincinnati) entered into CD in

August, 2010

Multi-billion dollar program comprised of wet weather, capacity assurance,

and asset management improvements

Negotiated the opportunity to conduct a 3-year study to develop and

evaluate a cost competitive alternative to the default CD solution (tunnel)

Integrated Planning to address stormwater issues and economic,

environmental, and social benefits for community

Sustainable watershed evaluation planning process

officially adopted in June 2012

CH2M Hill

St Francis bioinfiltration basin early success project

completed by MSDGC in Lick Run watershed

Lancaster, PA

Integrated Plan provides real benefits:

Lower Life Cycle Cost

Community Impacts (Triple Bottom Line)

CSO Volume Reductions

Water Quality (Pollutant Load Reduction)

Flood Risk Reduction

“The purpose of this analysis is to demonstrate

how accounting for the multiple benefits of

green infrastructure can provide a more

complete assessment of infrastructure and

community investments” US EPA

“CH2M HILL has been a tremendous partner throughout the development and implementation of our regulatory compliance

program for an update to our long term control plan and MS4 programs and helping us meet our goals for the TMDL. We have great local resources from the firm and we have also benefitted

from their global reach and experience.”

Charlotte Katzenmoyer, Director of Public Works, City of Lancaster, PA

CH2M Hill