Value of an Integrated Planning Approach for Euclid, Ohio CH2M Hill
Jul 16, 2015
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