Value of an Integrated

Planning Approach for

Euclid, Ohio

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

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

Initial Review of Euclid 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

Euclid’s Control Levels are high and

cost/benefits 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

Program Affordability is not

aligned with best practices to

protect Euclid 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

Cost Escalation - total program cost risk

0

20

40

60

80

100

120

140

160

180

Sep-11 Mar-12 Oct-12 Actual

?

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

Rationale for considering an integrated

planning and program refinement phase

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

Examples of Integrated and Adaptive

Wet-Weather Plans

Louisville, KY

Spokane, WA

Cincinnati, OH

Columbus, OH

Akron, OH

Lancaster, PA

Onondaga County, NY

Louisville, KY

Negotiated option to do integrated planning in multi phased CD

Allowed prioritization of competing CSO, SSO, and stormwater expenditures

over extended timeline ($800 million program)

Provided mechanism for substituting green projects if equal or better than

grey projects identified resulting in significant green projects and stronger

public support for rate increases

Has innovative incentives to maximize private green investments

Has resolved technical issues with EPA Region 4 to “measure” green project

performance and compare to grey projects

Spokane, WA

Integrated Clean Water Plan utilizing the USEPA’s

Integrated Planning Framework focused on the

City’s goal of achieving a cleaner Spokane River

faster

Developed of a CSO Plan Amendment that re-sized

CSO tanks and saved the City $120 million

Evaluated applicability and cost-effectiveness of

pollutant reduction approaches (in addition to

discharge reduction) including Green Infrastructure

Collaboration with Spokane area stakeholders and

the Washington State Department of Ecology was

essential for integrated planning success

Re-prioritized projects based on removal of

pollutants, meeting water quality requirements, and

on other objectives important to the residents of

Spokane including 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

Cincinnati, OH

Metropolitan Sewer District of Greater Cincinnati (MSDGC) 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)

Program incorporates integrated planning approaches to address Stormwater and wastewater issues while yielding enhanced economic, environmental, and social benefits for community

CH2M HILL professionals provided technical expertise to support MSDGC Office of the Director (OOD) in the development of a sustainablewatershed evaluation planning process (SWEPP) alignedwith the USEPA Integrated Planning Framework that wasofficially adopted in June 2012

St Francis bioinfiltration basin early success projectcompleted by MSDGC in Lick Run watershed

Columbus, OH

Proactively addressing their stormwater challenge as part of their SSO

mitigation

Have pilot program to implement GI to provide water quality treatment of

stormwater runoff in their sanitary sewer service area

This pilot program also includes private property rehabilitation of service

laterals, which are thought to be a significant source of I/I in the sanitary

sewer system

Columbus owes the EPA a report with monitoring and modeling based

findings on effectiveness and published cost effectiveness by September,

2015

Lancaster, PA

Integrated Plan that

provides the following

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

Onondaga County, NY

Consent Judgment was agreed to clean up “America’s most polluted lake” – but stakeholders were not satisfied with the stipulated approach

Prolonged public opposition increased cost and delayed implementation

New County Executive leadership convinced Judge to consider Greener, Balanced approach; given 1 year pause to develop new control plan

Revised program moves Green Infrastructure to front of program, implements a smarter gray program, Extended compliance schedule by 5 years

Saving over $20M+ in capital cost while reducing life cycle costs even more; improves other community assets immediately (roads, parking lots, roofing systems, vacant lots, parks, schools)

Community sees the benefits to the lake, tributaries, and public assets; able to appreciate why their sewer rates have increased

Euclid, Ohio

Next: Two - Step Revision Strategy

1. Develop consensus to proceed with a 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

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

Questions ?

Onondaga County, NYOriginal Consent Order planned to build four (4)

Regional Treatment Facilities (RTFs)

in neighborhoods and business districts

(1 of the 4 was built costing $79.1 million;

significantly over budget)

RTFs required large

conveyance

pipelines with

significant

community disruption

(over budget and

behind schedule)

Initial Projects Opposed by

Community Residents and Businesses

Onondaga County, NY ~ Balanced Approach

Syracuse becomes

one of first ten EPA

Green Cities

County Executive Mahoney Announces “Project 50!”

“Onondaga County will construct fifty distinct green

infrastructure projects to return rain water and snow

melt to the ground instead of our sewer system.”Joanne M. Mahoney, State of the County Address,

March 1, 2011

Onondaga County, NYOver 165 projects completed100,000,000 gallons of runoff reduction

Onondaga County, NYBenefits to County Facilities

OnCenter Convention Center

66,000 Square Foot Green Roof

New 30 year roof installed under CSO program;

study underway quantifying heating and cooling

benefits in addition to runoff reduction

Before

Onondaga County, NYGreen Streets Installed Adjacent To No-Standing Lanes

Add Aesthetic Value Without Impacting Traffic or Pedestrians

BEFORE: Stormwater enters catch

basins and is directly connected to

sewer

PROPOSED (Photo Simulation):

Stormwater is diverted to Green

Streets and only overflows to

sewer when necessary

AFTER (Actual Photo): Project

has been adopted* by local

business to pick up litter, weed,

and mulch (provided by County)

Adopt-A-GI Project program was created based on common Adopt-A-Highway format

Onondaga County, NYBenefits to County Facilities

OnCenter Convention Center

290 Parking Space Surface Lot(porous asphalt perimeter with subsurface

storage and infiltration system)

Lot had many potholes and significant cracking; resurfacing

paid for through CSO program. Improved safety through

smarter layout, LED lighting, as well as electric vehicle

charging station (separate funding source)

Before

Onondaga County, NYBenefits to County Facilities

Surface Parking Lot next to

Everson Art MuseumPreviously a puddle-ridden gravel lot, new

standard asphalt pavement drains to Bio-

retention designed to store, slowly infiltrate,

and provide evapotranspiration of runoff

due to poorly draining soils; large storm

events overflow to sewer

Vegetated

Bio-retention

System, including

90 new Trees

Before

Onondaga County, NYBenefits to City Streets

Award

Winning

Water Street

Green

Gateway

Project

Completely new City Street (City paid for asphalt mill and

paving, County program paid for all other work)

Before

Onondaga County, NYBenefits to City Streets – Typical Residential

Stone

Trench

New City Street

Storage and Infiltration Trench no longer visible

Onondaga County, NYBenefits to City Streets

Otisco Street

Residential Green Street

with Bioswale

• New Curbs, asphalt,

and sidewalks

• Traffic Calming

(Bump Outs)

• Added green space

Onondaga County, NYBenefits to City Commercial Districts

Westcott Street Commercial District

• New Curbs, Sidewalks, and Asphalt

• Improved Pedestrian Experience

Before

Onondaga County, NYBenefits to City Streets

West Onondaga Street

Commercial District

Before

Onondaga County, NYBenefits to City Streets

West Onondaga Street

Commercial District

• New Curbs, Sidewalk, Asphalt

• Improved Traffic Pattern

• Added Green Spaces Before

Onondaga County, NYAddressing the Vacant Lot Challenge

701 Oswego

Street Vacant

Lot Project

The CSO Abatement Program has utilized

multiple vacant lots in the City to manage

stormwater runoff while investing in new curbs,

sidewalks, and putting these properties to

beneficial use as nurseries and gardens

Before

Onondaga County, NYUtilizing Park Space

Leavenworth Park Bio-infiltration SystemProject included new roadside granite curbs and

carriage walk; plantings compliment park setting

(County program has also resurfaced basketball courts,

parking lots, and supported other park amenities)

Spring

Summer Bloom

Onondaga County Green Improvement FundA Public Private Partnership Grant Program

Incentivizing GI on Private Property 130 Applications Submitted (Mar 2014) 59 Projects Completed

(27 in 2013) 25 million gallons of

Stormwater Runoff capturedfor $6.1 million

21.5 million more gallons contracted Average rate = $0.25/gal for program

The County also has a program that has distributed over 1,000 free Rain Barrels, and has planted over 2,500 street trees (8,500 planned)

Monroe Building

Green Roof