On April 3, PNCWA, WEF, NACWA and Oregon ACWA cohosted a workshop with EPA region 10 on the Clean Water Act (CWA) Integrated Planning Framework . Local Government and State regulators spoke to wanting broad and innovative approaches to be supported, a desire to include watershed needs, and a proactive approach that goes beyond compliance orders. Oregon emphasizes a desire to have integrated planning include within the Permit. Representatives from Washington spoke to their experience, and perceived advantages of integrated planning and on the economic trade-offs, wanting to prioritize efforts that have greatest environmental gain and discussion on ability to pay.
EPA was very positive, responding to state and local governments saying “all of this is possible”, and that that headquarters and all ten regions are behind integrated planning. EPA did characterize integrated planning as a companion document to a compliance order. The EPA did not reject permitting approaches, rather encouraged it, but said that the local and State folks would have to present that option to them. EPA did encourage including broader environmental issues, beyond just Water Quality Act compliance needs, into an integrated plan.
EPA noted several times that developing an integrated plan was up to local governments and the state. The discussion was not clear on EPAs participation in the development of an integrated plan. The expectation for EPA involvement ranged from local governments build it and show it to EPA when it is done, to EPA expressing a desire to be involved throughout the process. Some consternation was expressed about spending a lot of effort on an integrated plan that EPA may reject if they are not involved in the development.
There was quite a bit of discussion around the ability to pay. Although EPA did note that the 2% of median annual income threshold was just one metric and they would consider other aspects of ability to pay. I do not think the response appeased everybody who raised concerns. Concerns raised included equity, environmental justice, and a community’s ability to pay for all environmental issues, such as ESA costs as well.
EPA did note that the integrated plan was not an alternative to compliance, or regulatory relief. EPA noted that the integrated plan developed a process to achieve compliance, and there was a lot of what I think was positive discussion on semantics which indicated EPA being very willing to broadly view the integrated plan as providing compliance strategies.