Following a June 2012 Integrated Municipal Stormwater and Wastewater Planning Approach Framework, a new memorandum to EPA regional administrators and Water and Enforcement Division directors from EPA’s Office of Water and Office of Enforcement and Compliance Assurance attempts to further clarify the types of considerations that municipalities can use when evaluating affordability of projects undertaken to comply with Clean Water Act (CWA) requirements. The three-page “Financial Capability Framework” memorandum is the latest product stemming from ongoing discussions with local communities and other stakeholders and reflects the real funding challenges faced when implementing CWA requirements.
Despite the flexibility advocated by EPA Headquarters within its integrated planning framework, many municipalities have found the message has not adequately filtered down to the regional and state levels. Though it does not offer concrete solutions, the memorandum represents the next step in a continuing dialogue between all government sectors. The framework encourages further dialogue on issues such as more appropriate indicators of community affordability, prioritization of projects, innovative financing and consideration of other community obligations (such as those under the Safe Drinking Water Act).