Annual FPA Update

As the state-designated water quality management planning agency for Portage, Stark, Summit, and Wayne Counties, NEFCO is responsible for coordinating the use, amendments to, and updates of the region’s Clean Water Plan (208 Plan), in accordance with Section 208 of the federal Clean Water Act. In recent years, some of NEFCO’s members expressed an interest in having the 208 Plan’s facilities planning areas (FPAs) updated more frequently than every several years, which has been the frequency of past 208 Plan FPA updates. In response to this interest, NEFCO’s contract with Ohio EPA for fiscal year 2023 included the initiation (start) of a voluntary annual FPA update process. This process provides an opportunity for primary wastewater management agencies (MAs) to update the boundaries and/or wastewater treatment prescriptions (options) of their respective FPAs, which is information that can be found in the 208 Plan’s Chapter 3 Appendices and on NEFCO’s interactive online 208 Plan map.

At the NEFCO Environmental Resources Technical Advisory Committee (ERTAC) meeting on March 1, 2023, after several months of the committee’s technical review, the ERTAC unanimously recommended that the NEFCO General Policy Board approve the guidelines and associated timeline for initiating a voluntary annual FPA update process. The NEFCO Board approved the guidelines on March 15, 2023. During the same week as NEFCO Board approval of the guidelines, staff sent them to the region’s 38 primary MAs (operators of publicly-owned treatment works and sewers), notifying them of the start of this year’s FPA update and establishing a June 19, 2023 deadline for them to submit their ‘draft FPA update application packet,’ as specified in the guidelines.

This first annual FPA update is completely voluntary on the part of the MAs. There will be no consequence for MAs that choose not to participate in the process.

Under the federal Clean Water Act and Ohio Revised Code, Ohio EPA should not issue a Permit-to-Install (PTI) for sanitary sewer extensions or approve an infrastructure loan when either conflict with the 208 Plan. Therefore, it is advantageous for the MAs to anticipate areas under their wastewater jurisdiction, which may not currently be consistent with the 208 Plan, and to recommend an FPA update so that the area is compliant with the 208 Plan’s wastewater treatment options.

The annual FPA update process will make FPA updates more manageable than letting needed updates accumulate over several years, and then having to undertake a comprehensive 201/208 FPA update. It may alleviate delays for some expected economic and residential development projects which would currently conflict with the 208 Plan. By correctly anticipating the size of an expected project, the MA can prepare an adequate 208 Plan update through NEFCO’s annual FPA update process, thus enabling the project to be in agreement with the Plan prior to the submittal of the project’s permit or loan application to Ohio EPA.

For the annual update of 201/208 FPAs to proceed efficiently, it will be important for the primary MAs’ GIS specialists to provide the GIS shapefiles for any proposed FPA updates to NEFCO in the same format that our agency uses. To help meet this important mapping goal, staff organized and held a virtual meeting with the interested MAs on April 21, 2023.  At that meeting, NEFCO’s GIS specialist provided the mapping guidelines for the annual FPA update and notified the MAs that the materials and data for the mapping would be sent to them soon. This is the link to the recorded annual FPA update mapping meeting.

For more information about NEFCO’s annual FPA update process or the 208 Plan, please contact Tom LaPlante.