Attach__No__1B_-_Clean_H2O_Act_Playbook.pdf

Air Force Civil Engineer Clean Water Act Playbook

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U . S . A I R F O R C E Clean Water Act

Playbook

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Table of Contents

Introduction

1.1 How to use this playbook

Chapter 2 Clean Water Act (CWA)

2.1 Federal Regulations: NPDES

2.2 State/Local Regulations

2.3 DoD/AF

2.4 Permits

2.4.1 WW Permits

2.4.2 SW Permits

2.4.3 Permit Management

2.4.3.1 Typical CWA Regulatory Hierarch

Chapter 3 Roles and Responsibilities Chapter 4 WQM Programming and Funding

4.1 AF Funding and Execution

4.1.1 Planning and Programming for EQ

4.1.1.1 Resource Allocation Model (RAM)

4.1.2 Planning and Programming for Built Infrastructure (Non-EQ Appropriated Funds)

4.1.2.1 Air Force Comprehensive Asset Management Planning Process (AFCAMP)

4.1.2.1.1 AFCAMP Utilities Guidance (SRM)

4.1.2.1.2 AFCAMP Facilities Guidance (SRM)

4.1.2.1.3 EQ Natural Infrastructure Guidance (SRM with EQ driver)

4.1.3 EPET (Environmental Programming Execution Tool)

4.2 Non-AF Funding and Execution Appropriation of Funds

4.2.1 Planning and Programming for Defense Logistics Agency (DLA) Capitalized Funding

4.2.2 Planning and Programming for Built Infrastructure (Non-Appropriated Funds (NAF) Non-EQ)

Chapter 5 Wastewater (WW) Quality Management Program Elements

5.1 WW Regulations

5.2 WW System Components/Infrastructure

5.2.1 Applicable Design Criteria/Permit

5.2.2 Collection Systems/Sanitary Sewer

5.2.3 Lift Stations/Manholes/Outfalls

5.2.4 Pretreatment Devices/Systems

5.2.4.1 Oil/Water Separators (OWS)

5.2.4.2 Grease Traps/Interceptors

5.2.4.3 Industrial Wastewater Treatment Plant (IWTP)

5.2.5 Federally Owned Treatment Works (FOTW)

5.2.6 Publicly Owned Treatment Works (POTW)

5.3 CE Operations (OPS)

5.4 Environmental Compliance Requirements

5.4.1 Annual and Cyclic Recurring Requirements

5.4.1.1 Permits, New and Renewals

5.4.1.2 WW Fees

5.4.1.3 Required Plans and Reports

5.5 EQ Sampling, Analysis and Monitoring (SAM) for Compliance

5.6 Studies and Surveys

5.6.1 Inflow and Infiltration (I&I) Survey

5.6.2 Pollutant Source/Loading Studies

5.6.3 Slug Prevention and Control

5.7 General Best Management Practices (BMP)

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5.8 Emerging WW Requirements

Chapter 6 Stormwater (SW) Quality Management Program Elements

6.1 SW Regulations

6.2 SW System Infrastructure

6.2.1 Applicable Design Criteria/Permit

6.2.2 SW Catchments/Drains

6.2.3 SW Conveyance Systems

6.2.4 Appurtenances (Manholes/Lift Stations)

6.2.5 Outfalls

6.2.6 Low Impact Development

6.3 CE Operations

6.4 Environmental Compliance Requirements

6.4.1 Annual and Cyclic Recurring Requirements

6.4.1.1 Permits: New and Renewals

6.4.1.2 SW Permit Fees

6.4.1.3 Required Plans and Reports

6.5 EQ SAM for Compliance

6.6 Surveys and Studies

6.6.1 Illicit Discharge Survey

6.6.2 Pollutant Source/Loading Studies

6.7 General BMPs

6.8 Emerging SW Requirements

Chapter 7 Information Technology, Data Systems, and Management

7.1 Environmental Business Information Systems (BIS)

7.1.1 Enterprise Environmental, Safety, Occupational Health Reporting Management Information System

(EESOH-MIS)

7.1.2 Enforcement Actions, Spills, and Inspections Environmental Reporting (EASIER)

7.1.3 Water Enterprise Tracking (WET) WQPM Roles - Quick Reference Guide

7.1.4 eDASH and Tool for Environmental Management Plan (T-EMP)

7.2 AF GeoBase/Mapping Capabilities

7.2.1 Utility Layers

7.2.2 Environmental (WQ) Layers

7.3 UTILITIES - Sustainment Management System (SMS)

7.4 NEXGEN IT/NEXGEN IT and Automated Civil Engineer System (ACES)

7.4.1 ACES - RP (NEXGEN IT and ACES - RP)

7.4.2 ACES - Project Management (ACES - PM)

7.5 Non-AF Environmental Information Systems

Chapter 8 Training

8.1 DAF Environmental (EQ) Training Center (AFCEC/CZCA)

8.1.3 The Environmental Awareness Course Hub (TEACH)

8.2 AF MyLearning

8.3 Air Force Institute of Technology (AFIT) Civil Engineer School

8.4 WET Classroom/Virtual Trainings (AFCEC/CZTQ)

8.5 Training Offered by Regulatory Agencies and Industry (non-AF)

8.5.1 Free and Local Training

8.5.2 Training Requiring Travel Costs and/or Fees

8.6 Other Training Requests/eTTRP

8.7 Recommended Training

8.7.1 WQPM

8.7.2 SWP2 Stakeholders

8.7.3 Other CWA Stakeholders:

Appendix A – Acronym List

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Appendix B –Office Symbols Appendix C - References and Master List of Links Appendix D – Continuity Checklist

List of Tables Table 1: WQPM Permit Management Responsibilities Action Quick Reference Table 2: Roles and Responsibilities Table 3: WW Collection System Action Quick Reference Table 4: Lift stations, Manholes, and Outfalls Action Quick Reference Table 5: CEIE OWS Management Program Action Quick Reference Table 6: CEIE Grease Trap Program Management Action Quick Reference Table 7: CEIE IWTP Management Program Action Quick Reference Table 8: CEIE FOTW Best Practices Table 9: CEIE POTW Program Management Action Quick Reference Table 10: WW Operations Collaboration Best Practices Table 11: WW Reports Action Quick Reference Table 12: WW Compliance Sampling Action Quick Reference Table 13: WW Studies and Surveys Action Quick Reference Table 14: SW Infrastructure Actions Quick Reference Table 15: CEIE SW OPS Collaboration Best Practices Table 16: SW Reports Action Quick Reference Table 17: SW Compliance Sampling Action Quick Reference Table 18: SW Studies and Surveys Action Quick Reference Table 19: EESOH-MIS Action Quick Reference Table 20: Environmental Event Timeline Requirements (in business days) Table 21: EASIER Action Quick Reference Table 22: WET Action Quick Reference Table 23: T-EMP Action Quick Reference Table 24: Continuity Checklist Table 25: POC Template Table 26: POC Template with functions Table 27: Permit Decomposition Example Table 28: Permit Decomposition Template

List of Figures Figure 1: State NPDES Program Status Map Figure 2: State NPDES Program Status Map Figure 3: Air National Guard Regulatory Flowchart Figure 4: IPL Validator screen Figure 5: Training Matrix

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Introduction The objective of the Water Quality Management (WQM) playbook is to provide process and narrative for the implementation and execution of the major Clean Water Act (CWA) compliance components, provide a basic description of the elements, and identify primary roles and responsibilities. This playbook uses a simplified interface with an in-depth approach on “how-to” comply with Federal, State/Local and Dept of Defense (DoD) Air Force (AF) policies and instructions. This playbook identifies key functions and promotes practical checklist-type actions to focus water quality program managers (WQPM) on achieving core capabilities described in the CWA WQM. The goal is to develop proactive management actions leading to the optimal resource decisions to support overall water quality (WQ) and regulatory compliance. This playbook identifies a corporate view of “what’s important” as a roadmap to this goal.

1.1 How to use this playbook

This playbook is intended to bring the WQ Management community to a best-in-practice capability. Job-Aids are provided in the form of action-oriented quick reference tables and checklists to assist WQPMs and supporting stakeholders in the development of their programs.

Job-Aids contribute to the evolution of WQM through tailored guidance, building on each step, maintaining each level as the next level is achieved.

Limitation: This playbook does not replace, supersede, or circumvent existing DoD or AF policy.

Federal, state, local or outside of the continental United States (OCONUS) regulations and permit conditions take precedence over the guidance in this playbook.

Applicability: This playbook is written for WQPMs managing wastewater (WW) and stormwater (SW) compliance and describes general responsibilities for personnel described in Chapter 3, Roles and Responsibilities. A WQPM is the primary person for ensuring CWA compliance is maintained for WW and SW. This duty is understood to typically be assigned to the Civil Engineering Environmental Flight (CEIE) for active-duty AF installations. Some installations may use a different office symbol for the CE (Civil Engineer) Environmental Flight. Some installations (such as Air National Guard (ANG) locations) may have an environmental element which does not fall under CE. For the purposes of this AF CE playbook, the term CEIE is used for the organization tasked with environmental compliance for the installation; similar users with a different office symbol should understand CEIE practices in this playbook may apply to them regardless of office symbol. Geographically separated units (GSU) and overseas locations are bound by applicable laws and regulations and may therefore require specialized consideration.

Consult the Final Governing Standard (FGS) or Overseas Environmental Baseline Guidance Document (OEBGD) where no FGS exists.

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Chapter 2 Clean Water Act (CWA) The CWA was enacted in 1972 and is predated by the Federal Water Pollution Control Act of 1948. Its purpose is to regulate discharges of pollutants into the waters of the United States (US) and regulating quality standards for surface waters. The CWA established the National Pollution Discharge Elimination System (NPDES), making it unlawful to discharge any pollutant from a point source into navigable waters, unless a permit was obtained. For more information on the CWA, please see the Environmental Protection Agency (EPA) Website. It is the WQPM’s responsibility to ensure that the AF follows CWA and NPDES regulations on installations.

2.1 Federal Regulations: NPDES

The EPA's NPDES permit program controls discharges into waterways. Industrial, municipal, and other facilities must obtain permits if their discharges go directly to surface waters, navigable waters, tributaries to navigable waters, interstate waters, and the oceans out to 200 miles.

Additionally, it also applies to intrastate waters, which are used by interstate travelers for recreation or other purposes, and as a source of fish or shellfish sold in interstate commerce, or for industrial purposes by industries engaged in interstate commerce.

The EPA published the general NPDES regulations in Title 40 of the Code of Federal Regulations (CFR). The primary regulations developed by EPA to implement and administer the NPDES permit program are:

• Part 122: EPA-Administered Permit Programs: The National Pollutant Discharge Elimination System

• Part 123: State Program Requirements

• Part 124: Procedures for Decision Making

• Part 125: Criteria and Standards for the National Pollutant Discharge Elimination System

Four elements or components that trigger the CWA NPDES include:

1. Discharge: A discharge is the release or action that allows any addition of any pollutant into the navigable waters of the US.

2. Pollutant: A pollutant includes any type of industrial, municipal, and agricultural waste discharged into water. Some examples include: sediments, solid waste, sewage, sewage sludge, chemical wastes, biological materials, heat, and industrial and municipal waste.

By law, a pollutant is not sewage from vessels or discharges incidental to the normal operation of an Armed Forces vessel.

3. Point Source: A point source is any discernible, confined and discrete conveyance, such as a pipe, ditch, channel, tunnel, conduit, discrete fissure, or container. It can also include vessels or other floating craft from which pollutants are or may be discharged.

4. Waters of the US: The term “water of the United States" is also defined very broadly in the CWA and after 25 years of litigation. It means navigable waters, tributaries to navigable waters, interstate waters, the oceans out to 200 miles, and intrastate waters which are used: by interstate travelers for recreation or other purposes, as a source of fish or shellfish sold in interstate commerce, or for industrial purposes by industries

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Other applicable regulations with CWA implications include:

• Oil Pollution Act (OPA): Refer to the Fuel Tank Compliance Playbook [correct name] for more information.

• Endangered Species Act: Refer to the Natural Resources Playbook for more information.

2.2 State/Local Regulations

The EPA authorizes a state for one or more of the NPDES program components based on the states’ request to administer NPDES permitting authority. Click here to view the EPA map of authorized states and learn more about the states with an approved program.

Figure 1: State NPDES Program Status Map

States with an EPA approved NPDES program may issue permits to AF installations where applicable. Click here to see state issued permits.

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Figure 2: State NPDES Program Status Map

2.3 DoD/AF

The DoD and AF set forth policies and standard requirements for complying with the EPA’s NPDES program for federal facilities. The Assistant Secretary of the AF Installations, Environment, and Energy (SAF/IEE) is accountable for all doctrine, strategy, policy, guidance, and resource advocacy related to WW and SW programs. The vision of the WQ Program is for all WW and SW systems to meet or exceed all AF mission requirements in full regulatory compliance. This playbook will be in accordance with Air Force Instructions (AFI), Air Force Manuals (AFMAN), Unified Facilities Criteria (UFC), and Air Force Guidance Memorandum (AFGM) as it relates to WW and SW systems permitting, operation and maintenance/sustainment, sampling/analysis, environmental compliance, and recordkeeping.

Among the key AF drivers for WQ are:

• AFMAN 32-1067, Water and Fuel Systems (replaced AFI 32-1067, Water and Fuels Systems and AFI 32-7044, Storage Tank Environmental Compliance)

• AFMAN 32-7003, Environmental Conservation

• AFI 32-1001, Civil Engineer Operations

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• AFI 32-7001, Environmental Management System

• UFC 3-240-03, Operations and Maintenance: O&M Wastewater Treatment (03 Oct 2019)

2.4 Permits

Both the EPA and delegated states issue permits to AF installations under the NPDES program. A NPDES permit will contain effluent limits, monitoring and reporting requirements, and other provisions to ensure that the discharge does not hurt WQ or people's health. The permit translates general requirements of the CWA into specific provisions tailored to the operations of each entity discharging pollutants. Contact the NPDES permitting authority for more information.

NPDES permits are issued by states that have obtained EPA approval to issue permits or by EPA Regions in states without such approval. The CWA limits the length of NPDES permits to five years. In addition, NPDES permits can be administratively extended if the facility reapplies more than 180 days before the permit expires, and EPA or the state regulatory agency that issued the original permit, does not renew the permit before its expiration date through no fault of the permittee. CWA permits of primary concern for the AF WQ program include WW and SW permits.

2.4.1 WW Permits

Direct Discharge: Installations that discharge pollutants directly to US Waters via a Federally-Owned Treatment Works (FOTW) require an individual NPDES permit. The permit will include the requirements discussed above but will also include specifics for the FOTW such as permitted maximum discharge, other required reports and operating parameters. The permit may address other aspects of the FOTW such as Total Maximum Daily Load (TMDL) requirements, biosolids (sludge) management and land application of effluent (if applicable).

Indirect Discharge: For installations which discharge to a Publicly Owned Treatment Works (POTW), the installation may be subject to regulation or oversight by the POTW. Types of regulation may include:

• Pretreatment (indirect discharge) permit: If the POTW has an approved pre-treatment program, they may have authority to issue permits to the AF Installation to discharge to their POTW. The permit may have specified discharge limits and reporting requirements which must be met. The POTW may have authority to issue enforcement actions (EAs) (as defined in AFI 32-7001) against the AF if the permit terms are not met.

• Agreements or Other Regulatory Instruments: May include Memorandum of Understanding (MOU), Memorandum of Agreement (MOA), or some other bi-lateral instrument to determine services and any associated conditions for discharge from the AF installation to the receiving POTW. These are typically not subject to EAs.

• Ordinance: The POTW authority may issue an ordinance governing discharge of WW which may include pollutant limits, flow limits, and general prohibitions for discharge of some hazardous pollutants. These can be subject to EA in some cases. In other cases, the POTW may assess a fee for the impact of the additional

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2.4.2 SW Permits

Installations which discharge SW to Waters of the US (WOTUS) often apply for coverage under general SW permits as applicable. General permits allow users to apply for coverage under an existing permit with standard requirements already specified.

Multiple general SW permits may be applicable for the installation. Common SW general permits include:

• Multi-sector general permit (Industrial) (MSGP): Addresses SW discharge from multiple industrial sectors as defined in the general permit. The installation is the “industry”. The MSGP requires the permittee to implement a Stormwater Pollution Prevention Plan (SWPPP).

• Municipal separate storm sewer system (MS4): Addresses discharge from municipal storm sewer systems. The installation is the “municipality”. The MS4 permit requires the permittee to implement a Stormwater Management Plan

(SWMP).

• Construction general permit (CGP): Required for construction projects which disturb more than one acre. The installation is the “construction owner”. The Construction general permit requires implementation of a SWPPP which is specific to the construction project (not to be confused with the SWPPP for the MSGP). The installation may have multiple CGPs with associated SWPPP’s active at one time.

The EPA or state regulators may also issue individual SW permits. The individual permit may be for one of the SW categories above or specific to another aspect of the installation such as de-icing operations. HAF/JAOE discourages individual SW permits due to the complexity and specificity of the requirements, unless absolutely warranted due to the nature of the installation.

Other types of permits may include but are not discussed in detail for the purpose of this CWA playbook:

• Wetlands: AF manages wetlands under the Natural Resources program.

• Dredging: Often managed under the AF Natural Resources program.

• Sludge: Typically addressed in NPDES permits for FOTW.

• Non-construction related sediment and erosion control activities.

• Dewatering: Often in conjunction with construction activities and may be covered under the CGP.

• NPDES permits for discharges of pesticides to WOTUS: Not discussed specifically in this playbook as these are infrequent in the AF; however, some of the general principles discussed in this playbook may be applicable.

• Permits for operation of WW collection or treatment systems.

• Land application: If associated with discharge from a FOTW, often included in the

NPDES permit (e.g., seasonal use of FOTW effluent to water golf course). General principles discussed in this playbook may be applicable.

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• Underground Injection Control.

2.4.3 Permit Management

WQPMs are the lead to ensure AF Installations are compliant with CWA NPDES permits.

However, the WQPM should collaborate with other installation stakeholders to ensure the success of the CWA compliance program. The Air Force Civil Engineer Center (AFCEC) Installation Support Section (ISS) is the primary reach-back for help outside the installation. The recommended tasks for permit management are described in the table below.

WQPM Permit Management Responsibilities Action Quick Reference

Step Action(s) Supporting stakeholders Review existing permit

• Conduct thorough review of permit.

• Seek clarification where needed from AFCEC ISS/MAJCOM

WQPM, regulator, or legal counsel.

• Permit decomposition:

o Conduct inventory of all required actions and deliverable products. Break-down each requirement to who prepares/contributes, signs, and due date.

Prepare/update compliance calendar to allow planning, resource allocation and time for staffing for required signatures.

o Incorporate into compliance calendar, if applicable.

o Communicate compliance calendar to contracting support for development of work statements for Fence to Fence or Base Operating Support (BOS) contracts.

o Note expiration date and plan to apply for permit coverage to prevent lapse in coverage.

• CE Operations (OPS)

• AFCEC ISS/MAJCOM

WQPM Legal counsel

• Regulator

Review draft permit

• Forward draft permit to AFCEC ISS/MAJCOM WQPM for concurrent review.

• Review draft permit, look for changes such as:

o Effluent limits.

o New pollutants for monitoring/limits.

o New reporting requirements.

o Changes in schedule, frequency, or deliverables.

o New effluent limits vs. current effluent limits. Compare these and determine if installation meets the new limits.

• Work with Base Portfolio Optimization Element (CENP)and AFCEC ISS/MAJCOM Water Quality PM (if using Environmental Quality (EQ) Scoring) to program projects necessary to meet new effluent limits.

• Request legal review for any concerns such as inability to meet requirements or inclusion of emerging contaminants in the permit.

• Consider possible avenues to engage with regulators for any concerns including state defined processes.

• Update compliance calendar for when new permit takes effect.

• AFCEC ISS/MAJCOM

WQPM Legal Counsel

• CE Portfolio Mgmt.

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WQPM Permit Management Responsibilities Action Quick Reference Step Action(s) Supporting stakeholders

Apply for permit coverage or renewal

• Prepare permit package (e.g., notice of intent (NOI)).

• Staff for signature (typically CEIE staffs for Installation

Commander signature)).

• Submit package to regulator in accordance with their timeline.

• Prepare public notice documentation when required by regulator while meeting the prescribed timeline.

• AFCEC ISS/MAJCOM

WQPM

• Contractor (if preparing package)

• Legal counsel

• OPS

• Installation

Commander

• Public Affairs

• Regulator

Table 1: WQPM Permit Management Responsibilities Action Quick Reference

2.4.3.1 Typical CWA Regulatory Hierarch

The following chart depicts a typical regulatory hierarch for CWA regulations for a sample ANG unit:

Figure 3: ANG Regulatory Hierarch

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Chapter 3 Roles and Responsibilities Roles Responsibilities

Base Civil Engineer

(BCE)

• Assigns appropriate personnel from the Installation Management Flight (CEI) and OPS Flight to provide oversight and support of all installation WW and SW programs and active utility privatization agreements in accordance with DoD, federal, state, and legally applicable host nation laws. If an ANG unit is not structured the same as active-duty units, the BCE will delegate the duties to the appropriate employee as necessary.

Tasks assigned by the BCE include:

o Ensures completion of sampling and testing procedures necessary for day-to-day operation of the WW, SW, review monitoring, sampling, and testing reports.

o Ensures implementation of necessary corrective actions for compliance with applicable permits, standards, laws, and regulations.

o Ensures system operations personnel are properly trained and have the required license or certification (e.g., applicable federal, DoD, state, local, or host nation requirements) before assuming plant operations, maintenance, or repair responsibility for WW, SW systems.

o Ensures all systems have required regulatory permits and sufficient resources to operate in compliance with applicable federal, state, and local regulations and standards.

• Develops local operating instructions (including operational monitoring for process control), sampling and testing procedures, emergency operations, maintenance, and regulatory compliance requirements.

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CE Installation Management

Flight, Environmental CEIE

Organizational responsibilities below fall to CEI. While it might not be an official title in CEI, a person within CEI typically fulfills the role of WQPM as described in this playbook and is often assigned the duties below for the purposes of CWA compliance:

• Serves as the primary Point of Contact (POC) and liaison office for compliance issues in consultation with AFCEC to EPA or other Federal, State, local, or host-nation regulators.

• Responsible for completion of compliance requirements for CWA WW and SW permits including but not limited to: sampling and analysis required for permit discharge monitoring reports, submission of discharge monitoring reports, preparation/maintenance/implementation of require permit plans such as SWPPP and SWMP, preparation of recurring reports for SW and WW permits.

• Participates in design reviews through consultation with project proponents and project managers (tenants, CEIE), on environmental requirements (including permitting, notification, and sampling).

• Provides guidance to construction PMs for construction SW permitting requirements.

• Manages EQ programs locally and in accordance with Air Force Policy Directive (AFPD)

32-70 to ensure installations comply with all applicable laws, regulations, and other requirements.

• Completes notification to regulators for new or modification WW and SW in accordance with (IAW) applicable agency rules and regulations and makes appropriate updates to NPDES required plans.

• Maintains Storage Tank Accounting and Reporting (STAR)/Water Enterprise Tracking (WET) as directed.

• Completes spill notifications to authorities according to regulatory requirements (Federal, State, local, and National Response Center (NRC)).

• Inputs regulatory inspections, AF inspections, non-compliance notifications, and spill releases into the Enforcement Actions, Spills, and Inspections Environmental Reporting (EASIER) tool.

• Coordinates programming requirements with AFCEC/CZO ISS.

• Implements processes to comply with new regulations applicable to the installation.

• Collects and reports essential data to AFCEC on Higher Headquarters (HHQ) data calls.

• Note: For the ANG, the equivalent is the Environmental Manager or State

Environmental Manager, which together form the Environmental Management Office.

Tenant Units and Unit Environmental

Coordinators

• Ensures compliance against Environmental Management System (EMS) performance metrics are conducted IAW installation environmental programs and policies, AF policies and guidance as well applicable permits and regulations per AFI 32-7001, Section 2.30.

CE Operations Flight

Per AFMAN 32-1067:

• Responsible for the operation and maintenance of WW and SW systems.

• Performs operational sampling and conduct testing procedures necessary for day-to-day operation of the WW and SW programs, reviews monitoring, sampling, and testing reports, and implements necessary corrective actions for compliance with applicable permits, standards, laws, and regulations.

Note: WW systems operated may include but are not limited to: WW treatment facilities (including industrial WW treatment, domestic WWTPs, lagoon systems, septic systems), oil water separators, lift stations, WW collection systems (sewer), and WW discharge/land application systems. SW systems may include but are not limited to SW conveyance (sewer/open channel), SW outfalls, and low impact development features/Best Management Practices (BMPs).

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Installation CE

Portfolio Management

Office

• Programs non-EQ funded requirements for WW and SW infrastructure.

CE Installation Cross Functional

Team (CFT)

• Represents management to ensure the development of compliance and pollution prevention requirements using: Environmental Action Plans, EMS framework implementation and maintenance requirements, and Environmental, Safety, and Occupational Health Council (ESOHC) direction and guidance.

Installation Judge Advocate (JA)

• Provides legal advice to the Installation Commander, Environmental Element, Environmental Management Office, and any other installation personnel on compliance with relevant environmental laws.

• Requests support from the Regional Counsel Office (RCO), HAF/JAOE-Field Support Center, Environmental Liaison Officers, Utility Law Field Support Center, and/or NGB JA (NGB/JA), as needed.

Installation Public Affairs

• Serves as liaison between the installation and external communities by assisting with procedures for communicating environmental aspects of the installation’s environmental programs, and input for media publications.

AFCEC/CZO

• Primary reach-back support for installation CWA PMs.

• Provides direct installation support through consultation on CWA compliance and by ensuring WW and SW environmental requirements are programmed IAW AF guidance using AF approved project management software for EQ, and Pollution Prevention.

• Maintains regional media experts and the Intermediate Environmental Function (IEF) through the ISS. Active-duty installations in the US & Territories are assigned an ISS as primary compliance program reach back support.

• Attends CFT meetings as appropriate. At a minimum, receive a copy of the meeting slides.

Note: Overseas or OCONUS: (AFCEC/CZOP supports Alaska, Hawaii, 611th PRSC and associated GSUs.) Air Force Mission Support Center (AFIMSC)/Detachment 2 support the Pacific (i.e., Japan and Korea). AFIMSC/Det 4 regional media experts support Europe.

AFCEC/COSC

• Serves as Subject Matter Expert (SME) for CE disciplines including the Water and WW.

• Provides expertise for engineering and operations aspects of water and WW infrastructure.

• Represents the AF in development of design standards per UFC and AF policy and guidance such as AF Instructions and AF Manuals.

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AFCEC/CZTQ

WQ SME and Water/Tank SME:

• Provides AF wide technical consultation, implementation guidance, and scientific and other support, primarily as reach-back support to the AFCEC/CZO ISSs, Major Command (MAJCOM) and AFIMSC Dets 2 & 4.

• Provides training support to installation, ISS, MAJCOM and AFIMSC CWA PMs through Air Force Institute of Technology (AFIT) course, webinars and other AF training venues.

• Provides technical consultation through eDASH Accessible Knowledge for Sustainable Resources (ANSR) and Frequently Asked Questions (FAQ) inquiries.

• Advises AF/A4C of the impacts of new WW and SW requirements on AF operations.

• Provides technical assistance to AF/A4C on implementation issues involving WW and

SW environmental policy.

• Performs special projects and studies on WW and SW compliance at the request of

AF/A4C or Water Panel.

• Identifies and monitors applicable Federal and State WW and SW regulations, compliance requirements, and enforcement policies.

• Conducts data collection, reporting and analysis for WW and SW compliance IAW AFI

32-7001, primarily through the EQ Data Call and tracking/adjudicating EAs in EASIER.

• Maintains eDASH WQ webpage with program and technical guidance.

• Co-chairs the AF Water Panel within AF CE Governance and provides technical support to the DoD CWA Services Steering Committee (CWASSC).

• Interacts with AFCEC/CZO primarily through the Water Panel representatives for each

CZO region, the MAJCOM water PMs, and the AFIMSC Det WQPM.

AFCEC/CO

• Integrates operational controls for activities that have environmental aspects to promote cost-effective planning, design, construction, operations and maintenance, repair, replacement, and disposal of the facility infrastructure and ensure that all life-cycle elements of facility programs are incorporated.

AFCEC/COAU

AFCEC WW and SW Sub-Activity Manager:

• Coordinates with the AFIMSC/IZB Utilities Activity Manager.

• Responsible for supporting and operationalizing CE Asset Management by training

Headquarters AF, MAJCOMs, and AFIMSC staffs and base personnel in Asset Management applications.

• Responsible for calibrating base efforts and standards across the AF enterprise.

• Validates project requirements, data and scope to ensure accurate built infrastructure utilities data to support resource allocation, operational decisions, and overall Asset Management implementation.

AFIMSC

• Provides a high-level oversight of capabilities that includes the prioritization of built and natural infrastructure, equipment, and human capital requirements; family and unaccompanied housing programs; installation planning; facilities operation and sustainment programs; division management overhead; programming; command architect and sustainable design; command interior designer; and CE enterprise information technology.

AFIMSC/IZ

The Installation Support Directorate of AFIMSC is comprised of seven subordinate divisions, of which Installation Engineering is relevant to AF CWA compliance management.

• Provides functional validation of planning, programming and budget execution.

• Acts as AFIMSC Utilities Activity Manager lead for oversight of AF Utilities portfolio and chairs the Holistic Utility Working Group.

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AFIMSC

Detachments (Det)

2 and 4

• Provides primary reach back support for environmental compliance including the OEBGD and the Host Nation (HN) FGS as appropriate.

Note: Pacific and Europe WW and SW compliance programs are supported by AFIMSC Det 2 (PACAF) and 4 (Europe), respectively. Reach back support includes consultation on environmental compliance, policy and guidance matters requiring additional expertise as well as support for EQ funds planning, programming, budgeting and execution (PPBE).

SAF/IEE

• Responsible for all matters pertaining to AF built and natural infrastructure, environment, safety, occupational health, radiation safety and radioactive materials management interests.

• Sustains the AF as a ready and robust force and preserves America's investment in the AF by integrating the best in environment, safety, occupational health, and installation practices into all AF activities.

• Provides strategic direction, policy and oversight in:

o Energy: Installation energy, innovation, policy development and water resource management.

o Environment: Environmental compliance, restoration and natural/cultural resource management.

o Infrastructure: Real Property (RP), Military Construction (MILCON), facilities

(includes government (GOV)-owned housing/general officer quarter management) and utilities.

o Occupational Health.

• Safety (excludes flight and weapons).

SAF/GC

• Serves as the principal legal adviser to HAF (including SAF/IE and SAF/IEE) on environmental compliance policy, including resolution of discrepancies with DoD policy and AF implementation.

SAF/IE • Accountable for all doctrine, strategy, policy, guidance, and resource advocacy related to WW and SW programs.

HAF/A4C

• Responsible for AF policy, strategy, doctrine, oversight, directive guidance, and resource advocacy related to the AF WW and SW programs. Be accountable for non-directive guidance related to the AF WW and SW program.

HAF/Surgeon General (SG)

• Incorporates environmental requirements and sustainment principles into occupational and environmental health strategic and mission planning, policies, procedures, and training.

HAF/JAOE-FSC

• Provides legal advice to the AFIMSC, AFCEC and Installations on compliance with relevant environmental laws.

• Requests support from the RCO, Environmental Liaison Officers, Utility Law Field Support Center, and/or NGB/JA, as needed.

MAJCOM

• Ensures implementation of the WW and SW, policies and programs through their installations.

Note: Implementation and oversight may be accomplished directly by MAJCOM personnel, through associated AFIMSC Detachment, by delegation to the installation, or other means as determined by each MAJCOM.

Table 2: Roles and Responsibilities https://www.safie.hq.af.mil/InstallationEnergy/ https://www.safie.hq.af.mil/Environment https://www.safie.hq.af.mil/Safety/

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Chapter 4 WQM Programming and Funding WQM requires funding for multiple activities including writing and implementing plans, sampling, monitoring, paying for permits and fees, producing studies, testing, reports, and recordkeeping. EQ funds support the activities required to achieve compliance with laws, regulations, permits, and instructions. Infrastructure condition and regulatory changes can affect compliance. It’s important to know when, how, and why EQ funds are used to ensure compliance and when non-EQ funding types such as Facilities, Sustainment, Restoration, and Modernization (FSRM) or base maintenance funding may be required to maintain or achieve compliance.

4.1 AF Funding and Execution

AF EQ funding and execution follow strict business rules. Funding and execution are two steps in the PPBE process. For active-duty AF, it is the requirement owner’s (installation environmental) responsibility to identify program requirements that require funding during the planning phase to AFCEC/CZO, AFIMSC/DET 2-PACAF and AFIMSC/DET 4-USAFE. AFCEC/CZO ISSs Continental United States (CONUS), Air Force Reserve Command (AFRC) installations, and Detachments (PACAF and USAFE) (OCONUS) accomplish programming through the RAM to capture all installation EQ requirements in the programming phase. Please see section 4.1.3 for the ANG.

Programming is necessary to accomplish the planned allocation of funds over a multi-year period. Budgeting occurs in the fiscal year preceding the fiscal year the requirement is needed.

Finally, execution occurs in the fiscal year the requirement needs to be funded.

AFCEC Business Rules for PPBE include:

• CZ-BR12 EQ Programming Guide Review (Planning)

• CZ-BR13 EQ Requirements Validation Process (Programming)

• CZ-BR14 Integrated Priority List (IPL) ETO Build (Budgeting)

• CZ-BR16 Execution Plan Management (Execution)

• CZ-BR18 Funding Line Adjustment Request (Execution)

• CZ-BR19 Operating Budget Authority Document Request Process (Execution)

• CZ-BR20 Preparing Authority to Release Packages (Execution)

• CZ-BR21 Requirement Approval Document Process (Execution)

• CZ-BR22 Emergent Requirement Request (Execution)

• CZ-BR23 Payment of Permits and Fees through Contractual Action (Execution)

• CZ-BR29 Acquisition of F2F Contracts (Execution)

Click here to view Business Rules.

4.1.1 Planning and Programming for EQ

The EQ Programming Guide is updated as needed through a business review process. The EQ Programming Guide consists of:

• EQ Program Matrix: Identifies what can/cannot be funded with EQ dollars, and under which EQ pillar it is categorized.

• EQ Standard Titles: Provides consistency for recurring or non-recurring projects across the enterprise. All requirements should be able to fit under these existing titles. The Standard Titles prescribe most of the codes necessary for programming in Automated Civil Engineer System - Project Management (ACES-PM), including

19 | P a g e assigned scores.

• EQ Prioritization Scoring Model: A five-factor scoring model used for requirements without a standard score in the Standard Title guide. A project’s score determines its rank in the funding sequence and is aligned to the Air Force Common Output Level Standards (AFCOLS). Higher scores are funded before lower scores.

Click here for the current EQ Programming Guidance.

4.1.1.1 Resource Allocation Model (RAM)

The RAM is an EXCEL based multivariate, steady state funding estimate across the 5-year Future Year Defense Budget intended to meet current legal and policy-driven requirements, and assume full and sustained compliance, and managed by AFCEC/CZCP (Program Management Office).

The RAM generates a portfolio of environmental requirements for Active Duty and Reserve Installation’s EQ programs using the following unit cost factors:

• Cost adjustment factors based on the installation’s:

o Tier o Size o Location o Complexity factor

• Data sources include:

o Past funding levels o Environmental Management Report (EMR) data o STAR/WET o Plans and Permit Tracker (in eDASH) o Air Program Information Management System (APIMS) data

Figure 4: IPL Validator screen

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AFCEC/CZO PPBE PM reviews and validates the RAM output (i.e., requirement and validates the amount for the proposed project based on standard titles.

This validated list is used to create the IPL ranking projects eligible for funding in the year of execution. The EQ process includes the execution plan (ExPlan) which uses the IPL to identify which requirements will be funded in the funding year (FY). The ExPlan, establishes the planned execution timing and servicing agent. However, it does not contain all the components required for proper execution. The specifics about how the money is to be spent (execution agent) and what the funds specifically buy are tracked by the AFCEC/CZO ISS in the ACES-PM, until the new CZO Planning and Management tool is developed.

ACES-PM, is the legacy database for active and reserve AF installation EQ requirements.

The project description in ACES-PM should include what the funding will buy (i.e., deliverables), how much, or where the project occurs. The RAM (See 4.1.1.1) does not predict what the money is specifically used for, or what execution agent receives the funds. These data inputs into ACES-PM are used to supplement, validate, and correct RAM outputs. Since the RAM rolls up or splits project line items, it is very important to include a specific description of the project in ACES-PM to assist in tracking funding, and developing appropriate Statements of Work (SOW) or Performance Work Statements (PWS) that produce the deliverables required to maintain compliance.

AFCEC/CZTQ conducts level 2 IPL validation of projects. The CZTQ WQ Team reviews EQ CWA compliance projects for President’s Budget 28 (PB28) Codes for SW (SWAT), OPA (SPIL) and WW (WWAT). The basis of the Level 2 validation is the IPL provided by AFCEC/CZCP per their validation process and does not include review of ACES-PM data. CZTQ will reach back to the AFCEC/CZO ISS for clarification and resolution of questions for specific projects.

4.1.2 Planning and Programming for Built Infrastructure (Non-EQ Appropriated Funds)

Per AFI 32-7001 and the EQ Programming Guide, many infrastructure repairs, updates or upgrades are not eligible for EQ funding, but are a cost of operating the installation infrastructure. While AF installation WW and SW systems are infrastructure dependent, CWA non-compliance can be the result of infrastructure condition. EQ PMs may need to collaborate with installation and AFCEC planning, programming, budgeting, and execution stakeholders for FSRM funding and projects.

Types of non-EQ funding for infrastructure includes:

• Installation Maintenance (521 Funding) is for recurring day-to-day or scheduled work to preserve RP. Examples: Inflow and infiltration (I&I) study or clearing clogged sewer lines.

• FSRM (522 and 524 funds) is for operations and maintenance (O&M), repair, and upgrades of RP. Example: Slip-lining of deteriorated sewer mains.

• MILCON is for building, developing or extending RP. Example: Build new WW treatment plant.

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Typically, at end of fiscal year, projects that could not be executed are cancelled from the queue and other projects are elevated to use the funds. FSRM projects that are ready to advertise or award may be considered for funding when their installation priority score had been too low to warrant funding in the regular funding process/timelines. FSRM funding is managed by the Air Force Comprehensive Asset Management Planning Process

(AFCAMP).

4.1.2.1 Air Force Comprehensive Asset Management Planning Process (AFCAMP)

AFCAMP allows the AF to plan and prioritize FSRM projects on a 5-year outlook, targeting installation critical mission needs and backlog of increasing sustainment requirements.

The AFCAMP is a centralized funding program, managed by AFCEC/CPDI. It utilizes asset management principles to objectively score and prioritize projects across the AF RP portfolio. For an overview of the AFCAMP scoring model, please refer to the AFCAMP playbook, Chapter 2. Project cost must meet a cost threshold (‘floor’) as specified in AFI 32-1020, para.2.12 to be considered for the centralized funding program. FSRM projects below the centralized program threshold are prioritized and executed by the installation using their decentralized funds (dFSRM) allocation via the ExPlan. Projects are prioritized by the installation Facilities Board.

Note: Please refer to the current version of AFCAMP in the CE Portal or on the CE Playbooks website.

4.1.2.1.1 AFCAMP Utilities Guidance (SRM)

Most WW and SW assets are included in the Utilities AMP. This includes but is not limited to:

• Sanitary sewer

• Lift stations

• Oil water separators

• WW treatment

• SW conveyance

• Low impact development (LID) features

Projects are prioritized based on scoring using the utilities dependency index (UDI) and condition index (CI).

For complete details on the scoring utilities requirements, please refer to the AFCAMP playbook, Chapter 5.

Note: Please refer to the current version of AFCAMP in the CE Portal or on the CE Playbooks website.

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4.1.2.1.2 AFCAMP Facilities Guidance (SRM)

Additional facilities not covered in the Utilities Asset Management Planning (AMP) might be covered in the Facilities AMP. For complete details on the scoring utilities requirements, please refer to the AFCAMP Playbook, Chapter 3.

Note: Please refer to the current version of AFCAMP in the CE Portal or on the CE Playbooks website.

4.1.2.1.3 EQ Natural Infrastructure Guidance (SRM with EQ driver)

The AFCAMP condition-based scoring models might not capture the potential impact of infrastructure on non-compliance. To address this gap, the AFCAMP requires the EQ Scoring model to be used to equitably score FSRM projects that have a direct effect on environmental compliance. The five factor EQ scoring model is used for scoring these projects according to their regulatory drivers and impacts. Installations will program these projects and the AFCEC/CZ ISS and/or AFIMSC Dets 2 & 4 will perform the scoring.

For complete details on the scoring utilities and other requirements using the EQ Scoring Model, please refer to the AFCAMP Playbook, Chapter 6.

Note: Please refer to the current version of AFCAMP in the CE Portal or on the CE Playbooks website.

4.1.3 EPET (Environmental Programming Execution Tool)

ANG uses EPET for programming needs and requirements for the PPBE process. It is designed to accurately define project costs, manpower costs, and programmatic funding levels for the three environmental pillars: Compliance (55256), Conservation (55853) and Pollution Prevention (55854). EPET allows specific ANG user groups to complete appropriate steps within the tool. Permissions are assigned based on EPET User Roles, as defined in the various EPET user guides. Click here to access the ANG EPET.

4.2 Non-AF Funding and Execution Appropriation of Funds

This section provides information on the various non-AF funding sources available for planning, programming cost-effective appropriated and non-appropriated funds for maintenance, repair and constructions of RP facilities collectively referred to as “built infrastructure projects” in compliance with law, DoD and AF policies. Organizations at all levels are responsible for employing a sustainable asset management approach while performing the day-to-day activities to maintain the AF mission. WQPM collaboration with non-AF stakeholders may be necessary to secure and/or execute non-AF funds to maintain CWA compliance.

4.2.1 Planning and Programming for Defense Logistics Agency (DLA) Capitalized Funding (Environmental)

DLA Energy is responsible for purchasing bulk fuel products and delivering them to the U.S. Armed Forces and other government agencies. DLA Energy manages a number of

23 | P a g e petroleum products, including jet fuels, aviation gasoline, heating oils, power generation, naval propulsion fuels, lubricants, natural gas, and coal. Over time, DLA Energy’s funding has expanded for maintenance and repair, minor construction, and environmental projects. DLA Energy’s increased role in funding is partly the result of centralizing fuel inventory management and facility upkeep, according to the Integrated Material Management (IMM) program. IMM is designed to centralize fuel inventory management and facility upkeep, with DLA Energy designated the executive agent for fuel in the DLA as part of the centralization.

For funding requests, use the DLA Enterprise External Business Portal (EEBP) and be sure to include supporting documentation in your request, such as statements of work, independent government cost estimates (IGCE), contract award documents, invoices, and other supportive documents. Funding requests for AF installations must go through the Air Force Petroleum Agency (AFPET) as the service focal point with DLA.

For more detail, please refer to the DLA Environmental Guide for Fuel Facilities (Mar 19), Chapter 14 for funding.

WQPMs can reach out to installation, MAJCOM or AFIMSC personnel with DLA EEBP accounts to program deficiencies requiring DLA funds. In addition, reviews should be conducted for any new construction including SW permitting, secondary containment requirements, oil/water separator installation and other WW/SW infrastructure.

4.2.2 Planning and Programming for Built Infrastructure (Non-Appropriated Funds (NAF) Non-EQ)

NAF projects are those funded with monies not appropriated by Congress, such as private donations, Army and AF Exchange Services (AAFES) dividends, Defense Commissary Agency (DeCA) surcharges, and revenue generated from AF Services Directorate morale, welfare and recreation (MWR) or lodging activities. Construction on AF installations funded through foreign military sales is a distinct project category subject to special planning and programming requirements discussed in this Instruction. Planning and programming of military family housing is addressed in AFI 32-6002, Family Housing Planning, Programming, Design and Construction.