A. Update on Infiltration & Inflow (I & I)0
CITY OF
CHANHASSEN
7700 Market Boulevard
PO Box 147
Chanhassen, MN 55317
Administration
Phone: 952.227.1100
Fax: 952.227.1110
Building Inspections
Phone: 952.227.1180
Fax: 952.227.1190
Engineering
Phone: 952.227.1160
Fax: 952.227.1170
Finance
Phone: 952.227.1140
Fax: 952.227.1110
Park & Recreation
Phone: 952.227.1120
Fax: 952.227.1110
MEMORANDUM
TO: Todd Gerhardt, City Manager
FROM: Paul Oehme, City Engineer /Dir. of Public Works
DATE: January 23, 2012a '
SUBJ: Update on Infiltration/Inflow (I &I) City Project #PW254
BACKGROUND
In 2007 the Metropolitan Council Environmental Services (MCES) implemented
a surcharge program that strongly encouraged communities that have documented
high I &I problems to make improvements to the system or face financial
penalties. Forty -six (46) metro communities took park in the program. I &I is a
problem because it takes up capacity in the larger regional sewer pipes and
treatment plants owned by MCES. During major rain events, this additional surge
of water can consume the capacity of sewer pipes, resulting in home backups and
overflows into creeks, wetlands and rivers. MCES estimates it would cost the
region a minimum of $900 million dollars to build infrastructure large enough to
convey the excess flows to the wastewater treatment plants.
Senior Center
Phone: 952.227.1125
Fax: 952.227.1110 Attachment
Web Site
www.ci.chanhassen.mn.us
G .\ENG\PUBLICTW254 1 &1 \bkgd council ws l &l 012312.doc
Chanhassen is a Community for Life - Providing for Today and Planning for Tomorrow
The surcharge program is now complete and the Metropolitan Council will
Recreation Center
implement a Demand Charge program starting in 2013. A representative from
2310 Coulter Boulevard
Metropolitan Council Environmental Services (MCES) is planning to give a brief
Phone: 952.227.1400
update on the new I &I Demand Charge Program. The program again is designed
Fax: 952.227.1404
to encourage municipalities to identify and reduce the amount of inflow and
Planning &
infiltration getting into the local system. A copy of the MCES demand charge
Natural Resources
program is attached to this background.
Phone: 952.227.1130
Fax: 952.227.1110
Staff is also planning to give a brief update on what the city has completed to
reduce I &I in the public system. Staff will also present information on what other
Public Works
communities have done, or are planning to do, to reduce I &I from their systems.
7901 Park Place
Phone: 952.227.1300
Staff will also discuss what options the city may want to implement in the future
Fax: 952.227.1310
to reduce the amount of I &I getting into the sewer system.
Senior Center
Phone: 952.227.1125
Fax: 952.227.1110 Attachment
Web Site
www.ci.chanhassen.mn.us
G .\ENG\PUBLICTW254 1 &1 \bkgd council ws l &l 012312.doc
Chanhassen is a Community for Life - Providing for Today and Planning for Tomorrow
It Metropolitan Council
Environmental Services
Demand Charge Task Force
Final Report
September 2010
Metropolitan Council Environmental Services
390 Robert Street, North • St. Paul, MN 55101 • (651) 602 -1005
Metropolitan Council Members
Chair
Peter Bell
Council Members
Roger Scherer
District 1
Natalie Steffen
District 9
Tony Pistilli
District 2
Kris Sanda
District 10
Robert McFarlin
District 3
Georgeanne Hilker
District 11
Craig Peterson
District 4
Sherry Broecker
District 12
Polly Bowles
District 5
Richard Aguilar
District 13
Peggy Leppik
District 6
Kirstin Sersland Beach
District 14
Annette Meeks
District 7
Daniel Wolter
District 15
Lynette Wittsack
District 8
Wendy Wulff
District 16
Council Regional Administrator
Thomas Weaver
General Manager, Environmental Services
William Moore
The mission of the Metropolitan Council is to develop, in cooperation with local
communities, a comprehensive regional planning framework, focusing on wastewater,
transportation, parks and aviation systems, that guide the efficient growth of the
metropolitan ara. The Council operates wastewater and transit services and administers
housing and other grant programs.
General Phone
Regional Data Center
TTY
Metro Info Line
E -mail
Council Web Site
651- 602 -1000
651 -1140
651- 291 -0904
651- 602 -1888
data.center cgmetc.state.mn.us
www.metrocouncil.ore
Publication #32 -10 -026
Publication Date
Table of Contents
Section
Executive Summary ...................................... ...............................
Introduction.............................................. ............................... .
Council's Existing I/I Policy and Program ............ ...............................
Demand Charge Task Force ............................ ...............................
System Capacity Analysis ............................... ...............................
I/1 Program Issues and Recommendations ............ ...............................
2030 Policy Plan Amendment .......................... ...............................
2011 and 2012 Surcharges .............................. ...............................
Summary Recommendations ........................... ...............................
Page
2
2
in
Appendices
Appendix A MCES Interceptor System Capacity Analysis
Appendix B Ongoing 1/I Reduction Program
Appendix C Recommended Water Resources Policy Plan Amendment
Executive Summary
The Metropolitan Council's 2030 Water
Resources Management Policy Plan calls
for the Council to implement a wastewater
demand charge in 2013 for communities that
have excessive inflow /infiltration. The intent
of the demand charge would be to defray the
cost of providing attenuation (storage) of
excessive I/I to avoid overloading
downstream facilities. In August 2009, the
Council established a Demand Charge Task
Force to develop specific recommendations
for the demand charge. The Task Force met
from September 2009 to August 2010,
generally on a bi- monthly basis.
Since the beginning of the Council's
infiltration/inflow program in January 2007,
46 communities have participated in the
program. A total of $46 million of local
infiltration/inflow mitigation work has been
documented through 2009. The recent
drought in the region has made assessing the
overall effectiveness of the program
difficult. However, the decline in influent
flow at the region's wastewater treatment
plants measured since 2002 is at least partly
the result of this investment in
infiltration/inflow mitigation.
With a desire to continue the infiltration /inflow program's progress and with the understanding
that investing in local mitigation rather than storage is the region's preferred approach to
reducing infiltration/inflow, the Demand Charge Task Force recommends:
• The Council implement an ongoing infiltration/inflow reduction program similar to but
improved from the existing program rather than a demand charge in 2013.
• In cases where a community is not meeting its infiltration/inflow goal(s) or the
community has not been implementing an effective I/I reduction program in the
determination of the Council or if regulations and/or regulatory permits require the
Council to ensure regulatory compliance, the Council may institute a wastewater rate
demand charge.
• The Council amend the 2030 Water Resources Management Policy Plan to reflect these
recommendations.
1
Introduction
The Metropolitan Council's inflow /infiltration (I/1) policy contained in the 2030 Water
Resources Management Policy Plan (2030 Policy Plan), adopted in 2005, established that the
Council will not provide additional capacity to serve excessive I/1 entering the regional sanitary
sewer system. Further, starting in 2013 the Council is to implement a wastewater demand charge
for communities that continue to require service for excessive I /I. The demand charge would
defray the cost of providing attenuation (storage) of excessive I/I to avoid overloading
downstream facilities. In August 2009 the Council appointed a Demand Charge Task Force to
develop recommendations for the demand charge including its specific features and the 2013
implementation date.
While the local mitigation of I/I has been successful in eliminating some of the excessive I /I,
some remains in the system and it is expected to be a long -term challenge to achieving the
Council's guidelines for allowable I/I. Without additional mitigation, the Council and its
ratepayers will face substantial capital expenses for infrastructure to convey and treat the
excessive I/I and risk of overflows will continue.
Council's Existing I/I Policy and Program
Concern about the impacts of I/I on the regional sanitary sewer system led the Council to appoint
an I/I task force that met in 2003/2004 to develop recommendations for an I/I reduction program.
The I/I Task Force estimated that the cost to store, convey, and treat excess I/I was in the $900
million range while the cost for source removal was in the $150 million range. Risk of system
backups and overflows would continue. The I/I Task Force recommended that the Council
initiate an I/1 program focused on mitigating excess I/1 versus increasing system capacity. The
Council's existing I/I reduction program, based on the Task Force's recommendation and
adopted in the Policy Plan, is a surcharge approach to source removal.
The Policy Plan states that the Council will
not provide additional sanitary sewer system
capacity to serve excessive I/1. Communities
with excessive I/1 would be required to
eliminate the excess I/I within a reasonable
time period. The premise of the policy is
that short -term peak wet weather flow uses
the system's reserve capacity needed for
growth. The program's implementation
strategies are shown on the right.
• I/I izoals for all communities based on the
designed peak hour flow capacity of the
interceptor(s) serving the community and
using the current peak hourly flow factor
design standards for interceptors
• Communi I/I mitigation programs
developed and implemented from 2007 to
2011
• 1/1 surcharge program initiated by Council in
conjunction with communities
• In 2013, for communities not meeting
goals (a) limit future increases in wastewater
service until goal(s) are met and (b) institute
a wastewater rate demand charge.
4
The I/I surcharge program began January 1, 2007. To date, 46 communities have participated in
the surcharge program. A total of $46 million of local I/I mitigation work has been documented
through 2009 as part of the program. The region's recent drought has made assessing the overall
effectiveness of the program difficult. However, the decline in influent flow at the region's
wastewater treatment plants measured since 2002 is at least partly the result of this investment in
infiltration/inflow mitigation.
Demand Charge Task Force
On August 13, 2009 the Council appointed a Demand Charge Task Force to develop
recommendations for the demand charge including its specific features and the 2013
implementation date. The Task Force generally met bi- monthly from September 2009 to August
2010. The Task Force reviewed information presented by the Metropolitan Council
Environmental Services (MCES) staff, which also provided facilitation and administrative
support. The recommendations and conclusions were arrived at by consensus of the Task Force
members.
The Task Force established goals for the
next phase of the Council's I/1 program. The
Task Force recognized that several goals
conflict and that satisfying all goals was
likely not possible. Given that I/I mitigation
is a complex issue with numerous aspects
that communities and the Council cannot
control or foresee the Task Force sought a
balanced approach that would foster
continued progress as it developed
recommendations for the next phase of the
program.
• Effective in achieving I/I policy goals
• Equitable among served communities
• Defensible using measured flow data
• Fiscally responsible consistent with cost of
service and other policies; accounts for
regional economics
• Reasonable, uniform rules and procedures
• Flexible to deal with uncertainties and
change
• Understandable
System Capacity Analysis
I/1 mitigation is needed in order to recover or maintain regional sanitary sewer system capacity to
provide for growth and to help minimize the potential for wastewater backups in basements,
spills from manholes, or overflows from regulators. The 2013 demand charge implementation
date was established based on a 2004 analysis of the sanitary sewer system performed for the
previous 1/I task force. A new capacity analysis was performed using more recent data and
projections. See Appendix A for full details of the capacity analysis. Conclusions from the
analysis are summarized in the box on the following page. The current system analysis indicates
that capacity is adequate for several years longer than the previous analysis indicated. With the
slowdown in regional growth, the current policy's 2013 demand charge implementation date
appears less urgent.
Interceptor Capacity
• A small number of growth- related interceptor capacity improvements are
needed and are underway.
• Capacity is adequate through 2020 for the remainder of the interceptor
system.
• If not addressed, excessive I/I will continue to cause interceptor system
capacity constraints and risks.
Treatment Capacity
• Excessive I/I uses reserve capacity at the Blue Lake, Metropolitan, and St.
Croix Valley Wastewater Treatment Plants (WWTPs).
• During extremely excessive I/I events, flow has been diverted around the
biological treatment system to protect the process. Though effluent limits
have been met under these conditions, this flow blending poses future
regulatory risk.
• No WWTP capacity expansions are planned in the immediate future.
I/I Program Issues and Recommendations
During the course of Task Force meetings, members' comments ranged from the I/I program's
nature and goals to specific aspects of program implementation. The following paragraphs
summarize members' comments about the overall program. Table 1 summarizes a number of
specific implementation issues and recommendations for the next phase of the I/I reduction
program.
Members' comments about the overall program fell into the following categories:
• Program's goal and approach
• Program procedures
• Appeals
Task force members agree with the Council's policy and the I/I program's premise of eliminating
excess I/I sources rather than increasing regional sanitary sewer system capacity to handle excess
I /I. Members commented that drought, water conservation and I/I mitigation itself can unfairly
make a community's goals more difficult to reach under the current program's goal- setting
method. Members also discussed how the program would ultimately measure success. Sources of
excess I/I may become more difficult to locate and mitigate, I/I mitigation is not well - defined,
and the vagaries of weather, such as drought, can complicate measuring the program's
effectiveness. Currently, a community satisfies program requirements by expending funds on
local mitigation equal to its surcharge. While this may satisfy program requirements, there is no
guarantee it achieves the program goal of reducing excess I/I and avoiding future exceedances.
4
Issue
Progran
Goal
Demand
charge
Table 1
UI Promm Issues and Recommendations
The goal of the I/1 program is to minimize the risk of system
backups and overflows and to reserve system capacity for
growth.
A demand charge approach to I/1 mitigation, in which a
community with excessive inflow /infiltration would be
assessed a charge to defray the cost of the Council's providing
attenuation (storage) of excessive I /I, diverts funds from local
mitigation and allocates them to building storage. This
approach does not address I/I at the source and it has not been
shown elsewhere to effectively avoid backups, spills, and
overflows. It is not the preferred approach to reducing
infiltration/inflow.
Allowable I/I The current program establishes I/I goals for each metershed by
setting an allowable peak hour flow, based on average flow
multiplied by the applicable MCES standard peaking factor.
The standard peaking factors account for diurnal fldw variation
and an allowable level of I/I. Although based on industry
standards, the factors do not directly address the following:
• Specific amount of allowable I/I incorporated in the factor.
• Type of sewer system (sanitary versus originally
combined).
• Age of sewer system (design codes that allowed sump
pump and foundation drain connections; materials of
construction).
• Antecedent precipitation and subsequent groundwater
level.
• Rainfall intensity, duration, volume, and frequency are not
considered, due to regulatory compliance issues.
Consequently, two problems arise:
Recommendations
Continue the I/I program with these two goals, with added
recognition of case -by -case evaluations of risk based on
system capacity analyses and applicable regulatory
Implement an ongoing I/I reduction program with
characteristics similar to the existing program (i.e.,
continuing to "rebate" mitigation costs), rather than
imposing a general demand charge, beginning in 2013.
In any specific case in which a community is not meeting
its infiltration/inflow goal(s), and the community has not
been implementing an effective I/I reduction program in
the determination of the Council or if regulations and/or
regulatory permits require the Council to ensure regulatory
compliance, the Council may institute a wastewater rate
demand charge.
Continue to determine exceedances based on peak hour
flow using its standard peaking factors to determine peak
hour flow limits.
Gather, analyze, and share the program's existing
information and data to better quantify mitigation
effectiveness
Evaluate and develop, as appropriate, an improved method
for determining allowable I/I that better accounts for items
such as:
• Age and type of sewer system
• Risk of overflow and backups
• Historical flow variability and components (base
sanitary flow, groundwater infiltration, rainfall -
dependent I /I)
• System hydraulics, such as available flow
attenuation, travel time, and reserve capacity
Use the findings of the above to update the program for
Goal and
Table 1
I/I Program Issues and Recommendations
Issue
Description
Recommendations
(1) It is difficult to assess the effectiveness of I/1 mitigation
the 2040 Policy Plan.
work.
(2) Communities may cycle on and off the I/I exceedance
list, even after expending significant funds on I/1
mitigation.
Program Procedures
Base flow
The current program uses a 3 -year rolling average daily flow as
Use a longer time period (e.g., 10 years) for the base flow to
the base flow for determining allowable peak flows. Drought
normalize the effects of precipitation (drought and wet
can lower a community's 3 -year rolling average which, in turn,
periods).
lowers the community's allowable peak flow.
Water
A community's water conservation and I/I mitigation can lower
Provide a general adjustment of 1% per year for water
conservation,
its 3 -year rolling average daily flow. This, in turn, lowers the
conservation and I/I mitigation so as not to penalize
and 1/1
community's allowable peak flow, effectively penalizing a
communities for their work in these areas. Also, allow for a
mitigation
community for water conservation and 1/I mitigation.
greater adjustment if a community can substantiate it with
actual data.
Growth
If a longer time period is used for the base flow in the
Adjust the rolling average daily flow for the wastewater
calculation of the allowable peak flows, communities that have
generated by the growth in the community from the middle of
had growth over the longer period will be penalized.
the rolling average period to the goal year, thus increasing the
base flow to account for the growth that has occurred.
I/I into
A community should not be accountable for I/I that enters the
Where applicable, adjust peak measured flows in a metershed
Council
Council's interceptors that pass through the community.
by subtracting out that portion of the peak estimated to be due
interceptors
to I/I into Council interceptors in the metershed.
Metersheds
The lack of multiple meters in some larger communities makes
• Continue to determine exceedances on a metershed basis.
it difficult to determine where I/I sources are and the
. Upon request and where substantial I/I exists, collaborate
effectiveness of specific I/I mitigation work. On the other hand,
with communities in metering projects to assess I/I
multiple meters can cause a community to have an exceedance
sources.
when, if the flow was consolidated in one meter, no exceedance
may have occurred.
Mitigation
The current program has a 5 -year mitigation period (this is the
Implement a 4 -year mitigation period beginning with the
period
length of the surcharge phase of the program).
exceedance's billing year (e.g., the mitigation period for a June
2013 exceedance would begin in January 2014; the mitigation
period for a July 2013 exceedance would begin in January
2015. Redu ing the mitigation period from 5 to 4 years
Table 1
I/I Program Issues and Recommendations
Issue
Description
Recommendations
reflects the fact that communities generally have had time to
determine I/I sources and priority areas. In addition, allow a 1-
year look -back period from the time of the exceedance; that is,
I/I mitigation work performed in the calendar year prior to the
exceedance would be eligible (e.g., mitigation expenses
incurred in 2013 could help meet the requirements for the June
2013 exceedance; mitigation expenses incurred in 2014 could
help meet the requirements of the July 2013 exceedance). The
1 -year look -back period is intended to provide incentive for
communities to perform ongoing and proactive I/I mitigation.
Appeals
Locating I/I
What should be done if significant funds are expended in trying
Allow a community to appeal to extend or defer the I/I
sources
to locate specific I/I sources without success?
mitigation period for a defined period of time until:
• I/1 sources are found (i.e., rain events occur that point to
the sources)
• The community can develop a reasonable mitigation plan
in the absence of specific location information.
The appeal must be based on the findings of the community's
I/I source en ineering investigation.
I/I mitigation
The current program assumes I/I mitigation costs $350,000
• Continue the current program's procedure of allowing a
cost
(escalated each year for inflation) per million gallon per day of
community to appeal and reduce the estimated mitigation
assumption
I/I reduced. While program cost documentation submitted by
cost if the actual cost of mitigating the sources can be
communities generally supports this value, there may be cases
shown to be less than the estimated mitigation cost.
where a cost - benefit analysis is warranted.
. Allow a community to appeal the estimated mitigation
cost if it is more than estimates of the lifecycle cost of
storage, conveyance, and treatment of excess I /I. The
appeal process would initiate a joint cost analysis between
the community and the Council. The cost analysis would
be based on appropriate design criteria such as a design
storm frequency. If the cost analysis indicates that the
estimated cost of mitigation is more than the estimated
cost of regional storage, conveyance and treatment, the
Council may allow the community to waive its option to
Table 1
VI Program Issues and Recommendations
Issue
Description
Recommendations
perform the estimated mitigation work and the Council
would impose a financial charge on the community to
defray the cost of regional storage, conveyance and
treatment.
Super Storm
Should there be some limit on the size of storm event for which
Although the Council's permits do not identify a storm
or other
exceedances will be measured?
frequency for which overflows or spills would be allowed,
extraordinary
include an appeal process that may allow relief if a community
circumstances
is otherwise making progress toward I/I mitigation and a peak
flow event was caused by unusual conditions or extraordinary
circumstances.
Task force members commented on various technical aspects of the current program. They urged
the Council to use the information and data gathered in the current program phase to further
develop the program. For example, they questioned whether MCES' standard peaking factors are
appropriate in all cases and whether the mitigation costs used to establish surcharge values are
valid for all communities. They recommended that these and other technical aspects be reviewed.
Finally, task force members discussed program procedures. While members understood the need
for the program to have uniform rules and procedures, they encouraged the Council not to take a
"one- size - fits -all" approach in a program of this magnitude because such an approach could lead
to inequities among communities. They suggested the Council consider ways to incorporate into
thr.program processes such as case -by -case analyses, cost effectiveness reviews, and an appeal
process for unique situations.
Though the Task Force and MCES staff could not address all of the issues raised, the Task Force
members' comments provide areas to consider in the next 1 to 5 years as the Council further
defines the I/I program and develops the 2040 Policy Plan.
After discussing a number of options for the next phase of the I/I program, the Task Force came
to the consensus recommendation that the Council implement an ongoing, second phase (herein
called "Ongoing Program ") of the inflow and infiltration (1 /I) reduction program beginning in
2013 rather than implement a demand charge at this time. The Task Force recognizes that the
Council may need to institute a wastewater rate demand charge for those communities that have
not met their I/I goal(s), if the community has not been implementing an effective I/I reduction
program in the determination of the Council, or if regulations and /or regulatory permits require
MCES action to ensure regulatory compliance.
A complete description of the recommended Ongoing Program is contained in Appendix B. The
Ongoing Program requirements apply to all communities whether or not they previously were
required to implement I/I reduction work. The Ongoing Program will be further defined in a
Procedure Manual.
2030 Policy Plan Amendment
The Task Force recommends that the Council amend its 2030 Policy Plan as needed to reflect the
changes to the I/1 program. The text of the Policy Plan amendment is in Appendix C. A public
hearing on the proposed amendment was held on July 13, 2010. Written comments on the
amendment are contained in Appendix C also. This report addresses a number of the issues
raised during the public hearing process, such as special regulatory circumstances, metering,
MCES standard flow peaking factors, I/I mitigation costs, and time to complete I/I mitigation
work. These issues will be addressed further in the Ongoing Program Procedures Manual and in
the next Policy Plan update.
The recommended Ongoing Program is a result of the Council's I/I reduction initiative that
began in 2003 with the initial 1/I Task Force and was defined in the 2030 Policy Plan. Figure 1
shows the Ongoing Program schedule in relation to the Council's overall I/I Program and Policy
Plan development, implementation, and evaluation. The Task Force recommends that a
Figure 1
UI Pro ram Schedule
Year
`03-
`05
`06
`07
`08
`09
`10
`11
`12
`13
`14
`15
Beyond
`04
`15
UI Policy
I/1
2030
Demand
Demand
2040
Task
Policy
Charge Task
Charge
Policy
Force
Plan
Force 1
Task
Plan
Force 2
M Program
a. Development
Surcharge
Ongoing Program
Program
Development
Develop-
ment
b. Implementation
Surcharge Program (recommended
Ongoing 1/I Reduction Program
extension of mitigation work to '12)
c. Evaluation
Surcharge
Program
Evaluation
subsequent demand charge task force be convened in approximately 2014 to review and revise,
as necessary, the Ongoing Program. The 2040 Policy Plan process will provide an opportunity to
make any resulting policy revisions.
2011 and 2012 Surcharges
Recognizing the financial stresses associated with the current economic environment, the Task
Force considered options to minimize the combined financial impacts of the Council's proposed
SAC shift (discussed under the "Ongoing Program Cap" section of Appendix B) and any
remaining I/1 surcharge work. In the current surcharge phase of MCES' 1/I program, I/I reduction
work for non - capped communities is scheduled to be complete in 2011. An evaluation period,
with no 1/I reduction work except for capped communities, is planned for 2012. To lessen
financial impacts and to allow 1/I reduction activities to continue into 2012, the Task Force
recommends that non - capped communities with I/I reduction work required in 2011 be allowed
to defer up to half of the required work to 2012. Because capped communities are already
deferring work beyond 2011, this recommendation does not apply to capped communities.
However, the annual required 1/1 reduction work for capped communities in 2011 and 2012 will
be determined based on 25% of the community's MWC minus the impact of any shift of costs
from SAC to the municipal wastewater charge allowed by state statute MS 473.517 subd.3b.
Summary Recommendations
The Demand Charge Task Force recommends that:
• The Council implements the Ongoing I/1 Reduction Program beginning in 2013.
• The Council may institute a wastewater rate demand charge for those communities that
have not met their I/I goal(s), if the community has not been implementing an effective
I/I reduction program in the determination of the Council, or if regulations and/or
regulatory permits require MCES action to ensure regulatory compliance.
• Non - capped communities with I/I reduction work required in 2011 be allowed to defer up
to half of the required work to 2012.
• The annual required I/1 reduction work for capped communities in 2011 and 2012 be
determined based on 25% of the community's MWC minus any SAC shift.
• The Council amends its 2030 Policy Plan as needed to reflect the above
recommendations.
G