v>EPA
United States • " ' * Office Of
Environmental Protection Water
Agency . (4204-M)
EPA-832-R-01-003
March 2001
Development Selection and
Pilot Demonstration of
Preliminary Environmental
Clean Water State
Revolving Loan Program
Volume 1: Task Force Report
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CWSRF:
Rich Deringer
Kong Chiu
EPA Headquarters:
Needs Survey:
Lisa Christ
Environmental Indicator Task Force Membership
November 2, 1999
States:
Ohio:
Greg Smith
Bob Monsarrat
Theresa Gordon
Office of Planning. Analysis, and
Accountability:
Anita Street
Arden Calvert (alternate)
Index of Watershed Indicators:
Karen Klima
Susan Holdsworth (alternate)
Margarete Heber (alternate)
Office of Wetlands. Oceans, and Watersheds:
Chuck Spooner
Otto Gutenson
AA/Water. Policy and Resource Management
Office
Anne Treash
Office of Science and Technology
Mahesh Podar
Office of Sustainable Ecosystems. Policy
Coordination Division
Michael Mason
Office of Wastewater Management. Permits
Division
KelleyVolak
EPA Region
California:
Bryan Brock
Texas:
Mark Hall
George Green
Clyde Bohmfalk
New Jersey:
Theresa Fenton
Karen Schaffer
Scott Shymon
Michigan:
Chip Heckathorn
Utah:
Walter Baker
Bryan Atwood
Brian Friel
EPA Region IX:
Juanita Licata
EPA Region V:
LulaSpruill
EPA Region IV:
Betty Barton
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Table of Contents
Volume I
Executive Summary i
Chapter 1. Introduction 1-1
Background I'l
The Clean Water State Revolving Loan Fund (CWSRF) Program 1-2
Funding Summary 1-2
CWSRF Indicator Development and Implementation 1-6
Chapter 2. Identification of Environmental Indicators for Pilot Testing 2-1
Chapter 3. State Pilot Projects to Test the CWSRF Environmental Indicators 3-1
Selection of States .. 3-1
Analysis Type • • 3-1
State Pilot Project Summaries • 3-2
Other States • • 3~5
Chapter 4. Evolution of Environmental Indicators 4-1
Chapter 5. Observations and Recommendations 4-1
Observations Related to Data 4-1
Observations Related to Programmatic Issues 4-2
Recommendations Related to Data 4-3
Recommendations Related to Programmatic Issues -. 4-4
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List of Tables
Table 2-1. Evolution of CWSRF Indicators from Draft 1998 Report to Pilot Testing 2-1
Table 3-1. Partial Summary of State Pilot Projects 3-1
Table 3-2. Partial Summary of California Analysis ,.. 3-2
Table 3-3. Partial Summary of Ohio Analysis 3-3
Table 3-4. Partial Summary of Texas Analysis 3-3
Table 3-5. Partial Summary of New Jersey Analysis 3-4
Table 3-6. Partial Summary of Utah Analysis 3-5
Table 3-7. Partial Summary, of Maryland Analysis .3-6
Table 4-1. Evolution of CWSRF Indicators from Draft 1998 Report Through Pilot Testing
Process and Final Proposed Indicators 4-1
List of Figures
Figure 1. Percent of $26.1 Billion Total CWSRF Assistance (1988-1999) by Category 1-4
Figure 2. Percent of Yearly Total CWSRF Funding for Eight Categories of Wastewater
Treatment 1-5
Figure 3. Percent of Yearly Total CWSRF Assistance Funding for Collection and Treatment
Projects 1-5
Volume II
Introduction
Appendix A.
Appendix B.
Appendix C.
Appendix D.
Appendix E.
Appendix F.
Appendix G.
Appendix H.
Force Membership
Generic Scope of Work for Pilot Project
Pilot Project Data Entry Questionnaire
Pilot Project Data Summary
State Reports on Pilot Project Experience
Ohio Pilot Project Specific Examples
Ohio EPA Biological Indicators
Ohio EPA Sampling Fact Sheet
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Executive Summary
Environmental indicators have been under development at the U.S. Environmental Protection
Agency (EPA) for more than a decade. Government-wide programs such as the Government
Performance Review Act and National Environmental Performance Partnerships, as well as the
environmental goals and milestones of EPA's Strategic Plan, establish the need for outcome-
based measures like environmental indicators. EPA conducted a feasibility analysis, developed a
methodology, and identified available resources for developing environmental indicators and
applying them to the Clean Water State Revolving Fund (CWSRF) program in 1998. EPA's
Office of Wastewater Management established a federal-state Task Force to propose and oversee
the pilot feasibility testing of a series of environmental indicators specific to the CWSRF
program. Participating states cooperated in testing a range of environmental indicators to
determine the feasibility of the indicators and their applicability to their respective state CWSRF
programs.
This report presents the findings of the Task Force, which evaluated a preliminary set of
environmental indicators developed for the CWSRF. Pilot testing was used as an approach to
evaluate whether data exist to support the selected indicators, and how easy or difficult it is to
apply the data to the environmental indicators. Based on the findings of this pilot testing,
recommendations are presented on how to proceed with the development and application of
environmental indicators to the CWSRF (i.e., to continue with or eliminate one or more of the
pilot indicators). California, Ohio, and Texas were selected to conduct environmental indicator
pilot projects. Michigan, New Jersey, and Utah also agreed to participate as pilot states. Each
state reviewed a subset of its projects funded through the use of the CWSRF and applied
environmental indicators to ascertain whether it could measure or otherwise reflect
environmental improvement as a result of the implementation of the proj ects.
Following initial conference calls, the Task Force members revised, developed, and discussed six
indicators. The states then conducted pilot projects to test as many of the proposed indicators as
they could apply to CWSRF projects in each of their respective states. Next, states modified the
indicators resulting in the following suite of final indicators:
(1) Actions funded by CWSRF programs. The Task Force recommends using this indicator as
an indirect measure of the contribution state CWSRF programs make to achieving Clean Water
Act objectives because this indicator would be useful in situations where there is an absence of
any other information regarding CWSRF-financed projects;
(2) Number of pounds of pollutants removed from the environment through CWSRF-funded
projects (Point source oriented). This indicator is suitable for projects with influent and effluent
data available. The indicator may also be used where pollutant loading levels in the receiving
stream are quantified and are expected to decrease as a result of the CWSRF-funded project. It
has remained consistent in focus throughout the indicator development stages;
(3) Number of pounds of pollutants prevented from entering the environment through CWSRF-
funded projects. This indicator is proposed as a prevention measure. It is suitable for projects
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that aim to reduce loading "to" or within a treatment facility, expand plants to handle increased
population, and address nonpoint sources of pollution;
(4) Physical changes to the terrestrial, riparian, or aquatic habitat and hydrology as a result of
CWSRF-funded projects. This indicator is proposed for the category of CWSRF-funded projects
that cannot be measured by load reduction or projected load prevention. Habitat destruction and
hydromodification are major causes of aquatic life impairment, surpassing organic enrichment
and dissolved oxygen impacts in some states. This indicator measures changes in land use (such
as a change in agricultural tillage practices or restoration of a riparian stream corridor) and other
attributes of the physical environment that could affect the aquatic community;
(5) Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, previously impaired, now improved or meeting designated uses, as a result of
CWSRF-funded projects. This indicator proposes to measure water quality conditions in terms
of designated uses for a distinct subset of waterbodies, impairment is quantified and reported as
not meeting water quality standards and designated uses.
(6) Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland awes, protected as a result of CWSRF-funded projects. This indicator has a clear focus
on protection of unimpaired resources; and
(7) Reduced health risks and/or increased recreational use attributable to CWSRF-funded
projects. The indicator is important because it monitors a Clean Water Act objective. The data
used for this indicator should be collected by a regulatory agency or collected hi a manner that is
subject to quality assurance and quality control procedures to ensure their accuracy. Problems in
using this indicator occur when sampling is lacking or inadequate to draw conclusions. Ideally,
bacteriological samples should be taken during low seasonal flows and at strategic locations, and
the sampling should be done before and after project completion.
The Task Force report covers both data and programmatic observations and recommendations. It
was observed that some states have suffered budget cutbacks hi the area of environmental
monitoring, including ambient monitoring. A lack of environmental baseline data undermines a
state's ability to directly measure environmental improvements that could be evident as a result
of implementing environmental programs and improvements such as the CWSRF. Without
ambient monitoring data, states that conduct only limited water quality monitoring would be
hardpressed to demonstrate actual environmental improvements as a result of environmental
infrastructure improvements through CWSRF funding. In order to document environmental
improvement, the Task Force believes that more data are needed to support environmental
indicators for nonpoint source (NPS) projects. A broader scope of data types beyond traditional
water quality parameters would be appropriate to better demonstrate environmental improvement
from CWSRF-funded projects.
Under programmatic issues it was observed that environmental data at the project level are not
reported or tracked by most states, and none of the information is reported to EPA. States do not
have procedures in place to collect information on environmental outcomes related to CWSRF
projects, or on whether they were the result of the combined efforts of many programs. There are
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a wide variety of approaches at the state level that could be used to report on environmental
improvements associated with CWSRF-funded projects.
The environmental indicators identified in this report represent the start of an evolutionary
process. As the states gain experience in trying to measure environmental progress by using
those indicators, additional or revised indicators are likely to surface, and use of geographic
information systems to detect progress is expected to be expanded. Additionally, determination
of total maximum daily loads and other monitoring efforts are likely to increase the amount of
information that is available. Because of the diversity among the states, the environmental
indicators are presented as a "suite" of indicators to be used at each state's discretion according
to its individual needs.
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Chapter 1. Introduction
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Chapter 1. Introduction
Background
Environmental indicators have been under development at the U.S. Environmental Protection
Agency (EPA) for more than a decade. Environmental indicators have been defined in many
ways: as biological, chemical, or toxicological constituents of the environment that define risk
levels; as trend measurements that describe improving or degrading conditions; and as
mechanisms to demonstrate the effectiveness of environmental projects and programs. Initially,
EPA environmental indicators were an outgrowth of the need for comprehensive and up-to-date
environmental assessment information used for internal planning and budgeting. More recently,
indicators have been recognized as an important tool for measuring and communicating
environmental progress and for demonstrating progress and accountability. Government-wide
programs such as the Government Performance Review Act and National Environmental
Performance Partnerships, as well as the environmental goals and milestones of EPA's Strategic
Plan, establish the need for outcome-based measures like environmental indicators.
In 1998 EPA conducted a feasibility analysis, developed a methodology, arid identified available
resources for developing environmental indicators and applying them to the State Revolving
Fund (CWSRF) program. This resulted in publication of a draft report, Environmental
Indicators for the Clean Water State Revolving Fund (EPA 832-D-98-002). One of the
recommendations of the report was that EPA should establish a workgroup with significant state
and regional participation to continue the development and implementation of indicators.
Another recommendation was to adopt a process to shape the development of indicators in a
stepwise manner that would clearly articulate EPA's desire for states to shift CWSRF funding
toward NFS, estuary, and wetland projects. The report also made the observation that traditional
CWSRF projects may employ a set of environmental indicators different from those that pertain
to NFS and wetland projects.
In response to these recommendations, EPA's Office of Wastewater Management established a
federal-state Task Force to propose and oversee the pilot feasibility testing of a series of
environmental indicators specific to the CWSRF program. The Task Force, which consists of
representatives from six CWSRF programs, four EPA regions, and eight EPA water program
offices, has participated hi monthly conference calls since January 1999. In addition to
participating in conference calls, participating states cooperated in testing a range of
environmental indicators to determine the feasibility of the indicators and their applicability to
their respective state CWSRF programs.
The purpose of this report is to present the findings of the Task Force, which evaluated a
preliminary set of environmental indicators it developed for the CWSRF. Pilot testing is being
used as an approach to evaluate whether data exist to support the selected indicators, and how
easy or difficult it is to apply the data to the environmental indicators. Based on the findings of
this pilot testing, recommendations are presented on how to proceed with the development and
application of environmental indicators to the CWSRF (i.e., to continue with or eliminate one or
more of the pilot indicators).
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
This chapter provides background information on the CWSRF pilot indicator project, discusses
the CWSRF program, and summarizes funding. CWSRF indicator development, Task Force
membership, and steps for applying the pilot environmental indicators to the projects also are
outlined in the chapter. Chapter 2 explains the proposed pilot environmental indicators. Chapter
3 discusses how states were selected to conduct pilot projects and summarizes state approaches.
Also included in Chapter 3 are segments written by individual states, detailing their experience
and their successes and failures while conducting pilot indicator projects. Finally, Chapter 4
presents succinct findings and recommendations from the states as a result of their work on the
CWSRF pilot environmental indicators.
The State Revolving Loan Fund (CWSRF) Program
The Nation has invested billions of dollars on wastewater infrastructure. In 1972 Congress
established the Construction Grants Program to provide grants to assist local governments in
constructing wastewater treatment facilities. The federal grants constituted a large percentage of
the funding for these projects. In 1987 the grant program began a phaseout with a transition to a
state revolving loan program. States now receive CWSRF capitalization grants, which are
matched at a rate of one state dollar for every five federal dollars. Loans are then made by the
states for eligible projects and activities. Repayments on the initial loans are reloaned, thus
establishing the "revolving" nature of the CWSRF program.
The states have considerable flexibility to develop and operate CWSRF programs that meet their
particular needs. Two types of federal requirements are imposed on state CWSRF programs:
"cross-cutting" authorities, which are the environmental, economic, and social policy
requirements that apply to all federal grant programs (e.g., equal employment opportunity,
participation by minority-owned businesses) and CWA Title II requirements (which include
federal wage rate requirements, value engineering, cost-effectiveness requirements, and so forth).
Title II requirements apply to only those projects wholly or partially financed before fiscal year
1995 with funds directly made available by federal capitalization grants.
Despite outstanding progress since 1972 in reducing water pollution and restoring our rivers,
lakes, and coastal water, serious water pollution problems persist. About 40 percent of the
nation's waterways assessed by states are still unsafe for fishing and swimming. A continued
federal financial commitment will be necessary to meet the promise of clean, safe water for all
Americans. This is particularly true as states continue to expand use of the CWSRF to address
estuary, storm water, and NPS pollution management projects to preserve past water quality
gains and strengthen our future efforts.
Funding Summary
The EPA Office of Wastewater Management tracks the financial performance of projects funded
through the CWSRF. During the period 1988 to 1999, the CWSRF program provided
approximately $26.1 billion in assistance to a variety of projects throughout the nation. Of this
total, approximately 95 percent of the CWSRF funding was used to support wastewater
treatment-related projects for publicly owned treatment works (POTWs), about 4 percent of the
funding was directed to nonpoint source projects, and less than 1 percent went to estuary projects
(Figure 1). Although the latter two categories of projects represented 20 percent of the number
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Nonpoint Source
3.9%
Storm Sewers
0.2%
Combined Sewer Overflow
Connection
6.4%
New Interceptor Sewers
12.5%
New Collector Sewers
7.0%
Rehabilitation of Sewer Systems
5.7%
Infiltration/Inflow Correction
3.2%
Estuaries
1.1%
Secondary Treatment
45.1%
Advanced Treatment
14.9%
Figure 1. Percent of $26.1 Billion Total CWSRF Assistance (1988-1999) by Category.
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
of projects funded by the CWSRF program, the projects tended to be of much smaller scale than
the wastewater treatment-related projects. For example, the average wastewater treatment
project used $3.71 million of CWSRF funds, whereas the average nonpoint source project
received $1.06 million and the average estuary project only $550,000. It also should be noted
that five states—Delaware, Minnesota, Ohio, New Jersey, and Wyoming—accounted for almost
84 percent of all of the nonpoint source projects. Only Washington State used CWSRF funding
for estuary projects.
Wastewater treatment-related projects accounted for over half of the CWSRF funding. These
monies were allocated among the following eight categories of projects: secondary treatment,
advanced treatment, infiltration/inflow correction, rehabilitation of sewer systems, new collector
sewers, new interceptor sewers, combined sewer overflow correction, and storm water/storm
sewers. Secondary treatment projects accounted for over one-half of the total funding ($11.79
billion), followed by advanced treatment ($3.9 billion) and new interceptor sewers ($3.28
billion). Storm sewer projects accounted for only $46.4 million of the funding compared to
approximately $1.5 billion each for combined sewer overflow, new collector sewers, and
rehabilitation of sewers. Finally, funding for infiltration/inflow correction totaled approximately
$846 million.
Figure 2 presents the change in percentage of total 1988 to 1999 CWSRF funding dollars by
year. Figure 3 compares the percentage of CWSRF assistance allocated between treatment
(advanced and secondary) and collection (new interceptor sewers and new collector sewers)
projects.
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
0.70
4 Secondary Treatment
-•-Advanced Treatment
-A— Mteation/MowGcKiection
-*- Rehabilitation of Sewer Systems
-*- New Collector Sewers
-O->few Interceptor Sewers
—I— Combined Sewer Overflow Correction
-ff-StomiSeweis
. 0.00
1968 1989 1990 1991 1992 1993 1994 1995 1996 1997 1996 1999
Figure 2. Percent of Yearly Total CWSRF Funding for Eight Categories of Wastewater Treatment.
0.90
- Collection (New Collector
and New Interceptor Sewers)
-Treatment (Advancedand
Secondary)
0.00
1988 1989 1990 1991 1992 1993 1994 1995 1996 1997 1998 1999
Figure 3. Percent of Yearly Total CWSRF Assistance Funding for Collection and Treatment Projects.
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Most CWSRF agreements have focused on areas where the population served is less than 10,000,
although these projects represent only 21 percent of the total CWSRF funds provided. Projects
in large population centers (areas with population greater than 100,000), on the other hand,
represent only 12 percent of the agreements but received 44 percent of the funding.
Although the CWSRF is a loan program, not a grant program, it provides a substantial subsidy to
communities through discounted interest rates on the assistance provided. The loan principal
repayments and interest payments are made available for future projects and represent
approximately 14 percent of the total funds available.
CWSRF Indicator Development and Implementation
A Task Force (subgroup of the State/EPA Clean Water State Revolving Fund Work Group) was
created to investigate the development of environmental indicators for potential use in the
CWSRF program. The Task Force includes 15 to 20 participants (listed in Appendix A) who
have worked on this assignment one or two days per month since January 1999. Members were
drawn from states, EPA regions, and EPA headquarters. Their objective was to develop a set of
indicators mostly drawn from a preliminary list developed by Tetra Tech, Inc., and as contained
in Environmental Indicators for the Clean Water State Revolving Fund, and to pilot test a set of
environmental indicators for the CWSRF program.
California., Ohio, and Texas were selected to conduct environmental indicator pilot projects.
Michigan, New Jersey, and Utah also agreed to participate as pilot states. Each state reviewed a
subset of its projects funded through the use of CWSRF and applied environmental indicators to
measure environmental improvement as a result of the implementation of the projects.
Information also is included from an effort to gather data from several other states for use in
testing the feasibility of the indicators. This effort met with only limited success. The
environmental indicators for the CWSRF program selected to be pilot tested are presented below.
Note that these environmental indicators are not ranked, and their presentation in this order does
not reflect relative priorities.
• Number of pounds of pollutants removed from the environment through CWSRF-funded
projects.
• Number of pounds of pollutants prevented from entering the environment through CWSRF-
funded projects.
• Increase in biophysical benefits or reduction in biophysical stressors by changing land use
practices and resource harvesting and extraction practices through CWSRF-funded projects.
• Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, previously impaired, now meeting designated uses as a result of CWSRF-
funded projects.
• Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, protected or improved as a result of CWSRF-funded projects.
• Benefits of reduced health risks and/or increased recreational use attributable to CWSRF-
funded projects.
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
The Task Force used the first four meetings (conference calls) to review, revise, and comment on
the environmental indicators as they could be applied to the CWSRF program. An informal
rating and evaluation format was produced and applied by each Task Force member to the six
proposed environmental indicators to do this preliminary evaluation. Ultimately, however, it was
agreed that further refinements to this language should await the states' experience during the
actual pilot testing phase. Chapter 2 provides a more detailed discussion of each proposed
environmental indicator.
The objective of this pilot phase was to examine more closely the feasibility of measuring
environmental outcomes and making linkages back to the CWSRF program activity with the
proposed environmental indicators. The pilot states investigated and reported on the availability
of data and the mechanisms (systems) to provide those data. States received a generic scope of
work (Appendix B), which was intended to help establish consistency among the pilot projects
and allow the results to be compared more consistently.
The steps of the generic scope of work included the following:
1. Identification of Type and Scope of Projects to Evaluate
States determined the type and number of CWSRF projects to be evaluated. Each state used a
consistent methodology to identify its own projects, although this methodology differed between
states.
2. Data Collection
States searched electronic and paper databases and project files to collect baseline data on each
CWSRF project. The purpose of this task was not only to collect the necessary data to apply
each indicator, but also to document the ease or difficulty of collecting the data. Data collected
for each selected project would encompass project-specific information as well as the
environmental data related to the project. Water quality conditions before and after project
implementation are critical environmental data sets.
The states were asked to document data collected using data source criteria, including
• Availability/accessibility of data (ease of acquiring information; were data out there?)
• Temporal coverage (period of time the data covered?)
• Spatial coverage (latitude/longitude, watershed, stream length)
• Technical credibility (quantity, diversity, robustness; comfort level with the data)
One tool used for managing collected project data was a questionnaire, which was available to
states online and in hard copy (Appendix C). The web-based questionnaire was presented hi
three successive pages entitled Project Information, Indicator Information, and Data Information.
A respondent could enter information for one project at a time, continuing through the three
pages for each project. Upon entry of the last input screen, the data were stored in a database.
3. Data Synthesis and Analysis
All data collected were synthesized in tabular or other format for display and analysis. Types of
CWSRF-funded projects were tallied along with water quality and environmental condition data.
March 2.002
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
The analyses of the results are presented in brief written descriptions from New Jersey,
Michigan, California, Ohio, Utah, and Texas, with discussions on validity/accuracy, data
comparability, and scope/applicability. Finally, results of assessing the data from the states that
Tetra Tech evaluated (Delaware, Maryland, and Washington) also are presented.
4. Indicator Evaluation
The environmental indicators applied in each state were evaluated. A brief narrative is presented
about the application of the environmental indicator against the following evaluation criteria:
Data sources
Data quality/quantity
Data availability (how available;, how long did it take to evaluate and compile the data?)
Data accessibility
Representativeness
Comparability
Cost-effectiveness
Ease of implementation
5. Reports
Each state prepared and submitted a written report on its findings. Recommendations about how
to best incorporate data requirements and identification of any barriers to using or accessing data
were included in the narrative. Chapter 3 presents a summary of results of the states'
participation in the environmental indicator pilot project. Appendix D provides a more detailed
summary of states' projects and the full state reports are presented in Appendix E and F.
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Chapter 2. Environmental Indicators for the Clean Water SRF Program
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Chapter 2. Environmental Indicators for the Clean Water SRF Program
Introduction
This chapter presents, in tabular format, the environmental indicators identified in the 1998 EPA
Report "Environmental Indicators for the Clean Water State Revolving Fund" and describes the
environmental indicators, based on this report, that were developed by the Task Force for pilot
testing by the participating states. The results for each state's experience with the pilot set of
indicators are presented in Chapter 3. The final set of environmental indicators is found in
Chapter 4.
Table 2-1. Evolution of CWSRP Indicators from Draft 1998 Report to Pilot Testing
bet0tH^1$&6 indicators
•rff'f'' '' N
1. Pounds of pollutants removed from the environment
through CWSRF-funded projects.
2. Pounds of pollutants prevented from entering the
environment through CWSRF-funded projects.
3. Reduction in biophysical stressors by changing land
use practices, resource harvesting practices, and
resource extraction practices through CWSRF-funded
projects.
4. Waterbodies, expressed as river and riparian miles,
lake acres, estuary square miles, and wetland acres,
previously impaired, now meeting designated uses, as
a result of CWSRF-funded projects
5. Waterbodies, expressed as river and riparian miles,
lake acres, estuary square miles, and wetland acres,
protected, improved, or restored as a result of CWSRF-
funded projects.
j^riH9*& Pilot JmiMicMtt' ' \v'* ' ""
1 . Number of pounds of pollutants removed from the
environment through CWSRF-funded projects. (Point
source oriented)
2. Number of pounds of pollutants prevented from
entering the environment through CWSRF-funded
projects. (Oriented toward NPS or no discharge)
3. Increase in biophysical benefits or reduction in
biophysical stressors by changing land use practices,
and resource harvesting and extraction practices
through CWSRF-funded projects.
4. Waterbodies, expressed as river and riparian miles,
lake acres, estuary square miles, and wetland acres,
previously impaired, now meeting designated uses, as
a result of CWSRF-funded projects.
5. Waterbodies, expressed as river and riparian miles,
lake acres, estuary square miles, and wetland acres,
protected, improved, or restored as a result of
CWSRF-funded projects.
6. Benefits of reduced health risks or increased
recreational use attributable to CWSRF-funded
projects.
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Indicator Development
1. Number of pounds of pollutants removed from the environment through CWSRF-funded
projects.
This indicator is suitable for projects where influent and effluent data is widely available. It may
also apply where loading levels in a receiving stream are quantified and are expected to decrease
as a result of the CWSRF-funded project.
2. Number of pounds of pollutants prevented from entering the environment through
CWSRF-funded projects.
This indicator is proposed as a prevention measure. It is suitable for projects that reduce
loadings either to or by a treatment facility, expand plants to handle increased flows, and prevent
nonpoint sources of pollution.
3. Increase in biophysical benefits or reduction in biophysical stressors by changing land
use practices, and resource harvesting and extraction practices through CWSRF-funded
projects.
In October 1998 this indicator read, "Reduction in biophysical stressors by changing land use
practices, resource harvesting practices, and resource extraction practices through CWSRF-
funded projects." The Task Force revised the indicator in 1999 by adding the possibility of an
increase in biophysical benefits as another measure of the land use and resource extraction
practices. . •
This indicator is proposed for the category of CWSRF-funded projects that cannot be measured
by load reduction or projected load prevention. This indicator can help quantify the wide variety
of nonpoint source, restoration, and preservation activities funded by the CWSRF.
4. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, previously impaired, now meeting designated uses, as a result of CWSRF-
funded projects.
This indicator proposes to measure water quality conditions for a distinct subset of waterbodies
where impairment is quantified and reported as not meeting water quality standards and
designated uses. This indicator focuses on waterbodies that were determined to be degraded to
some extent by a cause or source attributable to a problem that was remedied by a CWSRF
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
projects). The criteria that are used to determine the degradation may be the same as those used
to establish a state's 303(d) list. These data could include chemical, physical and/or biological
criteria, but will vary from state to state. Information should be available in each state's 305(b)
water quality report as to the condition of waterbodies with respect to their designated aquatic
life habitat uses. The problems addressed by the CWSRF project should be clearly described in
the environmental assessment for that project.
5. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, protected, improved, or restored as a result of CWSRF-funded projects.
This indicator is a more comprehensive measure of ambient water quality conditions than
Indicator 4. This indicator, as proposed, initially would be less precise by not having an
established baseline of impairment against which to measure progress (unless the CWSRF
project quantifies the level of impairment prior to the start of the project).
With the current emphasis through the Total Maximum Daily Load.(TMDL) process on impaired
waters, the group wanted to identify the importance of keeping rally attaining surface waters
from becoming impaired. The CWSRF program should address problems that will cause
impairments to water quality before the problems become apparent and before enforcement
action is required. This indicator serves to focus attention on areas of attainment and the
importance of using CWSRF resources to ensure maintenance of attainment.
6. Benefits of reduced health risks or increased recreational use attributable to CWSRF-
funded projects.
The indicator is important because it monitors a Clean Water Act objective. The data used for
this indicator should be collected by a regulatory agency or collected in a manner that is subject
to quality assurance and quality control procedures to ensure their accuracy. Although it may be
difficult to establish distinctions as to the degree of human health risk posed by different sources
of pollution, the presence of indicator bacteria (e.g., E. coli, fecal coliform) associated with fecal
matter at levels above established threshold concentrations indicates the presence of health risks
from pathogens. If an CWSRF project addressed a source of this problem, then reduction of
bacterial concentration subsequent to project completion would indicate that the CWSRF project
contributed to reducing risks to human health.
March 2001
2-3
-------
-------
Chapter 3. State Pilot Projects to Test the CWSRF Environmental Indicators
-------
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Chapter 3. State Pilot Projects to Test the CWSRF Environmental Indicators
Selection of States
California, Ohio, Texas, New Jersey, Michigan, and Utah participated as pilot states for the
testing of CWSRF environmental indicators. Tetra Tech also contacted other states, including
Delaware, Maryland, and Washington, to test the data collection process.
Analysis Type
Projects were selected by the pilot states on a program-wide, project-specific, or watershed/
subwatershed-level basis. California originally proposed to evaluate a randomly selected number
of projects (approximately 20 to 30) that were completed during the 1992 to 1993 period. Ohio
proposed to identify all projects funded through the CWSRF and then select for evaluation only
those projects for which water quality and other project-specific data were available and could be
applied to the six pilot environmental indicators. Texas employed a subwatershed or stream
segment approach and evaluated all projects completed within each subwatershed. Table 3-1
gives a brief summary of state project analyses.
Table 3-1. Partial Summary of State Pilot Projects
-.-.-. f * f vw.vs va&v*}* f '• ..
f' f»lfoi States V '
California
Ohio
Texas
Michigan
New Jersey
Utah
- - "'T^^Aaalysfe - -
program-wide
project-specific
watershed-level
program-wide
project-specific
project-specific
" N&v«f«eleva»t€WS^F^roj*cts3li^p«^ea
4
15
22
0
9
8
Other States
Delaware
Washington
Maryland
project-specific
project-specific
project-specific
0
0
4-,
March 2001
3-1
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
State PHot Projects
This report reflects the state evaluations of the April 1999 indicators1 and subsequent information
collected from the states.
See Appendix A for the state contacts and Appendix D for a detailed summary of project data for
each state. Appendix E contains individual state write-ups of their projects.
California
From a program-wide perspective, California evaluated a total of 10 to 12 projects, some of
which were nonpoint source projects. California has collected information on four projects to
date, all of which were related to publicly owned treatment works (POTWs) (Table 3-2).
Different people involved in the CWSRF projects filled out questionnaires by hand to submit the
data to Tetra Tech. Data came from the project files, health departments, regional water quality
districts, and self-monitoring data. To date, only the self-monitoring data from POTWs are
easily available. These types of data satisfy Indicators 1 and 2 (loadings-related indicators). A
cursory search for information on nonpoint source projects was not productive.
Table 3-2. Partial Summary of California Analysis
; ^l$jja^&£^
1,2
None
5
\ •" •:<..,
Secondary treatment
New interceptor sewers
Advanced treatment; infiltration/inflow
correction
, -ttaatartfita***'
2
1
1
Ohio
The state of Ohio has a wealth of in-stream monitoring data, including biological, physical, and
chemical data. A total of fifteen projects were evaluated using Ohio's Water Quality Inventories,
technical and permit support documents, Water Pollution Control Loan Fund (Ohio's CWSRF)
environmental assessments and project records, water quality standards, and field notes from the
monitoring staff (Table 3-3). These projects consisted of predominantly wastewater treatment
plant (WWTP) improvements. In general, project evaluation reflected a reduction of one or more
chemical or bacteriological pollutants to the receiving streams and a corresponding response hi
the biological communities.
!In February 2000 two additional indicators were suggested-Indicators A and B. Ohio and New Jersey
evaluated these indicators.
3-2
March 2001
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Table 3-3. Partial Summary of Ohio Analysis
April 1 W Iftdte*tejr t3Ml
A, 1,4,5,6
A, 1,2,4, 5,6
A, 1,4,5
A, 1,2, 4,5,6, B
A, 4, 5
I , cws»**wf*t7$i*;_ \ ;„-
WWTP improvements
WWTP improvements
Landfill; new interceptor sewers/WWTP improvements
WWTP improvements
Centralized collection system
[ ?ftti»%}r»fl»r0|*cfei-
10
i
2
1
1
Texas
Texas used a subwatershed or stream segment approach to identify its pilot projects. Texas
focused on comparing the current 303(d) list to 305(b) data from 1983-1987. Texas used these
as a before-and-after picture to identify three types of waterbodies: (1) waters previously
impaired that are no longer impaired, (2) waters previously impaired and still impaired, and (3)
waters previously unimpaired and currently unimpaired.
Texas submitted data to Tetra Tech on faxed questionnaires describing waters previously
impaired that are no longer impaired. Although the state listed the project indicator as Indicator
1 (Number of pounds of pollutants removed from the environment through CWSRF-funded
projects), the actual data are qualitative. For example, loadings from nutrients might have been a
reason a stream segment was listed as impaired on the 305(b) report, and when it was listed on
the 303(d) list as no longer impaired, it was assumed the nutrient loadings had been reduced in
the stream segment.
Texas later evaluated approximately 22 projects in various CWSRF project categories, ranging
from wastewater treatment plant expansions to nonpoint source pollution projects (Table 3-4).
Table 3-4. Partial Summary of Texas Analysis
1,2,4
Texas did not explicitly distinguish project type.
22
New Jersey
New Jersey provided information on nine projects completed in 1993 and 1994, six of which
were POTWs (Table 3-5). None of the projects addressed nonpoint source pollution. New
Jersey also reviewed information on other projects that received CWSRF loans to determine if
other means to establish quantitative or qualitative information were available to support the six
pilot indicators. New Jersey also provided support for the new indicator A by evaluating state
and CWSRF funds as an indirect indicator of potential water quality improvement
Tetra Tech retrieved data from EPA's Storage and Retrieval (STORET) database system to
evaluate some of the New Jersey projects. Trends before and after projects could be identified in
March 2001
3-3
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
only two cases for some pollutant parameters.! However, the state could not directly link the
CWSRF as a cause of the changes, as opposed to other factors involved.
Table 3-5. Partial Summary of New Jersey Analysis
' •> ^(yr •*>••>$• -' •• -"•-. % s A-.
%;-x-A|>^l IP$p ^Bicator^Bd^ ^
i
2
None
2
None
f €W$Jtrj>roj<*tTyj*e
Secondary treatment
Advanced treatment
Sewer replacement/rehabilitation
New collector sewers
Pump station rehabilitation/replacement
i K»)i»b0rj>l^ir«|«efs
5
1
1
1
1
Michigan
Michigan did not provide project-specific information, but did produce a detailed description of
its Priority Listing Procedure for ranking projects for which CWSRF funding has been requested.
The system relies on measures of environmental needs. Modeling is used to estimate in-stream
conditions resulting from existing discharges and those expected after project completion. The
differences between these two simulations are used to assign funding priority to projects.
Historically, Michigan maintained an ambient monitoring network of surface water quality
sampling sites, but nearly all of these efforts have been eliminated over the past 15 years.
Discharge Monitoring Report (DMR) data are available only for permitted point source
dischargers, and no reliable sampling record of nonpermitted discharges or discharges to
groundwater is available. Hence, although the Michigan priority models simulate pre-project
conditions, they can be used for Indicators 1 and 2.
Utah
Utah originally worked with eight CWSRF projects (all point sources—treatment plants and
interceptors, as well as new systems replacing failed on-site disposal systems [septic systems])
(Table 3-6). They investigated loading reductions to support Indicators 1 and 2, but faced
challenges different from those posed to surface water discharges. As data sources Utah relied
on DMRs (referred to as Monthly Operating Reports hi Utah), STORET data, and self-
monitoring reports from POTWs. Loadings extrapolated from septic systems were also
evaluated, but the data are less obvious than discharges to a receiving waterbody.
Utah reported on projects by using the on-line questionnaire. They provided specific loading
numbers for Indicators 1 and 2. Utah also compared a 1987 (pre-CWSRF) 303(d) list of
impaired water to the most recent list. No information was evident to support water quality
improvement identifiable under indicators 4 and 5.
3-4
March 2001
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Table 3-6. Partial Summary of Utah Analysis
* 4^i^i*&ttt»rtatt*
None applicable
2,4
2
2
2
2
~~~" > CW8KtP*tt!Mt1*9« '---"""
Secondary treatment (biosolids)
Advanced treatment
Secondary treatment; new collector sewers; new
interceptor sewers
Secondary treatment; new interceptor sewers
New interceptor sewers
New collector sewers; new interceptor sewers
;-- - $N*&^0f'$rQ!&!& - -
i
i
2
2
1
1
Other States
Delaware
To obtain past CWSRF project information from Delaware, Terra Tech contacted the Department
of Natural Resources and Environmental Control (DNREC). In response to questions about the
number, type, and location of projects funded by CWSRF loans, the program manager of the
DNREC Division of Water Resources, Financial Assistance Branch, stated that most of the
information was related to individual homeowners and septic system replacement/repair.
Because this is proprietary information, Tetra Tech did not pursue the information, which might
have violated the involved parties' privacy.
Next, Tetra Tech contacted the U.S. EPA Region 3 office in Philadelphia, Pennsylvania. EPA
said it did not have quantitative information on specific projects because that kind of decision is
made only at the state level. Qualitatively, EPA added that the CWSRF projects in Delaware
were funded on a first-come, first-served basis, and not according to any priority system based on
water quality needs. EPA had access to the total amount that Delaware loaned out in its CWSRF
program, but any information on specific projects (location, description, type) was maintained at
the state level.
Because Tetra Tech was able to obtain information on only one project (City of Seaford sewer
system upgrade) and information on the majority of the projects was not available, the Delaware
data were not particularly useful.
Washington
Tetra Tech developed a list of 12 specific completed CWSRF projects in Washington State. The
list consisted of a combination of the three types of projects (point, nonpoint, estuary) to be
evaluated using the indicators. Target projects were chosen based on date of completion and
project type.
March 2001
3-5
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
The Washington Department of Ecology stated that in-depth project information was not housed
at state headquarters and suggested that the regional office or specific project managers in the
cities or counties where projects were completed be contacted. Contacts in the regional office of
the Washington Department of Ecology informed terra Tech that it is likely that project
information for completed CWSRF projects is archived off site. Access to on-site files in the
regional office was limited due to a recent fire in the office. Attempts to contact project
managers at the city level were largely unsuccessful.
Maryland
Terra Tech visited the Maryland Department of the Environment to gather information on
CWSRF projects. This effort was intended to test the data collection process, including the use
of the CWSRF indicator questionnaire. Terra Tech collected data on two POTW projects and
two nonpoint source projects (Table 3-7). STORET data were used to evaluate ambient
(receiving water) pollutant parameter trends for the point source projects. For one nonpoint
source project, the Safe Drinking Water Information Database was used to represent a reduced
potential health risk, which would be applicable to Indicator 6.
The Maryland Department of the Environment also provided information oh its CWSRF
Application process, which uses an environmental information document, preliminary
environment screening checklist, and financial loan application. The environmental information
document requests information on the water quality/public health problems being corrected and
the potential impacts of the project on water quality, water supply, biology, wetlands, and
biosolids management.
Table 3-7. Partial Summary of Maryland Analysis
•* &!&&j$fr&^&&'^ !
1,2
5
6
£W&$&yw$#ti'Ty$& '-' ' « ' -
Advanced treatment
Nonpoint source: agriculture
Secondary treatment; new collector sewers
: T&W^&yftfy^ , i
2
1
1
3-6
March 2001
-------
Chapter 4. Evolution of Environmental Indicators
-------
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Chapter 4. Evolution of Environmental Indicators
This chapter describes the final set or suite of environmental indicators as they have evolved
based on the states' experience in testing them on a pilot basis.
Table 4-1. Evolution of CWSKF Indicators from Draft 1998 Report Through Pilot Testing Process
and Final Proposed Indicators
Pilot lastfcaters'
Sepiemfaer2$Q0 Final
Administrative indicators
• EPA/State Actions
• Actions by Regulated
Community
February 2000 Indicator A. Actions
funded by CWSRF programs.
(Evaluated by Ohio only)
1. Actions funded by CWSRF
programs.
1. Pounds of pollutants removedfrom
the environment through CWSRF-
funded projects.
1. Number of pounds of pollutants
removed from the environment
through CWSRF-funded projects.
2. Number of pounds of pollutants
removed from the environment
through CWSRF-funded projects.
2. Pounds of pollutants prevented
from entering the environment
through CWSRF-funded projects.
2. Number of pounds of pollutants
prevented from entering the
environment through CWSRF-
funded projects.
3. Number of pounds of pollutants
prevented from entering the
environment through CWSRF-
funded projects.
3. Reduction in biophysical
stressors by changing land use
practices, resource harvesting
practices, and resource extraction
practices through CWSRF-funded
projects.
3. Increase in biophysical benefits
or reduction in biophysical stressors
by changing land use practices, and
resource harvesting and extraction
practices through CWSRF-funded
projects.
4. Physical changes to the
terrestrial, riparian, or aquatic
habitat and hydrology resulting
from CWSRF-funded projects.
February 2000 Indicator B.
Changes in habitat of a waterbody
as a result of an CWSRF-funded
project. (Changes in ambient
habitat) (Evaluated by Ohio only)
4. Waterbodies, expressed as river
and riparian miles, lake acres,
estuary square miles, and wetland
acres, previously impaired, now
meeting designated uses, as a
result of CWSRF-funded projects.
4. Waterbodies, expressed as river
and riparian miles, lake acres,
estuary square miles, and wetland
acres, previously impaired, now
meeting designated uses, as a
result of CWSRF-funded projects.
5. Waterbodies, expressed as river
and riparian miles, lake acres,
estuary square miles, and wetland
acres, previously impaired, now
improved or meeting designated
uses, as a result of CWSRF-
funded projects.
5. Waterbodies, expressed as river
and riparian miles, lake acres,
estuary square miles, and wetland
acres, protected, improved, or
restored as a result of CWSRF-
funded projects.
5. Waterbodies, expressed as river
and riparian miles, lake acres,
estuary square miles, and wetland
acres, protected, improved, or
restored as a result of CWSRF-
funded projects.
6. Waterbodies, expressed as river
and riparian miles, lake acres,
estuary square miles, and wetland
acres, protected as a result of
CWSRF-funded projects.
6. Benefits of reduced health risks
or increased recreational use
attributable to CWSRF-funded
projects.
7. Reduced health risks and/or
increased recreational use
attributable to CWSRF-funded
projects.
March 2001
4-1
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Final Indicator Development
1. Actions funded by CWSRF programs.
I
Although the October 1998 version of indicators included administrative indicators, they were
dropped from the April 1999 pilot testing stage, which focused specifically on "environmental"
indicators. Indicator 1 was re-proposed after the other pilot indicators were tested. The Task
Force recommends using this indicator as an initial indicator of the contribution state CWSRF
programs make to achieving Clean Water Act objectives. This indicator would be useful in
situations where there is an absence of any other evidence regarding environmental
improvements brought about by CWSRF-financed projects.
.The issue of measuring some CWSRF projects that did not fit under the April 1999 list of pilot
environmental indicators arose in February 2000. Some categories of CWSRF projects could be
measured only by Indicator A (final Indicator 1). This indicator is the most basic measure of
actions to improve the environment because it counts the number of funded projects. It is the
minimal reporting indicator, and it assumes project initiations result in environmental benefits.
The number as well as the total dollar amount funded for projects by type may also provide
useful information for some CWSRF projects.
2. Number of pounds of pollutants removed from the environment through CWSRF-funded
projects.
This indicator is suitable for projects where influent and effluent data is available. It is also
suitable where loading levels in a receiving stream are quantified and are expected to change as a
result of the CWSRF-funded project. Indicator 2 may also be used for projects that convert
failing septic systems to centralized sewer systems.
3. Number of pounds of pollutants prevented from entering the environment through
CWSRF-funded projects.
This indicator is proposed as a prevention measure. It is suitable for projects that prevent
loadings either to or by a treatment facility, expand plants to handle increased flows, and prevent
NFS pollution.
• This indicator is expected to be derived from load reductions reported by states, by using
the Permit Compliance System database or the actual monthly Discharge Monitoring
Reports. Load reduction projections would most likely be estimated through established
engineering practices using modeling tools.
4-2
March 2001
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
4. Physical changes to the terrestrial, riparian, or aquatic habitat and hydrology as a result
of CWSRF-funded projects.
In October 1998 this indicator read, "Reduction in biophysical stressors by changing land use
practices, resource harvesting practices, and resource extraction practices through CWSRF-
funded projects." The Task Force revised the indicator in 1999 by adding the possibility of an
increase in biophysical benefits as another measure of the land use and resource extraction
practices. In February 2000 the Task Force agreed to add Indicator B— "Changes in habitat of a
waterbody as a result of an CWSRF-funded project. (Changes in ambient habitat)"— to
complement the language of the previous April 1999 indicator 3.
Indicator B was proposed in February 2000 after other pilot indicators had been reviewed. This
indicator would allow measurement of CWSRF project accomplishments hi terms of habitat
improvement. It would be particularly useful for those projects (mainly nonpoint source) whose
main benefit is to provide habitat restoration. The Task Force acknowledged that various types
of physical habitat measures, such as the Qualitative Habitat Evaluation Index (QHEI) and Zig-
Zag Pebble Count, might be useful with this indicator.
The Task Force decided to combine Indicator B and the interim version of Indicator 4 to reach
the June 2000 version. The final version of Indicator 4 reflects a move to categorize biophysical
benefits or reduction in biophysical stressors as "physical changes" and move away from the
potentially misunderstood language of "land use practices." Physical changes to terrestrial and
in-stream habitat types now may be reported under Indicator 4.
This indicator is proposed for the category of CWSRF-funded projects that cannot be measured
by load reduction or projected load prevention. Habitat destruction and hydromodification are
major causes of aquatic life impairment, surpassing organic enrichment and dissolved oxygen
impacts in some states. This indicator measures changes in land use (such as a change in
agricultural tillage practices or restoration of riparian stream corridor) and other attributes of the
physical environment (such as biosolids entering the stream from a POTW) that could affect the
aquatic community.
• This indicator can help quantify the wide variety of nonpoint source, restoration, and
preservation activities funded by the CWSRFs. Coupled with Indicator 5, this indicator
can show the effectiveness of CWSRF-funded activities.
• Biological monitoring will show effects of increased sedimentation. Macroinvertebrate
populations decline when substrates become embedded. Absent biological data, it is
possible to track sediment embeddedness. Used alone or hi combination with biological
data, embeddedness can indicate the success of various types of activities/best
management practices on aquatic habitat improvement.
March 2001 ' 4.3
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
After much discussion by the states, it was decided that this indicator is valuable because
of the correlation between habitat quality and attainment of Clean Water Act goals.
States are encouraged to further investigate the techniques (field surveys, Zig-Zag Pebble
Count Method), tools (QHEI, geographic information systems), and units (acres, river
miles, degree of embeddedness) used to measure progress under this indicator (See
Appendix G and H).
5. Water-bodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, previously impaired, now improved or meeting designated uses, as a result of
CWSRF-funded projects.
This indicator focuses on waterbodies that were determined to be degraded to some extent by a
cause or source attributable to a problem that was remedied by a CWSRF projects). The criteria
that were used to determine the degradation may be the same as those used to establish a state's
303(d) list. These data could include chemical, physical, and/or biological criteria, but this will
vary from state to state. Information should be available in each state's 305(b) water quality
report as to the condition of waterbodies with respect to their designated aquatic life habitat uses.
The problems addressed by the CWSRF project should be clearly described in the environmental
assessment for that project.
By comparing the miles impaired and degree of impairment before and after the completion of a
CWSRF project, changes in the degree of use attainment can be correlated with CWSRF-funded
projects within the range of river miles that the project influences. In some cases, the major
source of impairment will not be related to the CWSRF project, and so a minor improvement in
stream condition will be seen. In other cases, the problem that was addressed by the CWSRF
project may have been the only source of impairment, and so the subsequent restoration of that
waterbody segment will be entirely attributable to the CWSRF-funded activities. In still other
situations, a number of causes may have contributed to impaired water quality, all of which were
addressed, but only some of which were CWSRF-funded, and so only a portion of the improved
water quality will be attributable to CWSRF financing.
• EPA and the states have developed an up-to-date, comprehensive list of impaired waters
(303(d)). Ideally, this proposed Indicator 5 could measure progress against this nationally
established "baseline" of impaired waters. At the state and project levels, the indicator can
be developed using state or locally generated information on water quality conditions
without necessarily aggregating it with other states' results. Often, water data exist at the
state or local level which might be more useful in demonstrating results.
4-4
March 2001
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
• It was decided that showing improvements in the environment is important even if
designated uses were not met. The indicator now includes measuring improved
waterbodies that may have partially attained designated uses.
6. Waterbodies, expressed as river and riparian miles, lake acres, estuary square miles, and
wetland acres, protected as a result of CWSKF-funded projects.
This indicator originally read, "Waterbodies, expressed as river and riparian miles, lake acres,
estuary square miles, and wetland acres, protected, improved, or restored as a result of CWSRF-
funded projects." It was determined that with the original wording there was too much overlap
between Indicators 5 and 6. Rather than combining the two indicators into one, the group
decided to keep improvement of unpaired waters in Indicator 5 and put protection activities in a
different category, Indicator 6. With the current emphasis through the TMDL process on
impaired waters, the group wanted to identify the importance of keeping fully attaining surface
waters from becoming impaired. The CWSRF program should address problems that will cause
impairments to water quality before the problems become apparent and before enforcement
action is required. This indicator serves to focus attention on areas of attainment and the
importance of using CWSRF resources to ensure maintenance of attainment.
• The Task Force felt that Indicators 5 and 6 would (1) measure key environmental
objectives of all water protection programs, (2) help establish stronger linkages with other
federal water programs with similar indicators and objectives, and (3) encourage the
development of data sets that document before-and-after conditions.
Data from EPA's 305(b) reports, STORET, and other data systems can be used to support
this indicator. Project-specific information, where available, could also support the use of
this indicator.
• Indicator 6 provides a means to capture some of the less traditional CWSRF activities
that contribute to the protection and preservation of unimpacted resources, such as land
acquisition, easement purchase, and riparian stream corridor restoration.
The final indicator 6 removed the words "improved" and "restored." Indicator 5 will address
improvements in waterbodies, as well as cases where waters meet designated uses. Indicator 6
has a clear focus on protection of unimpaired resources.
March 2001
4-5
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
7. Reduced health risks and/or increased recreational use attributable to CWSRF-funded
projects.
The indicator is important because it monitors a Clean Water Act objective. Although it may be
difficult to establish distinctions as to the degree of human health risk posed by different sources
of pollution, the presence of bacteria (e.g., E. coli, fecal coliform) associated with fecal matter at
levels above established threshold concentrations indicates the presence of health risks. If a
CWSRF project addressed a source of this problem, then reduction of bacteria concentration
subsequent to project completion indicates that the CWSRF project contributed to reducing risks
to human health.
Sampling upstream and downstream of a POTW outfall can provide information regarding the
plant operations with respect to bacterial contributions. If the project addressed failing septic
systems or sewer bypasses, health department records of bacterial concentration violations in
pools, ditches, basements, and water wells should be used if available to document the problems
addressed. Such locations are not considered official waterbodies, but would nonetheless pose a
threat to human health. Frequently, these data are not in any known database or report, but are
often gathered on an individual project basis from local health departments. Some ambient
stream data may be available at the state level to determine recreational use attainment.
Problems in using this indicator occur when sampling is lacking or inadequate to allow drawing
conclusions. Ideally, bacteriological samples should be taken during low seasonal flows and at
strategic locations, and the sampling should be done before and after project completion.
4-6
March 2001
-------
Chapter 5. Observations and Recommendations
-------
-------
Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators .,
Chapter 5. Observations and Recommendations
This project was conducted at the state level for the purpose of developing and testing a range of
environmental indicators that could assist states in both setting priorities for project selection and
demonstrating CWSRF program and project success. Accordingly, the six environmental
indicators identified in Chapter 2 were tested and evaluated for use by several states through the
formation of a Task Force, which met monthly during this phase of the project. Based on the
review, revision, and pilot testing of the environmental indicators, the Task Force submits the
following observations and recommendations grouped broadly under the categories of "data" and
"programmatic issues."
Observations Related to Data
• Access to environmental monitoring data and other sources of information that could help
support the use of environmental indicators is difficult and at best time-consuming when
data are available. Many of the states discovered through this pilot project that
identifying and accessing environmental data related to CWSRF-funded projects ranges
from problematic to extremely difficult. Discharge Monitoring Reports submitted
monthly by National Pollutant Discharge Elimination System permit holders. They cover
treatment facilities and would account for a majority of CWSRF project funds. Sources
of monitoring data are usually collected and maintained by agencies, offices, or programs
other than the state CWSRF lead agency, resulting in problems and time delays in
accessing data for indicator analysis.
• Applying environmental indicators to CWSRF-funded projects other than wastewater
treatment upgrades or expansions is difficult at the present time. This is due, in part, to
the fact that many states have not funded a large number of nonpoint source (NFS)
projects, as well as the fact that there are fewer data available for NFS pollution than for
point sources. Lack of data to evaluate the effects of some CWSRF NFS projects may be
a temporary problem, because as more projects are funded, one would expect the effects
to eventually show up in water quality monitoring information. Further, because it takes
several years after project implementation before the benefits of NFS projects are
realized, there will be an additional time lag in having the benefits reflected through
physical, chemical, and biological monitoring.
• Substantial modeling would be necessary to apply final Indicator 3 (Pounds of pollutants
prevented from entering the environment from CWSRF-funded projects). This approach
would be costly, controversial, and time-consuming to develop. In the alternative,
nationally accepted estimation approaches might be able to establish load reductions by
estimating reductions in loads. Estimations may be possible. The objective should be to
get general indicators of CWSRF contributions to water quality improvement.
March 2001
5-1
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
• Chapter 3 contains documentation on the experience from each of the state pilot projects.
Each state presented its findings and individual recommendations. Variability between
states was observed, with the major problem being the availability of data to support each
environmental indicator.
Observations Related to Programmatic Issues
• The CWSRF Program information tracking system traditionally has used fiscal measures
(e.g., number of loans initiated per year) to evaluate program performance. The current
CWSRF information tracking system contains a significant source of information
regarding the amount of capitalization funds provided to states and, together with states'
matching funds, the funds available for projects. Environmental data at the project level
are not reported or tracked by most of the states, and none of the information is compiled
and submitted to EPA.
• Within a state, decisions on funding of projects through the CWSRF are often driven by
factors other than environmental protection or improvement. The projects on a state's
priority list are included on the list because of the state's objective to improve or expand
wastewater treatment or otherwise achieve water quality benefits. Projects often receive
loans regardless of their location on a state's priority funding list, however, because of
their "readiness to proceed." Although EPA has encouraged states to keep the funds
moving and to initiate as many projects as possible, use of CWSRF indicators provides
an opportunity to integrate environmental outcomes into the state priority ranking
process.
• Measurement or collection of data to document environmental improvements directly
related to CWSRF projects does not follow a standard operating procedure. States do not
have procedures in place to collect information on environmental outcomes related to
CWSRF projects, or whether they were the result of the combined efforts of many
programs. In defense of the states, they have not been requested or required to collect
such data in the past.
• Although some states can correlate trends with CWSRF projects, currently available
environmental monitoring data collected by many states do not necessarily help to assess
CWSRF outcomes because the monitoring was not designed for such purposes.
However, it may be possible to correlate water quality changes with CWSRF projects
when states have monitoring data (biological, chemical, bacteriological, and/or physical).
Even though the monitoring was not designed to evaluate the success of the CWSRF
program, much of the 303(d) and 305(b) data can be used directly or indirectly for that
purpose.
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March 2001
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
This project has demonstrated that there is a wide variety of approaches at the state level
that could be used to report on environmental improvements associated with CWSRF-
funded projects. Most of the pilot states agreed that loading reductions from CWSRF-
funded treatment projects could be either directly measured or estimated. The states also
agreed that connecting these load reductions to actual stream improvements in the
absence of the other indicators does not necessarily provide evidence of improvement in
the attainment of designated uses by waterbodies. The Task Force has discussed using
the environmental indicators together as a "suite" of indicators to get a complete picture,
when possible, of how the water quality and the aquatic organisms have responded to the
changes brought about the CWSRF projects. Indicators 1-3 used in combination with
indicators 4-7 give the most complete picture of environmental outcomes. For example,
Indicator 1 in conjunction with Indicator 6 might show the relationship between load
reduction and improvement in biological quality.
There are many factors relating to stream water quality, and habitat conditions that might
or might not be affected by improvements in a wastewater discharge. Load reductions
from one POTW could have a major beneficial effect on a stream or could be lost
completely given the many other sources of pollution or stream degradation. The states
emphasized that the indicators should be used together. It is important to keep in mind
the nature of the information that each indicator provides, and not to extrapolate beyond
the limits of each indicator. It is important to realize the limitations of individual
indicators in order to avoid making invalid assumptions regarding water quality and
aquatic community condition.
Because most of the current CWSRF funding is directed to POTW upgrades, expansions,
or improvements to maintain operational reliability, pilot states reported difficulty in
attributing incremental pounds of pollutant removed due to CWSRF funding. Clear,
specific, and uniformly applied guidance would need to be developed if all states were to
calculate load reduction benefits. An alternative to measuring load reduction might be to
measure reduction in concentration of pollutants. Also, the addition of the administrative
indicator measuring project types funded helps to address the issue of measuring
financing of improvements to existing, complying facilities. In addition, gains in
treatment might be offset by additional influent flows when a plant is upgraded because
of increased overall loadings if the plant also is expanded. Some states reported that
despite POTW projects providing treatment upgrades, such projects often concurrently
involve expansion to provide capacity to serve 20-year needs, rendering post-project
loads larger than pre-project loads. Discharge monitoring report data could be used to
calculate these load variations.
March 2001
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
• Most states predict that establishing confirmed links between CWSRF funding and
specific reduced health risks (Indicator 7) will be very challenging. In addition to POTW
discharges, there are many potential point and nonpoint sources of disease and health
risks in watersheds and coastal estuaries that are attributable to sources such as storm
water, combined sewer overflows, contaminated sediment removal, wildlife, and
livestock. However, establishing links between CWSRF funding and specific,reduced
health risks (Indicator 7) is possible if bacteriological data are available from project
areas during periods before and after project completion. Although it may be very
difficult to establish distinctions as to the degree of human health risk posed by different
sources of pollution, the presence of pathogenic indicator bacteria (e.g., E. coli, fecal
coliform, etc.) with or without a water-borne disease outbreak in an area, is something
than can be monitored. If a CWSRF project addressed a source of this problem, then the
'lack of high levels of potentially pathogenic bacteria subsequent to the project completion
would indicate that the CWSRF project had contributed toward reducing human health
risk.
Recommendations Related to Data
• Many states have suffered budget cutbacks in the area of environmental monitoring,
including ambient monitoring. This lack of environmental baseline data undermines a
state's ability to directly measure environmental improvements mat may be evident as a
result of implementing environmental programs and improvements such as the CWSRF.
Without ambient monitoring data, states that conduct only limited water quality
monitoring would be hard-pressed to demonstrate actual environmental improvements as
a result of environmental infrastructure improvements through CWSRF funding.
• More data are needed to support environmental indicators for NFS projects. A broader
scope of data types beyond traditional water quality parameters should be included for
NFS projects, such as biological and habitat indices (e.g., the zigzag count).
Documenting environmental changes attributable to a NFS project funded by the CWSRF
Program may require a longer period of time in order for the funded best management
practices to be reflected in improvements to water quality and aquatic biota. Indicators
such as final Indicator 4 may need more development and refinement in order to
accurately capture the benefits resulting from NFS activities.
• Several states suggested that they will collect data during the determination of TMDLs
and develop loading assumptions that could help support final Indicator 5 (waterbodies
previously impaired and now meeting designated uses as a result of CWSRF projects).
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Development, Selection, and Pilot Demonstration of Preliminary Environmental Indicators
Recommendations Related to Programmatic Issues
• Measuring environmental outcomes requires data. All states must report on the status of
their water to EPA through their water quality inventories, but the criteria for assessing
these waters vary greatly because of differing monitoring strategies, assessment
techniques, and program budgets. Consequently, the data available to use for the
CWSRF environmental indicators are inconsistent between the states. In many cases this
may not be due to a lack of water quality data, but rather to a lack of a system for
assembling and reporting the data. While some states may have biological data that
directly measure the response of the aquatic community to environmental changes, other
states simply have chemical data from the end of a pipe. States should be supported in
their efforts to monitor the environment in a manner that accurately portrays the condition
of their aquatic resources and the changes to these resources attributable to activities such
as the CWSRF Program. Until this is done, only a few states will have the data to
accurately use the indicators developed by this Task Force.
• Implementation of environmental indicators by the states should be discretionary and
should be viewed as an evolutionary process.
• The environmental indicators should be considered as a "suite" of indicators to be used at
each state's discretion and according to each state's individual needs.
• The environmental indicators would need to be accompanied by appropriate guidance
materials and concrete examples of successful application by the states prior to
implementation.
March 2001
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