;United States ; [ v
.iEnvironmeptal Protection
(Agency .-- i ". |; :
Office Off Water
EPA 842-B-93-OOT
March 1993
National Estuary
Program
Guidance
Basfe Pragrarn Analysis
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Table of Contents
I. Background ..................*....... ........................*. 1
Overview of the National Estuary Program 1
Purpose of this Document 1
Role of Characterization 3
II. Elements of a Base Program Analysis..........................6
Institutional Inventory 6
Institutional Analysis . 11
Base Program Analysis Report 15
Public Report 17
III. Bibliography
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Figures
Figure 1 Matrix of Management Conference Information
Needs 4
Figure 2 Matrix Approach for the Institutional Inventory 9
Figure 3 Sample Inventory Fact Sheet , 10
Figure 4 Checklist for Institutional Analysis 12
Figure 5 Question Guide for Institutional Analysis Interviews 13
Figure 6 Sample Base Program Fact Sheet 14
Figure 7 Sample Outline for the Base Program Analysis
Report 16
Tables
Table 1 Typical Sources of Estuary Problems ,,..,.5
Table 2 Typical Management Framework > 7
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I. Background
Overview of the National Estuary Program
Estuaries are waterways such as bays and sounds where fresh
water drained from the land mixes with salt water from the ocean.
This blend of fresh and salt water makes estuaries biologically
productive, sustaining many kinds of finfish, shellfish, marshes,
underwater grasses, and microscopic marine life. Since estuaries have
economic, aesthetic, and recreational value to people, they are
attracting a growing number of coastal residents and commercial
activities. Aquatic life and scenic values are affected in many ways by
these growing populations.
Section 320 of the Clean Water Act established the National
Estuary Program (NEP) to identify nationally significant estuaries
threatened by pollution, development, or overuse and to promote the
preparation of comprehensive management plans to ensure their
ecological integrity. The program's goals are protection and
improvement of water quality and enhancement of living resources.
To reach these goals, the Administrator of the U.S. Environmental
Protection Agency (EPA) convenes a Management Conference for each
estuary in the NEP to provide a forum for consensus building and
problem solving among interested agencies and user groups. The
Management Conference studies environmental conditions and trends
in the estuary and their likely causes, identifies the most significant
problems, and develops an action-oriented Comprehensive
Conservation and Management Plan (CCMP) to address high-priority
problems.
Purpose of this Document
Section 320 establishes several purposes (see box) for NEP
Management Conferences, including a requirement under purposes 1-3
to conduct an objective, technical assessment of the state of the estuary.
This assessment, called characterization, is the basis for defining and
selecting problems to be addressed in the CCMP. In addition, purpose 5
calls for Management Conferences to develop plans to coordinate
implementation of the CCMP by federal, state, and local agencies. Also,
purpose 7 requires the Conference to review all federal financial
assistance programs and development projects for consistency with the
CCMP.
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Background
Purposes of the Management Conference
As Defined in Section 320 of the Water Quality Act Amendments of 1987
(1) Assess trends in water quality, natural resources, and uses of the estuary
(2) Collect, characterize, and assess data on toxics, nutrients, and natural resources
within the estuarine zone to identify the causes of environmental problems
(3) Develop the relationship between the inplace loads and point and nonpoint
loadings of pollutants to the estuarine zone and the potential uses of the zone,,
water quality, and natural resources
(4) Develop a comprehensive conservation and management plan that recommends
priority corrective actions and compliance schedules addressing point and nonpoint
sources of pollution to restore and maintain the chemical, physical, and biological
integrity of the estuary,... and assure that the designated uses of the estuary are
protected
(5) Develop plans for the coordinated implementation of the plan by states as well as
federal and local agencies participating in the conference
(6) Monitor the effectiveness of actions taken pursuant to the plan
(7) Review all federal financial assistance programs and federal development projects
... to determine whether such assistance programs or projects would be consistent
with and further the purposes or objectives of the plan prepared under this section.
EPA has interpreted these purposes to call for a two-part
characterization process:
Q A technical investigation of pollution sources and their
impacts on the estuary.
Q An analysis of existing federal, state, and local resource
management programs.
This document provides guidance for NEPs on conducting a
management characterization, or base program analysis. A
companion document, Guidance on Technical Characterization for the
National Estuary Program, provides guidance on characterizing the
physical, chemical, and biological processes of the estuary and their
relationship to environmental conditions.
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Background
Role of Characterization
NEP Management Conferences follow four phases in developing
CCMPs:
Phase 1: Convening the Management Conference and establishing a
structure of committees and procedures for conducting the group's
work
Phase 2: Characterizing the estuary to determine its health, reasons for
its decline, and trends for future conditions; assessing the
effectiveness of existing efforts to protect the estuary; and
defining the highest priority problems to be addressed in the
CCMP.
Phase 3: Specifying action plans in the CCMP to address priority problems
identified through characterization and public input. The CCMP
should build on existing federal, state, and local programs as
much as possible.
Phase 4: Monitoring the implementation of the CCMP, reviewing progress,
and redirecting efforts where appropriate.
These phases need not occur sequentially; as the NEP has
evolved, EPA has encouraged Management Conferences to proceed
with the four phases simultaneously as often as possible. For example,
early results of characterization (Phase 2) may indicate obvious
management actions prior to completion of the CCMP. In these cases,
implementation of management actions should proceed using funds
other than those available under Section 320. EPA has found this
concurrent approach so effective that the Agency will base the selection
of any new estuaries on their ability to streamline the NEP phases,
focusing on estuaries where:
Q significant problem characterization is complete;
Q a management framework analogous to a Management
Conference already exists; and
Q key state and local agencies have already committed to
participate in and support the NEP process.
But to address less obvious or more complex problems, sound
characterization of the estuary's environmental and management
status is critical for developing action plans in the CCMP. During
Phase 2, the Management Conference identifies and fills in
information necessary to define priority problems, determine areas for
action, and identify appropriate corrective actions. Figure 1 outlines a
matrix of the Management Conference's major information needs.
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Background
Figure 1
Matrix of Management Conference Information Needs
Priority
Problems
Types of
Information
Desired
What activities or pollutants are
problems in the estuary?
Do they produce system-wide
impacts?
Are the impacts significant
enough to affect the entire
estuary?
Do they affect potential uses
of the estuary?
Can the causes or
sources be identified?
Do existing programs
address problems?
How effective are they?
If programs aren't effective,
why not?
What are some potential
solutions?
What institutional or
management barriers impede
solutions?
What resources (funding, staff,
public support, etc.) are
available for addressing
probems and their causes?
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PROVIDED BY THE TECHNICAL
CHARACTERIZATION
PROVIDED BY THE
BASE PROGRAM ANALYSIS
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DETERMINED BY THE
MANAGEMENT CONFERENCE
(with recommendations from
the Base Program Analysis)
During characterization and problem definition (Phase 2), the Management Conference
assembles information (rows of this matrix) about suspected high-priority estuary
problems (columns).
Each cell in this matrix actually represents from one to many pages of information
answering the row's question for that priority problem. The Management Conference
may decide to drop some priority problems from consideration (shown hatched above)
because the technical characterization indicates they are not significant enough to
require action in the CCMP.
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Background
Though essential, science cannot marshall action alone.
Decision makers must also consider whether corrective actions are
possible. Some problems, for example, may rate as high priorities for
the CCMP because mechanisms to address them are already in place or
could be readily implemented. The base program analysis, therefore,
serves as a management characterization of the estuary through a
process of:
Q describing the framework of institutions and programs
within which a CCMP will be implemented;
Q assessing the effectiveness of that framework in managing
and protecting the estuary's resources; and
Q recommending, in conjunction with the technical
characterization, issues to be addressed in the CCMP based on
potential management'. enhancements or alternatives.
Together, the technical characterization and base program
analysis create a receptive audience for program findings and
recommendations and help the Management Conference secure
effective mechanisms for addressing priority problems and their
causes.
Table 1
Typical Sources of Estuary Problems
Point Sources
Q Wastewater discharges from POTWs
Q Direct wastewater discharges from industrial facilities
Q Combined sewer overflows
G Stormwater discharges
Q Animal feedlots
G Boat discharges
Other
O Shipping and marinas
Q Dredging
Shoreline development
Freshwater inflow
Q Sea level rise
Other
Nonpoint Sources
Q Agricultural runoff
Q Urban and suburban runoff
Q Silvicultural runoff
Q In-place sediments
Q Mining runoff
Q Construction site runoff
Q Landfill runoff/Leachate
Q Septic system leaks and
overflows
Q Atmospheric deposition
Q Groundwater pollutant
transfer
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II.
Elements of a Base Program Analysis
Base program analysis offers decision makers a clearer picture of
the existing institutional "infrastructure" of the estuary. It examines
the likelihood and extent of environmental improvements that could
be achieved based on:
Q existing institutional capabilities for implementing
preventive and corrective actions;
Q potential enhancements or opportunities to close gaps and
strengthen weaknesses; and
Q value of the estuary to the public as reflected in public and
private resources directed to it.
To fully consider these factors, the Management Conference:
Q develops an institutional inventory to identify programs
likely to influence conditions in the estuary;
Q analyzes these programs for their current effectiveness; and
Q recommends management enhancements or alternatives to
improve their ability to carry out recommendations of the
CCMP.
Institutional Inventory
An institutional inventory is the first step in both the base
program analysis and in developing a process to review federal
financial assistance programs and development projects for consistency
with the CCMP. In light of both these needs, EPA has identified a
number of potentially relevant federal programs. (See bibliography at
the end of this document.) These programs are merely starting points,
however. NEP inventories are expected to identify an array of
available mechanisms to protect the estuary that go beyond basic
statutes, codes, and legal authorities. This would include powerful
influences on input and behavior such as economic incentives,
technical assistance programs, and the impacts of public pressure
factors not typically considered part of a management infrastructure.
Core elements of the inventory include program authorities,
regulatory and resource management programs, finance mechanisms,
incentive programs and voluntary initiatives, planning efforts, and
public education and technical assistance. Table 2 lists typically
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Elements of a Base Program Analysis
available management tools that should be examined for their
relevance to each NEP.
Table 2
Typical Management Framework
Below are programs, authorities, and activities which should be examined for
their potential relevance in implementing CCMPs.
Legal/Management Infrastructure
Q organizational structure
Q administrative/decision-making process
Regulatory Programs
Q laws/program authorities
Q water quality
permitting/enforcement
standard setting/criteria development
Q wetlands protection/dredging/dumping
Q remediation/emergency response
Q coastal zone management plans
Q public health/welfare
shellfish sanitation standards
septic system standards
- drinking water protection
Q hydropower licensing
Resource Management Programs
Q agriculture
Q fisheries
Q habitat/wildlife
Q parks/reserves
Finance Mechanisms
Q revenue access
Q revenue management
Q institutional arrangements
Voluntary Initiatives/Incentive Programs
Q public/private efforts
Public Education And Technical Assistance
Planning Efforts
Q growth management/corridor plans
Q land use controls
Q regional agencies
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Elements of a Base Program Analysis
Key steps in developing the institutional inventory include:
Q identifying activities or sources of concern for each potential
priority problem;
Q identifying existing programs, controls, or other tools for
managing problem sources and activities;
Q identifying standard topics to be included in the inventory;
Q reviewing existing programs, activities, or organizations to
identify those that should be added to the inventory; and
Q describing each program based on interviews, questionnaires,
and other background materials.
The information needed for the inventory lends itself easily to a
matrix approach. Such an approach, illustrated in Figure 2, has several
advantages, particularly for highlighting program operating
mechanisms and authorities.
A matrix approach organizes information along lines the
Management Conference is likely to find most useful by classifying
programs by the tools they provide and by referencing programs to
activities or sources of concern. It presents the information
consistently among issues, making it easier to update databases and
reports, as well as develop public outreach tools such as fact sheets,
newsletters, and electronic bulletin boards.
The matrix format is also particularly helpful in highlighting
programs' inadvertent or unexpected impacts on each other; for
example, large-lot zoning to preserve open space may also result ini
sprawl, habitat loss, and uncontrolled nonpoint source pollution.
Finally, presenting the institutional inventory in a matrix
simplifies the production of summary fact sheets for each program.
Figure 3 illustrates a fact sheet based on a matrix. The information in
such fact sheets can serve as the basis for further assessment of program
effectiveness in protecting the estuary and its resources and can be
revised (Figure 6) to accommodate the inclusion of new information
from the institutional analysis.
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Elements of a Base Program Analysis
-, Figure 2
Matrix Approach for the Institutional Inventory
Management
Framework
Pollutants or
Activities of
Concern
Wastewater discharges from
POTWs
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A h
SB
Direct wastewater discharges
from industrial facilities
Combined sewer overflows
Stormwater discharges
Agricultural runoff
Construction site runoff
Mining runoff
Silvicultural runoff
Septic tank leaks and
overflows
(Continue on additional pages as necessary)
Each blackened cell in the matrix represents the
intersection of a management tool with a specific
pollutant source or activity of concern. Each cell
then serves as the basis for more detailed
factsheets that represent standard data on issues
of concern to the Management Conference.
SAMPLE INVENTORY
FACTSHEET
Name of Program:
Priority Problem Addressed:
Implementing Organization:
Program Authorities:
Program Description:
I. Purpose
IL Functions
HI. Geographic Jurisdiction
IV. Resource or Activity Managed
V. Funding
VL Administration
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Elements of a Base Program Analysis
Figure 3
Sample Inventory Fact Sheet
Name of Program:
Priority Problem Addressed:
Implementing Organization:
Program Authorities (laws, ordinances, contract):
Program Description:
I. Purpose
II. Functions
A. Regulatory
B. Resource Management
C. Finance Mechanisms
D. Voluntary Initiatives/Economic Incentives
E. Public Education/Technical Assistance
F. Planning
m. Geographic Jurisdiction
IV. Resource or Activity Managed
V. Funding
A. Source of Funding
B. Funding Rationale
C. Allocation of Funding
D. Proposed Budget and Actual Funding
E. Other Resources Available
VI. Administration
A. Organizational Structure
B. Decision-Making Process
C. Linkages to Cooperating Agencies
D. Total Staff
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Elements of a Base Program Analysis
Institutional Analysis
After the institutional inventory has identified the programs
most relevant for managing the estuary, those programs are analyzed
further to describe their capabilities and effectiveness in relation to
problems likely to be addressed in the CCMP. This analysis considers
program funding issues as well as management strengths or gaps, and
identifies an array of potential management enhancements or
alternatives for consideration by the Management Conference. The
focus is on how the framework and individual programs or activities
within it are able to protect the estuary, not on the general effectiveness
of the agencies responsible for those activities.
Figure 4 shows a checklist of major questions to address in the
institutional analysis. The checklist is intended to ensure that the
institutional analysis includes as much objective, quantitative
information as possible, including data on resources invested and
environmental results. This is also an opportunity to update the
inventory to include any significant changes in programs, authorities,
or resources committed to an existing activity. The checklist also seeks
to ensure that a variety of views are represented in the analysis. The
credibility of the analysis depends on incorporating the insights of both
vested program participants and disinterested observers. In addition to
appropriate members of the Management Conference, commenters
should include:
Q program staff and mangers;
Q public and private sector individuals who deal with or are
subject to the program;
Q key legislative or political figures;
Q persons with a stake in the resource;
Q implementing agencies, particularly at the local government
level; and
Q informed members of the public.
The perspectives of these reviewers will provide more detail on
each activity's strong points, gaps in authority, and any other factors
that may hamper its effectiveness, as well as highlight areas for
improvement. Figure 5 is a sample question guide based on the
checklist. Figure 6 shows an inventory fact sheet revised to include
information from the interview.
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Elements of a Base Program Analysis
Q
Figure 4
Checklist for Institutional Analysis
Do existing programs already address priority problems?
laws/program authorities
How effective are they?
enforcement successes
sustained budgets and staff
environmental results
public resistance to budget cuts
If programs aren't effective, why not?
inadequate enforcement or limited authority to enforce
inadvertent or unanticipated impacts
inadequate staff or budget support
lack of monitoring to document results
regulatory gaps
lack of technical/scientific bases for decisions
What institutional and management barriers impede solutions?
unclear program accountability
inconsistent or conflicting program missions
pressure to address symptoms rather than causes
fragmented program responsibilities
restricted financing or revenue-raising authorities
overlapping or duplicative responsibility
lack of coordination mechanisms
What are some potential solutions?
consistent program accountability
cross-program review or coordination
increased support for enforcement
increased funding and staff allocations
technical assistance to improve implementation,
particularly for local governments
increased monitoring
new legislation or enabling authorities
What resources (funding, staff, public support, etc.) are
available for addressing problems and their causes?
dedicated funding or authority to raise or earmark funds
complementary activities of other programs
lobbying/pressure from public and organized groups
leveraged resources from other programs
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Elements of a Base Program Analysis
Q
Q
Q
Q
Q
Q
Q
Q
Q
Q
Figure 5
Question Guide for
Institutional Analysis Interviews
Has the program or activity changed since information was gathered for the
institutional inventory? Information such as an agency's mandate and goals,
position in its government's organization, resource trends, scope of
jurisdiction and responsibilities are very important in evaluation.
What are the most successful aspects of this program or activity things that
work well and should be capitalized upon in the future?
What innovative programs or approaches could serve as models for future
activities?
Are there any gaps in existing statutory authority that limit ability to take action
on one or more of the priority problems?
What kinds of problems has this program experienced, aside from a lack of
authority? For example:
unclear goals, responsibilities, or procedures?
conflicting efforts by other programs?
difficulties in coordinating with other organizations?
drastically insufficient resources?
Do other activities duplicate any of this program's efforts?
Are there complementary programs that enhance each other's effectiveness?
Are there programs that impede each other's effectiveness?
How much support does the program enjoy from the public and the legislature?
What is the extent of cooperation with other agencies and the potential for
leveraging?
What specific actions could improve the effectiveness of the institutional
framework?
What current activities should be accelerated or expanded?
« What new efforts should be instituted? Are new authorities or entities
required?
« What obstacles to effectiveness must be overcome?
« What should be the Management Conference's action priorities?
For each action suggested, what are the appropriate tasks, actors, and timing?
What are the potential barriers to redirection? How can support be generated?
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Elements of a Base Program Analysis
Figure 6
Sample Base Program Fact Sheet
This fact sheet shows an inventory fact sheet that has been updated. The new
Section VIE summarizes discussions on the effectiveness of the program and
identifies the source of the observations.
Name of Program:
Priority Problem Addressed:
Implementing Organization:
Program Authorities (laws, ordinances, contract):
Program Description:
I. Purpose
II. Functions
A. Regulatory
B. Resource Management
C. Finance Mechanisms
D. Voluntary Initiatives/Economic Incentives
E. Public Education/Technical Assistance
F. Planning
m. Geographic Jurisdiction
IV. Resource or Activity Managed
V. Funding
A. Source of Funding
B. Funding Rationale
C. Allocation of Funding
D. Proposed Budget and Actual Funding
E. Other Resources Available
VI. Administration
A. Organizational Structure
B. Decision-Making Process
C. Linkages to Cooperating Agencies
D. Total Staff
VH. Report
Interviewee:
Perceived Strengths:
Perceived Weaknesses:
Effects From or On Other Activities:
Suggested Improvements:
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Elements of a Base Program Analysis
Base Program Analysis Report
The final base program analysis presents findings on the overall
management framework for the estuary based on a synthesis of the
institutional analysis and consideration of crosscutting issues. These
findings form the basis of recommended management changes,
including suggestions for financing mechanisms. They further suggest
issues that should be addressed as priorities in the CCMP because of the
feasibility of corrective actions.
Figure 7 suggests an outline for the base program analysis report
based on the information needs first identified by the Management
Conference. In this format, the report first briefly describes the nature
and extent of each priority problem, summarizing the conclusions of
the technical characterization. Then, it integrates and condenses the
relevant inventory and assessment fact sheets pertaining to the priority
problems. Finally, the report discusses gaps and management needs
documented in the institutional analysis.
This discussion is the heart of the base program analysis and
identifies resource and management changes that must occur if priority
problems are to be successfully addressed in the CCMP. The intent is to
provide clear, objectively documented conclusions that provide the
Management Conference with a number of options for formulatine the
CCMP. 5
A useful approach to developing management options is to
examine case studies in areas of particular concern to the Management
Conference, such as the framework for managing development, or the
process of issuing permits. By comparing initial program goals with
final administrative and environmental outcomes, case studies can be
especially helpful in reviewing such complex issues as the adequacy of
scientific and technical support for decisions, the standards used in
decisionmaking, the consistency of decisions, and the unavoidable
political considerations affecting decisionmaking.
Case studies are also an opportunity to provide real world
information on the costs of pollution controls and to review financial
mechanisms available for implementing them. Identifying sources of
funding in advance is critical to the success of the CCMP. EPA has
studied a number of approaches for financing resource management
(See bibliography at the end of this document), including pollution
prevention and economic and market incentives. Economic incentives
include tax subsidies or credits, grants, and awards, while economic
disincentives usually include effluent or emission fees and fines.
Another financing option is to establish special-purpose governments -
- such as regional authorities, districts, compacts, or commissions to
assist in regional projects or projects with a limited group of
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Elements of a Base Program Analysis
Figure 7
Sample Outline for the
Base Program Analysis Report
Base Program Analysis Report
For Moonlight Bay
I. Executive Summary
II. The Estuary and Its Problems
(brief overview of technical characterization findings)
A. Priority Problem #1
(a problem the Management Conference has decided to address in the CCMP)
1. The Existing Framework for Managing the Problem
(from inventory fact sheets)
2. Strengths and Weaknesses of Existing Programs
(from assessment fact sheets)
3. Synergism or Conflicts Among Existing Programs
(from assessment fact sheets)
4. Gaps in the Institutional Framework
(from interviews and other sources)
5. Recommended Improvement Actions
(from assessment fact sheets and other sources)
B. Priority Problem #2
(repeat section headings from Priority Problem #1)
N . Priority Problem #n
(repeat section headings from Priority Problem #1)
III. Cross-Cutting Findings and Recommendations
IV. Case Studies
V. Alternative Management Options
VI. Appendix Inventory and Assessment Fact Sheets
(optional)
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Elements of a Base Program Analysis
beneficiaries or purposes. Although limited, special-purpose
governments typically have powers to raise and manage money to
finance operation, construction, and upkeep of physical plants; many
have authority to levy ad valorem taxes or to issue their own bonds. A
case study examining the effectiveness of organizations such as the
Cape Cod Commission or the Puget Sound Water Quality Authority
offers a chance to apply the lessons of their experience and avoid
mistakes or lost opportunities.
Despite the availability of such models, however, the universe
of financing options can be limited. Local governments in particular
often are restricted by state constitutions from raising revenue for
certain purposes. The base program analysis, thus serves as an
important catalyst to build financing capacity for environmental
quality in general, as well as for specific CCMP action plans.
Public Report
Although components of the technical characterization and base
program analysis may be too lengthy and complex for broad public
distribution, the public will be extremely interested in the results of
these studies. To facilitate the dissemination of this information, the
Management Conference may wish to publish a State of the Estuary
Report aimed at audiences with no scientific or regulatory background
in environmental protection or natural resources management. This
report can summarize clearly the key findings of both characterizations,
describing the priority problems, the existing management framework,
and potential avenues for improvement. All estuary programs can
benefit from a professionally written and visually attractive State of the
Estuary Report that highlights the main findings and conclusions for
the general public.
17
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III. Bibliography
Federal Financial Assistance Programs: Targeting Programs Applicable to
Coastal Management; Washington, DC. U.S. Environmental Protection
Agency; EPA 503/8-90-001; November 1989.
Financing Marine and Estuarine Programs: A Guide to Resources;
Washington, DC; U. S. Environmental Protection Agency; EPA 503/8-
88-001; September 1988.
Financing Strong State Water Programs in New Ways: Proceedings of a
National Workshop; Washington, DC; U. S. Environmental Protection
Agency; August 1989.
Local Government Water Quality Finance Guidebook; Olympia,
Washington; prepared for Puget Sound Water Quality Authority.
Protecting Coastal and Wetlands Resources: A Guide for Local Governments;
Washington, DC; U.S. Environmental Protection Agency; EPA 842-R-
92-002; October 1992.
Saving Bays and Estuaries: A Primer for Establishing and Managing Estuary
Programs: Appendices G, H, and I; Washington, DC; U. S.
Environmental Protection Agency; EPA 503/8-90-005; September 1990.
Small Community Financing Strategies for Environmental Facilities;
Environmental Financial Advisory Board, August 9, 1991.
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