vvEPA
Agency
Region 5
536 South Clark Street, Room 932
Chicago, Illinois 60605
Washington County Project
Institutional and Legal Complexities
of Nonpoint Source Pollution Control
Summary Report
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The U.S. Environmental Protection Agency was created because of increasing
public and governmental concern about the dangers of pollution to the health
and welfare of the American people. Noxious air, foul water, and spoiled
land are tragic testimony to the deterioration of our natural environment.
The Great Lakes National Program Office (GLNPO) of the U.S. EPA was established
in Region V, Chicago, to provide specific focus on the water quality concerns
of the Great Lakes. The Section 1u8(a) Demonstration Grant Program of P.L
92-500 (1972 Amendments to the Federal Water Pollution Control Act) is
specific to the Great Lakes drainage basin and thus is administered by
the Great Lakes National Program Office.
Several sediment erosion-control projects within the Great Lakes drainage
basin have been funded as a result of Section 108(a). This report describes
one such project supported by this office as a part of our responsibility to
improve water quality in the Great Lakes.
We hope the information and data contained herein will help planners and
managers of pollution control agencies to make better decisions in carrying
forward their pollution control responsibilities.
Madonna F. McGrath
Director
Great Lakes National Program Office
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INSTITUTIONAL AND LEGAL COMPLEXITIES OF
NONPOINT SOURCE POLLUTION CONTROL
Washington County Project:
Summary Report
Frederick W.Madison
Project Director
Project funded by
U.S. Environmental Protection Agency
Great Lakes National Program Office
536 South Clark Street, Room 932
Chicago, Illinois60605
Ralph G. Christensen Carl D. Wilson
Section 108(a) Program Project Officer
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Grant Recipient
Wisconsin Board of Soil and Water Conservation Districts
Cooperating Agencies
U.S. Geological Survey
U.S. Soil Conservation Service
Wisconsin Department of Natural Resources
Wisconsin Geological and Natural History Survey
Washington County Soil and Water Conservation District
Southeastern Wisconsin Regional Planning Commission
National Association of Conservation Districts
The University of Wisconsin System
Village Board of Germantown
Washington County Board
This report has been reviewed by the Environmental Protection Agency and
approved for publication. Approval does not signify that the contents
necessarily reflect the views and policies of the Environmental Protection
Agency, nor does mention of any trade names or commercial products constitute
endorsement or recommendation for use.
Additional copies of this document may be purchased from the National
Technical Information Service, Springfield, VA 22161.
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CONTENTS
5 Introduction
6 The Washington County Project
7 The Political Setting
8 Institutional Complexities Involved
8 Technical Dimensions of the Problem
9 Water Quality Monitoring
10 Institutional Strategies
11 Agency Linkages
12 Ordinance Development
14 The Rural Ordinance
15 Project Impacts of the Rural Ordinance
16 Conservation Tillage
16 Shoreland Areas
17 Urbanizing Areas
18 The Education and Information Effort
20 The Statutory Framework for Nonpoint Control
21 The Wisconsin Fund
21 Recommendations
23 Selected Project Publications
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«' -<- li?"
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Introduction
In the late 1960s the U.S. Congress
took a hard look at the nation's water
quality problems. The results of this
assessment were discouraging. Despite
a substantial financial investment in a
sewage treatment plant construction
program, improvements in water quality
were not apparent; the nation's waters
were, if anything, becoming more
polluted.
In response to this, Congress amended
the Federal Water Pollution Control Act
in 1972. The passage of this act—P.L
92-500—marked the beginning of a
sweeping new strategy designed to clean
up the nation's lakes and streams.
Pollutants would no longer be treated in
receiving waters; they would be treated
at their sources. Under this strategy,
effluent discharges from industries and
municipalities as well as nutrient, sedi-
ment, pesticide and heavy metal losses
from farm fields, city streets, parking lots
and lawns were to be controlled. The
terms "point source" and "nonpoint"
were coined to describe these situations.
P.L. 92-500 was a major, and in many
respects, a controversial piece of legis-
lation. An accelerated program of sewage
treatment plant construction was author-
ized and a permit system for pollutant
discharges was established. Extensive
planning requirements were imposed on
state, regional and local agencies. The
mandate was clear: treat pollution at
its source.
Point source problems were relatively
easy to identify and their solutions were
limited primarily by a lack of adequate
treatment technology and a lack of funds.
The nonpoint source problem, however,
was much more complex. Nonpoint
sources are difficult to define and
quantify and management strategies are
not clear. The institutional and legal
issues relating to the authority of
agencies to develop and implement non-
point pollution control programs were
unresolved.
In early 1973, a Wisconsin Governor's
Conference on Sediment and Erosion
identified sediment as a majqr pollutant
and urged the development of programs
to provide sediment control. At about the
same time, a major project to identify the
sources and assess the impacts of urban
nonpoint source pollution was initiated
on the Menomonee River in the Mil-
waukee metropolitan area by the
Wisconsin Department of Natural
Resources (DNR) and the University of
Wisconsin-Water Resources Center
(WRC) under the auspices of the Inter-
national Joint Commission (IJC). The IJC
project was part of a series of projects
initiated by Canada and the United States
as a result of the international water
quality agreements of 1972.
A comprehensive study in a specific
geographic setting was needed to
examine the complexities of the sedi-
ment control problem from its technical
side and from its legal, social and in-
stitutional aspects. A water quality
monitoring program was essential to
quantify the sediment and erosion prob-
lems arising from selected land uses. The
existing legal, economic, institutional and
political framework for sediment control
had to be scrutinized. Local decision
makers had to develop and implement
legal and institutional approaches to
sediment control problems.
Public involvement in the entire
process was critical to provide a
thorough understanding of the sediment
problem and its solutions and ensure a
general acceptance of measures pro-
posed to meet sediment control ob-
jectives. The successes and failures had
to be carefully documented so that the
experiences gained could be effectively
transferred to other areas.
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The Washington County Project
Washington County in southeastern
Wisconsin appeared to offer an ideal
location for the study described.
Although a predominantly rural area, the
county was under tremendous urban
pressures from adjacent Milwaukee
County and the Milwaukee metropolitan
area. Elected officials, political leaders
and private citizens were eager to seek
solutions to the pressing land use and
water quality problems associated with
growth and changing use patterns.
In this setting, then, the Washington
County Project was conceived. Staff of
the University of Wisconsin pulled to-
gether a coalition of five federal agencies,
four state agencies, and four local and
regional agencies "to demonstrate the
effectiveness of land control measures in
improving water quality, and to devise the
necessary institutional arrangements for
the preparation, acceptance, adoption
and implementation of a sediment
control ordinance applicable to incor-
porated and unincorporated areas on a
county-wide basis."
The Washington County Project, de-
signed as a sediment control project, did
not attempt to evaluate and seek
solutions for all types of nonpoint source
pollution. In rural areas sediment control
with its associated nutrients and pesti-
cides may be synonymous with nonpoint
source control. In urban areas, however,
sediment control is only part of the
problem. Sediment is, from a water
quality standpoint, a relatively minor
Study areas
Kewaskum
watershed
WASHINGTON COUNTY
Germantown
watershed
•• • "•" • ^""i:.T"T
component when compared to toxins,
heavy metals, etc.
The Washington County Project was
organized with the involvement and
cooperation of agencies from all levels of
government. The goal was to document
sediment problems in urban and rural
areas, to define the effectiveness of
control measures for solving those
problems, and to weave together into an
Great Lakes
Drainage Basin
effective coalition the governmental
institutions which have responsibility for
and jurisdiction over land use/water
quality problems. Once problems were
defined and solutions were developed,
the ultimate challenges facinglhe
project were to work with local decision
makers to implement these proposals
and to observe and document the
successes and failures of these efforts.
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The Political Setting
The decision to control pollution at its
source was controversial. In rural areas,
the specter of government regulation
of farm land and the resulting loss of
individual rights was raised. In many
places—including Washington County—
the mood was one of resignation.
Regulation was not a popular notion, but
most people agreed that if it were to
come, then at least it ought to be at the
local level.
P.L 92-500 was not, in the minds of
some people, clear on the question of
regulation. Section 208 called for the
development of plans for the control of
nonpoint sources of pollution and for the
development of regulatory programs
"wherever feasible." It was not clear,
however, if regulatory programs were
required before the U.S. Environmental
Protection Agency (EPA) would approve
"208" plans. A major objective of the
Washington County Project was to test
the potential for a regulatory program.
From the time of the passage of P.L.
92-500, the nonpoint source program was
the poor country cousin of the point
source programs. Billions were author-
ized for the construction of sewage treat-
ment plants while only planning dollars
were provided for nonpoint programs. A
series of court tests in the early 1970s
established that "208" planning had to
include entire states and cover both point
and nonpoint sources. A provision of
P.L 92-500 stated that no money could be
provided for a treatment facility unless
that facility was part of a "208" plan
which presumably established strategies
and priorities for the control of pollution
from all sources. This authority has yet
to be exercised.
In 1973 the State of Wisconsin
attempted to develop rules regarding the
handling of animal wastes. Howls of
protest were heard. Hearing rooms were
filled with irate farmers who feared
prohibition of winter spreading of
manure—a necessary evil in a dairy state
like Wisconsin. The state legislature
responded by passing a law which stated
that no regulation of animal wastes could
be adopted without the legislature's
approval. This constraint remained in
effect until 1980 and prevented the
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development of the mandated state
permit system for large animal
concentrations.
Fears by farmers of regulation and
overreaction by legislators forced non-
point planning programs to assume a low
profile. Additionally, not much was known
technically about the nonpoint problem.
Planners found it difficult to plan for
something about which they basically
knew nothing.
The EPA was well organized to handle
the expanded construction grant program
authorized by P.L 92-500. Basically, it
was a program they had handled for
years. An office of nonpoint programs
was established however, but it was
small and understaffed. Communi-
cations between EPA and the U.S.
Department of Agriculture (USDA), which
would ultimately play an important role
in nonpoint control, were virtually not
existent.
Institutional Complexities
Involved
Responsibility for the administration
and implementation of water resource
programs and policies at the national
level has followed a much different path
than that for land management pro-
grams. Historically, the federal govern-
ment has asserted its control over water
policy and has implemented a variety of
programs involving dams and flood
control, canals, irrigation and hydro-
power. Federal involvement in water
pollution abatement dates back to about
1900, although the role the government
actually played was limited until the
1960s and 1970s. Basically, states have
been responsible for regulating those
water problems not covered under federal
programs and, more recently, have been
charged with implementing federal
policies for pollution abatement. Local
involvement in water programs has been
minimal.
Land management programs and
policies have developed much differently
than water resource programs and
policies. These programs and policies
have emphasized the individual rights of
the landowner. The authority to regulate
the individual's use of the land has been
reserved for the states through their
police power. Over the years, much of
that responsibility has been delegated to
local government. Federal involvement in
land management programs has always
been minimal and primarily supportive;
witness, for example, the technical
assistance and cost sharing programs of
the USDA.
Nonpoint source pollution control
posed an interesting challenge because
it would require treating land use abuses
to restore and protect surface water
quality. Technically the land use
problems appeared to be solvable, but
when considering the historical
dichotomy between land and water
policies and programs the challenges
seemed insurmountable.
There were two options for the
Washington County Project: propose a
series of new agencies at all levels of
government to deal with nonpoint prob-
lems; or develop linkages between and
among existing agencies to meet new
programs and policies. The project
followed the latter course and
emphasized the analysis of the functions
and operation of existing units of govern-
ment, of statutory weaknesses and im-
perfections, of current program im-
plementation, and of manpower and
financial needs.
Technical Dimensions
of the Problem
Initially, not much was understood
about the nonpoint source pollution
problem. Estimates were made of the
magnitude but its total dimensions were
unclear. Some land uses—residential
construction and large animal feed-
lots—had been examined in some detail
and their sediment and nutrient yields
were fairly well quantified. In urban areas,
however, little was known about runoff
from established residential areas,
highway interchanges or manufacturing
and industrial sites.
In agricultural areas the situation was
equally complex. Extensive work by the
USDA and the universities had validated
the Universal Soil Loss Equation (USLE),
which provided information on soil loss in
individual fields under specific man-
agement, crop, slope, climatic and soil
conditions. Conservation practices to
reduce soil erosion and conserve water
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had been applied to the land for more
than 30 years in this country, but the
effectiveness of these practices from a
water quality standpoint had never been
tested. The USLE did not provide a
reliable determination of how much of the
soil lost from the land actually reached
the lakes and streams. Intuitively, it
appeared that many of the well
established land management practices
would conserve soil and protect water
quality. This idea, however, needed to
be examined.
Water Quality Monitoring
Field monitoring programs were
established in the rapidly urbanizing
southeastern corner of Washington
County around Germantown and in a
rural part of the county near Kewaskum
where well-operated, average-sized dairy
farms were located in two moderately
sized watersheds.
Legend Acres and Old Farm sub-
divisions were each a part of the same
cornfield when the project started.
Monitoring equipment was installed at
key locations in these developments
during the early stages of land forming
and street construction. In the initial
plans, about half of the land area in each
subdivision was to be treated and con-
struction was to proceed normally on
the remainder of the land. Treatment
involved stabilizing stockpiled soil and
mulching and re-vegetating undeveloped
lots. These practices would reduce
erosion while roads were laid out, lots
were graded and individual homes were
constructed. Data from the monitoring
stations would then be compared to
assess the effectiveness of the treatment
measures.
The first year of the project was an
extremely dry period climatically and a
time of fairly rapid economic growth. As
a result of these two factors, home
construction in the subdivisions was
nearly complete in about 11/2 years-
some 3 to 4 years ahead of projections.
Thus, treated and untreated areas could
not be compared, but data from the
period of initial construction showed
annual sediment losses ranging from
16,000 to 36,000 kg/ha. During the second
year, sediment yields at two of the sites
dropped to 2,800 to 4,600 kg/ha. These
figures are interesting in that during this
period most of the building was com-
pleted, lawns were established and lots
were stabilized. These results indicated
the need for a second level of control
designed to minimize erosion during the
construction of individual homes.
In the agricultural watersheds
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monitoring stations were established at
outlet points to determine total nutrient
and sediment outputs and at selected
sites within them to isolate specific land
uses. In one of the watersheds, treatment
involved the installation and implementa-
tion of conservation practices such as
contour stripping and grassed water-
ways. This resulted in a 50 to 60%
reduction in total nitrogen and phos-
phorous and nearly a sevenfold reduction
in sediment at the bottom of the
watershed.
At one site—a dairy barnyard/feed lot
area—results were even more dramatic.
Reductions of 94% for total phosphorous
and 83% for total nitrogen followed the
construction of an improved barnyard
area. Annual sediment yield dropped
from 5,500 to 200 kg/ha at this site.
Institutional Strategies
The Washington County Project's
monitoring program was established to
quantify the nonpoint pollution problem
in selected settings, to assess the
effectiveness of control measures in
reducing the problem and, perhaps most
importantly, to provide the technical
back-up for programs designed to control
this diffuse type of pollution. On the
premise that local units of government
were best suited to meet the challenge
of controlling nonpoint source pollution,
project attention was focused on
identifying the appropriate local govern-
mental unit and defining its role in the
process and on establishing linkages
between it and other land and water
agencies at all government levels.
A detailed analysis of the county board
in Washington County indicated that it
might be well suited for the task. The
public did not appear to understand the
functions of the board and elected
supervisors had very little contact with
their constituents. To political analysts,
this appeared to be an ideal govern-
mental unit to deal with the controversial
issue of the regulation of agricultural
land.
Powers of county boards in Wisconsin
are limited because they are an arm of
state government and have only those
powers which the state grants them.
Additionally, they are restricted in their
authority to the unincorporated areas of
the county. Chapter 92 of the Wisconsin
Statutes, however, created Soil and
Water Conservation Districts (SWCDs or
the districts) as a special purpose unit of
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government to be coterminous with
counties. Furthermore, SWCD super-
visors are designated by statute to be
those county supervisors who serve on
the county board's Agriculture and
Extension Education Committee. This
linkage, plus some additional authority
provided by the statutes, made the SWCD
the ideal focal point for the development
of programs for controlling nonpoint
source pollution.
Although questions were raised as to
whether or not Chapter 92 provided
adequate authority to deal with the broad
spectrum of land use-water quality
problems, it was clear that SWCDs
should initiate the development of
remedial programs. The SWCDs in
Wisconsin, however, were underfinanced
and understaffed and the supervisors
were often unaccustomed to and uninter-
ested in taking on the assertive role that
this new leadership would require. An
exhaustive review of the statutory
authorities available to the districts and
counties concluded that the legal tools
to do the job existed, although certain
improvements and clarifications in the
statutes would be required in the
long run.
Agency Linkages
The key to the success of any non-
point control program at the local level
would be the involvement of the USDA's
Soil Conservation Service (SCS) and the
Agriculture Stabilization and Conser-
vation Service (ASCS). The SCS is a
technical assistance agency with a
mandate to provide, at the direction of
the SWCD, management and design
assistance to landowners in reducing soil
erosion. The ASCS, through its Agricul-
tural Conservation Program (ACP),
provides cost sharing to farmers and
landowners for the installation of
conservation practices.
Over the years, these two programs—
in many areas, including Washington
County—have not been closely co-
ordinated. Decisions on ACP investments
are made by a separate committee
elected by rural residents. Project
research showed that in Washington
County the SCS spent over 50% of its
time providing technical assistance for
ACP projects, yet the SWCD had little, if
anything, to say about the approval of
those projects. ACP projects were
randomly spread across the county with
little apparent relationship to areas of
erosion or water quality problems.
Likewise, SCS assistance in Washing-
ton County and elsewhere was provided
to farmers who chose to participate in
the program; little or no effort was made
to involve farmers in selected critical
erosion areas in the program. Conser-
vation planning was a slow and cumber-
some'process which resulted in extensive
plans seldom used by farmers. Close
coordination and some redirection of
these programs will be essential to the
successful implementation of rural
nonpoint pollution control programs.
Ordinance Development
One of the goals of the Washington
County Project was to develop a
mechanism for sediment control on a
county-wide basis applicable to incor-
porated and unincorporated areas. The
sediment problems were readily
identified—the control of construction
site erosion, primarily a concern in
urban areas, and the reduction of
sediment and nutrient losses from agri-
cultural activities. The statutory
separation that exists in the Wisconsin
statutes between incorporated and
unincorporated areas would hamper
efforts to achieve uniformity.
Chapter 236 of the Wisconsin statutes
requires a potential subdivider to submit
plans for development to a variety of
local and state agencies for review and
approval. Most states have similar
requirements in one form or another.
Normally, plan review includes only such
things as grades, storm sewer capacity,
septic tank suitability if appropriate,
and the like. Any provision in the plans
to control sedimentation and erosion
during construction when topsoil and
vegetation are removed, exposing
subsoils to the erosive forces of rainfall
and wind, was commonly overlooked.
The solution seemed fairly straight-
forward—require that developers include
adequate provisions for erosion control at
the time they are preparing plans for
streets, sidewalks and sewers, etc. In
Wisconsin, permits for subdivision con-
struction in unincorporated areas are
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Wisconsin's Organizational Structure for Water Quality Management
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12
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usually issued by the county zoning
administrator. Thus, the proposal was
made to require the developers to add
erosion control plans to the plans
submitted to the county zoning office.
The technical expertise of county
government to assess the effectiveness
of the proposed erosion control
measures was immediately questioned.
The answer was obvious—the SWCD
with its staff and ties to the SCS was well
suited for the task.
With all this in mind, the Washington
County Project staff developed a model
sediment control ordinance which
required the submission, review and
approval of erosion control plans as a
part of the plat review process. In the
drafting of the ordinance, great care was
taken to make the review process as
painless as possible for the developer
and to insure that the review of the
erosion control provisions did not
increase the time involved in the overall
review of the plat. The role that the
SWCD could play in this process was
unclear in the Wisconsin statutes. Rather
than risk any legal challenge, the
ordinance proposed that the SWCD make
recommendations on the adequacy of
the plans to the zoning administrator who
clearly had approval authority.
Once drafted, the model ordinance
was widely circulated among county and
town officials and town legal repre-
sentatives. Many meetings were held and
a variety of constructive suggestions
were made. Whenever appropriate, these
suggestions were incorporated in the
model ordinance. Public hearings held
before the county zoning committee were
attended by two people, both of whom
testified in favor of the proposed legis-
lation. County Board action in favor of the
ordinance was unanimous.
In Wisconsin, civil towns have the
authority to adopt village powers.
Although the full implications of this are
not clear, village powers do provide towns
with planning and zoning powers if they
so choose. Those towns in Washington
County which have taken on these
responsibilities immediately added the
county-adopted provisions for erosion
control to their existing subdivision
controls.
Adoption of the model ordinance in
incorporated areas—cities and villages—
posed another set of problems. Most
cities, for example, have their own
engineers and thus may have the
capability to review plans for sediment
and erosion control themselves. The
project strategy was to propose to the
cities and villages that they adopt the key
provisions of county ordinance, namely,
that plans for erosion control during sub-
division construction be developed. It
was also suggested that these govern-
mental units review the plans themselves
or submit them to the SWCD for advisory
review. The Village of Germantown,
which previously had become a co-
operator with the SWCD for assistance
with erosion control problems, chose
to utilize its engineer for review. The
City of West Bend, however, entered into
a memorandum of understanding with
the SWCD which established the SWCD
as the review agency. Ultimately, all the
incorporated areas in Washington
County adopted the project-developed
ordinance in one form or another.
As indicated previously, water quality
monitoring data from the subdivisions
in Germantown suggested that ap-
preciable amounts of sediment were
being generated from the construction
of individual homes. Mechanisms to
control this probem appeared elusive.
The problem stems from the fact that
homes in subdivisions are often built by
individual contractors rather than by the
original subdivider. For these home
contractors, time is literally money and
houses need to be finished as quickly as
possible. Much of the specialized work-
plumbing, dry walling and wiring—is
subcontracted out. None of the people
involved have much of a stake in seeing
to it that erosion is controlled on the lot
during construction.
The Village of Germantown, aware of
project data and plagued with sediment-
clogged streets and storm sewers, added
provisions covering sediment control to
their requirements for individual home
construction permits.
The project worked closely with the
Village of Germantown, local con-
tractors and individual homeowners to
provide solutions to this problem.
Demonstrations were established to
show how simple practices, many of
which involve little or no financial outlay,
can be installed onsite to alleviate many
of these erosion problems. Brochures
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describing the techniques were written
for contractors. A mechanism for pro-
viding state cost sharing assistance for
urban erosion control was tested
successfully.
As a result of the project, a uniform
mechanism for sediment and erosion
control during subdivision construction
has been established in Washington
County. Acceptance of and compliance
with the new requirements has been
excellent. Problems in determining
compliance were anticipated as zoning
officials in the county did not feel that
they were sufficiently trained in erosion
control technology to determine whether
or not plans were being followed. Tech-
nicians from the SCS and SWCD agreed
to do onsite inspections where necessary.
Guidelines indicating what was
expected of developers under the new
ordinance were prepared. Concerns for
increased costs due to the installation
of the required measures failed to
materialize. Most importantly, the
new requirements were developed within
existing statutory frameworks. New
legislative mandates were not required.
The Rural Ordinance
Developing an ordinance to control
sediment from agricultural lands in rural
areas posed a much more complex set
of problems. What standards would be
established? How and by whom would
those standards be administered and
enforced? What agencies would be
involved and what would their roles be?
Under what statutory authority would the
program be developed?
The question of standards was
particularly difficult since there were
several options. Stream standards, under
which levels for nutrients and sediment
would be established for various stream
segments, was one possibility. The
problem with this approach was that
even though water quality monitoring
might indicate elevated levels of one
pollutant or another, it would be impos-
sible to say from where in the watershed
a particular pollutant was coming. The
only way to attempt to reduce the
excessive pollutant loading would be
to treat the whole watershed, a cumber-
some and expensive strategy.
Another way to solve these problems
would be to mandate "wall-to-wall"
conservation, which is to say simply that
a conservation plan would be required for
each farm. This is a desirable goal, but
probably unrealistic. In Washington
County, during the mid-1970s and after
more than 30 years of government
programs, more than 100,000 acres of
farmland (about 65% of the county total)
was not covered by a conservation plan.
Planning was proceeding in the county at
a rate of about 3000 acres per year and
at existing manpower levels at least 30
more years would be required to
complete planning for the county. The
existence of a conservation plan for each
farm, however, does not guarantee that
the plan is followed. Some type of
inspection and enforcement program
would be needed to insure compliance,
but the manpower was simply not avail-
able for this type of effort.
Another strategy, and that which the
Washington County Project chose to
pursue, was the development of
performance standards for individual
farm units. The concept is relatively
simple: each farmer must meet a per-
formance standard; his/her farm must
not exceed a certain rate of sediment
loss as determined by the USLE. There
are distinct advantages to this approach:
it does not dictate directly how farmers
must farm, it is based on the "tolerable
soil loss" (T value), which is an accepted,
uniform standard for soil conservation,
and it is administratively feasible.
Project staff, utilizing the authorities
of Chapter 92 of the Wisconsin Statutes,
drafted a rural sediment control
ordinance for Washington County. The
ordinance prohibited long-term average
soil losses >3 tons/acre/year for each
farming unit and prohibited losses
>9 tons/acre/year for any 200 square
foot area (approximately 1 acre). This
latter caveat was designed to meet the
situation where a farm unit meeting the
overall soil loss standard might have
small critical erosion areas that con-
tribute excessive amounts of sediment.
Chapter 92 provides SWCDs with the
authority to develop and implement an
ordinance of this type if a majority of the
voters residing in the area to be affected
approve it in a referendum. The project's
draft ordinance was reviewed extensively
with the county SWCD supervisors and
the decision was made to take it to
referendum in selected areas of
Washington County. Unfortunately
governmental support for regulatory
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programs at the state and federal levels
collapsed at about this time. Without
pressure from external sources Wash-
ington County could not be expected to
quickly implement an ordinance to
restrict sediment loss from agricultural
operations.
Although the ordinance was not
enacted in Washington County, a
resolution endorsing the objectives and
standards of the regulatory proposal was
adopted by the SWCD and passed by
the county board. Although it was
obviously not the same as an ordinance,
this resolution indicated an awareness of
the problem and its solutions by local
decision makers and endorsed the
standards which an ordinance would
have established. Most importantly,
perhaps, it provides a framework for the
SWCD to operate within as it attempts to
prioritize its programs and invest its
funds in projects which will effectively
reduce water quality problems.
Projected Impacts
of the Rural Ordinance
One of the obvious concerns which
arose in the review of the rural ordinance
was its potential economic impact on
farmers. A detailed analysis of several
dairy farms in the Kewaskum watershed
revealed that not only could existing
farms meet the standard with ease and
with little or no adverse economic impact,
but also that appreciably lower soil loss
limits dould be met with approximately
the same minor impacts. The secret
lies in the inherent flexibility of dairy
farming. Feed needs for dairy cattle
require the production of both legumes
and corn. This allows for significant
manipulation of croplands. Legumes,
which resist soil erosion, can be grown
on vulnerable sloping soils, while flatter
soils can be used for row crops, par-
ticularly corn. Reduced tillage can further
retard soil losses from row-cropped
fields. A farmer with an excess of sloping
land, in order to meet soil loss standards
and avoid adverse economic impacts,
might produce more hay, this in turn,
would necessitate the expansion of
his/her dairy herd.
This economic analysis was not
expanded to include cash cropping
agricultural enterprises which are by their
nature often restricted to the production
of a single crop. Cash crop operations
are currently not widespread in Wash-
ington County. In other parts of
Wisconsin and in other states, however,
monoculture is a grave problem requiring
careful attention and which may result
in significantly different economic
impacts on farmers and/or significantly
higher investments of public money.
Another potential economic impact for
farmers affected by the proposed
-------
ordinance would be the cost of erosion
control structures. This concern was
alleviated by adding a provision to the
proposed Washington County ordinance
which stated that no structural measures
would be required if public cost sharing
assistance of at least 50% of the cost
of the measure was not available.
There were other questions, too.
How many farmers would be affected?
What kind of manpower would be
required to administer and enforce the
ordinance? It was estimated that in
Washington County soil losses exceeded
3 tons/acre/year on about 20% of the
cropland. Under the proposed ordinance,
it was anticipated that 100 to 150 farms—
of the nearly 1400 farms in the county—
would be affected. A 50% reduction in
soil loss on these farms would reduce
total cropland soil losses in Washington
County by 35%. Most importantly, the
existing technical staff, with a reordering
of priorities, could handle the workload
generated by the ordinance.
Conservation Tillage
An integral part of the strategy to
reduce agricultural soil loss was the
adoption of reduced tillage techniques by
farmers. Reduced, or conservation tillage
involves—in the very simplest sense-
less working of the soil. Plant residues
left on roughened soil surfaces reduce
the impact—and hence erosive energy—
of falling raindrops and allow greater
infiltration of water into the soil. In the
extreme case of no-till farming, seeds
are placed in a narrow seedbed without
disturbing most of the land.
Demonstration plots were established
in the Kewaskum watershed to compare
no-till techniques with reduced and
conventional tillage. Yields from the
latter two were comparable, while
yields under no-till were somewhat lower.
Sediment and total phosphorus losses
under no-till cropping were the lowest of
the systems tested, although amounts
of available phosphorus—that which
stimulates aquatic plant growth—were
the highest. Reduced tillage offered a
reasonable alternative because sediment
and phosphorus losses were reduced
significantly with little if any yield
reduction.
Reduced tillage techniques were not
new, but the number of acres in Wiscon-
sin being farmed in this fashion were
limited. If the benefits were as great as
the demonstrations suggested, why had
the concept not been more accepted by
farmers? To examine this question, a
detailed survey was taken of 50 farmers
in Dane County, Wisconsin, who had
participated in an SWCD-sponsored
reduced tillage project. All respondents
were generally pleased with conservation
tillage and felt that it saved soil, time
and money, although 40% of them felt
that the financial savings were negligible.
An analysis of how these farmers
practiced conservation tillage revealed
that on the average they only cultivated
their fields one less time than they did
with conventional tillage. This would
account for the notion that financial
savings from conservation tillage are
minimal. One less trip across the field
is not conserving enough!
Yield results reported by the farmers
surveyed were comparable to those
reported in the demonstration effort in
Washington County. Most reported
equal yields from reduced and con-
ventional tillage, while 18% of those
interviewed had higher yields with
conservation tillage. Forty percent,
however, experienced a significant yield
reduction with no-till.
Farmers also reported other draw-
backs to no-till cultivation, including
planting and germination problems and
an increase in weeds and insects. They
appeared concerned about the additional
chemicals required for no-till and
expressed frustration over their
inability to solve problems in no-till fields
during the growing season.
Shoreland Areas
Wisconsin has a strong dairy industry,
yet one of the greatest rural nonpoint
source pollution problems arises from
the practice of pasturing cattle in areas
adjacent to streams. Streambanks and
adjacent lands often are not well suited
to conventional farming, but farmers
are taxed for their ownership. They in
turn feel that they must get a return for
the taxes they pay. Shoreland areas do
provide limited amounts of feed and are
a source of water. Water quality problems
arising from their use involve the direct
16
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deposition of waste in the stream and,
more importantly, the physical break-
down of the streambank itself under the
pressures of animal traffic. Unprotected,
eroded streambanks are a direct and
significant source of sediment.
Section 59.971 of the Wisconsin
Statutes requires counties to adopt
comprehensive shoreland zoning to
include land areas 300 feet from navigable
rivers and streams and 1000 feet from
lakes. The project staff developed a
series of amendments to the existing
Washington County shoreland zoning
ordinance. These amendments would
have regulated highly erosive tillage
practices in shoreland zones, prohibited
cattle access to erodible streambanks,
controlled pollution from barnyard/feed-
lot areas in the shoreland zone and
restricted the application of animal
wastes while the ground is frozen.
The advantages of using the shoreland
zoning approach is that it focuses
attention on those areas contributing
nutrients and sediment directly to
streams and lakes. There are, however,
drawbacks. Zoning had not been widely
used in the past to control farm practices
in areas already zoned for agricultural
uses. Also, when zoning ordinances are
enacted, existing land use practices are
"grandfathered," i.e., such practices are
allowed to continue until they have been
discontinued for a 12-month period.
Another problem arises from the fact that
if these amendments had been adopted
in Washington County, they would have
been administered by committees and
agencies other than the SWCD.
Originally designed to complement the
proposed Chapter 92 ordinance, the
zoning amendments took on new im-
portance as support for more compre-
hensive regulation evaporated. Although
not yet adopted, the Washington County
Park and Planning Commission has given
the proposed amendments serious
review and may, in the future, include all
or part of them in revisions to their
existing code.
Urbanizing Areas
As urban areas grow, the lands around
them are converted from cornfields and
pastures to houses, roads and shopping
centers. This process can be slow and
carefully controlled or it can be rapid and
random. As urban growth encroaches on
rural areas, a belt transitional land
develops. This land often remains in
agricultural production, but is owned by
an absentee landowner and cash
cropped by an operator with little stake
in conserving the soil resource.
A detailed analysis of the transitional
land area around the City of Madison in
17
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Dane County, Wisconsin and the Village
of Germantown in Washington County,
Wisconsin revealed some interesting
facts. As this land is purchased, often
for speculative purposes, agriculture
changes from dairying to cash cropping
and the advantages of dairy farming
from a water quality perspective are
lost. Crops are still produced, but the
motivation is merely to provide some
income to the landowner to offset the tax
bill while the land awaits development.
Soil losses under these circumstances
are extremely high for what could be an
extended period of time. For example,
several years ago the City of Madison
exercised its extraterritorial zoning
authority. The City prohibited develop-
ment in the 3-mile wide strip immediately
adjacent to its city limits and uncon-
trolled cash cropping will probably
continue for the foreseeable future.
No solution to this problem is
apparent. Management assistance to
owners and operators was proposed,
but it was observed that the conser-
vation ethic had been lost and that
short-term financial return was more of a
concern than long-term productivity and
protection of the soil resource. Although
specific proposals were not developed,
project staff agreed that this situation,
perhaps more than any other in the rural
setting, required regulation to control
soil erosion.
The Education and
Information Effort
It was apparent from the outset of the
project that the public's understanding
and knowledge of sedimentation and
nonpoint source pollution was limited.
To acquaint people with the sedi-
mentation process—how it worked, what
contaminants moved with sediment in
runoff waters and what the impacts of
those materials were on water quality—
an education and information effort
was designed. The first audiences were
primarily elected officials and local
community leaders. In the early months
of the project, the staff made presenta-
tions to every service, garden and
environmental club in Washington
County. The initial strategy was to take
advantage of meetings called for other
purposes. Convening meetings to dis-
cuss only nonpoint source pollution
proved to be a hopeless task; the work
involved in setting them up was enor-
mous, while the number of people
attending was miniscule.
18
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As the project evolved and various
regulatory proposals were drafted and
supporting monitoring data were
collected, many organizations were
revisited and presented with updated
information and materials. Linkages
were established with other agencies
doing nonpoint work, particularly the
Southeast Wisconsin Regional Planning
Commission (SEWRPC) which was
developing the "208" plan for Washington
and other counties in the Milwaukee
Metropolitan area. The adult education
strategy of the Washington County
Project focused on local elected officials
and other community leaders in the hope
that they would pass on the information
to the general public.
Audio-visual materials were developed
to support the public information pro-
gram and to broaden its audience. A
slide tape set titled "Clean Clear Water
for Washington County" provided the
back up for the initial educational effort.
Brochures describing the sediment
problem in general, as well as specific
aspects of the nonpoint problem, were
written and distributed. A film—"Runoff,
Land Use and Water Quality"—explored
the broad aspects of the nonpoint source
problem from a regional and national
perspective. A print media specialist
developed a series of newspaper stories
on project efforts which were widely used
in Washington County, particularly in
weekly newspapers. A day-long back-
ground tour for journalists was jointly
sponsored by the Washington County
and the Menomonee River Projects.
Finally, a film called "Save Our Soil,
Save Our Streams" was produced to
explore the institutional alternatives
available to local decision makers to
solve nonpoint source pollution
problems.
Conferences of various types afforded
project staff the opportunity to discuss
problems and achievements with workers
tackling similar problems in other
physical and geographic settings.
Scientific meetings and journals pro-
vided vehicles for the discussion and
review of technical accomplishments.
Early in the project, school teachers in
Washington County were contacted to
determine their interest in including local
land use and water quality issues in
school curricula. Teacher response was
excellent and a program was designed
to provide the teachers with sufficient
background and training so they could
develop new teaching units on topics
such as land use, water quality and soil
and water conservation.
These training programs took several
forms. Initially, a one-credit graduate
seminar, entitled "Understanding Non-
point Source Pollution," was offered to
explore the technical, legal and
economic aspects of the nonpoint
problem. A week-long summer workshop
explored many dimensions of current
resource problems. The aim of this
program was to educate the teachers,
both as teachers and as community
members, and to increase the awareness
of the 20,000 K-12 students in
Washington County.
To complement these programs,
funding was received from the State of
Wisconsin Department of Public In-
struction (DPI) under Title IVc of the
federal Elementary and Secondary
Education Act. These grant funds were
used primarily to support a project
coordinator and to pay teachers for time
spent on researching and writing new
teaching units.
19
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Students who were taught these units
were pre-tested and post-tested to
determine if the new materials increased
their awareness and understanding
of resource issues and problems. Results
were highly encouraging. After the units
had been taught and evaluated, they
were edited and assembled into two
volumes entitled "Local Watershed
Problem Studies: Materials for Middle
and High School" and "Local Watershed
Problem Studies: Elementary School
Activities."
In the next phase of activity, teachers
who had experience with the program,
were selected to work on dissemination
teams. These teams worked to involve
teachers not previously involved in the
program. All types of schools—public,
private and parochial—participated in
the program. In addition, teachers in
neighboring Waukesha County were
included. Efforts to expand the program
beyond the boundaries of the two
counties were frustrated by a lack of
financial support and by the cumbersome
bureaucratic constraints of the
educational establishment.
In addition to working with teachers,
a program—the Resource Information
Program (RIP)—was designed to
increase the understanding of the
relationship between land use and water
quality by local officials. Base maps with
overlays were utilized to show how
existing information (soil surveys, water
quality inventories, etc.) could be used
to identify areas of potential water quality
problems resulting from land use
activities. The technique was intended as
a tool to assist local officials to assess
water quality problems, to direct staff
and support activities and to invest
public monies for water quality
improvements.
RIP presentations were made in six
counties in the state. Local officials
responded favorably and the program
is now used by the Wisconsin DNR in its
local water quality planning program.
The Statutory Framework
for Nonpoint Control
The first objective of the project's
legal staff was to determine the
adequacy of existing Wisconsin statutes
for dealing with nonpoint source pollution
problems. It was necessary to determine
whether local governments had sufficient
authority to control the problem or
whether new state authorizing legislation
was required. It was concluded that
adequate authority existed, even though
this authority was often flawed because
many of the applicable statutes had
really been written to serve other pur-
poses, such as soil erosion control,
subdivision regulation or zoning.
To eliminate some of these short-
comings, a comprehensive revision to the
state's soil and water conservation law
was drafted. This legislation is designed
to improve the ability of government to
deal with nonpoint source pollution by:
(1) making nonpoint pollution abatement
an explicit statutory objective, (2) expand-
ing the authority of the county to
regulate nonpoint pollution in incor-
porated areas (cities and villages),
(3) making county-level regulation easier
to enact by deleting the requirement for
a referendum presently required for land
use regulations under Chapter 92,
^4) abolishing the soil and water conser-
vation district (a special purpose unit
of state government) and replacing it with
a land conservation committee of the
county board and (5) transferring the
state level soil and water conservation
function from the Board of Soil and
Water Conservation Districts—which is
attached for administrative purposes to
the University of Wisconsin-Extension—
to the Wisconsin Department of Agri-
culture, Trade and Consumer Protection
(DATCP), where the program will be
combined with the farmland preservation
program. The soil and water conservation
research and education responsibility
remains with the University of Wis-
consin-Extension.
Moving the local soil and water
conservation function from the soil and
water conservation district into the
mainstream of county government
should make the program more visible.
The legislation also provides that the new
county land conservation committee
may assume responsibility for programs
dealing with land use problems cur-
rently scattered among several
20
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committees of the county board. Trans-
ferring the state-level responsibility to
the DATCP should build a stronger
program as that agency is more likely
to promote an assertive program that
includes regulation if appropriate.
Chances for enactment of this legislation
are viewed as excellent.
The Wisconsin Fund
It is difficult to evaluate the effective-
ness of the Washington County Project
because the time frame of the project
encompassed a period when a number of
agencies were actively attempting to
quantify the nonpoint problem and devise
strategies to achieve its control.
In 1978 the state legislature created
a new program—the Wisconsin Fund—
which was designed to provide funds
for the control of nonpoint source
pollution, for the construction of
municipal sewage treatment plants and
for the replacement of failed septic
systems. This unique venture was
particularly timely because it afforded
the opportunity to design and implement
a voluntary nonpoint pollution control
program. Project staff worked closely
with DNR staff, who were responsible
for the administration of the program, in
the development of rules and guidelines
for the rural nonpoint effort. A program
was established which gave money to
local agencies—in rural areas, the county
board and the SWCD—to implement a
program in designated watershed areas.
The local management agencies
identified priority problem areas within
the watersheds, planned investments in
those areas and organized and defined
the roles of local public agencies in the
program. Overall, it presented an
excellent opportunity to put into practice
many of the ideas and strategies which
had evolved during the preceding years.
It is not possible at this time to
evaluate the ultimate successes or
failures of the Wisconsin Fund nonpoint
control program. Progress to date has
been excellent. Critical areas have been
identified, farmer cooperation has been
established and needed practices have
been installed. The program is ongoing
and is serving as a model for similar
efforts nationwide.
The legislation which established the
Wisconsin Fund required that a report be
submitted to the state legislature
evaluating the effectiveness of voluntary
programs for controlling nonpoint source
pollution and the need for regulatory
measures. The voluntary vs. regulatory
question remains unresolved. Basically,
the issue centers on the ability of local
project managers to secure the co-
operation of farmers who previously
have not participated in government
programs. Watersheds cannot be
effectively treated unless all farming
operations in critical locations
participate. This problem has long
plagued soil and water conservation
efforts.
Recommendations
From the work of the Washington
County Project the following recom-
mendations are made for future work
with nonpoint source pollution.
Land use-wa ter quality monitoring
work should be continued, but the
focus should be on assessing the
contributions of individual land use
activities. Remedial measures
should be tested on the same scale.
River or stream mouth monitoring
provides only information on the total
pollutants delivered from a watershed.
Using these methods, the relative
contributions of individual land uses
within that watershed are difficult to
determine, and this complicates the
development of effective treatment
strategies.
A major research effort should be
focused on soil and water conser-
vation with particular emphasis on
reduced tillage and the effects of
erosion losses on the capability
of the soil for crop production.
Reduced tillage offers demonstrated
advantages in terms of reduced soil
losses and of savings of time and money.
Further work is required to solve nutrient
uptake and pest problems and to develop
effective reduced tillage systems for a
wider variety of agronomic crops. Those
soil properties most essential for plant
21
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growth are concentrated in the top few
inches of an undisturbed soil, and if that
critical topsoil is removed by erosion,
plants are forced to grow in often entirely
different materials.
A statewide framework for nonpoint
source pollution control is required
which identifies technical, resource
and manpower needs and which sets
out and clearly defines program
objectives and responsibilities.
Implementation of this recom-
mendation may require new enabling
legislation at the state level. In addition,
existing state statutes may need to be
revised and updated to reflect new
program thrusts.
A specific local unit of government
must be identified as the agency
responsible for the administration
and implementation of nonpoint
source pollution control programs.
Such an agency may already exist
in many local governmental structures
and all that is required to strengthen it is
to define more clearly its functions and
responsibilities and to increase or
upgrade its staff capability. If such an
agency does not exist, one must be
created.
More active field work with soil and
water conservation problems at the
local level is required.
In many instances, ongoing local
programs can be redirected with their
missions redefined. Administrative and
planning time should be reduced and
more attention focused on implementa-
tion of conservation programs in
priority areas. Increased financial support
for remedial programs must be provided
by federal, state and local governments.
The status and role of Federal
agencies at the local level should
be reviewed.
The functions of these agencies
should be carefully assessed to de-
termine if their tasks could better be
handled by a local unit of government.
If the diverse functions now housed in
several agencies at the local level were
combined, would greater efficiency be
achieved? Could administrative costs be
reduced, and more money be utilized
for program implementation? Could the
confusion which exists in the public
mind about who does what be reduced?
7776 impacts of and technical
standards for pollution control
practices must be constantly evalu-
ated to insure maximum pollutant
reduction for each public dollar
invested.
With limited public dollars available
for implementing nonpoint source
control programs, it is critical that maxi-
mum pollutant reduction be achieved
for each dollar invested.
22
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Regulatory programs for sediment
control should be adopted wherever
they are needed and feasible.
Regulatory programs for the control
of construction site erosion are equitable
and workable and should be adopted by
local units of government wherever the
problem exists. Nonpoint source pro-
grams on agricultural lands should be
reviewed periodically to determine if the
voluntary approach is working. If agri-
cultural regulatory programs are required,
they should be based on performance
standards per farm unit.
A major educational effort is needed
in rural areas to increase farmers'
understanding of soil erosion and
nonpoint problems and of new
technologies and management
techniques available to reduce those
problems.
Much of the nonpoint problem in
rural areas can be solved fairly simply—
and inexpensively—through improved
management of cropland and barnyard/
feedlot areas. Moreover, those practices
installed to reduce soil erosion and
nonpoint source pollution will not be
effective unless they are properly
managed. Sound management will be
the key to the ultimate success or
failure of programs in rural areas.
Selected Project Publications
Arts, J.L, and S.J. Berkowitz. 1978. Institutional Needs for
Effective Nonpoint Source Pollution Control Programs.
In: Proc. U.S. EPA Conf., Voluntary and Regulatory
Approaches for Nonpoint Source Pollution Control.
EPA-905/9-78-001, U.S. Environmental Protection Agency,
Chicago, IL pp. 48-56.
Berkowitz, S.J., and R.R. Schneider. 1979. A Description and
Critique of Soil and Water Conservation Programs in
Washington County, Wisconsin. Washington County
Project Report. Water Resources Center, University of
Wisconsin-Madison. 65 pp.
Carpenter, A., and D.A. Wilson. 1978. Development of Resource
Information for Local Decision-Makers. In: Proc. U.S. EPA
Conf., Voluntary and Regulatory Approaches for Nonpoint
Source Pollution Control. EPA-905/9-78-001, U.S.
Environmental Protection Agency, Chicago, IL pp. 65-76.
Daniel, T.C., and R.H. Klassy. 1977. Washington County Project
Work Plan. EPA-905/5-77-001, U.S. Environmental Protection
Agency, Chicago, IL. 73 pp.
Daniel, T.C., P.E. McGuire, D. Stoffel, and B.A. Miller. 1979.
Sediment and Nutrient Yield from Residential Construction
Sites. J. of Environ. Quality 8(3):304-308.
Daniel, T.C., P.E. McGuire, G.D. Bubenzer, F.W. Madison,
and J.G. Konrad. 1978. Assessing the Pollutional Load
from Nonpoint Sources: Planning Considerations and a
Description of an Automated Water Quality Monitoring
Program. Environmental Management 2(1):55-65.
Harder, S.M., T.C. Daniel, and F.W. Madison. 1978. Guidelines
for Mandatory Erosion Control Programs. J. Soil and Water
Cons. 33(2):80-84.
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Harder, S.M. 1976. Review and Analysis of Selected Regulatory
Programs for Controlling Erosion: Recommendations for a
Practical Approach. M.S. Thesis. University of
Wisconsin-Madison. 120 pp.
Hutchison, U.K. 1978. Urban Fringe Agriculture, Nonpoint
Water Pollution and Policy Considerations. Ph.D. Thesis.
University of Wisconsin-Madison. 183 pp.
Johnson, L, G. Jackson and J. Arts. 1981. Controlling Runoff
and Erosion from Land Development Projects: Some
Institutional Tools. University of Wisconsin-Extension. 50 pp.
Madison, F.W., and C.P. Runge. 1978. The Need for Sediment
Regulations: The Washington County Example. In: Proc. U.S.
EPA Conf., Voluntary and Regulatory Approaches for
Nonpoint Source Pollution Control. EPA-905/9-78-001, U.S.
Environmental Protection Agency, Chicago, IL pp. 42-47.
Madison, F.W., J.L Arts, S.J. Berkowitz, E.E. Salmon, and B.B.
Hagman. 1979. The Washington County Project: Final Report.
EPA 905/9-80-003, U.S. Environmental Protection Agency,
Chicago, IL. 118pp.
Miller, B.A., T.C. Daniel, and S.J. Berkowitz. 1979. Computer
Programs for Calculating Soil Loss on a Watershed Basis.
Environmental Management 3(3):237-270.
Miller, B.A., and T.C. Daniel. 1981. Predicting Soluble P Loads
on a Watershed Basis. Transactions ASAE (in press).
Moore, I.C., B.M.H. Sharp, S.J. Berkowitz, and R.R. Schneider.
1979. Financial Incentives to Control Agricultural
Nonpoint Source Pollution. J. Soil and Water Cons.
34(2):60-64.
Pollard, R.W., B.M.H. Sharp, and F.W. Madison. 1979. Farmers'
Experience with Conservation Tillage: A Wisconsin Survey.
J. Soil and Water Cons. 34(5):215-219.
Schellentrager, G.W. 1979. The Resource Information Program:
Land Use and Water Quality Information for Local
Decision-Makers. M.S. Thesis. University of
Wisconsin-Madison. 80 pp.
Sharp, B.M.H., and S.J. Berkowitz. 1978. Economic Issues of
Controlling Nonpoint Sources of Pollution. In: Proc. American
Water Res. Assn., Wisconsin Section, Second Annual
Meeting, Planning and Managing Wisconsin Water
Resources, Milwaukee, Wl. pp. 219-236.
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