United States
Environmental Protection
x°/EPA     Second Annual Report
           State/EPA Agreements

Second Annual Report
 State/EPA Agreements
      October 1980

                             TABLE OF CONTENTS
INTRODUCTION                                                             1

EXECUTIVE SUMMARY                                                        5

RECOMMENDATIONS                                                         13


     Region I                                                           15

     Region II                                                          23

     Region III                                                         29

     Region IV                                                          37

     Region V                                                           47

     Region VI                                                          55

     Region VII                                                         63

     Region VIII                                                        77

     Region IX                                                          85

     Region X                                                           93

The Partnership Reassessed

     This is the second Annual Report assessing the development and
implementation of State-EPA Agreements (SEA) nationwide.  Last year's
Report characterized the SEA process as the key to a new Federal/State
partnership dedicated to the principle of integrated environmental
problem-solving.  The partnership was new then, and only tentative
conclusions could be drawn about its utility.  Now another year has
passed and the FY 1980 SEAs have been completed and put into effect.
An expanded FY 1981 process is under way.  Once again it is time to
take stock of the partnership and determine how well it is working.

     In reviewing the SEA experience since last August, it is well to
bear in mind the ultimate goals of SEA as they were stated in the
first Annual Report.  Those goals were:

          •   To ensure that the large sums of Federal
              money going to the States produce tangible
              results in solving priority environmental
              problems; and

          *   To realign available resources to identify
              and solve the problems that separate programs
              cannot handle alone.

     The goals call for consolidated action.  Individual media programs
are aimed at particular aspects of environmental problems that are often
broader in scope than the programs themselves.   The SEA process is designed
to widen the scope of problem-solving beyond programmatic boundaries by
enlisting EPA and the States in a joint,  comprehensive effort to define
the true dimensions of the problems and to make commitments for solving them.

     The groundwork for the partnership was laid in 1977 by enactment of
the Clean Water Act (CWA),  which emphasized the need for intergovernmental
coordination of programs for environmental protection.   On this foundation
EPA devised the State-EPA Agreement and encouraged the Regions and States
to adopt the instrument in FY 1979, covering all CWA programs.  The SEA
then became mandatory in FY 1980,  for programs  under the Clean Water Act,
the Safe Drinking Water Act (SDWA)  and the Resource Conservation and Re-
covery Act (RCRA).   For FY 1981,  all EPA programs are encouraged to be
considered in the SEA negotiations.

     Last year the emphasis of the SEA assessment was on the mechanics
of starting up a new procedure.  This year the emphasis is less on
mechanics and more on outcomes in light of the SEA goals.  Although the
process is still relatively new, one can now begin to ask how much
progress has been made toward integrated problem-solving.

     To determine the current status of the SEA program, EPA undertook
Regional assessments during July and August, 1980.  As in 1979, teams
of EPA Headquarters personnel visited each Region and interviewed Regional
SEA participants and some State representatives.  The conclusions drawn
and recommendations made in this Annual Report are based on the findings
of these surveys.

     The Annual Report consists of two sections.  The first, an executive
summary provides a general overview of SEA trends, cites examples of
successes and problems encountered in specific Regions, and makes recommenda-
tions for improvements where they are needed.  The second section contains
individual trip reports for each of the ten Regions, prepared by assessment
team members.

Aims of the Assessment

     The FY 1980-FY 1981 SEA Assessment had four chief purposes:

          *  To determine changes in SEA approach since
             the last assessment and the reasons for
             adopting them,

          *  To identify specific instances of successes
             and problems in SEA development,

          *  To assist in further refinement of the SEA

          *  To evaluate the SEA experience with particular
             emphasis on areas identified from the last
             assessment as needing improvement:

             —  Integration:  Orientation toward
                 environmental issues that cut across
                 program categories.  Consistency of
                 priority issues with EPA National Guidance.
                 Reflection of SEA priorities in grant
                 applications/work plans.  Improved commit-
                 ments to SEA by Headquarters, Regions and

—  Coordination:  Liaison with State executive/
    legislative branches.  Involvement of inter-
    state and areawide branches.  Synchronization
    of SEA's with State budget cycles and ZBB.
    Improved public participation.

    Procedural improvements:   Improved methods  for
    analyzing environmental problems.  Involvement
    of EPA program staff in SEA process.   Improved
    use of environmental assessments and  multi-year
    strategies.  Reduction of paperwork.   Improved
    tracking of SEA commitments.

                            EXECUTIVE SUMMARY

          Execution of FY 1980 Agreements was timely (by December 31,
          1979, 52 out of 57 SEAs were signed) and negotiation of
          FY 1981 SEAs is expected to be completed early in the
          fiscal year.

     The State-EPA Agreements for FY 1980 were, in many cases, executed by the
States and territories prior to October 1979.  Where deadlines were missed, it
was mainly because SEA negotiations did not commence early enough in the fiscal
year or processing delays held up formal execution.

     Negotiations for the FY 1981 Agreements were in process during the assess-
ment and it appeared that most SEAs would be signed by early FY 1981.  In the
course of last year's assessment the Regions strongly urged that the FY 1981
State-EPA Agreement Guidance encourage the inclusion of all media programs, and
this was done.  As a result all EPA media programs were considered during the
FY 1981 SEA negotiations.

     The overall emphasis in the FY 1980 Agreements was programmatic rather
than problem-specific.  For example, one State agreed to issue 54 industrial
and 104 municipal NPDES permits due to expire in FY 1980 while the Region
agreed to provide technical, legal and administrative assistance in the opera-
tion of the NPDES program.  In contrast to that programmatic priority another
Region had four States identify acid rain as a major environmental problem; the
Region and the State are considering forming a task force to deal with the
interstate transfer of atmospheric pollutants in response to the problem.
Generally the same condition pertains in the FY 1981 Agreements although de-
termined efforts are being made in most regions to structure SEA negotiations
in such a way as to promote inclusion of more environmental problem-solving
issues and to approach their resolution in an integrated way.


          The organizational structure and processes used by EPA
          Regional Offices for SEA development continue to vary
          according to Regional preferences and circumstances.
          Significant progress hate been made in securing the
          active involvement of staff members responsible for
          specific programs.

     This year, nine of the ten Regions have placed responsibility for coor-
dinating the Regional SEA process in either the Regional Administrator's
Office or the Management Division.  This reflects the fact that SEA negotia-
tions now cover all EPA programs rather than just water-related programs.

     Last year's assessment found that the most successful Regional  ap-
proaches always featured active participation by EPA program staff.   More
extensive involvement was encouraged.   This year all Regions indicated  that
program staff had been more fully involved.  This area still needs continued
attention.  However, the SEA process has proven generally less successful
in securing the participation of interstate and areawide organizations,  an-
other goal set last year.  The primary actors continue to be EPA Regional
and State environmental officials.  Either greater efforts should be made
to recruit substate and multi-state entities as active participants  or  this
goal should be reassessed.

          State approaches to the process and organization of SEA
          development continue to vary widely.  There has been a
          marked improvement overall in State participation in
          and approval of the SEA as an aid to cooperative environ-
          mental action.

     Little change in State structure and process has occurred since the last
assessment.  A variety of approaches,  reflecting the diversity of the States
themselves, exists.  Last year it was concluded that several States  were
skeptical of the SEA process and were participating reluctantly.  With  a few
exceptions, the States are now increasingly positive toward the SEA  process.
They have come to realize its inherent value for coordinating efforts,  as  a
communication channel, and as a device to jointly identify and solve problems.
In a number of States, the SEA is regarded as a primary tool for management of
environmental affairs, whereas previously it was viewed as having doubtful
utility.  Last year it was found that several States doubted the willingness
of EPA to make meaningful SEA commitments of its own.  This year most States
seem convinced that the EPA Regions are making sincere and credible  efforts.


          In most Regions the process of identifying priority SEA
          issues can be regarded as proced.ura.lly successful — it
          has been adopted into the routine operational cycle, it
          functions smoothly, and the participants generally under-
          stand their roles.  However, from a substantive standpoint
          the process remains largely confined to categorical, pro-
          grammatic issues and has not yet resulted in comprehensive,
          problem-specific priorities on any broad-scale basis.

     A basic goal of the SEA is to assure that resources are allocated  to
priority environmental problems.  If the SEA program is to be successful,  it
must be capable of consolidated action to solve environmental problems  that
cut across the boundaries of agency programs.  This focus is particularly
important in this era of limited resource allocation.  A few Regions have
made long strides toward this end, but most SEAs remain program-specific
despite the heightened awareness of all participants that integrated environ-
mental problem-solving approaches are desired.  This is partly because  the
process being used to identify priorities does not often facilitate  an

integrated approach.  Environmental assessments,  multi-year strategies and
environmental profiles are in only limited use.   Generally, the Annual
Operating Year Guidance is used as a basis for determining SEA priorities.
Grant applications and work plans more often reflect  SEA priorities than

          In Region VI interdisciplinary teams for each State,
          headed by Division Directors, negotiated the FY 1980
          SEAs.   Acting as a panel of EPA experts, the teams
          met and developed mutually acceptable lists of what
          they considered to be State priorities.  At the same
          time,  the State developed similar lists.  The EPA
          and State representatives then compared lists,
          negotiated changes and finalized a list of  priority

          Region VIII conducted its SEA priority identification
          process in a similar way.  Early in the SEA process
          each State was required to highlight areas  of priority
          as its work plan was developed.   The Regional Adminis-
          trator (RA) and each media program (e.g., air, water,
          etc.)  identified areas which they felt needed priority
          concern.   A Division Director took the lead in discuss-
          ing with the RA and program staff the level of emphasis
          which  should be placed on priority and program issues.
          In this way the concerns of day-to-day management of
          the program were defined, discussed and decided upon
          in light of overall top management priorities.

          In Region X, Environmental Profiles for each State
          were used to develop priorities.   Multi-year strategies
          were included in each agreement for water programs and
          in some agreements for cross-cutting issues.


          A major purpose of the SEA is to serve as an effective
          management tool for environmental problem-solving that
          cuts across program boundaries.   In a  few instances
          this goal has been approached, but overall  the emphasis
          is still  on administration of individual programs.  How-
          ever,  coordination among and within agencies has continued
          to improve and the opportunities for cross-cutting problem-
          solving are rapidly increasing.

     As the examples below demonstrate,  SEA has  scored some important  successes
as a catalyst for management of EPA/State  environmental action, but too often
the action being managed is programmatic rather  than  integrated to address

cross-cutting environmental issues.  More emphasis must be placed on
making the SEA a management tool for comprehensive problem-solving.
Tracking arrangements are greatly improved and constant efforts are
being made to perfect them.  A recent study of SEA tracking systems
found that eight Regions had formalized a tracking process using such
supporting mechanisms as quarterly and summary reports, mid-year reviews,
end-of-year evaluations and work plan amendements.  Unfortunately, the
SEA process to date has not succeeded in reducing the burden of management
paperwork.  In a number of Regions, the SEA process is still labor inten-
sive.  Last year's assessment revealed a need for more prompt and detailed
Headquarters guidance on SEA; this year the Regions believe that some
improvement has been made in the quality and timeliness of guidance.  It
is hoped that these improvements will continue.

     The most significant contributions of the SEA have been its ability
to focus the attention of Regional and State managers on priority
problems and its value as a tool of communication between State envir-
onmental agencies and Divisions within EPA.  As long as it continues to
serve this purpose, SEA has an excellent chance to evolve into a more
comprehensive management tool.

          In Region IX, the SEA is regarded as an "Agreement in
          Principle" among the parties.  It is based on broad
          areas of agreement and general commitments, which
          are then specified in detail and linked to program
          grants.  Thus the SEA acts as the Region's chief
          management instrument, translating general priority
          commitments into grant-specific terms.  The SEA is
          also a high-level policy document in this Region.
          During SEA development there is close coordination
          between the Regional Administrator and the Governors
          to ensure compatibility of budget commitments.

          As part of the FY '80 SEA process, the Regional
          Administrator of Region IV visited the Governors of
          the States in the Region to explain the SEAs and to
          solicit support for its implementation.  As a result,
          five of the Governors were signatory to the FY '80
          agreements, with State Agency Heads comprising the
          balance.  Several of the States have used the SEA in
          discussions with State legislative committees that
          review the budgets to demonstrate effective priority
          setting and planning efforts.

          In Region  VI, problems are dealt with on an exception
          basis.  The staff of each program area is responsible
          for tracking the SEA commitments which pertain to their
          program (e.g., water, hazardous waste, etc.) as a normal
          function of work program, tracking, and for reporting to
          the Division Director/Team Leader.  The team leaders
          take corrective action on an "exceptions" basis, involving
          other Divisions and the Regional Administrator/Deputy
          Regional Administrator to the degree necessary.

          Region X has taken major strides in institutionalizing
          a concept  called "Managing for Environmental Results."
          The Regional office, through the SEA process, enters
          into a formal agreement with the States on the designation
          of priority environmental problems and the approaches to
          be taken as an attempt to solve them.  These approaches,
          or strategies, become State commitments.  In the same way,
          the Regions use written agreements between employees and
          supervisors to ensure the attainment of environmental
          goals and  objectives.  The Region's SEA tracking system
          serves as  a means of follow-up on the commitments made by
          both the States and the Region.

          Region VII has been in the forefront of efforts to merge
          the Region's grant process with the SEA process.  The use
          of a new SEA format has reduced the burden of cross-
          referencing of SEA commitments with the work program during
          the process of tracking.  Tracking efforts are now more
          streamlined and of greater utility.


          The experience with public participation in SEA development
          has been erratic.  Although there have been isolated successes,
          the record is a disappointing one.  A major reassessment of
          the public participation requirement may be warranted.

     Last year's assessment noted that timing difficulties often impede
public participation.  Proposed SEAs were submitted for public review too
late for the citizens to have any meaningful influence.  Despite efforts
to correct this problem, it still persists in several Regions.  Even with
the Regions' energetic efforts to promote participation,  public  apathy
has also been encountered.   In line with last year's recommendations,
most Regions have been more active in the planning and implementation of
SEA public involvement,  and EPA Headquarters has improved its guidance.
Despite the several  positive  experiences with this year's programs, the
many public participation problems encountered strongly suggest  that the
requirement should be reconsidered.

          In Region I, public participation was conducted
          primarily by the States.  In Maine, the Department
          of Environmental Protection (DEP) sponsored three
          environmentaf fairs before the SEA was developed.
          It featured ''topic tables" staffed by resource people
          from DEP and EPA who solicited participants views
          on environmental problems.  Comments were recorded
          for development of the FY '80 issues.

          Region VI also encouraged innovative public part-
          icipation techniques.  For FY '81, Arkansas had
          university graduate students conduct in-depth
          telephone interviews with 600 persons to discover
          their perceptions on environmental problems, programs
          and activities.


          In some ways, the SEA process has made remarkable
          advances since last year.  A year ago many Regions
          and States were doubtful of its utility and skeptical
          of the support EPA Headquarters was likely to continue
          to give it.  Now the SEA is generally regarded with
          enthusiasm and is being widely used as a Regional mana-
          gement and coordination tool.

     An indication of the significant improvement made in many aspects of
the SEA process is depicted below.  The table was developed from comments
in the Regional Trip Reports.  If no comment was made on a specific goal,
the assumption was made that either no problem was involved or no change
had taken place and a "No Change" tabulation made.  There are some variations
in degree and areas of progress between Regions, but it is obvious that
the trend is positive.  Conversely, those elements that continue to cause
difficulty stand out clearly.
Cross-Cutting Issues Addressed
EPA Program Staff Involvement
Interstate/Areawide Agency Involvement
Priority Issues/National Guidance
SEA/Grant Application Work Plan
Improved Tracking
Improved Headquarters Guidance
Environmental Assessment/Profile Use
Reduction of Paperwork
Improved State Commitment
Multi-Year Strategy Use
SEA/ZBB Interface
Public Participation

No Change


     Procedurally, the SEA has gained acceptance as an integral part of
the annual planning cycle.  It is becoming institutionalized and is pop-
ular with many participants.  However, the success of SEA as a process
should not mislead us.  It is all too easy to regard a process as an end
in itself, and to forget what the process was meant to accomplish.

     The SEA was intended to facilitate integrated environmental problem-
solving.  It has moved in this direction by enabling top State and EPA
managers to focus together on high priority issues.  Yet, despite its
success as a process, the SEA is still largely programmatic rather than
comprehensive in character.  Several Regions and States have made progress
tow£rd program integration and the prospects for success are more promis-
ing today than they were a year ago.  As long as this problem remains the
SEA will not be able to achieve its most important goal.  It must be pre-
vented from coming to be regarded as only a new and more efficient instru-
ment of conventional grant programs.  It should therefore focus on a few
key priority problems.

     The growing popularity of the SEA should smooth the way for further
improvement in the direction of comprehensive, integrated coverage.  The
challenge now is to find ways to make those improvements and gradually to
incorporate the SEA approach and principles into the Agency's normal plan-
ning, management and budgeting process.


     If the SEA program is to achieve its desired results,  several major
issues must be resolved by EPA in a swift and  effective manner.   These
issues are sufficiently critical to warrant special treatment.   Conse-
quently, it is recommended that an SEA task force be assembled,  to be
chaired by the Office of Program Management with representation  from each
HQ media program and from the Regions, to address the issues and develop
directives for inclusion in next year's SEA Guidance.  The  issues are:

           •  The need to identify approaches  which can be  used
              to develop integrated SEAs that  define and solve
              cross-cutting environmental problems.  If the SEAs
              do not focus their attention on  problems that re-
              quire integrated effort beyond the capacity of a
              particular media program, they will be diminished
              in value and in danger of becoming no more than an
              umbrella under which established programmatic ac-
              tivities are carried out.  All problems should be
              considered to assure comprehensive and coordinated
              planning, but only critical environmental problems
              or those cutting across programmatic lines in terms
              of complexity and need for resources need to  be
              included in the SEAs.

           0  The need to clearly define what  a priority environ-
              mental problem is and what its scope and magnitude
              is.   Guidance on this question is needed to facili-
              tate at least a minimum degree of consistency among
              Regions in their approaches to priority-setting.

           •  The need to reevaluate the requirement for SEA public
              participation in light of the largely disappointing
              results achieved to date.  EPA should determine whe-
              ther the current public participation required for
              the grant programs is sufficient for SEA purposes.
              If so, a special SEA requirement may be redundant;
              if not, it may be necessary to revise the requirement.
              One possible revision would be to involve the public
              only in the identification of priority environmental
              problems rather than throughout  the entire process of
              SEA  development, thus gaining citizen input at the
              earliest and most crucial stage.   Negotiation and
              completion of the Agreements would then be carried
              out  by the agency participants,  consistent with the
              objectives the public has helped define.

           0  The  need to 'reassess the requirement for SEA  par-
              ticipation by areawide and interstate organizations.
              There is no evidence that this goal  has been  serious-
              ly pursued.   Yet the involvement of such bodies remains

             important to the comprehensiveness of the SEA pro-
             gram, since they regularly identify and pursue their
             own environmental objectives which may or may not
             conform with those addressed by EPA and the States.
             The task force may wish to consider this issue and
             develop policies for securing the involvement of such

     In addition to those issues, three others that were identified  in last
year's report need further effort and emphasis:

          •  Those Regions and States that make use of long-range
             strategies and environmental profiles have found them
             useful in setting priorities, conducting SEA negotia-
             tions and preparing budgets.  Regions and States should
             consider the use of such approaches, as appropriate.

          •  Efforts are still needed to better coordinate the SEA
             and the ZBB and to consider the impact of changes in
             priorities on State budget processes.  Changes in
             timing or reporting requirements and greater use and
             reliance on long-range strategies are techniques that
             should be investigated to achieve this goal.

          •  There is no indication that improvement in the SEA
             process has brought about a reduction of paperwork.
             A review of administrative and reporting requirements
             could lead to elimination of those reports no longer
             needed as well as elimination of duplicative reports.

                        REGION I SEA TRIP REPORT

     On August 6-7, 1980, Peter Wise, Deputy Director, Water Planning
Division, and Barbara Roth, Water Planning Division, visited Region I
to perform the Second Annual State-EPA Agreement Assessment.

Persons Contacted

     Mr. Bill Adams, Regional Administrator
     Ms. Leslie Carothers, Deputy Regional Administrator
     Mr. George Mollineaux, SEA Coordinator, Management Division
     Mr. Charles Murray, Director, Water Division
     Mr. David Pickman, Public Participation Coordinator

     State of Massachusetts

     Ms. Linda Simio, Massachusetts Department of Environmental Quality
     Ms. Lynn White, Audubon Society

Regional Summary

     The Regional Administrator (RA) and the Deputy Regional Administrator
(DRA) continue to strongly support the SEA process and actively participate
in negotiating the Agreements.  They view each SEA as a bilateral Agreement
between EPA and the States.  Each Agreement serves as a vehicle to focus
top management on key environmental issues within a one-year time frame.

     In FY '80 lead responsibility for coordinating the Agreements was in
the Water Division.  For FY '81, George Mollineaux, the SEA Coordinator has
been transferred from the Water Division to the Management Division.  The
Grants Policy Committee (RA, DRA and Division Directors) is responsible for
overall direction of development and tracking of SEAs.  The SEA Coordinator
acts as staff to the Committee.  Program managers from pertinent Divisions
are assigned to specific issues.

     It is anticipated that all FY '81 Agreements will be signed by October
1, 1980.  As of August 7, 1980, all the draft SEAs were submitted to EPA,
except Connecticut.  Public hearings are scheduled for late August and early
September.  Progress toward meeting the FY '80 SEA commitments were tracked
on a quarterly basis.   The Region's tracking system is well advanced and
extremely effective in focusing top management attention on problems as
they arise.   For example, t.he RA sends a letter to each State Agency
representative to discuss any problem that surfaces as a result of commitment

FY '80 SEA

Process and Organization

     The process for developing FY '80 SEAs was similar to the process
used in FY '79.  A letter was sent to each State Environmental Agency
outlining the time table for negotiating FY '80 SEAs.   FY '80 SEA policy
was discussed at meetings held at the State offices.  A preliminary list
of major management and environmental issues was prepared by Region I's
Grant Policy Committee for each State.  The Grants Policy Committee met
with each State Agency and, through a negotiating process, agreed upon
twelve specific priority issues.  The DRA led the negotiating team.
EPA staff personnel were assigned to develop work plans for the SEA priority
issues in conjunction with specific individuals at each State Agency.

     In many States more than one State Agency was involved in developing
and negotiating SEA priorities.  Each State designated one Agency primarily
responsible for coordinating the SEA process.  Individual sections of the
SEAs were negotiated with the State Agency responsible for the priority
issue and these sections were tied together with a covering agreement signed
by the Agency heads and the Governor of each State.

     Two new features were added to the format of the FY '81 agreements.
First, the work plan activities in the agreement were displayed in a table
format rather than a narrative one.  The tasks, resources, and outputs to
meet each particular SEA priority commitment were documented in the agreement.

     The second new feature in Region I's FY '81 SEAs was the inclusion of
a new section titled "Program Grant Highlights."  Both the Region and States
felt a number of important issues which were not selected as State-EPA
Agreement issues deserved special attention and should be listed in a
separate section in the agreements.  The negotiation of specific project
officer assignments and other matters pertaining to program grant highlights
are not included in the SEA, but are included in the program grant work plans
which are developed concurrently with the SEA.  The grant work plans are
referenced in the SEA.  Up to twelve issues may be selected for program
grant highlights.

Procedures for Identifying SEA Priorities

     The methodology for identifying priorities in FY  '81 is very similar
to the one used in FY '80.  Several States were more actively involved in
the negotiation process than in previous years.  The States increasingly
have been using the Agreements as a tool to extract meaningful commitments
from EPA (IPAs, technical assistance).

     The Region used the Operating Year Guidance as a basis for identifying
priorities.  The consensus was that the Guidance was much improved.  The
issues are a mix of environmental, management and programmatic priorities.
Some of the FY '80 issues are carried over into FY  '81 SEAs.

     Although the use of environmental assessments and five-year strategies
 has been minimal in preparing SEA priorities, they are included in the grant
 document.  The Region is considering using environmental profiles as a frame-
 work for identifying priorities in the future.

     Several of the priorities in the FY  '81 Agreements focus on distinct
 region-wide and interstate pollution problems.  Four Region I SEAs identify
 acid rain as a priority issue.  As a consequence, they are considering the
 establishment of a Region-wide Task Force to address the problem of inter-
 state transport of atmospheric pollutants which cause acid deposition.


     In FY '81 the tracking of SEA priority issues will remain relatively
 the same as in FY '80.  The Region is making an effort in the FY'81 Agreements
 to more clearly define outputs so they can be more easily tracked.  Issues
 in the Program Grants Highlights Section will also be tracked.  Issues in the
 Program Grants Highlights Section will also be tracked and evaluated through
 the grant process, at the Division Director level.  Region I Division
 Directors and comparable State level officials will be responsible for
 evaluating progress on meeting commitments associated with these issues.  The
 frequency and format for reporting progress on these issues will be dependent
 upon the issue manager.

     The RA has suggested scheduling informal meetings with top State level
management to discuss FY '81 SEA issues.  It is hoped these meetings will
provide an opportunity to discuss the States' environmental problems in a
cooperative and mutually informative way.

     Region I has had substantial success in meeting commitments in the FY '80
Agreements.  The Region feels that many of the unmet commitments were the
result of unrealistic manpower estimates and unexpected delays in passage
of legislation and issuance of regulations.

Public Participation

     In FY '80 public participation was primarily conducted by the States.
The major technique the States used to involve the public in the SEA process
was public hearings on the draft SEAs.  Connecticut spent approximately $10,000
advertising its hearings and attendance was poor.  Vermont sent out 200 notices
to interested persons and only a few showed up at the hearing.  In fact, with
the exception of Maine, public hearings were poorly attended.   Public involve-
ment in some cases had significant influence on the types of priorities and
commitments addressed in the Agreements.

     In Maine, the Department of Environmental Protection (DEP)  sponsored
three environmental fairs in various locations throughout the State
before the draft SEA was developed.  The format consisted of two to four-
hour sessions with informal topic tables staffed with resource people
from the DEP and EPA.  Participants were encouraged to table hop and
express their views on environmental problems.  Their comments were recorded,
for agency response and for development of the FY '80 issues.  See FY '81
SEA Handbook for more detail.

FY '81 SEA

Process and Organization

     Lead responsibility for coordinating the SEA was transferred from the
Water Division to the Management Division in FY '81.  The SEA Coordinator
remained the same.  The Grants Policy Committee remained responsible for
overall direction in developing, negotiating, and tracking the SEAs.  The
procedures for negotiating the Agreements remained relatively unchanged.

Public Participation

     Overall, the public participation in the development of the FY '81
Agreements has been limited.  Each State has planned to hold a public meeting
in late August or early September.  As was done for the FY '80 SEA, Maine
conducted three environmental fairs to stimulate interest and involvement
in the FY '81 SEA process.  For FY '82 the State plans again to consolidate
presentations of SEAs with other State program reviews.  Connecticut will
employ an advisory group.  Rhode Island plans to consolidate its hearing on
the priority list for construction grants with the SEA.

     In FY '82 the Region plans to take a stronger role in generating public
involvement in the SEA process.  In cooperation with the States, the Region
is considering sending a questionnaire on environmental problems to
interested persons and organizations during the problem identification phase.
The results will be incorporated into the Agreements.  Region I has made a
grant to the Audubon Society to help the State of Massachusetts involve the
public early in FY '82 process.  It is thought special interest groups may
be able to generate more meaningful and earlier involvement in the process.


     The Assessment team met with Massachusetts representatives in the
Regional Office.  This meeting enabled the assessment team to have a clearer
understanding of the State's perspective on the SEA process.


     In Massachusetts a number of State Agencies participated in negotiating
the Agreement.  They were:  Massachusetts Department of Environmental Quality
Engineering (DEQE), Department of Environmental Management  (DEM), Department
of Food and Agriculture (DFA), the Executive Office of Environmental Affairs (EOEA)

and the Metropolitan District Commission  (MDC).  DEQE was responsible
for overall coordination of the Agreement.

    The State felt the FY '80 Agreement issues were generated mostly by
EPA.  The SEA concept and process was still new.  In FY  '81 the State
Directors became more actively involved in selecting and negotiating
priority issues and preparing implementation work plans.  The State also
began to use the Agreement as a tool to gain more EPA involvement and
commitment on the issues (through IPAs, specific set asides or conditions
applied to grant funds).

    The State indicated that some issues agreed upon in FY '81 SEA
reflected EPA national priorities rather than State environmental needs.
Some of the issues the States ranked high were not selected as priority
issues, but were incorporated in the Program Grant Highlights Section of
the Agreement.  DEQE conducted an extensive mid-year evaluation of the
FY '80 SEA process.  The purpose of the review was to solicit ideas about
improving the SEA process in Massachusetts.  Interviews were held with
each SEA State project manager and DEQE Division Director.  Some things
the survey revealed were:

    •  Agreements were a useful way to address problems
    *  State can use the Agreement to direct EPA resources to State priorities
    •  Difficult to generate public interest in the Agreements as a whole.
       However,  the public is interested in specific issues.
    •  State must take a tougher stance in negotiating priorities with EPA.
    *  Reasons for delays in meeting work plan commitments vary - however,
       once any party misses a date the entire work plan is thrown off
       Project managers assigned to SEA issues have a heightened visibility
       within the Department.

    The evaluation report also presented a series of recommendations for
DEQE and EPA, individually as well as jointly.  Many of these recommendations
were incorporated into the FY '81 SEA process.  For example,  the addition
of the Program Grant Highlights Section was,  in part, a response to one of
DEQE's recommendations.  Some of the other recommendations included:

    *  More active involvement of top level State management  in the SEA process.
       Adoption by the State of a quarterly SEA memo and report system similiar
       to EPA's.
    *  Preparation of a summary of previous year's SEA process.
    *  Encouragement of multiple year work plans.
    *  Increased qualitative evaluation of outputs.


     There are thirteen priorities in the FY'  81 Massachusetts-EPA
Agreement.  They include a mix of environmental, management and program-
matic issues.  They cover all EPA program aieas.  One of the priority
issues "Massachusetts and EPA Strategy for the Control of Interstate
Transport of Water Pollutants" involves cooperation and coordination of
pollution control and abatement efforts between Connecticut and Massachusetts.
EPA will take the lead in coordinating this effort.  Acid rain is another
priority issue in the Agreement, which seeks to foster communications between
States on regionwide problems.

Public Participation

     Public Participation in the SEA process was rather limited in developing
the FY '80 Agreement.  For FY '81 DEQE sent a memo to 300 interested parties
asking for their nomination of SEA issues.  The Department received comments
from regional planning agencies, committees, and associations.  A public
meeting is planned for August on the draft FY '81 Agreement.  To generate
more meaningful involvement EPA has contracted with the Audubon Society
to assist DEQE in conducting public participation for FY '82.  The contractor
will prepare a comprehensive mailing list and a brochure which explains the
SEA process and solicits nomination of SEA issues.  The contractor will also
circulate news articles, a summary of major accomplishments of past SEAs,
and will organize workshops and meetings held on SEAs.

General Regional Perspective

     The Region identified several areas of concern during the assessment.
They are the following:

     *  Slippage of HQ commitments to the Regions (i.e. issuing regu-
        lations) .  Many commitments in the Agreements are contingent
        upon HQ meeting deadlines.
     •  Concern that the Agreements remain as simple and flexible as
        possible.  Increased reporting requirements will reduce the
        Agreements' utility as a true management tool able to focus on
        key issues.
     •  Earlier distribution of Agency Operating Year Guidance.  The
        Guidance is used in setting priorities.  This would be particularly
        useful to the States.
     *  Conflict between SEA commitments and resources allocated in the
        ZBB process.  Need to translate SEA priorities into ZBB process.
        This requires getting an earlier start on the Agreements.
     *  Need for more funding flexibility.

Assessment Team's Perspective

     Region I's top level managers have used the SEAs as an effective tool
in managing key environmental issues in a limited time frame.  The Agreements'
success has been largely the result of strong and active support of the
RA and DRA.  The Agreements have served as a vehicle to improve communications
between the Region and the States and among State Agencies by providing a
forum to discuss environmental issues.  The States have begun to actively
support the Agreement and extract commitments from EPA in negotiating
priorities.  The document is evolving into a true bilateral agreement.

     The addition of the Program Grants Highlights Section provides a more
comprehensive account of the other important activities being conducted
in the Region.

     The Assessment Team believes that the Region I Agreements could become
more effective, if they are developed in the context of long term strategies,
particularly in the cases where priority SEA issues require several years
to complete.

                           REGION II SEA TRIP REPORT

     On August 4-6, 1980 Peter Wise, Deputy Director, Water Planning
Division and Barbara Roth, Water Planning Division, visited Region II
to perform the Second Annual SEA Assessment.
Persons Contacted

     Mr. Charles Warren, Regional Administrator
     Mr. Conrad Simon, Water Division Director
     Mr. Richard Caspe, Chief of Technical Resources Branch (N.J. SEA
     Mr. Kevin Bricke, Acting Chief of Program and Toxic Integration
          Branch (Region II SEA Coordinator, N.Y. SEA Manager)
     Ms. Joann Brennan, Chief of Program and Policy Development Section
     Mr. Raymond Pfortner, Region II Citizen Participation Coordinator
     Mr. Ralph Pruiett, Technical Resources Branch
     Mr. John Smith, Technical Resources Branch

     Puerto Rico

     Mr. Rafael Andreu Villegas, EPA Caribbean SEA Manager
     Mr. Frederick Rushford, Governors Office
     Mr. Carl-Axel P. Soderberg, Director of Water Quality Area,
          Environmental Quality Board

Regional Summary

     The SEA process continues to be supported by the Regional Administrator.
Since the regional reorganization, overall SEA coordination responsibilities
moved from the Regional Administrator's office to the Planning and
Management Division.  Each year, individual SEA managers are named for
each jurisdiction.  This year, the Caribbean manager is from the San Juan
Field Office, the N.J. manager is from the Water Division, and the N.Y.
manager is from the Planning and Management Division.

     In developing FY '81 Agreements the Region is concentrating its
efforts on updating and integrating the strategies and work plan activities
related to FY '80 Agreements.   The Region is also trying to refine its
tracking system - by more clearly defining the SEA commitments and their

     The FY '81 Agreements will cover all EPA programs except air in New
Jersey and Puerto Rico.  For FY '81, New York has separate water and air
SEAs.  The State plans to integrate the two SEAs into a single Agreement
in FY '82.  It is anticipated  that all FY '81 SEAs will be signed by
October 1, 1980.

FY '80 SEA

Process and Organization

     With the regional reorganization, overall SEA coordination
responsibilities moved from the Regional Administrator's Office to the
Planning and Management Division.  Individual SEA managers were subsequently
named for each State.  Project managers for specific SEA issues were
responsible for the substance of the Agreements, for reviewing current
SEA issues/strategies, updating current strategies and developing strategies
to address new issues.  Each Division Director was ultimately responsible
for those parts of the Agreement that pertain to his/her program.

     In three States more than one Agency was involved in identifying and
negotiating SEA priorities.  Each State designated one Agency as responsible
for coordinating the Agreement.  In the case of New York and Puerto Rico,
the SEA process was principally responsible for improving cooperative
relationships between Agencies.

Procedures for Identifying SEA Priorities

     The principal priority-setting technique used for SEAs in Region II
is built upon a process already in place - the previous year's Agreements.
The process of updating the SEAs included mid-year reviews, where State
and Federal program managers reviewed current issues and strategies and
identified any new or revised environmental and institutional problem
areas.  Later Federal project managers and their State counterparts met
to negotiate differences uncovered during the review.  The States prepared
a draft of the SEA which included long-range strategies and program work
plans.  EPA reviewed the States' drafts and final differences in the drafts
were negotiated at meetings with State Program Managers and EPA Program
Managers/Division Directors and conferences between the Regional Administrator
and State Commissioners.

     The FY '80 issues were predominately programmatic as opposed to
environmental problem issues.


     The Region centered most of its FY '80 SEA tracking activities around
the mid-year review.  The SEA coordinator conducted an on-site review of
SEA commitments with State representatives.

     The SEA coordinator also received progress reports from Branch and
Section Chiefs regarding SEA activities.  From this information the
coordinator prepared a list of issues for resolution by top management.
Top level management then discussed policy options with their State
counterparts.  On the remaining issues the RA contacted the State Commissioners
to work out differences.

     The State one year work plans (included in the Agreement) were used
to support program grant applications.  The grant applications were
developed concurrently with the SEAs.

FY '81 SEA

Public Participation

     In FY '80, except for New Jersey, public involvement in the SEA
process was limited in Region II.  New Jersey did contract with a
Statewide public interest group (Association of New Jersey Environmental
Commissions) to inform target organizations about the intent of the SEA
and to solicit input into the development of the Agreement.  The Agreement
was revised in response to public comments.

     New York, Puerto Rico and the Virgin Islands all sent mailings to
notify the public about the draft SEAs and conducted hearings on the
individual Agreements.  Responsiveness summaries were prepared for each

FY '81 SEA

Process and Organization

     The process for developing the FY '81 SEA was similar to the one used
in FY '80.  The only major change was the designation of an individual in
the Caribbean Field Office to be responsible for coordination of the
Puerto Rico and Virgin Islands Agreements rather than the Regional Office
in New York.  Commonwealth representatives believe that having the EPA
coordinator in the Field Office has improved communications between the Region
and the Commonwealth and expedited the preparation of Agreements and work
programs.  In Region II all EPA programs will be covered in the FY '81
Agreements, except for air in the Puerto Rico and New Jersey Agreements.
New York has separate air and water SEAs.  The State plans to integrate
the two agreements in FY '82.

procedures for Identifying SEA Priorities

     The procedures for identifying priorities in the FY '81 SEA were
similar to the previous year.  In updating New Jersey's Agreement - the
original 24 issues were restructured by integrating water resources with
cross cutting policy and managerial issues.  Relevant strategies and
activities were updated accordingly.  Region II personnel were largely
responsible for preparing the draft of the FY '81 New Jersey Agreement;
New York State personnel were largely responsible for drafting the FY '81
New York Agreement.


     The procedures for tracking and reviewing grant and SEA output
commitments for FY '81 and developing the FY '82 SEA will be significantly
revised.  Region II plans to have in place by October 15, a commitment

tracking process consolidating all EPA and State commitment tracking with
the FY '82 SEA update process.  State and EPA program managers and SEA
coordinators will be the focal points for every step in the process begin-
ning with monthly commitment tracking and quarterly review meetings for
each program.

      The Planning and Management Division's Analytic Center is planning to
undertake a comprehensive study of the SEA process with particular emphasis

      •  Ensuring that five year strategies and one year work
         plans are clearly linked to the solution of a state's
         priority environmental problems;

      •  Ensuring a proper link between the SEA and other state
         planning and management processes;

      •  Ensuring a proper link between the SEA and other EPA
         planning and management processes (e.g. ensuring the
         inclusion of EPA-SEA output commitments in the Region's
         annual operating plans, etc.).

Public Participation

      The Region took an active role in trying to involve the public in the
FY '81 SEA process.  At a minimum, public hearings on the draft will be held
in each State.  Puerto Rico and the Virgin Islands present speqial problems
in conducting public participation activities because of their unique cultural
and organizational perspectives.  A State by State breakdown of public partici-
pation follows:

New York

      The Region, in conjunction with New York State, developed an environmental
needs/issues survey.  The survey was sent to over A,800 persons and organizations
representing a wide range of interests.  The survey requested that:  (1) the
public rank environmental issues,  (2) indicate their interest in receiving
future mailings and  (3) indicate their interest in attending a public hearing
on the draft SEA.  Over 800 responses were received.  An additional hearing was
scheduled because of the results.  Four hearings are scheduled on the draft SEA
during August.

New Jersey

      The New Jersey Department of Environmental Protection, with the cooperation
of EPA, sent mailings to interested persons and organizations.  Three workshops
are scheduled in August to present the draft Agreement to the public in an in-
formal setting prior to the public hearing for discussion and clarification.
Two public hearings on the draft agreement are scheduled in September.

Puerto Rico

     Public involvement was limited in the early stages of the FY '81
SEA process.  A public hearing was held in June on the draft agreement.
10 people attended the meeting which was held in Spanish.  The Agreement
was prepared in Spanish, and subsequently translated into English.

Virgin Islands

     Limited early public involvement in the SEA process.  Hearings
scheduled on draft Agreement in August.  Time only permitted discussion
with the representatives from the Commonwealth of Puerto Rico on the
State-Commonwealth perspective of the SEA process.  The Assessment Team's
perceptions are based on a conference call with those representatives.

Puerto Rico SEA


     The FY '81 SEA will cover all EPA programs except air.  Five Agencies
are directly involved in the development of the FY '81 Agreement in Puerto
Rico.  Three other Agencies are peripherally active in the process.  The
Governor's Office is responsible for overall coordination of the Puerto
Rico Agencies.

     In the past, the EPA individual responsible for EPA's efforts in
developing the Puerto Rico SEA was stationed in the Regional Office in
New York.  This year the responsibility for coordinating the Commonwealth
Agreement was delegated to the Caribbean Field Office in Puerto Rico.
The State representatives feel this arrangement has improved communication
between EPA and Puerto Rico and will make it easier to update future
Agreements.  The priorities in the FY '80 and FY '81 Agreements are similar.

     State officials also feel that the mid-year review helps focus on
slippages in meeting commitments, provides a forum to resolve issues and
provides an opportunity to discuss coming year Agreements.

     State representatives voiced some concerns during the assessment:
They include:

     *  EPA needs to make more commitments in the Agreements.
     *  Need for assistance in estimating manpower to meet agreed commitments.
        Puerto Rico has experienced staffing problems which have often made
        it difficult to meet commitments.
     *  Need guidance on how to coordinate the SEA process more closely
        with the budget cycle.
        Puerto Rico needs help in translating the Agreement from Spanish
        into English.  This procedure is time consuming and costly.

    A public hearing on the draft Agreement was held in June in
Spanish.  10 people attended the meeting.  The Agreement is in the
process of being circulated by the Governor's SEA coordinator to
the Puerto Rico Agencies for their concurrence.  The Governor and
the RA are expected to sign the Agreement in August.

General Regional Perspectives

    The Region identified several areas of concern during the assessment.
They include:

    *  SEA needs to remain a flexible document.
    *  SEA guidance needs to address relationship between ZBB, SEA
       process and State budget cycles.
    *  Agency Operating Year Guidance needs to be distributed earlier.
    •  AAs need to provide more direction to each program.  In Agency
       Operating Year Guidance everything is a priority.
    *  Agency Guidance is only a one year plan.  Need a longer term

Assessment Team's Perspective

    Region II was a pioneer in the SEA process.  Its top level management
continue to support the process and the Region has made a conscious
effort to involve the public early in the SEA priority setting process.

    The Assessment Team feels, however, that the SEA process could become
a more effective management tool if the Region would concentrate on
making more diverse and meaningful commitments in the SEAs (i.e. in
addition to the rather heavy emphasis on grant awards).  This would
encourage the States to take a more active interest in the phase development
of the SEAs.

                       REGION  III  SEA TRIP REPORT

     On August 12 and 13, Greg Glahn of  the Office of Air Quality Planning
and Standards, OANR and Sherry Hiemstra  of the Program Evaluation Division,
0PM, visited Region III as part of the State-EPA Agreement  (SEA) Assessment.

Persons Contacted

     Mr. George Pence, Acting Director,  Office of Intergovernmental
        Relations and Public Awareness (OIRPA)
     Ms. Mary Sarno - Grants Coordinator  (OIRPA)
     Mr. Steve Wassersug and staff - Director, Air and Hazardous
        Materials Division
     Mr. Len Mangiaracina - Deputy Director, Enforcement Division
     Mr. Greene Jones - Division Director, Water Division
     Mr. Stan Laskowski, Bob Kramer, and  Larry Wilson - Surveillance
        and Analysis Division
     Mr. Henry Brubaker - State Program  Officer for Virginia (OIRPA)
     Mr. Dick Pastor - State Program Officer for Pennsylvania (OIRPA)
     Mr. Jim Burke - State Program Officer for West Virginia (OIRPA)
     Mr. Paul Ambrose - State Program Officer for Delaware and Maryland (OIRPA)


Principal Responsibility Is In OIRPA

     State-EPA Agreement activities are managed by the Office of Intergovern-
mental Relations and Public Awareness (OIRPA), an office that reports directly
to the Regional Administrator.  The Office has responsibility for Environmental
Impact Statements, Congressional Affairs, Public Affairs, Basin Coordination,
the Federal Regional Council, and State Relations.  It is in the State
Relations Branch that responsibility for  SEA is housed.  This Branch has five
GS-14 Program Officers — one for each State the Region covers with the ex-
ception of Maryland and Delaware, which are covered by one Program Officer.

     The State Program Officers also are  responsible for issuing 105 and 106
grants.  Right now, Program Officers negotiate SEAs and the 105 and 106 grants
jointly.  The Region plans to include more and more of th^ grants in the agree-
ments.   George Pence,  Acting Director of  OIRPA, indicated that using the Pro-
gram Officers for the SEA negotiation process has worked well — that State
officials like having a specific person they can come to and who can then draw
in the  appropriate Regional Program staff on an issue.


To Varying Degrees

     In conversations with Regional staff, it appeared that other persons
in the Region are involved to varying degrees in the SEA process.  Although
we were unable to interview the Regional Administrator, it was clear that
he is seen by Regional staff as being very supportive of the State-EPA
Agreement Process.

     Regional Division Directors and Branch Chiefs are involved to varying
degrees in the State-EPA Agreement process.  State Program Officers ask
Division Directors and Branch Chiefs to help in developing the list of SEA
priorities for negotiation with the States; each State Program Officer
asks each Division for a list of its State-by-State priorities, consolidates
them, and then negotiates the list with the State.  However, whether
Division Directors and Branch Chiefs actually sit down and negotiate with
the State along with the Program Officer, who takes the principal role in
negotiations, depends on the State, the Program Officer and on the personali-
ties and relationships of particular Division Directors.  We noted what
appeared to be considerable variation in involvement depending on who the
State Program Officer was; in only one case 	 the Pennsylvania SEA — did
it appear that program staff had been extensively involved in negotiations.


The Region is Flexible

     Region III has been very flexible in its approach to State-EPA agreements.
State Program Officers appear to have the same general philosophy about where
the Agreements should be going  (although some are more focused on using the
SEA as an accountability mechanism for grant funds while others are more
intent on identifying major environmental issues and directing available
grant funds toward them), but are limited in how far they can go by the
attitude of the State they work with.  Virginia, for example, wants to keep
its agreement vague and general, while the  State official negotiating the
Delaware agreement wants the agreement to be so specific as to provide a work
plan with flow charts.

     The Preamble to the Agreements is standard for all the State Agreements,
but Parts I, II, and III vary more from State to State.  In most of the
Agreements, Part I is a statement of major environmental issues and objectives
for improving them; Part II is an elaboration of those objectives, and Part
III is the actual EPA grant agreements (incorporated by reference).  The
Delaware agreement, which identified "program development needs"  (e.g.,
delegation of the Construction Grants program, establishing a procedure for
developing AWT facilities requirements), is an exception.  Part I  is an
introduction, Part II is a State environmental assessment, Part III, identifies
"Program Development Needs," Part IV contains program  summaries and key
activities each of the programs will address, and Part V is the grants (included
by reference).

     Part II of the documents is where one sees the greatest contrast.  Some
draft Agreements (for  '81) have specific milestones with dates by which they
will be achieved and the name and phone number of the persons responsible in
EPA and the State.  Other agreements do not contain this specificity.

Most SEA Commitments Are Not New Activities

     It appeared, from reviewing FY '80 and FY '81 drafts of the Agreements
and from our discussions with Regional staff, that most of the SEA commitments
are not "new" activities for EPA and the States.  Rather, they are more specific
statements of things EPA and the State would be doing anyway.  For example, in
the FY '80 Virginia agreement the State agreed (among many other actions) to
process Construction Grant applications in a timely manner and EPA agreed to
expeditiously process all construction grant actions referred to it by the
State; Pennsylvania agreed in its FY '80 agreement to "issue 54 major indu-
strial and 104 major municipal NPDES permits that will expire in FY '80" while
EPA agreed to "provide technical, legal, administrative, and policy guidance
and assistance in the operation of the NPDES program."

     The FY '81 West Virginia Agreement seemed to be an exception in this
regard.  The agreement appears to have resulted in greater integration of acti-
vities and more interagency cooperation that might not have resulted without the
SEA.  For example, the '81 draft agreement provides for using 208 funds to assess
problems of acid mine drainage, combined with EPA's arranging for an IPA from
the Office of Surface Mining to be assigned to the State.

     The objective of this work is that, in FY 1981, the State and EPA will
make an effort to develop a "coal strategy" intergrating planning, implem-
entation, monitoring, permitting, enforcement, and evaluation.

     One problem several/ interviewees raised with us was that the SEAs are very
program-specific and do not attempt to intergrate funds from several programs
to solve a problem.

     One Regional Division Director indicated that we "have SEA but it's like
a box with blocks — not an umbrella.  There are no ties between programs; we
need more coordination."  Coordination was seen as particularly difficult for
programs in other than "environmental" agencies in the States — e.g., TSCA
and Pesticides, which are often in the Agriculture Department.


Regional Staff Seem Positive

     Region III staff are still,  for the most part, not certain about whether
the benefits of SEAs are worth the resources, but on the whole seemed positive
about their possible benefit over the next several years.  Right now they see
the Agreements as being resource  intensive, and don't think they've gained much
by having them.  However, the State Program Officers agreed that progress has
been made over the last year, and that  there is more focus on major envir-
onmental problems as a result of  the SEAs.

Benefits that are conceded include the fact that SEAs have forced program
people to integrate more, have sensitized Regional staff to States' problems
and to multi-disciplinary approaches States have to take, and have begun to open
up resources— to show relationships between resources that permit those funds
to do more than just solve a single problem.  However, they are also expensive
in terms of staff and travel time; we were repeatedly told that it takes
more resources to track grants than simply to give grants.

     One Deputy Division Director  said that most things  done under the
auspices of SEA would be done anyway, but SEA decreases  the number of misunder-
standings that would take place.

States See Little Benefit

     George Pence indicated that the States in Region III in general see
relatively little benefit in the SEAs, with the exception of Delaware, where
the person responsible was formerly with EPA's New York Regional Office.
(This person wants the SEA to provide a work plan with flow charts.)   The
major "selling points" the Region is using with the States are:

     1)   that funding can be made available to the State

     2)   that it's an opportunity for the State to get the
          Region to commit to deadlines;

     3)   that it allows the Region to talk with the State and come to
          an agreement about whether certain aspects of the program
          can be done;  and

     4)   that it is a "mutual" agreement.

     Even given these selling points, though, it appears that several States
in the Region, and particularly Virginia and Maryland, have been  very wary
of the process.  (We did not speak with any State officials during our visit.)
Their concern, as presented to us by the Region, has been that EPA may be using
this mechanism to create "State EPA's" — a very threatening prospect to
independent air boards and other State organizations that want to retain their
autonomy.   EPA, we were told, did not help alleviate this concern when it stated
in the SEA guidance document that EPA should encourage the formation of State
EPA's.  Similarly, while States want more flexibility in using resources with-
in a program,  they are resistant to grant consolidation, particularly where
programs are small, because they assume the small programs will be meshed with
a larger program.

     We were also told that, while the SEA is intended as a two way street,
the States don't now use them to their advantage — they simply see the SEA
as a grant mechanism.  The'Region doesn't encourage States to require EPA
to make commitments because they see themselves as having little control over
what gets done.   For example, the State can have the Regional Office commit to
getting the regulations for a particular program out on time, but Headquarters,
not the Region, controls what is done.

Regions' Bargaining Power  Is Limited

     Flexibility of operating plans and timing were also mentioned as problems
associated with SEA negotiation.  The Regional staff thought that there needs
to be more flexibility to  allow the Regions to trade resources from one area
to another (e.g., from Water Quality to RCRA) to enable the Regions to address
priorities the State wants to include in the State/EPA Agreement.  Right now,
operating plans are submitted by  the Regions in April or May; the Regions are
still negotiating SEAs with States at that time.  As a result, the SEA is
made vague; how vague it needs to be is the big problem.

     The Regional program  staff also indicated that because States have diff-
erent fiscal years and must plan  their budgets early, the Agreements are not
really negotiations with the States — they are "second-guessing" the States.
(Some persons argued that  this was not the case, since States' budgets cover
a wide range of areas and  were talking about a limited amount of money to
match EPA grant dollars.)

     The point was also made that SEAs are in regulations only in the water
program, and that we should require them in all our program regulations if
they are really important  to us.


     The Program Officer for each State conducts quarterly and semi-annual
assessments of State activities.  In most cases, a representative from every
program office goes out with the  Program Officer on these assessments.  These
persons sit down with the  Division managers in each State and follow up with
persons at the Commissioner level.  In these sessions, Program Officers
review progress aginst SEA and grant commitments and begin to negotiate SEA
priorities for the coming  year.


     Each State Program Officer has made a very good effort to get public
patricipation, but few thought the response was worth the effort.

     One program officer indicated that the Agency's public participation
requirements are much too  detailed and are not very effective.

     In West Virginia, the State  consolidated the public hearings required
for its SEA and all EPA grants into one session.


     All '81 agreements appear to be on schedule; drafts are available now
and signing ceremonies are being planned with the Governors and the RA for
early October.

     '81 agreements for all the States are more comprehensive than last year.
This is discussed in more detail  in the State reports which follow.



     To get a sense of progress and problems with the Virginia agreement,
we spoke with the State Program Officer, Henry Brubaker.

     Mr. Brubaker stated that the key to getting a State-EPA Agreement in
Virginia is in dealing with all of the agencies and independent boards
responsible for environmental activities.  The State's organization is complex
(e.g., the Air and Water Pollution functions are located in separate independent
boards that report to the Secretary of Commerce and Resources; the Health
Department is under a different Secretary) and follows tradition; State officials
are very reluctant to take action they perceive as making them less auton-
omous — such as having the Governor sign the SEA, or having grants (which
are signed by the Executive Directors of the Boards) included as part III
of the SEAs.

     Whether grants will be part of the SEAs and whether the Governor will
sign the agreement are major controversies right now.  The State wants grant
conditions in hand before signing the SEA.  Mr. Brubaker indicated that the
Region's leverage on the State is quite limited in that the States outmatch
Federal money, and have been leading the Federal government in their expend-
itures for environmental programs.

     Another issue of concern is how general or specific the agreement should
be.  Mr Brubaker and other program officers in the Region want specific goals
and objectives in the agreement — e.g., taking action to reduce the pesticide
runoff into the Albemarle Sound — but the State wants the agreement "vague
and general."

     The '80 Virginia agreement included RCRA, SDWA, the water and air programs
(including  I/M, FIFRA, and TSCA.  The Virginia Department of Agriculture's
participation in the '81 agreement is uncertain.


     Dick Pastor, the State Program Officer for Pennsylvania, provided us with
information on the Pennsylvania agreement process.

     The Secretary of the Department of Environmental Resources in Pennsylvania
is very supportive of the State-EPA Agreement process.

     The Pennsylvania agreement for FY '80 covered a limited number of programs
so as to raise chances of success.  The '80 Agreement is very detailed.  Part
I contains issues; Part II, which contains PPA's, is the grant work plan.
Part III contains the grants themselves.  Mr. Pastor intentionally wrote in this
much detail in order to highlight to the Governor, who signs the Agreement,
that the State hadn't been meeting its commitments.  He sees including this
detail in the SEAs as a way of limiting the amount of paperwork on 106 grants.
The outcome of this he told us, has been three-fold;

     1)   The Governor indicated to State staff that he expected the SEA
          commitments to be met, and that if there were competition for
          resources, these priorities were the ones to be met first;

     2)   When other programs saw the specificity the State was held to in
          the Agreement, they became interested in getting their programs
          into the State-EPA Agreement; and

     3)   Establishing these detailed commitments has lent some stability
          to programs, since EPA must meet its commitments, and has helped
          the State do some realistic program planning:  what's in the State-
          EPA Agreement is what's done first.

     Mr. Pastor indicated that in his view, if there is a failing with State-
EPA agreements, it is that they aren't documents that enable a State to lay
out its environmental problems and determine how to solve them, but are oriented
toward those problems where EPA money is available.  He pointed out that
frequently these areas — problems and areas where EPA money is available —
aren't the same — e.g., nonpoint source and acid mine drainage.

     In FY '81 the Pennsylvania agreement will include a wider range of
EPA programs — everything except noise — and the Department of Transpor-
tation, the Basin Commission, and, although not a signator, the Philadelphia
Air Agency.

West Virginia

     West Virginia's SEA was described to us by the State Program Officer,
Jim Burke.

     West Virginia, like Virginia, is decentralized, and State Officials are
concerned that State-EPA Agreements are an EPA mechanism for forcing develop-
ment of a superagency.  For this reason, the FY '80 State/EPA Agreement
concentrated on the Health Department (RCRA and SDWA)  and Department of
Natural Resources (DNR)  programs.  The FY '81 agreement, though will be
completely comprehensive, including the Health Department, DNR,  the Department
of Agriculture, the Air  Pollution Control Commission,  and the Governor's
Office of Economic and Community Development.

     The Agreements,  which are negotiated by Jim Burke's meeting one-on-one
with the directors of these Departments and Commissions, will be signed by
the Governor and the Regional Administrator.   There is some resistance to the
agreements at the State  agency director level and more resistance at the staff

     The West Virginia Agreement will be more specific in FY '81 than it was
in FY '80 in order to provide for some evaluation.   Part I of the agreement will
focus on seven major environmental issues in the State to which resources from
single  or multiple grants will be directed.   Where EPA funds are not available
to resolve problems,  the State Program Officer has attempted to work out

arrangements with other agencies to provide assistance.   For example,
acid mine drainage from abandoned coal mines is a major  issue in the
State.  EPA's 208 program can be used for planning regarding this problem,
but not for solving the problem.  To provide assistance  on solving the
problem, the State Program Officer negotiated an IPA from the Office of
Surface Mining to the Department of Natural Resources.


     Delaware and Maryland are the responsibility of Paul Ambrose.

     Mr. Ambrose saw the benefits of SEAs in both States in that they
forced people to talk and coordinate, and forced them to address environmental
issues.  However, he pointed out that there are different perceptions of what
should be in the State-EPA Agreements — that some people argue for including
only major problems while others want to include "bean-counting."

     In general, Delaware has been supportive of the Agreements, largely
because there is a new Director for Environmental Control in the State who
had worked for Chris Beck in New York and who supports the process.  In
FY '80, Mr. Ambrose prepared a list of top priorities using the Operating
Year Guidance, had meetings with the Regional Office Division Directors,
and then met with the Director of Environmental Control.  Mr. Ambrose wanted
to emphasize environmental problems in Part I, but that  didn't work because
the Director wanted to focus on "program development needs," including
milestones, rather than environmental problems.  The FY  '81 agreement with
Delaware will include air, noise, water, and pesticides.

     In Maryland, little was done in FY '80 on the State-EPA agreements.
The Governor did sign a letter which the RA accepted as  the SEA, but few
if any commitments were made.  Mr. Ambrose was unclear about whether he
expects to make any progress with the State in this regard.

     The items in SEAs are tracked at monthly meetings between the Division
Directors and program officer, at which forms submitted  by the States are

                        REGION  IV  SEA TRIP REPORT

     On July 29-30, 1980, Jerry Emison  (Office of Planning and Management)
 and Greg Glahn  (Office of Air, Noise and Radiation) visited with officials
 and Staff of EPA Region  IV in Atlanta to review the current status of the
 State-EPA Agreement (SEA) process and the changes that have occurred since
 the previous review in July 1979.  A number of Regional Office officials
 and staff, including the Regional Administrator, were interviewed by the team
 during the two-day visit.  This report  summarizes the results of the visit
 and discussions.

 Persons Contacted

     Ms. Rebecca Ha&mer  Regional Administrator
     Mr. Tom Devine, Director, Air & Hazardous Materials Division
     Mr. George Harlow,  Deputy Director, Air & Harzardous Materials Division
     Mr. James Silva, Deputy Director, Water Division
     Mr. Robert Humphries, Director, Office of Congressional & External
     Mr. Sanford Harvey, Director, Enforcement Division
     Mr. Howard Zeller,  Deputy Director, Enforcement Division
     Mr. Bill Adams, Deputy Director, Surveillance/Analysis Division
     Mr. H. Mack Rhodes, Office of Program Intergration and Operations
     Mr. Henry Hudson, Office of Program Integration and Operations
     Mr. Frank Redmond,  Office of Congressional & External Affairs
     Mr. Brian Beals, Air & Hazardous Materials Division
     Mr. Mike Levi, Water Division
     Mr. Don Taylor, Office of Program Integration and Operations
     Mr,, Tom Nessmith, Office of Program Integration and Operations
     Mr. Winston Smith,  Air & Hazardous Materials Division
     Mr. Harold Hopkins, Water Division
     Mr. Robert Jordan,  Water Division
     Mr. Thad Allen, Enforcement Division

     State of Georgia

     Mr. Jim Setzer, Georgia Environmental Protection Division

Regional Summary

     Region IV, while not participating in the FY '79 SEA process, undertook
major efforts in FY '80  to implement the process within all States.  The FY
 '80 effort resulted in the execution of agreements prior to the end of the
fiscal year.   The FY '81 efforts are focusing on improving the process, in-
cluding certain modifications in organizational roles, procedures, and
schedules.  Overall the  process for FY  '81 is proceeding on schedule.

     The SEA process in Region IV has strong support and continual interest
and attention from the Regional Administrator who personally takes a very
active role in priority setting and the negotiation process.  The Regional
Administrator sees the SEA process as an extremely important management tool
to help her manage Regional Office Staff and to work with the top management
of State environmental programs.  The Regional Administrator feels the pro-
cess provides much needed flexibility to the Regional Office and particularly
to the Regional Administrator.  She also expressed concern that no actions be
taken by the Headquarters in its overview capacity which would limit or re-
strain this flexibility and important decision making authority.

     Most interviewees felt the SEA process continues to improve communica-
tions at the upper management levels of both the Regional Office and the State
environmental programs.  Several also felt it helped foster better communica-
tions among staff of the Regional Office and the State, especially those where
responsibilities are split between different State agencies.  While recognizing
the importance of the SEA process as a top level management tool, most of the
interviewees felt the process, while significantly improved in FY '81, had
not reached the point where the benefits outweighed the costs.  Many stated
the process was very resource intensive and that benefits as a working tool
had, to date, been limited.  During the interviews, a number of other per-
spectives and recommendations were provided by various staff.  A list of some
of these perspectives and recommendations  is  provided later in this report.

FY '80 SEA


     The FY '80 agreements covered programs under the Clean Water Act (CWA),
the Safe Drinking Water Act. (SDWA), the Resource Conservation and Recovery Act
(RCRA), and the Clean Air Act (CAA) in all States.  In addition, radiation
issues were included in the agreement of one of the States.  No noise or
pesticides issues were included in any FY '80 SEA.  The Region experienced
no delay, with the agreements being finalized in August and September of 1979.

Process and Organizational Responsibilities

     As described in the 1979 Report for State-EPA Agreements (October 1979),
the SEA process for FY '80 was managed by the staff of the State Operations
Branch (SOB) located within the Office of Program Integration and Operations
(OPIO) which is part of the Office of the Regional Administrator.  The SOB had
prime responsibility for the negotiation and finalization of the SEAs in FY '80.
Staff of the SOB functioned as the responsible Project Officer for the imple-
mentation of the process and the successful completion of agreements with all
States.  Program Offices (Divisions) participated in the process but the
extent of participation varied among the offices and at different stages
in the process.

Priority Identification

For the FY '80 agreements, staff of SOB initiated the priority setting
process by developing a preliminary list of priorities addressing all major

 program areas.  At  the  request  of  SOB, the Divisions provided  input  into
 the priority development effort.   The States were  then given copies  of the
 listing and requested to prepare similar lists of  their own.   Regional
 Office program and  management staff including the  Regional Administrator
 subsequently provided a final list of 10-12 issues per State suitable
 for formal negotiations with the State.

     While some of  the  FY  '80 issues were responsive to specific problem
 areas, the majority focused on  implementation of more traditional programmatic
 activities.  Although certain issues selected will likely have to be con-
 tinued into future  years,  the Region has not pursued as a matter of policy
 the development of  specific multi-year strategies.  Several of the issues
 involved cross-cutting  of  traditional program lines where the programs
 were in the Office  of Water and Waste Management.


     For FY '80 agreements, SEA teams comprised of staff from both SOB
 and the Divisions conducted a series of meetings with the States to  finalize
 SEA issue selection with State Agency Heads to develop corresponding write-
 ups and to negotiate grant work plans which would  incorporate activities for
 the implementation  or resolution of the SEA issues.  The grants were included
 as appendices to the final executed SEAs.

     In early FY '80, Region IV developed procedures for the tracking of SEA
 progress.  The procedures required the preparation of brief narrative
 quarterly reports for each SEA issue by both a State and Regional Office
 task leader assigned to each issue by the respective agencies.  The reports,
 including the State report, are reviewed by SOB who reviews them for progress.
 SOB forwards copies of  the Regional Office and State prepared reports to
 the Divisions for their review and comment, and transmits copies of the
 Regional Office report  to the respective States.  A quarterly briefing for
 the Regional Administrator and other senior management staff concerning SEA
 progress and problems is an element of the tracking procedure.  To date it
 has been possible to conduct one such briefing on  selected issues.

     It appears that the FY '80 process did not result in major reduction in
 paperwork for the Regional Office but in reality increased it beyond that pre-
 viously required for the traditional grants process.  The reporting procedures
 for the SEA have also increased reporting requirements for both the Region and
 the States.   The Regional Administrator has expressed a particular concern
 about the reporting requirement's for States and has designated a committee
 to study reporting for both the SEA and grants.  A final decision concerning
 reporting requirements  for FY '81 will be made shortly after the beginning
 of the fiscal year.

     Overall,  progress to date appears to have been satisfactory in meeting
 the FY '80 SEA commitments.  Some shortfalls are being experienced on specific
 issues in some States, but efforts are underway to resolve these with the
appropriate  States.  Some of the shortfalls are due to circumstances beyond
either the Regional Office of State control (i.e., lateness in the promulgation
of a regulation by EPA)  or reflect different interpretations between the Region
and a State  concerning the meaning of an SEA commitment.

     As part of the FY '80 process, the Regional Administrator visited the
Governors of each State to explain the process and to solicit thier support
for its implementation.  Five of the Governors were signatory to the agree-
ments with State Agency Heads comprising the balance.  No similar contact
effort was undertaken with respect to the State legislatures.  However, staff
felt that some States have used the SEA in discussions with State legislative
committees as a demonstration of effective priority setting and planning

     The SEA process was not synchronized with the State budget cycles as most
States within Region IV are on a July-June fiscal year.  This cycle requires
States to make major budgetary and planning decisions early in the calendar
year before the SEA process really gets underway.  However, the Region did
not consider this a major problem for the SEA process, at least at the present
time.  States seem to be able to get around this problem, particularly since
the grants are not synchronized either with most State fiscal years.
Concern was expressed about the schedule for the SEA process not being con-
sistent with the schedule for the development of the Regional Office Operating
Plan.  This could result in different commitments to the States and to Head-
quarters for use of the same limited Regional Office resources.

Public Participation

     For FY '80 agreements, public participation efforts were minimal
because of the late start in initiating the process in the Region and the time
required to implement the process with all of the States.  The States did con-
duct public hearings on the final draft of the agreement prior to their execu-
tion by the Regional Office and the State, but there was concern that such in-
volvement by the public near the end of the process limited meaningful input.

FY '81 SEA


     The FY '81 agreements are scheduled to be completed prior to the beginnig
of the fiscal year.  The process for FY '81 agreements provided opportunities
for coverage of all programs.  Some programs, however, were not included in the
final SEA list for each State.  Noise is not included in any of the proposed
SEAs,  the SEA for one State will contain several issues on pesticides,
and radiation concerns will be included in the SEA of several States.

Process and Organizational Responsibilities

     Several changes in the process and organization are occurring as part ot
the FY '81 efforts.  The procedures and schedules for the FY '81 process were
developed by SOB in late 1979.  SOB staff visited each State in January/
February to discuss the procedures and schedules and to encourage early State
involvement in the process.  However, the SOB has less of a direct management
role for the process in FY '81 compared to FY '80.  SOB staff now serve more
as process coordinators than direct Project Officers.  The Divisions have
been directed by the Regional Administrator to play a more direct role in
process, and have greater responsibility for the implementation and success
of the process.  Also, the management of the grants process which had been

the responsibility of SOB in FY  '80 has been transferred bach into the res-
pective Divisions.  Some confusion exists between OPIO and the program
offices concerning relative responsibilities for  portions of the process
as the transition continues.SOB  staff help keep the process on track and
provide comments and guidance to the respective Divisions.

Priority Identification

     The initial step in the identification of priority issues for the FY '81
agreements required the development by each Division/Office Director of 3-5
proposed issues or priorities for each State.  The States were simultaneously
encouraged to prepare a similar list.  The FY '81 Operating Year Guidance
issued by Headquarters in February was a major consideration in developing
this preliminary list of issues.  The Division/Office Directors ranked the
issues contained in the listing, not only for those of their office, but the
others as well.  The ranking criteria was composed of three elements:  the
mandate for (i.e., legislative, regulatory); the environmental impact of; and
the marginal utility (i.e., cost/benefit) of each issue with a low (1 point),
medium (3 points) or high (5 points) ranking accorded to each element for
each issue.  This procedure provided a more "scientific" rationale for deter-
mining which issues should be incorporated into the final recommendations made
to each State by the Region.  A Regional Office Committee comprised of the
Regional Administrator, Deputy, and Division/Office Directors then met to
review the ranking results and made limited adjustments as needed.

     This final Regional Office list, in conjunction with the State's list
and input from the public, formed the basis for the negotiating sessions held
during April with each State ("Summit Conference").  At these sessions, the
Regional Administrator served as the principal EPA spokesperson and negotiator.
Also attending were the Deputy Regional Administrator, Division/Office Directors,
SOB staff, selected Division staff, State Environmental Director, and State
Program Managers.  The results of these sessions were a jointly agreed list
of 10-12 issues per State.  Agreement was also reached as to whom (State or
Regional Office would prepare a statement of the problem or issue; necessary
commitments; and resources to be allocated to the issue.  Also, at or
following the session, a Regional Office or a State task leader was assigned
the responsibility for coordinating and finalizing the write-up of each of
the issues and to insure that the write-up provided sufficient specificity,
including schedules and milestones.  One State indicated it intended to prepare
the write-ups for all of negotiated issues within the State.  Most disagreements
concerning the issues were resolved at the conferences.  However, where
inclusion of an issue could not be resolved, it was classified as a "candidate"
issue where further study would be conducted for possible inclusion later.
It appears that most of the "candidate" issues will not be included in the
final SEAs.

     Most of the issues selected were geared to problem solving.   The issues
included both environmental and management problems.   As in FY '80,  the
Region is not requiring the development of multi-year strategies.  However,
staff is attempting to improve State recognition that certain issues will
require efforts over several years and that commitments in future SEAs will

likely be necessary.  As in FY '80, some issues reflect a cross-cutting of
traditional program lines (i.e.,  radiation in groundwater supplies) and included
program areas outside the Office of Water and Waste Management.


     For FY '81, the States are being requested to make their grant workplans
and activity and resource descriptions more definitive about how they will
be responsive to specific SEA issues.  The Region considers the FY '81 grant
workplans as an integral part of the total SEA.  The workplans are initially
developed by the States in June/July following completion of joint agreement
on the issue write-ups for each issue.  While it is premature to determine
if the final workplans will adequately address all of the SEA issues, it
appears from preliminary workplans that most will be responsive, although
others will require additional follow-up with the States.

     The Regional Office is currently reassessing tracking procedures for
possible changes in FY '81.  At the same time, it is also assessing reporting
requirements for the grant programs.

     Since her arrival in January 1980, the Regional Administrator has met
with the State Governors on a wide variety of subjects, including discussion
of SEAs in some cases.  It is expected that four Governors will be signatory
to the final FY '81 agreements.  The remaining three will be delegated to
the appropriate State Agency Head,  As in FY '80, no initiative has been
undertaken by the Region to directly contact State legislatures concerning
the process.  The SEA process continues to be unsynchronized with the States'
budget cycles, but again this does not appear to be presenting any major

Public Participation

     The Region, in developing its procedures for the FY '81 process, en-
couraged States to involve the public early in the process, particularly in
the development of the State's preliminary issue list.  Most of the States
have tried to involve the public directly into the priority identification
process.  Examples include the use of questionnaires in one State and
consultation with standing State citizen committees in another.  One State
has employed a contractor to help foster public participation because of
restrictions on State employment, which prevents increases in State staff.
As in FY '80, the States will continue to hold public hearings in July and
August for the final draft of the SEA prior to its  execution.  The Regional
Administrator also has a citizens advisory committee (Regional Administrators
Council) with two representatives for each State which provides input to the
Regional Administrator and the State programs concerning priorities and problem
areas.  The Office of Congressional and External Affairs works to secure State
public participation efforts as key issues in the SEA and to emphasize the
need for the various State pulbic participation programs to be effectively


Significant SEA Accomplishments

•    A more "scientific" approach employing a numerical ranking process for
     determining recommended SEA issues was developed and implemented for
     the FY '81 process.

•    Efforts have been enhanced to insure that FY '81 issues for the SEA
     are more problem oriented; to insure that SEA issues and associated
     write-ups contain more specificity; to insure that the grant workplans
     for FY '81 are more responsive to the jointly negotiated SEA issues;
     and to insure that grant workplans are made a more integral part of
     the total SEA.

•    A formal tracking mechanism for reviewing SEA progress has been de-
     veloped and implemented.  Studies are under way to review options for
     improving the tracking mechanisms.

•    Direct participation by the Divisions in the process has been strength-
     ened through several modifications in procedures and organizational

Problems Encountered

•    Most interviewees felt the SEA process continues to present a major
     resource burden upon the Region with the benefits of the process, while
     tangible, still not equaling the cost. Too taany issues in the SEA was
     the most frequent reason given for the high cost and marginal benefit.

•    While there is agreement among most that issues should be more problem
     oriented and less programmatic, there is significant disagreement as to
     whether the issues should be solely environmental or a combination of
     environmental and management related.

•    In the opinion of some interviewees, most media or organizational office
     units felt that for  "survival" purposes each had to nominate and strongly
     push for inclusion of issues from their program area in the SEA in every
     State.  They felt that top management might feel they were not being re-
     sponsive or did not have any problems, even though the issue proposed
     might not be especially appropriate  for the SEA.

•    Several interviewees expressed the concern that the SEA process further
     "etches in concrete" Regional Office and State  commitments, making it more
     difficult to respond to rapidly changing priorities and demands which
     frequently occur.

•    Some interviewees felt that States continually  try to use the SEA process
     to deliberately gain unnecessary and imprudent  leverage with the Region,
     that they are not  able to secure under the grants process,  in order to
     get deservedly low priority items raised and unpopular high priority items
     lowered.   The interviewees were concerned that  frequent occurrences of such
     inversions would seriously undermine the salability and effectiveness of
     the process for the  Region.

•    Some interviewees felt the lack of synchronization among the SEA process
     and the internal Regional Office planning process could precipitate serious
     inconsistencies between Regional commitments to States in the SEA and those
     made to Headquarters in the Regional Operating Plan.

•    Some interviewees felt there was no real incentive for States to negotiate
     SEAs lacking any financial incentive.  Several indicated that without some
     type of "consolidated" grant legislation there was no flexibility to re-
     channel monies among the grant programs.  Another indicated there is no
     opportunity to increase funding since the level of finding to each State
     (with the exception of one joint grant program) is not really discre-
     tionary.  One interviewee felt that the Funding Simplification Act
     enacted in the early 1970's provided certain capabilities to consolidate
     and direct monies.

•    Some interviewees found it very difficult to prioritize the issues of
     another Division or media because knowledge concerning the mandates, im-
     pacts,  etc., of the other's issues was lacking or not well understood.

•    Among the interviewees, differing opinions existed about whether the SEA
     process had reached its potential as a true negotiating process between
     the Region and the  States.  Some felt most States still view the SEA as
     just another procedural process they must address.

*    Most interviewees felt that while public participation has improved since
     FY '80, public interest is still quite limited.

Improving" the SEA Process

•    Most interviewees suggested future SEAs encompass fewer issues per State
     and that specificity of the remaining issues be significantly enhanced.
     Some interviewees suggested that if an issue reflected a recognized pro-
     gram requirement which would be normally addressed in the grant workplan
     anyway, it should not be considered as an SEA issue.  Some also suggested
     that SEA issues should be limited to ones requiring a multi-media response
     or involving interregional or interstate concerns.

•    Some interviewees suggested that more consideration should be given to
     using SEAs as multi-year vehiclesnot in terms of a long-term strategy,
     but for requiring specificmulti-year commitments for issue resolution.

•    A few interviewees' suggested that future annual operating guidance address
     a limited number of key issues which will require major multi-media efforts
     and coordination to resolve (i.e., toxics).  However, others suggested  the
     current format for  the guidance be retained leaving the prioritization  of
     multi-media efforts to the States and the Regions since they are in the
     best position to understand the need and potential coordination problems.

•    A few interviewees  suggested that future tracking mechanisms for SEAs
     should  provide for  resource accountability in addition to accomplishment

State Perspective — Georgia

     On the second day of the visit, the interview team was able to meet
briefly with a representative from the Environmental Protection Division of
the State of Georgia.  The Georgia Agency is very supportive of the SEA
process and feels it has significantly aided planning efforts between the
Region and the State at the highest management levels.  The representative
from Georgia felt strongly that the SEA process will work only if it has the
support of management from the top down because of different priority interests
among some program managers within both the Regional Office and the State.  In
the opinion of the representative from Georgia, the number of issues presently
contained in the agreements appears to be a manageable number and that national
guidance should be as brief as possible.  The State did not see any need for
the extensive guidance the Region prepares for the State for certain program

     Staff of Region IV cautioned the interview team, prior to the meeting
with Georgia, that the State agency would likely express stronger support for
the SEA process than any of the other Region IV States.  Staff indicated that
some of the other States, particularly those that do not have a consolidated
program type agency, would probably express an almost opposite viewpoint.

                        REGION V SEA TRIP REPORT

      On August  13,  1980,  Bernie Steigerwald  (OAQPS-RTP)  and  Dave
 Ziegler (OWPO)  conducted  an SEA Assessment in  Region V.   On  August  14,  the
 Headquarters' team,  and Dave Stringham and Jim Fillippini of Region V,  traveled
 to Lansing, Michigan to continue the  assessment with the Environmental  Protection
 Bureau, Michigan Department of  Natural Resources.

 Persons Contacted

      The primary Region V contact was Mr. Dave Stringham,  Region V  SEA
 Coordinator and Assistant to the Regional Administrator.   The assessment
 team  conducted  a series of  interviews and group meetings with the following
      Mr. John McGuire, Regional Administrator
      Mr. Devon  Schnieder, Region V Analytic  Center
      Ms. Mary Canavan, Illinois SEA Coordinator
      Mr. Wayne Pearson, Wisconsin SEA Coordinator
      Ms. Connie Hinkle, Minnesota SEA Coordinator
      Mr. Jim Fillippini,  Michigan SEA Coordinator
      Mr. Tony Leffin, Indiana SEA Coordinator
      Mr. Bob Springer, Management Division
      Mr. Mike MacMullen,  Water  Division
      Ms. Mary Ryan, Air Division
      Ms. Sandy Gardebring,  Director,  Enforcement Division
      Mr. Tom Mateer, State  Programs Branch, Air Division
      Mr. Ed Watters, Water  Quality Management Branch, Water  Division
      Ms. Marcis Carlson,  Office  of Intergovernmental and External Programs
      Mr. Tom Jackson, Water  Quality Management  Branch, Water Division


      The contact in the State of Michigan was Ms. Gloria Hecht, Environmental
Protection Bureau,  Department of Natural Resources.  Because of last-minute
conflicts, other staff were  unable to attend, but contributed to the
assessment through previous  discussions with her.

Regional Summary

     The Region has made great progress in its approach to SEAs in FY '81
While the  SEAs are  still very detailed, they are evolving into policy
oriented documents.  Regional staff is committed to making the Agreements
more useful management tools.  Based on Region V's comments,  Headquarters
offices,  particularly water  programs,  may wish to review their SEA guidance
and regulations  in  terms of  streamlining requirements.

FY '80 SEA


   .  The FY '80 SEAs for Region V were completed in October 1979,  with
the exception of Indiana and Ohio, which were completed in February
1980.  The Agreements covered all OWWM programs.

Process and Organization

     Region V used State Coordinators, operating out of the Regional
Administrator's Office, to coordinate negotiation of the FY '80 Agreements.
Three media task forces (air, water, hazardous materials) developed most
of the content of the Agreements.

Procedures for Identifying Priorities

     For FY '80, the media task forces met and developed lists of
highlighted State issues in their areas.  Then the Coordinators and program
staff worked with the States, through meetings and one-on-one negotiations,
to come to a consensus on the highlighted issues.  Next, the States and
Region agreed to problem-solving approaches for the highlighted issues.
The FY '80 highlighted issues included a predominance of programmatic
(as opposed to problem-solving) issues.


     The Region attached significance to the use of the term "highlighted
issue" instead of "priority issue."  Highlighted issues were those which
were significant, had a good chance for resolution in FY '80, and  could,
therefore, demand some resources from EPA and the State.

     The highlighted issues were not, however, priorities in the strict
sense of the word, since certain ongoing efforts (e.g., monitoring,
permits administration) would still absorb the bulk of the resources.
The Hazardous Waste Management Program was a highlighted issue in every
State in FY '80.

     The State Coordinators were responsible for tracking the FY '80
 Agreements and for bringing problems to the attention of appropriate
 program offices or the Regional Administrator.  This part of the  process
 stressed mid-year and end-of-year SEA progress assessment.

     Region V's SEA development process evolved somewhat slowly at first,
 but  significant resources and priority were assigned by the Region to
 the  Agreements.

     The SEA process served to focus Region V staff's attention on the
 unique features of Indiana's environmental institutional structure and
 to identify improved working arrangements.

Public Participation

    Region V experienced difficulty with public participation in FY '80
because of a very tight schedule for review and comment.  The consensus
among staff was that public participation could be improved in the
process, but that inventive ways to do so still had to be developed.
Nevertheless, Ohio, Wisconsin and Illinois accomplished a significant
improvement by consolidating Policy Advisory Committees (PAC) to advise
the State during SEA development.  For example, an Illinois consolidated
PAC advised the State on all air, solid waste, and water issues.

General Regional Perspective

    Since the Region did not prepare FY '79 Agreements, and since the
FY '80 SEA process also experienced some schedule slippage, the general
attitude of the Region was one of cautious optimism and a desire to see
what changes were needed after the SEA process worked for a year.
Although they encountered some problems, the Region did incorporate the
SEAs into their management structure, committed experienced staff to
their development, and finalized four of six FY '80 Agreements in October
1979.  Region V included all media in its FY '80 Agreements.

FY '81 SEA


    The Region expects all Agreements to be signed by October 1, 1980.
Several Agreements were in draft form during the assessment visit.  All
the involved program offices are covered in the Region V FY '81 Agreements -
OWWM programs, enforcement, air, noise and toxics.  Air and hazardous
materials have been a part of the Region V Agreements since FY '80.

Process and Organization

Regional Office

    The process of SEA development for FY '81 is similar to the process
for FY '80.  There are State SEA Coordinators who coordinate and negotiate
with support from three media task forces — air, water and hazardous
wastes.  They negotiate State highlighted issues and problem-solving
approaches which Region V incorporates into State specific guidance and
the State then incorporates into its work programs.  The process is
essentially the same from State to State in the Region.  The Region, for
FY '81, placed considerable emphasis on developing media strategies for
planning and SEA negotiating purposes.


    In general,  the States in Region V have to involve only one or two
agencies in the SEA process so identification of lead agencies and
responsible parties has not been a problem.  Increased management attention
at both the State and EPA levels has improved the overall process.

Procedures for Identifying Priorities in SEAs

    The methodology for identifying priorities in FY '81 is similar to
the one the Region used in FY '80.  However, the media task forces have
developed media strategies for the Region, prior to nominating their
highlighted issues for each State.  This step has helped priority
setting, and holds promise for future years.

    The Region issues State-specific guidance to each State prior to
development of their various program work plans.  The Region uses the
EPA Operating Year Guidance in developing the State guidance, but notes
that it would be more useful if it came out about two months earlier.
Since they issue State-specific guidance in May, they must use the draft
Operating Year Guidance for input.  Management Division staff observed
that some of the evaluation thrusts in the OWWM guidance were useful,
but that some programs (e.g., drinking water) provided little guidance.

    The States and Region V identify more programmatic highlights than
environmental highlights, although the Region is moving toward an
environmentally-based planning process based on problem assessments.
The media strategies serve as the basis for implementing this approach
and are reflected in any highlight issues — programmatic or environmental.

Program Staff Participation

    Staff from the various program offices participate in the media task
force meetings and, thus, participate in the Agreements.  Also, program
staff helps to negotiate problem-solving approaches for highlighted
issues which affect them.  All major program areas (air, water, hazardous
wastes) are involved.

Examples of Successes/Problems

    Regional staff from the Water and Air Divisions said it has not been
hard to agree on highlighted issues, but it has been difficult to agree
with the States on exactly what should be done, in terms of timing,
responsibility, and funding.  SEAs probably go into more detail than is
useful for high level managers.  Regional staff also felt that the SEA should
represent mutual understanding among key managers on items to focus on,
which will result in environmental enhancement.

    Staff also said the States feel the SEA is for EPA.  The States do not
see a mutual benefit in all cases, but feel that EPA could use the SEA
as leverage against them.  On the positive side, the SEA does elevate
important issues to a high management level and, therefore, results in a
better front-end direction for program grants.  It also forces the Region
and States to improve coordination of their internal priorities.


    The Region has accelerated the schedule for developing its FY '81
SEAs, so that the Agreements can drive the program grants, literally
and figuratively.  Thus, problem-solving approaches for highlighted
issues were incorporated into work program development in the appropriate
Air, Water or Hazardous Waste Offices.  EPA expects all six SEAs for
Region V to be signed by October 1, 1980.

    The FY '80 Agreements do not always include many specific milestones.
Where they are included, the SEA Coordinators are responsible for tracking
them and reporting problems to the Regional Administrator or the appropriate
program office.

    For FY '81, the Region is making more use of problem assessments and
multi-year strategies in guiding the Agreements.  The media task forces
develop long-term media strategies for the Region, based on problem
assessment information.  The Region then translates these strategies
into State specific guidance and uses them in SEA negotiations.  Regional
EPA staff would like to see all the States prepare their own media
strategies prior to negotiating the SEA with EPA.

    There was a consensus among those interviewed that the Agreement should
be a brief policy document, which guides, but does not duplicate, individual
grant agreements.  The major problem the SEA represented for the Region
was the amount of staff time spent negotiating details.

Public Participation

    For FY '81, the Region has organized its public participation efforts
along constituency lines.  That is, the Region has targeted information to
certain interest groups and individuals.  Staff felt, however, that the
Region had not done a complete job of explaining to the public how the
SEAs work and has, perhaps, raised expectations too much.  There is a
concern that the public will perceive the SEA negotiations as a "fait
accompli".  Staff said the Region must be serious about its commitment
to inform and involve the public.  As the SEA becomes more of a policy-
level document for high-level management, the Region will have to consider
adapting its public participation techniques accordingly.

General Regional Perspective

    The Region believes that Headquarters managers are committed to the
SEA process.   The Region shares this commitment.  However, staff said,
in effect, that some Headquarters SEA policies are not practical in the
real world of SEA negotiation.

    As previously mentioned, the Region is experimenting with an
environmentally-based planning process.  This process, in which long-range
planning spins off comprehensive problem assesments and results in media
strategies, is similar to the process used in Region X.  Integration
occurs when the problem assessments surface cross-cutting or inter-media
problems, or as a result of staff meeting with the Regional Administrator.

The Regional Administrator said that the media task forces enhance
integration between and within individual media.

    The SEA aids management in Region V by acting as a decision
document on key issues of concern to both EPA and the State.  However,
the Region is concerned that the Agreements often get bogged down in
detail, and involve too much lower-level staff time.  The Region does
not want to use the Agreements to replace or duplicate grant processes,
but rather to generate consensus on approaches to key environmental
problems prior to developing grant agreements.

    To increase the utility of the SEA, the Region suggested that
Headquarters study the guidance and regulations to make sure they do
not imply that the SEA should be a highly complex, sophisticated
document.  The Region feels that the SEAs should be coherent policy
documents, developed by April of each year, followed by grant work plan
development.  Staff emphasized that negotiations on the Agreements should
be conducted at a top management level, preferably Division Director
and above.

General Comments on FY '81 Experience — Review Team

    The Region has made some major adjustments in the FY '81 SEAs.  They
have based their development of the SEAs on media strategies and have
initiated the SEA process earlier in the fiscal year.  This has impacted
the general direction of grant work plans and internal EPA work plans for
FY '81.  The media task forces provide a strong and valuable input in
identifying issue priorities to be considered in developing SEAs.

    The SEAs in Region V involve an undesirable level of detail.  The
Region and States agree  easily on issues and priorities, but get bogged
down in intense negotiations at the staff level that duplicates the grants

    The assessment team questions whether more agencies at the State and
sub-State levels should be involved in the SEA process, e.g., health
agencies, areawide planning agencies and regional and local air planning

State of Michigan

    The State of Michigan has supported the SEA process.  They feel it is
needed, especially in the water programs.  However, the State is not happy
with the way the process has worked, and is not sure EPA Headquarters knows
what it wants from the Agreements.  The Agreement, in their opinion, should
not try to do too much.

    The level of detail -is a problem in the development of the Agreement
for the State of Michigan.  It feels the SEA should be a policy document.
Michigan would prefer to keep negotiations at the Division Director level,
and feels face-to-face negotiations are helpful.

    The State noted that the WQM regulations require areawide agencies
(CWA, section 208) to be involved in the SEA process and say the SEA
can serve as a part IV grant application narrative.  These two WQM
policies lead to excessive detail.

    The State said that the issue list developed by the Region also
leads to too much detail.  The list includes many simple program require-
ments that do not require top management involvement.  In addition, the
State said it was difficult to negotiate with EPA as equals since EPA
has the authority to withhold grants.

    With respect to public participation, the State said the public can
relate to general priorities, but not to detailed program jargon.  The
public participation meetings are awkward.

    The key to a successful Agreement, in the State's opinion, is hitting
the right level of detail by pulling the right people together.  The
State does not feel that milestones or target dates should be required,
since they tend to duplicate grant program milestones.  If milestones are
appropriate for policy considerations, they should be included.

    The State develops priorities through the use of five-year strategies
for all programs, especially the water quality, hazardous waste, solid
waste program complex.  The State tries to cost out its strategies, then
goes through informal rankings by Division Chiefs.  This year, the highest
priorities were hazardous waste, ground water, and solid waste.

    There was discussion about whether the provision of out-year guidance,
and the negotiation of multi-year approaches in the SEA process would be
useful.  The State's attitude was to leave out-year decisions to the
discretion of those involved in the Agreements, not to make them mandatory.

                     REGION VI SEA TRIP REPORT

     On July 15-16, 1980, Headquarters staff conducted a State-EPA
Agreement assessment in Region VI.  The participants from Headquarters
were Dave Ziegler  (Water Planning Division, OWPO) and Bob Linett (Office
of Analysis and Evaluation, OWRS).

Persons Contacted

     The primary Region VI contact was Ray Lozano, Region VI SEA
Coordinator.  The  assessment team conducted group meetings with each
of the State teams working on the Agreements.  The team leaders are:

     Mr. Al Davis, Director, Air/Hazardous Waste Division, Arkansas
     Mr. Myron Knudson, Director, Water Division, Louisiana
     Mr. Ray Lozano, SEA Coordinator, New Mexico
     Mr. Oscar Ramirez, Chief, Surveillance Branch, Oklahoma
     Ms. Diana Dutton, Director, Enforcement Division, Texas

The assessment team also held an exit interview with Mrs. Harrison, the
Regional Administrator, Fran Phillips, the Deputy Regional Administrator,
and Ray Lozano.

Regional Summary

     The Region has made some adjustments in its approach to SEAs in FY '81.
The SEA is evolving into a more effective management tool each year.  The
Region feels, however, that the Agreements must be more than work program
summaries to be useful, and that Headquarters needs to provide clear,
simple guidance and give the Region a certain degree of flexibility to
negotiate.  Staff  said, in general, that simple Agreements are preferable,
with detailed discussions reserved for individual work plans.

FY '80 SEA


     All the FY '80 SEAs for Region VI were completed in October, 1979,
with the exception of the Oklahoma agreement, which the Region and State
finalized on December 14, 1979.  The delay in finalizing the Oklahoma
agreement was partially attributable to late HQ guidance regarding 208
grant eligibilities which delayed negotiations.  The Agreements covered
all OWWM programs.

Process and Organization

     Region VI used interdisciplinary State teams to negotiate the
FY '80 Agreements.  Each team was headed by a Division Director and
included members from all the covered programs.  There were some
problems negotiating Agreements in FY '80 in Region VI as both State
and Regional personnel learned the process, but in most cases
cooperation was excellent.

Procedures for Identifying Priorities

     The State teams, acting as panels of EPA experts, met and
developed mutually acceptable lists of State-EPA priorities.  Simul-
taneously, the States developed analogous lists.  The States and EPA
then met, compared lists, and negotiated changes.  One problem Regional
staff mentioned was that the States were developing State strategies,
SEAs, and work programs all at the same time.  The FY '80 priorities
included predominantly   programmatic (as opposed to problem-solving)


     The relationship between the State-EPA Agreement and various program
work plans (106, 208, etc.) was an issue in FY  '80 in Region VI, and
the Region handled it differently from State to State.  In some States,
the Agreements focused on traditional high-priority operating programs;
in some States they focused on the State's highest priorities regardless
of whether they were traditional priorities; and in some States the
Agreements covered only priorities which involved integration.  In general,
the Agreements in Region VI supplemented, but did not replace the separate
work plans.  The Region's approach to tracking was to include milestones
in the Agreements, require quarterly reports on their status, and conduct
semi-annual review visits.

     Coordination with State executive branches was an issue in several
States which had complex institutional set-ups and lacked a strong lead
person to pull things together.  The assessment team expressed the view
that a stronger role for State five-year strategies would settle questions
on priorities earlier, and expedite preparation of Agreements and work

     In general, the Region managed the FY  '80 Agreements well.  They
assigned significant resources and priority to the Agreements and the RA
informed the team leaders of her personal interest in their success.
The Region's major accomplishments were in the areas of internal organization,
commitment, and public participation.  The RA made the Agreements very
visible in the Region.

Public Participation

     In FY '80 the Region hired a public participation consultant who
helped design and manage the SEA public involvement effort.  The Region

also established an SEA Advisory Committee of 61 persons with previous
participatory/advisory experience in the Region.  The Committee provided
EPA with an independent assessment of priorities and with comments on
EPA's strategies and commitments.  Each State was responsible for its
own public participation, with Regional assistance where available.
Arkansas received over 200 responses to a questionnaire it sent out to
identify priority environmental problems.

General Regional Perspectives

     The major issue bothering the Region in the FY '80 Agreements was
the need for financial management and funding flexibility.  The RA
expressed a need for more precise guidance on financial management
procedures.  The comments Regional Staff made were that the SEA guidance
should be less WQM-oriented, that RQ should circulate examples of good
SEAs and interesting formats, and that guidance on Indian/EPA Agreements
would be useful.  The RA also said that she expected a great range in the
quality of the Region VI Agreements considering the varying capability of
the States in the Region, the lack of incentive for them to cooperate
and resistance to additional Federal paperwork.

FY '81 SEA


     The Region expects all Agreements to be signed no later than
October 1, 1980.  The Agreements were either in early draft, or near
completion at the time of the visit.  All the involved offices' programs
are covered in the Region VI FY '81 Agreements — OWWM Programs, Enforce-
ment, Air, Noise, Toxic Substances and Radiation.

Process and Organization

Regional Office

     The process of SEA development for FY '81 is the same as in FY '80.
There is an inter-disciplinary State team for each SEA, led by a Division
Director.  They follow an 11-step process very similar to the process
identified in the FY '80 report.  There was broader program staff involve-
ment in FY '81 SEAs.  Minor differences in the process occur from State
to State.


     Oklahoma's negotiations are going very smoothly thanks to the
addition of a Governor's Aide to their negotiating team.   This has been
a tremendous help in unifying the State responsibilities.

     In Louisiana the reorganization of State Agencies responsible for
environmental programs has also been of great help.

Procedures for Identifying SEA Priorities


     The methodology for identifying priorities in FY '81 is very
similar to the one the Region used in FY '80.  However, the Regional
Administrator, Deputy Regional Administrator  and Division Directors are
even more involved than they were in FY '80 through a series of high-
level meetings between the RA and State Team leaders.  The RA has placed
significant emphasis on this process.  This has helped priority-setting.
In addition, there was broader program staff involvement in the FY '81

Consistency with National Guidance

     The State teams reported that they started with the FY '81 Operating
Year Guidance in defining their priorities.  Therefore, the priorities —
although they show State and Regional differences — track the national
priorities.  There was consensus that the FY '81 guidance was much
improved over past years.

Ratio of Programmatic v. Problem-Solving Issues

     The States and Regions identified many more programmatic issues
than problem-solving issues.  One explanation is that problem-specific
issues can cause problems for the Region justifying future resources needs
via ZBB manpower models.  It did appear, however, that the Region was moving
in a direction of more problem-solving issues, from the perspective of
"managing for environmental results."  They are begining to use problem
assessments, such as 305 (b), more in priority setting.

Examples of Successes and Problems

     Two States identified pesticide container disposal plans as high-
lights for the SEA.  This intermedia issue would not have received such
great attention outside of the SEA context.

     An encouraging development in the Region is the effort between Oklahoma
and Arkansas to establish mutually agreeable interstate priorities to deal
with point source problems, water quality standards and forestry pollution.

     At the time of the assessment the Texas Air Control Board had declined
to participate in the SEA.  Negotiations to resolve this problem are

Sea Priorities in Grants/Work Programs

     In Region VI, the grant applications and work programs are generally
developed concurrently with the SEA.  The grant requirements are, in
most cases, Regional policy decisions which follow national policy and
are also reflected in SEA issues.

     In two States (Oklahoma and Louisiana), however, the State-EPA
Agreement is "out in front" and is driving the preparation of the covered
programs' work plans.  The Oklahoma team thought this was a preferable
arrangement, since it gives more meaning to the SEA negotiation.

Tracking Arrangements/Meeting Commitments

     Generally, each program area (water, air, enforcement, etc.) is
responsible for tracking the SEA commitments which pertain to it as a
normal function of tracking work programs, and for reporting to the
Division Director/Team Leader for their State.  The team leaders take
corrective action on an "exceptions" basis, involving other Divisions
and the RA/DRA as necessary.

Reducing Paperwork

     The Region VI staff said that the SEA did not, and never would,
reduce paperwork compared to the amount of paperwork that existed prior
to the SEA in FY '79.  However, they did say the process was producing
less paper in FY '81 than in FY '80, as the staff gained experience.
Several suggested that HQ not advertise the SEAs as a means of reducing
paperwork, since it raises false expectations.

Coordination with States

     As mentioned above, coordination with the executive branch in
Oklahoma is a major improvement.

Environmental Assessments and Multi-Year Strategies

     One Region VI staffer described the role of these documents as
"subliminal."  That is, staff is aware of what they say but doesn't use
them directly in preparing for SEA negotiations.  One interesting develop-
ment is that Region VI is now gearing up to develop environmental indices -
similar to the Region IV and X Environmental Profile models — which will
help with SEA negotiations in the future.

SEAs,  State Budget Cycles and the ZBB

     State budget cycles which differ from EPA's continue to cause trouble
for the Region.

SEA Commitments

     The Region pointed out the HQ's commitment to the process could stand

improvement.   In particular, the Region pointed out that the Agency
guidance prescribed inclusion of hundreds of program priorities,  which
was clearly impossible.  Similarly, it was pointed out that the guidance
did not address what EPA commitments in the SEAs would, or should,  look

EPA Regional Offices

     The Region feels that it is strongly limited in its ability to make
SEA commitments by PPAs developed at HQ for ZBB tracking purposes.   The
FY '81 SEAs will contain a significant number of EPA commitments to the


     Some Regional staff believe that State commitments under the process
are not much different that they would be under the "traditional" grants

Examples of Successes and Problems

     The Oklahoma situation appears to be an example of a successful
management change from last year.  No particular management problems
were apparent.

Public Participation


     The Region encourages the use of types of public participation other
than meetings and hearings.  The Region has dropped the Regional public
consultant and the 61-member advisory committee and delegated public
participation to the States.  Arkansas in FY '81 used a telephone survey
instead of a questionnaire, with assistance from the University of Arkansas,
and the results were extremely successful (funded with $15K of Federal
grant dollars;  $5K each from RCRA(D), 106,and 105  .  The timing of public
participation did not change significantly in FY '81.  The Region has
established a Public Participation Coordinator, to work with the States on

Contribution of Public Involvement to SEA Process

     Using the Arkansas telephone survey as an example, the Region is
genuinely interested in involving citizens in the Agreements.  However,
a common reservation expressed by the staff is that public involvement
tends to be unfocused.  Particular individuals or groups air grudges or
make proposals which are not necessarily relevant to State environmental
priority questions.  Nevertheless, the Region continues to involve the
public and elected officials.

Examples of Successes and Problems

     The Arkansas telephone survey, in which university graduate students
conducted in-depth interviews with over 600 persons on their perceptions
of environmental programs and priorities is an example of a successful
public participation effort.

General Regional Perspective

EPA Administrator and AA Commitments to SEA Process

     The region questioned the commitment of highest EPA management to the
SEA process on the following points:

     •  The Operating Year Guidance for FY '81 obviously has mare
        priorities in it than any one Region and State could accomplish
        in a year.  Yet it provides no out-year guidance.

     •  There is no sense of inter-media priorities in the Guidance

     •  AA's seem to support the process as long as their priorities
        are mentioned and their programs not threatened.

HQ Performance in Promoting Integration and Problem-Solving

     Regional staff said that shifts of resources among program
areas to respond to integration or problem-solving thrusts often back-
fired during the ZBB process.  The ZBB manpower models tend to penalize
shifts and provide a disincentive, for integration.  Thus, if HQ is
serious about integration, it must remove this disincentive.

Ability of SEA to Address Problem-Specific Issues

     (See comment immediately above.)  There does appear to be a gradual
trend in Region VI toward problem-specific issues in State-EPA Agreements.
The Region is beginning to use environmental index figures, for example,
based on the Region IV and X pilots, to identify problems and priorities.

SEA Utility

Management Tool

     The SEA aids management in that it helps focus on priorities.   For
example, in New Mexico the improved management of water quality enforce-
ment received a great deal of State and Regional attention in the SEA pro-
cess.   In some States,  it is essentially a summary of highlights from the
various covered programs,,  In other States, however, the Agreement  actually
drives work plan development in the covered programs.

CoTnmunication Tool

     Some Region VI staff have not seen much utility in the SEA as a
communications tool.  However, the SEA process is a boon to inter-program
communication on both the State and Regional level.

Steps to Increase Utility of SEA

To the Region

     Region VI staff said that simpler Agreements are better.  They would
prefer to place detail in individual grant work plans.  Also, the Region
would like more flexibility to shift resources to respond to environmental
problems peculiar to their States.

To The State

     State staff were not interviewed.  In general, the same comments would
apply as above.

Utility of FY '81 SEA Handbook

     Although the response was not overly enthusiastic, several of the
staff thought that the Handbook was useful.  It was said that the Handbook
was used as training material for new employees.  They did not appear to
have used the "info transfer" aspect of the Handbook.

Suggestions for FY '82 SEA Guidance

     Briefly, keep it simple.  Also, the provision of more out-year
guidance and a sense of inter-media priorities would be helpful.

Assessment Team Perceptions

     The Region has made some minor, but effective, adjustmentsin FY '81.
The SEA is definitely evolving into a more effective tool each year.  Staff
felt, however, that the Agreement must be something more than a summary of
covered work programs and that HQ needs to provide clear, simple guidance
and a certain amount of flexibility.

                       REGION VII SEA TRIP REPORT

     On July 15-16, 1980, the Second Annual State-EPA Agreement Assessment
was conducted in Region VII.  This report was prepared by Tim Icke (Office
of Water Programs Operations, OWWM) and Gerald Emison (Office of Planning
and Evaluation, 0PM).

Persons Contacted

     Regional Office

     Mr. William Rice, Deputy Regional Administrator
     Mr. Don Christenson, Director, Office of External Affairs
     Mr. Paul Walker, Director, Survey and Analysis Division
     Ms. Louise Jacobs, Director, Office of Enforcement
     Mr. Allan Abramson, Director, Water Division
     Mr. Gene Ramsey, Office of External Affairs
     Mr. Dan Vallero, Office of External Affairs
     Mr. Carl Walter, Chief, Permits Branch
     Ms. Rowena Michaels, Chief, Public Involvement Branch
     Ms. Patricia Kraft, Hazardous Materials Branch
     Ms. Eloise Reed, Air Support Branch
     Mr. Tom Buechler, Chief, Solid Waste Management Section

     State of Missouri

     Ms. Linda James, Missouri Department of Natural Resources
     Mr. Ed Lightfoot, Missouri Department of Natural Resources

Regional Summary

     The FY '80 State-EPA Agreements (SEAs) signed in October 1980, clearly
represent the key mechanisms that the Region and States utilize for managing
their environmental programs.  The strong support and involvement that top-
level management has shown in the past is continuing in the development of
the FY '81 SEAs.  The development of FY '81 State-EPA Agreements is progress-
ing quite smoothly.  The Region is nearly two months ahead of schedule as com-
pared to last year, and if negotiations continue as anticipated, the Region
expects to have draft SEAs completed in early August and final Agreements
signed by mid- to late-September.

     Region VII is now in its third year of developing State-EPA Agreements.
Perhaps the two most significant improvements gained during the FY '80 experi-
ence were: (1) development of tracking procedures for measuring progress in
achieving SEA commitments, and (2) identification of more specific types of
commitments to be included in the Agreements.

      The SEA staff within the Office of External Affairs is responsible
for coordinating the SEA process in Region VII.  The Regional Office program
staffs and their State counterparts are responsible for drafting the content
of the SEAs and multi-year strategies.  The draft agreements are reviewed and
approved by the State-EPA Policy Review Committee which is chaired by the
Deputy Regional Administrator and includes the SEA staff, Division Directors,
Director of the Office of External Affairs and the Regional Counsel.  The
program staffs then negotiate with the States on the final content of the
Agreements.  If there are any unresolved problems, the Policy Review Committee
works out solutions with the States.

      The process for negotiating the FY '81 State-EPA Agreements, as outlined
in the Regional SEA guidance issued to the States in February 1980, (see at-
tached) represents a significant step toward further refinement of the SEA
process.  The Region's guidance outlines four major areas of emphasis.  They
include:  (1) providing a substantive role for the public early in the
process; (2) requiring that each priority issue contain a separate strategy
discussion outlining a long-range (3-5 years) approach for continued action;
(3) integrating the SEA priority issues with all other ongoing grant
activities; and (4) further refinement of the tracking function in order to
Provide data both on priority issue commitments, as well as all other grant-
related program outputs.

      The remainder of this report will focus primarily on the progress the
Region and States have made toward achieving these goals, and secondly will
Highlight information on successes, problems and recommendations gained during
this assessment.

Summary of the FY 1980 Process

      The FY 1980 State-EPA Agreements cover a broad range of priority issues
and problems, and reflect the Regional Policy that all grant programs be
covered under the process.  Although the Regional Administrator continued to
push for greater emphasis on problem-solving priorities, many of the issues
addressed in the FY ;980 SEAs were specific program-related priorities — e.g.,
hazardous waste program development, 205(g) delegation and NPDES permits, etc.

      The process for selecting the FY "80 priorities relied largely on joint
negotiation.  At the Regional level, suggested lists of priority issues were
developed through media and State task forces.  These lists were then presented
to the Policy Review Committee (consisting of Division Directors, DRA and
Enforcement staff) who met with each of the States to develop a final, mutually
agreeable, set of priority issues.  Once the priorities were established the
Office of External Affairs staff, with assistance from the involved program
offices in the Region and States, negotiated commitments necessary to carry
out each priority issue.  All other non-priority related program activities
were negotiated separately by the individual program offices and incorporated
by reference in each Agreement.

     Procedures for tracking the SEA commitments are fairly advanced and well
established in the Region.  On a quarterly basis, staff in the Office of Ex-
ternal Affairs distribute, within the Regional Office and each State, a sum-
mary list of all commitments identified in a given SEA.  The responsible
parties respond in writing on the status of any commitments due within a
given quarter, and also on the status of progress as it relates to future
commitments.  This information is then gathered and used to prepare excep-
tion reports identifying all unfulfilled commitments.  Information contained
within these exception reports becomes the basis for conducting formal mid-
year and end-of-year reviews with each State.  If amendments to an SEA are
justified, they are presented to the RA for review in writing.  In FY 1982,
efforts will be made to computerize the tracking system in order to reduce
the time required to prepare status and exception reports.  In addition, the
Region recommends that in FY 1982, EPA Headquarters clarify the link between
Planned Program Accomplishments (PPAs) and SEA commitments.

FY 1981 State-EPA Agreements

     Negotiation Process

     As previously stated, the process for developing the FY 1981 State-EPA
Agreements is detailed within guidance issued to the States by the Office of
External Affairs in February 1980.  This guidance divides the negotiation
and development process into three phases: Phase I — Problem Identification
and Strategy Development; Phase II — Commitment Development and Finalization
of Agreements; and Phase III — SEA Tracking and Evaluation.

     A brief description of each phase is as follows:

     Phase I — Problem Identification and Strategy Development

     •  Staff from the Office of External Affairs work with the various
        programs on developing suggested lists of priority issues for
        each State.   (The rationale for selecting priority issues is
        based on staff knowledge of problems/issues, environmental
        profile data,  305(b) reports, National/Regional guidance and
        other written materials.)

     •  Simultaneously the States also draft initial lists of priorities.

     •  Regional and State priority lists are exchanged.

     •  Draft strategies (3-5 year timeframe) are prepared for each
        priority issue through negotiations among staff at the Regional
        and State level.

     •  Draft priorities and strategies are presented to the public for
        review and comment.  (See discussion under public participation
        section for further details.)

     •  Formal meetings are scheduled between Policy Review  Committee
        (membership includes the Deputy Regional Administrator,  Re-
        gional Division Directors, External Affairs Director and Re-
        gional Counsel) and State staff (usually State Agency Director(s)
        and other appropriate staff).

     •  Final Agreement is reached on the priorities and  strategies to
        be addressed in each SEA.

     Phase II — Commitment Development and Finalization  of  Agreements

     •  Regional and State program staff jointly negotiate priority
        issue commitments, as well as all other remaining ongoing
        program commitments.

     •  Follow-up meetings are held between State staff and  the  Policy
        Review Committee to agree on all commitments.   (Any  issues not
        resolved are submitted to the Regional Administrator and State
        Director(s) for resolution.

     •  Draft Agreements are finalized and distributed for public review
        and comment.

     •  Agreements are finalized and signed.

     Phase III — Tracking and Evaluation

     •  SEA commitments are circulated for review each quarter.

     9  Exception reports are prepared on all unfulfilled commitments.

     •  Formal mid- and end-of-year meetings are held (Division  Di-
        rectors and counterparts) to discuss progress/problems.   In-
        formal quarterly meetings are scheduled as needed.

     The negotiation process for developing priority issues  and  commitments
in FY 1981 differs from that used in the FY 1980 process  in  two  ways.   First,
a conscious choice was made to eliminate the Regional media  and  State  task
forces organized last year for the purpose of generating  draft lists of pri-
orities for each State.  Because of the excessive time required  to develop
these lists, the decision was made to eliminate this organizational loop and
rely on External Affairs staff to work directly with the  individual program
offices.  The Region feels that this decision was a correct  one  and accom-
plished similar results in far less time.

     The second major modification in development of the  FY  1981 Agreements
is greater staff level involvement during the negotiation of commitments.
The process as it was structured last year did not allow  for adequate  staff
involvement in Phase II — Commitment Development and Finalization of  Agree-
ments.  While this approach appears to have been well accepted at the  staff

level, we did note some continued concern over a perceived breakdown in
communication once initial staff input was sought.  For example, once program
level staff had negotiated tentative commitments with their counterparts in
the States, the Policy Review Committee would review and frequently revise,
delete or add to commitments without proper feedback.  To correct this problem,
the Office of External Affairs has encouraged the program Branch Chiefs to
serve as the conduit for transferring information back to their respective

State-EPA Agreements and Grants Management

     Another major thrust in negotiating the FY 1981 Agreements has been the
effort to merge the Region's grant process with the SEA process.  In theory,
this approach was in use during FY 1980; however, in practice the grant agree-
ments (work programs) remained largely a separate component tied to the Agree-
ments by reference only.  This year the format and structure of the process
was modified to allow for integration of the SEA priorities with all other on-
going grant activities.

     To accept this interface, the commitments for both the priority issues
and grant work programs are being negotiated at the same time, and all com-
mitments are listed on media-specific summary sheets for tracking purposes.
(See example in attached Regional Guidance.)  In addition, commitments spe-
cific to a given SEA priority are listed separately along with the required
background statements and strategy discussions.

     Through the use of this new SEA format, the Region expects tracking
efforts to be more streamlined and of greater utility.  Under the current
tracking system, only the commitments specific to each priority issue are
easily tracked.  All other grant-related commitments must be tracked via
constant cross-reference to the attached work programs.  The revised format
should eliminate much of this problem and simplify the tracking burden.

     Another improvement expected in the area of SEA/grants interface includes
a proposal to restructure the Office of External Affairs to include staff from
the program grants arm of the Region's Management Division.  If approved, this
organizational change should greatly facilitate the Region's measurement and
evaluation of progress on parallel grant programs and SEA priority issues.
In addition, efforts will be made this year to computerize the tracking sys-
tem in order to reduce the time required to prepare status and exception


     As was the case last year, most of those interviewed believe that the
single greatest benefit brought about by the SEA process is the increase in
program coordination.   Because of the face-to-face communication associated
with the negotiation process, both inter- and intra-program coordination has
increased significantly.  This opinion was strongly expressed both by senior
management and staff within the Regional Office and by those interviewed from
the State of Missouri.

     On the other hand, significant gains in achieving true "program integra-
tion," with respect to solving environmental problems, may not be occurring
as rapidly as once hoped.  Clearly the Regional Administrator continues to
believe that the SEA process can be most effective in this type of problem-
solving capacity.  However, it appears that the vast majority of priority
issues will remain program-related in the FY 1981 Agreements.  Most of the
regional personnel interviewed believe this trend is continuing because of
the restrictions placed on grant monies by Congressional mandates, program
regulations and the Agency's Operating Year Guidance.  To correct this prob-
lem, it is felt that Headquarters must continue to push strongly for some
form of funding flexibility within grant programs.

Public Participation

     The process for negotiating the FY 1981 SEAs incorporates a much stronger
role for involving the public in the overall process.  In developing the FY
1981 Agreements, the Region and States have been more successful in incorporat-
ing meaningful public involvement in the priority setting phase.  By issuing
small grants to the States for public participation, three of the four States
have been able to distribute information on the process through the League
of Women Voters, obtain public comments early in the process (during and
after priority issue selection), and schedule public hearings on completed
draft Agreements.

     Response from the public, thus far, has been encouraging.  Both the
Region and States feel that the public involvement process this year has
had significant influence on the types of priorities and commitments addressed
in the Agreements.  Nebraska, the only State that did not have League parti-
cipation, established a similar public involvement process using State staff
and advisory groups.

                                   REGION  VII


                   Phase ]:  Long-Term Problem Identification
                            and Strategy Development
Surra ry
The State/EPA Agreements staff will provide the initiative and primary staff
support to develop drafts of the 5-year environmental problems in each state
and coordinate the development-of strategies to address the problems.  The
regional office program staff will prepare the initial drafts of the 5-year
strategies.  The drafts will be reviewed by the S/EPA Policy Committee, who
will conduct face-to-face negotiations with the states on the problems and
strategies.  The S/EPA Policy Committee is chaired by the Deputy Regional
Administrator ana includes the five Regional Office staff, Division Directors,
Director of External Affairs and Regional Counsel.


1.  Problem Identification -

    •Procedures for negotiating the FY-81 State/EPA Agreements will be
    developed by the State/EPA Agreements Staff and finalized by the S/EPA
    Policy Committee.   The procedures will be presented and discussed with
    each State by the S/EPA Staff.

    «The S/EPA staff will develop a draft that identifies and prioritizes the
    5-year problems by searching out, analyzing, and summarizing information
    from all possible,  appropriate sources, including:

          State environmental agencies
             Interview state personnel in their offices
          PuDlic inputs
             Get views from League of Women Voters in three states
          EPA-7 programs
             Meet with director and branch chiefs
             Interview each branch chief
             Discuss with any other program personnel
          Environmental Profile data
             Use preliminary data to confirm present problems, provide
          Review any Headquarters guidance, other written materials

    *The S/EPA staff will produce a focused and definitive 1-page statement on
    each problem with a goal or goals to be achieved and develop a tentative
    prioritization of the issues.

    *The S/EPA Policy Committee will review and revise the problem
    statements.   The problem statements will be sent to each state for
    review.   If there is not substantial agreement, a face-to-face meeting
    will be scheduled to negotiate the problems.

2.  Develop FY-81 SEA Guidance -

    •The S/EPA staff will prepare a brief (15-page maximum) guidance document
    for use by the states.  The guidance will provide region office views of
    program priorities for use in developing the agreement.  A draft of the
    thrusts ana priorities of the guidance will be reviewed by the S/EPA
    Policy Corrvruttee.

3.  Strategy Development -

    *The Regional Office program staff will develop a draft of the 5-yeai-
    strategy for each problem in each state (approximately 40 strategies; by:

          Telephone discussions with state agency personnel (although much of
          the strategy information can be gathered during the state visit on
          environmental problems).

          Discussions within each EPA-7 program division between the director,
          branch chiefs, and Regional Office staff

    *Copies of the drafts will be sent to the State/EPA Agreements staff for
    analysis and review, then the S/EPA Policy Committee will meet to review
    and revise.

    *Pubiic input on problems and strategies will be reviewed and incorporated.

4.  *Prepare list of on-going state commitments -

          Simultaneously with the drafting of the strategies each EPA-7
          program director and branch chiefs will prepare a list of
          commitments for each state for FY-81.  The commitments from each
          program will be reviewed by the S/EPA Policy Committee in terms of
          total demands being made and trade-off questions.  After revision,
          the S/EPA staff will include the commitments in the set of materials
          to be sent to each state.

5.  Develop Content of SEA -

    *The following will be sent to each state, preparatory to a required 1-day
    negotiating session between the state and the S/EPA Policy Committee to
    finalize the 5-year problems and strategy statements.

          Information for FY-81
             Final Environmental Problems list
             Draft of 5-year environmental strategies
             Target funds available for FY-81
             Draft list of ongoing state program commitments

6.  «finalization of problems .and strategies -

          Face-to-face negotiations of S/EPA Policy Committee with each state
          Resolution of any remaining issues by the State Director and the
          Regional Administrator
          Copies of the 5-year problems and strategies will be sent to the
          League of Women Voters in three states for broad-based information
          dissemination for comments.


        Phase II:  Commitment Development &r»d Finalization of Agreement


Specific commitments by the State and EPA-7 to address each  priority problem
in FY-81 will be developed, along with the remaining cofimitments by the state
to perform expected ongoing activities as a part of its  grant.  Initial drafts
of all the commitments will be developed jointly by state and Regional Office
program staffs, Branch Chiefs, and Division Directors.   This joint draft of
the commitments will be reviewed by the Policy Review Committee and then
face-to-face negotiations will be conducted with each state  to agree upon the


7.  Draft Commitments -

    *EPA-7 and the state will jointly prepare a draft of the commitments it
    will make to each priority problem in FY-81 and the  commitments it is
    asking for from the other.  In addition, the remaining ongoing program
    commitments for each state will be identified and negotiated.  The
    commitments will include:

          Brief description of the activity, stated in terms of products or
          outcomes that are observable or measurable
          Dates for each activity
          Federal and state resources, in terms of workyears and dollars.

    *fcithin EPA-7, the draft of the commitments will be  developed jointly with
    the states, Division Directors, and Branch Chiefs, and coordinated by the
    S/EPA staff with review by the S/EPA Policy Committee.

    *EPA-7 will provide to the state, at the time Phase  I negotiations are
    conducted, a draft list of the ongoing program commitments (for example, -
    number of inspections of majors municipal NPDES) for each program.  The
    state will propose appropriate outputs, dates, and resources for each
    activity.  These will comprise the on-going program  commitments for the
    agreement and grant.

8.  Negotiation meeting on commitments -

    *The S/EPA Policy Committee and the states will conduct  face-to-face
    negotiations to agree upon all commitments.  The Directors will all meet
    on the same day in individual sessions with their counterparts, joining
    together when necessary to address commitments cutting across more then
    one Division.

    •Any issues not resolved will be referred to the State Director and the
    Regional Administrator.

9.  Prepare Final Draft -

    *The final draft of the S/EPA Agreement will be prepared by the S/EPA
    Staff.  The agreement, which will run about 70 pages, will include:

          Executive Summary (5 pages)
          Introduction (3 pages)


          Priority Problems (JO 6 4 = 40 pages)
             3-5 Year problems and goals (1 page)
             3-5 Year strategy (1 page)
             FY-81 priority problem commitments for state and EPA (2 pages;
          FY-81 Program Summary (5 pages)
          List of All State Commitments (6 pages)
             (Including priority problem commitments shown with asterisks)
          List of Other Agreements and Documents Incorporated by Reference
          (1 page)

    *The draft will be reviewed for accuracy by the state, prior to public

10. Public Participation -

    •Drafts of the Agreements will be sent to the League of Women Voters in
    three states.  The State League will conduct public participation
    activities by:

          Widely distributing copies and information, collecting comments, and
          conducting public meetings.  The results will be sent to both EPA-7
          and the state.

    *The S/EPA staff will confer with the state on whether revisions need to
    be made.  If so, changes will be negotiated by the EPA-7 Director involved
    and the state counterpart.

11. Finalization and Signing of Agreement -

    *Tne State Director and Regional Administrator will review the final
    revised draft and sign.

    *The consolidated grant is awarded.

    *The agreements are distributed and publicized.

                      Phase III:  Tracking and Evaluation


The States and Region 7 Divisions will submit written status reports to
EXTR/SEPA at the end of each quarter.  Utilizing this information, EXTR/SEPA
will prepare an exception report of all unfulfilled commitments for review by
the S/EPA Policy Committee.  Formal on-site meetings of Division Directors and
their State counterparts will be held at mid-year and the end of the year.
Other quarterly meetings to discuss specific problems will be held as


12. Each quarter written reports on the status of the completion of each
    priority problem commitment and operating program commitment will be
    submitted to EXTR/SEPA by EPA-7 Division Directors and State Directors.

13. The S/EPA staff will prepare an "Exception Report" listing those priority
    problem commitments ano operating program commit/rents not fully completed.

14. The S/EPA Policy Committee will meet quarterly to review unaccomplished
    commitments for that quarter.

15. EPA and State Directors will meet at the end of the second and fourth
    quarters to evaluate the completion of priority problem commitments and
    operating program commitments.

                    Timetable for FY-81 State/EPA Agreements

                                    Phase I

    1.  Develop draft of 5-year problems               1/28 - 2/29
          Review by S/EPA Policy Committee             3/3  - 3/11
          Review by state and meetings
            with states, if necessary                  3/12 - 3/21

    2.  FY-81 Guidance
          Develop and issue                            3/3

    3.  Develop draft of 5-year strategies             3/3  - 3/31
          Review by S/EPA Policy Committe              4/1  - 4/11
          Send to states for their review              4/7  - 4/18

    4.  Develop list of ongoing commitments for
        FY-81                                          2/25 - 4/4
          Program drafts                               2/25 - 3/21
          Review by S/EPA Policy Committee             3/24 - 4/4

    5.  Develop guidance for states                    2/18 - 3/28
          Finalize procedures for FY-81
            negotiations and distribute                1/14 - 2/1
          Develop SEA Content                          2/25 - 3/21
          Review by S/EPA Policy Committee             3/24 - 4/4
          Issue SEA Content Package                    4/7  - 4/11

    6.  Negotiate with each state                      4/21 - 5/2
          Finalize by State Director and R.A.           5/5  - 5/9
          To League of Women Voters                    5/2

                                    Phase II

    7.    Develop draft of commitments                 5/5  - 6/9
             EPA-7 and state programs  prepare  drafts    5/5  - 6/6
             Prepare complete draft of SEA             6/2  - 6/6
             Review by S/EPA Policy Committee           6/9  - 6/13

    8.    S/EPA Policy Committee negotiate
          commitments with each state                   6/16 - 6/27

    9.    Prepare complete final drafts                6/30 - 7/3

ID.    To League of Women Voters                    7/3
         PubHc hearing/meeting and comments       8/4  - 8/15
         back from League

11.    Revisions,  responsiveness summary            8/18 - 8/29
         Signing of agreements                     9/8  - 9/12
         Award grants                              9/15
         Distribution and publicity                9/15
                               Phase III

12.   Reports on status of commitments             3rd week after end
      by states and EPA program divisions          of each quarter

13.   S/EPA staff prepares "Exception Report"      4th week after end
      on accomplishment of commitments             of each quarter

14.   S/EPA Policy Committee Review of             5th week after end
      status of commitments                        of each quarter

15.   Meeting of state and EPA directors to        end of 2nd and
      review accomplishment of commitments         4th quarter


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                       REGION VIII  SEA  TRIP  REPORT

     On June 24-25, 1980, Tim Icke of the Water Planning Division and
Jerry Emison of the Program Evaluation Division met with key Region VIII
staff to discuss the status and experiences of Region VIII FY  '80 SEAs
and the preparation of FY '81 SEAs.


     The State-EPA Agreements have become a principal means for the
Regional Administrator, Deputy Regional Administrator and Division
Directors to establish with their State counterparts the thrust of
environmental programs during a particular fiscal year.  This can be
attributed to:

     •  Top management's commitment to using SEAs
     •  Inclusion of all EPA programs
     •  Emerging State recognition of SEAs  use to them

RA and Senior Managers Use SEAs for Key Choices

     The RA uses SEAs to identify and choose those environmental issues
he believes necessary for EPA and a State to pursue.  This is accomplished
in two ways:

     •  Early in the process the RA identifies his priorities
     •  These priorities are negotiated by the lead Division Director
        and the State.  The mutually agreed priorities are reviewed by
        the RA.

     The Division Directors use the SEAs to make choices in two ways:

     •  Each Division Director acts as the Region's representative
        with one State.  In this role, he must negotiate the Region's
     •  Each Division Director must ensure that the person negotiating
        with each State understands the issues concerning his program
        and is able to represent the views essential to the conduct of
        that program in the State

SEAs Cover All Programs

     The FY '80 Agreements in Region VIII covered every EPA program that
is carried out in concert with the States.   The FY '81 SEAs are being
negotiated on that same basis.   This broad coverage is especially impor-
tant because the negotiations for the SEAs also represent the negotiations
for all grant agreements.  The Regional staff, however, indicated that

often grants processes and their associated planning and guidance
documents are not in phase with SEAs regard to timing.

The Region Plans to Start Earlier Next Year

     The SEA process for FY '81 did not begin until April 1, 1980.  This
resulted in some especially tight deadlines that both the Region and the
State were able to meet only by limiting analysis and consultation both
within the Region and the State and between the Region and the State.  The
Region plans to start preparation of the FY '82 Agreements during the early
winter so that ample time is provided for analysis, consultation, and exp-
anded public participation.

The Process Has Both Organizational Breadth and Depth

     The Region VIII SEA process has been designed to involve the widest
range of staff views while at the same time obtaining the depth of know-
ledge found in each individual program.  While this is a distinct plus
in improving SEA quality, the staff indicated that it was a very time
consuming and resource intensive process .   Within the Regional Office
SEA development is based on these responsibilities:

     •  RA provides overall policy and strategy direction for issues within
        a State
     •  Division Directors, as lead for one State, negotiate all programs
        with that particular State.  They also ensure that for all States
        their media receive the emphasis, analysis and attention essential
        to deal with relevant environmental problems in each particular
     •  SEA coordinators for each State assist the State's lead Division
        Director in the analysis,  assembly and negotiation of SEAs with
        the States.
     •  Branch Chiefs are responsible for seeing that their programs
        receive appropriate emphasis in the negotiations.  They are also
        responsible for developing and negotiating particular work plan
        elements and commitments associated with their programs in each
        State .

Assignments Cut across Programs

     Region VIII uses a matrix management approach for the preparation
and negotiation of SEAs.  Each Division Director is assigned the lead
responsibility for serving as EPA's representative in negotiations with a
particular State.  With assistance of his SEA coordinator, who is tempor-
arily detached from another Division, the lead Division Director must
orchestrate the preparation of all negotiating positions and analysis
for his State and conduct the actual negotiations.  This requires the
Division Director to think not only in terms of his own program for every
State, but also requires him to think in terms of all programs for a part-
icular State.  A number of Division Directors stated that having to represent
all programs to one State had given them a fresher perspective seeing how
their work integrated with other programs, and that this enabled them to

provide more service to other programs.  Since the SEA coordinator for each
lead Division Director was detailed from another Division, this further
guaranteed a balanced consideration of the program issues.  This situation
has, however, resulted in some confusion about the responsibility of
individual program offices to people not directly in a line management

Process Stresses Wide Inputs

     The SEA process in Region VIII draws on inputs from both the State
and the Regional Office.  While the Regional Office is going through the
process of preparing its agenda and developing its work plan for SEAs,
the States are also conducting similar activities.  The degree of emphasis
and amount of preparation accorded this activity by the States varies
highly.  Regardless, the Regions and States continually work together in
the process.  Colorado, for example, seems to value the SEA not only in
its role as a negotiation tool with EPA but also as a tool to identify and
manage internally the activities essential to the Colorado program.

Program Staff:  Key to Day-to-Day Functions

     In FY '80, once the Agreements were negotiated and set, it became
the individual program managers' responsibility to track the progress
of the program in each State.  They maintain these relationships in two

     •  Day-to-Day contact with their regional counterparts.
     •  Quarterly formal reviews of SEA progress in the State.

The mid-year (second quarter) and end-of-year reviews are chaired by
the lead Division Director for the State using program-specific information
prepared by the program staffs.  There appeared to be a difference of
opinion at the program level about the utility of SEAs.  Some program mana-
gers indicated that EPA should be undertaking these activities whether
under the SEA umbrella or not.  Other program managers believed that only
limited advantages could be gained from the SEA.  One certain advantage
seemed to be that the SEA formalized and focused the discussion of the
program staff with their State counterparts on achievements and accomplish-

EPA Has Had Mixed Successes

     This process has caused some States to carry out activities they
would not have undertaken otherwise.  The State of Utah's assumption of
primacy under drinking water falls in that category.

     EPA has also used SEAs to focus on problems at the State level which EPA
could help solve.  At the request of the North Dakota Department of Health,
Region VIII undertook a detailed program evaluation that the State managers
presented to the legislature in defense of an expansion of their budget.

     On the other hand, EPA raised the issue of pesticides disposal
with South Dakota during SEA development.  While the SEA process did
strengthen communication between the South Dakota Department of
Agriculture and the Department of Health, disagreement remains on
the issue of responsibility for pesticide disposal sites in the State.


     In the initial stages, the preparation of priority issue areas in
the SEAs is carried out in a parallel fashion between the Regional
Offices and the State.  When the SEA process is initiated, the State
is asked to develop its priority issue areas as well as its work plan.
EPA in the process described above, also commences similar work.  From
that point on, priority development is a joint activity.

Method is Guided, but Bottom-Up

     Within the Regional Office, priorities are set in two ways.  The
RA identifies his key areas of emphasis at the same time the program
staffs are identifying areas of concern.  The lead Division Director
then discusses with the RA and the program staffs the appropriate
level of emphasis for both cross-cutting and program-specific issues.
In this way, the concerns of day-to-day program management are defined,
discussed and decided upon in the context of overall top management

National Guidance is a Signal; Regional Guidance more Firm

     At both the program manager and top management levels, Region VIII
staff view the National Guidance as an indicator of the type of emphasis
that should be accorded the topics in the SEAs.  They did express concern
that every Headquarters program office seems to insist that its programs
receive priority treatment.  When the Regional Office, in executing its
SEA responsibilities, must make the choice of emphasis, the National
Guidance does not provide enough information to trade off issues against
each other.

     The Region provides its States a Regional Guidance in the preparation
of SEA.  This guidance is oriented towards format and broad policy topics
common throughout the Region and stresses procedures with the following
basic coverages:

        Organizational responsibilities
        Region VIII objectives
        SEA format and content
        Public participation
        Cross-cutting issues

Problem-Solving Issues are Increasing

     The percentage of priority issues devoted to cross-cutting or integra-
tive topics in Region VIII is on the rise.  In FY '80 very few topics were
of this type; most SEAs stressed programmatic achievements.  In FY '81 the
Region expects about fifty percent of the topics to be programmatic; with
the remainder being either cross-cutting or non-programmatic issues.

Most Successes Involve Setting Agendas

     In the opinion of the Region VIII staff, the most beneficial result
of the SEA process was the setting of an agenda to guide the work of the
States during the upcoming fiscal year.  This involved getting the States
to take into account issues that EPA considered of importance, such as
energy development in western North Dakota.  It also included topics that
EPA had not considered but which the State viewed as important, such as
agricultural land control in North Dakota.  When asked to identify signi-
ficant achievements made by the SEAs, the preponderance of the staff in
Region VIII identified coming to a common understanding of the responsibili-
ties of EPA and the State; that is, setting the environmental agenda for
both the State and EPA.


     Region VIII?s conduct of the SEAs emphasizes meeting the needs of
top management in both the State and Regional Offices.

SEAs and Grants are Closely Tied

     The negotiation for a program grant is conducted under the aegis of
the SEA.  When the SEA is negotiated, its contents and the associated work
plan become that of the grant and no further individual grant negotiations
are conducted.

Tracking Is through Personal Contacts

     The tracking of the SEAs occurs in the day-to-day telephone contacts
of the program managers with their counterparts in the State governments.
The more formal tracking takes place quarterly.  In the first and third
quarters,  program managers individually meet with their counterparts in the
State to discuss progress.  The SEA commitments and activities form the
subject of this review.  In the second and fourth quarters,  the RA,  DRA and
Directors conduct this review with their State counterparts, emphasizing
overall State progress made in meeting the SEA commitments.

Managers Are Committed to Using SEAs

     The Division Directors,  DRA and RA appear to strongly support the use
of SEAs as a means for prioritizing and monitoring the activities essential
not only for the State but EPA in a fiscal year.  At the State level this
view is tempered somewhat.  The State of Colorado views the SEA as not
only a process to work with EPA,  but also to manage within the division
and to represent the division in negotiations over resources within the
Department of Health.   At the other end of the spectrum is the State of
Wyoming, which views the process as another hoop through which to jump
to get a grant.   The other States appear arrayed between these two poles
of opinion.

Multi-Year Strategies Lack Specificity

     Each one of the SEA priority areas is required to have a multi-
year strategy.  Conversations with the Region VIII staff,  and review
of the multi-year strategies, indicated that these strategies lack
a great deal of specificity.  Part of this problem has been attributed
to unfamiliarity with the concept and partly to the reluctance of
managers to spell out long-term action when they do not control the
resources necessary to carry it out.

Public Participation:  A Developing Process

     Public participation in Region VIII has basically been confined to
the conduct of public hearings once the SEA has been prepared in draft
form.  The Region plans to alter this approach to obtain public input
early in the setting of the priorities for the next fiscal year.

States Have First-Line Responsibility

     Region VIII looks to the States to provide public participation
for SEAs.  In Colorado and Montana, participation was achieved through
the use of standing advisory committees.  In Colorado a committe was
involved at the priority-setting phase and as the process  became more
specific, involvement decreased.  The Region's attitude seems to be that
the States are closest to the citizens and their interests, and therefore
can be most effective reaching the citizens.

Timing Changes Planned for Next Year

     The Region expects to begin the SEA process earlier for FY '82.
One of the principal reasons for doing this is to provide  time for a
formal public input to the identification of priority areas.

                      REGION VIII SEA TRIP REPORT

                            ATTACHMENT 1

                         PERSONS INTERVIEWED
Mr. Gene Lucero, Deputy Regional Administrator
Mr. Lance Vinson, Director, Enforcement Division
Mr. Irv Dickstein, Director, Surveillance and Analysis
Mr. Jim Lehr, Deputy Director, Air and Hazardous Materials Division
Mr. Harvey Hormberg, Director, Office of Public Facilities and Grants
Mr. Pat Godsil, Chief, Water Planning Branch
Ms. Joan Barnes, Chief, Resources Management Branch
Mr. Jack Hoffbuhr, Chief, Water Supply Branch
Mr. Dallas Miller, Pesticides Program Staff
Mr. Bill Basbagill, SEA Coordinator for Wyoming
Ms. Loretta Pickerell, SEA Coordinator for North Dakota
Mr. Duane Traylor, SEA Coordinator for Colorado
Mr. Bob Arnott, Colorado State Assistant Director for Health Protection
     and Environmental Programs
Mr. Steve Kelsey, Colorado State Department of Health

                         REGION IX  SEA  TRIP REPORT

    On July 16-17,  1980,  Saul  Rosoff, Associate Assistant Administrator,
 Office of Planning  and Management,  and Judith Wheeler, Water  Planning
 Division, visited Region  IX  to perform the FY  '81  SEA Assessment.

 Persons Contacted

    Mr. Paul De Falco, Jr.,  Regional Administrator
    Ms. Sheila Prindiville,  Deputy  Regional Administrator
    Mr. Frank Covington,  Director,  Water Division
    Ms. Catherine Kuhlman, SEA Coordinator

    Directors:  Air and Hazardous Materials, Enforcement, Management,
                Surveillance and Analysis Divisions

    Mr. Mike Reed, Arizona Branch, Water Division
    Mr. James Thompson, Nevada Branch, Water Division
    Mr. Steven Pardieck,  Pacific Islands Branch, Water Division
    Mr. Dick Coddington,  California Branch, Water  Division
    Ms. Loretta Barsamian, California Branch, Water Division

    State of California

    Ms. Mary Shallenberger,  Office  of Planning and Research

 Regional Summary

    The Regional Administrator (RA) and Deputy Regional Administrator  (DRA)
 evidenced strong support  of  the SEA process and actively participated  in the
 SEA assessment effort.  They view the SEA as an agreement in  principle,
 connected to the grant work  plans by policy commitments to perform specific
 activities.  In Region IX the  process is started in late fall by meetings
 between the Governor and  the RA to  identify priority problems and/or organi-
 zational responsibility for  SEA development.

    The Regional organization  remains unchanged from last year.  The
 Regional SEA Task Group defines EPA priorities and develops Regional policy
 on public participation,  tracking and other SEA related activities.  The
 Task Group consists of Division Directors, State Branch Chiefs, State  Project
 Officers and other Regional  staff as appropriate.  They also meet as necessary
 to resolve problems that arise during implementation of the SEAs.  Day to day
 oversight and coordination rest with the SEA Coordinator.

    It is anticipated the FY '81 SEAs will be signed by August and the
work on program grants (except 208)  will be completed by October, 1980.

FY '80 SEA

Process and Organization

    Lead responsibility for the FY '80 SEA coordination was in the
Water Division.  Each State Branch was assigned lead responsibility
for negotiating its State's SEA.  Representatives from other Divisions
were assigned to each State team.  A multi-divisional team of Division
Directors and staff met weekly and were involved in the development
and review of the SEAs.

Procedures for Identifying Priorities

    Priorities were developed by the Regional Office based on State
profiles developed from 208 plans, monitoring data, 305(b) reports,
air quality management plans, SIPs, solid waste management plans and
other pertinent data.  State Branch Chiefs worked with the States to
refine the priority lists.


    FY '80 SEA priorities were reflected in the grant program work plans.
Tracking of commitments was tied in with the quarterly and midyear grant
reviews.  The SEA review was performed by the EPA grant project officers
who relayed their findings to the SEA project officers.  Arizona held a
public workshop to review progress of the FY '80 SEA and to obtain public
input for development and State priorities in the FY '81 SEA.  While it
was agreed that the SEA process did not reduce paperwork, the Region
noted a more efficient use of paperwork.

    Except for California, most of the FY '80 SEAs involved single State
Agencies.  The Governors' Offices were involved in those agreements.
For the California agreement EPA coordinated negotiations with seven
State agencies, and there was only limited involvement of the Governor s

Public Participation

    In general, the Region found public participation in the FY  '80 SEA
process disappointing, despite substantial efforts on the part of the Region
and State agencies.
FY '81 SEA

Regional Overview

    Region IX views the SEA as an agreement in principle which addresses
top priority problems.  The focus is on problems rather than EPA programs,
Sustained high level participation by the State and the Regional office
is key to the success of the process.  To implement this philosophy the

 Regional  Administrator  started meeting with  the  Governors in late 1979.
 These meetings  provided  an  opportunity to  discuss  the  States'  environmental
 problems  in  a non-confrontational  setting.   Extensive  staff  work was  done
 by the  States and  the Region  in  preparation  for  the  RA/Governor meetings.

     As a result  the meetings were extremely productive  and  resulted  in
 either  an identification of major  priority issues  or decision  regarding
 the roles of EPA  and the State in  the  SEA  process.

     All  Region IX SEAs  are expected  to be signed  by mid-August.   The
 agreements will drive the grant  process.   Work on  program grants (except
 208) will be completed by October  1,  1980.   Among  the  benefits of the SEA
 process identified by Region  IX  is that it highlights  problems and focuses
 resources at the  State and  EPA level.   While the agreements  themselves
 are general  in  nature,  the  grant work  plans  identify specific  outputs to
 achieve the  goals  identified  by  the SEA.   In some  cases  policy documents
 provide a linkage  between the SEA  and  the  grant  work plans.   The Region  is
 preparing "cross walks"  which identify these linkages.

 Regional  Process  and Organization

     A  tracking strategy is being  developed  by Region  IX. Currently  track-
 ing is  done  through quarterly progress reports and mid-year  evaluations  by
 the program  grant  officers.   It  is expected  that,  at a minimum, a Divis  on
 Director  and key  staff will attend mid-year  evaluation meetings,   In
 California,  which  is a multi-agency State, one meeting will  be held with
 EPA Division Directors and  State Agency Executive  officers to  discuss SEA

     Lead  responsibility  for  the SEA process  is  in the Water Division,
 which is  organized  by State Branches.   There  is  a Regional SEA Task Group
 which meets  weekly.  Task Group members include  Division  Directors, Branch
 Chiefs, SEA  State  project officers, and other  staff  as appropriate.   The
 Task Group was  responsible  for identifying priority  issues for each State.
 The  priorities  were based on  305 (b) Reports,  needs  assessment, 208 plans,
 State Environmental Profiles, and  the Agency Operating Year Guidance.
 After the priority  issues were identified and  conceptual  agreement reached
 with the  State,  the Regional  Office developed  programmatic guidance which set
 forth program objectives  and  defined what the  States must do to qualify  for
 grant funds.

 Public Participation

     In general, Region IX felt a great deal of  time and money  was put into
 public participation without getting much from it.   In Nevada a grant was
made to the League of  Women  Voters to encourage public  involvement in the
 SEA Process.   The  Arizona League  of Women Voters  had a similar  grant and  the
 State contributed  with  press releases,  speakers and staff support.  California
added some of its  own  funds  to the grant.  Public meetings were held on the
draft SEA  in each  State.

jJevada SEA

      In the highly productive meeting between the Governor and the RA, the
decision was made  to emphasize priority problems  that are visible and  address-

able.  Nevada has most of its population in two urban areas and the State
government is weak in relation to local government.  The growth rate is
the fastest in the nation.  There is strong budget pressure to limit state
government.  Because the State agencies are small, EPA took a major role in
drafting the FY '81 SEA.

Priority Issues

     The Regional Office reviewed each geographical area of the State to
determine the priority issues.  Consideration was given to whether a given
program delegation would help solve the associated environmental problems.
It is anticipated the final SEA will address ten priority problems ranging
from several relating to specific air and water quality problems (e.g.,
Tahoe, Clark County) to broader based problems such as ground ground water and
solid/hazardous waste.

Public Participation

     A $10,000 grant was given to the League of Women Voters to conduct
SEA public participation activities.  The League prepared and distributed
six media fact sheets and conducted two workshops with about fifty attendees
at each.  Because of the relatively large number of newcomers to the State,
who do not have strong roots there, it is difficult to get extensive public


     •  Governor's priorities clearly identified
     •  Possible future bi-State (Nevada, California) agreement regarding Tahoe
     •  Major programmatic decisions made in overall context


     Arizona is the third fastest growing State in the nation with approxi-
mately 75% of its population in the Phoenix and Tucson areas.  27% of the
land area of the State is Indian Reservations, 44% is Federally controlled,
13% is owned by the State and 16% is in private ownership.Governor Babbitt
and his office have taken an active role in SEA development.  The Department
of Health Services has lead responsibility for all EPA grant programs except
pesticides.  The Office of Economic Planning and Development coordinates
SEA development.  Arizona has used the SEA to bring policy questions to
the attention of higher level decision makers in relation to proposed
State air quality regulations.

Priority Issues

     Priority problems include six air quality issues such as metropolitan
area air quality and multi-point rollback regulations; water quality manage-
ment problems receiving insufficient resources to maintain programs at
current levels; ground water (need for a comprehensive State program); solid
and hazardous waste, including interim authorization and hazardous waste
disposal site selection; pesticides and toxics; emergency response; and

Public Participation

     A $10,000 grant was made to the League of Women Voters to work with
eight targeted groups to involve them in the SEA process.  Targeted groups
included Junior League, Arizona Nurses Association, Universal Unitarian
Church, and Tucson Singles Council.  Programs were set up tailored to each
group's interests and needs.  Written information was distributed; there
were slide shows, speakers and panels, and response forms.  The meetings
were well attended and generated lively discussions of the issues.  Regional
evaluation of this effort was that it was not time and cost effective to
try to develop a personalized program for each group; rather, preparation
of a standard public relations package to reach as many community groups
as possible through statewide workshops would be a better approach.


     •  Involvement of Governor's office
     •  Public input impacted SEA
     •  SEA drives the work plan


     Eleven media specific agencies are participating in the FY '81 SEA.
Overall coordination is performed by the Governor's Office of Planning and
Research (OPR) rather than by EPA as was the case with the FY '80 SEA.
In California, Department and Board heads have strong policy making ability.
EPA FY '80 grants for all media programs totalled over $28 million.  About
$12,000,000 of this grant money goes to the State Water Resources Control
Board (SWRCB).  California differs from  many other States not only in the
autonomy and number of State agencies concerned with environmental programs,
but in the fact that State funds heavily overmatch Federal funds.

     The FY '80 SEA addressed one cross-cutting issue - toxics management.
For FY '81 it was decided to address three new issues in addition to updating
the toxics agreements.   The SEA is an agreement in principle which defines
the roles of the participating agencies.   There is also a policy statement
from the SWRCB which provides a link between the broadly worded SEA and the
program work plans.


     The SEA process began with a meeting between the RA and the Governor's
office to define roles and responsibilities.   OPR was given lead responsibi-
lity to coordinate the SEA.   Early in the year OPR met with agency heads
to begin the problem identification process.   OPR drafted a description of
each of the problems it identified which  was  then reviewed by the State
agencies.   At that point in time,  EPA became  involved in the priority setting
process.   A meeting was held with State Agency heads which was attended
by the RA and Water Division Director to  finalize the priorities.

Priority Issues

     Both OPR and EPA independently developed priority lists.  The State
placed emphasis on priority issues which needed coordination - thus air
quality, while a major environmental problem in California, was not
included as a SEA priority because it is not an issue needing coordination.
Since the SEA is oriented toward State problems needing coordination rather
than EPA programs, some problems are included in the SEA which are unrelated
to EPA grant programs.

     The Four priority problems identified in the FY '81 SEA are:  toxics
management; ground water quality (unrelated to EPA grant programs); waste
reduction, resource recovery and recycling; and water conservation, reclama-
tion, and reuse.

Public Participation

     A fact sheet, developed with the assistance of the league of Women
Voters, describing the draft SEA was mailed to a wide list including
COG's, private industry, local government, and public interest groups.
There was substantial telephone response to this mailing.  A public
meeting was held July 15 with very small attendance.  In general the wide
variations in Californis (e.g., over half the population is in the bottom
one-quarter of the State and over half the water is in the north) make true
statewide public attention difficult.
        Process accepted by State
        Involvement of 11 State agencies
        Continuation of toxics activities (newly created Toxics Substances
        Coordinating Council)
        Three additional problems addressed
        Increased State role through coordination function of OPR
        SEA directs State activities; goes beyond EPA funded activities
        SEA drives work plan process
     The FY '81 SEA will include CWA, CAA, SDWA and the RCA programs in
the Department of Health and, for the first time, the pesticides program
in the Department of Agriculture.  The agreement includes activities which
go beyond EPA - funded programs.


     Ground water management and water supply are the top priority
problems in Hawaii.  Other priorities are non point source run off, point
source, hazardous wasted, air pollution in certain limited areas, and
monotoring and data support.  The Department of Agriculture priorities
involve pesticide use regulation and environmental monitoring for pesticide

Public Participation

     Public hearings-were held  in  all  four counties in conjuction with
other environmental issues  such as the construction grants priority list
and  208 plan revisions.  There  was limited attendance which was attributed,
at least in part,  to cultural attitudes  toward public involvement.  In
addition, environmental problems are not perceived by the public to be


     •  SEA successfully used by DOH in  dealing with the State legislature
on budgetary matters

Pacific Islands

     The Pacific Islands include the Northern Marianas, Guam, the Trust
Territories and American Samoa.  Grants  to the island are made under the
Omnibus Territories Act which waives the matching share and provides for
a block grant.  Each of the island groups has a centralized environmental
agency.  Because of the consolidated grant process the SEA can easily be
related to the grant.  The draft SEAs  were developed by the Regional Office
based on environmental profiles.   EPA  has IPA's in Somoa, Guam and the
Northern Marianas at the Deputy Director level.  The Governor in each
island group will sign the SEAs.

Priority Issues

     The major problems in the Pacific Islands are public health, water
supply, and ground water degradation.

Public Participation

     For the islands, public participation consists mainly of review of
the draft SEA by environmental and other agencies.


     •  More efficient paperwork
     •  Improved relationships between EPA and island government


     Several areas of Regional concern were identified during the assess-
ment.  The Region noted that guidance has been sent out by various
Headquarters program offices subsequent to the issuance of the Agency
Operating Year Guidance which requires that additional items be considered
for inclusion in the SEA.  'Because the priorities in Region IX States are
identified early in the calendar year it would create credibility problems
for the region were they to add new items to the State negotiations after
conceptual agreement had been reached  (usually in mid-April).

    Another Regional comment regarded the length of some of the guidance
material (other than the Operating Year Guidance) being sent to the Regions.

    The Regional Administrator expressed his concern that the SEA remain
flexible and be reserved as a high level document to address top priority
issues only.

Assessment Team Comments

    Region IX has a substantial and serious commitment to the SEA process,
which is evidenced by the direct involvement of the RA and DRA.  Extensive
new ground was broken in the area of priority problem identification.
The Region has used the SEA successfully as a top level document and,
through the SEA process, has established and strengthened relationships
with the Governor's Offices.  The SEA provides the policy basis for defining
activities and outputs in the program work plans and the timing of the
Regional process provides for completion of the SEAs early enough to allow
completion of most work plans by the beginning of the fiscal year.

    The Region is currently developing a tracking strategy.  One area
which needs further thought is public involvement.  The Region has recognized
this as a problem area that must be addressed by both the Region and the
Headquarters during the coming months.

                        REGION X SEA TRIP REPORT

Background Information

     On July 14-15, 1980, Saul Rosoff, Associate Assistant Administrator,
Office of Planning and Management, and Judith Wheeler, Water Planning
Division, visited Region X to perform the FY '81 SEA assessment.

Persons Contacted

     Mr. Donald DuBois, Regional Administrator
     Mr. Ed Coate, Deputy Regional Administrator
     Mr. Richard Bauer, Chief, Resources Management Branch
     Ms. Alex Smith, Director, Air and Hazardous Materials Division
     Mr. Lloyd Reed, Director, Enforcement Division
     Mr. Bob Burd, Director, Water Division
     Mr. Jim Sweeney, Alaska Operations Office
     Mr. Lyman Nielsen, Washington Operations Office
     Mr. Lynn McKee, Idaho Operations Office
     Mr. John Vlastelicia, Oregon Operations Office

Regional Summary

     The Regional Administrator and Deputy Regional Administrator continue
to strongly support the SEA concept and process.  The Regional organization
remains the same as it was last year, with lead responsibility for
negotiating SEAs in the Operations Office and coordination responsibility
in the Resources Management Branch.  The Divisions provide guidance and
support.  The Operations Offices now have increased responsibility for
managing program grants.  The Regional SEA format is unchanged.

     The 1981 SEAs will cover all EPA programs, with the possible exception
of pesticides in Washington.    Emphasis is being placed on refining the
FY '80 SEAs to define more accurately the outputs and time frames for
solving priority problems.  The Region will continue to regard the SEAs
as bilateral agreements by making Regional commitments.  The FY '80 SEAs
were used during the mid-year and quarterly evaluations and Region X tracks
commitments made in the SEAs.

     Because the FY '80 SEAs  identified many long-term priorities, the FY '81
SEAs are less concerned with identifying new priorities than with refining
existing priorities to reflect problems and updating activities related to
the FY '80 priorities.   Of major concern are possible budget problems in
Oregon which could result in a 15% to 30% cut in State programs and may lead
to a decision not to accept program delegations.

     There appeared to be substantial improvement in the relationship
between the Regional Office Divisions and the Operations Offices.  A
meeting was held July 23 to clarify the remaining questions regarding
respective responsibilities.

FY 1980 SEA


     State                                   Covered Programs

     Alaska                                  CWA, RCRA, SDWA, CAA
     Washington                              CWA, RCRA, SDWA
     Oregon                                  CWA, RCRA, SDWA, CAA
     Idaho                                   CWA, RCRA (limited), SDWA,
                                             CAA (very limited)

Process and Organization

     For the FY '80 SEAs primary responsibility was placed in the Operations
Office in each State.  Divisions in the Regional Office were responsible
for providing guidance and assistance and retained responsibility for
management of some program grants.  The Resources Management Branch
coordinated SEA development.

Procedures for Identifying Priorities

     Priority lists for each grant program were developed by the Divisions.
These lists were used by the Operations Offices as the basis for negotiating
SEA priorities with the States.


     SEA priorities were reflected in the grant work plans and, in some
cases, in multi-media work plans relating to integrated problems.  Progress
toward meeting SEA commitments was tracked through quarterly and mid-year
reviews.  Personnel performance agreements were related to SEA responsibilities.

     Environmental profiles for each State were used to develop priorities.
Multi-year strategies were included in each agreement for water programs and
in some agreements for cross-cutting issues.

SEA Commitments

     Region X made numerous commitments in the FY '80 SEAs and had substantial
success in meeting them.  Many of the State commitments were unrealistic.  The
FY '81 SEAs show changes in commitments which reflect a more realistic approach
to problem-solving based on experience with the FY '80 Agreements.

 Public Participation

      Public participation in the FY '80 SEAs was  limited.   For  example,
 in Alaska EPA did  not  participate in the SEA workshop  and  general  attendance
 was limited.  In Washington inadequate time  was left for public participation.
 In Idaho, two citizens attended the SEA workshop.

 General Comments of  FY 1980 Experience

      Region X and  its  States broke a great deal of new ground in identifying
 cross-cutting issues in the FY  '80 SEAs.  Strong  emphasis  was placed  on
 multi-year and multi-media stategies.

 FY 1981 SEA


      State                Expected Signing Date          Covered Programs

      Alaska               9/30/80                       CWA, CAA,  SDWA, RCRA,
      Oregon               9/1/80                        CWA, CAA,  SDWA, RCRA,
                                                        Pesticides (limited),
      Washington           9/30/80                       CWA, CAA,  RCRA, SDWA,
      Idaho                9/15/80                       CWA,CAA,RCRA,SDWA,
                                                        Pesticides (Separate

 Process and Organization

      The Region X  organizational structure remains the  same as  last year's.
 Increased responsibility is  being given to the Operations  Offices  to manage
 the program grants.

      Once a month  the  Directors  of  the  Operations Offices  come  to  the Regional
 Office.  At that time  an SEA status meeting  between the program managers, staff
 and the Operations Offices Directors is held.  The SEA process  and status in
 each  State is reviewed  and any problems are  addressed.

      In general more State agencies are involved in the FY  '81  SEA process
 than  were involved in  FY  '80.   In addition to the lead agency in each State,
 Alaska will be involving  the  Alaska Coastal  Zone Management Agency, Oregon and
 Washington have been negotiating with the State Department of Agriculture
regarding  pesticides, and .Idaho  is involving  the  Department of Agriculture
 (pesticides) and  the  Department  of Water Resources (UIC program  for wells
over 18 feet deep ).

Procedures for Identifying SEA Priorities

     The Regional approach for identifying FY 1981 SEA priorities remains
unchanged from FY '80.  Environmental profiles and 305 (b) reports are used
to identify priorities for each State by program.  Based on the Agency
Operating Year Guidance, Regional guidance is developed for each program
which defines negotiating bounds.  These priorities and the guidance are
sent to the Operations Offices and provide the basis for negotiations with
the States to develop mutually acceptable priority lists.  Generally, there
have not been any major disagreements over priorities.  However, there may
be a problem regarding the 205 (g) delegation in Oregon and the NPDES
delegation in Washington (which relates to control of Indian lands).  In
the FY '81 SEAs relatively few new priorities are being identified, since
many of those in the FY 80 SEAs were multi-year problems.  Rather, FY '80
priorities are being updated.


     The SEA management system for FY '81 remains the same as in FY '80.
SEA priorities are reflected in program work plans and multi-media work
plans.  Tracking is based on quarterly reports and mid-year evaluations.  In
general, both the States and EPA have met their FY '80 commitments.  In some
cases SEAs were amended to reflect changed conditions.  Where FY '80
commitments were unrealistic or too numerous, changes are being made in
the FY '81 SEAs to provide more achievable commitments.

Public Participation

     Although efforts were made to involve the public in the development of
the FY '80 SEA, success was limited.  For FY 81, at a minimum, public meetings
on the draft SEA will be held in each State.  A State-by-State breakdown
of public participation for the FY '81 SEA follows.

     Alaska:  A notice of intent to begin the SEA process was available
              in late April.  In June, 3000 State questionnaires on
              environmental problems were sent out and approximately
              200 responses were received.  Three workshops will be
              held on the draft SEA.

      Idaho:  The FY '81 SEA process has shown improved public participation.
              Only two people attended the FY '80 public meeting.  For
              FY '8l there was increased involvement of local government,
              COGS   Health District and industrial groups throughout
              the year.  Numerous drafts of the SEA were sent out and
              public meetings held after the draft was prepared.

     Oregon:  Public participation retreats for State agency staff
              and others were held in January and February to begin
              to identify priority issues.

 Washington:  FY '80 public involvement was very limited.  For the
              FY '81 process 4000 notices were sent out to the
              public that the process was beginning.  Key SEA
              papers, including the draft SEA, were available at
              information centers in public libraries, State office?
              and EPA.  The Executive Summary was sent out upon

General Regional Perspectives

     The SEA concept is completely compatible with the Region X management
concept.  The Region used the Agency Operating Year Guidance in the
priority-setting process, although the Guidance came too late for the
initial Oregon problem identification meetings.  The RA and DRA expressed
their belief that strong statements are needed from the Administrator and
Deputy Administrator regarding which priorities are the most important.
They also expressed concern for the manpower demands of the SEA on both
the Region and the States and strongly supported keeping the SEA as
flexible as it currently is.  At least two States (Oregon, Idaho) in Region
X expect substantial resource problems because of legislative spending
limits which will undoubtedly impact SEA commitments.  The RA and DRA said
the public participation aspect of the SEA has been disappointing.

     The Director of the Air and Hazardous Materials Division commented
on the supportive attitude of Headquarter's Air programs regarding inclusion
of air in the SEA.   She would like to see clearer guidance concerning the
inclusion of pesticides and radiation in the SEA.  Pesticides are managed
by State Departments of Agriculture which fear losing the program to State
environmental agencies.  In addition, she believes that the Regions need
more toxics staff in order to gain credibility with the States as to the
importance of toxics control.

     The Enforcement Division Director said his Division has limited
involvement in the SEA.  Compliance Assurance Agreements are Enforcement's
basic input to the SEA.  He identified as a problem area conflicts in
timing between SEA enforcement commitments and ZBB.  The Municipal Management
System is expected to resolve conflicts but timing problems preclude
meeting the Headquarters 10/1/80 deadline.

     The Water Division director felt SEAs were being taken seriously by
the States.  208 work plans will be included in all SEAs.  The SEA is
specifically being used to target problem areas in Region X identified
by the DAA for Drinking Water.  In FY '81 there will be an increased emphasis
on groundwater.

Comments on FY '81 Experience (Review Team)

     The SEA process in Region X appears to be on track.  The Regional
staff and the States accept the SEA concept.  The SEA has been an
integrating tool at the Regional level.  Strong support by senior
management has been a significant factor in the success of the SEA
process in Region X.