_   |       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C. 20460
                                                          OFFICE OF THE
                                                          ADMINISTRATOR
  TO:   All Water Quality Officials
       The enactment of the Federal Water Pollution Control
  Act Amendments of 1972 has imposed on the Environmental
  Protection Agency, on the States, and on local communities
  many and important responsibilities.  These requirements
  provide the opportunity to clean up the waters of the
  United States using various resources, both financial and
  administrative.  The application and timing of these
  resources have been developed into the enclosed water
  strategy.  This strategy is to provide EPA and the States
  with a presentation of national objectives and relative
  areas of emphasis.

       The document is part of a management system conceived
  to implement the water legislation.  It should guide EPA
  Headquarters, EPA Regional Offices, and the States in
  setting annual objectives, allocating resources in support
  of these objectives, and regularly reporting on their
  achievement.  It is meant to ensure that the many activities
  conducted under the 1972 Amendments, by conforming to a
  cohesive strategy, will complement each other.  As a public
  statement of EPA's intentions for a decade of water pollution
  control,  it will also serve as a means of encouraging public
  comment and public participation.  It will be revised an-
  nually to reflect the changing circumstances of the national
  abatement program.

       The strategy focuses on areas of Federal-State program
  activity and does not encompass all activities (such as
  research)  to be performed under the Act.  Efforts have
  been initiated to extend the strategy to cover these areas

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with an anticipated completion in several months.   However,
it is important at this time that we disseminate the
present strategy so that Federal and State officials can
begin implementing many of the operational aspects of the
program.

     I wish to emphasize the important role which it is
envisaged that States will play in carrying out the legis-
lation.  This role is wholly appropriate, not only because
of the magnitude of the pollution control efforts we must
undertake, but also we must recognize the special and localized
nature of many water pollution problems.  Within the limits
of our resources, the Environmental Protection Agency will
assist the States in developing their programs to carry out
this water strategy.

                                   Sincerely yours,
                                   William D.  Ruckelshaus
                                        Administrator

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                                               April 30, 1973


                           PREFACE
     This April 30, 1973 edition of the Water Strategy has been
prepared for use and review by Federal, State, and local government
officials and for the information of the public.   Several changes
to the previous February 27 edition have been made.  Pages on which
changes were made are indicated by a date and the changes are
indicated in italics.  This edition has also been expanded to include
a memorandum from the Acting Administrator enunciating his views on
the Strategy, and to incorporate the Administrator's Decision Memo-
randum on permit processing priorities.

     On the use of the Strategy, it is emphasized that the Strategy,
while based on the law, is not the law, nor is it a regulation man-
dated by the law.  It is guidance prepared for use by Government
agencies in implementing the Act.

     The Strategy should be viewed as a dynamic document, and it is
intended that it be responsive to situations and conditions that
develop as the Act is implemented.  This edition of the Strategy has
not incorporated several areas of suggested changes, but it is expected
that these changes and any modifications that are subsequently required
will be incorporated in a revised Water Strategy document that will be
completed this summer.  However, it is intended that while introducing
these revisions, the basic philosophy and framework of the Strategy will be
be continued.  This revised document will also extend the scope of the
Strategy into other areas of the Act.

     Comments on the Strategy are welcomed.  They should be addressed
to:

        Water Program Planning and Accomplishment Branch
        Environmental Protection Agency
        Room E-813, Waterside Mall
        401 M Street, S.W.
        Washington, D.C. 20460

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       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                        WASHINGTON, D.C.  20460
                                                                 OFFICE OF THE
                                                                 ADMINISTRATOR
MEMO TO:
FROM:

SUBJECT:
Assistant Administrators
Regional  Administrators
Deputy Assistant Administrators
Office Directors
Robert W. Fri
Water Program Policy Issues
     The Water Strategy Paper has been an extraordinary tool in
determining how to implement the unusually complex provision of
PL 92-500.  It has been a vehicle for resolving the sometimes
conflicting points of view-within both the law and our own Agency--
between the planners and the permitters.  It has been an experiment,
perhaps the first of its kind, in explaining publically before the
fact how an agency will implement a new program.

     The Water Strategy Paper does not, however, appear to state
without ambiguity the policy forged from this debate.  Some questions
have been raised both in my regional visits and in recent hearings
in the Senate.  To resolve these questions is the purpose of this
memorandum.
Priorities for Issuing Permits

     There has been some confusion over our priorities for issuing
permits.  The Administrator's Decision Statement of January 30,
'973> governs our policy on this subject.  In cases of conflict,
this ADS wins.
Water Quality Standards vs. Best Practicable Technology

     There are, to me, remarkably deep and unproductive disputes
between Water Quality Standards and Best Practicable Technology as
a basis for issuing permits.  The law is quite clear on this issue:

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     1.  All  permits must issue by December 31,  197^,  or
         applicants will  be in violation of the  law.

     2.  Permits will be  issued on a BPT basis,  or,  if
         more stringent controls are needed to protect water
         quality, on a WQS basis.

     3.  By incorporating the BPT philosophy,  the law  sub-
         stantially reduced our reliance on WQS  as  a basis
         for  setting effluent limitations.

     The thrust of these  points is, first,  that  many—even  most--
permits will  be based on  BPT; WQS will  just not  be  an  issue in
these cases.   Second, even if WQS should be the  basis  for a permit,
the permit will issue on  a BPT basis anyway if the  water quality
analysis cannot be completed in time to meet the December 31,  197^
deadline.  To do otherwise would put a  permittee in violation  of
the law because of our inability to complete our analyses.

     Thus, it  is the policy of the Agency to issue  permits  by
December 31,  197^, and to issue BPT-based permits in  lieu of WQS-
based permits  if necessary to meet that deadline.

     However,  it is also  our policy to  write permits  right  the
fi rst time.  It would not be responsible to issue a BPT-based  permit
in  lieu of a  WQS-based permit without even  trying to develop
effluent limitations to protect water quality.  So  we  should,  and
wi11, try.

     The problem, then, is not a philosophical one,  but a pragmatic
one.   It is how to order  our work to maximize the opportunity  to do
the job right the first time.

     Thus, our priorities, reflected in the ADS  and the Water
Strategy,  is  to work first on permits where we already have WQS-
based load allocations or where we know we  will  write  BPT-based
permits.  This gives us some time to develop load allocations  on
the water quality standards-limited segments where  more work is
required.  I  believe we have enough work in the pipeline to give
us breathing  room to complete load allocations where we need them.

     But, the  load allocation game will be  over by  mid-CY 197^-  If
a permit cannot be written by December  31,  197^, with  water quality
standards-based allocations  (where that is  required),  it will  be

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written on a best practicable technology basis.   If we reach the
question of getting a polluter on an abatement schedule in CY 197^
versus developing a load allocation, the schedule wins.

     In short, we have arranged the system to provide time to develop
load allocations where we need them.  But we run out of time for this
function by mid-197^~~and perhaps sooner if the pace of issuing permits
would be delayed by waiting for load allocations.  In these cases, we
will meet the deadline by issuing BPT-based permits in lieu of WQS-
based permits.
Content of 303(e) Plans

     The main purpose of the water quality analysis in the 30*3 (e)
plans between now and December 31, 197^>  is to help us develop the
load allocations, if needed, to write permits to achieve water
quality the first time.

     The primary issue these plans must address, therefore,  is the
load allocation question.   And the plans  must produce load alloca-
tions, if they are to be useful, soon enough to not delay the
issuance of permits.

     In this context, the content of initial 303(e) plans is reasonably
clear.

     1.  The plan must contain a list of  dischargers, target
         attainment dates, and target load allocations.   In
         fact, that is all it need contain in order to write
         permi ts.

     2.  The method of deriving load allocations need only
         meet the test being defensible in a public hearing.
         Elaborate methodology is not needed, and is even
         undesirable in the interest of time.  It's the result,
         not the method, that counts.

     3-  Documentation is  useful to the extent needed to meet
         the test of reasonableness in a  public hearing.  More
         than that is counterproductive.

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     4.  Once a reasonable load allocation is produced,  call
         it a 303(e) plan and stop.   This means that if  we
         already have a load allocation (say, from the PBAP
         exercise), or if one is worked out through enforcement
         means (as in the Houston Ship Channel),  further
         planning is not required.   (There are other parts to
         a 303(e) plan, like non-point source control.  They
         should not stand in the way of the primary purpose
         and, for plans submitted in CY 1973 or CY 1974, can
         be included only nominally.)

     5-  The "management plans" should be regarded simply as
         discharge inventories on a  basin that systematically
         ensure each discharger is  permitted and  that tie
         together certain other program priorities in a  con-
         sistent way.

     After December 31, 197^, further elaboration of basin plans
may be needed—to determine non-point source controls, for example.
But before that date, the purpose of planning is  to produce per-
mits, ones that are likely to protect water quality with adequate
margins of safety for lack of knowledge.  You will note  the schedule
for plan development in the Water Strategy is consistent with this
goal .
Priorities for Planning and Priorities for Action

     The 303(e) planning process (as opposed to the 303(e)  plans)
produces two sets of priorities.  One is a set of priorities for
doing 303(e) basin plans.  The other is a set of priorities that
guide our action programs for issuing grants and permits.   The
annual action programs themselves are documented in our internal
annual planning system and, for States, through the 106 program.

     There has been some confusion over these two sets of  priorities.

     The action priorities derive from the State's problem assessment
and the Administrator's January 30 Decision Statement.  Thus, we would
expect to see early action in basins (or for classes of dischargers)
where the pollution control problems are most severe and where, in the
case of permits, we have some basis for issuing permits.  Basins requiring
load allocations may be deferred until the load allocation can be calcu-
lated, consistent with the policy discussed above.

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     Planning priorities, on the other hand,  depend on where planning
is needed.  Early planning effort needs to be placed where we need,
but don't have, load allocations.  Thus, it is entirely possible that
planning priorities and action priorities will be different.  Since
action programs and 303(e) basin planning programs are distinct, if
complementary, functions, these differences are only natural.


Revisions to Water Quality Standards

     The Water Quality Standards revision we  undertook has limited
object i ves.

     1.   Eliminate inconsistent use designations and criteria
         on opposite shores of interstate waters.

     2.   Upgrade use designations which were  set too low for
         no plausible reason.

     3.   Upgrade criteria that depart from the Green Book
         for no good reason.

     k.   Set water quality standards for intrastate waters.

     In  other words, we want to conclude the  water quality standards
process  begun in 1967, not begin the upgrading process leading to 1983
water quality standards.  We elected to do so because the law provides
us the tools to wrap up the standards more decisively than ever before.

     Some care must be taken in keeping this  revision process limited to
our relatively narrow objective.  Extended delays will only result  in our
inability to write WQS-based permits by December 31> 1974.


Permitting in States Lacking 402 Authority

     Federally-sanctioned permits must issue  by December 31, 1974.
In most  States, this means we must process permits beginning now.  But
many States will lack 402 authority for some  months — some well  into
1974.

     It  is our policy to process and issue permits under our own
authority where required to meet the deadline.  However, it is also
our policy to:

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     1.  Involve the States up to the point of issuance to the
         maximum extent.  In some States that have everything but
         the requisite legal authority, the permit may be comp-
         letely processed by the State as if they had approval of
         their program.  The permit would issue under Federal
         authority, however.

     2.  Extend ourselves to protect the integrity of State pro-
         grams.  We may issue identical Federal and State permits
         or, if possible, joint permits.  Where it would not pro-
         duce unreasonable delays, we might even hold up issuance
         of fully processed permits so the State can get final
         program approval and issue the permits itself.


PBAP/PBAR and the 303(e) Process

     Substantial confusion exists respecting the relation between
Priority Basin Accomplishment Planning and Reporting (PBAP/PBAR) and
the 303(e)  process.  Perhaps it is best sorted out by distinguishing
between the planning and reporting system and the priority basins on
which EPA wants plans and reports.

     The systems are, or will be, identical.  In either case, a plan
should contain:  (1) load allocations to meet water quality standards,
if that is  required; (2) target load reductions, whether derived from
water quality standards or best practicable technology"; (3) a discharger
inventory;  and (k)  a set of target dates both for obtaining abatement
commitments and for achieving target load reductions.  Reports in either
system would assess progress against such a plan.

     In order to ensure we do what is required of us, plans and
reports such as these are required as part of the 303(e)/106 process
for all waters where we have an abatement effort.

     However, certain basins are of priority importance to EPA
because they involve pollution control  problems affecting large
numbers of  people or critical bodies of water.  These basins are
>'!lf derived from best practicable technology,  the target load reduction
 is not preplanned.  It is just the sum of the permit requirements for
 the basin.

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described in the Water Strategy.   Taken together,  they represent
the nat ional priorities that we want to accommodate in a largely
State-run program.

     This assertion of national priorities has two impacts.   First,
it means Regions must work with States to harmonize national  and
State priorities; the 303(e) planning process is the vehicle  for
this.  Second, it means EPA needs plans and reports on these  basins
to assess progress  against our national goals.

     Thus, it follows that:

     1.  Ideally, States would agree with our national priorities
         and prepare 303(e) plans for our priority basins. .  In
         some cases, they may elect to adopt the load reductions
         and target dates we have already established in the  Priority
         Basin Accomplishment Plans (PBAP's); it would save a  lot
         of work if they did.  Their reports of progress on  these
         basins would be forwarded to EPA headquarters through  the
         Priority Basin Accomplishment Reports (PBAR) as a basis
         for our internal assessment of accomplishment of national
         priori t ies.

     2.  Alternatively, if a State does not adopt  a national  priority
         as their own, the Region will prepare a PBAP and submit its
         own reports through PBAR.  This is not a  desirable  solution,
         but is a necessity if we are to monitor progress against
         national priorities.

     In summary, the systems are the same in terms of plan and  report
content.  PBAP/PBAR remains as an expression of national priorities,  and
as a process for reporting progress against those  priorities.   Hopefully,
the States will adopt our priorities and, in so doing, automatically
become responsible  for preparing the Priority Basin plans and  reports.
If not, we will do  it ourselves.

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       UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                       WASHINGTON, D.C. 20460

                        January 30, 1973
                                                            THE ADMINISTRATOR
ADMINISTRATOR'S DECISION STATEMENT NO.  3
SUBJECT: PERMIT PROGRAM AND 303(e) PLANNING
    The purpose of this decision statement is to record certain decisions
made  concerning the Permit Program and the 303(e) Planning Program and
to assign certain tasks necessary to implement those decisions.

I.   Permits

    During the first year of the new water bill, the following will be
EPA's policy  on  the issuance of permits:

    1.   Permits will be issued to dischargers in basins where
    water quality standards will dictate permit conditions  (i.e. ,
    where receiving water quality will require more stringent
    abatement conditions than the best practicable control
    technology  currently available standard)  and where sufficient
    water quality data are available .to indicate  the degree of
    abatement necessary to achieve water quality standards.
    These permits should be written for a term of up to five years
    and should  not be  subject to revocation during the period of
    the  permit, except as provided  in Section 402(b)(l) (C) .  Legal
    action should be initiated where a discharger refuses to accept
    such a permit or fails to comply with the permit conditions.
Dist: ADS Distribution

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                                —2 —

        2.    Permits will be issued to dischargers who are 1) located
        in basins where water quality standards do not govern permit
        conditions, and 2)  such dischargers are within industrial
        categories for which effluent guidelines for best practicable
        control technology  currently available have been promulgated
        prior to the twelve  month statutory deadline.   These permits
        should be written for a term of up to five years and should
        not be subject to revocation during the period of the permit,
        except as provided in Section 402(b)(l)(C) . Legal  action
        should be initiated where a discharger refuses to accept
        such a permit or fails to comply with the permit conditions.

        3.    Permits may be issued if:  1) dischargers are located in
        basins where water quality standards do not govern permit
        conditions, and 2)  such dischargers are within industrial
        categories for which  interim effluent guidance for best
        practicable control technology currently available  has been
        developed and is sufficiently thorough to give a high degree
        of confidence that permits can be written that will not be
        materially inconsistent with effluent guidelines subsequently
        issued.  Permits also may be  issued to dischargers in such
        basins if such dischargers  fall outside of the  defined industrial
        categories for which  EPA is planning to issue  effluent guidelines,
        since individual determinations of best practicable control
        technology currently  available must be made  in such cases.
        Guidance will be furnished to the regions on  which industrial
        categories fall within these classifications.   These permits
        should be written for a term of up to five years and should not
        be subject to revocation during the period of  the permit, except
        as provided in Section 402(b)(l)(C) .  Such permits once  issued
        will be enforceable and will remain in effect  without change
        notwithstanding the possibility that effluent guidelines  subsequently
        issued might be more or less  stringent in certain respects.
         Discussion:

         The purpose of these decisions on permit issuance is to get
dischargers started as fast as possible on pollution abatement programs
while at the same time minimizing the possibilities  far establishing
inappropriate requirements or constructing "moving targets" for abatement
requirements.  In situations #1 and #2, EPA will be issuing permits where
formally established standards exist.  In situation #3 permits will be

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                                  -3-

based on guidance in which a high degree of confidence exists, but
contain some risk of being more or less stringent than effluent guide-
lines to be promulgated.

     It  is my belief that during the first year of operation under the
amended Act, the number of permits issued  under this policy will
equal the EPA and State capacity physically to process permits.
Notwithstanding, care must be taken to moderate any risk  entailed
in issuing permits under situation #3, above.  For example:

     1.    Permits should not normally issue to dischargers in
     water quality limited basins where water quality data  do
     not exist to formulate permit conditions. There may be
     cases where permits can issue under these circumstances
     with little  or no risk of having to revise the permit shortly
     after it issues; for example, an exception could  be made
     for a discharger whose primary constituents are not those
     for which the basin is water quality limited.  The planning
     process should be  scheduled to provide local allocations
     for water quality limited basins in time to issue  permits
     (after covering situations tf 1, #2, and #3, above) without
     delaying permit activities unduly.  If delays occur, this
     policy will be reconsidered.

     2.    It will generally be wiser to prefer actions in situations
     #1 and #2 if a permit issued under situation #3 would require
     inordinate  analysis to work out permit  conditions.  Subsequent
     promulgation of effluent guidelines will provide the analytic
     basis necessary in most cases,  and thereby conserve regional
     resources.
II.   Planning

     Full 303(e) water quality plans will be required only for those
basins where water quality standards will dictate permit conditions.
These plans will determine the gross effluent reduction required to
meet water quality standards.  Allocations of reductions to individual
dischargers must be made  as a part of the permit issuing process  at
the outset of operating the program, but the question of whether this
should be done in the permit issuing process  or as part of the 303(e)

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                                  -4-

 process on a permanent basis has not yet been resolved.  In basins-
r-v/heie water quality standards are not governing, only the management
 portions of the  303(e) plans will be required.
 Ill.   Work Assignment

     1.    Effluent Guidelines: By January 24  the Assistant Administrator
     for Air and Water Programs and the Assistant Administrator for
     Enforcement and General Counsel  will submit to the Administrator
     a list of  a) those industries for which we have adequate infor-
     mation to begin full promulgation of effluent guidelines based on
     best practicable control technology currently available,  and b)
     those industries for which we have effluent guidance adequate
     for interim use in  the issuance of  permits.  They shall attempt
     to agree on the list, but shall provide dissenting reports rather
     than miss the deadline  trying to get agreement.

     2.    Basin Classification:  Each  state, with the concurrence of
     the Regional Administrator, shall identify those basins or rivers
     segments  where  1) water quality standards will govern permit
     conditions and adequate data are available, 2)  water quality
     standards will govern permit conditions and adequate  data are
     not available,  and  3) water quality standards will not govern
     permit conditions  and best practicable control technology can
     consequently be used.  This classification should  be  based on
     technical judgment and whatever limited analysis can be done
     in the time available and submitted as part of the continuing
     planning  process  according to the deadline therein  established
     (current expected  deadline February 18) .  Considering the use
     of this'classification in the  permit issuance process described
     above,  a reasonable degree  of conservatism should be used in
     deciding  whether  or not a basin is water quality sta'ndard limited.
     When there is  significant doubt, it should be classified as water
     quality standards limited.  The consequences of a mistake
     classifying a basin as water quality standards limited when it
     is not are less costly both environmentally and  economically
     than the opposite mistake.  However, this  principle should not
     be carried to excess because that will run the risk of imposing
     planning  and monitoring requirements in excess of the available
     resources and of delaying the start of the abatement program.

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                                  -5-

    Each Regional Administrator, in cooperation with the states,  shall
    also estimate the number of major and minor permits which will be
    issued in his region during CY 1973  under the strategy herein set
    forth.  The estimates will show the  number of permits by basin in
    the case of those in water quality standards limited basins and by
    industry in the case of those in technology limited basins.

    As a practical matter it will be difficult to do much  of this required
analysis until the list of industries where we expect to have BPT guidance
is available (after January 24) , we  have  explained our strategy to the
states,  (meeting  is currently scheduled for  January 18) and until we obtain
the lists of the basins or river segments in  the various classification from
the states.  Therefore the Regional Administrator should provide required
basin lists and permit estimates to the Assistant Administrator for Air and
Water Programs one week after the  deadline for receipt of the basin infor-
mation from the states. After appropriate consultation with the Assistant
Administrator for  Enforcement and General Counsel the Assistant Administrator
for Air and Water Programs should submit the  results together with any
recommendation for changes to the  Administrator.
                                 William D. Ruckelshaus
                                      Administrator

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                                                  February 27,  1973
                            WATER STRATEGY
I.      PURPOSE

       The water strategy paper is designed to play an important part
in implementing the 1972 FWPCA Amendments.  As the management system
for that implementation is conceived, the strategy paper will provide
guidance to EPA Headquarters and Regions and to the States.  On its
basis these authorities will set annual objectives, allocate resources
in support of these objectives, and regularly report on their achieve-
ment.  The paper will ensure that regulations issued under the 1972
Amendments, by conforming to a single strategy, are consistent with each
other.  As a public statement of EPA's intentions for a decade of water
pollution control, it will also serve as a means of encouraging public
comment and public participation.  Each year it will be revised to accom-
modate new realities and to refocus the national program in light of
legislative deadlines and the expanding role of the States in pollution
control activities.

       This water strategy paper provides an outline of the Federal-State
partnership for 1973.
II.    INTRODUCTION

       The FWPCA Amendments concentrate on the control of point source
pollution to achieve national water quality.  The principal means of
this control is a universal, base level of effluent limitations derived
from currently available control technology.  This may be supplemented
by a higher level of effluent limitations dictated by water quality
requirements.  The combination of these instruments provides the Admin-
istrator with flexibility in meeting the environmental objectives of the
Law.  By outlining the circumstances under which each level of treatment
is appropriate, this paper develops a strategy for using limited resources
to provide maximum impact on water quality.  The strategy is elaborated
in the following sections:

       III.  The Water Problem

        IV.  Strategic Objectives

         V.  Sequence of Implementation

        VI.  Strategic Guidance and Approach

       VII.  Ma j or Outputs

      VIII.  State Activities

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III.   THE WATER PROBLEM

       This section discusses the current water quality problem in
three distinct sets of waters:  inland surface waters and estuaries,
marine waters, and groundwater.

       (1)  Inland Surface Waters and Estuaries

            Approximately one-third of the stream miles of the United
States are in violation of the water quality standards which are the
index of pollution.  A strategy implemented with limited resources
must isolate those areas where pollution is most severe and significant
concentrations of population would benefit from cleaner water.  Of the
Nation's 267 water basins, 89 fall within this category.  Here EPA
Regional Administrators have reported serious pollution problems, or
water quality assessments indicate major violations of standards (either
in terms of miles of stream affected, or duration and intensity of the
violations).

            Table 1 shows how these basins were selected, starting with
the 62 basins containing EPA priority areas and adding 27 basins with
high pollution problems not attributable to non-point source pollution.
Table 2 shows that these basins contain 65% of the Nation's population
and 60% of the major industrial dischargers.

            Intermittent oil spills in inland waters have grown in
number.  More than 1500 were reported in 1971 on the Great Lakes and
along rivers.  This figure does not include spills of hazardous materials
now covered by legislation.

            Elsewhere, as a result of point source and non-point source
discharges of nutrients, eutrophication has emerged as a major problem
in many of America's lakes, impoundments, estuaries, and slow-moving
streams.

       (2)  Marine Waters

            We know something about the frequency and magnitude of ocean
dumping, ocean oil spills, and discharges from ocean outfalls, but little
about their effects.

            Over 62 million tons of assorted wastes (sewage sludge,
dredge spoil, construction debris, toxic chemicals, etc.) are disposed

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of at sea each year in approximately 130 dumping sites.   Table 3
shows the most recent information concerning their type  and geographical
distribution.

            As of 1971, about 7000 oil spills were reported annually in
marine waters within the limits of the contiguous zone (including the
salt water portions of harbors, rivers, and bays).  The  volume of
these reported spills, which exceeds 5 million gallons,  represents
perhaps 95% of the volume of all oil spills in this area.  NOAA reported
that together with spills on the high seas, this has resulted in the
contamination by 1972 of over 665,000 square miles of the Western
Atlantic.

            Although dredge spoil accounts for 80% of the total by
weight, ocean dumping is more dangerous in the case of industrial waste
(10% by weight) and the smaller categories (10%) of sewage sludge,
construction and demolition debris, solid waste, explosives and chemical
munitions, and radioactive wastes.  While the implications of dumping and
spills for the ambient quality of the oceans are not well understood,
the impact can clearly be severe in terms of the food chain, economic
and recreational losses, and the esthetics of the ocean.

            The FWPCA Amendments, in coniunction with the Marine Protection
Act of 1972, give EPA the authority to regulate or prohibit the discharge
or disposal of pollutants into marine waters.

       (3)  Groundwater

            Groundwater forms the base flow for all inland surface
waters.  It also accounts, in whole or in part, for the  public water
supply of one third of the Nation's 100 largest cities and 95% of its
rural population, and over half the water used for livestock and ir-
rigation.  Once polluted, however, it lacks the self-cleansing
properties of surface water and will remain unfit for use far longer.

            The Nation's groundwater pollution problems  arise mainly
from deep-well and other subsurface disposal of wastes,  percolation,
and from excessive withdrawal of groundwater causing salt water in-
trusion .

            There are significant technical problems associated with
any general monitoring, regulatory, and water quality standards-setting
activities for groundwater.

-------
IV.   NATIONAL STRATEGIC OBJECTIVES

      Water pollution is not uniform throughout the country.   The
major sources of pollution and the level of effluent control  needed
both differ by geographical area.  This non-uniformity, when  set
against a background of budgetary constraints, leads to the following
water strategy:

      - Attack water pollution in the areas where it is most  serious
        and where it results principally from the discharges  of point
        sources and controllable non-point sources.  This will also
        maximize the program's ijnpact on population, as shown in
        Table 2, which correlates population and basin geography.

      - Preserve existing high water quality while sub-standard
        ambient conditions are improved to meet water quality
        standards.

      - Promote the participation of States in implementing the
        Water Law.   They will assume the major responsibility where
        feasible for basin and areawide planning, permitting, enforce-
        ment, grants review, etc.

      - Concentrate on the 1977 water quality goals, but lay  the
        groundwork for the future implementation of the 1983  goals.

      - Issue discharge permits expeditiously, in consonance  with the
        priorities described above.

      - Establish an ongoing Federal/State management process which
        integrates planning and program formulation to set milestones
        and provide reports in terms of these milestones.  In conjunction
        with the establishment of a National Water Quality Surveillance
        System, this will enable us to determine if water quality is
        actually improving toward the 1977 and 1983 goals.

      - Institute procedures which assure the public of effective
        participation in establishing the direction of the water program.
        This will include active consultation during the early stages of
        policy formulation before public announcement.

-------
                                                          April 303 1973
V.    SEQUENCE OF IMPLEMENTATION

      The water strategy is a sequence of timing and of relative
priorities for implementing sections of the Water Law.  Its philosophy
is to provide critical information quickly where it is now lacking and
to institute a strong program immediately where data are available.
Phasing will allow for the development of further water quality data,
final effluent guidelines, and certain new programs (e.g., ocean
dumping, non-point).  The groundwork has already been laid for prompt
action in the following areas:

      - the permitting of selected major dischargers,
      - planning and monitoring in the basins where pollution is
        concentrated,
      - grants for municipal plant construction, and
      - enforcement against violators.

      Table 4 presents the sequence of major inter-related activities
under the water strategy through FY75.

      All basins are to be divided into hydrologically discrete segments.
The States will make a preliminary determination for each segment.  Where
the application of best practicable technology for industries and secondary
treatment for municipal plants will result in meeting 1977 water quality
standards, the segment will be categorized as an effluent guideline seg-
ment.  Where this technological base will be insufficient and where the
standards themselves will dictate the necessary level of effluent reduction,
the segment will be classified as a water quality segment.  Where there is
significant doubt, a segment will be considered as a water quality limited
segment subject to later reclassification as more data are generated.

      Where a segment is effluent guidelines limited, the State will develop
a management-type plan listing the dischargers into that segment and the
schedule of compliance for these dischargers.  It will not be necessary
for a plan to be completed and approved prior to issuance of a permit.
(Phrase deleted)

      This management information will also be developed for water quality
segments.  In addition, the plan for these segments will develop, from
monitoring surveys and data, maximim daily loads for pollutants for that
segment, and establish target effluent reductions for dischargers on that
segment.  Once adequate water quality data are available, plans including
wasteload allocations as well as permit sequencing will be developed.

-------


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                                                         April SO, 1973


                            11
Permit issuance can immediately follow wasteload allocation (without awaiting
completion and approval of the plan) but to the extent feasible should
be preceded by monitoring and/or analysis in areas without adequate data.
Permit issuance should be consistent with any schedules incorporated in
the State Industrial and Municipal Facilities Permit Lists.

      Permits should be issued to all dischargers in all segments prior
to December 31, 1974.  After this date, dischargers without permits are no
longer immune from either governmental or citizen legal actions.

      Ten basins where the non-point problem is acute are selected for
intensive monitoring and demonstration programs on non-point source pol-
lution.  The information and techniques gathered here will be used in
subsequent years for other basins to develop assessments of the extent
and causes of non-point source pollution.

      Construction grants and enforcement activities should be consistent
with the strategy.  Construction grant awards would be concentrated on
historic eligibilities such as treatment plants rather than new eligibilities
such as collection sewers.   This priority focus recognizes the enforce-
able requirements of the Law in contrast to those areas where construction
may be desirable, but is not mandated.  Meeting the provisions of the 1972
Agreement between Canada and the United States on Great Lakes Water Quality
requires a special high priority be given those projects that must be
constructed to achieve the objective of that Agreement.

      Federal enforcement activities will initially be at a constrained
level until permits are issued and permit conditions become effective.
Selected enforcement resources will participate in efforts associated
with the issuance of permits in water quality limited segments.

      Complementary to the activities taken on inland surface waters,
a program for controlling ocean outfalls and dischargers will be
developed.  Within three months the Agency will begin issuing permits
to ocean dumpers, based on criteria research and directed first against
toxic and hazardous discharges.

-------
                                    12
VI.     STRATEGIC GUIDANCE AND APPROACH

       The primary sources of water pollution which the legislation
identifies for control are industrial and municipal discharges,  ocean
dumping, and non-point sources.  The water strategy structures lead
areas of program activity, or modules, as a management approach to
controlling these sources of pollution.

       This section provides strategic guidance and the approach for
each of the six modules--Planning and Monitoring,  Permits,  Municipal
Construction, Enforcement, Non-Point Sources, and Ocean Dumping.

A.  Planning and Monitoring

    1.  Strategic Guidance

        The first objective in planning and monitoring is to assist the
States in the revision of interstate water quality standards and prom-
ulgation of intrastate standards to meet the water use objectives set
forth in the Law.  Current revisions of standards  will follow the policies
in effect prior to the passage of the Act and shall be based on available
information.  Where the State's revision or promulgation is not satisfactory,
EPA will act.  The State/Federal standards should be adopted at the earliest
possible date in order to establish a firm target for 1977.  The revisions
will be adopted in all States by the end of FT 1974.

        Until December 31, 1974, the second objective is to complete
plans under the authority of section 303 for all river segments.   These
plans will be aggregated as basin plans and thereafter reviewed and
revised as such.  For segments on which water quality standards would be
met after the application of best practicable technology and secondary
treatment, 303 plans would:

        - indicate the basis for classifying the segment as effluent
          limited (or water quality limited);

        - contain the abatement schedules or target abatement dates
          of significant dischargers, and

        - provide a management structure for processing grants and
          permits.

For segments in which industry could be required to go beyond best
practicable technology and municipal plants to go beyond secondary
treatment, these plans would, in addition, include for each discharger
of each parameter in violation of standards, a target load reduction
under which water quality standards would be met.   At a future time
estimates of maximum daily loads will be done for all segments.

-------
                                   13
        A third objective in this field is to encourage, under section
201 authority, planning for the cost effectiveness and technical
effectiveness of municipal waste treatment facilities.  In metropolitan
areas this planning can be performed on an areawide scale.  This strategy
provides that a municipal project must conform to the 201 plan for its
area before it can be eligible to receive any further stages of a
construction grant.

        A fourth, and long-term, objective is to complete plans under
section 208 which would coordinate all water pollution control efforts, including
non-point source control, on an areawide basis.  This strategy gives
these plans a delayed priority except where there is a strong local desire
to create such a planning authority. The plan developed under section 208
will generally focus on 1983 goals.

        Water quality monitoring and analysis should be performed wherever
it is necessary to complete these plans and to issue permits.

        A final objective is to create a State program reporting process
which enables EPA to measure in specific quantitative terms progress towards
the objectives set out both in legislation and in State plans.  This infor-
mation will come from State section 106 resource and accomplishment reports
to EPA which include monitoring data to indicate changes in water quality and
to assess the relative amount of pollution from point and non-point sources.
This information, which will be supplemented by other data derived from the
National Water Quality Surveillance System, will be particularly important as
we assess the means of achieving the more stringent water quality goals in
1983 and 1985.

         The three principal kinds  of plans envisaged in  this strategy  -
  those under sections 303,  201 and  208  - differ in their  timing, their
  focus, and their geographical application.  303 plans  are basin-wide
  and consider, by segment,  the effect of discharges on  the condition
  of the receiving water.  They provide  a management schedule  for municipal
  and industrial point sources  (and  ultimately non-point sources) for
  attaining the desired improvement  in water quality.  201 and 208 plans
  have only area-wide application.   Moreover the purpose of 201 plans to
  determine cost-effectiveness makes them source-oriented, in  contrast to
  303 plans.  They provide a reasoned choice from among  alternative sites
  and alternative treatment  technologies for the construction  of municipal
  facilities.  208 plans are more complex than  201 plans,  in the planning
  and in the implementation, and affect  the investment of both public

-------
                                  14
and private resources over a longer period of time.   They are developed
for metropolitan areas with critical water conditions,  where the
pollution from such non-point sources as urban run-off  is a major
factor which must be considered along with point sources discharges,
and where the control of land use may be necessary for  the control of
water pollution.

    2.  Approach

    Water Quality Standards

        Step 1 - Interstate standards and previous intrastate standards
have been submitted.  States should submit to EPA their proposed
standards for intrastate waters not previously covered  by April 18,
1973.  EPA will determine the consistency of all standards with the Law.

        Step 2 - If revisions are required the State will be notified
of the revisions requirements and requested to make  changes.

        Step 3 - If the State revises in a manner acceptable to EPA,
the standards are promulgated.  If the State does not submit acceptable
standards, then EPA will promulgate these itself.  By June 1974 there
will be water quality standards for all navigable waters.

    303 Plans

        Step 1 - States should classify all river segments as either
water quality limited or effluent guidelines limited.  An effluent
guidelines limited segment would meet water quality standards after
the application of best practicable control technology  for industry
and secondary treatment for municipal plants.  All other segments are
water quality limited.  If there is substantial uncertainty on the
classification of a segment, it should be categorized as water quality
limited.  Appendix A provides more detailed criteria for making the
classifications using existing data.

        States should submit this list of classifications as part of
their submittal of the continuing planning process (303(e)).  The
Regional Administrator and the State should review this list to their
mutual satisfaction.

        Step 2 - On water quality limited segments for  which adequate
data are available to make load allocations, these plans should be sub-
mitted no later than June 30, 1973.

-------
                                   15
        Step 3 - On water quality limited segments for which adequate
data are not available to make load allocations,  States should identify
the resources and time schedules for obtaining the necessary data and
completing 303 plans in sufficient time so that the plans can be used as
a basis for issuing permits.  Permits under the law should be issued by
December 31, 1974.  States should submit this resource information annually
as part of their State program report under section 106.  States should
proceed in monitoring and data analysis so data will become available
to make load allocations.  Plans for these segments (and for effluent
guidelines limited segments) should be submitted as soon as they are
completed.

        Step 4 - On effluent guidelines limited segments, State should
begin preparing 303 management plans.

    106 State Program and Reports

        Once the tasks by basin have been defined in the 303 management
plans, the States will formulate under section 106 an annual program
strategy which identifies, by program area:

        - the work to be accomplished during the year,
        - the State resources assigned to target accomplishments, and
        - the manner in which these resources will be applied.

Under the reporting provisions of section 106 the States will report
semi-annually on the achievement of milestones, and annually on the
deployment of resources.   Further guidance on this report is contained
in Appendix B.
     201  Plans

         Step 1  -  Local planning agencies should continue current
 18  CFR plans until Title  II  grant regulations and revised  18 CFR guide-
 lines  are promulgated.

         Step 2  -  EPA will respond to new local initiatives for facility
 plans  under the construction grant program.  For grants purposes,  201
 planning will be  considered  as the first and a necessary step in the
 construction of publicly  owned treatment works.

         Step 3  -  Existing areawide planning agencies can coordinate, as
 an  interim  step to 208 planning, the concurrent development of several
 201 plans.

-------
                                  16
    208 Plans

        Step 1 - Using the guidelines for 208 designation and the
analyses of 303 plans, States will identify areas where section 208
authorities are likely to be established.

        Step 2 - EPA will enter into contractual agreements with
planning agencies to fund plans for the designated areas meeting all
208 requirements.

        Step 3 - In these areas, areawide planning oriented to 1983
goals of legislation should be developed.

        Step 4 - For those areas which are not 208-designated, as part of
its continuing planning process, the State may act as the 208 planning
and implementing agency for non-point source and groundwater control.

B.  Permits

    1.  Strategic Guidance

        The first emphasis for permit issuance is placed on dischargers
into water quality limited segments which have adequate data for 303
plans.  Permits to dischargers in other water quality segments will be
written as technology information and plans are completed.  If data
collection and analysis on water quality segments will not be completed
in sufficient time to meet the December 31, 1974 date for issuing permits,
permits should be issued based on the best technical judgment of ambient
conditions.  Where final guidelines on control technology have not been
promulgated, permits should similarly extrapolate from existing effluent
guidelines.

        Analysis and load allocations need only be done for those param-
eters which will not be at standards level.  Where standards criteria do
not apply, effluent guidelines would be used.  As an example, a significant
discharger in a water quality segment may find that the level of discharge
of three of his pollutants is established by load allocations, while
seven other pollutants are controlled by effluent guidelines.

        The schedules for permit issuance to municipalities should be
consistent with the schedules for construction grants.  Permit issuance
should reflect practical judgments.  Significant dischargers with long
abatement schedules should be targeted first.  Minor dischargers with
little or no abatement requirements should be given a lesser initial
priority.  Permit issuance should be balanced so that the most efficient
use of available resources results in getting the greatest number of
significant dischargers permitted.

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                                                       April 30, 1973


                             17
     In water quality segments where analysis indicates that the
predominant reason for not achieving water quality standards is non-
point source pollution, and point source abatement would not achieve
standards.  Discharge limitations should be based on effluent guidelines
where supplemental non-point source control programs will not be adequate
to achieve standards.

   2.  Approach

   Interim (Prior to issuance of final effluent guidelines)

     Step 1 - Permits would be issued as follows:

              a.  Permits'Will be issued to dischargers in segments
where water quality standards will dictate permit conditions and where
adequate water quality data are available to write water quality
limited permits.

              b.  Permits will not be issued to dischargers in
segments where water quality standards will dictate permit conditions
and where adequate water quality data are not available to write water
quality limited permits.

              a.  Permits may be issued to dischargers who are (1) in
segments where water quality standards do not dictate permit conditions,
and  (2) in industries where adequate interim effluent guidance is available
in the absence of a promulgated  guideline based on best practicable
control technology currently available.

              d.  Permits may be issued to dischargers who are (1) in
segments where water quality standards do not dictate permit conditions,
and  (2) in industries for which effluent guidelines are not planned to be
issued.

     Final (After issuance of final effluent guidelines)

     Step 1 - Permits will be issued on water quality limited segments
as adequate data are developed.  If load allocation data will not be
available by the middle of 1974, then the permit should be written
on the basis of existing effluent guidelines and the best technical
judgment of ambient conditions.

     Step 2 - Permits will be issued to dischargers who are (I) in
segments where water quality standards do not dictate permit conditions,
and  (2) in industries where best practicable control technology currently
available guidelines have been promulgated.

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                                18
        Step 3 - The priority and scheduling of permits shall be in
accordance with the State Municipal and Industrial Permits Lists con-
tained in the annual State program submission.

        Step 4 - All dischargers should be permitted by December 1974.

C.  Municipal Construction

    1.  Strategic Guidance

        The first objective of this module is to manage funding of the
cost of "construction" of eligible "municipal treatment works," as
defined in the Water Law, so that those works will meet the effluent
and ambient requirements set by the Water Law for 1977 and 1983.  The
second objective is to establish the principle that municipal works
should be not only cost-effective, but also ultimately self-sufficient
through the practice of user charges and capital cost recovery.  The
third objective is to operate and maintain efficiently the plants that
are now constructed.

        The establishment of appropriate priorities is critically
important in maximizing the program's impact on water quality.  States
will develop the priorities for construction through a State Municipal
Facilities Grants List, subject to EPA review.

        EPA will coordinate, process, award, and oversee municipal con-
struction grants.  It will also participate in each stage of the construction
of treatment works, with particular emphasis on pre-application and design
conferences and on the consideration of cost-effectiveness and environmental
impact.  A management system will be developed to ensure nationwide uniformity
of construction grant processing and monitoring.  The States, wherever pos-
sible, shall be responsible for the detailed review and certification of
engineering reports, studies, and construction plans and specifications.
EPA will maintain final approval authority for any action required of the
Agency by statute, such as entering into contractual obligations.

        The operation and maintenance program will be used to determine
which plants currently operating are not in compliance with the 1977 standards
and to ascertain what is required to bring them into compliance.  State
records, surveillance and analysis data, and permit applications will be
relied upon to locate the problem areas.  On-site operation and maintenance
visits, as well as training programs for plant operators, will be available
to municipalities to correct deficiencies.  These efforts will focus on
priority basins and on plants where the required degree of improvement can
be achieved without additional major capital investment.  Manpower training
will primarily support the operation and maintenance program.  Regional
training programs should assess training needs, encourage the States to meet
those needs, and move to satisfy deficiencies.

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                                                           April 30, 1973


                              19


    2.  Approach

        Step 1 - Prepare guidelines and regulations governing the approval
of construction grant applications, including such prerequisites as user
charges and capital cost reimbursement.  An outline of these requirements
is included in Appendix C.

        Step 2 - Assist communities and States in adjusting their appli-
cations to these guidelines and regulations.

        Step 3 -Beginning in FY 73, ensure EPA participation particularly
in pre-application and design conferences.  Major assistance will be needed
in successfully integrating industrial pretreatment requirements into the
design plan for the municipal facility.

        Step 4 - Prepare guidelines for EPA Regional Offices which will
ensure that construction grant processing and monitoring is directed on an
essentially uniform basis across the Nation.  The management system developed
in these guidelines will cover a project from pre-application conferences
through the operation and maintenance of the facility.

        Step 5 - Prior to June 30, 1973, issue pending grants in accordance
with current State priority lists.

        Step 6 - By June 30, 1973, the Regional Administrator and State
authorities should modify/develop the State Municipal Grants List which is
part of the annual State program submission according to the following
guidelines which are stated in order of importance:

                 a.  Projects which are required to meet water quality
standards and which must comply with the enforceable provisions of the Law--
i.e., treatment works that provide secondary treatment or any higher level
of treatment dictated by water quality standards.  Included in this category
are ancillary improvements which must be done in conjunction with an award,
such as a cost-effective solution to certified excessive infiltration into
sewers.

                 b.  Projects which are not required to meet water quality
standards but which must comply with the enforceable provisons of the Law--
i.e., treatment works that provide secondary treatment.  This would include
ancillary improvements as described in Step (a) above.

                 c.  Projects that are desirable in terms of water quality
improvement, but against which the enforceable provisions of the Law for
secondary treatment can not be applied--e.g., storm and combined sewers.
These projects will be subject only to the treatment requirements necessary
to meet water quality standards.

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April SO, 1973


                               20
                 d.  Projects which are not discharges--e.g.,  collection
sewers or recycled water supplies.   Collection sewers may be given higher
priority where there is a special problem of groundwater  contamination,
or where they are an integral part of a waste treatment system (which
includes a treatment plant) for a community which previously was  without
such a system.  This ranking of importance does not mean  that  all projects
in class (a) must be funded before initiating projects in class (b),  and
so forth.

D.  Enforcement

    1.  Strategic Guidance

        In FY 73 and FY 74 the enforcement objective is to complete
enforcement proceedings on actions initiated prior to the passage of
the Water Bill.

        In FY 74 and FY 75, as permit conditions and implementation
schedules come into effect, enforcement actions will be taken  against
violators.

        Emphasis will be placed on shared responsibility with  the States
for enforcement.  Where States cannot maintain an adequate enforcement level,
the Federal Government will ensure enforcement.  The Federal role is a
backup role.

    2.  Approach

        Step 1 - In FY 73 and FY 74

                 a.  Complete enforcement proceedings initiated before
the enactment of the new law and which are retained by the savings provision.

                 b.  Initiate proceedings against dischargers  who fail to
apply for a NPDES permit.

                 c.  Continue to support proceedings and initiate new
proceedings where appropriate under either the Refuse Act or Section 311,
to control oil and hazardous material spills.

        Step 2 - During FY 73 and FY 74 surveillance personnel will support
the development of monitoring data necessary for the preparation  of permits
in those basin segments where permit conditions will be established by water
quality requirements rather than by effluent standards.

        Step 3 - In FY 75, as permit conditions and implementation schedules
come into effect, enforcement activities will emphasize:

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                                                            April 30, 1973


                                  21
                 a.  Identification of violations of discharge conditions
or schedules of compliance; and initiation of proceedings to correct and/or
penalize these violations.

                 b.  Conduct of a statistically significant review of dis-
charger monitoring reports.

                 c.  Selected audit, through effluent sampling, of dis-
charger monitoring reports.

E.  Non-Point Sources

    1.  Strategic Guidance

        Non-point source  (NFS) activities will not be oriented at
first towards aggressive control and enforcement.  Knowledge on the
formation, extent, and effects of NPS pollution is limited.  More
important, the pervasive dispersed nature of NPS pollution does not
lend itself to the conventional application of control technology such
as waste water treatment plants.  Therefore, this strategy aims at the
eventual control of NPS pollution through local combinations of treatment,
preventive management techniques (appropriate applications of contour
farming, construction site terracing, and clearcutting in forests, etc.),
and, as a framework, legislative initiatives to promote proper land use
and NPS prevention (such as EPA's model sedimentation law).

        Over the next two years, to correct for the informational
deficiencies surrounding NPS pollution, each State through its 303(e)
planning process and 106 reports will:

        - develop a profile of its particular NPS problems, and
        - prepare an assessment of what it feels to be the most effective
          mix of available prevention and control techniques for its
          particular set of NPS problems.

        In the same period EPA will be primarily responsible for research
on the generation and effects (by type) of NPS pollutants, and for the
development and assessment of additional prevention and control techniques
and strategies.

        The coordination of these State and Federal efforts should
allow for the establishment within three years of local and State NPS
pollution control programs focused on the achievement of 1983 ambient
goals.

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                                   22
        Where eutrophication is a special  problem--in  lakes,  slow-moving
rivers and estuaries,  and impounded waters--this  strategy calls for  State-
directed monitoring and analysis, to  be the  basis for  State eutrophication
control programs within the 303 planning process.  These will cover  the
initial efforts of the lake restoration program authorized by section  314.


         The Federal Government does  not have  explicit authority  to  control
 groundwater pollution under the FWPCA Amendments.  However,  the  Law does
 provide the States with the authority to  develop a groundwater regulatory
 program under section 208, and requires them  (section 402(b)) to have the
 authority to control subsurface disposal  as a condition for  State assumption
 of the Permit Program.

         This Strategy envisages the  active  use of the States' authority to
 begin a program of State control and enforcement.  EPA will  conduct research
 specifically to support a well disposal control  program, but more generally
 also to investigate the formation and effects of groundwater pollution, and
 the possibility of its consideration as a form of non-point  source  pollution.
 An expanded mandate may come in the  groundwater  area,  through new legislation
 or the interpretation of existing law, as the extent  and severity of  ground-
 water pollution become known.

     2.  Approach

     General NPS

         Step 1 - Many States presently have some form of NPS control  and
 enforcement.  These programs should  continue, and States be  encouraged to
 adopt the model sedimentation law.

         Step 2 - EPA will publish information by October 1973 on processes
 and procedures of control and on the identification of NPS pollution.

         Step 3 - States should develop a  program for  the accurate character-
 ization of their NPS problem as part of their 303(e)  planning process.

         Step 4 - EPA, as part of the 303(e) planning  process, will  begin
 intensive monitoring and selective demonstration programs in ten of the
 most severely NPS-polluted basins in the  country.  The techniques developed
 here will be used in other basins to assess and  ameliorate their NPS  pol-
 lution problems.

         Step 5 - EPA will establish  an information and action liaison with
 the other Federal agencies involved  in the NPS problem--DOT, HUD, USDA, DOI.
 This will draw attention to the water quality implications of their super-
 vision of public lands and their programs for private development.

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                                  23
       Step 6 - For the FY 1974 State program submittal, each State
should indicate those waters where NFS pollution will make the attain-
ment of water quality standards difficult, outline the major sources
of NFS pollution, and identify the range of available institutional
management actions for the prevention of NFS pollution.

       Step 7 - For the FY 1975 State Program submittal, each State
should include a program for the initiation, in that year, of the NFS
institutional controls identified in FY 1974.  Also, by FY 1975, localities
which have approved areawide waste treatment management authorities under
section 208 should make provision for NFS control measures in their
planning process.

       Step 8 - For the FY 1976 State program submittal, each State
should include:

                a.  As part of the initial submittal, a quantitative
analysis of the various types of NFS pollution in their State, the relative
contributions from each, the geographical distribution of the sources
and their areas of major effect.

                b.  As part of the final submittal, plans for the FY 1976
implementation of an NFS prevention, control and enforcement program in
identified areas.  A statewide NFS program may be effected by the extension
of the NFS portions of the 208 planning process to the entire State as
provided in section 208.

   Lake Eutrophication

       Step 1 - In their initial survey of navigable water conditions under
the 303 planning process, States will also determine which of their lakes,
rivers, impoundments and estuaries are eutrophic.

       Step 2 - Where a body of water is found to be eutrophic,  water
quality analysis will be performed to establish the relative contributions
of point and non-point sources.  In this analysis, the Federal Government
will assist the States directly by providing technical assistance and sup-
plementary data derived from the National Eutrophication Survey.

       Step 3 - Where the primary reason for lake eutrophication is the
discharge from point sources, limitations based upon effluent guidelines
or a higher degree of treatment necessary to decelerate eutrophication
may be imposed.

       Step 4 - Where the primary reason for eutrophication is pollu-
tion from non-point sources,

                a.  limitations based upon effluent guidelines will
be imposed on point source discharges.

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                                  24
                 b.  States shall develop nutrient control strategies,
(using EPA's 304(e) NFS information and guidelines for cost-effectiveness)
to be implemented with other NPS programs no later than FY 76.

    Groundwater

        Step 1 - States in which there is well disposal of waste will
provide for its control in the plans developed by the 303 planning
process.

        Step 2 - EPA will develop a national policy on subsurface waste
disposal and will encourage the adoption for Federal, State,  and local
implementation of the Council of State Governments'  model law on toxic
waste disposal and other model legislation.

        Step 3 - EPA will conduct research on the formation and effects
of groundwater pollution; on concepts and techniques for groundwater
monitoring; and on criteria for the selection of well disposal sites,
aquifer withdrawal, and aquifer recharge.

        Step 4 - At a future time States will expand their control
program to encompass other sources of groundwater contamination.

F.  Ocean Dumping

    1.  Strategic Guidance

        Because of resource constraints the ocean dumping strategy
concentrates on those pollutants which are toxic, bioaccumulative, and/or
disease-bearing.  Major substances that are known to be detrimental to
marine life will receive first priority in the issuance of ocean dumping
permits.   Appropriate process and effects research will be conducted
to understand the consequences of other pollutants dumped.  Ocean dumping
permits will remain solely a matter of Federal jurisdiction.

    2.  Approach

        Step 1 - EPA develops guidelines for the issuance of permits,
with the first ocean discharge criteria to be available April 18, 1973.

        Step 2 - EPA develops an ocean dumping permit program.

                 a.  Prior to April 18, 1973, assemble the personnel
and develop procedures for permit issuance.

                 b.  Issue permits to ocean dumpers, with a goal of
1,000 permits issued by June 30, 1974.

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                                  25
VII.  MAJOR OUTPUTS

      Table 5 is an estimate of the accomplishments in terms of
plans, permits, construction grant obligations, and enforcement
actions, which could result from the implementation strategy for
the Water Law.

      Plans

      Within two years there will be a State 303 plan, or at a minimum
the necessary water quality analysis, to govern the management and dis-
charger control process for each of the 267 basins in the country.  The
plans are divided into management plans for segments where effluent
guidelines will control dischargers, and waste load allocation plans for
segments where water quality standards will govern.  Of the 267 basins,
it is estimated that there are 178 basins where there are relatively few
water quality limited segments.  More complex and detailed plans will be
developed for the smaller number of basins (89) where load allocations must
be made to meet water quality standards.  Both sets of plans will be pre-
pared by States.  Existing data are believed to be sufficient for 30 basins
where water quality is the major limiting factor.  It is expected that plans
for these areas can be ready by the end of FY 73.  In addition, 45 manage-
ment plans could be completed.  By the end of FT 74 more than 3/4 of the
basin plans will have been prepared, with the balance to be completed six
months into FY 75.  Local-level 201 plans are designed to provide cost-
effectiveness data to assess topical environmental conditions, to guide
facility planning.  Section 208 plans of broader scope will be developed
for a limited number of metropolitan areas with critical water quality
problems after FY 75.

      Permits

      Permit figures for both industrial and municipal dischargers show
an initial concentration of agency efforts in water quality limited seg-
ments with adequate data.  Initial permit issuance will focus on industry
and agriculture, where a considerable number of applications exist.  There
are no permit applications presently on file from municipalities.  These
have until April 1973 to file their applications, which substantively
postpones permit issuance for municipal treatment works until FY 74.

      Grants

      EPA has been directed to allot $5 billion over the course of FY 73-74.
A strategy of meeting water quality goals by 1977 dictates that the entire
amount be obligated.  The time delay involved in initial construction grants

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                                  26
review and projects conforming to the new prerequisite conditions accounts
for the bulge in FY 74 obligations as compared to the figures for the pre-
ceding years.

      Ocean Dumping

      EPA will begin issuing ocean dumping permits at the rate of 1,000 per
year in late FY 73.  Although this is the estimated total number of major
dischargers, no drop-off in the number of permits in FY 75 is anticipated
because of the possibility of new dumpers, revised discharge criteria, and
the irregular nature of many disposals.  In FY 74 a national contingency
team will be formed as well, equipped to respond to any major oil or hazardous
material spill in the country and serving as a model for possible future
State or additional Federal teams.

      Support Outputs

      Many important Federal activities do not appear in Table 5 because
their role is essentially supportive.  They are still essential to the
success of the primary outputs and are therefore tailored to this strategy.
By the end of 1973 final effluent guidelines for 27 major industries will
have been promulgated for use by State and Federal permit authorities,
defining best practicable technology, best available technology, and new
source performance standards.  In addition an effort will be well advanced
to provide guidelines for at least 7 more major industries in early 1974.
A standard of secondary treatment for municipal treatment works is scheduled
for publication in February.  Other regulations on pretreatment, user charges,
capital cost recovery, and cost effective planning are being developed to
support grants and permits to municipalities.  A major research effort into
fresh and salt water quality criteria will result in a more complete and
up-to-date set of water quality standards, singling out toxic and hazardous
substances for special attention.  Criteria and information are also being
developed to support a non-point source identification and control program.

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                                                                       27
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                                  29
VIII.  STATE ACTIVITIES

       The water strategy emphasizes, where possible, State partici-
pation in and responsibility for the implementation of the Water Law.
Hence the following section, which is a matrix of the activities to
be performed by the States, or encouraged, in each of the program
areas.  This material is elaborated in Appendix D.  Where it is feasible
the Federal role will be restricted to issuing guidance, providing financial
and technical assistance, and reviewing accomplishments.

A.  Planning and Monitoring

    States have the primary responsibility for the 303 process.  They
classify segments as either water quality limited or effluent guidelines
limited.  On water quality segments, they complete load allocations and
303 plans, performing monitoring and analysis where required.  On effluent
guidelines limited segments, they complete 303 management plans.

    The Federal role is to provide guidance and technical assistance
to the planning process and to review the plans when completed.

    States also formulate an annual report program which describes the
interim milestones to be achieved during the year (based upon past
progress and the ultimate goals of their 303 plans), the State resources
to be assigned in meeting those goals, and the manner of assignment.

    The States have the primary responsibility for reviewing local 208
plans.  Their responsibility is to ensure adequacy,  completeness, and
compatibility with the overall process of implementing the Water Law.

B.  Permits

    As much as possible of the permit program will be transferred to
State authorities.  When this transfer does not occur, the basis for
many of the permits issued will be agreement with the States, supported
by analyses performed under the 303 planning process as such become
available.

C.  Municipal Programs

    Each State has responsibility for developing its construction
grants priority list.  This list will reflect the use of criteria for
ranking projects as set forth by EPA.  All awards of Federal money allotted
to States by the needs formula will be based upon this list.

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April 30 s 1973


                               30
    States will increase their role in reviewing plans and specifications
for treatment works.  Prime responsibility for seeing that treatment plants
operate correctly shall also be the States'.

    The Federal role will be to develop criteria for the construction
grants priority list, to provide funds at the applicable rate for approved
projects, and to participate in the stages of construction with an emphasis
on pre-application and design conferences, cost effectiveness determination,
and environmental impact.

D.  Enforcement

    Emphasis will be placed on shared responsibility with the States for
enforcement.  Where States cannot maintain an adequate enforcement level,
the Federal Government will ensure enforcement.  The Federal role is a
backup role.

E.  Non-Point Sources

    Non-point source pollution control is basically a State problem.
States will therefore be responsible for the planning and implementation
of all problem identification activities and for the development of
appropriate control strategies.  States should consider the special
relation of NFS pollution to lake eutrophication.  In those areas where
deep-well disposal is practiced, States should also develop disposal
control programs.

    EPA's support of the States will consist primarily of technical
assistance and supplementary monitoring.  However,  Federal agencies will
take direct action regarding NPS problem identification and control on
Federal lands.

F.  Ocean Dumping

    The Ocean Dumping program is primarily a Federal program.

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                            A-l

                        APPENDIX A
                                               .§/
            Criteria for Water Segment Classes
     As part of the section 303(e) planning process, the
Governor of each State shall submit a classification of
segments to the Regional Administrator.

     The term "segment" means a portion of a basin the
surface waters of which have common hydrologic characteristics
(or flow regulation patterns) and common natural physical,
chemical, and biological processes, including reactions to
external stresses.

     Classification shall be based upon measured in-stream
water quality, where known, or where not known, estimated
in-stream water quality in the area of maximum pollutant
concentration.  Each segment shall be classified as follows:

     (1) Water Quality Class:  Any segment where it is
known that water quality does not meet applicable water
quality standards, and which is not expected to meet water
quality standards even after the application of the effluent
limitations required by sections 301(b)(1)(A) and 301(b)(1)(B)
of the Act.

     (2) Effluent Limitation Class:  Any segment where
water quality is meeting and will continue to meet applicable
water quality standards or where there is adequate demon-
stration that water quality will meet applicable water
quality standards after the application of the effluent
limitations required by sections 301(b)(1)(A) and 301(b)(1)(B)
of the Act.

     Any classification shall reflect any necessary allowance
for anticipated economic and demographic growth over at
least a five-year period and an additional allowance reflecting

a/
  Excepted from §§130.2(m)  and 130.11 of section 303(e)
  regulations proposed by EPA.

-------
                           A-2
the degree of precision and validity of the analysis upon
which the classifications are based.  Where the analysis
is less precise or there is uncertainty concerning growth
projections, a greater margin of safety shall be required
for the assignment of any segment to an Effluent Limited
Class.

-------
                              B-l

                            APPENDIX B

                        STATE PROGRAM GUIDANCE
                      FOR STATES AND EPA'S REGIONS
A.  General

    The State Program plans and reports provide:

          a means of developing individual State strategies that

          are consistent with the national strategy.

       -  a mechanism for the timely exchange of funding information

          a systematic method of reviewing and evaluating actual

          and programmed accomplishments to improve water quality.


       To provide the structure noted above, the programming activity

must be viewed not as a single annual submission, but an orderly system

of activity over the year.  The diagram below provides a snapshot of

the system.
          JAN 15
          FEE 15
  (D

APRIL 15
                        Regional Administrator's mid-year summary
                        report (based on mid-year evaluation).
                        State Receives:
                        - national strategy statement (reference)

                        - preliminary funding guidance
                                State submits to Region:

                                - State strategy

-------
                     B-2
  ©
   V
JUNE 30
JULY 30
DEC 31
                         - preliminary estimate of scheduled
                           outputs

                         - preliminary assessment of resource
                           needs

                         - annual lists
                            Regions coordinate with States on
                            proposed activities

                            State submits grant application §
                            program to region

                            - evaluation of current year accomplishments

                            - programmed accomplishments for coming
                              year

                            - final resource allocation

                            Regional Administrator's end-year summary
                            report
                     —    Program Approval by EPA
                      —    Mid-year evaluation (Regional/State)

                            - program status

                            - milestones achieved

A  National Strategy Preparation Period

B  State Strategy Preparation Period

C  State Program Preparation (To include conferences with

   region, public participation, etc.)

D  Regional final review period.

-------
                             B-3
B.   Funding



    Normally, each State will receive preliminary funding guidance



by February 15 and funding guidance by April 15 (subject to



later adjustments resulting from Congressional appropriation process).



Because the FWPCA changed the basis upon which federal program grants



are allocated, preliminary funding guidance will not be available



until a new formula is developed and approved.  The target date



for FY'74 funding guidance is March 30.






C.   State Guidance



    The accomplishments listed in the State summary output form generally



indicate the areas in which the States' major activities should take place



during fiscal 1974.  Most of the high priority outputs reflect areas



in which joint State and EPA responsibilities exist.  The State outputs



in some of these areas, such as grants awards and Section 201 cost-



effectiveness plans, might only be outputs to the  extent that the



applications are reviewed and approved by the States.



     1.  For the initial submission of the State program in mid-April,



         each State will list the accomplishments it anticipates in



         the coming fiscal year.  This forecast will be accompanied by



         an assessment of the water quality problem within the State, an



         outline of projected geographic and programmatic priorities,




         and a tentative statement of resources to be employed based



         upon the best available knowledge of Federal and State program



         funding.  The initial April submission will provide a basis for

-------
                               B-4






         public hearings and for discussions between the State and



         the EPA Regional Administrator on the program.   Reflecting



         these discussions and the final budget figures  from Federal



         and State sources, the State will make its final program



         submission in June.



     2.  A report on the outputs of the previous fiscal  year will be



         required as part of the final State program submission.




     3.  A report on outputs will also be required each  January,  for



         the Regional Administrator,  on the accomplishments of the




         first six months of the current fiscal year, together with a



         discussion of program status.



     A list of permit and grant recipients should accompany all submis-



sions of the State summary output form, both when it is  used retrospectively



to report on accomplishments (July and January), and when it is used




prospectively to forecast accomplishments (April and July).

-------
B-5


























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-------
                            B-8




D.  Regional Guidance




    10  Tactical Guidance




        The first objective is to conduct a regional review




of the State's program strategy as submitted annually in




response to the annual strategy developed by EPA.




        The second objective is to review and assess State




effectiveness in carrying out program plans, by analyzing




State program reports.




        The third objective is to correlate State accomplishment




of 303(e) plans with the scheduling requirements for the




planning and permitting efforts.




        The fourth objective is to review State lists of




dischargers; municipal needs,  and priority of construction




projects and priority of permits to be issued.




    2.  Task Assignments




         (a) 303/106 State Plans and Programs - These plans




and programs will be formulated at the State level.  Once




program requirements and schedules have been defined by the




303 management plans, the States should incorporate these




plans within the annual strategy and program under Section 106.




Where plans are not available the States should utilize available




information in developing the State strategy.

-------
                       B-9






        - Step 1 - Provide the States with the national




          strategy developed by EPA.




        - Step 2 - Assist the States  in integrating  the




          objectives of the national  strategy into their




          own strategy.




        - Step 3 - Review State strategy submissions.




        - State program strategy submissions will delineate




          the direction and scope of  State activities




          during the forthcoming year and set the basis for




          the annual program grant.





         (b)  State Program - Once the State strategy  has been




developed, the annual program is formulated.  The program




describes the tasks to be done and the schedules to  be




followed in each program module.  (See Appendix     for




guidance in preparing module submittals.)




        - Step 1 - Review State program as submitted.




        - Step 2 - Coordinate State program with regional




          program plans.




        - Step 3 - Allocate resources in consonance  with




          the State program as approved.

-------
                  B-10







(c)  State Program Reports




- Step 1 - Conduct review of State progress based




  upon semi-annual reports.   Milestone accomplish-




  ment will be evaluated semi-annually.  The second




  milestone accomplishment evaluation will be done




  as part of the review of the next year's program.




  Resource expenditures will be reviewed annually.




- Step 2 - Assist States in identifying potential




  or actual problems.




- Step 3 - Assist States and, if necessary, EPA in




  adjusting resource or program priorities to




  overcome problems.

-------
B-ll





















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